ML20072J030
| ML20072J030 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/10/1981 |
| From: | Harbin R METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-11, TASK-3, TASK-GB NUDOCS 8306290882 | |
| Download: ML20072J030 (80) | |
Text
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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF NEW YORK j
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GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 4
-against-80 Civ. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and j
J.
RAY McDE RMOTT &
CO.,
INC.,
Defendants.
_______________________________________x 4
Continued deposition of RONALD STEPHEN
(
HARBIN, taken by Defendants, pursuant to i
x 4
j Notice and adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase i
Manhattan Plaza, New York, New York, on Friday, July 10, 1981, at 9:35 o' clock in the forenoon, before Joseph R.
Danyo, a
)
. Shorthand Reporter and Notary Public
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within and for the State of New York.
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DOYLE' REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 Lax NGTON AVENUC s
New Yo=K. N.Y.
1C017 0306gBf0 07[10 c
DR PDR Tet.uwoNe 212 - as7.e22o T
1 405 2
Appeara nce s :
O) k-3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York BY:
ANDREW MacDONALD, ESQ.,
6 of Counsel
-7 8
DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 BY:
PATRICIA M.
VAUGHAN, ESQ.,
12 of Counsel 13 14 Also Present:
15 KATHI BROWN 16 17
]
18 19 RONALD S TE PH E N HARB I N having 20 been previously duly sworn by a Notary Public, 21 was examined and continued to testify as
-22 follows:
23 MRS, VAUGHAN:
I would like before we 24 begin today just to put on the record a request f-25 that we'll make of Mr. Harbin, more specifically,
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Harbin 406 1
2.
to produce certain documents which he has I
3 identified during the course of this deposition.
4 We would like to adjourn the deposition today
)
5 and resume at Mr. Harbin's convenience and 6
the convenience of counsel with Mr. Harbin 7
bringing those documents unless those documents 8
can be produced and Mr. Harbin can verify 9
they have been produced as they are kept in 10 the course of business land also verify or l
11 explain if they are kept the same way they 12 have been since he has been assistant to the 13 Unit 1 superintendent.
1 p)
(_
14 The list of documents I have so far is 15 the B&W correspondence file which he testified 16 to earlier keeping, the users minutes, B&W 17 users minutes, any notes from the users minutes 18 kept, the copies of the Current Events-Power 19 Reactors as well as the routing page on those, 20 and then copies of the B&W Operating Plant 1
21 Service Bulletin.
l 22 EXAMINATION (continued) 1 23 BY MRS. VAUGHAN:
24-g Would you pick up again B&W Exhibit 211.
\\.
25 A
Yes.
I
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- - - - - - ' + * - * ' " - ' ' ~ * * ' ' * ' - * * * ~ * " * - " - ' * ' "
1 Harbin 407 2
Q Would you look at the section marked g3U 3
" Atomic Energy Clearing House"?
4 A
Yes.
,5 Q
Under number one there, as you have 6
described it in this memo, there are six to eight 7.
articles presenting recent speeches, papers, and excerpts 8
of industry, academic and political leaders.
9 Can you tell me if you ever recall reading 10 an article about the Davis-Besse September 24, 1977 11 event in any Atomic Energy Clearing House document?
12 MR. MacDONALD:
You are not attempting to 13 quote this exactly?
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14 MRS, VAUGHAN:
No, that's correct.
15 A
No, I don't recall'ever reading of that event 16 in the Atomic Energy Clearing House.
17 Q
Would you look at item 27 18 A
- Yes, 19 Q
In parenthesis is the word "all" with a 20 question mark ascer it.
21 A
Yes.
]
22 Q
And it reads, " Descriptions of (all?) NRC 23 inspection infractions," et cetera.
24 Can you tell me why you have a question
[)D 25 mark after the word all?
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1
. ~ _ _. - _
l 1
Harbin 408 2
MR. MacDONALD:
You are asking him what O
3 his recollection is?
4 MRS. VAUGHAN:
That's correct.
5 A
My present recollection is that I was unsure 6
as to whether all infractions or alleged infractions 7
were listed in the document.
8 Q
What was the basis for that uncertainty on 9
your part?
10 MR. MacDONALD:
This is at the time he 11 wrote it?
12 MRS. VAUGHAN:
That's correct.
13 A
To the best of my recollection, it was that (s
14 knowing the number of licensees that were inspected s
15 by the NRC and the number of infractions or alleged 16 infractions that were listed in this publication, I 17 had a suspicion that not all were listed.
18 Q
Did you actually review this section 19 that you have described in item 2, this section of 20 the Atomic Energy Clearing House document?
21 A
In the section of this document that follows 22 item 4, it says that I did review that section.
i 23 Q
Is that your recollection at this time?
24 A
Yes, it is.
[T 25 Q
What was your interest in reviewing'the
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l
'l Harbin 409 f
2 material in the section dealing with NRC inspection 3
infractions?
4 A
To the best of my recollection, it was to
)
5 determine from infractions or alleged infractions 6
that had occurred at other plants any alleged 7
infraction that might be of interest to TMI-1 8
because I had prior experience that some infractions i
9 or alleged infractions were the result of interpretations 10 of regulations, and if I identified any practices 11 at other plants for which a citation was made by 12 the NRC and had knowledge that or suspicion that 13 Met E d had a similar practice, then I would bring
)
14 that to the attention of the appropriate, an appropriate 15 member of the plant staff.
l 16 Q
Did this section contain the NRC's 17 inspection reports and the utilities' responses thereto?
18 A,
No.
)
19 Q
What did it contain?
What was its i
20 format?
21 A
As I recall now, its format was to list the 22 utility, give a brief description of the regulation, l
l 23 a brief description of the utility's practice or 24 in what way the utility was in violation or allegedly 25 in violation of a regulation and_then to give a short n
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I Horbin 410 2
description of what the utility's response was to I
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3 that alleged violation.
4 Q
Would it give a description of the s;
)
5 resolution?
6 A
sometimes utilities would deny the alleged 7
infraction as being an infraction, and I recall there 8
were times when corrective action taken by the s
9 utility was provided.
N
_s 10 Q
What would happen or what would be t h'e.
11 description in this publication if the utility 12 denied it and the NRC pursued it?
Was there a 13 description of the resolution in that event?
g,,
14 A
I don't recall ever seeing one, no.
15 Q
You don't recall ever seeing a resolution 16 or you don't recall seeing a situation in which I
17 the utility would deny there was an infraction?
18 A
I already testified that I recall seeing 19 descriptions in which the utility denied that there i
20 had been an infraction, but I don't recall ever t
21 g
seeing a description of the NRC's response to that 22 denial.
23 Q
Item 3 is "Brief descriptions of all'
't
,N 24 NRC authorized amendments to commercial power reactor, 25 licensees."
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1 Harbin 411 2
Why would you be interested in item 37 0-3 MR. MacDoNALD:
You are asking him why 4
he was?
x 5
MRS. VAUGHAN, That s correct.
6 A'
Pr'imarily as a matter of' interest in knowing 7
of requests being made by othe't utilities of the 8
NRC to be relieved from restrictions that might also
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9 apply to TMI-1.
10 g
po' yo u s e e on page 2 of the memo at the 11 top of the page "Recent significant industry V
12 announcements / occurrences."
13 Would you describe those, please, as t(h '
y 14 you understood them at the time?
What are recent g
s 15 cignificant industry announc rients?
?
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q 16 '
'A-An example of one would be the vacating and 1,
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ist g
y 17 filling of positions within the NRC and other 18 regulatory agencies.
Anoth$r example that I recall 19 was results of studies performed on storage locations o
j 20 for nucl' ear waste and the results of those studies.
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21 Q
)
uld you review that section as well?
22
,~ A Yes, I ' would'.,
23.
3 W$at was your interest in that section?
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24 3
A Primarily 'to maintain a. broad perspective of j
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25 industry news.
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1 Harbin 412 2
Q Could you turn to B&W Exhibit 208
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again.
That is the letter to the Kemeny Commission, 4
and would you look at attachment 13, the Atomic
)
5 Energy Clearing House document.
Would you turn to 6
page 2 of that attachment which is actually page 17 7
of the issue dated January 9,
- 1978, 8
Do you see at the bottom of that page 9
" Valve malfunctions"?
10 A
Yes.
11 Q
Where would this section normally fit 12 within the sections as you have described them?
13 A
Prior to seeing this issue in this deposition, O)
(_
14 I don't recall ever having seen this description of
- 15 valve malfunctions in this document.
16 Q
I understand that.
Do you recall ever 17 having seen a section entitled "NRC's Report of 18 Current Events for Power Reactors"in general in 19 the Atomic Energy Clearing House document?
20 A
.No, I do not.
21 Q
Do you know whether a section such as 22 that exists in that document today?
23 A
No, I do not.
24 Q
Do you know whether it existed at the f
(~N 25 time you wrote this memo in August 19797
1 Harbin 413 2
A I don't recall now whether I did or not.
3 Q
Do you recall now whether a section 4
like this appeared in the Atomic Energy Clearing
)
5 House when you wrote the memo?
6 A
I don't recall any knowledge prior to giving 7
this deposition that a section entitled NRC report 8
of current events for power reactors in any period i
(
9 existed in any Atomic Energy Clearing House 10 document.
11 Q
Do you recall a section existed irrespective i
12 of its name, whether it was called NRC's report of 13 current events, which described recent events or 14 incidents at other utilities?
4 15 A
Could you repeat the question?
16 (Question read by the reporter.)
17 Q
Do you understand the question?
18 A
Yes.
Yes, I do recall.
19 Q
Where would that section fit within 20 the description of the four sections that you gave in 21 this memo?
22 A
In Exhibit 211, under the heading "LERs - Old 23 Method," I will read it.
It says, " List of industry i
1 24 LERs approximately 100 to 150 contained in every l
25 third or fourth bi-weekly Atomic Energy Clearing
1 Harbin 414 2
House (see Group B below) routed to all Lead
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3 Engineers who review for applicability to TMI."
4 Q
Is that the section that you were thinking
)
5 of?
6 A
Yes, it is.
7 Q
Would you describe the section on page 8
17 of attachment 13 as a list of industry LER's?
9 A
No, I would not.
10 Q
Do you recall seeing a section like the 11 one on page 17 in any Atomic Energy Clearing House 12 document?
13 A
No, I do not.
)
14 Q
So at the time you wrote your memo in 15 1979, your description of Atomic Energy Clearing 16 House did not include any kind of a section like 17 the one appearing on page 17 of attachment 137 18 MR. MacDONALD:
You are asking for his 19 recollection now?
20 MRS. VAUGHAN:
Yes.
21 A
Yes, that's correct.
-)
22 Q
And you did not mean it to include any 23 section like the one on page 177 a
24 MR. MacDONALD:
I object to the form.
I
(i 25 think he said he doesn't recall whether he ever
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I 1
Harbin 415 2
saw the section.
Not knowing whether he ever 3
3 recalls seeing the section, I don't know how 4
he can testify what it included at the time.
5 MRS. VAUGHAN:
If he has any recollection.
6 I want to make sure I understand that his answer 7
is not only that it did not include it but 8
that it was his understanding that it should 9
not have included it based on his recollection 10
- today, 11 Q
Is that correct?
12 MR. MacDONALD:
You are asking whether 13 the section under Atomic Energy Clearing House O'
14 Exhibit 211 when he wrote it it was his 15 understanding that a section like what appears 16 on page 17 of attachment 13 to Exhibit 208 17 was not included in those four categories, 18 to his recollection?
19 MRS. VAUGHAN:
That's right.
20 A
I don't recall at the time that I wrote this 21 memo, Exhibit 211, whether I had any knowledge that a 22 section like the one on page 17 of the Atomic 4
23 Energy clearing House in Exhibit 208 existed or not.
24 Q
You have no recollection of a section l
l-(N -
25 like that which appears on page 17 of attachment 13 J
1 Harbin 416 2
in Exhibit 208, and therefore, is it also correct O
3 that you would have no recollection of a time when 4
the Atomic Energy Clearing House ceased including
)
5 those kind of sections?
6 MR. MacDONALD:
I object to the. form.
7 There is a characterization in there, and I 8
can't quite grasp the intent of the question.
9 I think he testified what his recollection was, 10 that he had no knowledge at the time and has 11 no knowledge whether the section on page 17 12 ever appeared in the Atomic Energy Clearing 13 House and what that meant in relation to 14 Exhibit 211.
I don't know what the question 15 is aiming at.
On' top of the characterization 16 of the first part of the question that was 17 included.
18 Q
Do you recall when the Atomic Energy 19 Clearing House stopped including sections like the 20 one on Exhibit 208, if indeed it ever stopped?
l 21 MR. MacDONALD:
You are including s
i 22 MRS. VAUGHAN:
The same sections we 23 have been talking about.
24 MR. MacDONALD:
Just the page?
25 MRS. VAUGHAN:
Page 17.
. ~.
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1 Harbin 417 f
2 g
Q Do you have a recollection of the Atomic i
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[
3 Energy Clearing House ceasing to include sections i
l 4
like the section that appears on page 17 of attachment 5
137 6
MR. MacDONALD:
I object to the form.
I 7
think he testified he doesn't have a recollection 8
of ever seeing a section like that.
How is 9
he going to know when it stopped if he doesn't i
10 have a recollection of when it was in or out.
4 11 MRS. VAUGHAN:
You keep talking of i
12 knowledge.
13 MR. MacDONALD:
The same word.
\\
14 Q
Are you using knowledge and recollection I
15 interchangeably?
i j
16 MR. MacDONALD:
In the context of not a 17 question, it is very difficult to put those j
{
18 two.
Are you trying to ask him if 19 in this deposition he uses them interchangeably ?
20 I object to that.
)
21 Q
Do you have any recollection of the 22 Atomic Energy Clearing House ceasing to include a
23 sections like the section on page 17 of attachment 24 13 to Exhibit 208?
j
)
25 MR. MacDONALD:
He can answer but I object.
1 Harbin 418 2
A I have no recollection of the Atomic Energy 3
Clearing House ever including a section like that 4
shown on page 17.
)
5 Q
Is it correct that your review of the 6
Atomic Energy Clearing House and the sections that 7
you have described of that publication in this 8
document was to keep you informed of what was going -
9 on within the nuclear industry and other utilities?
10 MR. MacDONALD:
You mean solely from 11 this document?
Exhibibt 211 l'2 was the only place he was gleaning that 13 information or that was part of the reason h
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14 why he was reviewing?
~
15 MRS. VAUGHAN:
No, I didn't ask that at 16 all.
Could you repeat the question?
17 (Question read by the reporter.)
18 MR. MacDONALD:
You didn't mean to 19 imply it was from only that source?
You 20 mean the reason you were reviewing was to glean 21 that information from that particular document?
l 22 MRS. VAUGHAN:
From the Atomic Energy 23 Clearing House, that's right.
24 A'
Part of the reason.
25 Q
What was the other part of the reason?
1 Herbin 419 2
A I already described other parts as we went 3
through the items one through four.
4 Q
But the other parts as I understood
)
5 you to describe them were to keep you aware for 6
purposes of TMI applicability of what was going on 7
within the nuclear industry and at other utilities, 8
is that correct?
9 A
Yes, that's correct, but I gave in more detail 10 specifically why I reviewed the specific sections.
11 Q
Did you have a system or a log for keeping 12 track of those individuals to whom you sent copies 13 of the Atomic Energy Clearing House or distributed
/~
(_Tj 14 copies for their review?
15 A
No, I didn't.
16 Q
You had no system whatsoever?
17 MR. MacDONALD:
Let me suggest again I 18 think the question was log or system.
I 19 don't know what his no answer is applicable to, 20 when it is a straight no answer to a compound 21 question.
22 MRS. VAUGHAN:
I think I said a system 23 or log, so your no answer implies you had no 24 system or no log, is that correct?
'r~T 25 A
That's right.
I had no system or no log.
C/
1 Harbin 420 2
Q Is it correct that you had no way of 3
knowing or keeping track of the people to whom 4
you distributed the publication?
)
5 A
For some period of time, the publication was 6
routed with a cover sheet that listed -- excuse 7
mo -- a form letter cover sheet that had typed on 8
it various names of members of both the Unit 1 and 9
Unit 2 plant staffs, and it was my general practice 10 to indicate next to those names pages that would 11 contain,.might contain, items of interest to those 12 individuals, and it was my general practice to cross 13 out names or to add additional names as appropriate D)
(_
14 to that routing list, and as I have stated before, 15 at some point in time, Nelson Brown was made the 16 last person on the routing list.
17 Q
Do you recall the period of time in 18 which you had this cover sheet method that you just 19 described?
20 A
It began before the accident.
21 Q
Do you remember how far back before the 22 accident?
23 A
To the best of my recollection, one or two 24 years before the accident.
25 Q
Was Nelson Brown the last person on the 1
1 Harbin 421 2
list for that same period of time?
{%
3 A
I don't recall.
4 Q
The paragraph on page 2 of your memo
)
5 directly under it'em number 4 says, "This periodical 6
is mailed "directly to me."
7 By that do you mean in fact directly 8
to you as opposed to the Unit 1 superintendent?
9 A
I don't recall.
1 10 Q
You don't recall what that means?
l 11 A
I don't know that that is a correct statement.
12 Q
Do you recall any time in which the 13 publication was mailed directly to you rather than f'j _
T 14 the Unit 1 superintendent?
15 A
No, I do not.
16 Q
Do you recall whether the publication 17 was already being received by the Unit 1 superintendent 18 or by someone within his office at the time you first 19 became an assistant to the Unit 1 superintendent?
20 A
No, I don't recall that.
21 Q
Do you recall that you ordered it, the 22 publication, or subscribed to it?
23 A
No, I don't recall ordering it or subscribing 24 to it.
g 25 Q
You don't recall whether it was being (O
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1 Harbin 422 2
received at the time you commenced your duties, and
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you don't recall whether you subscribed to it?
You 4
don't recall either of those facts?
)
5 A
That's correct.
6 Q
You have no recollection at all as to 7
how this publication came to be received and reviewed 8
by you?
9 A
That's correct.
10 Q
Do you know who might kn'ow that fact?
11 A
No, I do not.
12 Q
Would Mr. Colitz know that fact?
13 A
I don't know that he would.
(3
(_,)
14 Q
Do you have any reason to doubt that he 15 would?
16 MR. MacDONALD:
You are asking if it is 17 a possibility that he might?
18 MRS. VAUGHAN:
Does he know of any reason 19 why Mr. Colitz would know whether or not that 20 publication was being received at the time you 21 commenced your 22 MR. MacDONALD:
I object to the form 23 of the question.
24 A
I don't know of any reason for certain.
l 25 Q
In this same paragraph, you indicate
~
I Harbin 423 2
that you reviewed the cover sheet for articles of
^h (V
3 interest in section 1 and in greater detail sections 4
2, 3 and 4 for applicability to the station.
)
5 What did you.mean by the cover sheet?
6 A
I meant the table of contents that was listed 7
or that was provided on the cover sheet of every 8
issue that I recall reviewing of the Atomic Energy 9
Clearin'g House, 10 Q
With reference again to attachment 13 of 11 Exhibit 208, the first page of that attachment, is 12 that the table of contents that you are referring to?
13 A
Yes, the section entitled"In this week's issue."
14 Q
As far as you can recall, did that table 15 of contents look like that for the period of time 16 that you reviewed these Atomic Energy Clearing House 17 documents?
18 A
Not every one looked like this one, but in 19 general, this was the standard format, 20 Q
When you say you reviewed the cover sheet, 21 did you mean by that that you reviewed the cover sheet 22 for articles of interest in 1 and 2 and 3 and 4, or 23 did you review sections 2,
3 and 4 directly?
24 A
Could you repeat that?
I'N 25
-(Question read by the reporter.)
(_)
1 Harbin 424 2
MRS. VAUGHAN:
I will restate the
^h (G
3 question.
4 Q
You reviewed the cover sheet for section
)
5 1; is that correct?
6 A
Yes, that's correct.
7 Q
Did you review section 1 itself?
8 A
I may have reviewed portions of section 1.
9 Q
Do you mean that sometimes you did and 10 sometimes you didn't, depending upon the articles?
11-A Yes, that's correct.
12 Q
Are these sections sections as they l
13 appear in the Atomic Energy Clearing House actually, Okj 14 or are they just your general characterization of 15 items that appear in the Atomic Energy Clearing House?
16 A
Just so we are talking about the same section, 17 you are referring to my reference in Exhibit 211 18 under Atomic Energy Clearing House item 1 which 19 states "Six to eight articles presenting recent l
20 speeches, papers, etc.,"
and so on?
21 Q
That's correct.
That is what I am 22 referring to when I say section 1.
23 A
Yes, I am referring to a general category of 24 articles.
25 Q
And that category of articles would be U
l 1
Harbin 425 2
under the first section or a section in the Atomic
_s 3
Energy Clearing House?
Would there be a section 4
called articles.and papers, speeches, et cetera?
5 A
If you look at the cover sheet of the Atomic 6
Energy Clearing House enclosure 13 to Exhibit 208, and 7
you read the first six articles that are listed, 8
those are the types of articles that I was referring 9
to in Exhibit 211.
10 Q
When you get to the other two sections 11 which you have described, the three sections which 12 you have described in your memo, would you as a 13 general practice go beyond the cover page and actually (O
_)
14 review those sections?
O 15 A
As a general practice, yes.
16 Q
When you say in the same paragraph under 17 item 4 on page 2 of your memo that "This review takes 18 approximately 20 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />," are you 19 referring there to the review of the whole document 20 of the Atomic Energy Clearing House including the 21 time it would take to review the cover sheet for 22 articles of interest in section 1?
23 A
Yes, I am.
24 Q
You then state in your memo that you
(~N 25 route the pertoalcal to appropriate department heads
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1 Harbin 426 a
2 and engineers for more detailed review and action
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3 where appropriate.
Then you have a parenthesis 4
"(see attached). "
)
5 Do you recall what was attached?
6 A
No, I don't recall what was attached.
t 7
Q And I take it that by your use of the 8
words " appropriate department heads and engineers,"
9 you mean those people who would be interested in 10 the items that you had indicated, is that correct, 11 those people whom you felt would be interested?
12 A
Those people who I felt should,be interested.
13 Q
Did you ever assign action from items fm (m
14 that you had marked?
15 MR. MacDONALD:
You are talking about 16 in this document?
17 MRS. VAUGHAN:
That's correct.
18 A
As I stated, my general practice was on the 19 cover sheet to indicate page numbers on which there 20 would be items of potential interest to the recipient, 21 and then on that page put initials of the person in 22 the margin indicating what portion of the document 23 I felt to be of interest to that individual.
24 Q
So when the individual received the
[~)T 25 document, he or she would look at the cover page and I
i i
g i
Harbin 427 l
l 2
rx see a page number next to his or her initials, f
1
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3 and flip to the page and also see his or her initials 4
next to the item of interest?
}
5 MR. MacDONALD:
Are you asking Mr. Harbin 6
whether or not he ever knew that an individual 7
who received the document actually did that?
O MRS. VAUGHAN:
No, I am just asking if 9
that was the general practice and that is what 10 you assumed the individual would see or do.
11 MR. MacDONALD:
You are asking what his 12 intent was in making that designation?
13 Q
Was that your intent?
14 A
Yes, that was my intent.
15 (Recess taken.)
16 BY MRS. VAUGHAN:
17 Q
After you routed an issue of the Atomic 18 Energy Clearing House to the appropriate department 19 heads and engineers, would that issue get back to 20 you in the regular course?
21 A
I recall that for some period of time I was 22 the last individual on the routing on the document,.
23 so that it would come back to me.
24 Q
When you were not the last person on 25 the routing list for the document, would it come back
.. +
4 1
Harbin 428 to you as a general practice?
3 A
I don't recall that.
4 Q
Do you recall whether Nelson Brown ever 5
returned any of the issues to you after he had 6
reviewed them?
A I don't recall him ever returning any after 8
he had reviewed them.
9 Q
Do you know that Nelson Brown kept them 10 after he reviewed them while he was the last person on 11 the routing list?
j A
I recall a discussion with Nelson Brown in r
13 which he related to me his general practice of 14 maintaining the documents for some period of time 15 and then disposing of them.
16 Q
When the,se documents were returned to you, 17 would you keep them in a file?
Did you keep them in 18 3
a file as a general practice?
19 A
No, I didn't.
Q What would you do with them?
)
A I don't recall what I did with all of them, 2
but I recall that'for some,and for some period of 23 time I reviewed the routing sheet to determine 9~4 whether any additional names had been added to the I~'
25
- (,)
routing and for what reason as a matter of feedback l
l-
1 Harbin 429 2
to me so that I-could make any necessary adjustments
,C\\
3 in future routings of the document.
4 Q
Who added names to the routing list other 5
than yourself?
6 MR. MacDONALD:
You are asking whether 7
he recalls any instance where he knows of a 8
person who added a name?
9 MRS. VAUGHAN:
That's right.
10 A
I don't recall any individual, any specific 11 individual, who ever added anyone.
12 Q
Did those people on the distribution 13 list add names?
(
14 A
Yes, I recall instances where that occurred.
I 15 g
Do you recall instances where anyone 16 else not on the distribution list added names?
17 A
No, I do not.
18 Q
Why was Mr. Brown the last person on 19 the routing list?
20
.MR.
MacDONALD:
You mean for the period 21 of time Mr. Harbin recalls?
22 MRS. VAUGHAN:
That's correct.
23 A
He was added as-the last person on the 24 distribution at his request.,
-(~N,-
25 Q
Was he on the distribution list before b
,v.
,-_w r..
~ -.,., -
-- ~,
y y
r yv---,,
e
1 Harbin 430 2
that?
~#
3 A
I don't recall whether he was or was not.
4 He was not as a general rule on the typed version, 5
the form version of the routing list.
6 Q
Why did he ask to be added?
7 A
I don't recall why he asked to be added.
8 Q
Did you at one time know why he asked?
i 9
A I don't recall ever knowing.
10 Q
Did he talk to you to ask you to add him 11 to the distribution list?
12 A
Yes, he did.
13 Q
And at the time, did he give you his 14 reasons?
15 A
I don't recall whether he did'or didn't.
16 Q
Do you recall the names on the form or 17 any of the names?
18 A
I recall some names that were on a form.
That 19 form may have changed depending on what period of 20 time.
)
21 Q
What were some of the names that you
)
22 remember, and to the axtent you remember, the times 23 when you remember they were on?
24 A
I don't recall the times.
25 Q
What were the names?
y
1 Harbin 431 2
A Rick Barley, Dick Orlandi, Charlie Hartman, 3
John Brummer, Dick Bensel, John Hilbish, George 4
Kunder.
Those are all I recall.
5 Q
Can you recall the general positions of 6
the people who were on the distribution list?
I MR. MacDONALD:
You are asking him for 8
these people or in addition to those people?
9 MRS. VAUGHAN:
No, just a general 10 categorization of those people.
11 Q
Were they supervisors, department heads?
12 A
Department heads and. lead engineers.
13 Q
Any other general descriptions?
Did x/
14 the station superintendent at least at that period 15 of time when there was a station superintendent also 16 appear on this distribution list?
II A
I don't recall that he did appear on the li s t,.
18 Q
Do you recall that he did not?
19 A
No, I do not, 20 Q
Were the department heads and lead 21
).
engineers those just for Unit 1 or for Unit 1 and 22 Unit 27 23 A
I don't recall whether that applied to 24 department heads in Unit 2.
It did apply to lead
['T 25 engineers in Unit 2.
v/
~
1 Harbin 432 i
l l
2 Q
So there were names of lead engineers k_
3 from Unit 2 on this distribution form?
4 MR. MacDONALD:
You are talking of the 5
specific once he recalled?
6 MRS. VAUGHAN:
No, just in general.
7 MR. MacDONALD:
You are asking whether 8
they were on each form?
9 MRS. VAUGHAN:
If they ever appeared on 10 any form.
11 A
Two of the names that I gave were those of 12 Unit 2 lead engineers.
13 Q
Which two are they or were they?
x 14 A
Dick Bensel and John Brummer.
15 g
Is it your testimony you don't recall 16 whether there were any department heads in Unit 2 on 17 any of these forms; is that correct?
18 A
I don't recall whether there were or were not.
19 Q
It is true, however, isn't it, that 20 there are department heads for Unit 1 and Unit 2?
21 A
There were at that time.
22 Q
Who composed the form or made up the 23 form?
24 A
I don't recall who made it up.
(
25 Q
Where did it come from?
1 Harl in 433 2
A I don't recall, 3
Q Did your secretary, the secretary you 4
shared with the Unit 1 superintendent just have a
)
5 pile of these forms in her office?
l l
l 6
A I recall now that the document came to me in i
\\
l l
7 the mail for some period of time with the form 8
already on it.
9 Q
Which you mean, am I correct, that 10 during that period of time, the document was not 11 mailed directly to you from the Atomic Energy Clearing 12 House?
13 A
Yes, that's correct.
b)
(_
14 Q
Do you recall where the document came 15 from during that period of time?
16 A
To the best of my recollection, it came to 17 a member of a clerical pool that existed on the 18 island, and they performed the function of removing 19 it from its envelope and applying the standard form, 20 routing form, on the document, and placing it in 21 my mailbox.
22 Q
Did you instruct them to do that?
Was 23 the mail addressed to you and they still got it first?
24' A
I don't recall during that period'of time to 25 whom it was addressed.
I only recall that that was
_-._m_.-_--__
1 Harbin 434 2
the practice.
k-3 Q
Was that the practice with all the mail 4
that you were reviewing at that time?
)
5 A
No, it was not.
6 Q
Was it the practice with any other mail?
7 A
Not that I recall.
8 Q
Was it the practice with the Current 9
Events-Power Reactors document?
10 A
Not that I recall.
11 Q
What period of time was this?
12 A
I don't recall the specific period of time.
13 Q
Do you have an approximate period of time?
14 A
Approximately one to two years prior to the 15 accident.
16 Q
Was there a different practice before 17 this period of time?
In other words, did it come 18 to you directly?
19 A
I don't recall whether it ever did or not.
20 Q
Was the practice changed for the time 21 during which you were reviewing the Atomic Energy 22 Clearing House?
23 A
The practice of it coming to the clerical pool 24 and applying the cover?
~N 25 Q
That's correct.
I
{J 3
\\
1 Harbin 435 2
A Yes, I recall that it was,
/,_T L U 3
Q It was discontinued?
4 A
It was changed.
)-
5 Q
How did it change?
6 A
I recall for some period of time prior to the 7
accident that I either used a routing form that 8
was handwritten as opposed to a standard form 9
and that for some period of time I used a standard 10 form that I applied myself to the document.
11 Q
Both of those before the accident at 12 Three Mile Islancs 'is that correct?
13 A
To the best of my recollection.
14 Q
Do you recall why there was a change in
' how it was handled?
15 16 A
I am not sure why it was changed.
17 Q
Do you have any understanding as to why 18 it was changed?
19 A
I recall that no, I don't.
It would only 20 be speculation.
T 21 Q
Did anyone tell you why it was changed
.2 22 or did you hear from anyone as to why it was changed?
23 A
No, I don't recall anyone telling me or hearing 24 from anyone.
f')
25
_Q Is it correct that you did retain some V
1 Harbin 436 2
copies of the Atomic Energy Clearing Hruse that were 3
returned to you?
4 A
I don't believe that I ever did.
5 Q
What would you do with them?
6 A
My general practice during the period of time 7
in which I was the last individual on distribution 8
was to discard them after I had reviewed them.
9 Q
Throw them in the trash can?
10 A
Yes.
11 Q
Did you look at them to see whether 12 anybody whom you had asked to review them had in 13 fact reviewed them?
(
14 A
Yes, I did.
Let me clarify that.
I looked to 15 see that there was an initial on the routing slip 16 by each individual's name who I had indicated on 17 the routing slip that there was an item of interest 18 contained in the document which wasn't necessarily 19 verifying that they had reviewed the portion.
20 Q
But at least that they had received it?
21 A
That's c o r.r e c t.
l 22 Q
During the period of time when the 23 document was not returned to you, how did you 24 determine whether those individuals who were
{^N 25 supposed to have received it did in fact receive it?
%_]
1 Harbin 437 2
A I never did say that there was a period of O-3 time that it wasn't returned to me.
4 Q
I thought I understood you to say when i
5 Mr. Brown was the last person on the distribution 6
list you did not get it back?
7 A
No, I didn't.
I don't recall having said that.
8 Q
Was there a period of time when you did 1
9 not get the document back?
10 A
I don't recall any.
11 Q
was it the general practice that the i
12 document was always to be returned to you?
4 13 A
To the best of my recollection.
/^)
k/
14 Q
So that during the time when Mr. Brown l
15 was the last person on the distribution list, he 16 would return it to you?
17 A
No.
During the ' time that he was the last 18 person on distribution, to the best of my recollection, 19 I was the next to last person on distribution.
20 Q
Then you would receive it after eve.ryone p
21 else had reviewed it and then forward it on to 22 Mr. Brown; is that correct?
23 A
Yes, that's correct.
24 Q
During that period cf time, did you check
[))
25 to see whether those who were supposed to have i
4 1
Harbin 438 4
~
2 received it did receive it?
3 A
That was my general practice.
4 Q
Was there a period of time when you did
)
5 not use the form distribution list that you referred 6
to in distributing this document?
7 A
I described recalling a short period of time
?
8 in which I used a handwritten routing slip.
};
14 I
9 Q
During that period of time, was the
.s u
10 document returned to you at some point?
i 11 A
I don't have any recollection of any period of
\\
]
12 time in which I was not either the last person on 13 the routing list or next to last.
4
)
14 Q
Why did you not keep a file of the i-15 Atomic Energy Clearing House documents, although "x
1 l
16 you did keep files of the Current Events-Power 1
17 Reactors document?
18 A
I felt that the information contained as a 3
19 general rule in
-,rrnnt Events-Power Reactors to 20 be informs e -
t'.t was analyzed, reviewed and 7
21 analyzed, by individuals within the Nuclear Regulatory
. ]h 22 Commission that had a great deal of expertise iA
~
i 23 analyzing events at other planto and providing l
24 analyses and detailed descriptions of those events 1 s
l.
25 and that because of that in general it was a better
\\
f N
sg 3
1 Harbin 439
(
l 2
publication and a publication that I felt to be more i
\\-
3 reliable than the Atomic Energy Clearing House 4
document which I felt was a document that simply 5
gathered information from other sources and l
6 reprinted that information.
[
7 Q
Did you speak with Mr. Brown in the
~
)
I-M 8
course. of preparing this memo, B&W Exhibit 2117 s.
Ni\\
o, I don't believe I did.
I don't recall 9
A N
~
l 10 any discussions with him in preparing this memo.
i 11 Q
How did you know that he reviewed the 12 Atomic Energy Clearing House for possible incorporation 13 into established training programs?
[ N, 14 r A
I don't know how I knew that.
'\\
3 15 g ~
Yo have no recollection of'asking u
\\\\
16 Mr. Brown what he did or why he wanted the Atomic g
- m 17 Energy Clearing House publication?
s
\\ 18 A
At the. time I wrote this letter, I don't know
-3 19 why at the time,I wrote this letter I would have s
g 3
x_
20 made that statement other than speculation.
21 Q
Is 'it your normal practice to speculate 22 in memos or are you saying it would be speculation 23 now for you to say how you knew that?
3 5, 24 A
Yes, I would be speculating now.
~'p l w{x\\
25 Q
Did you speculate when you wrote in
. j i--
Ls
.s
.)
\\
1
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L-
1 Harbin 440 2
what Mr. Brown did with the periodical?
~
3 A
I would say that that statement was based 4
either on a discussion from him or by knowledge 5
of what his function was in the Training Department 6
and that he received the document.
7 Q
Did you talk to anyone else in the course 8
of preparing this memo?
9 A
No, I don't recall that I did.
10 Q,
Did you ask anyone to send you a memo 11 describing what they did with certain publications?
12 A
No, I don't recall making a request like that.
13 Q
Did you send out any kind of a memo or 14 written statement asking for information about what 15 publications individuals received and what they did 16 with it?
17 A
No, I don't recall doing that.
18 Q
Was this entire memo just based on your 19 knowledge.of what went on, or did you refer to any 20 written documents or administrative manuals or i
}
21 whatever?
22 A
What it states on the cover page, there is a 23 reference to the memo from Gary Miller to D.
Reppert 24 dated July 12.
25 Q
Did you refer to any other source of k_,)/
1 Harbin 441 2
information?
3 A
To the best of my recollection, all of Exhibit 4
211 was based on-my knowledge at the time and 5
experience.
That knowledge and experience having 6
been gained certainly from conversations with 7
individuals in the past, No specific conversations, 8
and in general -
experience in dealing with the 9
documents listed as I have discussed I was in 10 general the focal point in Unit 1 for most of these 11 documents.
12 Q
Have you recalled since your deposition 13 testimony yesterday what the categories group A, 4
14 group B and group C are there for?
y,,
15 A
No, I don't recall.
16 Q
Did it have any thing to do with whether 17 group A was the source of documents received those 18 people put primary emphasis on, group B was 19 secondary, and group C was the last in order of 20 importance?
i 21 A
I considered ta. a t, and I don't think -- I don't i
i 22 believe that is the reason for that grouping.
23 Q
Under group c on page 2 of your. memo a
24 A
Yes.
~}
25 Q
the first line there reads " Personal t
+
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-m.,.. -,
y-mw.-
+--y
-. + *. - -
e,so,-.--
-,m,
l 1
Harbin 442 2
contact with other plants - no comment."
3 What did you mean by that?
4 A
By personal contact with other plants?
)
5 Q
By that whole sentence,
- no comment."
6 A
By personal contact with other plants, I meant 7
either by telephone or by members of other plant 8
staffs visiting our plant and vice versa, there 9
being discussions relating to operating experience 10 at the plants, and by the term "no comment," I 11 recall that I felt that that was this item was 12 self-explanatory.
There was no need to go into 13 detail as to what it means to say personal contact 14 at other plants.
15 Q
Did you mean to say that you had no 16 comment with regard to its value in terms of 17 obtaining information?
18 A
No, I didn't mean that at all.
19 Q
Would your explanation be the same for 20 the second line which reads " Personal contact with 1
21 NRC inspectors" insofar as the phrase "no comment" is 22 used?
23 A-Yes, it implies the same.
24 Q
In other words, you didn't feel you had
()
to explain what personal contact with NRC inspectors 25 l
- - ~,
1 Harbin 443 2
meant?
3 A
That's correct.
4 Q
" Professional Organization," is that the 5
same?
You didn't have to explain what that meant?
6 A
Yes, that is what I meant by "no comment."
7 Q
In fact, what are the professional 8
organizations?
9 A
I don't recall what I was thinking at the time 10 that I wrote this memo.
11 Q
Are you or were you a member of any 12 professional organization since your employment with 13 Met ED?
\\
(s' 14 A
No.
i 15
.Q On the next line, " Participation in 16 meetings such as B&W Users /B&W Owners Only comment 17 is that past representation of Met-Ed'has~been 18 somewhat sparce."
19 What did you mean by that at the time you 20 wrote this?
21 A
I don't recall what I' meant by that.
22 Q
Did you feel that the past representation 23 of Met ED had been sparce in meetings such as 24 B&W Users and B&W Owners?
25' A
I can read what it says, and that is that past
1 Harbin 444 2
representation of Met ED has been somewhat sparce, s
3 and I don't recall that prior to ~ the accident there 4
was ever a B&W users meeting that Met ED was not 5
represented by a superintendent or station manager, 6
and so therefore, as I sit here today, I don't 7
recall what I would have meant by that statement.
O Q
Do you recall having any feeling at the 9
time you wrote this memo that more people from 10 Met Ed should be going to those meetings?
11 A
No, I do not.
4 12 Q
Do you recall having a feeling that the 13 meeting should be held more frequently?
s_/
14 A
No, I do not.
15 Q
In the next several lines, "B&W Weekly 16 Newsletter," that section, do you see that?
17 A
Yes, I see that section.
10 Q
Did you have any system or any log for 19 keeping track of who received the B&W Weekly 20 Newsletter from you?
21 A
No, I didn't.
22 Q
In this section it says that the weekly 23 newsletter is received by the unit superintendent 24 and reviewed by his assistant.
[NJ^\\
25 I assume that_his assistant, the I
1 Harbin 445 2
reference there is to you; is that correct?
n
3 A
That's correct.
4 Q
Did you use the same kind of form
)
5 distribution cover sheet on this publication as 6
you used on the Atcmic Energy Clearing House for any 7
period of time?
8 A
can I back up to the last answer I gave?
9 Q
Yes.
10 A
The term assistant may have either referred to 11 me or to a counterpart that I may have had at the 12 time in Unit 2.
13 Q
Would that have been Mr. Shaffer?
14 A
I don't-know that it would have been.
It may 15 have been.
16 Q
Was there any other assistant to the 17 Unit 2 superintendent that you are aware of?
18 A
Not that I recall.
i 19 Q
Are you saying that when you wrote this 20 particular section and used the words unit superintendent,
21 you may have meant the Unit 1 superintendent and the 22 Unit 2 superintendent?
23 A
Yes, I-just don't recall.
I was just trying a
24 to clarify a previous answer that I gave that by
[~)-
25 assistant that meant me.
'%./
~. -..,
1 Harbin 446 2
Q But in fact you did review the B&W 3
Weekly Newsletter; is that correct?
4 A
Ones that I received, yes.
)
5 Q
Going back to the method of routing 6
to the appropriate department heads, did you use at 7
any time the same form cover sheet on the B&W Weekly 8
Newsletter that you used on the Atomic Energy Clearing 9
House letter?
10 A
No, I didn't.
11 Q
What kind of a routing slip did you use 12 on this document, the B&W Weekly Newsletter?
13 A
To the best of my recollection, I wrote on
,j 14 the document itself indicating portions of the 15
' document of potential interest to individuals by 16 placing their initials in the margin and then at 17 the top of the document on the cover sheet by 18 providing a routing list to those individuals.
i
)
19 Q
Would you put the page number that 20 those individuals were to look at next to the 21 routing list?
22 A
I don't recall the document, No, I would not.
l 23 However, the document, to the best of my knowledge, 1
24 was never longer than one page.
Sometimes both sides
{'}
25 of the page being utilized.
m
1 Harbin 447 2
Q Did you ever write any comments next
. /3 V
3 to any of the items saying this should be followed 4
up on or check further into this?
Anything of that
)
5 nature?
6 A
No, not of that nature.
7 Q
This section of the memo says that 8
the originals are not maintained after routing.
9 Did you keep a copy of the routing list or a copy 10 of the page, cover page, to indicate to whom you 11 routed it?
12 A
No, I did not.
13 Q
Would it be returned to you so that you s,)
14 could determine whether everybody had received it 15 who was supposed to have received it?
16 A
I don't recall whether I did or didn't.
'17 Q
Did those people who received it indicate 18 that it had been received by initials or crossing 19 out their initials or something similar?
20 A
I don't recall that I ever received them backs 21 therefore, I don',t recall that they did that, however, 22 that was the intent that that be done so that 23 individuals.who would receive the document would 24 know that it had been reviewed by everyone on the
(
25 routing list.
I 1
Harbin 448 2
Q Would the routing list vary according
. Al 3
to the items that were in the publication?
4 A
Yes, it would.
5 Q
So that the document didn't always go 6
to each department head?
,7 A
That's correct.
8 Q
Did anyone keep copies of the B&W Weekly 9
Newsletter?
10 A
Excuse me, could we clarify the period of 11 time we are referring to?
12 Q
If there is a difference, by all means.
13 I am referring to the period of time that you
(~)
(_/
14 recall receiving this B&W Weekly Newsletter.
If 15 any of your answe_rs differ because you recall 16 something different being done in a period of time 17 that you received it 18 A
Yes, there is a difference with respect to 19 answering the most recent question.
20 Q
What is the difference?
21 A
Could you repeat the question?
}
22 (Question read by the reporter.)
23 Q
Let me clarify that.
Keep a copy of it 24 or keep the original in some place?
}
25 A
Yes, since the time that Mr. Seelinger directed
--m cw -
-.a 4
1 Harbin 449 2
me to initiate the program concerning the B&W l
3 newsletters that I referred to earlier, I kept 4
the originals of the newsletters, at least that was 5
my practice since the beginning, to maintain those 6
newsletters, and to the best of my recollection, the 7
originals that I maintained would have an indication 8
as to whom they were routed, but not necessarily be 9
the same copy as the one that had been. routed.
10 Q
could you explain that a little further.
11 A
During some period of time, I may have routed.
7 12 a copy of the newsletter and retained the original 13 in my files and also since Mr. Toole has been 14 superintendent, the practice of routing the document 15 has been discontinued and now copies are made for 16 each individual that might have an interest in an 17 item listed in the newsletter, and the original is 18 routed to Mr. Toole and then back to me.
19 Q
Do you retain the original?
20 A
Yes.
21 Q
Do you determine who copies are
)
22 distributed to?
23 A
Yes, I do.
24 Q
Do you keep a list?
/~h 25 A
I don't keep a list.
1 Harbin 450 2
Q Do you indicate that on the original?
(3 U
3 A
Yes.
4 Q
So that Mr. Toole can see that as well?
5 A
Yes.
6 Q
Before'the accident or before you began 7
to maintain copies or the original, do you know 8
if anyone maintained a copy for a B&W Weekly 9
Newsletter file or the original itself?
10 A
No, I don't know that anyone did.
11 Q
Do you know that anyone retained copies 1,2 or originals for any purpose at all?
13 A
No, I do not.
14 Q
To the best of your knowledge, after
~
15 the last person on the distribution list reviewed
^
16 the B&W Weekly Newsletter, it was discarded?
17 MR. MacDONALD:
You are asking if he 18 knows as a fact?
19 MRS; VAUGHAN:
To the best of*his 20 knowledge.
}-
21 A
During the period of time that the document 22 was routed, to the best of my knowledge, that was 23 the general practice.
.24 Q
In the next paragraph, there is a f'
25 "B&W Internal Problem Report System - no comment."
x-)
m.
1 Harbin 451 2
What is a B&W Internal Problem Report b'
G
.3 System or what were you referring to when you used 4
that phrase?
5 A
I don't recall.
6 Q
You have no recollection at all?
7 A
I don't recall ever hearing of that system.
8 Q
You did write this memo, didn't you?
9 A
I already testified that I wrote the memo.
10 Q
Do you have any understanding of what i
11 that means today or what it is?
12 A
No, I do not.
r 13 Q
And you have a "no comment" next to its 14 is that correct?
15 A
That is what it says.
16 Q
Did you mean when you used those words, 17 "no comment," that it didn't need any explanation?
18 A
I don't know what that "no comment" meant.
I 19 can only speculate that it meant the same as no 20 comment in the previous sections under group C.
1
}
21 Q
In the next paragraph, "I will not comment 22 on.our proficiency at insuring a thorough and 23 complete investigation of any of these documents 24 except to say that I am sure that improvements could I
(~)
25 be made (some have since the accident) in most areas."
t
1 Harbin 452 2
By "our proficiency at insuring a 3
thorough and complete investigation of any of these 4
documents," what did you mean when you used those 5
words?
6 A
What do those words mean to me now?
j 7
Q What did you mean when you wrote them?
8 A
To the best of my recollection, that statement 9
was to indicate to the GORB committee secretary 10 that the purpose of this document that I was sending 11 to him was not to imply or discuss the thoroughness 12 and completeness of the review of the documents 13 listed above but simply to indicate the mechanism 14 for review and dissemination of information.
-15 Q
When you state in that paragraph that 16 "I am sure that improvements could be made (some 17 have since the accident) in most areas," what were 18 you referring to there?
19 A
I believe that that statement referred to the 20 fact that Mr. Seelinger had requested me to initiate
}
21 the program relating to the B&W newsletters and the 22 information contained in the newsletters that we 23 ~
discussed before as an improvement or as a change in 24 how one of the documents is reviewed.
25 Q
Is there anything else that you were
,s-
\\
1-Harbin 453 2
referring to when you made that statement?
'N-]
3 A
I don't recall anything specific.
4 Q
Did you ever speak with Mr. Reppert 5
about any part of this memo?
6 A
I don't recall whether I did or not.
7 Q
You don't recall that he had any 8
questions about anything that'you stated in this 9
memo?
10 A
I don't recall any discussions with him 11 concerning this memo.
12 Q
Do you see the list of those individuals 13 whom you copied for this memo?
\\.
14 A
Yes.
15 Q
Why did you copy each of those people?
16 Why did you copy Mr. Brown?
17 A
It was my general practice to send copies of 18 my memos to persons whom I listed in the memo and 19 had made some indication as to what my perceptions 20 were of their practices so that if they had.some
)
21 conflict with what I had stated in the memo they 22 could bring that to the attention of either myself 23 or the recipient of the memo.
24 Q
I see where Mr. Brown's name is mentioned
(
25 in the memo-but I don't see any reference to
1 Harbin 454 2
Mr. Hilbish or any of the others except perhaps
'~
3 Mr. Shaffer when you referred to him as an assistant.
4 Why did you send a copy to Mr. Hilbish?
5 MR. MacDONALD:
I object to the form of 6
the question.
Because there are references 7
to the unit superintendent in the memo, and 8
you do have a J.
L.
Seelinger on distribution.
9 I don't think necessarily the assumption built 10 into the question is correct.
11 Q
Why did you send a copy to Mr. Hilbish?
12 A
Before I answer that, l e.t me clarify my last 13 statement.
I understood your question to be why
(~hl
\\_j 14 did I send a copy to Mr. Brown, and my answer was 15 strictly with respect to why I sent a copy to 16 Mr. Brown, although it was a general answer.
There 17 were other reasons for including people on distribution 18 other than that they were mentioned in the memo.
19 Q
Fine.
What was the reason for Mr. Hilbish?
20 A
I don't recall.
}
21 Q
You have no recollection at all why you 22 sent a copy to Mr. Hilbish?
23 A
None other than speculation.
24 Q
Any understanding whatsoever?
(~}
25 MR. MacDONALD:
Not if it's speculation,
\\_-
1 Harbin 455 l
2 7,
Q What was Mr. Hilbish's position at the t
t
%J 3
time?
4 A
I don't recall what it was, 5
Q How about Mr. Miller?
6 A
I don't recall why I sent a copy to Mr. Miller, 7
although I will state that I also had a general 8
practice of sending copies of memos to my superiors 9
or their superiors where appropriate and to 10 superiors of recipients of the memo where appropriate.
11 This was a general practice.
And to individuals 12 or department heeds that I felt had some past or 13 present interest in the subject of my memo.
pl N-14 Q
Was Mr. Hilbish's position superior to 15 yours or somebody who held a position higher than 16 you at the time of this memo?
17 A
I don't recall what his position was at the 18 time.
19 Q
You don't recall the fact that whatever 20 position it was, it was above yours?
In other
]
21 words, that he was senior to you?
22 A
I don't recall that he was ever senior to 23 me in terms' of chain of command.
Reporting chain of 24 command.
(J) 25 -
Q was he senior to you in any other way?
l' Harbin 456 i
2 A
I recall that there was a period of time that
- ~.
3 he held the position supervisor of Licensing.
4 Q
How about Mr. Potts?
Do you have any
)
5 recollection of why you sent him a copy of this?
6 A
No t other than for the reasons that I already 7
stated as general reasons.
8 Q
Was he one of Mr. Reppert's superiors?
9 A
No, he was not.
10 Q
Do you recall what position he held?
11 A
Not at the time of this memo.
12 Q
Was he in Unit 17 13 A
I don't recall.
14 Q
And Mr. Zechman, do you recall why 15 you sent him a copy of the memo?
16 A
No, I don't recall.
Other than for the i
17 reasons I have already given.
I believe that at 18 the time Mr. Zechman was Mr. Brown's department head.
19 Q
Did you have any conversations with 20 Mr. Miller about his memo or your memo, his 21 July 12, 1979 memo?
. 22 MR. MacDONALD:
That was asked yesterday.
23 Go ahead.
24 A
Yes, I recall that I did.
("3 25 -
g when did you have that discussion with N_)
v r
w w
ac-
1 Harbin 457 4
2 him?
3 A
I don't recall.
4
-Q Was it after you wrote your memo or
)
5 before you wrote your memo?
6 A
I don't recall.
7 Q
What was the nature of the discussion?
8 A
I don't recall.
9 Q
But ~you recall you had a discussion with 10 him about your memo or his memo; is that correct?
I-11 A
Yes.
12 Q
Do you recall which memo it was that 13 was discussed?
14 A
I believe that I recall that the discussion i
15 related to my generating a list of items that were 16 reviewed by the staff such as the list given on 17 page 2 of his July 12 memo to Mr.'Reppert.
18 1
Q Do you recall what the purpose of 19 generating the list was?
Was it to respond to 20 this memo?
7 N
21 A
To respond to which memo?
)
22 Q
Mr. Miller's memo.
23 A
No, I believe it was to provide him with the i
i 24 list that he used as' enclosure 2 or page 2.
25 Q.
So as best you can recall, you developed e
--y-.-
y e.~,_
y 4
,,,yv
,, +, -, -, - -,,
,m--e,-
,-g-,m,,w,,--
.w.,m-
+,-,+-e,..-w.
e
I Harbin 458 2
the list on page 2 of his memo; is that correct?
3 A
As be.t as I recall, I developed at least 4
part of the list.
)
5 Q
Do you recall specifically what items 6
on this list you didn't develop?
7 A
No, I do not.
8 Q
Is that your handwriting on the bottom 9
of this list?
1([
A Yes, it is, it appears to be.
11 Q
Do you know what it says?
12 A
I can read what it says.
13 Q
Could you do that?
/~T k,)
14 A
" Info not used.
NPRD reporting system," and m
15 below that "NRC gray book."
16 Q
What is the NPRD reporting system?
17 A
I understand that it refers to the nuclear 18 plant reliability data reporting system.
19 Q
Is that a system outside Met ED?
20 A
It is my understanding that it is a system 21 that is managed by an outside organization.
22 Q
The words " Info not used," did you mean 23 by that that those two items that you listed were l
24 not reviewed or not received?
{')%
25 A'
The term " Info not used" I believe referred to u
l l
l
.. _, - _~
I Harbin 459 2
the fact that I had no knowledge of anyone in 3
. Met ED or GPU utilizing those two sources of 4
information to gain information on operating
)
5 experience at other plants.
6 Q
Did Mr. Miller tell you why he wanted 7
you to get up this list of publications.?
8 A
I don't recall that he did.
9 Q
Do you recall having any idea at all 10 as to why you were doing it?
11 A
I knew at some period of time that this was an 12 item of interest to GORB, but I don't know now that 13 I knew at the time that I developed this list that 14 it was in response to GORB action item 31 or any 15 concern of GORB's.
16 Q
Although Mr. Miller states that at the 17 top of his memo here, doesn't he, that it is somehow 18 related to GORB item 317 19 A
Yes, I see that.
20 Q
And you still don't recall why you 21 wrote the memo to_Mr. Reppert using the same list 22 you developed or at least part of which you developed 23 for Mr. Miller?
24 -
A No, I don't recall why I did that.
( s, 25 Q
Did Mr. Miller say anything else to you L)
- 1
r I
Harbin 460 4
2 at the time he asked you to develop the list?
-3 A
No, I do not.
'4 Q
No, he didn't say anything else to you 5
or you don't recall?
6 A
I don't recall anything else he said to me.
7 Q
Do you recall anything you said to him?
8 A
No, I do not.
9 (Recess taken.)
10 BY MRS. VAUGHAN:
11 Q
Would you look one more time at Exhibit 12 211, B&W Exhibit 211.
The second page of Mr. Miller's 13 memo.
(~%
(,)
I4 Why did you indicate that those 15 documents were not received or not used, to use 16 your words?
17 A
I recall using or referring to this list of 18 sources of information and recalling that there 19 were two other sources that had not been mentioned I
20 above and just as a matter of information to me j
4
)
21 indicating those two documents.but just to clarify 22 that they weren't used making that indication on 23 this document.
24 Q
Were there any other documents that
(~}
25 you knew were not used.that you did not' list?
\\ J' 4
v-
1 Harbin 461 2
A I don't recall that there were or weren't.
3 Q
Do you recall whether Mr. Miller asked 4
you to specifically check to see whether those 5
documents, these two that you listed, were used?
6 A
No, I don't recall that he made any request 7
like that, i
0 Q
Do you recall at the time that you drew 9
up this list that there was discussion about whether 10 or not these documents should be received?
11 A
No, I don't recall any discussion like that.
12 Q
Do you recall anything else about why 13 you included these documents?
O
(_/
14 A
Not other than what I already discussed.
15 MR. MacDONALD:
I think there was 16 something Mr. Harbin said to me that he had 17 recalled, and it may have relateu to a 18 question you asked yesterday, supplementing 19 the answer.
Before we put aside the document, 20 I would like him to add that to the record
])
21 now so the record will be complete.
22 THE WITNESS:
Something that we 23 discussed yesterday that I believe was a 24 discussion that we had b'efore we looked at fh 25 this document but that this document dealt
\\/
l 1
Harbin 462 2
with was GORB's interest in review of gs 3
industry operating experience and you asked 4
me if I knew of any systems that had been 5
created since the accident, the TMI-2 6
accident,'that sere designed to disseminate 7
operating experience information, systems or 8
organizations, and I recalled last night 9
after finishing the deposition another 10 system that has been proposed by B&W, and kl that is a system or program called the 12 Transient Assessment Program or TAP, and since 13 the program has been proposed, examples of
\\ -)
14 transient reports from other plants have been l
15 sent to the Unit 1 superintendent as examples 16 of reports that would be issued to GPU, if 17 GPU accepted the proposal, and I recall that 18 the reports that I reviewed contained a great 19 deal of detail and analysis of trips, 20 reactor trips, and associated transients at 21 other plants that was in more detail and 22 encompassed a greater number of areas'than 23 or publications that I had seen prior 24 to that time, and I recall feeling that because
(
25 these were reports only on B&W plants tha't
1 Harbin 463 2
they would be of greater value to us as a N
3 source of information than some of the 4
documents I had seen befora.
That was an 5
additional program.
4 6
Q Has Met ED bought the TAP program or
\\
7 subscribed to the TAP program?
8 A
It is my understanding that they intend to 9
or have.
10 Q
Do you know when the TAP program was i
11 developed?
12 A
It is my understanding that within the GPU 13 organization the procedure is currently being s,
14 developed.
15 Q
Is the TAP program a program developed 16 by B&W?
i 17 A
The B&W organization is the driving force
-18 behind the development of the program.
However, it 19 is my understanding that the implementation of 20 the program at GPU will incorporate methods that 21 GPU has had input on as to how transient reports 22 at other plants will be reviewed within GPU and how 23 transients within GPU generating stations or at 24 GPU generating stations will be reported to B&W.
()
25 Q
Do you know who prepares the transient
1 Harbin 464 2
reports that you receive from other plants?
l
[h
')
a 3
A It is my understanding in reading the 4
proposals that that would be a joint effort by 5
B&W representatives and the plant staff, 6
Q Do you know --
7 A
And possibly corporate staff members.
8 Q
Do you know whether B&W ever attempted 9
before the development of the TAP program to have 10 a similar program like this in which the utilities i
11 would participate?
12 A
I recall that before the TAP program, B&W 13 had resident engineers at various B&W plants, TMI-1 14 being one of those plants, whose purpose it was in 15 part, at least my understanding, was to discuss with 16 resident engineers at other plants transients at 17 other plants and inform GPU or Met ED department 18 heads and management of appropriate occurrences at 19 other plants.
That is the only other system that I 20 recall.
)
21 Q
Do you recall the B&W Users Group 22 meetings?
23 A
res.
24 Q
Would that have done the same thing among
[]
25 the users of B&W equipment?
i.
\\./
3 r
r
.------s.-.-
i 1
Harbin 465 l
1 i
2 MR. MacDONALD:
You mean are they v
3 geared to do exactly the same as the TAP 4
program or supposed to serve'the same function?
5 MRS. VAUGHAN:
To serve the same function 6
or the same function of the group of resident 7
engineers you were discussing.
O A
Yes, I felt that it was also the purpose of 9
the B&W Users Group to disseminate operating 10 information at other B&W plants as part of the 11 responsibility.
I also thought it was the responsibility 12 of the company itself, at B&W, to notify directly 13 utilities of operating experience and problems at (3
(/
14 other facilities.
15-Q Do you know whether B&W itself participated 16 in the Users Group meetings?
17 A
I recall seeing minutes that indicated that 18 B&W employees had attended Users Group meetings.
19 Q
You never attended any Users Group 20 ~
meeting; is that correct?
- 21 A
That's correct.
22 Q
So-you don't know what was said by 23 any of the B&W people at the Users Group meetings; 24 is that also correct?
m
}
).
25
-A No,-I_ don't think you can say that.
. _ _ _. ~.. _
1 Harbin
'466 2
Q You did know what B&W would say at O
s 3
those meetings?
4 A
I don't recall anything they said, but I recall 5
that there were descriptions or summaries of what 6
B&W employees said at those meetings in minutes.
7 Q
would the unit superintendent, whomever j
8 that might be at the time you were working f'or 9
that particular person, ever come and talk to you i
i 10 about the Users Group meetings and what information 11 was conveyed there?
s 12 A
Not that I recall.
13 Q
Did you ever hear any of the Unit ~ 1
(~)h
\\-
14 superintendents for whom you worked describe the 15 usefulness of those meetings in any way?
16 A
I don't recall whether they lid or didn't.
l q
g 17 Q
None of the superintendents for whom, l<
t 18 you worked for ever said they either thought it T
i 19 was a waste of time or it was a useful meeting or 20 anything like that?
}
21 A
I recall having an impression that it-was a 4
22 useful meeting, and the reason that I recall that 23 is because,'as I recall, the superintendents did 24 very little travelling and, to ~ the best of my 4f~^)
25 recollection, always.made it a point of attending ll t'
l 1
U Harbin 467 s
2 Users Group meetings.
O 3
Q Why was that useful to the superintendents 1
4 I.
or w1iy did that make the meeting useful?
t 5
[A Why did what?
6 Q
Why did the fact that the superintendents 7
trave 11eds to attend the meetings make it useful?
n' 8
A I'am not'sure what you mean.
9 Q
Perhaps I misunderstood your last
?>
. - t 10 marswer.
a 11 (Record read by the reporter.)
12 Q
Why did you feel that the Users Group
- N 13 meetings were useful?
D)
- s
(_
14 A
Because as a general rule, if a meeting, if 15 a ceriodic meeting is found to not be useful I
16 woula lika to strike that'.
Could you restate the 17 question?.
18 (Question read by the reporter.)
19 A
Because of the consistency of attendance by
,20 the unit superintendent.
(g 21 Q
Was it only the fact that the unit 22 superintendents attended'that made you believe it 23
.was useful?.
s 24 A
And because of the fact that subsequent to 25 the meeting,, the superintendent or whoever attended
+
1 Harbin 468 2
representing the company would disseminate O
3 information regarding what had been said at the 4
meeting.
)
5 Q
Would that information include what 6
other utilities said at the meeting about events 7
that were occurring at their facilities?
j 8
A Yes, that was the general practice, for each 9
superintendent to or representative to give a 10 presentation on events that had occurred at their
]
11 plant since the last meeting.
12 Q
And did --
13 A
That were of significance.
14 Q
Did that include the unit superintendents 15 from Three Mile Island, Units 1 and 2 making 16 presentations about events at TMI?
17 A
I don't recall that it would or would not have 18 included both Unit 1 and Unit 2 superintendents at 19 any particular meeting.
20 Q
Even if both of them did not make 21 presentations at the same meeting, do you recall that
)
22 the unit superintendent for Unit 1 made a presentation 23 at the Users Group meetings, any of them?
24 A
Yes, I recall that the Unit 1 superintendent
(~T 25 made presentations on Unit 1 operating experience.
l
%)
1 Harbin 469 2
Q And do you recall that the Unit 2 3
superintendent ever made a presentation about 4
experiences at Unit 2 at any of these meetings?
)
5 A
I don't recall.
r 6
Q You don't recall ever reading in the 7
minutes whether a Unit 2 superintendent did that?
8 A
No, I don't.
9 MRS. VAUGHAN:
I would like to have 10 marked as B&W Exhibit 212 a copy of the 11 minutes dated February 3, 1978.
They are 12 minutes for the B&W Users Group meeting held 13 on November 15 and 16, 1977.
(
14 (Copy of minutes for B&W Users Group 15 meet'ing held on November 15 and 16, 1977 dated 16 February 3, 1978 marked B&W Exhibit 212 17 for identification, as of this date.)
18 MRS. VAUGHAN:
Parenthetically, these 19 minutes were attached to B&W Exhibit 208.
The 20 copy I have here is a clearer copy.
21 Q
Have you had an opportunity to review 22 these minutes?
23 A
Yes, I have.
24 Q
Have you seen them before today?
(~s 25 A
I don't recall seeing them before today.
I
1 Harbin 470 i
2 Q
Would you have seen them in the ordinary 3
course of your employment as an assistant to the 4
Unit 1 superintendent?
5 A
Yes, I would have.
6 Q
Did you also in the ordinary course of 7
your employment see the agenda that was prepared for 8
the B&W Users Group meetings before the meeting?
9 A
I don't recall whether I did or did not.
10 Q
See the agenda?
11 A
That's correct.
Before the meeting.
12 Q
Would you normally see the agenda if 13 it was attached to the minutes, however?
14 Strike that.
15 Do you know whether an agenda was 16 circulated before the meeting?
17 A
I don't recall that i t was.
18 Q
Do you recall that Mr.'O'Hanlon was the 19 Unit 1 superintendent at the time of this meeting?
20
.A No, I don't recall that.
21 Q
. He is however listed as such on the-22 distribution list which is the third page of this 23 exhibit?
24 A
Yes, I see that he is.
(~}
25 Q
And Mr.' Miller is also listed on the
%)
1 Harbin 471 1
2 distribution list, station superintendent?
3 A
Yes, I see that.
4 Q
Was it your practice to normally retain 4
)
5 copies of the Users Group meeting minutes?
6 A
No, it wasn't my practice.
7 Q
Was it somebody's practice?
8 MR. MacDONALD:
Whether he knows?
9 MRS. VAUGHAN:
Yes.
10 A
I know that it was the general practice of 11 the superintendent to maintain copies of minutes.
12 Q
Would you look at page 6 of these l
13 minutes?
()
14 A
Yes.
15 Q
You see down towards the bottom of 16 page 6,
" Operations at Three Mile Island"?
17 A
Yes.
18 Q
And Mr. Miller led off his report by 19 announcing the appointment of Mr. O'Hanlon as 20 cuperintendent for Three Mile Island Unit 1,
and 21 then he reported on the progress at Three Mile 22 Island Unit 2?
22 A
Yes, I see that, 24 j
Q Did you play any role or assist Mr. Miller 25 Q(~N in any way in-the preparation of.the report he gave?
I i
l
1 Harbin 472 2
A I don't recall that I did have any input to
- (_,
3 that.
4 Q
Do you recall that anyone else had any
~)
5 input?
6 A
No, I do not.
7 Q
On page 7, you see where Mr. O'Hanlon 8
gave a report on Unit 17 9
A Yes, I see that.
10 Q
Did you assist Mr. O'Hanlon in any way 11 in the preparation of his report?
12 A
No, I don't recall that I did assist him in 13 preparing his report.
)
14 Q
Would it be your practice to assict the g
15 Unit 1 superintendent in preparing reports for these 16 meetings?
17 A
I don't recall that that was my practice.
18 Q
Did you ever on occasion assist in the 10 preparation of any reports?
20 A
Yes, I did.
l 21 Q
Do you recall when?
l h
l 22 A
No, I do not.
23 Q
.Would you flip to page 10 and page 11.
24 A
Yes.
25 Q
Do you see at the bottom of that page
-1 Harbin 473 J
2 where Mr.
T.
D.
Murray, superintendent of Davis-Besse 0%
(,/
3 reported on operations there?
l 4
A Y e s'.
'}
5 Q
And do you see the chronological list 6
of events?
7 A
Yes, I do.
8 Q
On page 11, do you see where it says 4
9 9/24/777 10 A
Yes, I do.
11 Q
Do you remember any discussion by j
12 Mr. O'Hanlon or Mr. Miller about Mr. Murray's
~
13 presentation and in particular anything about the 14 9/24/77 event?
15 A
No, I don't recall any discussion by Mrl Miller IG or Mr. O'Hanlon.
That is not much of a description 17 of that event.
18 Q
Not on this list?
19 A
That's correct.
20 Q
Do you recall Mr. Miller or Mr. O'Hanlon 21 saying anything at all about Mr. Murray's
)
22 presentation?
23 MR. MacDONALD:
Are you assuming in 24 your question Mr. Murray gave the full 25 presentation?
The only reason-I question it a
s.
1 Harbin 474 l
2 is because Mr. Harbin wasn't there, and he f
3 has no recollection as to whether Mr. Murray 4
gave that presentation entirely himself or
)
5 somebody else contributed to the presentation.
6 The assumption is it's Murray's 7
presentation.
That is what the document 8
states on its face.
I wouldn't want him to 9
r ep r e's e n t, having no recollection, that it 10 was Murray's presentation.
11 MRS. VAUGHAN:
The question lends itself 12 to his answering as to whether they said 13 anything about what Mr. Murray presented.
)
14 MR. MacDONALD:
That is fine.
15 A
I don't recall either Mr. Miller or Mr. O'Hanlon 16 referring to anything that Mr. Murray said in that 17 meeting.
{
18 Q
Do you recall whether Mr. O'Hanlon 19 kept any notes of this Users Group meeting?
20 A
I don't recall whether he did or did not.
21 Q
If he did keep any notes, what practice, 22 what was his general practice in terms of where he 23 filed them with regard to the Users Group?
24 MR. MacDONALD:
If there was a general 25 practice.
I!
1 Harbin 475 2
A His general practice was to file notes in a
(
r 3
folder, in a file folder, labeled with the date of 4
the meeting.
)
5 Q
Just the date of the meeting, or would it 6
say B&W Users Group meeting date?
7 A
I don't recall exactly what it would have 8
said on the folder, but the essence would be B&W 9
Users meeting and the date of the meeting.
10 Q
Would you turn to the enclosure right 11 after page 11, enclosure 1.
12 A
Yes.
13 Q
Do you know from any contacts whatsoever
)
14 any of the individuals listed on this page?
Let 15 me exclude B&W people and obviously the people 16 from Metropolitan Edison.
17 A
Yes, Mr. Rodriguez.
18 Q
Is he the only one?
19 A
Yes.
20 Q
How do you know Mr. Rodriguez?
21 A
Through correspondence on a subject that I 22 don't recall with him.
23 Q
Do you recall anything at all about the 24 subject?
rT 25 A
No.
- N~)
4
. ~ - -.
I i
I 1
Harbin 476 i
t 2
Q Was that the only contact you have jN j
3 had with Mr. Rodriguez?
{
l i
4 A
Yes, to the best of my recollection.
)
5 Q
Do you recall whether the correspondence 6
w.a generated by you?
7 A
No, I don't recall.
8 Q
Do you recognize or know any of the 9
other names at all?
10 A.
No, I do not.
11 Q
Would you have occasion to have any 12 contac,ts with people from other utilities, other 13 l
B&W utilities?
14 A
As of what date?
15 Q
As of any of the time that you have been 16 employed by Met ED.
17 A
With the exception of the reference I just 18 made of the correspondence with Mr. Rodriguez, I 19 have been in discussions, had discussions, with 20 Mr. O'Hanlon who is now employed by Arkansas Nuclear, 21 and those discussions were primarily personal in 22 nature.
23 Q
You never had any occasion or you never 24 did write to or call any other utility to inquire i
I
(
f'}
25 about anything that you had read regarding an event u
?
l l
t
1 Harbin 477 2
they had had?
fh 3
A No, I don't recall that I did.
4 Q
Was that because you were discouraged 5
from doing that, or it just never occurred to you 6
to do that?
7 A
I was never discouraged to do that.
I don't 8
recall now why I would not have done that.
9 Q
Do you know anyone else within Unit 1 10 or Unit 2 who would have contact, who did have 11 contact with other utilities other than through this 12 Users Group meeting on a regular basis?.
13 A
Not on a regular basis, no.
D 14 Q
Is the Users Group meeting, as far as 15 you know, the only meeting by which contact is 16 maintained with other B&W utilities?
17 MR. MacDONALD:
On a regular basis?
18 MRS. VAUGHAN:
Yes.
3 19 A
No, I don't know that.
20 Q
But you don't know of any other?
21 A
I know of one other vehicle that I knew of 22 is the B&W Owners Group meeting, and as I believe I 23 testified before, I am not aware of what differentiates 24 those two meetings.
25 Q
Have you ever called anyone for more
{
1
-a
1 Harbin 478 2
information about an event that you have read about?
(~\\
\\~
3 A
Yes, I 1. ave.
4 Q
Who was that?
)
5 A
I don't recall the name of the individual.
6 But it would be one of two individuals that work in 7
the Plant Analysis Group, the group that has been 8
formed since the accident.
9 Q
How about someone from outside the' Met ED 10 or GPU organization?
11 A
No, I don't recall ever having.
12 Q
Have you ever called the NRC or written 13 the NRC7 f)i q,
14 A
No, I don't recall ever having done so.
15 g
Do you recall other than the possible 16 exception of Mr. Rodriguez that anyone from another 17 utility has contacted you to ask for additional 18 information about an event that occurred at either 19 Unit 1 or Unit 27 20 A
No, I don't recall that anyone has.
21 Let me make a clarification.
I am aware of 22 persons on the TMI-1 staff who have had discussions 23 with persons at other utilities and who have 24 received calla from persons at other utilities
(i 25-concerning events at TMI-1, and it is my understanding V
1 Harbin 479 2
that the reason for that is that there are other
,m
(]
3 members of the plant staff that are more specialized 1
4 in varfous areas of operations and maintenance and 5
about components and procedures in our plant, and 6
it is the general practice to have an individual 7
most knowledgeable in a certain area of interest 8
discuss with his equivalent, an equivalent individual 9
at another plant, an event or occurrence or finding 10 that would be of interes t.
11 Q
Did the Unit 1 superintendent ever ask 12 you to contact another utility for information, 4
13 additional information?
g) 14 A
Not that I recall.
I 15 Q
Do you recall that the Unit 1 superintendent 16 ever told you to tell somebody on the staff to l
17 obtain, on the Unit 1 staff, to obtain more 18 information about a certain event?
19 A
Yes.
20 Q
Do you recall any of those events 21 specifically?
}
22 A
No.
23 Q
Is that a general practice?
24 A
It wasn't a general practice.
'N 25 Q
Did it occur with some degr'ee of k'_
1 Harbin 480 2
frequency?
t')
3 A
No.
4 Q
It was an infrequent occurrence?
)
5 A
Yes, it was.
6 Q
Have you ever suggested to anyone within 7
Unit 1,
Unit 2, Met ED or GPU people, that you 8
should get in touch with another utility or that 9
would be a goed thing to do, that there needed to 10 be more feedback f rom other utilities, more 11 communication between Met ED and other utilities?
12 MR. MacDONALD:
I object to the form.
13 Three questions.
I don't know which one he fs()
14 is going to answer.
15 MRS. VAUGHAN:
I will rephrase it.
16 Q
Have you ever suggested to anyone within 17
. Met ED or GPU that there should be greater 18 communication between the various B&W utilities?
19 A
Yes, I have.
20-Q When was that?
21 A
I don't recall.
22 Q
After the accident or before the accident?
23 A
I don't recall.
24 Q
To whom did you make that suggestion?
s.
25 A
I don't recall.
1 Harbin 481 2
Q You don't recall anything about it?
3 A
Yes, I do.
4 Q
What is that?
)
5 A
I recall a discussion about s e curi ty systems 6
and that when some regulatory agency imposes a i
7 new regulation, security being the one that was 8
being discussed and security access control, that 9
it would be cost beneficial for utilities to 10 consult with one another as to interpretation of 11 the regulations and means to comply with the 12 regulations, 13 Q
Do you recall any other occasion?
14 A
No, I do not.
4 15 (Time noted:
1:35 o' clock P.M.)
16 17 RONALD STEPHEN HARBIN 18 l
19 subscribed and sworn to before me 20 this day of 1981.
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22 23 24
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1 482 CERTIFICATE 2
STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
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4 I,
JOSEPH R.
DANYo a Notary Public of the State of New York, do hereby certify that the continued deposition of RONALD STEPHEN HARBIN was taken before 8
me on Friday, July 10, 1981 consisting 9
of pages 404 through 481 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; 7(j That I am not connected by blood or
(
14 marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my hand this h b day of U
20
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,1981, W
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J H R DANYO 24
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.. July to, 1981
' ' 483 I N D E X J
WITNESS PAGE Ronald Stephen Harbin 405 E XH I B I TS l
l B&W EXHIBITS FOR IDENT.
i 212 Copy of minutes for B&W Users 469 l
Group meeting held on November 15 and 16, 1977 dated
+
1 February 3, 1978 1
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