ML20072J019
| ML20072J019 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/01/1981 |
| From: | Harbin R METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-04, TASK-06, TASK-3, TASK-4, TASK-6, TASK-GB NUDOCS 8306290875 | |
| Download: ML20072J019 (84) | |
Text
I L
484 UNITED STATES DISTRICT COURT S OUTl!ERN DISTRICT OF NEW YORK
/
- - - - -x GENERAL PUBLIC UTILITIES CORPORATION, s
JERSEY CENTRAL POWER & LIGHT COMPANY, 3
METROPOLITAN EDISON COMPANY and a
/
PENNSYLVANIA ELECTRIC CONPANY, a
Plaintiffs,
-against-80 Civ. 1683 (R.O.)
TIIE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
3 Defendants.
,a
x Continued deposition of RONALD STEPHEN II A RB I N, taken by Defendants, p u rs uan t to
('s b
adjournment, at the offices of Davis Polk
& Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Thursday, October 1,
1981, at 1:15 o' clock in the afternoon, before Robert Capuzelo, a Shorthand Reporter and Notary Public within and for the State of New York.
S.
/
qqB i>
DOYLE REPORTING. INC.
I CERTiriCD STENOTYPC RCPORTERS p
369 LtalNGTON AVENUC WALTCR SH APlHO C.S.R.
Ntw Yonx. N.Y.
1o017 CHARLES SHAPlHO C.S.R.
TELEPHON 212 - 007-c22o 8306290075 811001 PDR ADOCK 05000289 T
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1 485 2
APPe a rance s:
3 xAYE, scHOtER, PIERnAN, HAYS & HANDtER, Esos.
Attorneys for Plaintiffs 4
425 Park Avenue
~
ANDREW MacDONALD, EsQ.,
6 of counsel 7
8 DAVIS POLK & WARDWELL, EsQS.
Attorneys for De fendants 9
One chase Manhattan Plaza New York, New York 10 By:
PATRICIA M.
VAUGHAN, EsQ.,
11 of counsel 12 13 Also Present
}4 BARBARA SCOTT, Paralegal, Davis Polk & Wardwell, Esqs.
15 16 17 18 RON AL D STE P HEN HARB I N,
10 resumed, having been previously duly sworn 20 by the Notary Public, was examined and
)
21 testified further as follows:
22 EXAMINATION DY MRs. VAUGHAN:
23 Q
Mr. Harvin, you remember that you are 24 still under oath from way back when, right?
25 A
Yo8-j
i 1
Harbin 486 2
Q The first thing I would like to ask you, 3
are you still today employed by Met Edison?
4 A
Yes, I am.
{
5 Q
In the same job that you were employed in 6
at the last session of your deposition?
7 A
Yes.
8 Q
Have you worked for anyone other than those 9
individuals that we previously identified before on the 19 organization charts?
Do you remember that?
11 MR. MacDONALD:
You mean directly reporting 12 to somebody?
i 13 MRS. VAUGHAN:
Mr. Colitz, O'Hanlon, 14 Mr. Seelinger, Mr. Miller and Mr. Toole.
15 A
Yes, that is-correct.
16 Q
I am only referring now to your employment 17 with Met Edison.
18 You have not worked for anyone other than 10 those individuals?
20 A
That is correct.
f 21
.Q Is it also true that you have not had 22 employment with anyone other than Met Edison with 23 the exception of'the Navy?
24 A
That's correct, with the exception of summer
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25 employment while I was in college.
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1 Harbin 487
- (]
2 Q
One last preliminary question.
%J 3
Have you had discussions with 4
anyone other than counsel with respect to your
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5 deposition either before the last deposition session 6
or in between that session and this session?
7 A
No.
8 Q
No discussion?
9 A
No, I have not.
10 Q
I have a series of questions, and I can 11 refer to the deposition pages if you want.
If you 12 don't necessarily disagree with anything I say, 13 I don't know if you are going to want to take time to O
14 look at those pages 15 A
What are the deposition pages?
IG Q
The transcript f rom your previous testimony.
17 You testified at pages 216 and 217 of your deposition 18 that it was your general practice to maintain copies 19 of the Current Events-Power Reactors publication.
20 MR. MacDONALD:
Let me inte rj e ct.
f_
21 If we are going to go back over prior 22 deposition testimony or if you are going to refer 23 to it directly rather than having him agree that 24 that cha ra c te ri z ation is necessarily correct,
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.maybe we can just refer to those two pages and
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1 Harbin 488
[V) 2 you can refe r him to that as to the subject 3
matter of which you are talking about and then 4
you can go on and ask whatever you want to.
5 Q
Do you want to take a look'at pages 216 6
and 2177 7
A Yes.
8 (Document handed to the witness.)
9 MR. MacDONALD:
Do you have a specific 10 question and line?
11 Q
You also testified at pages 258 to 260 12 that Nelson Brown asked you to look for information 13 relating to an event at Davies-Besse and you found past fs 14 publications of Current " vents-Poser Reactors when 15 you were looking for that.
16 My question to you is, are there 17 files which contain issues of Current Events-Power 18 Reactors?
19 A
Yes, there are files that contain that document.
20 Q
when you say "that document," do you I
21 mean mo re than one issue of the Current " vents-Power 22 Reactors?
23 A-Yes.
24 Q
How are those files labeled?
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25 A
How is the file folder labeled?
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1 Harbin 489 2
Q That is correct.
3 A
I believe it's labeled "NRC Current Events-Power 4
Reactors."
5 Q
Who maintains those files?
6 A
Ron Toole's secretary.
7 Q
What is her name?
8 A
Pat Schlegel.
9 Q
Have you ever been asked to gather 10 information relating to a transient that occurred 11 at Davis-Besse on September 24, 1977?
12 A
Not that I recall.
13 Q
And your answer would refer to either O
14 before the accident at Three Mile Island or after 15 the accident at Three Mile Island, is that correct?
16 A
Yes, that is correct.
17 Q
If you want to again re fer to your 18 deposition on page 157, you testified I believe that 19 Pat Schlegol, who is Mr. Toole's secretary, 20 keeps a file of some B&W User Group meeting minute.s,
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21 and that Al Stowe keeps the minutes for those meetings 22 that were held prior to 1980 or for those minutes 23 that were written prior to 1980 24 MR. MacDONALD:
What is the question?
25 Q
How are those files labeled?
.m 1
Harbin 490 MR. MacDONALD:
Both Mr. Stowe's and 2
4 Miss Schlegel's?
3 MRS. VAUGHAN:
That is correct.
4 A
The general practice was to label the files 5
6 "B&W Use rs ' Meeting," and then the date of the 7
meeting on the file folder.
8 Q
Does Ms. Schlegel keep some of those files?
A Yes, she does.
9 10 Q
And Mr. Stowe would keep the files prior to 19807 gg 12 A
I can't be sure of the date.
13 Q
When you testified --
i A
I testified to the best of my knowledge files g4 15 prior to 1980.
I was really referring to the date because gg I'm not sure of the date.
17 Q
But it is your understanding that 18 he does have or would maintain files of some previous 19 time?
A Yes, that's right.
20
)
Q On page 164 of your deposition you testified 21 that a filu was kept for some B&W Users' meeting of 22 23 memos that you sent out regarding minutes from those me tings.
21 My qu stion to you is, how would those 25 v
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1 Harbin 491
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2 files be labeled?
3 A
I'm sorry, what files?
4 Q
The files into which any notes or memos, 5
rather, that you wrote regarding B&W Use r Group meeting 6
minutes would be kept.
do you see somewhere 7
'A Did I say somewhere 8
that I said that I wrote memos?
i 9
Q Yes.
10 A
Because I don't recall now ever writing any notes i
11 or letters.
7 12 Q
" Question:
Would a file be kept of any f
13 memos that you sent out regarding B&W Use rs ' Group gg Q
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14
-meetingst 15 Answer:
I don't know that that was the 16 general practice.
I know that there were some 17 meetings that that was that was done."
18 And my question to you is, how would that 19 file be labeled?
20 A
The gene ral practice at the time was for f
21 any correspondence that I may have generated -- a n'd l
22 I don't remember now having generated any -- that that t
l 23 correspondence and any correspondence that would be 24 generated by or to the Unit Superintendent would be m
25 kept in the same file.
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Harbin 492
(
2 Q
In the same file as the meeting minutes?
3 A
That is correct.
4 Q
So that those files, that would also 5
be kept by Ms. Schlegel or Mr. Stowe, depending 6
on the time?
7 A
That was the general practice.
8 Q
At page 178 you testified that copies 9
of Mr. Toole's minutes and anyone else's minutes 10 from Users Group meetings we re maintained.
11 Do you see that testimony?
12 A
Yes, I see what you are referring to.
13 Q
And my question is the same as the previous 14 question, and that is, how were those files labeled?
15 A
The same way, "B&W Users Meeting," and the date 16 of the meeting.
i 17 Q
And they are also maintained by either i
i l
18 Ms. Schlegel or Mr. Stowe?
19 A
Yes, that is correct.
20 Q
In your previous testimony. -- and it
]l 21 appears Apocifically at page 438 -- you testified that 22 you did not maintain copias of the Atomic Energy 23
- Clearing flouse publication.
24 My question to you is, is.that still your 25 testimony today?
I Harbin 493 2
A Yes, on the ones that were returned to me, that 3
is still the case.
4 Q
That you did not maintain them?
5 A
That's correct.
6 Q
Do you have any knowledge about those 7
documents, those copies of the Atomic Energy Clearing 8
!!ouse that were not returned to you?
i 9
A I believe I testified and it's in my testimony i
i 10 that at some point in time that document was returned 11 to Nelson Brown as opposed to being returned to me, 12 and I don't know what he did with it.
13 Q
Do you know if there exists anywhere
(
14 else within Met Edison or GPU a file of Atomic 4
15 Energy Clearing !!ouse publications?
IG A
I don't know whether there is or isn't.
17 Q
You don't have any knowledge of that?
18 '
A That's correct.
19 Q
llave you had any conversations with 20-anyone since our deposition about the Atomic Energy h
21 Clearing flouse publication and whether or not it was 22 kept or maintained?
23 MR. Ma cDO!!ALD :
About the publication or 24 about whether'or not it was --
'25 M its. V A U G!t A N :
Let me make it clear.
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I Harbin 494 I
f) 2 Q
About copies of the Atomic Energy v
3 Clearing House publications and whether those copies 4
were kept or maintained.
5 A
what copics?
6 Q
Copies of the Atomic Energy Clearing 7
House publication.
8 Have you had.any conversations since the 9
last time you'were deposed about the whereabouts'of e
10 any copics of the Atomic Energy Clearing House 11 publications?
12 A
Yes, I have.
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13 Q
With whom have you had those convarsations?
e3 O
e 14 A
Nelson Brown.
4 15 g
what has been the content of those.
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16 conversations?
17 A
As I recall, I was in his office and saw'one of t
18 the documents that was a recent publication.
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19 Q
Of the Atomic Energy Clearing House?
20 A
Yes, that's right.
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21 And I made some comment about the fact
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22 that he was still receiving that publication, and r
23 I don't recall any discussion as to what the disposition 24 was or what he did with them, but there was no 4
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25 discussion at all on any past practices or what was.
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Harbin 49S 2
done with past issues after they had been routed or 3
distributed.
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4 Q
Are *ou awara of the fact that for a period-5 o f time in 1977 nc one at Met Ed or GPU received 6
copies of the Atomic Energy Clearing House?
That 7
is that the publication was not sent to anyone at 8
Met Edison or GPU.
9 A
No,'I have never heard anyone make a statement 10 like that or I.have no knowledge of that.
11 Q
On page 312 of your deposition, you
^
12 testified that you do not know of anybody who has 13 maintained file s,o f '.p'h s t copies o f B &W Operating
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i 14 Plant Service Bulletinn.
15 My question to you is, is that still your7 estimony today?
16 t
17 A
Are you referring to the question on page 312
- i 18 that reads, "Do you know<today if-there arefiles 19 maintained inte which. this copy of the Operating 20 Plant Service Bullet'in can be found"?
4 thinikthere is more if you go down.
)
21 1-Q I
I testified' on -page 311 that I was unsure 22 A[
23 of the t'itle of the' document that we were talking y,
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4 24 about, and I believe now, since I'last testified, h
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f fe' 25 the title is different.
I believe it's the same
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I Harbin 496 2
report at Icast in substance.
As far as the question on the top of page 3
312, my answer to that question and also my 4
testim ny elsewhere in the deposition since the 5
g accident, Jim Seelinger had directed me to implemenet a program of collecting these documents and 7
8 establishing a computer program or a computer -- a computer program for keeping track of incidents at g
10 B&W plants.
At that time I started keeping a file of this document, and I have 'that file now.
gg But the question refers to "this copy,"
12 and depending on what that copy is, I may not have 13 O
\\l that copy, but I have some copics.
y Q
I understand, and that is fine.
15 What I am really getting at is, do you 16 know of anyone who has a file in which are kept back g7 issues of the B&W Operating Plant Service Bulletin?
gg A
Besides myself?
gg Q
Besides yourself, what I understand, 20 it is after the accident.
I would be interested in
)
21 22 -
finding copics that might have been kept that came ut bef re the accident.
23 f
A I don't know of anyone that would have copics 24 p
f those.
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1 Harbin 497
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2 Q
When you say the name is di f fe rent,
3 what is the name of the bulletin now as you understand 4
it?
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i 5
A I don't know what the name is now.
There was 6
an insignificant change from something to the 7
effect of " Operating Plant Service Bulletin" to 8
" Plant Status Report," for example.
9 Q
Was that changed _after the accident?
10 A
Yes, I believe it was, 11 Q
When Mr. Seelinger asked you to set up a 12 system -- is that what you said, to, set up some kind 13 of a mechanism by which you would keep track of O
14 events at B&W plants?
Is that what you testified 15 to?
Am I correct in that?
IG A
Yes.
17 Q
-- did you at that point go back through 18 the publications that Met Ed was receiving to see what 19 kind of information they were getting?
20 A
No, I didn't have any back issues.
At that
)
21 point I started saving them.
4 22 Q
But you didn't do any kind of a search of-23 information that had been obtained in the past or that 1
24 was being received by Met Edison?
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25 A
No, I didn't.
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1 Harbin 498 i
.2 Q.
Have you talked to anyone since the last 3
day of your deposition about keeping any back issues i
4 of the D&W Operating Plant Service Bulletin or whatever
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5 the name of it is now?
I 1
6 A
No, I have not, i
7 Q
Do I understand you that Pat Schlegel is 8'
still the secretary for Mr. Toole and yourself ?
j 9
A Yes, she is.
10 Q
Who was the secretary before Miss Schlegel?-
11 A
There was a temporary secretary for a period of 12 two weeks.
I don't recall her name.
1 13 Q
How about before the temporary s e c re ta ry'?
C:)
14 A
Donna Kent.
15 Q
How.long was Miss Kent the secretary for 16 the Unit 1 Superintendent and yourself?
17 A
Probably six to eight months.
18 Q
Who was the secretary be fore Miss Kent?
19 A
Anna Mac Trcutman.
20 Q
For what period of time was she the secretary?
)
21 A
Approximately a year.
I 22 Q
Who would have been Unit 1 Superintendent.
4 23 while she was the secretary?
24 A
Jim O'Hanlon.
25.
Q Then how about a secretary before her?
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1 Harbin 499 V[ D 2
A I believe it was Debbie Russ.
3 Q
Who was the Unit 1 Superintendent when 4
she was the secretary?
5 A
Joe Colitz.
6 Q
Was there a secretary before Miss Russ 7
but after you started working?
8-Are those the only women who have 9
been secretaries to the Unit 1 Superintendent while 10 you were there at Met Edison?
11 MR. MacDONALD:
Are you talking about 12 full-time secretaries?
13 MRS. VAUGHAN:
Yes.
14 A
Yes, full-time secretaries.
15 Q
Have there been part-time secretaries?
16 A
I believe before Debbie Russ, Bev Hockley was 17 a se c re t a ry that was shared between the Unit 1 and 18 Unit 2 Superintendents.
19 Q
Was that after you started.warking for 20 Met Edison?
4
)
21
-A Before and after.
22 Q
On page 317 of your deposition testimony,.
23 you testified that you maintained a file for 24 Mr. Seelinger which contained notes of his from the
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25 day of the accident, l
1 Harbin 500 2
My question is, is that the only file 3
of Mr. Seelinger's that you did maintain or are 4
now maintaining since he has left?
5 A
Yes, that is the only file.
6 Q
Do you know who maintains, if anyone, 7
any other files of his?
8-A During the period of time that he was Unit 1 9
Superintendent, he used the Unit 1 Superintendent's 10 files, and there is correspondence in the files that 11 are now Mr. Toole's that was written to or by 12 Mr. Seelinger and those are -- those files are being 13 maintained by either Pat Schlegel or by Mr. Stowe.
O 14 Q
How about after Mr. Seelinger left or 15 censod his employment as a Unit 1 Superintendent, 16 would all the files have stayed in the Unit 1 17 Superintendent's office?
18 MR. MacDONALD:
He just testified that 19 some were maintained by Mr. Stowe, unless I 20 heard wrong.
)
21 Q
Is there anyone else?
22 MR. MacDONALD:
You mean aside from that?.
23 MRS. VAUGHAN:
That's right.
21 A
No, I don't know of anyone else.
25 Q
You don't know of anyone else to whom he
I Harbin 501 2
gave files.as he gave you the notes from the day of 3
the accident?
4-A I don't have any knowledge of him giving 5
files to anyone else.
6 Q
Do you have any understanding of what?
~
7 MR. MacDONALD:
If you have a recclicction, 8-A No, no recollection.
9 Q
No knowledge, no. recollection?
10 Have you ever heard anyone say anything 11 about that?
12 A
Not that I recall.
13 Q
Why did he give you his notes from the 14 day of the accident to keep?
15 MR. MacDONALD:
Are you asking if there 1G was a conversation which ensued when he gave 17 them to him?
18 MRS. V A U Gil A N :
Whatever.
Certainly 19 Mr. Seelinger must have said something when 20 he handed it to him or did something or wrot,e h
21 something or whatever.
l 22 MR. MacDONALD:
You can ask him if he did.
23 I don't know whethe r he must have.
^24 A
lie 'didn' t write anything.
25
-Q Did he say anything?.
w.
I Harbin 502 2
A Mr. Seelinger was at TMI at the time of 3
the accident and he was involved in some of the 4
testimony to the various commissions following the 5
accident, and at the time he terminated his employment g
with the company, the files, or the notes that he had 7
taken the morning of the accident he did not feel 8
were notes that would appropriately be a part of the 9
Unit 1 Superintendent's files nor did he feel that 10 it was appropriate to take them with him to Florida 11 which is where he moved to, and so he left them with me.
12 Q
Did he say anything when he gave them to 13 you?
O 14 A
I don't recall specifically what he said, but 15 j
something to the effect of requesting me to hold on IG to them in case any of the information contained in 17 the noto.s we re ever needed.
18 Q
Where were you on the day of the accident 10 at Three Mile Island?
20 MR. Mac DONALD: I think we went over t.his, f
21 MRS. V A U Gil A N :
I don't think it is contained 22 in the deposition.
If you can point it out to 23 me, that is fine, but I have no recollection.
24 A
I was at the observation center part of the day.
25 I was never on site that day.
u
I Harbin 503 2
Q Did you.take any notes from that day?
3 A
Not that I recall.
4 Q
Were you in communication with anyone 5
on site that day?
6 A
Not that I recall.
7 Q
You have previously testified at pages 1
8' 362 and 363 of your deposition that the Unit 9
Superintendent would maintain a file for some 10 of the GORB meetings and that you would file any notes 11 that you took of these meetings in the Superintendent's 12
- file, 13 How is that file labeled?
\\J 14 A
The general practice was to label the file 15
" Meeting GORB," and then the number of the meeting.
16 They were numbered sequentially.
17 Q
Who has kept or is keeping those files?
18-A For some period of time they were kept by the 19 secretary of the Unit 1 Superintendent.
I'm not sure 20 that we are continuing that practice.
)
21 Q
If you are not continuing that practice, 22 do you know where they would be kept now or who would 23 keep them?
24 A
No, I don't know.
rm 25 MRS. V A U G l! Ati Will you please mark this I
i
4 1
Harbin 504 2
document, Mr. Reporter.
3 (Memorandum dated September 14, 1979 from 4
GPU marked B&W Exhibit No. 284 for identification 5
as of this date.)
6 Q
Do you recognize this document?
7 A
Do I recognize it?
8' Q
Does it look familiar to you?
9 You signed it, is that correct?
10 A
That appears to be my signature.
1 11 Q
Do you remember writing this document?
4 12 A
No.
1 13 Q
You have no recollection of writing it?
O 14 A
I recall being involved in setting up interviews 15 for these people, some of the. people listed there.
IG Q
What was the purpose of the inte rviews that 17 you were setting up?
18 A
GPU set up an investigative task force to 19 investigate the TMI accident, and the purpose of the 20 interviews was to conduct the investigation.
)
21 Q
Who was conducting the interviews?
22 MR. MacDONALD:
You are talking about what 23 poopic?
24 MRS. VAUGHAN:
That's right.
25
~ A I don't know who was on the task. force.
I know
1 Harbin 505 f~}
2 Bob Keaton was either in charge of the task force v
3 or coordinated their efforts.
4 Q
Do you know whether the interviews were 5
conducted by GPU or Met Edison employees?
i 6
A I know that Bob Keaton conducted some of the l
7 interviews and he was a GPU employee.
I don't know 8
who else conducted interviews.
9 Q
Do you know whether anyone from outside 10 Met Edison or GPU conducted any interviews?
11 A
No, I don't.
12 Q'
.Do you know whether there we re inte rviews 13 held other than the ones that are scheduled here O
14 with regard to this same task force?
15 A
Yes, I recall that there were.
16 Q
Do you recall when they were conducted?
17 A
Subsequent to these.
18 Q
Do you recall that these were the first 10 interviews conducted by the task force?
20 A
no, I don't.
21 Q
Is that your writing in the margins and 22 down at the bottom?
23 A
No, I don't believe it is.
24 Q
Do you know how the interviews we re 25 conducted?
I Harbin 506
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A What do you mean?
'%./'
3 Q
Were they taped, were they recorded, 4
was there a stenographer present? Any one of 5
those ways, do you know how they were conducted?
6 A
I believe they were tape-recorded.
7 Q
Do you know what happened to the tapes?
8-A No, I don't.
9 Q
You don't know the whereabouts of the tapes 10 now?
11 A
No, I don't.
12 Q
Do you know whether the individuals who 13 were interviewed had an opportunity to listen to the 7-)
twJ 14 tape and correct any of their statements?
15 A
No, I don't.
16 Q
Do you know whether the tapes were 17 subsequently transcribed?
18 A
No, I don't.
19 Q
Do you know who would know that?
20 A
I don't know who would know that, but as 21 coordinator of the task force, I believe that Bob 22 Keaton would know that.
23 g
would Bob Keaton also know where the tapes 24 are now located?
r8
(_.)
25 A
I don't know.
1 Harbin 507 1
2 Q
We re you ever interviewed for this task 3
force?
4 A
No, I wasn't.
5 Q
Did you do anything else other than 6
schedule these interviews with respect to this task 7
force?
8-A I don't recall that I did.
9 Q
Did you have any involvement at all with l
10 the task force, any other involvement with the task 11 force?
12 A
No, I didn't.
13 fs Q
When you reviewed an Atomic Energy Clearing t
14-House publication or a Current Events-Power Reactors 15 publication, did you look for those items which 16 would affecc nuclear sa fe ty ?
17 A
Part of my review was to look for items 18 that might pertain to nuclear safety.
19 Q
How did you determine whether an item 20 involved nuclear safety?
21 A
Could you define what you mean by " nuclear 22 safety"?
23 Q
Why don't you tell me what you understand 24 it to be f rom your previous answer.
h
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25 A
'Something that has to do with the design or
1 Harbin 508
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2 operation or maintenance of a component or system 3
that supports the operation of the reactor itself.
4 Q
That is how you would define " nuclear safety"?
5 A
You asked me the question did I look for things 6
in those two documents that dealt with nuclear sa fety,
7 and in that context, that is the way I define it.
g Q
In what context?
9 A
In the context of reviewing those documents, 10 I would look for things that had to do with the 11 design, operation, maintenance.
12 Q
In 1977 and in early 1978, or throughout 13 1978 -- we 'ron't limit it to early 1978 -- what was
- O 14 your understanding of the significance of an event, 4
15 if you had any, which led to saturation in the reactor 16 coolant system?
17 Mr. MacDONALD:
Let's have a base from 18 which you can ask your question.
We can ask him if he knew that doesn't bear on whethe.r 20 of any events h
or not he understood the significance of an 21 any event that would lead to 22 event 1
23 saturation.
l 24 I am just looking for his un de rs tan ding g
. (,)
25 of the significance of any event which would lead
]
i
)
i
=1 Harbin 509 2
to saturation in the reactor coolant system 3
in 1977 and 1978.
4 A
To the best of my recollection, the TMI-2 5
accident was the first incident that I had ever 6
heard of in which there was saturation in the reactor 7
coolant system in a nuclear plant.
8-Q What was your understanding when you heard 9
of it in 1979 then?
10-MR. MacDONALD:
Understanding as to what?
11 MRS. VAUGHAN:
Saturation in the reactor 12 coolant system.
13 A
I'm not sure what you mean.
14 Q
Did that strike you as something 15 significant, that saturation occurred in the 16 reactor coolant system?
17 A
Yes, it did.
18 Q
Did it strike you as something that.
o 10 should not have happened?
20 A
Not with water in the pressurizer.
)
21-Q' Did it strike you as an abnormal occurrence?
22 A
Yes, very abnormal.
23 Q
Is it one that affects the safety of the 24 plant?
(_/
25 A
I'm not really qualified to make a statement like I
1 Herbin 510 i
' - (/ -
2 that.
s.
3 Q
So you are not qualified to judge whether 4
an event affects the safety of a plant or not?
I'm not willing 5
A There a re a lot more variables 6
to agree that the saturation, strictly saturation in 7
the reactor coolant system has c negative effect on nuclear safety.
9 Q
Saturation in the context of a transient 10 occurring, does that have some consequence with 11 respect to nuclear safety?
12 MR. MacDONALD:
Are we talking about the 13 TMI-2 accidenc or are you asking the witness' f~)
NJ 14 opinion?
15 MRS. VAUGHAN:
I am not asking for his 16 opinion.
17 I am asking for his understanding of the 18 occurrence of the saturation in 1979 at the time 19 of the accident.
I am not talking about the 20 day after the accident.
I am talking about, h
21 at the time of the accident or be fore the 22 accident.
23 MR. MacDONALD:
What is the pending 24 question?
O, -)
\\
25 (Question read by the repo rte r. )
n_._.m
I Harbin 511
(
2 Q
The pending question is whether that 3
would be considered, if there were saturation in the 4
context of a transient, saturation in the reactor 5
coolant system, would you consider that to involve 6
nuclear sa 'ety?
7 MR. MacDONALD:
You are talking about the 8-day before the accident?
You said up until the 9
day of the accident.
10 MRS. VAUGHAN:
At the time of the accident.
11 MR. MacDONALD:
Ask if he has any 12 recollection of that at the time of the accident.
13 MRS. VAUGHAN:
You can go back and start k
14 at the beginning.
15 Q
In 1977 or 1978 what understanding did IG you have with respect to the occurrence of saturation 17 in the reactor coolant system during the course of 18 a transient?
19 MR. MacDONALD:
Granted he gave you that 20 answer.
21 MRS. VAUGHAN:
No, he didn't.
He started 22 and we ended up at Three Mile Island, the date 23 of the accident.
24 MR. MacDONALD:
He told you he didn't have 1
25 any understanding at that point in time that i
i
I Harbin 512
[~))
2 saturation could occur in the reactor coolant 3
system; the first time he heard about it was 4
TMI.
5 MRS. VAUGHAN:
I am asking what he would 6
have understood of the significance of it.
7 Q
If your answer is that you didn't understand
'8' saturation and what that meant in the reactor coolant 9
system until the accident at Three Mile Island, 10 that is one thing.
11 Is that your answer?
12 A
No.
3 Q
What is your answer?
13
\\s I 14 I will repeat it once more.
15 A
Yes, because I really do feel that you have IG asked about three different questions.
17 Q
In 1977 and 1978 what was your understanding 18 of the significance of the occurrence of saturation 19 in the reactor coolant system during a transient?
20 MR. MacDONALD:
I d on' t think there is a 21 foundation for that.
I object.
22
.Q Did you have an understanding?
23 MR. MacDONALD:
Ile told you.
24 A
I had considered the possibility of saturation f
- (
25 in the reactor coolant system not necessarily during P
~
...~,
-m-
I Harbin 513
[
2 1977 and 1978 but be fo re the TMI-2 accident, but it V
3 was my understanding that that could not happen with 4
wate r in ' the p ressurize r.
5 g
was it your understanding if it did 6
occur it was an abnormal event?'
7 A
Any thoughts that I would have had or that 8'
I had about saturation in the reactor coolant system 9
were in the context of that being an abnormal occurrence.
10 Q
Was it your understanding that the 11 occurrence of saturation in the reactor coolant system 12 during the course of a transient affected nuclear 13 safety?
p
!]
14 MR. MacDONALD:
Just that alone?
15 MRS. VAUGHAN:
That alone.
16 Q
In 1977 or
'78, in the course of a 17 transient.
18 A
Or befort then?
19 Q
Yes.
At least as of then, you had an 20 understanding?
k 21 A
I'm sorry, wh t ie *he question?
22 MRS. VAUGII AN :
Could you read it back, 23
- please, i
24
.(Question read by the reporter.)
\\m/
25 A
I don't recall specifically what my definition
1 Harbin 514
(
2 at the time was of nuclear safety, an effect on 3
nuclear safety, but it was my understanding that
'4 those conditions, saturation conditions in the reactor 5
coolant system would imply a detrimental ef fect on the 6
safety of the primary plant.
7 Q
In 1977 and 1978 what was your understanding, if you had any understanding, of the 9
significance of a PORV which failed open?
In other 10 words, a PORV that didn't close properly.
4 11 A
I don't recall that I had any understanding.
12 Q
In 1977 and 1978 you had never heard 13 of a PORV that failed open?
14 MR. MacDONALD:
He already told you 15 that.
1 IG A
I don't recall whether I did or didn't.
17 Q
In 1977 and
'78, within Unit 1,
who was
-18 the person most knowledgeable about PORVs and whether 19 they would fail open or closed?
20 A
I don't know.
21 Q
Who was most knowledgeable in 1977 and 22
'78 within Unit 1 about events which involved a loss 4
23 of feedwater?
24 A
I don't know.
25 Q
Who was most knowledgeable during that
4 1
Harbin 515
[~ /)
2 same period of time, 1977 and 1978, within Unit 1 b
3 about LOCAs, loss of coolant accidents?
4 A
I don't know.
5 Q
Do you know who was most knowledgeable 6
about small-break LoCAs?
7 A
No.
8-Q When you say you don't know, do you mean 9
that you can't remember?
10 A
No, I mean that as I recall I never knew.
11 Q
In 1977 and 1978 what, if any, understanding 12 did you have about the significance of the quench tank 13 line or the rupture disc of a plant blowing?
rJ i
14 A
I don't recall that I had any knowledge of that 15 possibly happening.
16 Q
Are you familiar with the quench tank, i
17 when I use that term?
18 A
Yes, I um now.
19 Q
When did you become familiar with that 20 term?
)
21 A
To the best of my recollection, af ter the TMI-2 22 accident.
23 Q
Arc there main files at Met Ed -- I use 24 those wo rds in quotes, " main files" or main file p
(,,
25
' storing or central filing?
1 Harbin 516 2
You used that term on several 3
occasions in your deposition, and I am trying to 4
figure out what it means or where those main files 5
or central filing, whatever you underst.snd by those l
6 words.
7 A
By the words " main files"?
8-Q Yes.
9 Does that imply anything to do?
10 A
No, not the words, "the main files."
There was 11 a central filing system in Redding fo r-co rr e spondence 12 generated in Rodding which was the home office for 13 the company before the accident.
14 Q
Is there any kind of a central filing i
15 system on the Island or contral filing placa?
IG A
Not to my knowledge.
17 Q
Is there one at Parsippany?
18 A
I don't know.
ID Q
In 1976 when you assumed your i
20 responsibilities as an assistant to the Unit 1 21 Superintendent, did you view your responsibilities 22 as reviewing his mail as administrative?
23 A
Primarliy.
s 24 Q
Do you view your responsibilities in that O(_/
i 25 way today?
1
~
l I
Harbin 517 I
l
()
2 A
To some extent, yes.
3 Q
Does your answer indicate that you have 4
changed your view of your responsibilities since the 5
time you first undertook them in 1976?
-6 A
Yes.
7 Q
How has your view of your responsibilities 8-changed?
9 A
In general, they have become more technical 10 in nature.
11 Q
How have they become more technical in 12' nature?
r-13 A
I'm better qualified technically today than I was V
14 five years ago to review technical documents.
15 Q
How have you become better qualified?
16 A
Do you mean what school have I attended?
I 17 Q
How are you better qualified today than 18 you were five years ago?
19 A
I know the plant better; I know the procedures 20 better; I know more about the operation of the plant.
21 That is three examples.
22 Q
Did the manner in which you reviewed the 4
23 Current'Ovents-Power Reactors publication change in 24 any way after the accident at Three Mile Island?
f' 25 A
Which document?
i
- 1 Harbin 518 r (#'\\
2 Q
Current Events-Power Reactors.
3 A
No, it hasn't.
4 Q
Do you review that publication in the 5
same manner as you did before the accident?
6 A
Yes, I do.
7 Q
Would you take a look at what was marked 8-B&W Exhibit 75.
1 9
Have you ever seen this document before?
10 A
No, I don't believe I have.
11 Q
Then I tak e it you wouldn't know who 12 prepared it.
13 A
No, I don't.
~
%.)
14 Q
Do you recognize the handwriting in the 15 margins?
16 A
No, I don't.
17 Q
Look at page 1,
the second paragraph, 18 about two-thirds of'the way down a sentence begins on 19 the right-hand side, "Recent reinstituted NRC I&E 20 information notices."
h 21 Are you familiar with those information 22 notices?
23 A
Yes.
24 Q
Do you know when they were instituted?
\\_)
25 A
I believe approximately 1978.
I
. ~.
I Harbin 519
(J.
l 2
Q So they would have been instituted 3
before_the accident?
4 A
I believe that they were.
3 5
Q What are NRC I&E information notices?
6 Would you describe them?
7 A
They are descriptions of events or findings at 8-either power reactors or possibly fuel fabrication 9
plants or in other businesses that deal with nuclear 10 material,.that are intended to disseminate 11 information to other licensees about those problems 12 or findings.
13 Q
Is that publication still published today?
I wr 14 A
Yes.
An information notice generally comes 15 out for each event and they are numbered sequentially.
In Q
And they are in addition to the bulletins, l
17 circulars, and notices, or is the information notice 18 the last part of those notices?
l 19 A
That's right, it's the last part.
20 Q
On page 2,
the first full paragraph, the f
)
actually the second line -- " Copies, 21 second sentence 22 although no longer reviewed by the Generation Review 23 Committee (GRC) are reviewed by both applicabic 24 site and corporate staff members."
25 I should note that the copies that are
I Harbin 520 2
being referred to have been called the Commerce 3
Clearing House document.
4 Do you know why the Commerce Clearing 5
House document was no longer reviewed by the Generation 6
Review Committee?
7 A
I never heard of that document.
8-Q If we said that it was the Atomic Energy 9
Clearing House document, do you know that that document 10 was at some point no longer reviewed by the Generation 11 Review Committee?
12 MR. MacDONALD:
Are you assuming it was 13 reviewed at some time?
i.O 14 MRS. VAUGHAN:
That is fine.
15 A
I don't know that it was ever reviewed by the IG GRC.
17 Q
You don't know that it stopped being 18 reviewed by the GRC7 19 A
That is correct.
i 20 Q
Or that the GRC stopped reviewing it?-
21 Do you know whether site and corporate staff 22 members reviewed the Atomic Energy Clearing House 23 document?
24 MR. MacDONALD:
What do you mean by'" site j
25 and corporate staff members"?
I I
-w i--
-w
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+
.,..=,
,~
,ww.,
I Harbin 521
~ /-
2 MRS. VAUGHAU:
As used in this document.
'N_/
3 MR. MacDONALD:
I don't know that that
).~
4 has any meaning to him.
5 MRS. VAUGHAN:
If it doesn't, he can say s
6 that.
I 7
A I testified earlier today that I had discus 31ons 8-recently with Nelson Brown in which he indicated 1
9 to me he was still reviewing the Atomic Energy Clearing 10 House document.
11 I don't know of any other uember of the i
12 site of corporate staff that does that or that doesn't.
1 13 Q
This also says, "The GRC is well informed 7g
.\\
j 14 of any significant events by the time they appear 15 in the Clearing House document."
16 Do you have any knowledge about how the 17 GRC is informed of significant. events that would 18 occur that would be reported in the Clearing House 19 document?
In other words, events at other facilities.
20 MR. MacDONALD:
You mean if it is at all 21 in fo rme d?
22 MRS. VAUGHAN:
Yes.
23 A
If it is informed, I don't know how.
24 Q
_Have you ever had any dealings with the
(~)
(/
25 Generation Review Committee?
i c
~. _ _
- -_,.. ~
l 1
Harbin 522
(~T 2
A Yes, but not in areas that pertain to events
()
3 at other nuclear power plants.
4 Q
In what areas have you had dealings e
5 with them?
6 A
I don't recall.
7 Q
You do recall it hasn't been in areas 8-involving other plants?
9 A
That's right, incidents at other plants.
16 Q
How about incidents involving Three Mile 4
11 Island itself have you had any dealings with the GRC i
12 in that regard?
13 A
No, not that I recall.
O 14 Q
In the third full paragraph, the one 15 beginning, "The General Office Review Board" 16 MR. MacDONALD:
On page 2?
i I7 MRS. VAUGHAN:
Yes, the same page.
i 18 the fourth line there is a sentence Q
19 which begins, " consultants are commonly and 20 consistently utilized both as advisors and members-21 to provide the Board with additional expe rtise in 22 many areas of specialized industry experiences."
23 Do you have knowledge of consultants 24 being used by the General Office Review Board?
l O
25 A
Yes.
I testified to that in a previous i
-l'
)
j 4
is--.
m
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- 1 harbin 523 is o Y f
2 dopo tion.
i 3
Who are those' consultants?
- - l Q
/
4
'A B&W is one.
There,is one, I believe,
,-f, J
5
,..M r. Lowe o f Iickard, Lowo & Garrick which is an attorney
'd or law firm iti-Washington, and another is Mr. Lou 1j' 1
/
'7
,Raddis, and I-believe that he was employed by Carolina i
o l',8,
'Pdwer & Light.
i
)
>9
/
.Those are three examples, and I don't
';t 10 know --
I'.m not stating that they are consultants s
?
t Il now,'but that they have boon.
',, 12 MRS. V A U G II A N :
Why don't we take a break.
13 (Recess taken.)
3
' 14 BY MRS. VAUbilAN:
10) y Q Would you take a look at B&W Exhibit 76, J
16 please.
It is dated 6-3-79 and entitled " Training c
. Departmont Notifications."
17
.c
.)i a
18
.Ha,ve'you ever seen this before?
a
..i 19 A'
No, I haven't.
~ 20 Q
I take it you don't know why it was
,s 21,
- p repa re d?
/
P.c.. ' ' j 22
. A I don't know why.
) 2 23, Q,
'I t was prepared in June of 1979.
/
1 Does that refresh your recollection about l
t,. 12Y f j
z.
1 3 i 7-
~
l f
/
125 anything that wan going on with respect to gathering
.J.
c j
1 l
- \\ _
by* p-
&., r, ",....
.a i
I Harbin 524 e
1
(
2 sources of information that were received by Met Zd?
3 A
No.
4 Q
If you look next to Item B under Roman 5
numeral I, about six or seven lines down it says, 6
" Send directly to the Training Department from the 7
NRC data system."
'8' Are you familiar with that system?
9 A
No, I never heard of NRC data system.
10 Q
Be fore you read it here?
11 A
That's right.
12 Q
At the very bottom of the first page, 13
" Depending on the size of the routing list" and we 14 are talking about the Clearing House document 15 "they are received within two weeks of receipt at the 16 station.
Presently the initial reviewer is W.
R.
Gross."
17 Who is W.
R.
Gross, do you know?
18 A
I believe that is Bill Gross.
19 Q
What was his position in 1979, if you know?
20 A
I don't know what it was.
21 Q
Do you know what he does now?
22 A
He works at the observation center in the 23 Public Relations Department.
24 Q
Do you know how long he has had that job?
Od 25 A
'No, I don't.
(
,--.nr-y---y
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y
,,,,-w~
1 Harbin 525
(
2 Q
Do you know whether he started in that 3
position after the accident at Three Mile Island?
4 A
No, I don't.
5 Q
Do you see on the second page next to 6
Roman numeral II, " Current events of operating 7
reactors," is how Mr. Brown has it.
8-This document was sent to John Peters.
9 Who is John Peters, if you know?
10 A
He was an individual that had responsibility 11 for some of the things that I accepted responsibility 12 for when I was first employed by the company, and he 13 terminated his employment prior to my starting employment 14 with the company.
15 Q
Do I understand then that he is no longer IG cmployed by Met Ed?
17 A
That is correct.
18 Q
Or GPU?
19 A
That is correct.
20 Q
Do you know where he is employed now?
21 A
no, I don't.
22 Q
The statement is made that, "We have not 23 received a copy of that document for about a year."
24 "Wo" meaning the Training Department.
Ak-25 Do you know why they didn't roccive a
~
1 I
Harbin 526 1
()
2 copy of this document for about a year?
l 3
MR. MacDONALD:
I'm not sure vho the "we" 4
refers to.
I wouldn't want Mr. Harbin to
~)
5 verify the "we" in a document he hasn't read or d
doesn't know that it is necessarily coming from 7
Mr. Brown.
There may be something on the last 8'
page that says, " Brown," but I don't think that 9
necessarily means that the signature there, 10 the "we",
is necessarily the Training Department 11 Q
Do you know that tha Training Department 12 didn't receive a copy of current events for (s
13 operating reactors for about a year?
\\]
14 A
no.
l 15 Q
Did Mr. Brown ever mention that to you?
16 A
No, I didn't know they ever received it, or 17 they didn't receive it.
18 Q
When you see " Current events of operating 19 reactors," do you understand that to be something 20 in Current Events-Power Reactors?
21 A
From reading this document, it appears that 22 he implied in writing that to mean Current Events-Power 23 Reactors.
24 Q
Are you familiar with any publication v
25 called " Current Events of Operating Reactors"?
~.. _
m _. _.
I Harbin 527
(
2 A
As I testified earlier in the deposition, 3
I believe that the name of the document, " Current 4
Events-Power Reactors," has changed similar to the 5
way that bsW's Weekly Newsletter has changed, and 6
I don't know the other specific title.
I l
7 Q
Roman numeral VI, there is a reference 8*
made to " Change mods."
9 Does that phrase mean anything to you, 10
" Change mods"?
I l
11 A
Yes, it does.
l 12 Q
What is it?
f-
. 13 A
The' company has a procedure for proposing and O
14 approving a modification to the plant and part of j
15 the procedure consists of a form that requires the 16 necessary app ro vals for the change to be made, 17 and item VI I believe is referring to that document.
18 Q
To which document, the document that you 1
19 have to sign?
1 20 A
That is correct, the document that de s c rib e s-21 what the change is and requires the necessary approvals.
22 Q
llow does it differ from what is referred j
l 23 to in Roman numeral IV and Roman numeral V above, 24 that is, a temporary change notice and a permanent 25 change request?
I Harbin 528 2
A Those are changes to procedures, either
{}
3 temporary or permanent and item VI deals with hardware 4
changes.
That is the basic difference.
5 Q
This document says, "We received copies 6
of the change mod requests if stamped for training 7
as deemed by the Unit Superintendent.
(I believe or 8
it may be the supervisor of Maintenance. )"
9 Do you know whether it is the Unit 10 Superintendent who would stamp the document?
11 MR. MacDONALD:
At what time?
12 MRS. VAUGHAN:
In June of 1979.
13 A
I don't know what it was then.
14 Q
Do you know what it is now?
15 A
No.
IG Q
Did you ever know what it was?
17-A Two or three months ago approximately I knew it 18 was the Unit superintendent.
19 Q
Do you know that it has changed since then?
20 A
I don't know that it has since then.
21 Q
Look at the next page next to Roman numeral 22 VII, " Technical spe cification changes."
There is 23 reference in the fourth line of that paragraphto " Key 24 control copy.'
("h
(_)
25 What is a key control copy, if you know?
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r-
I Harbin 529
/~
(
2 MR. MacDONALD:
Aside from the way Mr.
3 Brown may have referred to it, whether he ever 4
heard of key control copy?
5 MRS. VAUGIIAN:
Absolutely.
6 A
Could you please repeat the question?
7 Q
What is a key control copy, if you know?
8-What is meant by the phrase, " Key control copy"?
9 A
I'm not sure that key control copy as I 10 once knew them exist now, but at one point in time my 11
. understanding was that a key control copy was a 12 copy of the toch specs that was held by an indi"idual 13 or department in which it was deemed necessary fo r g
J 14 them to have a current copy of the tech specs and 15 there were restrictions, procedural restrictions on 16 how soon after a tech spec change had been approved 17 by the NRC, how soon that copy would have to be 18 updated to reflect those changes.
10 Q
Do you see next to Roman numeral VIII 20 a reference to, "B&W Users Group meeting notes and 21 bulletins"?
22 A
yes.
23 Q
Do you have any unde rstanding of " Users 24 Group meetings notes and bulletins"?
N/
25 A
As a general rule, when a B&W Users Group
1 Harbin 530
)
2 meeting was attended by a representative of the 3
company, that representative issued notes following 4
the meeting or a summary of what took place in the 5
meeting.
Those are the only notes.
I don't know 6
what the term " bulletins" refers to.
7 Q
Do I understand from your earlier j
8-testimony that thoce notes, if filed, should be 9
found in the file that refers to that Use rs Group a
]
10 meeting?
i 11 A
That was the general practice, to file them 12 there.
13 Q
Would those notes be disseminated to other
.O 14 people?
Would they be publicly availabic within 4
15 Met Ed?
16 A
I don't know that.
17 Q
On the last page of this exhibit, it is 18 marked Roman numeral VIII, I think it is a mistake.
19 I think it should be IX.
20
" simulator Group," does that phrase have 21 any meaning to you?
22 A
No.
23 Q
You have never heard it used before?
24 A
The term " Simulator Group"?
25 Q
Yes.
l I
Harbin 531 f))
2 A
That's correct.
3 Q
Are you familiar with training coordinators 4
f rom other sites?
Do you know any?
5 A
No, I don't.
6 Q
Do you know whether anyone at Met Ed 7
or GPU reviewed for any purpose operating experiences at other plants?
9 MR. MacDONALD:
In terms of publications 10
.put out or actually went to the plants to see 11 their charts or 12 MRS. V A U G il A N :
Any way.
We can start with 13 the publications.
(3>
s_/
14 MR. MacDONALD:
I think he has gone through 15 that.
1G A
Gee, that has been --
17 MR. MacDONALD:
Anybody else aside from 18 himself?
19 MRS. VAUGl! AN :
Yes.
20 A
We just looked at a piece of correspondence 21 that Nelson Brown wrote.
22 Q
That is one.
i 23 Do you know anyone else that hasn't been 24 mentioned?
25 A
TI know the Unit Superintendent has.
I l
I Harbin 532 J
2 Q
Would that be the Unit Superintendent for 3
Unit 2 as well as the Unit Superintendent for Unit 17 4
A I don't know about the Unit 2 Superintendent.
5 Q
So there would be you and Mr. Brown and the 6
Unit Superintendent?
7 MR. NacDONALD:
Are you talking about 8-on a regular basis or whoever picked up a piece 9
of paper to review it?
10 MRS. VAUGHAN:
I am talking on a regular 11 basis.
Not just somebody who might accidentally 12 pick up a piece of paper and say, "Oh, look, look 13 at this."
But somebody who had, as their i
14 responsibility, the review of operating 15 experiences at other plants.
16 A
I talked about Dave Carl in earlier testimony.
17 I have talked about the Plant Analysis Group which 18 was formed since the accident.
19 Q
Both Mr. Carl's responsibilities and the 20 Plant Analysis responsibilities are subsequent to the 21 accident, is that right?
22 A
I don't recall when Mr. Carl's responsibilities 23 when that first became a responsibility o f his.
21 Q
My recollection of your testimony was that O
k/
25 he now reviews the Atomic Energy Clearing House
1 Harbin 533 i
2 documents.
3 Does he do anything other than that?
1 4
A I don't know that he does that now.
He took 4
5 that over from me and to the best of my knowledge 6
that was the only thing that he reviewed, the only 7
document.
8-Q Is that the only responsibility that you 9
think of when you think of him in terms o f operating 10 experiences at other plants, in terms of reviewing?
11 A
yes.
12 Q
Is there anyone else?
13 MR. MacDONALD:
A point of clarification.
14 Do you mean to exclude people who were 15 cc'd or routed documents?
16 MRS. VAUGHAN:
I mean to exclude them.
17 Q
Tc make it a little easier, I'm really 18 focusing on the time before the accident at Three 10 Mile Island.
20 A
There were people in the Licensing Department 21 I don't recall their namas that reviewed NRC, in 22 general, NRC publications.
I don't recall any others.
23 Q
Is Nelson Brown at the Island or is he at 24 Redding or Parsippany?
D 2.5 MR. MacDONALD:
Currently?
1 Harbin 534
[~'~
2 MRS. VAttGII AN :
Right now.
3 A
Right now he is located near the Island in a 4
new training center which is by the observation 5
center.
I 6
Q Prior to being at that location, 7
where was he?
. 8.
A On site.
3 9
Q Has he been on site for as long as you have 10 been on site?
11 A
Yes, I believe he has.
12 Q
Are you familiar with anyone by the 13 name of Brown who was at Redding in 1977 and 19787 fr.
14 A
Not that I recall.
15 Q
Who was Mr. Barton?
Are you familiar 16 with that name, B-a-r-t-o-n?
17 A
John Barton?
18 Q
I don't have his first initial.
19 A
I know of a John Barton.
20 Q
What is he?
What position does he hold?
)
21 A
I don't know the title, but 22 Q
Do you know the substance of what he does?
-23 A
The substance is Director of Operations in 21 Unit 2.
O
'- (,)
25 Q
And that is his current position?
I-Harbin 535 2
A Yes.
3 Q
How about Mr. Hetrick, do you know who he 4
is?
5 A
Yes.
6 Q
Are you familiar with him?
7
.a.
Yes.
4 8-Q What is his job position or the substance 9
of what he does?
10 A
I don't know.
11 Q
Is he in Redding?
12 A
I don't know.
13 Q
You don't have any idea what he does?
14 A
The last time I heard anything related to what 15 he does, he was in Redding.
That was approximately a 16 year ago.
17 Q
Do you have any recollection, just 18 generally?
Was he in the Accounting Department or 19 the Technical Department or the library or management?
20 A
I don't know what department.
21 Q
How about Mr. Wayne in Parsippany?
Do you i
22 know anyone by that name?
23 A
No, I do not.
24 Q
And a Mr. Lee.
\\
(~~/
s-25 A
Yes, I have heard the name.
l 1
4 1
1 Harbin 536
()
Q Have you ever met him?
2
~_/
3 A
I think I have.
4 Q
Do you know what position he holds or 5
what his job function is?
6 A
No, I don't.
7 Q
Not even generally?
'8-A No.
9 I'm sorry; Engineering.
10 Q
How many libraries do you have access to 11 within Met Ed, corporate libraries?
12 MR. MacDONALD:
How many there are or 13 how many he can walk to?
ba 14 MRS. VAUGHAN:
How many are there.
15 A
I know there are more, but there are two that 16 I know of.
17 Q
Which two are they?
18 A
One at TMI and one in Parsippany.
10 Q
Do you know whether there is one in 20 Redding?
21 A
I know there once was.
22 Q
Do you have any dealings with the library 23 in'Parisppany from the perspective of you being an l
24 assistant to the Unit 1 Superintendent?
s x,/
25 A
No.
Anythir.g I have to do with the library, i
l l
1 Harbin 537 2
I deal through the library staff at TMI.
3 Q
So, if you want to get a publication or 4
some information, you ask the staff on the Island 5
and they take care of your request?
't 6
A That's correct.
7 Q
Do you know anything about the library 8-in Parisppany?
Do you know how large it is or 9
what kinds of materials they get?
10 A
As I discussed in an earlier deposition, at one 11 time I got a publication from the Parsippany library 12 called "Nuc1 car Power Experiences."
I no longer get 13 that and now I don't deal with them at all.
fg 14 Q
Do you know who the librarian is at 15 Parsippany?
16 A
I don't now.
17 Q
cid you know who the librarian was at one time?
18 A
I believe her last name was Sayers.
10 Q
What period of time was she the librarian?
20 A
some time during 1979.
)
21 Q
Do you know whether there was a different 22 librarian be fore that or you just didn't have any 23 contact with the librarian before that?
f 24 A
I didn't know there was a librarian be fore that.
25 Q
In 1977 and 1978, you didn't know the re
1 Harbin 538 2
was a librarian in Parsippany?
3 A
That's correct.
4 Q
Do you know who the librarian is on the 5
Island?
6 A
Today?
7 Q
Yes.
8-A I believe it's Joan Parrick.
9 Q
How long has she been the librarian?
10 A
Approximately a year and a half.
11 Q
Who was the librarian before she was the 12 librarian?
13 A
It's my understanding that she established the
\\j 14
- library, 15 Q
There was not a library before then?
16 A
Not that was called a library.
17 Q
What was it called?
18 A
Well, there were a lot of documents that she ID now maintains that were maintained at various locations 20 on site.
21 Q
Did she establish the library after the 22 accident?
23 A
I said she has been employed approximately a 24 year and a half and that she established it when she 25 came.
I Harbin 539
)
2 Q
In point of fact, was that af ter the
\\_/
3 accident?
4 A
Yes, it was.
5 Q
Are you familiar with the library in 6
Redding?
7 A
It's my understanding there is no longer a 8-library in Redding.
9 Q
When did there cease being a library in 10 Redding?
11 A
Approximately a year ago.
12 Q
Again, after the accident?
13 A
Yes.
14 Q
Do you know why there is no library there?
15 A
Because -- it's my understanding there is no 16 longer a staff there for a library to support.
17 Q
Do you know who was the librarian at i
18 Redding be fore they closed it?
10 A
Debbie Bossler.
20 Q
Do you know how long she was the
)
21 librarian?
22-A No, I don't.
23 Q
Would you ever, prior to there being a 24 library established at Three Mile Island, get any
.O)
\\_
25 publications or notices from either the library at
1 Harbin 540
(~N 2
Parsippany or the library at Redding?
b 3
I am speaking now of just general 4
notices to bring you up to date on what kinds of 5
publications they carried.
6 MR. MacDONALD:
Are you asking did he?
7 MRS. VAUGHAN:
Did he, yes.
l 8-A When?
9 Q
Before there was a library established on lo the Island, in other words, for that period of time 11 for which there was a library at Parsippany and a 12 library at Redding, did either one of those libraries 13 ever send you notices or bulletins or any information I
14 about the kinds of materias1 they carried?
15 A
Yes, they did.
16 Q
Was that done on a regular basis?
17 A
As I recall, it was done on an irregular basis.
18 Q
would they send you something, a memo, 19 telling you what they had or would they send you the 20 actual document?
21 A
They would send me a listing o f what they had.
22 Q
Apart from the " Nuclear Powe r Experience" 23 publication, did you ever requent any publications of 21 them?
b(_j 25 A
That is the only publication I ever recall
I liarbin 541
(
2 requesting from Parsippany, 3
I also recall receiving from Parsippany 4
a computer run on -- a computer run listing 5
publications on control room design after the 6
accident, and those are the only two things that 7
I eve r recall requesting from the Parsippany 8-library.
9 From the Redding library, I recall 10 requesting usually publications like " Nuclear News,"
11 general trade publications.
12 Q
Would you request that they be sent to 13 you on a regular basis?
14 A
Yes.
15 MRS. VAUGIIAN :
Off the record.
4 10 (Discussion off the record.)
17 BY MRS. VAUGII AN :
18 Q
Mr. IIarbin, would the Generation Library 19 be the name of the only library at Redding or 20 is that a different library from the one that you 21 we re re fe rring to?
22 A
I believe that's the same library.
l 23 Q
So, if I see " Generation Library,"
i.
24 I can assume that is just the one?
i 25 A
The one that I have been referring to as the i
I Harbin 542 (9
2 Redding.
V i
3 Q
.Do you have any knowledge of two libraries?
4 A
No.
5 g
flow about the technical library at 6
Parsippany, do you understand that to be the one 7
and the same library you have been re fe rring to, or is
'O' there a second library at Parsippany?
9 A
It's my understanding that there is only one 10 library.
11 Q
And that would be the technical library?
12 A
I don't know that I have ever -- I don't recall 13 ever hearing it referred to that way.
14 Q
Are you familiar with someone by the name 15 of Gary Droughton?
16 A
Yes, I am.
17 Q
llow are you familiar with him?
18 3
1.ve talked to him.
II e ' s, in the past, been 19 involved with GORB meetings. He's b'e e n involved in 20 computer analyses of transients.
21 Q
When you say, "He's been involved in 22 computer analyses of transients," you mean transients 23 that have occurred at Three Mile Island?
24 A
Yes.
It's my ursdorstanding that he was involved 25 in that and other transients.
i
I Harbin 543 i
2 Q
Is he still in Parsippany today?
3 A
Yes, I believe he is.
4 Q
Do you understand that he is the Safety 5
and Licensing Manager today?
G
'A I don't know what his title is today.
7 Q
Do you understand that the functions that 8-he performs are those related to safety and licensing 9
today?
10 A
I didn't know that he was involved in licensing.
11 g
But you did know that he was involved in 12 safety?
13 MR. MacDONALD:
Safety as a section or unit?
I s-14 MRS. VAUGII AN :
Safety and Licensing u
15 Manager is what he is called.
l 16 A
That title doesn't mean anything to me.
17 Q
Do you know someone named L.
B.
Shattuck?
18 A
I have never heard that name before.
19 Q
Ilow about with respect to Mr. Lee, if I 20 told you it was Robert B.
Lee, is that somebody 21 different from who you were thinking o f be fore, or 22 does that refresh your recollection as to Mr. Lee?
23 A
That is not the Mr. Lee that I was thinking 21 about earlier.
b\\
(/
25 g
Do you know this Robert B.-Lee?
1 Herbin 544 2
A I'm not sure.
I don't know.
3 Q
How about Patrick Walsh?
4 A
Yes, I re ferred to him previously.
5 Q
Who is he?
4 6
A I believe his title is Plant Analysis Manager.
7 Q
That is his present title?
8-A Yes, I believe it is.
9 Q
Is his office located in Parsippany?
10 A
Yes, I believe it is.
11 Q
W.
R.
Correll, do you know him?
12 A
no.
13 Q
If I told you that he was the Records
. ~%
V(
14 Management Coordinator, does that refresh your 15 recollection?
16 A
No.
17 Q
How about Mr.
E.
G.
Wallace, do you know 18 him?
I 19 A
Yes, I do.
20 Q
What do you understand his function is?
h 21 A
IIe 's the Licensing Manager in Parsippany.
22 Q
Does he have anything to do with Three 23 Mile Island?
24 A
Yes.
)
25 Q
What is that?
. _ = = =
1 Harbin 545 1
2 A
He's a GPU cmployee and he's in the Licensing 3
Department for the company and the employees at i
i 4
Three 1111e Island are operators of the TMI-1 nuclear 5
plant.
6 Q
Do you have contact with him frequently?
7 A
Not f re que n tly.
{
'8-Q How often do you have contact with him?
9' A
Verbal contact?
l r
10 Q
Verbal or written.
11 How often do your functions come into 12 contact with his job functions?
13 A
on the average once eve ry two months.
14 Q
In what sense?
15 A
I don't recall the last specific thing that i
16 we worked -- or that we discussed.
l j
17 Q
Was he the Licensing Manager in 1977 and 18 1978?
19 A
I don't know.
20 Q
Mr.
R.
L.
Wayne, are you familiar with him?
h' 21
.I think we have gone over his name.
22 A
I have never heard that name before.
I don't 23 recall it.
24 Q
You don't know him?
25 A
No.
1 Harbin 546
[g'T 2
Q Quality Assurance Manager doesn't refresh 3
your recollection?
4 A
No.
J 5
Q Do you know Mr. LeRoy Harding?
6 A
Yes.
7 Q
What ic his position with Met Ed?
8-A He's a Supervisor in the Licensing Department 9
in Parsippany.
10 HRS. VAUGHAN:
Please mark this as 11 B&W Exhibit 285.
12 (Copy of document entitled "GPU Service 13 Corporation Information Services Division, 14 Div. 50" marked B&W Exhibit No. 285 for i
15 identification as of this date.)
16 Q
Have you had a chance to look at B&W l
17 Exhibit 2857 18 A
Yes.
19 Q
It is entitled "Information Services 20 Division, Division 50" and is dated 4/1/79.
h 21 What is the Information Services Division, 22 do you know?
23 A
My understanding of that Civision has always 24 been that they deal with the service aspects of any 01.
(_/
25 compute r programming or computer programs for the
1 Harbin 547 i
2 company.
3 Q
So then it is not meant to imply in any 4
way that it has anything to do with getting information r
5 out to the various utilities within the GPU organization?
6 A
It's my understanding that they don't have anything 7
to do with that.
8-Q And you have never had any contact with 9
anyone within this division for that p urpo se?
10 A
That's correct.
11 Q
Is that division still within the 12 organizational structure as you understand it today, 13 the Information Services Division?
g~g U
14 A
Yes, within the GPU organization.
15 MRS. V A U Gil A N :
Let's mark the next document 16 as B&W Exhibit 286.
17 (Copy of document entitled "GPU Service 18 Corporation Administration Division, Div. 20" 10 marked B&W Exhibit No. 286 for identification 20 as of this date.)
]h 21 Q
Would you look at what has been marked 22 as B&W Exhibit 286 entitled " Administration Division, 23 Division 20,"
and dated 4/20/79.
2g Do you see something marked " System I
\\_/
25 Librarian," and then you go over and see W.
F.
Sayers?
~.
I Harbin 548 2
Do you see that?
3 A
Yes.
4 Q
Is that the Ms. Sayers that you were 5
re fe rring to before?
6 A
Yes, I believe it is.
7 Q
Underneath you see " Librarian, J.
A.
Temple."
8 Do you know who that is?
9 A
I don't recall hearing that name before.
10 Q
Do you know whether that librarian would 11 be in Redding or Pars Lppany or whatever?
12 3
go, 13 I see the chart is labeled "GPU Service O
1 14 Corporation, Administration Division."
It is my 15 understanding that anything in Redding at the IG Generation Division would have been Met Ed.
So that 17 I would assume that the people on this chart were 18 in Parsippany.
19 Q
Does the location tell you anyt.hing?
20 Do you see where it says, " Location," and then there
)
21 a re numbers?
22 A
No, I don't know what that means.
23 Q
How about the building symbols?
24 A
I've never soon that before or noticed that 25 designation.
~.
~
l Harbin 549 2
mas. VA UCil AN :
This will be 287.
3 (Copy of document entitled "GPU Se rvice i
4 Corporation Communications Division, Div. 80" 5
marked B&W Exhibit No. 287 for identification 6
as of this date.)
7 Q
Do you see B&W Exhibit 287 marked
'8*
" Communications Division, Division 80, GPU Service 9
Corporation"?
10 A
Yes.
1 11 Q
What does the Communications Division 12 do, if you know?
13 A
What do they do now?
14 Q
This is dated 4/1/79, so we can start 15 with that.
16 What did they do then?
17 A
It was my understanding then that their primary 18 function was interfacing with the public and with 10 political representatives of the public.
20 Q
Is that your understanding now?
h 21 A
I understand now that that division does more 22
~than that now.
23
-Q What does it'do now?
24 A
Let me clarify that.
'_['Tg,)
25 I know more specifically some more specific i
I
' A. 2,
.m-
. -.. -, +
a+.
1 Harbin 550 7
2 tasks that they perform now.
For example, issuing (O
l v
3 Press releases, publishing employee type information 4
through newsletters.
They are in charge of the bservation center, still, in general, they deal 5
6 with the public.
7 Q
Do you see about six lines down it says, 18
" Representative Internal Communications, A.
E.
Arnold"?
9
. /
gg A
Yes.
s,
/
gg Q
What are internal communications a s, f.,,,
'
- t 12 you understand it?
. /
.je/
e.J 1,,s i, '.
13 A
I have never heard that term before;
,j y
/
a I
r.- s ', 3
,O g4 Q.
Did you have any de aling s 'w'ith thhl ', /
" T --
jp
</
15 Communications Division?
Have you had any deal /ngs e
t 16 with the Communications Division with respect to
,\\
g7 any of your job functions?
J/
/ -
18 I am specifically referring to envieping
~<
s gg any publications or the mail that this. Unit S upe r.ind en de n t t u(
< 1,fy y a
" "10 9 '*
nj l
I 20 p'
A No.
The Communicat! ions Div4sion, to ryk,
f, 21 t
invopved'in ab'ut 22 knowledge, was not at all in fo rmation o
A
/
events or occurrences at o t h e_ fr plants.
23 r
Mr. Rop o r te r, pleas mark
/
24 i.,
. o /-
25
.this document.
ll l >>,,
y e
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Harbin-551 l
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.J (Copy of* document entitled " Metropolitan y
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/
3 Ddison Company ~ Corporate Division, Consumer
>a h i "f
l 4 poi 4
Scrxices h Corp." dated 4-1-79 marked B&W
)<
.,f- [
/
5 Idxhibit No. 288 for identification as of this e
a
/
.,i,,
6 bate.)_
?
b
?,
7 Q
Do you.mee what has been raarked as T'g.
8-B&W Exhibit 288, ' Metropolitan Edison Company g'
~
'/
I,/
Consumer Services - Corp."?
9 Corporate Divicpon,
.[j 10 A
fes.
/ !
f
/
-11 Q
are you fam,iliar with this division's 3,
c functions?,
[Y
'12
+
/
.*f p
II "*'A_
I was'famili'ar)with some of their functions f,,':a.
q;l
.t
' i
' y"f p /
14 duri:ig, the timo_ frame,that this organization chart
,e g
1
>e 15' y{. was published., 4-1-79.
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1
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16-76 Q
/ Wh c. t did they do?
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