ML20072J045
| ML20072J045 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/08/1981 |
| From: | Harbin R METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-04, TASK-3, TASK-4, TASK-GB NUDOCS 8306290893 | |
| Download: ML20072J045 (149) | |
Text
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CC 147 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK O
k v ________________________________________x GENERAL PUBLIC UTILITIES CORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
, PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
- 80 Civ. 1683
-against- (R.O.)
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. :
x Continued deposition of RONALD STEPHEN HARBIN, tak'en by defendants, pursuant to
%s No tice and adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Wednesday, July 8, 1981 at 9:40 o' clock in the forenoon, before Charles shapiro, a Certified Shorthand Reporter and Notary Public within and for the State of New York.
[V_.
i DOYLE REPORTING. I N C.
CERTIFIED STENOTY PE REPCRTERS I O 369 LaxlN GTO N AvtNut I Ntw Yomm. N.Y. 1 Col 7 l
9 N TELEPHONt 212 - 867 8220 l T l
I 148 2 Appea ra nce s :
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue g New York, New York 3 5 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 O(_/ 14 Also Present:
15 KATHI BROWN 16 i 17 * *
- 18 19 RO NALD S T E P H E N HARB I N , having 20 been previously duly sworn by a Notary Public, 21 was examined and continued to t'estify as 22 follows:
23 EXAMINATION (continued) l 24 BY MRS. VAUGHAN: .
./~T, 25
-() Q Mr. Harbin, I remind you that you are e
-e _ , - , - = , -m- ,, , , , , - w- p
1 Harbin 149 j_ 2 under oath as you were yesterday.
l
\ ,) \
3 MRS. VAUGHAN: I would like to mark as 4 B&W Exhibit 204 for identification a letter
'\e 5 dated May 20, 1977 to Mr. Klingaman from 6 Joel T. Janis, service-manager at B&W.
7 (Letter dated May_20, 1977 to Mr. Klingaman 8 .
from Joel T. Janis, service manager at B&W 9 marked B&W Exhibit 204 for identificati on, as 10 o f this date. )
11 (Handing document to the witness.)
12 Q Mr. Harbin, have you had a chance to 13 review this letter?
14 A Yes, I have.
15 Q Have you ever seen this let'ter before?
,- 16' A No, I don't recall seeing it.
17 Q Would this letter, a letter from B&W 18 to Mr. Klingaman be the kind of correspondence that 19 you would revfsw in your job as assistant, administrative 20 assistant to the Unit 1 supervisor?
21 MR. MacDONALD: Are you asking him 22 specifically whether this correspondence was 23 something that he reviewed?
24 MRS. VAUGHAN: No, because he said he 25 didn't recall receiving it. I am asking if i
e,e- L v - m,~ <y---, e-w w -- -
1 Harbin 150 2 this kind of correspondence is the kind of 3 correspondence that he would have reviewed at 4 any time during his employment as an administrative 5 assistant to the Unit 1 manager.
. 6 A Yes, I reviewed some B&W correspondence.
7 Q Do you recall whether any of the B&W 8 correspondence that you reviewed was of this nature, t
9 tha't is it informed Metropolitan Edison of an incident 10 that occurred at another plant?
11 A I don't recall any correspondence specifically 12 notifying anyone in Metropolitan Edison Company of
~
13 incidents at other plants, no.
, 'gO
(,) 14 Q Do you recall generally correspondence 15 notifying Met ED of incidents at other plants?
16 A No, I don't.
17 Q Do you maintain a file of B&W correspondence; 18 A I don't, no.
19 Does your secretary maintain a file of Q
20 B&W correspondence?
21 A Yes, she does.
22 '
Q How far back dses that file go?
23 A Prior to the accident. I don't know specifically
. 24 how far back.
,e-j 25 Q What is your secretary's name?
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1 Harbin 151 2 A Pat Schlegel, S-c-h-1-e-g-e-l.
3 Q How long has she been your secretary?
4 A She is not my secretary.-
) 5 Q ' Whose secretary is she?
6 A Ron Toole's.
7 Q Do you have a secretary?
8 A Ron Toole and I share her as a secretary.
9 Q Was she Mr. Seelinger's secretary when 10 he was the unit superintendent?
11~ A No, she was not.
12 Q Who was Mr. Seelinger's secretary at 13 the time?
I)
\s 14 A Donna Kent, K-e-n-t, who was one.
, 15 Q Was one?
16 A Yes.
17 Q Was there another?
18 A I don't recall.
19 Q was there more than one secretary for 20 Mr. Seelinger at one time?
) 21 MR. MacDONALD: Do you mean at a certain
./
22 period of time --
23 Q Did Mr. Seelinger have two secretaries?
24 MR. MacDONALD: At the same time?
- 25 MRS. VAUGHAN: Yes, that's right.
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1 Harbin 152-2 A I don't recall. Not as a general rule, f' 3 Possibly during some period of turnover from one 4 secretary to another.
) 5 Q Did you share the secretary with 6 Mr. Seelinger at that time as you do with Mr. Toole 7 now?
8 A Yes, I did.
D Q Would the files that--Ms. Schlegel did 10 you say?
11 A Schlegel.
I 12 Q -- Ms. Schlegel have relating to B&W 13 correspondence contain B&W correspondence that would
.('T
(,) 14 have been received at the time Mr. Seelinger was the 15 Unit 1 superintendent?
16 A Yes, it does.
17 Q Would it also contain correspondence 18 that was received at the time Mr. O'Hanlon was the 19 Unit 1-superintendent?
20 A I don't know that for sure, s 21
) Q Would it be the general practice that 22 that would be so?
23 A Yes, it would, 24 Q Do you know whether the files contain 25
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correspondence from B&W that would have been received I
e
- w , - , . . - , - - - , - - , - - , - - > . - - - - , , - . - - , -
1 Harbin 153 2 at the' time Mr. Colitz was the Unit 1 superintendent?
A Yes, it would have.
3 4 MRS. VAUGHAN: I would like to mark as
)' 5 B&W Exhibit 205 a copy of B&W Users Group 6 meeting minutes, .the meeting was held on 7 June 27 and 28, 1979. The date of the minutes 8 are July 24, 1979. In addition there is a ,
9 cover memo from J. L. Seelinger to distribution 10 with a cc to Harbin.
11 (Copy of minutes of a B&W Users Group 12 meeting held on June 27 and 28, 1979, dated 13 July 24, 1979 with an attached cover memo from b)
(, 14 J. L. Seelinger to distribution with a copy 15 to Harbin marked B&W Exhibit 205 for 16 identification, as of this date.)
17 (Handing document to the witness.)
18 Mr. Harbin, have you had a chance to look Q
19 at B&W Exhibit 205?
20 A Yes, I have.
! 21 Q I would like you to turn to the second 22 page, please, the page that is the memo from J. L.
i 23 Seelinger.
24 A Yes.
25 It says "cc Harbin." Is that you?'
(7 N/
1 Q I
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1 Harbin 154 l
2 A Yes.
}
3 Q Underneath that is a note that says "Go 4 through in detail and put this in the same system
) 5 as B&W newsletter."
6 Do you see that?
7 A Yes.
8 Q Could you explain to me what Mr. Seelinger 9 meant by that note to you?
l 10 MR. MacDONALD: I object to the form.
11 Just before we get into it I would like -
12 to preface that by asking the witness whether 13 he recalls seeing the document at some point j 14 in time and also the question should be geared
^
15 to his understanding on 8/21/1979 on what 16 Mr. Seelinger meant at that time.
17 MRS. VAUGHAN: I have no problem with 18 the latter.
. 19 Q I will ask you if you recall receiving 20 this? ,
21 A Yes, I do.
J' 22 Q Could you please tell me what your
- 23 understanding was at the time that you received 24 this 8/21/79 and what Mr. Seelinger meant by "Go
25 through in detail and put this in the same system i ~- )-
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1 Harbin 155 2 as B&W newsletter"?
3 A I gave this deposition yesterday concerning 4 the program that I was directed to establish, relating
) 5 to the weekly B&W newsletters and there are events 6 listed at various B&W plants in this report that he 7 felt would be additional input to that system, to the 8 same system and wanted me to review this report for 9 any additional items.
10 Q Do you see on the first page of the 11 actual minutes --
12 A I am not sure what page that is.
13 Q It is like the 7th page of the exhibit
( 14 at the top of the page it says " Minutes of Meeting,
~15 B&W Users Group."
16 A Yes.
17 Q On that page and on some of the succeeding 18 pages there appear to be initials on the left-hand l 19 side of the page.
20 on page 6 of the minutes is a clearer 21
)
s copy o f some of the. initials.
22 A Yes.
23 Q Would those have been initials that you 24 marked in?
25 MR. MacDONALD:
O Are you asking were they?
. i 1 Harbin 156 2 MRS. VAUGHAN: Yes.
~O 3 MR. MacDONALD: Initials that he marked 4 in?
) 5 MRS. VAUGHAN: Yes, 6' A That appears to be my writing.
7 Q Can you tell me why you put-those initials 8 there?
9 A Assuming that that is my writing, the initials 10 are an indicator of who should review each of the 11 subjects listed in the -- in this document.
12 Q Would it be your general practice to 13 go through the B&W Users Group meeting minutes and 14 put-initials next to those items,'certain. items?
15 A No, I don't think that's a fair statement to 16 make.
17 Q Are-these minu'tes the first time you did 18 that?
19 A I don't recall.
20 Q Do you recall any other time that you r 21' did it?
22 A No.
23 Q Do you keep a file of B&W Users Group L 24 meeting minutes?
f'}.
25 A I don't,'no.
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l Harbin 157 2 Q Does anyone keep a file of those minutes?
O 3 A Pat Schlegel keeps a file of some. I don't 4 know --
I don't know how complete that file is.
-) 5 Q Is it the general practice to put'those 6 meeting minutes into a file which she keeps?
7 A Yes, it is.
8 3 Q Do you know how far back those meeting 9 minutes go?
10 A They go back before the accident.
11 Let me clarify that. To the best of my knowledge files prior to 1980 are maintained by Al 12 13 Stowe, once again in the Unit 2 administration 14 building.
15 Q When you say files you mean the files 16 of these meeting minutes would be maintained by him?
17 A Yes.
f 18 What is his title, Mr. Stowe's?
Q 19 A I don't know.
20 Q When Mr. Seelinger stated in his memo I
- 4 21 "Go through in detail," what did you understand him
. 22- to be saying to you at that time?
23 A To carefully read and review the document.
24 Q And for what purpose were you to review l 95 and read the document?
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1 Herbin 158 2 A The same purpose that I stated a few minutes O 3 ago.
4 Q Only for the purpose of putting it into
) 5 the system?
6 A Yes.
7 Q That you discussed before?
8 A' Yes, that's correct.
9 Q Were you responsibile for making sure 10 that those people whose initials appear in these 11 minutes received a copy of these minutes?
12 A No.
13 Q What was your responsibility with regard
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(_ 14 to their involvement, that is, those people whose 15 initials appear here? .
IG A I had no specific responsibility with respect 17 to that.
18 Q Who did? Did anyone? l l
19 A Who did what? l 20 Q Who had any responsibility for their 21 involvement?
22 A No one.
23 Q Why did you put the initials next to their '
24 names --
next to the items, excuse me. Why did you-25- put the initials next to the items in these minutes?
-. ~. . . - - - __ _ _ _ . -
1 Harbin 159
. . 2 A As I said a few minutes ago I felt that the g
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k/ 3 item adjacent to an individual's initials would be 4 something of interest to them.
) 5 Q How did you communicate that to them?
6 A I can't tell by looking at this document that 7 I did.
8 Q Do you know that you did not?
o 9 A No.
10 Q Would it be your practice to put initials .
11 next to items and then not follow through on them 12 if you thought those items were to be of interest ,
xl 13 to those individuals?
14 MR. MacDONALD: Follow through, what do <
15 you mean by follow through?
/
16 MRS. VAUGHAN: Follow through in terms of '
/)
17 notifying them of the item itself.
18 A Could you repeat the question, please?
- 1 /
19 MRS. VAUGHAN: Could you read it back, g.
20 please? ,' '
f
' ; / .,
21 '
(Ques tion read by the reporter.) '.- l ,
t 22 A No, that was not my practice.
~ ~
23 g what would be your practice in terms of 24 communicating to the individuals the fact that the
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'% J 25 item appeared iri the minutes?
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1 Harbin 160 s'f,x 2 MR. MacDONALD: That is assuming he had
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t' \ ') 3 a general practice. He testified a moment 4 agc he doesn't have any recollection of ever
) 5 doing this on the meeting minutes --
6 MRS. VAUGHAN: I am not sure he didn't 3
i :'
7 have a recollection. He said he couldn't tell
, 8 by looking at the minutes.
la '
9 MR. MacDONALD: I think the question was i s 10 before whether or not he had any recollection of
{ / '
11 ever doing this with other meeting minutes. He 12 said he had no recollection so he may just be j '
13 puzzled by the term " general practic3" as it
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)' 14 applies to distribution of meeting minutes with
' <) / 15 initials in the margin.
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16 MRS. VAUGHAN: Let's try it this way.
l' f, > 17 Q Did you have a general practice with
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' I ,; 18 respect to circulating to individuals whom you j 19 identified as those individuals who might be interested !
r 20 in an item that appeared in these minutes?
/
/ 21 A No, I don't believe I did.'
)
22 Q You don't believe you had a general practice 2
/, 23 A That's correct.
rj 24 Q What would be any practice that you had,
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- 25 any means at all of communicating to individuals s_-
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I Harbin 161 2 identified as being those individuals who would be O
O 3 interested i n items mentioned in the minutes?
4 MR. MacDONALD: Are you speaking now of
) 5 these particular minutes?
6 These in front of us, MRS. VAUGHAN:
- 7 yes.
8 A I don't recall what my practice was. '
9 Q Would you talk to the individuals?
i 10 A I don't recall talking to any individual.
11 Q Would you write them a memo?
12 MR. MacDONALD: You are still talking 13 about this whether or not he did write them a 14 memo and whether he can recall if he spoke to N
15 them or wrote them a memo?
16 MRS. VAUGHAN: Yes.
17 A I don't recall whether I wrote anyone a memo.
18 Q Did you send anyone the minutes?
19 A I don't recall whether I did.
20 Q Do you recall at any time in your 21 g employment after having reviewed B&W Users Groups 22 minutes of communicating to anybody at any time any 23 item that you had identified as being of interest to 24 them?
,/ 25 MR. MacDONALD: I object to the form. I
- - - -, - - ---m, g.,m - ,%-y y e- .rm+w -yN - m
- . ~ - . - . . . .-. . .- . - - . - .
1 Harbin 162 2 think he already testified that the only 3 recollection he has of ever reviewing a B&W 4 Users Group meeting minute was this one. Now
} 5 you are trying to extrapolate that and turn 6 to --
MRS. VAUGHAN: I don't think he testified 8
this is the only one.
9 MR. MacDONALD: Let me finich my statement 0 --
and turn it to a review of every Users Group 11 mreting minute that came into Metropolitan 12 Edison. I don't think that's his testimony.
i 33 Q Is it your testimony that these are the 14 only meeting minutes that you have ever reviewed, 1
that you have any recollection of ever having reviewed?
IO A No.
II Q It is not your testimony?
18 A That's correct.
I You do recall reviewing other Users Group Q
20 meeti ng minutes? .
21 A- Yes, I do.
)
22 Q Do you recall at any time identifying i
23 individuals who would be interested in items that i
24 were mentioned in Users Group meeting minutes either
' ("%
(j 95
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this one or other Users Group meeting minutes?
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1 Harbin 163 2 A Yes, I did in this one and I did in others.
)
V 3 Q Identify individuals who might be 4 interested in particular items mentioned in the
) 5 meeting minutes; is that correct?
6 A Yes, that's correct.
7 Q All right.
8 Now, my question to you is: How would you 9 communicate that particular item of interest to the 10 individual you identify?
11 A For this document I don't recall.
12 Q For any document at any time. Referring 13 now only to the meeting minutes.
) 14 A For o ther documents I recall making a distribution 15 to the individuals that I have indicated in the 16 margins would be interested in the item -- in the 17 adjacent item.
18 Q In making that distribution would you 19 send along a copy of the entire minutes to the 20 individuals?
g 21 A I don't recall.
i j' 22 Q How would you make that distribution?
23 A I don't recall.
24 Q Do you recall any way at all how you 25 would make it?
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1 Harbin 164 l
- 1 2 A No.
O l 2 3 Q You have no recollection whatsoever of
, 4 how it was that you distributed the item to the
) 5 individual?
6 A Not other than-to speculate.
7 Q Would a file be kept of any memos that 8 you sent out regarding B&W Users Group minutes?
9 A I don't know that that was the general practice.
10 I know that there were some meetings that that was --
that 11 was done.
i 12 Q And who would have that file?
) 13 A Excuse me, of that file?
O y 14 Q Yes.
15 A Either Pat Schlegel or Al Stowe.
i
, 16 Q Would you look again at the memo from 1
3 17 J. L. Seelinger?
18 A Yes.
l 19 Q Do you see the individuals listed next i 20 to the word to, t-o and a colon?
l 21 A Yes.
22 Q Is the first name Mr. Shovlin, 23 S-h-o-v-1-i-n?
24 A Yes.
25 -
Q Do you know why he would be getting a b(~T i
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1 Harbin 165 2 copy of these meeting minutes?
3 A I don't know.
4 Q How about Mr. Ross?
) 5 A' I don't know why anyone on the distribution would 6 since I didn't write the memo.
4 7 Q Did you have any discussions with 8 Mr. Seelinger about this particular memo?
9 A I don't recall.
10 Q Did Mr. Seelinger ever discuss with you 11 anything having to do with the meeting minutes, these 1
12 or others ?
13 A Not that I recall.
14 Q Did you have any discussions with the 15 individuals listed about the meeting minutes?
16 MR. MacDONALD: You are now talking 17 about Exhibit 205?
18 MRS. VAUGHAN: I am talking about the 19 same exhibit (indicating).
1 20 A Not that I recall.
21 Q Who goes to the B&W Users Group meetings 22 from Met E d?
23 MR. MacDONALD: Are you asking who has l, 24 gone, who goes?
I - 25 MRS. VAUGHAN: Well, let's start this way.
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1 Harbin 166 2 Q Who goes today?
4 3 A could you be more specific?
4 Q In terms of who goes today to the Users 5 Group meetings?
6 A Yes.
7 Q I think that's fairly specific.
j- 8 A I think who went to the last one is more 9 specific.
10 Q Whatever.
f 11 A Ron Toole.
t l 12 All right. Who else?
Q I
13 - Is he the only one that went to the last 14 one? f 15 A I don't know.
l 16 Q How about the one before that?
' '17 A I don't recall.
18 Q Do you know whether there is a general 19 practice in Met Ed to send the same individual in 7 r
20 a-particular job position?
I 21 A Yes.-
22 Q And what job position is-that?
l I. 23 A~ The position of unit superintendent.
24-Q Would that be for Unit 1 and Unit 27
- x. 25 A I-don'tfknow for Unit 2.
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1 Harbin 167 2 Q But for Unit 1 that would be true?
O 3 A As a general practice.
4 Q so essentially it should have been since 5 1977 or whenever the Users Group meetings started, f
6 your boss who went to those meetings; is that right?
7 A Yes. However, I recall some meetings that he 8 did not go.
5 Q But as a general practice h,e was the 10 individual who was supposed to go?
11 A Yes, that's right'.
12 Q Did he ever take any notes of the meetings 13 whichever boss it would be in any particular point 14 in time?
15 A I recall some notes being taken by some 16 superintendent.
17 Q Do you recall any notes being taken by I
' 18 Mr. Colitz?
l 19 A No, I don't.
i l
20 Q Do you recall that Mr. Colitz went to any I
21 Users Group meetings?
22 A No, I don't recall that he did.
23 Q Do you recall whether Mr. O'Hanlon attended 24 any Users Group meetings?
I~ 25 A No, I don't recall that he did.
V)
1 Harbi'n 168 2 Q Do you recall any notes that Mr. O'Hanlon
(^N.
k-) 3 had from Users Group meetings?
4 A No, I don't.
) 5 Q How about Mr. Seelinger, do you recall 6 that he went to any Users Group meetings?
7 A No, I don't.
8 Q Mr. Miller, do you recall that he went 9 to any Users Group meetings?
10 A No, I don't. '
11 Q And then Mr. Toole is the individual that 12 you just testified to; is that right, as having 13 attended the last Users Group meeting?
14 A Yes.
15 Q Who was the - individual or individuals 16 that you did recall did make notes of Users Group 17 meetings?
18 A I don't recall the specific individual.
19 Q You just recall that there are notes of 20 Users Group meetings made by any one of those 21 individuals?
22 A Yes, that's correct.
r 23 Q But you don't recall who the individual 24 was?
, /^N 26 A' No, I don't.
b 4
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1 Harbin 169 2 Q Way is it that you recall the notes?
, (~Ni 5- 3 A Because I recall the location of the meeting 4 and I recall that the individual prepared most of
, 5 his. notes in the airport following -- at the airport 6 following the meeting.
7 I just don't recall which superintendent it 8 was.
9 Q were you at the meeting with that 10 superintendent?
4 11 A No, I wasn't.
12 Q Where was the meeting held?
13 A I believe crystal River.
O( j 14 Q How do you know that the notes were
^
15 prepared at the airport?
16 A Because he told me that's where he prepared 17 them.
l 18 Q But you still don't remember who the 19 individual was?
20 A No.
21 Q Did you keep a copy of_those notes?
22 A I don't know.
23 Q When was that meeting?
24 A I don't know.
25 Q Were there any other Unit 1 superintendents I
, . _ _ _ , _ - - - - - - - - --o .- - ,,_ , ,
1 Harbin 170 2 from the time of your employment other than those 3 that we have so far mentioned, that is, Mr. Colitz, 4 Mr. O'Hanlon, Mr. Seelinger, Mr. Miller in whatever
) 3 acting capacity he was and then Mr. Toole in any other 6 capacity?
7 A Not that I know of.
8 Q Was Mr. Seelinger's instruction to you 9 to go through in detail a new instruction from him 10 at that time? In other words, had he ever asked you 11 to do that before with regard to any other Users 12 Group meeting minutes?
13 A I don't recall.
( 14 Q Do you recall that your review of these 15 minutes was any different from your review of previous 16 meeting minutes?
17 A Yes, it was.
18 Q In what respect?
19 A In that I was looking for specific failures 20 and information relating to those failures that would 21 lend itself to the program that I was developing.
22 Q When you used the words " specific 23 failures," do you mean by that that Mr. Seelinger 24 identified for you the kind of failures he wanted you 25 to look for?
O 4
_ _ _ _ _ . _ _ _ - - - ----- - - ~ - ~ -
i 1 Harbin 171 i
2 A I don't recall whether he did that or not.
O 3 Q What did you mean when you just used the 4 words specific failures?
) 5 A Component failures.
6 Q Do.you mean then that before this 7 particular meeting minutes that you reviewed, when 8 you reviewed the other ones you did not look for any 9 component failures or any indication of component 10 failures at other facilities?
11 A No, I don't mean that.
12 Q Did you in your review of previous meeting 13 minutes look for component failures?
14 A Yes, I did.
i5
- Q Do you recall when that was?
16 A I don't recall reviewing any specific minutes.
17 Q Do you recall as you sit here today 18 identifying any particular component failures from 19 the meeting minutes?
20 A _ No, I don't.
g- 21 Q When you reviewed meeting minutes previous
! J 22 to this was there anything else that you can recall
- 23 looking for as-you reviewed them?
24 A one thing that-I tscall was reviewing matters 25 concerning personnel management levels as an example
- -w - - - , n ,
1 Harbin 172 2 with other plants.
g 3 Q Why were you interested in that?
4 A I don't recall specifically why.
I 5 Q Personnel management matters, is that 6 what you said?
, . 7 A Manageaent levels.
8 Q Management levels, do you mean the numbers 9 of employees?
10 A Yes.
11 Q That particular facilities had or had 12 problems attaining?
13 A I didn't say that.
() 14 Q No, I know you didn't. I am asking whether 15 that's what you meant.
16 A No.
17 Q You meant just the number of employees 18 that other utilities had?
19 A Yes.
20 Q Is there anything else you mean by 21 management levels, personnel management levels?
22 A -No.
l 23 Q All right.
24 Jo you recall looking for that be
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x_,
25 don't' recall why you looked for that, is that >
, w- ~< -- ,p 9 -w< y r-ew4--
1 Harbin 173 2 testimony?
3 A No, my testimony is that's something else that 4 I remember seeing and knowing, not that I was looking
) 5 for that.
6 Q I see. Do you recall why you noticed it, 7 what it was about that that brought it to your 8 attention?
9 A Yes.
10 Q What was that?
11 A An interest in comparing management levels at 12 various plants.
13 Q What generated your interest in that?
- [4 A My knowledge of the apparent disparity between 15 management levels at various plants.
16 Q Did'you feel that some plants didn't 17 have enough people and other plants had too many 18 people?
19 A No.
20 Q What was your interest?
21 A I stated my interest.
22 Q Just a disparity?
l 23 A Yes.
24 Q Did you feel that Met Ed had enough p 25 people?
V. .
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1 Harbin 174 2 A Yes.
O 3 MR. MacDONALD: At what time?
4 MRS. VAUGHAN: At the time that he remembers 5 looking at this.
6 A Yes, I did.
7 Q Were there any other minutes that you 8 saw other than the ones that were prepared by B&W and 9 sent to Metropolitan Edison of these Users Group 10 meetings?
11 A I am sorry, could you repeat that?.
12 Q Yes. Were there any other minutes which 13 you saw other than these that were prepared by B&W O)
(_ 14 of a Users Group meeting and I am not talking about 15 this meeting in particular but at any time during 16 y'our employment when there were User Group meetings.
17 Did you r9e minutes other than those 18 prepared by B&W7 19 A As of today?
20 Q As of today?
} 21 A I am asking you.
22 Q No, I know, but I don't understand your 23 question.
2; MR. MacDONALD: I think he means up until 25 the present time.
1 Harbin 175 2 MRS. VAUGHAN: All right.
3 MR. MacDONALD: Through the last Users
, 4 Group meeting. '
) 5 MRS. VAUGHAN: Yes. ,
6 A- Yes.
7 Q' Whose minutes were they?
0 l
! 8 A Ron Toole's.
- 9 Q Is that from the.last meeting or one 10 previous to that?
11 A 1 don't recall.
12 Q Do you recall seeing minutes of Ron 13 Toole's from the last meeting?
14 A Yes, I do.
15 Q Do you recall that' Ron Toole has attended i
4 16 users meetings other than the last one?
17 A Yes, he has.
3 18 Q Do you recall seeing other minutes of 19 his from any of the others or any of the other Users 20 Group meetings he would have attended?
' g 21 MR. MacDONALD: These are minutes J.
22 prepared by Mr. Toole?
23 MRS. VAUGHAN: That's right.
24 A Yes, I do.
25 Q Whv would you-see them?
.M -
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Du n- eoe-e+<ww%W-w e ---*r?--ga+9- T w- r* v-'9T T--9 -w
.1 Harbin 17G 2 A I don't recall, t
3 Q Would Mr. Toole distribute the minutes 4 to others for their review?
) 5 A Yes, he would.
6 Q His minutes now we are talking about?
7- A Yes.
8 Q Would he ask you to make that distribution
! 9' for him or would he do it himself?
10 A He would do it himself.
11 Q Were you one of those to whom he 12 distributed the minutes?
13 A I don't recall.
14 Q Do you know who else might have been t
15 on his list-of distributees?
16 MR. MacDONALD: Who else was on his list?
f 17 MRS. VAUGHAN: Who else was. *-
18 A I don't know.
19 Q How soon after the meeting would he 20 distribute the minutes?
l l
1 -
21 MR. MacDONALD: You mean as a general t s
! 22 matter?' The only reason I ask is tha t "wo uld "
l 23 connotates could have, may have possibly have 24 as opposed to did which would be actual fact 25 and which is what we are trying to get from the
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+-- y +- '* e -----aw- ~ - -- -T--'
1 Harbin 177 2 witness.
l' )
(/ 3 MRS. VAUGHAN: Did is fine.
4 It can be a general answer, would it be Q
) 5 within a week, did he distribute the minutes within 6 a week?
7 A For the last meeting he did.
i 8 Did he distribute at other times within Q
9 the same period of time or do you recall that it 10 took longer?
11 A I don't recall.
12 Did Mr. Seelinger take minutes of the Q
13 meetings or write up minutes of the meetings?
() !4 A I believe we already discussed that.
15 I don't recall whether he did, whether O'Hanlon 16 did. I recall some minutes that were written up by 17 one of the superintendents previous to Toole. '
18 Q But you don't recall which one?
19 A That's correct.
20 Q All right. We were talking about notes i
21 before but if you understand notes --
22 A I am sorry.
23 Q -- not to be minutes.
24 Do you know with that distinction whether 25 you ever saw something less than minutes, something l
. g-)g.
i I
p --, .- , - '
4 1 Harbin 178 2 perhaps that was not typed up that were just notes
)
/ of one of the Unit 1 superintendent's that they took 1
j 3
4 at those meetings for their own use?
) 5 A Yes, I recall that.
j 6 Q whose notes were they?
7 A Gary Miller's.
]
8 Q And we are talking about that time period 4
j 9 when he was Unit 1 superintendent?
10 A Not necessarily.
11 Q Did you see notes that Gary Miller took 12 at the time or at some time during which he was the I
I 13 Unit 2 superintendent?
14 A Not that I recall.
, 15 Q sut you do recall seeing notes of his
- 16 from a Users Group meeting; is that right?
f 17 A Yes, I do.
18 Q Do you recall seeing anyone else's notes 1
- 19 from a Users Group meeting and now I mean to include 20 not only the Unit 1 superintendent but anyone else 21 who might have attended or who did attend?
22 A No, I don't recall.
23 Q would copies of Mr. Toole's minutes and 24 anyone else's minutes be maintained?
i n ~25 A Yes.
. _ w- - --- -et
[
l 1 Harbin 179 l
l
! 2 Q Did you maintain a file of those minutes?
,s k- 3 A No, I did not.
l 4 Q Who maintained the file of those minutes?
') 5 A Pat Schlegel has minutes generated by Ron Toole.
6 Q How about if there were minutes generated i
7 by somebody else that you can't remember?
8 A I don't know.
9 Q Would those minutes either B&W minutes 10 from the Users Group meetings or the minutes of 11 Mr. Toole or anyone else who took minutes be posted 12 anywhere?
13 A Not that I know of.
14 Q In the minutes that Mr. Toole has taken 15 of the meetings, did he ask for any follow up on 16 any, items?
17 A Yes, he did.
18 Q Which items?
19 A I don't know. .
J 20 Q Do you recall attending a meeting after 21 the Users Group meetings at which those who went to 22 the meeting made a general report?
23 A No, I don't.
24 Q At any time in your employment?
/~ 25 A That's correct.
k)T y3 p . - - _ , ,
1 Harbin 180 4
2 Q Do you know whether any meetings were 3 held even if you did not attend?
4 A No, I don't.
) 5 Q Are you aware of any form of communication 6 by those attending the Users Group meeting to others 7 at Met ED at which they would inform them of any 8 items that they thought were of particular interest 9 or report back on the meeting?
10 MR. MacDONALD: Are you talking about 11 now aside from distribution of the minutes 12 themselves?
13 MRS. VAUGHAN: That's right.
4
[)
\_s 14 A Could you please repeat the question?
15 Q Yes. Do you know of any form of 16 communication that was used or that occurred by which 17 those attending the Users Group meeting reported to 18 Met ED employees items of interest or anything that 19 occurred at those Users Group meetings? ,
20 MR. MacDONALD: Again this is aside from i
l 21 the distribution?
l 22 MRS. VAUGHAN: Yes.
23 A No, not that I recall.
24 Q When B&W Users Group meeting minutes
, gg 25 would come in from B&W itself, were you in any way b
, - . . - - - .r -y-. y.- - ---
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I 1 Harbin 181
- 2 responsibic for distributing those minutes at any D' 3 time?
4 A I have a problem with the term "re spo nsibl e for."
5 Q Were you asked by the unit superintendent 6 to distribute those minutes?
7 A Not that I recall.
8 Were you asked to do anything at any Q
9 time by any of the Unit 1 superintendents for whom 10 you worked with respect to the minutes other than 11 this one that we have in front of us now?
12 A Not that I recall.
13 Were the user minutes something that Q
14 you would categorize under the B&W correspondence
, 15 that we referred to yesterday?
16 A Yes.
17 Would you review it from that prospective?
Q 18 A Yes.
19 As you reviewed all correspondence?
Q 20 A Yes.
,' 21 Q Would you then determine whether it
( 22 should be distributed to anybody?
l l
23 A Excuse me, let me go back and answer the 24 previous question a little more clearly.
r~
! 25 I would not perfo'rm the same review on B&W
_ . , , y --
e yav T- - - ++e +
I Harbin 182 4
2 correspondence in general and on B&W users meeting 3 minutes specifically, the same as I reviewed all i
4 other correspondence, w
I
) 5 Q What would be the difference?
6 A In general I perform a more detailed review.
7 Q Of the user minutes?
8 A Yes.
9 Q Then would you forward it on, the minutes?
I 10 What would you do after you reviewed the minutes 11 received from B&W7 12 A It would have depended on the superintendent 13 and the period of time.
r
( j) 14 Q What would you do with Mr. Colitz?
15 A I don't recall.
16 Q What would you do with Mr. O'Hanlon?
17 A I don't recall.
18 What would you do with Mr. Seelinger?
Q l
19 A I don't recall.
20 Q Irrespective of for whom it might have 21 been, what methods do'you recall employing with the 22 minutes?
23 A I recall highlighting portions of the minutes 24 and passing the highlighted document on to the
(- 25 superintendent for his review and disposition.
D]
i
. , r - - - - - - - . s_ ,. .- - + - - , - - ,
1 Harbin 183 2 Q Do you recall using any other method.or 3 doing anything different from that?
4 A I don't rece.ll whether I did or not.
) 5 Q Do you recall any of the superintendents G ever identifying action items from the users' minutes?
i 7 A Yes, I believe I testified a few minutes ago 8 that I recall that in Mr. Toole's minutes there were 9 action items generated.
10 Excuse me, are you referring now to minutes 11 that wcJe generated at the time by the superintendent' 12 or by B&W7 13 Q No, by B&W.
( 14 A Yes, I recall that.
15 Q Do you recall that occurring with a 16 superintendent other than Mr. Toole?
17 A Yes, I do.
18 Q Do you recall which one?
19 A No, I don't.
20 It was the general practice, to the best of 21 my knowledge, that all three superintendents carefully 22 reviewed users' meeting minutes and assigned action 23 items where appropriate.
24 There is a lot that I don't recall and I don't 25 recall primarily which superintendent.
O l
__~
1 Harbin 184 2 Q When those action items were assigned f 4
(_/ 3 were you then responsible for following those action 4 items to see that they were completed on a particular
) 5 date?
6 A I don't recall ever being responsible for any, 7 no.
8 Q When we spoke yesterday about your general 9 areas of responsibility and we were talking about 10 the action items, didn't you testify that you would 11 follow through on some of those and keep track of 12 action items to see that they were completed when 13 due?
,m (v ) 14 MR. MacDONALD: Are you asking anew 15 whether or not that's his testimony? I just 16 have problems with the characterization which 17 may be correct or may not be or may not 18 accurately reflect everything that he testified 19 to yesterday. If you want to ask him anew 20 so that we have it here rather than your 21 characterization, it will be fine.
22 MRS. VAUGHAN: I mean to ask it anew in 23 the sense that I thought I understood him to 24 say yesterday that he did follow through on r~ 25 action items to the extent of watching the due i
m-I
1 Harbin 185 2 dates and seeing that they were completed.
t
\_/ 3 Q If that is not correct I would be happy i
4 to have you correct that for me.
)
~
5 A That's correct.
6- Q And so my question now is: Would action 7 items from the minutes be one of those things that 8 you would follow through?
4 9 A I said I don't recall that I did.
10 Q Do you have any reason to think that 11 you would not have? In other words, let me make it ,
12 clearer.
13 was there something about action items
() 14 with regard to the user meeting minutes that were 15 beyond what your responsibilities were?
16 A In general, because the superintendent attended t
17 the meetings and was more intimately familiar with 18 what had been said at the meetings, in general he 19 followed action items that were issued as a result 20 of the minutes, the B&W minutes or his minutes more 21 than I did, if I did.
22 MR. MacDONALD: Off the record.
23 (Discussion off the record.)
24 (Recess taken.)
( N, 25 BY MRS. VAUGHAN: -
g - # g y- --
ev - -~ ~
g e s. e wy- 4 m - , .
I Harbin 186 2 Q Mr. Harbin, I would like you to look O 3 at --
actually we can mark it as either one or two, 4 they are not the same documents, so if we mark them
)-
5 as the same ex hibi ts it will be all right with me.
6 It will be B&W Exhibit 206 and B&W Exhibit 207.
I MR. MacDONALD: Is there any sequence 8 to them?
9 MRS. VAUGHAN: No. The questions that 10 I have to ask are really not related to the 11 substance of the memos.
12 MR. MacDONALD: Why don't we mark them 13 separately.
14 MRS. VAUGHAN: Let's mark as B&W Exhibit 15 206 a letter signed by Mr. Herbein dated 16 July 25, 1978 and addressed to Mr. Brummer.
17 (Letter dated July 25, 1978 addressed to 18 Mr. Brummer from Mr. Herbein marked B&W Exhibit 19 206 for identification, as of this date.)
20 MRS. VAUGHAN: Please mark as B&W Exhibit
! 21 207 for identifi, cation a three-page document
])
22 at the top it reads " Appendix A, Notice of 23 Violation." In the left-hand corner " License 24 No. DPR-50" and at the top right-hand corner ,
25 there are two dates, one, 7/29 and the other
( }_
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y 1
1 Harbin 187 -)j ,
2 8/5. There is no indication of year. '
3 3 (Three-page document headed " Appendix A, 4 Notice of Violation" marked B&W Exhibit 207 5 for identification, as,of this date.)
6 Q Mr. Harbin, have you had a chance to,.look 7 at B&W Exhibit 206? ;
I 8
(Handing document to the witness.{s '
9 A Yes, I have.
[ ',
10 Do you recall ever seeing this document Q -
11 before today?
12 A No, I don't.
13 MR. MacDONALD: Let me interject. Your
/O '
5--) 14 questions would be aside from counsel?' '
+ ' ,
15 MRS. VAUGHAN: Yes, obviously. '
16 In the top right-hand corner there is a Q
17 notation "Not posted H" and then 7/27. ,,
10 Would.that "H" refer to you?
, i 19 A Yes.
l 20 Q Is that your writing? ,',' '
a
/l >
} 21 A Yes, it appeahs to be. ## '!
, / -
22 Q My que's' t ion >is what do you mean;by "not ll 23 posted" in the context of obviously having'p'osted 24 some.' things at some point in time? ,
e;-
'[ 25 t-
, - NR'. MacDONAIO: What did he mean.in or ^
-l
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7 p '
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1 Harbin 188 2 around July 25th, 19787 i i t
\# 3 MRS. VAUGHAN: Yes, that's right.
4 A There is a code of federal regulations
) 5 requirement concerning posting certain NRC violations 6 .that are identified during inspections of a licensee 7 and responses by the licensee to those violations 8 and the particular code of federal regulations J
9 requires or contains posting requirements and this 10 being a response to a violation that was identified 11 in inspection 7812 --
excuse me, in response to an 12 apparent violation.
13 I made a determination that this didn't fall 14 within the posting requirements of that code of
~
15 federal regulations and therefore did not have it 16 posted and indicated in the upper right-hand corner
",' 17 the date that I reviewed it and the fact that I 18 did not post it.
19 Q Just so I understand, the posting 20 requirement is based on the type of violation or s
[ y+h 21 apparent violation; is that correct?
22 A Yes, I believe so.
.r' 23 Q Would reviewing NRC inspections and
/
/ 24 notices of violation or apparent violations and
[ (~N 25 responses by Met Ed to those violations be part of h_,1 ,'
y> . , 2.l, 1
, l' '
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'l a : ( .i ? . -,-
i 1 Harbin 189 l
2 your job responsibilities? !
3 A Now or at some point?
4 Q At some point in July of 1978.
, ) 5 A Yes.
6 Q In other words, is that a responsibility 7 that we can-add on to the list of responsibilities 8 that we were talking about yesterday?
9 A Yes.
10 Q Would your review of these documents '
11 involving NRC inspections be only for purposes of 12 determining whether or not to post the relevant 13 documentation?
A Let me just make a clarification,
( 14 a
15 Q sure.
16 A I reviewed the inspection reports, not the 17 inspections, a minor point.
18 Q But in reviewing those inspection 19 reports was it for purposes of determining whether it 20 should be posted?
91 A In part, yes.
22 Q what else did you review it for?
23 A For any other problems or deficiencies, 24 criticisms or positive comments on observations made 4
- 25 by the inspector.
e
- ,e- a---- m T- e --e
- H e-
_. . =.
1 Harbin 190 2 Q For what purpose would you be reviewing
[
3 for those reasons?
4 A As a general rule for my own edification.
) 5 Q Would you take any follow up action with 6 regard to any comments that you had noted in any of 7 the NRC inspection reports?
8 A I have on occasion.
9 Q What kind of follow up?
10 A one example would be to compare the report 11 itself which may come out six or eight months after 12 the inspection itself with minutes that were taken 13 at meetings held between one or more NRC inspection
/~N
( ,) 14 team members and members of the plant staff, that 15 review being performed, in part, for consistency.
16 Q What do you mean by " consistency"?
17 A To insure that what we understood them, their 18 findings to be at the time that they left were 19 consistent with the findings as reported in the 20 official report.
21 Q If you found something that was inconsistent, 22 what would you do?
23 A I don't recall.
24 Q Did you ever find anything that was
(~T 25 inconsistent?
U .
e
, - - ,-,y-, --, . - - - n ---~rw ,,-e , ,
1 Harbin 191 2 A Yes.
(3
~
3 Q But you don't recall what you did to 4 cure that inconsistency 7
) 5 A Nothing -- I don't recall anything specific.
6 Q Would it be something that somebody else 7 had already picked up on?
8 MR. MacDONALD: You mean was it?
9 MRS. VAUGHAN: Yes.
10 A Not that I recall, 11 Q Did the inconsistency remain?
12 A The general practice at the time was to, 13 upon --
at the time of the exit, to take action or
/"
(%) 14 assign action and take action on items that were 15 identified during the inspection and not to wait for 16 the follow up report or for the official report.
17 If something was identified in the official 18 report that was identified and hadn't been earlier, 19 then we would, as a general rule, assign action to 20 insure that this new item would be followed up on 21 and action would be taken.
22 Q Who would assign action?
23 A I don't recall specifically.
24 l Q Who in gener 17 The Unit 1 superintendent?
r"'N; t
25 A It depends on the period of time.
6
1 Harbin 192 2 Q Would it depend on who it was who was t
N-- 3 working on the NRC inspection?
4 A The NRC inspector?
I
) 5 Q No, who was working with the NRC
- 6 inspector and with respect to that particular 7 inspection and report.
8 MR. MacDONALD: You are speaking now of 9 Met Ed personnel?
10 MRS. VAUGHAN: Yes.
11 A Not necessarily.
4 12 Q Would you assign that action?
13 A Not as a general rule.
( 14 Q Did you ever assign action?
~
15 A Yes, I did.
16 Q Do you remember the items involved?
17 A We are talking about assigning action for 18 items that were identified in a final report and not 19 at.the time of the exit?
20 Q That's right.
21 A And what was the question again?
22 Q Did you ever assign action and you 23 answered, I believe, yes, and.the question was: What 24 kind of action items were they that you assigned 25 or what action items were there?
(--) <
%/-
-- . ,,,_...%. r_, .%-y-,. y , _ . _ , - - . . , , , __
1 ~ Harbin 193 2 A I don't recall.
O
\~/ 3 Q But you do recall instances when you did 4 assign ~ action items coming out of NRC inconsistencies 5 in NRC exits and NRC reports; is that right?
6 A Yes.
,i 7 Q Looking again at B&W Exhibit 206, do
, 8 you know what those file numbers mean on the bottom i
i 9 left-hand side?
10 A No,"I don't know.
11 Q Do you ever use file numbers like that?
12 A No.
13 Q Which department would use them?
(I 14 A I don't know.
15 Q Have you seen them before?
16 A Yes.
17 Q You know nothing about them?
1 18 A No.
19 Q Do you know whether they relate to GPUSC --
?
20 A No.
4
, g 21 Q --
files?
- 22 Do you know whether they relate to Met Ed i
23 files?
24 A No.
' ~
25 Q And you have never had occasion to use D
- l. , . , _ . ,,, . . . . , . , ,- - - - - - - - - ~ ~ - - - ' " " ' - " ~ ' *
- 1 Harbin 194 2 them?
3 A That's correct.
4 Q Is there an administrative manual that
) 5 would explain that file system?
6 A I don't know.
7 Q You have never seen one?
8 A I don't know if one exists.
9 Q Have you ever se9n one?
- i 10 l A No, a
11 Q Have you ever heard anyone mention one 12 in connection with the file numbers?
13 A Not that I recall.
f~}.
14 Q Who would know what the file numbers mean?
15 A I don't know.
16 Q How about at the top of the page, GQL, i
17 what does that stand for? -
18 A I don't know.
19 Q That is something that Met Ed would have 20 affixed to this letter; is that right?
21 A Yes, it is.
22 Q Do you know who would know what GQL 23 stands for?
l l-24 A Do you want the name of someone?
25 Q Yes.
4 D
-- , - ~ *-W -- m +r *-e
- 1 Harbin 195 2 A George Troffer.
'( ' 3 Q Why would he know?
4 A He held a management position in the Licensing
) 5 Department during the period of time in which GQL 6- letters were generated.
7 Q Does GQL relate in some way to the Licensing 8 Department?
9 A I don't know that.
10 Q But why is it important that he was in 11 Licensing and then would know what GQL means?
12 A To the best of my recollection GQL makes some 13 reference to the department, 14 Q To the Licensing Department?
15 A I don't know that.
16 Q To any department?
17 A To a department.
18 Q And your guess is that it might be the 19 Licensing Department and that's why Mr. Troffer would 20 know?
21 A No. ,
22 To the best of my knowledge this is a letter 23 that was prepared by, to some extent, by the 24 Licensing Department in Reading.
25 Q I understand.
s
1 Harbin 196 4
2 would you look at B&W Exhibit 207 marked
{ \
\/ 3 for identification.
4 (Handing document to the witness.)
) 5 Q I just have a few questions about this, 6 nono of which will be substantive in nature.
7 Do'you want to take time to review it?
8 MR. MacDONALD: Yes, let him take a 9 couple of minu'tes.
10 A Yes, let me review it quickly.
11 Q- All right.
12 A Yes.
13 Q Am I correct that on the top right-hand s
14 corner of the first page of B&W Exhibit 207 there 15 is the notation " posted 7/29" and then under that 16 your initials RSH?
17 A - Yes, that's the way I read it.
18 Q And then under that " removed 8/5"?
19 A Yes.
20 Q Would this document have been posted
,. 21 pursuant to the same regulations you were talking 22 about before?
23 MR. MacDONALD: Can you ask him a 24 preliminary question whether he recalls seeing 25 the document?
o (sss)
O e
1 Harbin 197 2 Q Do you recall having seen this document 3 before?
4 A No.
5 Q Those are your initials on the top right-hand 6 corner?
7 A They appear to be.
8 Would this document have been a document Q
9 that was posted under the same regulations that you 10 referred to before?
11 A The marks in the upper right-hand corner, 12 the term " posted" and " removed" was placed on the 13 document because of the regulation that I referred Ch
{V 14 to before.
15 Q Is there a certain length of time that 4
16 the regulation requires these documents to be posted?
17 A To the best of my knowledge there is.
10 And what is that, seven days?
! Q 19 A I don't recall, 20 Q Where would you post a document when you j
21 did post it such as this?
f 22 MR. MacDONALD: Are you asking him 23 generally now?
i 24 MRS. VAUGHAN: Yes.
~
25 MR. MacDONALD: Not specifically with l-l .
1 Harbin 198
. 2 regard to this?
O-
'> 3 MRS. VAUGHAN: That's right.
4 A There was a bulletin board in the Unit 1 service
) 5 building that was used for posting legal notices and 6 that's where these were generally posted.
7 Q Were these posted in any facility involving 8 Unit 27 9 A During what period of time?
10 Q During any period of time.
11 A To the present day?
12 Q That's right. From the beginning of your 13 employment?
14 A Yes.
~
15 Q Where would they be posted?
16 A I don't know.
17 Q Would you post documents relating to 18 NRC inspections of Unit 1 in Unit 2 facilities?
19 A could you please repeat that?
20 Q Yes. In other words, I want to clarify 21 your answer.
22 I want to know if documents involving 23 NRC inspections, these kind of documents that we have 24 been talking about, of Unit 1 facilities would be
/~% 25 posted in any' facilities involving Unit 2?
9
1 Harbin 199 2 A Yes.
f
\2 3 Q And where would that be?
4 A I don't know.
. -) 5 Q Did you post them?
6 A I posted these documents for a specific period 7 of time. I no longer post them.
8 Q During the period of time that you 9 posted the documents, did you post them in any Unit 2 10 facilities?
11 A Not that I recall.
12 Q Did anyone at your direction post them 13 in Unit 2 facilities?
O I don't recall.
I g 14 A 15 Q But did I understand your testimony to 1G be that the documents were posted in Unit 2 facilities?
17 A It is my understanding that to the present day 18 documents have been posted in Unit 2, these type 19 documents.
20 Q Do you know how that would happen? In 21 other words, do you know how a document such as this 22 would get.to somebody who would post it in Unit 2 23 facilities?
j 24 A No, I don't know that.
l 25 Q How is it that you know or understand that i
4
, - - . . - -- -.y- 3 y 7- me-- + etu-u
1 Harbin 200 2 they have been posted in Unit 2 facilities?
%- 3 A Because I have had discussions with the 4 supervisor of Licensing in Unit 1 as to how these
) 5 get posted now and since -- since the time that I 6 was responsible for posting them.
7 Q When did you cease being responsible for 8 posting these documents?
9 A I don't recall.
10 Who picked up that responsibility from Q
11 you?
- 12 ' A The Unit 1 Licensing Department.
i
, 13 But you don't recall when that occurred?
Q 14 A Not the date. .
15 Do you recall generally when it occurred, Q
16 the month?
17 A No.
1 18 Q Do you recall the year?
19 A No.
l 20 Q Do you recall whether it was before 21 Three Mile Island, the accident at Three Mile Island?
22 A Yes, I recall that it wasn't.
23 It was not?
Q 24 A That's correct.
(~) 25 -
Q You recall then that it was after the
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-yy- c *-m- ,y ..v~. e ~ - -
1 Harbin 201
~2 accident at Three Mile Island that this responsibility
)
s -
3 was assumed by Licensing?
4 A Yes.
5 Q Lo you know why Licensing assumed this 6 responsibility for posting?
7 A- Yes, because they had a department on site.
8 Q They did not have a department on site 9 prior to the accident at Three Mile Island?
10 A That's my understanding.
11 Q Who was it you talked to in Licensing?
12 A Roy Harding. ,
I f 13 Q Why did you have this conversation t-i
()~ 14 with Mr. Harding? "
f 15 A It was a conversation relating to turnover of 16 the responsibility.
17 Q And during that conversation he told you 18 that the documents would be posted in Unit 2 facilities; 19 is that correct?
20 A Uo, I don't believe so.
21 Q Is this the same-conversation where you
( 22 learned that the documents were going to be posted 23 in Unit 2 facilities?
24 A No.
(~g 25 Q When did you learn that~ the documents A_)
g l *
'l Harbin 202 2 were posted in Unit 2 facilities?
t
\ A Sometime before that conversation.
3 4 Q From the same individual, from Mr. Harding?
5 A No.
6 Q Who did you learn it from?
7 A I don't recall, 8 Q You don't know his name?
9 A I don't recall who it was.
10 Q Did I understand you to say that it was 11 the supervisor of Licensing or to give a job title?
12 A Yes, I believe that that was his title, the 13 title of Roy Harding.
' O(_j 14 Q The title that Roy Harding held?
15 A Yes. At the time of that discussion.
16 MRS. VAUGHAN: Off the record.
17 (Discussion off the record.)
18 Q Mr. Harbin, from whom did you learn that 19 the documents were posted in Unit 2?
20 A I don't know for a fact that the documents were 21 ever posted, have ever been posted in Unit 2. It 22 was my understanding at some point prior to the 23 conversation that I had with Roy Harding that in 24 addition to the bulletin board in Unit _1 service 25 building there would be built or displayed at several 9
203 1 Harbin 2 locations in both Unit 1 and Unit 2 bulletin boards
\ #= 3 to be used for posting information for employees 4 and that the Personnel Department on site would be 5 responsible for all documents which were posted on 6 any of the bulletin boards.
7 Q Did you understand that the documents 8 relating to NRC inspection reports dealing with Unit 1 9 would be posted at those locations?
i 10 A could you please repeat that?
11 Q Yes.
12 In other words, did you understand that 13 the bulletin boards that were to be built and on 14 which items were going to be posted would include 15 items such as Exhibit 207?
i l 16 A I don't believe I ever had that thought go 17 through my mind.
18 At the time that I heard that there was.a plan r
19 to have such a program and to have built and
- 20 maintained these controlled bulletin boards, it 21 was my feeling that this was the kind of thing 22 that should be-posted on those bulletin boards and 23 I pursued -- I_ guess insuring that there was a 24 mechanism for getting'these documents to personnel 25 and having them posted. -
e- -- e =mr= -m y -- - y +
1 Harbin 204 2 Q Did this understanding which you
, m
- 3 attained come about after the accident at Three Mile 4 Island?
) 5 A What unde rs tanding ?
I 6 of the bulletin boards that ere to be Q
7 built.
8 A Yes.
9 Q It was all after the accident at Three 10 Mile Island?
i 11 A Yes.
j I
12 Do you know yourself whether these reports J Q i
13 that were posted such as B&W Exhibit 207 marked 1
[)
%.j 14 for id entifica ti on relating to Unit 1 were in fact 15 posted at Unit 2 locations before the accident at 16 Three Mile Island?
17 A I don't know that they were and I don't know 18 that they were not.
4 19 Q All right. Do you know whether there 20 existed any kind of a mechanism to get these reports l
g 21 to Unit 27
) .
22 A No, I don't.
- 23 Q Do I take i t from your answer then that 24 you never forwarded to Unit 2 any of these notices 25 of violations or any of these NRC reports?
)
e g - - , , _ + ,
1 Harbin 205 2 A I don't recall whether I did.
ij 3 Q Nere you involved in any way, other than 4 reviewing for posting requirements, with NRC inspections?
5 A Could you please rephrase that?
6 Q I can repeat it.
7 Were you involved in any way with NRC 8 inspections other than reviewing, for purposes of 9 posting, what we have just been talking about?
10 A During what period of time?
11 During any time of your employment.
Q 12 A Yes.
13 Q In what way would you be involved in
/^\
(,) 14 the NRC inspections?
15 A I have had interviews with NRC inspectors as 16 part of the inspections, I have been a member of 17 meetings, both entrance meetings and exit meetings 18 held prior to and following the inspection itself.
19 As I said before, I have reviewed other l
20 portions of the inspection reports other than the l
! 21 violations or apparent violations themselves. I 22 have assigned action based on NRC inspection exits 23 and inspection reports.
24 Have you engaged in these activities on Q
("T 25 your own behalf or were you standing in for the Unit 1 N-]
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~
l Harbin 206 2 superintendent?
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- J
\ 3 A Both.
l 4 Q Can you distinguish those times when you
) 5 were there on your own behalf from those when you 6 were there for the Unit 1 superintendent?
7 A I can recall a specific instance.
3-8 Q Were there any -- excuse me.
1 9 A I might be able to.
10 Q Were there any items arising from an NRC 11 inspection as to which you could not be there for 12 yourself? In other words, was there a type of item 13 that required the Unit 1 superintendent to be there or
-0j
, 14 types of items that were clearly within your areas of Ns 15 responsibilities for which you would be representing 16 yourself?
17 A At what?
18 Q At these NRC inspections or in any of 19 the dealings that you have just described involving
, 20 NRC' inspections.
I 21 A Yes.
22' Q What types would those be?
( 23 A Could you please ask a specific question?
24 Q I don't know any specific. I am asking fw 25 you to describe them.
l r
(-
l 9
1 Harbin 207 2 You have been involved in those meetings, O
C# 3 I haven't.
4 A Wel4, we are talking about a lot of meetings.
l ) 5 Q But we can focus --
6 A We are talking about entrance meetings, exit-7 meetings, we are talking about meetings with specific 8 NRC personnel as part of an inspection and I would 9 just like for you to be a little more specific as 10 to --
11 Q But we are talking about the NRC 12 inspections as a group and we are talking about
! 13 notices of violations or whatever kind of reports the
(/)
~_
14 NRC would write resulting from those inspections.
15 Now, if the NRC noticed a violation 16 dealing with a component of some kind would you be 17 present at that for your own purposes?
18 MR. MacDONALD: You mean in his own 19 capacity as assistant to the superintendent?
20 MRS. VAUGHAN: That's right.
3 21 , A I don't recall any instances.
b 1 I **
Q Of being present?
I 23 A of being present.
24 Q Do you recall sitting in for the Unit 1 l
fs 25 superintendent at a time when it involved some kind
.' ( )
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1 Harbin 208 5
2 of a component violation or violation involving a
/ 3 component of some kind?
4 A No, not that I recall.
i 'N
- / 5 Q would NRC inspections deal with matters 6 of personnel? Would that be the area in which they 7- would get into in these inspections?
l 8 A I don't recall any ins *.ances of their taking 1
9 an interest in personnel.
10 Excuse me, could you define personnel?
j 11 Q Personnel matters as for example the 12 one we talked about this morning when you were talking 13 about personnel management. I am not talking about 14' now about personnel errors in terms of an operating 15 error or something like that, I am just talking about 1
16 matters dealing with personnel.
17 - MR. MacDONALD: As opposed to components?
18 MRS. VAUGHAN: That's right.
19 A T recall that they have taken an interest in 20 our working limitations.
l g 21 Q But that's not the kind of thing you j 2. "
22 would be involved in.or you would be there on your own j 23 behalf for?
24 A I don't recall if I w a s .-
25 Q Mr. Harbin, in your review of the mail-
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1 Harbin 209 l
2 which the Unit 1 superintendent would receive, was~~~
3 there any time at which somebody would put a time 4 limitation on how long it would take you to review
) 5 that mail?
6 A No, I don't recall any time limitation.
7 Q In other words, you don't recall Mr. Colitz 8 ever saying to you the mail comes in on day one, 9 by day three I want it to have been gone though and 10 disposed of as appropriate?
11 A No, but it was a standard practice to take 12 some action on all incoming correspondence the same 13 day.
() 14 Q Was there any system for logging in the 15 publications that were received by the Unit 1 16 superintendent that you reviewed?
17 A Up until today?
18 Q That's right.
19 A Yes.
20 Q Could you describe those systems and i 21 tell me during what time they were applicable if 22 there have been different systems?
23 A I keep a log of all bulletins, circulars and 24 notices that is a matrix that provides the notice,
' 25 bulletin or circular number, a very brief description K
+~ --w,-
1 Harbin 210 2 of the event, the date of the document that it was O 3 issued by the NRC and sometimes who it was assigned 4 to in our organization.
5 Q How long have you kept that log?
6 A For 1980 and 1981.
7 Q Did you keep it before then?
8 A No.
9 Q Did you have any system before then for 10 receipt of NRC circulars, bulletins and notices?
11 A Not that I recall but let me clarify that. I 12 keep that simply to use as an administrative aid so 13 that when I am reviewing correspondence that refers A
(_) 14 to, for example, a notice, by number, and I don't
.15 remember numbers and I can refer to that and jog my 16 memory as to what the subject matter was of the 17 document.
18 Is that your own personal log or did Q
19 somebody else --
20 A That's my own personal log.
21 Does anyone else in your office or in
) Q 22 the Unit 1 superintendent's office keep track in any 23 way of NRC circulars, bulletins and notices that are 24 received?
(~}
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25 A Could you repeat that, please?
_ _ _ , . - ~ , 3 7
1 Harbin 211
- 2 Q Yes. Does anyone else in your office or t .
%' in the office of the unit superintendent for instance, 3
4 his secretary, keep track of NRC bulletins, notices
, f 5 and circulars that are received? i 6 MR. MacDONALD: Keep track of, did you 7 mean in the form of a log of some sort?
8 MRS. VAUGHAN: In any way, yes.
4 9 A I don't believe so.
10 Q And that would be your answer for as long 11 as you have been an assistant to the Unit 1 12 superintendent?
13 A I don't know that.
14 Q You don't know what?
15 A That that's been the case for all superintendents 16 for which I have worked.
l 17 Q Do you know that anyone at any time kept 18 a log or had any system by which they would record l 19 receipt of NRC's bulletins, circulars or notices?
20 A Yes.
21 ,Q And who was that or what is the system?
22 MR. MacDONALD: That's two separate l
( 23 questions.
24 MRS. VAUGHAN: Well, whichever one is l
' 25 the appropriate answer.
O-w -'7"-9
1 Harbin 212 2 A I don't know who by name.
\- 3 Q Who by position?
4 A I don't know who by position.
5 Q How dc you know it is that somebody has 6 kept track of them?
7 A Because I have received copies or a copy of a 8 typed matrix that listed various bulletins or 9 circulars or notices, I don't know which, and made 10 some indication of whether a response has been 11 made.
12 po you recall when that was?
Q 13 A That I saw that?
(~N 14 t
( ,/ Q Yes.
4 15 A Not specifically.
16 Q How about generally?
17 A Since'the accident, the TMI-2 accident.
18 Q So you have no knowledge today of anyone 19 before 1980 keeping track in any way of NRC notices, r
l 20 bulletins and circulars.that were received by the l
21 Unit 1 superintendent other than what you just 22 described?
l l 23 MR. MacDONALDr No knowledge or no l
l 24 recollection?
^
25 MRS. VAUGHAN: If he has knowledge then s- .
I'
1 Harbin 213 2 he will have recollection.
l,
'- ' 3 A As I said yesterday, the corporate office in 4 Reading and specifically the Licensing Department, s s
/ 5 had the responsibility for receiving and responding 6 to bulletins, notices and circulars where applicable 7 and I know that at some point in time they have had 8 systems for tracking those, that's not my department 9 and I am not familiar enough with their system or 10 systems to make comments on it.
11 Q How about focusing now just on your 12 department and just on the publication Atomic Energy 13 clearinghouse, (j 14 A Yec. !
15 Q Did you keep or did anyone eltre within 16 your department keep a log which would show receipt i
17 of that document?
l 18 A Not to my knowledge.
19 Q or any kind of a system which would show 20 receipt _of that document?
21 A Not to my knowledge.
22 Q Just so I understand it completely, that 23 document came directly to the Unit 1 superintendent-24 so that i fI were looking for a log I would look in 25 s
^] his office rather than it being distributed to him i
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'l Harbin 214 2 from somebody else?
O 3 MR. MacDONALD: Do you mean exclusive 4 of anybody else in the company, one superintendent 5 that was ever on distribution?
6 MRS. VAUGHAN: My question is only to 7 focus on the fact that the Unit 1 superintendent 8
received it not necessarily exclusively but 9 directly addressed to him. In other words, 10 attached to the Atomic Energy Clearinghouse 11 would not be a stapled sheet of paper where 12
, somebody has written declaration of distribution, 13 there would be a mailing lable that says either
( 14 Unit 1 superintendent or the name of the 15 individual as such.
16 Q That's what I mean when I say directly 17 received.
18 A For copies of that document that were received 19 by him, there was no mechanism, to my knowledge, 20 to keep track of which ones had been received or '
21 to document the receipt of those documents. 2 i
22 And you yourself kept no personal track Q
23- of which ones you had looked at? '
24 A That's correct.
~
25
- {x-}, , Q 'Just again so that we are clear, do you
-.= ,
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2 have any recollection ,att all of any time when that ,
5
-.3 - -
3 document was not received directly by the/ unit 4 superintendent as we have just described it?' -
l fi A I don't know.
/ ,
/ ,
6 Q In other words, you have no knowlsdge ,e 7 that at some point in time that document was sent to j 7
+
8 'the unit superintendent from the library in Reading i'
' G- or from' CPU or from somebody else; is that correct?
- ' /,
s 10 / Is that your' testimony?
11 A , My _ testimony is that I know that for some \;
/
12 period of time the document was received,directly (
,;- 7 i :
by the unit superintendent.
13
\r- .jf All right,
/
14 Q f f
>; ~
15 A From the publisher. ./
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, 16 Q All right, g
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. '!i f 17 2 ,
Do you know that for some period of time $
4 1 h
18 it was received from an internal source by the Unit 1 -
k s ..
10 superintendent? r
,I 20 A j 'No , I don't. ;)
21 Q .How about the Current Events-Power Reactor ,
22 document, was that document received directiygby 23 the Unit 1 superintendent as we have just been *
/
24 - discussing it, or describing it would be a be'tter word?
p 25 MR. MacDONALD: That's thdl, Current v
i
' 9 s
k 3 , - . . . . -- . - - . . -- - - . . - .ee
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1 Harbin 216 fk Ni,'[/ ) #
4
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2 Events-Power Reactor?
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3 mas. VAUGHAN: Yes.
.',I q i ) \, 4 Q In other words , did the Unit 1 superintendent 4 ., ,%
f/t jI 5 receive that document directly, a mail label, as
(/[ir 6 opposed to being on a distribution list from some i .
- /, ', 7 other internal source within?
- j f'b ! ' 8 A For some period of time, yes.
J' j 9 Q Was there any period of tim'e which you l 10 are aware that he received it from an internal source?
/s'
{
11 A Yes.
12 Q What period of time?
e l -
4/' 13 A Let me retract the question and say there l
) 14 were selected documents that he received from other 15 sources within the company and that may have been in 16 addition to having received them from the publisher.
i 17 Q Was there a log kept by you or by anyone i .
- 18 else that you know of with regard to his receipt of, i- 19 first of all, the Current Events-Power Reactor from L ,, 20 the publisher itself?
i
?4 d 21 A No, I don't know of any log.
22 Q Yo.u never kept a log or any system that 23 would keep track of it? I used the word log, but I
'+
=
24 don't mean to preclude you'from any other systen that 25 _ might be applicable.
1 i
l J
1 a
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1 Harbin 217 2 A It was the general practice to maintain copies 3 of the document.
4 Q Itself?
5 A Yes.
6 Q Would the document have a date on it on 7 which it was received?
8 A It's never been the standard practice of anyone 9 in my office or the superintendent's office to 10 stamp a document upon receipt.
11 Q So that there was not a log as such but 12 the documents, the Current Events-Power Reactors 13 were maintained, were kept?
() 14 A Yes, that's correct.
15 Q How about those Current Events-Power 16 Reactors that came from other sources within the 17 company? Was there a log or any system of noting 18 when they were received?
19 A Not to my knowledge.
20 Q Were those documents also kept?
21 A I don't know.
}
22 Q Do you know who else within Met Ed or 23 GPU received the document Current Events-Power 24 Reactors?
25 MR. MacDONALD: You are making that a
.O l
e y, __m______ _ _ - - - - - - - - - - - - - - - - - - - - - - -
i 1 Harbin 218 2 distinction now from internal or external?
3 You have been. I am just asking whether or 1
4 not --
g
/ $ MRS. VAUGHAN: No, I am not.
6 A No.
7 Q No, you do not know if anyone else 4.
8 received it, is that what you mean?
9 A Excuse me, can I --
10 Q confer with counsel?
11 A Yes.
12 Q Sure. ,
1 13 (witness conferring with his counsel off 14 the record.)
15 A Yes. The answer is no.
16 Q No, you do not know that anyone else 17 received the publication Current Events-Power 18 Reactors?
19 A That's correct. -
20 Q Have you heard that anyone else received 21 that?
22 A Not that-I recall.
23 Q Did you undertake any kind of an 24 investigation or survey or anything to determine
/~N- 25 whether anyone received that?
t] .
L l
,- . -_ . , . - ~ . , - ~
1 Harbin 219 2 A No, not that I recall.
' O 3 Q Am I correct that when reviewing either 4 the Atomic Energy Clearinghouse document or the 5 Current Events-Power Reactors document that you never 6 received any instructions from anybody as to what 7 kind of things to look for in those documents at 8 any time during your employment?
9 A Could you repeat th'at again, please?
10 Q sure.
11 Am I correct that in reviewing the Atomic 12 Energy Clearinghouse document or the Current 13 Events-Power Reactors document you never received 14 any directions or any instructions from anybody as
, 15 to what kind of things you should be looking for 16 when reviewing those documents?
17 A I don't recall receiving any specific written l 18 3 or oral instructions from any superior, but based 19 on my previous experience in the Navy and the 20 training that I received when I first came to the l
g 21 company and my knowledge of the plant after receiving 22 that training and my knowledge of the organization, I 23 considered that training and I think I used the term 24 "on the job training" yesterday, also the fact that l
l 4
w . - re -- , ,
1 Harbin 220 2 making it very clear to members of the staff that
,/
\-) 3 documents were normally routed to, that if there was 4 ever a problem with an assignment made that they 5 should inform me of that and I don't recall ever 6 being informed of any such problems.
7 So, I think from that standpoint that was 8 positive feedback, that assignments were being made 9 correctly.
10 Q How did you determine what it was that 11 you should be looking for or what it was that you 12 should highlight in any of those documents? If you 13 didn't receive instructions from somebody else and (n) 14 you looked to your own experience, what kind of 15 guidelines did you set for yourself?
16 A Of the events or findings that I recall 17 reviewing, most could be categorized as examples 18 of categorizations would be component failures, 19 events that resulted from operator error or 20 procedural inadequacies, those are three examples.
l N 21 Q Would you focus on any report of I
)
22 something involving a component or would you limit it 23 in sono way to a level of seriousness which you
- 24 had determined was appropriate?
l 25 A Let me finish answering.
(')s
(_
4
1 Harbin 221 2 Q I am sorry, sure, s_/ 3 A And based on my knowledge of the plant staff 4 and the fact that taking the example of component
) 5 failures, I was usually aware of an engineer or 6 some individual in the plant staff that I would 7 consider cognizant in that area, that area of 8 expertise who could best make a determination in
, 9 reviewing a document, the incident of finding, 10 the extent of applicability and the importance for 11 example on nuclear safety.
12 Q Does that mean that every component 13 failure was routed to somebody, every report of a
()
/~'
14 component failure was routed to somebody within 15 Met Ed by you?
16 A Listed in the two documents, Atomic Energy 17 clearinghouse?
18 Yes, and the Current Events-Power Reactors.
Q 19 A No, I don't think you can say that.
20 Q Some were not routed; is that correct?
21 Some reports of component problems were not routed 22 by your is that correct?
23 A I don't know that.
i 24 Q I am just trying to get at how you would 25 determine which ones to send and which ones not to O
9
1 Harbin 222 2 send, or send on. .
3 A Yes.
4 Based on my knowledge of the plant and my
) 5 background and the failure event or finding in 6 question and its significance on nuclear safety 7 or plant availability, I would make a decision that 8 it was either worthwhile for further review or not.
9 Q How would you measure its significance?
10 A Let me make one comment.
11 Q Sure.
12 A Referring to significance of events and ,
13 findings, although we are talking about two documents,
( 14 the Atomic Energy Clearinghouse and Current Events-Power 15 Reactors, I am no't sure why you categorize, you 16 lump those two documents into the same categorization, 1
17 but at the time that I reviewed those documents it 18 was at the time of the accident, I considered 19 events listed in the Atonic -- excuse me, retract 20 that --
listed in the Current Events-Power Reactors
} 21 to have more significance, more potential for 22 significance on nuclear safety than information 23 listed in the Atomic. Energy Clearinghouse. In 24 addition to that I looked at or considered information 25 that was reported in bulletins and circulars to be
(~3'
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1 Harbin 223 f
f 2 the primary source of information relating to events
/ and findings of nuclear safety significance and 3
4 also letters from correspondents from B&W, and T/
5 although the publication Current Events-Power Reactors 6 contained information on events of nuclear 7 significance, I perceived those reports to be 8 repetitive or additional information or supplemental
. 9 information to what was contained in bulletins and 10 circulars.
11 Q The Current Events was published by 1
12 the NRC, was it not?
13 A That's my understanding.
() 14 Q And it is still?
15 A Yes.
16 Q Does the Current Events contain more 17 information, would you say, then the NRC bulletins, 18 circulars and notices?
19 A I don't know that.
20 Q How frequently do the bulletins, circulars 21 and notices come out?
i 22 A It's been my perception that 25 bulletins a l
23 year will be generated, maybe the same -- the same l
24 number of circulars, and I would estimate 40 notices.
25 l
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Q Are these publications the bulletins, l
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l 1 Harbin 224 2 circulars and notices issued on a regular basis or
(~h k- 3 as I would deset?.be as an as needed basis?
4 A On an as needed basis.
s,
) 5 Q And the Current Events is something that 6 comes out regularly; is that correct? '
7 A Yes,.that's my understanding.
8 Q Do you know how frequently that comes 9 out?
10 A I don't know.
11 Q In your review of these documents, these 12 two documents, and I am not lumping them together 13 for any particular reason, they just happen to be
( 14 the ones that you indicated you received or the l 15 Unit 1 superintendent received and you reviewed on 16 a fairly regular basis before the accident at Three 17 Mile Island, when you would note something in either 18 of those two or sending something on to somebody else, 19 would that ever involve anyone from Unit 2 or were 20 you limited only to Unit 1 people? .
_21 A What documents are you referring to?
)
22 Q The Atomic Energy Clearinghouse and 23 the Current Events-Power Reactors.
24 A I do recall routing the Atomic Energy Clearinghouse l
I l (N 25 to Unit 2 personnel. I don't recall with respect to I \-]
l -
,y- r- - -
w - - 4 - - ---a m 't- -
1 Harbin 225 2 the Current Events-Power Reactors, f~
3 Q Do you recall when you routed the Atomic 4 Energy Clearinghouse to Unit 27 5 A I don't recall the specific period of time.
6 Q Was it a period of time for a certain 7 number of months?
8 A Yes, it was.
9 Q Was it during 1977?
) 10 A I don't recall.
11 Q Would it have been before Unit 2 had, 12 at least according to our organization charts, an 13 individual in the same job slot you are in, that is f's Q' 14 an assistant, Mr. Shaffer?
1 15 'A Yes, I believe so.
( 16 Q Do you recall to whom you circulated it?
17 A I recall circulating it to John Brummer, i 18 Dick Bensel. I don't recall any other names. 2 19 Q Do you recall what their job positions -
]
90 were at the time you circulated it to them? -
s l
t g 21 A I recall routing them to the lead electrical 22 mechanical and I&C enginecrs.
1 23 Q 'I and C7 24 A I & C, instrument and control.
t
/~s 25 Q Did you route it for a period of time 4
n-+- --w , - , w w - --se - . - -
e -,-av e rw - - - - - - - - - - -
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I Harbin 226 i i
I l 2- on a regular basis to them, the Atomic Energy q
3 Clearinghouse document?
4 A Depending on whether there was anything contained 4
5 within the document that I considered to be of 6 interest to them.
7 Q Were you instructed to route it to them 8 or did it just occur to you that they were interested 9 in something?
10 A No, I don't recall receiving ar.y instructions 11 to route it to them.
i 12 You just knew that they were involved in
-Q 13 something and you saw an item of interest and you 14 sent it on to them; i s that correct?
15 A Yes, that's correct.
16 Q Do you know if Unit 2 received the Atomic 17 Energy Clearinghouse document? In other words, do 18 you know whether Mr. Miller received a copy of the 19 Atomic Energy Clearinghouse document while he was 20 Unit 2 superintendent?
21 A No, I don't.
22 Q Lo you know if Mr. Logan received copies i
23 of the Atomic Energy Clearinghouse. document.while he 24 was the Unit 2 superintendent?
l 25 A No, I don't. '
b i
4
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1 Harbin 227 2 Q Do you know if either Mr. Logan or
.f~
\s, 3 Mr. Miller rueelved copies of the Current Events-Power 4 Reactors?
5 MR. MacDONALD: Your original question 6 was whether Unit 2 received it and then your 7 subsequent questions are Miller and Logan.
8 Are you attempting to limit it to Unit 2 having 9 received i t or not received it because those 10 two individuals did or did not receive it?
11 MRS. VAUGHAN: I think I struck the first 12 part and meant to say only --
13 Q My question is: Did you know whether
() 14 Mr. Miller as Unit 2 superintendant a copy of either 15 of those publications?
16 A Oh, either.
17 Q Either Atomic Energy Clearinghouse and 18 we were ge tting into the Current Events publication.
19 A I don't know that.
20 Q Do you know whether Mr. Logan ac 21 Unit 2 superintendent received either of those 22 publications?
23 A No, I don't.
24 Q Did you ever route to either Mr. Miller 25
('N
\_)
or Mr. Logan copies of the Atomic Energy Clearinghouse
,i - ,-y , %e s , - . - - - - - rw,-- m -
1 Harbin 228 2 or Current Events publications while they were n
3 superintendents of Unit 2?
4 A I don't recall.
) 5 Q Do you know whether anyone else within 6 Unit 2 would receive copies of either the I.tomic 7 Energy Clearinghouse or the Current Events-Power 6 Reactors documents?
9 A No, I don't know.
~
10 Q would any of the department heads to 11 which you would route either the Atomic Energy 12 Clearinghouse or the Current Events document or 13 any of the other documents that you might have been s
14 routing have responsibilities over Unit 27 15 MR. MacDONALD: Are you'asking if they 16 did?
17 MRS. VAUGHAN: Yes.
18 A I don't recall.
19 Q You don't recall.if they did or did not 20 or you --
21 A I don't recall if I routed any documents to 22 department heads that had responsibilities over
. 23 Unit 2.
24 Q were there department heads thst had i
25 responsibilities over Unit 27 4
I
'l Harbin 229 i
2 A Yes.
3 Q Would they have responsibilities as 4 well over Unit 17
, ) 5 A Yes.
! 6 Q Which department heads were they? Not j 7 by name but by position. '
8 A I don't recall the position at the time. The 9 ' functional position was supervisor of maintenance.
10 Q Anyone else?
11 A Station manager. The supervisor of training.
t 12 That's all I recall.
i 13 MRS. VAUGHAN: All right, why don't we
, 14 take a break for lunch.
15 (Luncheon recess taken at 12:38 o' clock P.M.)
I 16 17 i ,
. 18 19
~
20 21
.22 l
l 23 24 O
i
1 Harbin- 230 2 AF TE RNO O N S E S S I ON r
f 3 (2:02 o' clock P.M.)
4 RONA LD S TE PH E N H A RB I N , having
~). 5 been previously duly sworn by a Notary Public, 6 resumed and continued to testify as follows:
7 EXAMINATION (continued) 8 BY MRS. VAUGHAN:
9 Q Mr. Harbin, during 1977 was there 10 anyone performing your duties with respect to reviewing 11- mail or publications that came in for Unit 27 12 MR. MacDONALD: The duites that he had 13 for the Unit 1 superintendent, does he know of 14 anyone performing them for the Unit 2 f 15 superintendent?
16 MRS. VAUGHAN: I am not limiting it 17 to the superintendent. I am focusing basically 18 on the duties and if they were performed by 19 somebody else for somebody else, that's fine.
l 20 A Not that I recall. ,
21 was there a Unit 2 organization of some
) Q 22 kind in 19777 23 A Yes.
l 24 Do you know how, within Unit 2, publications Q
25 like the'ktomic Energy Clearinghouse and the Current
(-)/
\-
, ,e--- w W+ - %'-- s -
1 Harbin 231 2 Events-Power Reactors would be circulated or items
. [^h
(_)
3 would be highlighted and then circulated within 4 Unit 27 5 A With regard to Current Events-Power Reactors, I 6 don't know.
7 With regard to the Atomic Energy Clearinghouse 8 document, I have already stated that during some 9 period of time, and I don't recall if it was 1977 10 specifically, I routed that document to the people 11 that I listed who were individuals assigned to Unit 2.
, 12 Q All right. Would your answer change, 13 be any different for 19787 14 MR. MacDONALD: Which part of his 15 answer?
16 MRS. VAUGHAN: Both parts, the one about 17 the Atomic Energy Clearinghouse document and 18 the one about the Current Events-Power Reactors.
19 A My answer would be the same with respect to
- 20 Current Events-Power Reactors and I don't recall the 21
) time period with respect to the At,omic Energy 22 Clearinghouse.
23 Q Were there any other publications that 24 you recall routing to anyone at Unit 2 other than 25 the Atonic Energy Clearinghouse in any of the years
}
r
1 Harbin 232 2 in which you were an assistant to the superintendent q
3 of Unit 17 4 A Yes.
5 Q Which publications were they7 ,
6 A One that I recall was Federal Register.
7 Q Any others?
S A I don't recall any others, I
1 9 MR. MacDONALD: Before we go on there 10 was just something I wanted to clear up 11 and I would have done it before this afternoon 12 but he forgot about it.
13 Mr. Harbin has in the course of the 14 last day's deposition recalled -- you had a 15 question yesterday that related to other 10 bulletins or pamphlets or publications 17 other than the ones you had listed yesterday 18 that he recalled receiving on a sonawhat 19 regular basis, he has recalled a few others 20 that he would like to add to the record so
} 21 that you are aware of that.
22 MRS. VAUGHAN: That's fine.
23 MR. MacDONALD: I thought this was as 24 good a place as any.
/~N 25 MRS. VAUGHAN: It's a fine time.
_ _- - - ---- -- )
1 Harbin 233 2 Q Go ahead, Mr. Harbin.
s 3 A Nuclear related or industry related publications 4 were Electric Power and Light, Power, Simply Power, 3/
5 Power Engineering, Nuclear News, Nuclear Technology 6 and Atomic Industrial Forum publications. Also 7 EPRI reports. That's all I can think of right now.
8 Q Are these publications that you have 9 just listed publications that would be received by 10 the Unit 1 superintendent?
11 A Not necessarily.
12 Q If they weren't received by the Unit 1 13 superintendent, how did they come to you?
( 14 A They were addressed to me.
15 Q Are they ones that you ordered 16 specifically for your own purpose?
17 A Excuse me, let me restate that.
4 18 They were either addressed to me or routed 19 to me.
20 Q When you use the word " routed," you 21 mean from an internal Met Ed or GPU source?
g 22 A Yes, that's correct.
23 Q If they were addressed to you, were they 24 publications that in your experience you had
(~N 25 determined to be worthwhile receiving and then you
\_
1 Harbin 234 t
2 went ahead and ordered them?
s
\~ 3 A I ordered them based on a determination that 4 they may be worthwhile reviewing.
5 Q Would you review them yourself and 6 then if there was an item of interest to pass it on 7 to somebody else?
8 A If there was an item of interest to someone i,
9 else that I felt was job related, then I might have.
10 That was the standard -- my standard practice.
11 Q Do I understand, however, that in terms 12 of passing publications on to others it was the i
!. 13 Atomic Energy Clearinghouse and the Current Events
(~N
( j) 14 and the NRC bulletins and circulars and notices that 15 you would more frequently refer to? Is that a 16 correct statement?
17 MR. MacDONALD: I don'c know what you 18 mean by refer to.
10 Q More frequently rely on would be a 20 better word.
21 A Well, we had a discussion before lunch on -- you l
22 used the term reliability, I believe you used the i
23 term significance to nuclear safety and I don't 24 think I --
let me just restate that and be a-littla.
25 more clear or be clearer than I was before lunch, (v)
i
~
l l
1 Harbin 235 2 I considered the NRC bulletins, circulars
~O 3 and notices to be the most reliable source of 4 information in terms of depending on being notified 5 of events and findings at other plants, and with G respect to events at other B&W plants I relied 7 primarily --
when I say primarily I don't mean more 8 than relying on bulletins and circulars and 9 no tice s -- on either the weekly B&W newsletters
[
10 or on correspondence from B&W and it always -- it 11 h'ad been my perception for some period of time 12 that B&W performed a service as a focal point for 13 information for B&W plants, a primary example of 14 that is the fact that they held periodic B&W users s
15 meetings, they coordinated those meetings, and some 16 of the other sources of information I just gave some 17 examples of some additional ones that I hadn't 18 thought of yesterday, for example Nuclear News, l 19 although those publications may have contained i
20 information additional to information contained in bulletins and circulars and B&W correspondence.
]) 21 22 There were of ten items of interest both to i
i f 23 me and members of the plant staff, I didn't consider 24 those reliable from the standpoint of what we really 25 should be aware of.
=
0
- - - - - _ _ ,-., ,_ , , . 4 -
.-_ - .. -_. -_ . - - - - - . _ - . _ . ~ ., - -_ .-
1 Harbin 236 2 Q Did you consider Atomic Energy Clearinghouse O 3 reliable in terms of what you should be aware of?
l 4 A In that sense how do you define reliable?
5 Q In the same sense that you were using ,
i G it before when you talked about Nuclear News.
7 A No.
! 8 Q You did not?
9 A That's correct, i
10 Q What about Current Events-Power Reactors?
11 A Yes, I did, but realizing that that was an 12 after the fact notification of events from the 13 standpoint of timely notice, I didn't consider it 14 reliable.
- 15 Q From whom did you get your understanding 16 that the NRC bulletins, circulars and newsletters r
17 and the B&W weekly newsletters and correspondence
, 18 were the most reliable sources of information for 19 you to consider?
20 A Through my experience in reviewing those 21 documents.
22 Q Did anyone tell you that, that that was i 23 to be your understanding?
l l
24 A Not that I recall.
25 Q Did you' consider yourself'at that time S
. . . , - - . - , , - - , , , e ---r- m- n.~., - +--
i .
1 Harbin 237 2 to be the focal point of the information flow about Os 3 what was going on at other B&W facilities or any 4 other facilities?
5 MR. MacDONALD: For Unit 17 6 MRS. VAUGHAN: For Unit 1.
7 A No.
8 Who or what would you have considered to Q
9 9 be the focal point for information spread?
10 MR. MacDONALD: Assuming there is one.
11 MRS. VAUGHAN: I am sorry?
12 MR. MacDONALD: That's assuming there 13 is one.
14 MRS. VAUGHAN: Right, if he isn't.
15 A Of what kinds of information?
16 Q Of the kind of information that we are 17 talking about, that one would pick up in a B&W 18 newsletter or any of these publications that we 19 have been talking about and the circulars and the 20 bulletins and so on.
) 21 A It would depend on the document. Some of 22 the documents that we have discussed I was the focal 23 point in Unit 1 for reviewing those and making the 24 determinations that we have discussed on further j
25
}_ reviews and/or action.
e
1 Harbin 238 2 For some correspondence and information that
[
3 we have discussed, for example correspondence from 4 B&W, I would consider the focal point to be the 5 addressee of the letter and the general practice 6 was over periods of time to have a single addressee 7 within the company te which B&W would send their 8 correspondence. I would consider that individual 9 'the fo cal -- focal point.
10 There is other information that is related in 11 these documents that may be discussed verbally with 12 people like -- such as the superintendent or the 13 manager of operations.
() 14 In that respect I would consider, for example, 15 the manager of operations a focal point for 16 information.
17 Q If you saw correspondence from B&W would I6 that mean that it was addressed to the Unit 1 19 superintendent?
20 MR. MacDONALD: As a primary addressee 21 now?
22 MRS. VAUGHAN: Yes.
23 MR. MacDONALD: Not as a cc.
24 Are you asking did that happen rather 25 then a hypothetical if.
O O
"I- - . . . . . . . . .
1 Harbin 239 i
2 THE WITNESS: Could you repeat the
,O' 3 question?
4 MRS. VAUGHAN: Let me ask you this:
5 Q You indicated that you would censider 6 the addressee of correspondence from B&W to be the 7 focal point for that particular information; is 8 that not correct? You didn't say that?
9 A That's right, I didn't say that.
i 10 Q Ther. with regard to that who would you 11 consider to be the focal point of a letter from B&W7 12 A I said that the addressee would be a focal 13 .
point, not the focal point.
f' 3
(,j 14 Q I tend to think of a focal point as one 15 particular person but who else would you consider 16 to be a focal point?
- 17 A A focal point may be --
in some cases the i
- 18 focal point is an individual on a cc list of a piece l 19 of correspondence.
20 Q With regard to the Atomic Energy i
j
) 21 Clearinghouse publication did you consider yourself l 22 to be the primary person or the focal point for 23 making sure that information got disseminated within 24 Unit 17 A For a period of time, yes. (
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1 Herbin- 240 2 Q Which period of time?
- T
(~/
\~ 3 A I don't recall the period of time.
4 Q Was it before the accident at Three Mile 5 Island?
6 MR. MacDONALD: You mean for the entire 7 period before the accident or just for a <
8 period.
4 9 MRS. VAUGHAN: For whatever period he .
10 is thinking of, did that period exist before 11 the accident at Three Mile Island.
12 A Part and maybe all existed before the accident.
13 Q Is that because after the accident
(' 14 Mr. Carl took over?
15 A I don't recall when he took over.
16 Q But did you consider yourself the focal 17 point for disseminating that information until 18 such time as he took over?
19 A Yes.
20 Q Did you consider yourself the focal 21 point for disseminating relevant information in 22 that, what you considered to be relevant information 23 within the Atomic Energy Clearinghouse 24 publication to Unit 2 at any period of timo?
25 p)
A Yes.
, .,a- -- .g-- --
.wa q-
I Harbin 241 2 Q Which period of time?
O
- 3 A I don't recall the period ef time.
4 Q Again, is it until Mr'. Carl took over?
) 5 MR. MacDONALD: Again the implication 6 could be from the question the entire period 7 of time before or until Mr. Carl took over.
8 I don't think that's what the answers have 9 indicated. There was a period of time, it
'10 doesn't necessarily mean that the entire 11 period of time up until Mr. Carl took over 12 is when he may have performed that function.
13 I just think that if your question breaks it
() 14 down that way the record will be clear.
15 MRS. VAUGHAN: Charlie, could you go back 16 and read his answer to the previous question 17 where I asked him about Unit 17 18 (Question , read by the reporter.)
19 Q For that same period of' time for which.
20 you considered yourself the focal point for 1
21 disseminating the information to Unit 1, did you i
j 22 also consider yourself the focal point for l
l 23 disseminating the information from the. Atomic Energy l 24 Clearinghouse te Unit 27 25 A No, I don't recall that.
e
1 Harbin 242 4
1 2 Q You don't recall what specifically?
O 3 A I don't recall that it was the same period of 4 time.
5 I became familiar with the Unit 1 staff before 6 I became familiar with the Unit 2 staff and therefore 7 I don't recall that my disseminating information 8 to the Unit 2 staff started at the same time as when 9 I disseminated the information to the Unit 1 staff.
10 Q Oo you recall who was disseminating 11 information to the Unit 2 staff, if anyone was, for 12 the period of time that you were not yet familiar 13 with the Unit 2 staff?
14 A Could you be more specific on " disseminating 15 information"?
16 Q The same kind of information we are 17 talking about, the information from the Atomic 18 Energy Clearinghouse.
19 A I don't know if other people did or did not.
20 Q You don't know either way?
) 21 A That's correct.
22 Q And you have no recollection whatsoever 23 as to when you began disseminating information to 24 the unit staff, that is when you became familiar with j ()
%,-)
25 the Unit 2 staff?
l i
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-r Harbiu 243 l N.c ,
, 2 A< That's corrdct.
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Q, Would rtj have been a matter of months 4 after your employNent began? g l
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5 A I don't know.
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6 Q d
-old yjou consider yourself the focal point i )' .-
7 for disseminating information to the Unit 1 staff 8 with regard to items'that appeared in the Current '
9 Events-Power Roactors publication? ,,
10 A Yes, for a period of time.
11 Q And what was that period of time?
12 A Sometime prior to the accident until the 13 present.
t
\_ ' 14 Q But you don't recall what time prior to 15 the accident?
16 A Approximately 1977.
17 Q Did you consider yourself the focal point 18 at any time prior to the accident for disseminating 19 information to the Unit 2 staff from the Current 20 Events-Power Reactors?
} 21 A I don't recall if I ever disseminated any
(
22 information from that publication to the Unit 2 staff.
23 Q Do you recall if there would be a reason 24 why you would not have disseminated any information?
i js 2 25 A Can I recall now of ahy reason why I might not r
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1 Harbin 244 0 -. have?
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3 Q That's correct.
4 In other words , what I am asking is,
~
l 5 would somebody have said to you don't bother thinking 6 about the Unit 2 staff when you read the current
, 7 Events because Joe so and so is already looking at 4
0 that for the Unit 2 staff?
9 MR. MacDONALD: I will object to the
. 10 question. I object to the form. We are here j 'll to deal with what he recollects, what might 12 have taken place or what would have or 13 could have taken place, there is a myriad
() 14 of possibilities. We are here to hear 15 Mr. Harbin's testimony on what he recollects.
16 I think that is what he is supposed to 17 testify about, what he recollects. We are I8 not here to have opinion as he sits here today 19 on various facts and circumstances. We.are 20 here to have his understanding and recollection 21 at the time the events took place.
! 22 Now, you know, within the confines of 23 that, fine, I have no problems with his 24 answering that. . There have been other portions
j 25 of prior depositions in this case where, you 4e y y y --e- e tv ' * *'F+ - "- -
- l. Harbin 245 2 know, we get to a point where it is present 3 opinion testimony that is not allowed to be 4- delved into. I have no problem with his
.. ] 5 understanding of his recollection at any point 6 in time that is a relevant period prior to 7 today but he is not here to give testimony on 8 what he might or thinks may have happened today, 9 what his understanding is right now or what II) his opinion is or what could have taken. place 11 in.1977 or 1978.
12 If he has a recollection of when in '77 13 or '78, what his understanding was at that
() 14 point in time as to the reason why not, if he 15 had a conversation, fine.
16 'MRS. VAUGHAN: I am not asking him to 17 give his opinion on anything. I am-asking him 18 if he recalls today whether there was a reason 19 then that he was not reviewing the Current 20 Events-Power Reactor for anyone at Unit'2, 21 whether it was because ---and'I'am only 22 suggesting the possibilities, I am not asking 23 him to answer one way or the other.
24 Q I am simply suggesting the possibility 25 that somebody else told you sonebody else is reviewing C
'f 1 E H-
____.--.m.m_.m._.i-_ a __m.__ -u_ _ _ ____
1 Harbin 246 2 it or ycu didn't see any item that might have been 3 relevant to anybody at Unit 2. You have, as I 4 understand it, testified simply that you don't recall 5 ever having sent anything from the Current Events-Power 6 Reactors to anyone at Unit 2 and I am just asking 4
7 you if you recall why that is so.
1 8 A No, I don't recall.
9 Q In other words, you don't recall anybody 10 saying to you don't send it to anyone over at Unit 2; 11 is that correct?
12 A I don't recall anyone saying that to me.
13 Q All right.
() 14 With respect to my earlier question relating 15 to the Atomic Energy Clearinghouse document and 16 whether anyone else was disseminating that information 17 to Unit 2 during the point in time when you didn't
', 18 know the staff at Unit 2, you said you didn't know 19 of anybody who was doing thatt is that correct?
i 20 MR. MacDONALD: Can I have that question 21 again, Charlie, please? ,
22 (Question read by the reporter.)
23 Q I am not trying to paraphrase your 24 testimony, I just want to make sure I understand 25 your answer.
- l. C);
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l 1 Harbin 247 1
2 MR. MacDONALD: Are you asking him '
- 1((): 3 to answer the question again from what he j 4 answered?
5 MRS. VAUGHAN: I am asking the question 6 that I asked him and whether he can answer the' 7 question I just asked, if that-is correct.
8 MR. MacDONALD: I think he answered the
. 9 question in his own words. If you want him 10 to read it back again, fine, . but if you 11 want to ask him a question again --
- 12 Q Is that correct, that you did not know 13 who if anyone was disseminating the information 14 to Unit 2 from the Atomic-Energy Clearinghouse 4
j 15 during that period of time?
16 A During the period of time in which I was not 17 as familiar with the Unit 2 staff as the Unit 1 18 staff?
19 Q That's correct.
f i 20 A I don't know. I am confused as to what you
~
21 are asking.
22 Q well, my question is going to be who 23 would know who was disseminating information from 24 the Atomic, Energy Clearinghouse document during the 25 period of time when you .weren't?
[-
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1 Harbin 248 2 'A I don't know who would know.
I
- 3 Q When you reviewed the Atomic Energy 4 Clearinghouse publication, did you also review that 5 portion of it that contained LER computer summaries?
6 MR. MacDONALD: Are you talking about 7 now for each time he reviewed it, would it 4
8 be different?
9 MRS. VAUGHAN: Whether he had a general 10 practice.
11 A My general practice was to not review that 12 portion of the report.
- 13 g Why was that?
( 14 A Several reasons, one was because of the time 15 that would be involved in performing such a review, i
16 one was because there was no apparent organization 17 to the report, there was no apparent attempt to 1
18 categorize events as to their importance on nuclear 19 safety, as to their applicability to other plants, 20 the third reason is that, as I have stated before, 21 I didn't consider that publication reliable from 22 the standpoint of having sent to us information 23 that had been filtered by B&W and by the NRC, I l
24 felt that it was their responsibility to perform 25 that kind of a review of LER's especially the'NRC and
(~)}
L.
r
1 Harbin 249 6
2 B&W plant events and a fourth reason was that for
>O
\/ 3 some period of time issues that contained the 4
4 summaries that we are talking about I routed to the 5 lead engineers in both units for the purpose of 6 their picking out any LER's that might have been of 7 potential interest to them.
8 Q Just so I understand you correctly, was 9 your answer related only to the LER supplement?
10 A The LER portion of the Atomic Energy Clearinghouse 11 document, yes.
12 Q Was that LER portion the same as the NRC 13 itself published?
14 A I don't know that.
15 Q Did you ever see an LER couputer 16 printout published by the NRC?
17 A Yes, once.
18 Q Do you know that the LER computer 19 printout published by the NRC comes in various forms?
20 A Yes, I do.
21 Q Which forms are you aware of?
22 A I am aware that information on LER's is 23 sorted in at least the ten categories and I don't 24 know what any of the categories are.
--25 Q Do you know that one of the categories i .
}
l Harbin 250
~
2 - is personnel errors?
3 MR. MacDONALD: What time does he know e
4 that?
5 MRS. VAUGHAN- Right now.
6 MR. MacDONALD: Right now or at the time 7 of the accident?
8 MRS. VAUGHAN: Does he know it now.
9 A No.
10 Q Do you know now that it is sorted by 11 facility?
lj2 A No.
13 Q Do you know that that LER is published 14 by the NRC and sent to utilities free of charge?
15 A No.
16 Q Do you know that Nelson Brown receives 17 cr did receive. prior to the accideng several sorts 18 of the LER's published by the NRC7 19 MR. MacDONALD: You are asking whether 20 he knew that at any point in time?
! 21 MRS. VAUGHAN: Does he know that now.
}
22 Q~ That he received it before the accident, 23 Nelson Brown?
24 A Yes.
("N 25 Q. when did you learn that?
.V
1 Harbin 251 2 A I don't recall.
[ T '
~ 5- 3 Q Did you learn it before the accident?
4 A I don't recall.
5 Q Did you ever talk to Nelson Brown about 6 any information contained on the LER's?
7 A Not that I recall.
8 Excuse me, just to clarify that, it was from 9 Nelson Brown that I learned that those summaries 10 existed.
11 Q What was the context in which you learned 12 that?
13 A In a discussion with him concerning publications
(
O) 14 on industry operating experience.
15 Q when did that discussion take place?
l 16 A I don't recall.
17 Q Was it before the accident at Three Mile 18 Island?
19 A I don't recall. ,
20 Q You don't recall whether it was before 21 or after?
[ 22 A That's correct.
23 Q Do you recall what he said to you in that ;
24 discussion?
25 Yes. He told me that someone in the Training t
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1 Harbin 252 4-2 Department received more than one sort of LER's
/9
\/ 3. and that a catalogue of sorts existed, a copy of 4 which he subsequently sent to me. That's all I S recall of the discussion.
6 Q Do you recall what you said to him at 7 any point in the discussion relating to this subject?
8 A My general remarks were that it sounded like 9 a source of information that might have -- might be 10 of interest to me or to the plant staff.
11 Q In terms of the publications that were 12 received by the unit superinte,ndent and of the ones 13 that you reviewed, who made the decision which O).
( 14 publications would be received?
15 A We both did depending on the publication. Also .
]
16 other people made decisions.
L 17 Q Would other people --
- 18 A In what we would receive.
19 Q Would other people make decisions without 20 contacting you or would they call you and say I 21 looked at this, it looks like a good idea, let me 22 send this over to you and you can decide whether you 23 want to get it?
24 A I don't recall. The only publication that I 25 recall decisions being made on as to the distribution
(~
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D
1 Harbin 253 I 2 from the NRC were notices, bulletins and circulars.
4 3 Q But 'ow about those that would come in 4 to the unit superintenilent's office? I am not 5 talking now about publications in terns of your
?
6 distributing them after they came in, I am just 7 talking about who made up basically the list of 8 publications you received?
9 A Yes, that's what I am talking 'about.
10 Somebody made a decision that the Unit 1 j 11 superintendent would be on distribution directly 12 from the NRC for notices, circulars and bulletins.
13 Q All right.
(_, 14 A I know that there have been times that decisions 15 were made by someone that that distribution be 16 , changed.
17 Q when you say " changes," what do you 18 mean?
19 A Individuals added or removed from distribution.
i 20 Q on the NRC circulars, bulletins and 21 notices?
22 A Yes.
23 'Q Independently of the Unit.1 superintendent?
24 A The decision being independent?
25 Q Somebody else made the decision to send-
~
, a ,o y.,- m, ,- -e q< w e,e o v 's w- w e-e--- w N *w h"'~~me
1 Harbin 254 I
2 to the Unit 1 superintendent the NRC's bulletins, l O
N) 3 circulars and notices; is that correct?
4 A I don't know that.
5 Q Do you know whether the unit superintendent 6 made the decision'that he wanted to receive those 7 publications?
8 A No, I don't know that.
9 Q All right.
10 would you ever go out and seek information 11 from others within Met Ed or GPU about publications 12 that might be good for the unit superintendent to 13 receive or for you to review?
14 A Yes.
15 Q Would your discussion with Nelson Brown 16 in the Licensing Department have been part of that 17 process?
18 A Nelson Brown in Licensing?
19 Q Excuse me, in Training, with regard to l
l 20 the LER summaries.
]g 21 A That discussion that I referred to that we had, 22 the discussion between Nelson Brown and myself, 23 was related to my interest in obtaining additional i
l l 24 information concerning industry operating experience.
l 25 Q What was the basis for your interest in
("]
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1 Harbin 255
,, 2 additional. operating experience?
-s 3 A I considered myself,as I have said,the focal 4 J point in Unit 1 for several of the documents that 5 we have been discussing and in that capacity I had 6 a desire to be aware of information that existed 4
7 concerning industry operating experience.
8 Q Did you have any other discussions with t
9 Mr. Brown regarding information that might be worthwhile 10 for you to receive?
11 A I don't recall any.
12 Q Did Mr. Brown recommend to you that you 13 should receive one of the various sorts of'the LER I 14 summaries?
15 A I don't recall him making any recommendation.
16 Q Do you recall coming to a decision 17 yourself with regard to whether you should receive 18 those summaries?
19 A Yes, I did.
20 Q And what was that?
21 A That I shouldn't.
) ,
j 22 Q You should not?
l 23 'A That's correct.
24 Q And why was that?
l f')s 25 A I stated _ earlier four reasons for not reviewing 4
e
1 Harbin 256 2 the sort that was provided of LER's that was provided.
f i t 3 in the Atomic Energy Clearinghouse and one of those 4 was that events were not categorized and although
) 5 this service that was provided by the NRC provided 6 that categorization, I still felt that it was 7 such -- there was such a volume of information and 8 such a lack of detail concerning each event and for 9 the other reasons that I listed as to why I didn't Id review LER's in the Atomic Energy Clearinghouse. I 11 made the decision not to be on distribution for 12 these, i
13 Q Did you ever communicate to Mr. Brown 14 your reasons for not wanting to receive the LER 15 s umma ri es ?
16 A I don't recall whether I did or not.
17 MRS. VAUGHAN: Why don't we take a five 18 minute break?
19 MR. MacDONALD: Yes, I was going to 1
20 suggest that.
21 (Recess taken.)
22 MRS. VAUGHAN: Let me mark as B&W Exhibit
. 23 208 a letter dated August 30, 1979 from 24 Mr. R. C. Arnold to John G. Kemeny and the i 25 letter contains 18 attachments.
4
-Nm w " 'W
- w T % v 3
, 1 Harbin 257 2 (Letter dated August 30, 1979 from
<~g
\# 3 Mr. R. C. Arnold to John G. Kemeny with 18 4 attachments marked B&W Exhibit 208 for
)/ 5 identification, as of this date.)
6 (Handing document to the witness.)
7 Q Mr. Harbin, do you want to take a minute 8 or two to look over at this point just the letter?
9 A Just the cover letter?
10 Q That's right.
11 A Yes, please.
12 MR. MacDONALD: Off the record.
13 (Discussion off the record.)
) 14 MR. MacDONALD: Why doesn't he leaf 15 through it to know what the attachments are 16 so he knows what's in it.
17 MRS. VAUGHAN: Sure.
18 MR. MacDONALD: Off the record.
19 (Discussion off the record.)
20 Q Have you had a chance to review it, i 21 Mr. Harbin?
22 A Yes, I have.
23 Q Have you ever seen this document before 24 today?
i r'}
L/
25 A Not outside of discussing it with counsel.
=
m - g- ww -q,y --y-m w y - = , w
1 Harbin 258 2' Not that I recall.
A U 3 Q Did anyone ever ask you to gather 4 inform:ttion with respect to either the first event 5 at Davis-Besse which is mentioned in this letter, 6 that event occurred on November 29, 1977, or the 7 event which occurred at Davis-Besse on September 24, 8 1977? Do you understand the question?
9 A Yes, but could you clarify the period of time?
10 After the accident at Three Mile Island.
Q 11 A I am sorry, and could you repeat the question.
12 Q Sure. After the accident at Three Mile 13 Island did anybody ask you to gather information O)
(_ 14 relating to the incidents at Davis-Besse referenced 15 in this letter and the' sources from which that
- . 16 information came? -
- 17 A Yes.
18 Who asked you to do that?
Q 19 A Nelson Brown.
20 Q When did he ask you to do that?
21 A During the period of time between the time of i
l 22 the accident and six months subsequent to the accident.
23 Q Why did he.ask you to do that?
24 A He was being interviewed by one of the
/~T - 25 investigative committees that-was investigating the
%)
I
1 Harbin 259 2 accident and the topic of receipt and distribution (3
\-) 3 of the Current Events-Power Reactors publication 4 became an issue and some member or members of the 5 committee to which he was testifying requested that 6 he obtain any document that might exist in the 7 superintendent's files that would indicate any 8 distribution made of that document.
9 Q of only the Current Events or of any other 10- documents as well?
11 A That's the only one that I recall.
12 Q Did he ask you to specifically search 13 the unit superintendent's office to see if you had
{\
V 14 copies of the Current Events?
15 A Yes, he did.
16 Q And just so that we are clear, which of 17 the two events referenced in GPU Exhibit 208 were 18 you looking for?
19 MR. MacDONALD: You are talking about 20 the November 29 --
21 MRS. VAUGHAN: ,
Or the September 24th.
22 A I don't recall which.
l 23 Q You don't recall which one?
I 24 A That's right.
j (- 25 Q were you able to find any Current Events
\s)l ,
l
1 Harbin 260 2 in the Unit 1 superintendent's office?
(
-\% 3 A Yes, I found some past publications.
4 Were they responsive to Mr. Brown's Q
5 request?
6 A No, they were not.
7 Q Did you give them to hi.m anyway?
8 A No. I gave him Xerox copies of cover sheets 9
to what we understood at the time to be documents 10 that were published both before and after the document 11 that was responsive to their request.
12 Q Did you not find a document that was 13 responsive to Mr. Brown's request because it simply
[v\ 14 didn't exist in the file? In other words, there 15 was a volume missing?
16 MR. MacDONALD: Are you suggesting that 17 was the only volume missing?
18 MRS. VAUGHAN: No, just that the 19 volume that might have been responsive to 20 Mr. Brown wasn't there.
21 A I did not find it in the specific file that 22 I was looking at.
23 Q By that I take it you mean it was missing?
24 A That was my conclusion at the time.
e~s 25
' \
Q You found a volume before the date and
'J II - I ' ' ll '
1 Harbin 261 2 you found a volume after the date but you didn't O 3 find one for the date; is that correct?
4 A An issue.
5 Q An issue?
6 A Yes.
7 Q Were you looking for one of these two 8 events or do you not even recall which event you 9 were looking for?
10 A What are the two events again?
11 They both occurred at Davis-Besse, the Q
12 first event discussed in the letter occurred on 13 November 29, 1977 and covers a loss of pressurizer 14 level indication, the pressurizer level went off 15 scale low.
16 A Yes.
17 Q And then there was another event referenced 18 in the letter on September 24, 1977, also at 19 Davis-Besse.
20 A Where is that referenced?
l g 21 Q Starting at the bottom of page 2.
22 A What was that?
23 It would be on September 24, 1977.
l Q 24 A Right.
I 25 i
Q That event was an event much.like the onc
()'T N.
t ..
9 . , . ---r w r.ui e
~
i
'l' Harbin 262 2 at Three Mile Island.
(~h
'\~ A 3 I don't recall which event.
4 Q You don't recall which of these two or 5 you don't recall whether it was either of those two?
6 A I don't know now that it was either of these 7 two.
8 Q But you still recollect that Mr. Brown 9 asked you to go back and search the Current Events 10 that were in the unit superintendent's office for 11 a particular event? -
12 A For a particular publication.
13 Q All right.
14 Did he give you a number on the publication 15 or a date on the publication?
16 A I don't recall.
17 Q Do you recall that-it involved 18 Davis-Besse?
19 A Yes, I do.
20 Q Have you heard of the event at Davis-Besse
]j 21 on September-24, 1977 before today?
22 A Before today I heard of'an event that occurred 23 at Davis-Besse that was much~like ~ the event that
. 24 occurred at TMI-2.
i j 25 sitting here right now I --
I am not-sure which e --
w w< m
- ee-- t
1 Harbin 263 2 of these two events.I didn't know until this time h'#
3 that there were two events that close in time that 4 were that similar, that occurred at Davis-Besse.
5 Q Were you familiar with any events that 6 occurred at Davis-Besse prior to the accident at 7 Three Mile Island?
8 A When?
9 Q' Prior to the accident at Three Mile 10 Island. Were you aware yourself, before the accident 11 at Three Mile Island, of any events that occurred at 12 Davis-Besse?
13 A Not that I recall.
(("h_) 14 Q Do you recall anything more about what 15 Mr. Brown asked you to look for?
16 A In terms of other documents?
17 Q In terms of the request that you referred
. 18 to, whether it was other documents or anything else?
- 19 -A No, I really don't remember anything else.
20 Q He asked you only to look for the 21 Current Events-Power Reactors issue?
. ]g 22 A 'I don't know that. That's all I recall that he 23 had requested.
24 Q Do you recall whether he got the issue
("T 25' he wanted from some other source?
N] .
l t
I
1 Harbin 264 2 A No, I don't know that.
t 3 Q Did you send him a memo telling him you 4 couldn't find it or did you communicate orally to 5 him?
6 A He and I went through the file together and 7 both came to the same conclusion, that is that you 8 couldn't- that it wasn't there, there was no 9 information. That's right.
10 Q Did he say at that time he was going to 11 go search the Unit 2 superintendent's. office?
12 A I don't recall that he said anything at the 13 time.
() 14 Q Do you know whether he had searched either 15 before or after that the Unit 2 superintendent's 16 office?
17 A No, I don't.
18 Q Do you know whether he had gone to any 19 other places to look for the document?
20 A No, I don't.
21 Q Do you know why he came to you looking 22 fo'r the document?
23 A No, I don't know why.
24 Q Have you heard why? Has anyone told you?
25 A I can only speculate that --
k O
.r. s_ m ... _ . sum.. . - .._ . . . .u..._. .a. di d
1 Harbin 265 2 MR. MacDONALD: No. I just don't G' 3 think speculation will do anyone any good.
4 A --as to why.
5 Q Do you have any impressions as to why?
6 MR. MacDONALD: If it's based on 7 speculation, I don't think the witness should 8 give it.
9 Q Do you have an understanding why?
10 MR. MacDONALD: If it's based on 11 speculation or guess work, I don't think it's 12 a proper question or properly answering the 13 question.
14 Q Do you have an understanding as to why?
15 A As I told you earlier, I was the focal point 16 in Unit- 1 for this and some other documents and 17 Nelson Brown and I had had discussions concerning 18 operating experience information and it was my 19 understanding at the time that he was aware of that, 20 the fact that I was the focal point and therefore came to me.
) 21 22 Q Were these discussions that you had with 23 Mr. Brown, apart from the discussion that we have 24 previously referred to this afternoon, generated by 25 the accident at Three Mile Island?
'(V%
1 Harbin 266 2 A I don't recall whether it was.
i 3 Q Do you recall that any discussions took 4 place after the accident at Three Mile Island?
5 A The one I just related.
6 Q Dealing with this document or the --
7 A Yes, dealing with his search for this document.
8 Q Were there any other conversations you 9 can remember having with Mr. Brown involving 10 operating experience or anything of that nature after 11 the accident?
12 A Yes.
13 Q What other discussion?
) 14 A Discussions relating to a publication called 15 Nuclear Power Experiences.
16 Q What was the substance of that discussion?
17 A The discussion related to considering whether 18 on site personnel and which on site personnel might~
19 receive the publication, what kinds of information 20 the publication contained, what value it would be 21 to the plant staff.
22 Q Was he asking you if you knew who 23 received Nuclear Power Experience?
24 A I don't rehall him asking me that question.
~
25 Q Was he asking you for your opinion as to
~
1 Harbin 267 2 to whom it might be good to send copies of Nuclear 3 Power Experience?
4 A. Could you repeat the question, please?
5 MRS. VAUGHAN: Will you please repeat the 6 question?
7 (Question read by the reporter.)
8 A I don't recall that he asked me for my opinion 9 of that.
10 Q Did he ask you for your views on that?
11 Let me ask you thi's : Was the reason for 12 the conversation for the two of you to decide who 13 should receive the copies of Nuclear Power Experience
(~) 14
\
, (_/ or was the conversation one that was geared to 15 finding out who already got copies of Nuclear Power 16 Experience? -
17 A The discussion was, first of all, to establish 18 whether it was a publication that we, being the 19 site, wanted to receive at all and assuming that we 20 would receive it, what department would receive it, 21
) what would be done with it when it was received and 22 who would maintain the documents.
23 Q. Was it after this that you determined 24 to get copies of Nuclear Power Experience yourself?
(~} 25 A Could you repeat?
%.l
,, 7 a , . _ _ - - = -
. ~
1 Harbin 268
'l 2- Q Was it after this conversation with O 3 Mr. Brown that you decided to get copies of Nuclear 4 Power Experience?
5 A I don't recall.
6 Q Do you recall that you were receiving
, 7 copies of Nuclear Power Experience before your ,
8 conversation with Mr. Brown?
9 A No, I don't recall.
10 Q Did Mr. Seelinger ever ask you to gather 11 any information about the Davis-Besse September 1977 1L event?
13 MR. MacDONALD: Gather information when?
- (_/ 14 HRS. VAUGHAN
- After the accident at i
15 Three Mile Island.
16 A Not that I recall.
17 Q Did he ask you to look for documentation 18 in various reports about the September 24, 1977
, 19 Davis-Besse incident?
20 A Not that I recall.
21 Q Do you recall that he-asked you to look
- 22 for anything involving Davis-Besse irrespective 23 . of a date?
1- 24 A Yes, Davis-Besse is one of'the B&W plants that 25 is contained in the report that we discussed earlier, 1
y- -
9 --. r ,% - = - y y- +y y 7-w-i,- w m y -
e -
wa- *--'
I 11arbi n 269 2 B&W weekly newsletter and therefore was --
therefore 4
3 information pertaining to events at Davis-Besse 4 would be a part of the. program that I was to have
- 3/
5 developed.
6 Q But you don't recall his asking you to 7 look for any information about any events at
, 8 Davis-Besse that occurred prior to the accident, is 9 that right?
10 A I recall for one superintendent, and I don't
-Il recall which superintendent, that I was requested to 12 gather information on availability and refueling 13 outage times, those kinds of statistics on all B&W 4
( 14 operating plants, Davis-Basse being one.
15 Q Were you asked to do this after the 16 accident?
a
- 17 A No, before the accident. '
18- Q My question was.to focus on ev'ents that 19 occurred at Davis-Besse before the accident but as 20 tc which Mr. Seelinger made the request after the 21 accident.
22 A No, I don't recall that he'did.
23 Q Do you recall --
24 A After the accident.
G
-) 25 Q Excuse me.
4 o
M p - - - - - -,
9- y . y
1 Harbin 270 2 Do you recall anyone else at all making O( ) 3 any request of you regarding events at Davis-Besse 4 that occurred before the accident?
) 5 A No, I don't.
6 Q Do you recall anyone making any request 7 of you regarding the kind of publications you 3 received and reviewed before the accident but the 9 request was made after the accident?
10 A I don't recall whether anybody did or not.
11 Q could you turn, flip your pages on 12 Exhibit 208 marked for identification and although 13 the attachments arene't marked they should be l 14 consistant with the stapling so I would ask you to 15 look at attachment 7 which, I hope, if everything 16 works out right is dated October 7, 1977; is that 17 right?
18 A tes.
19 Q And it's a letter from Jack Evans to 20 Mr. Keppler?
21 A Yes.
22 Q Do you recall having seen this before?
23 MR. MacDONALD: Can he take a couple of 24 minutes to look at it?
gs 25 MRS. VAUGHAN: Sure.
m
. I 4.
1 Harbin 271 2 A No, I don't recall ever seeing this outside of
' counsel.
3 4 MR. MacDONALD: The questions are all 5 outside of counsel.
6 THE WITNESS: Okay.
7 Q Am I correct that Mr. Evans is transmitting 8 a copy of an LER?
4 MR. MacDONALD: Are you asking him to 10 sit here today and tell you if that is what the 11 document says? I mean he says the document 12 ,has a cover letter of Evans to Keppler.
13 A It says reportable occurrence.
14 Q And in'the first sentence, Licensee
~
'- 15 Event Report?
16 A Yes.
17 Q Do you see in the bottom right-hand 18 -
corner the bec list?
19 A Yes. .
20 Q Is there anybody on that list whose name 21 you recognize as being an employee at that time of J'
22 Metropolitan Edison?
23 A No.
24 Q Do you see where it says Edison Elect'ric jN 25 Institute?
n.]
4
.g % , m y - u .- - 4gy - - - - . . - - - yw.. w w-#- y q ,,-
l 1
1 Harbin 272 2 A Yes.
D) 5
'~'
3 Q Are you familiar with the Edison Electric 4 Institute? Is that the EEI we referred to yesterday?
5 A Yes.
6 Q Do they ever send to you or have you ever 7 seen sent from them copies of LER's like this? i j 8 A No, I have never seen any.
9 Q You are not aware of EEI having sent at 10 least to the Unit 1 superintendents attention an LER, 11 a copy of an LER?
12 A Other than having read it for the first time 13 in Mr. Arnold's cover letter, I wasn't aware that
\_/ 14 they had sent any LER's to any member of Met Ed or 15 GPU.
16 Q Okay, fine.
17 Would you flip to the next attachment, 18 attachment 8. This attachment is dated November.14, .
19 1977 and it is a letter from Terry Murray to 20 Mr. Keppler transmitting a copy of an LER supplement.
)
21 A Yes, I see the cover page. .
22 Q Have you ever seen this document or any 25 of the material under the cover page before? l 24 A No, I don't recall ever.having seen this before.
I '25 Q Would you look again at that bec list and O
gg m ww ey y y w -y-v $- v-y -+--y--tw** -vv yw- r-9w--~,-ye e-t-v -y *FTT' e-t-'*---ev * *~g
1 Harbin 273 2 tell me whether there is anybody on that list who
(
'~ was at that time employed by Metropolitan Edison or 3
l 4 GPU?
i ,
5 A I don't know of anyone.
6 Q And again do you see where it 'says 7 Edison Electric Institute?
8 A Yes, I do.
9 Q Are you aware of Edison Electric Institute 10 ever sending a copy of an LER that you reviewed?
4' 11 An LER supplement, excuse me.
( 12 A No, I am not.
4 13 Q Do you know if anybody within Unit 1 or
[\
\_/ 14 Unit 2, received copies of LER's or LER supplements
- 15 from any of the utilities?
16 A Yes.
17 Q Who would that have been?
18 A I don't recall.
19 Q How do you know somebody did?
20 A Excuse me, what time frame are we referring to?
21
) Q Before the accidentoat Three Mile Island.
22 A I recall seeing LER's from other utilities.
23 Q Do you recall in whose files or where 24 you saw them?
25 A I recall that they were being routed to the O
g-p6 --s y-. e.,e+, y -wan- e. y ei . - . , -~ e. w .e---_. --ve+i- ,p.- , .c ,, --y , w y i
I.
1 Harbin 274 2- unit superintendent.
O 3 Q Do you recall from where it was being 4 routed? Any instant at all?
5 A Yes, Jack Herbein.
6 Q Do you recall which utility's LER 7 Mr. Herbein did send? Which one?
I 8 A Oyster Creek.
9 Q When was that?
l 10 A For approximately a year prior to the accident
{
11 and approximately a year after the accident. l
. I 12 Q I am sorry, I don't understand your 13 answer.
O)
(_ 14 He was sending LER's related to Oyster 15 Creek for a year before and a year after?
16 A Yes, that's right.
17 Q A number of LER's, more than one?
18 A Yes. l 19 Q Do you know why he was sending the LER's 20 relating to Oyster Creek?
g 21 A ! don't know why, no.
22 Q Do you have an understanding as to why?
23 MR. MacDONALD: Did he have an 24 understanding at the time? ,
/~T 25 MRS. VAUGHAN: Yes.
V e
4 1 Harbin 275 T
2 A Yes, my understanding at that time was because
(
3 of potential applicability to TMI-1, 4 Q Do you know whether Mr. Herbein sent 1
5 LER's to Unit 2?
6 A No, I don't recall.
- 7 Q Was there a distribution list on the LER i
8 or on the various LER's that he sent?
}
9 A Yes, I recall that there was.
10 Q Do you recall seeing anybody on that i 11 distribution list that was with Unit 27 12 A No, I don't recall that. .
i 13 Q Do you recall that there was anybody at .
4
{~%
% 14 all from Unit 2?
15 A I don't recall whether there was or whether 1
16 there wasn't.
17 Q Do you recall ever seeing any other 18 LER's that Mr. Herbein did send other than those l
19 relating to oyster Creek?
?
- 20 .A Yes, I do.
4 Which ones are they?
) 21 Q 22 A I don't recall.
23 Q But you do recall seeing other LER's?
l 24 A Yes, and as a general practice on a very
() 25 infrequent basis.
I e
, . , - , , , , . , - - . - . ~ , . - , ,
,,yn - --- . - , , ---,,,,,,,,e-- , . . , - - . , - , . - , . , ,
I 1 Harbin 276' 2 Q You mean it would be an infrequent basis O 3 that you would see an LER come from Mr. Herbein to 4 the Unit 1 superintendent relating to another 5 utility, is that what you mean?
6 A Yes. ,
7 Q Do you remember at all what other 8 utilities?
t 2
9 A No, I don't.
10 Q Do you know what the unit superintendent 11 would have done with any of the LER's that he 12 received?
.i 13 A .I don't recall.
14 Q Was this the kind of thing that you would 15 look at first and then send to the unit superintendent?
16 A Yes, that was my general practice, i
17 Q Would you send it on to any others?
1 18 A I don't recall, i 19 Q Do you recall that you ever did?
20 A I don't recall that there was ever a time that
,} 21 I received an LER that was being sent to the unit 22 superintendent by Mr. Herbein regarding an incident
! 23 or a finding at another utility that I did not give l i
! 24 to the unit superintendent. '
I l
25 Q But if,you gave it to the unit superintendent r
9
. ,,v, +_,, , em .---ww- -w<- --r=y-- v~~*-*-v*v--e'- ---v*' 1r=* '- * - " - " ' * *"--T'Y ~-" ""C "*- ~ * '"' #
I 1 Harbin 277 i
~
, 2 might you also make a copy and give it to somebody
{.
/ 3 .else, too?
i i
4 MR. MacDONALD: I will obj ect to the o form.
! 6 Q Did you also make a copy and give it to 7 anyone else?
8 A I don't recall ever doing that.
I 9 Do you recall if the unit superintendent Q
10 ever issued an action item from one of those LER's a
j 11 that he received from Mr. Herbein?
i 12 A No, I don't recall that, j 13 Q Do you recall LER's coming in from any
( ) 14 other source besides Mr. Herbein?
15 A Prior to the time of the accident?
i J
16 Q That's right.
i 17 A No.
18 l Q What about after the time of the accident?
1 i
19 A Yes, j 20 Q From whom would they come?
21 A I believe that we discussed yesterday the
}
22 establishment of a plant analysis group in Parsippany.
l 4
23 New Jersey whose responsibility is to review LER's l
i 24 and send to-various organizations within the GPU 25 company those LER's for review and acti'on where i .
e
+
1 Harbin 278 2 necessary.
-s 3 Q Do you know where the plant analysis 4 group obtains the LER's, from whom they obtain the 5 LER's?
l 6 A No, I don't.
l 7 Q Do you know whether the Licensing 8 Department before the accident at Three Mile Island
)
9 ever maintained in its files copies of LER's either 10 as a unit or anyone in particular?
j 11 A I don't know that.
12 Q Have you heard that they do from anyone?
13 MR. MacDONALD: That they did?
14 MRS. VAUGHAN: That they did.
! 15 A Are we referring to any LER's? The answer is i
16 no, I don't know.
17 Q You don't know and you have never heard 18 anyone say that they have?
19 A That's correct.
20 Q If you wanted to get a copy of an LER-i before the accident at Three Mile Island, what was
) 21 22 your understanding then of where you would have 1
23 gotten a copy from?
l t
i 24 MR. MacDONALD: Are you talking about 25 LER's generated by other utilities?
\
t
. . . . _ . _ . . , . . . . . . - - . . . . _ . , _ . . , . _ . . _ . . _ , . . . - _ . . _ _ ~, . . , , . . ~ , . - , , _ . . . - - _ ~ .
i .
1 Harbin 279 f
! 2 MRS. VAUGHAN: Yes.
k\ 3 A My understanding then was that at least some I
4 LER's became public documents and although I didn't
~
) 5 know the mechanism I knew there existed a mechanism 6 for at least reviewing other LER's. I had heard of 7 the term public document room and it was my 8 understanding at the time that any member of the 9 public, I being a member of the public, could review 10 those documents.
3 11 Q Are you speaking about the public document 12 room of the NRC?
13 A yes, 14 Q Did you have any knowledge about sources 15 either on site or in Reading or in Parsippany from 16 whom you could obtain copies of LER's. filed by other 17 utilities?
18 A No.
19 Q Would you look at attachment 9, please, ,
t 20 which is the next attachment. Attachment 9 is a 21 copy of a monthly licensee event report (LER) PWR 22 listings,.the date is unclear on this copy and it is 23 signed by a Mr. Kirk whose initials are unclear, 24 acting director, Regulatory Systems Division from l
25 the NRC.
O ,
4
1 -
Harbin 280 2 Hr.ve you seen this document before 3 today, these two pages?
4- A No, I haven't. **
5 Q Have you seen anything like this before 6 today?
7 A Like what?
8 Q Like a monthly licensee event report .
9 even though it is not this one, have you seen other i
10 monthly licensee reports before today?
11 A Could you please repeat the question?
12 Q Have you seen other monthly licensee 13 event reports before today?
14 A Other than those listed here?
15 Q Other than this particular attachment.
16 A Yes, I have seen other licensee event reports l 17 other than this, those listed in this attachment.
18 No, I am asking --
Q 19 MR. MacDONALD: That wasn't the question."
20 Q Whether you have seen a publication '
21 like this one before today, not whether you have
)
22 seen the LER's listed.
23 MR. MacDONALD: Or something generated 24 in this format.
25 MRS. .VAUGHAN: That's right.
e 6
1 Harbin 281 2 A I don't recall that I ha,ve.
t 3 Q Mr. Brown never showed you anything like 4 this?
5 A I don't recall that he did.
6 Q Do you know a Mr. Lieb? Have you ever 7
heard that name before?
8 A I don't recall ever hearing that name.
9 Q How abour a Mr. Loeb?
10 A I don't recall hearing that name.
11 Q You don't know anyone by that name?
12 A I don't recall ever hearing anybody by that 13 name.
14 Q Could you turn to the next attachment, 15 please, attachment 10. Its title is " Operating Units 16 Status Report" and this attachment is dated as of 17 10-31-77.
18 Have you ever seen this document before 19 today?
20 A No, I haven't.
21 Q Do you see what is called the NUREG 22 number, NUREG 0020? Is that familiar to you?
23 A The term NUREG is familiar to me.
24 Q Is this particular number of NUREG familiar 25 O to you?
1 Harbin 282 2 A No.
/~
'(_,N) 3 Q If I said to you that this is the NRC's 4 gray book, would that mean anything to you?
'N .
/ o A Yes.
6 Q what does that mean?
7 A It's been my understanding and it's my 8 understanding that the report that we discussed 9 yesterday, the NRC monthly operating report, information 10 contained in that report is used to make up a gray 11 book that is published periodically.
12 Q Have you ever seen copies of the gray 13 book before today?
I)
NJ 14 A Yes, I have, 15 Q Is this a copy of the gray book?
16 A I don't know.
17 Q Do you know whether the copies you have 18 seen look like this?
19 A I don't recall that they did.
20 MR. MacDONALD: Or in a format like 21 this?
22 MRS. VAUGHAN: Yes.
23 A I don't recall that they did.
24 Q When did you see a copy of the gray book?
t f3 I
25 A Sometime before 1978.
\v/
_ . _ _ _ m .
1 Harbin' 283 2 Q Did you ever see a copy after 1978?
4 s/ 3 A I don't recall that I did.
4 Q Do you recall the circumstances under
) -5 which you saw a copy?
6 A Yes.
7 Q What were they?
8 A I had heard of the term the gray book and I f
9 was in Gary Miller's office and he was on distribution 10 for the gray book and I saw several copies in his
- 11 office and I spent two or three minutes looking
- 12 through one or two.
13 Q Do you recall that it said gray book on it?
( 14 A No, I don't recall if it did or if it didn't.
15 Q How did you know it was the gray book when 16 you saw it?
17 A I don't know how I knew.
- 18 Q You just knew?
19 A I don't know how I knew.
i 20 Q Was it actually gray?
l 21 A Yes, it was.
22 Q What was Mr. Miller's position at that 23 . time?
24 A It was either station superintendent or Unit 2 g- 25 superintendent or station manager.
NJ 4
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1 Harbin 284 i 2 Did Mr. Miller, while he was station Q
/~%
! - 3 manager, have an assistant much like you are an 4 assistant to the Unit 1 superintendent?
5 MR. MacDONALD: Much like, you mean 6 somebody acting in th'e same capacity?
7 MRS. VAUGHAN: Irrespective of whether g 8 they do exactly the same functions but 9 generally speaking the same capacity.
10 A I don't recall.
11 Q Do you know whether he had anybody when*
j 12 he was the Unit 2 superintendent who was an 1
i 13 assistant?
i 14 A I don't recall.
t 15 Q' Do you know whether Mr. Logan ever had 16 an assistant other than Mr. Shaffer when he was 17 the Unit 2 superintendent?
18 A Yes, I recall that he didn't.
19 Q Going back to attachment 10, the
, 20 operating units status report and also attachment 11, i
21 the same kind of document dated 11/30/77 --
22 A Yes.
- 23 Q --
is it your testimony that you have 24 not seen either of these before today?
l 25 A That's correct.
4 O
t
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, 1 Harbin 285 1
- 2 Q Could you turn to the second page of
- ' U 3 attachment 10, that is the earlier one, it is i
l 4 headed Davis-Besse 1."
5 A Which document are you referring to, the 6 document dated 10/31 or 11/317 7 Q 10/31.
8 A 10/31.
9 Q I realize that they are not very clear 10 but I wonder if by looking at that page you can
- - 11 tell me what, if any of the kind of information 12 that is listed there would be the kind of information j 13 that you would gather information for, for the (T
() 14 operating, the monthly operating reports?
15 MR. MacDONALD: You are talking about 16 the monthly operating reports on Unit 1?
l 17 MRS. VAUGHAN: Yes.
18 A I can't make out much of the information on 19 the left side of the page.
20 In the center of the page at the bottom, 21 plant status, the description that they give there
}
- 22 of the plant status is similar to the operations 23 summary that I would provide in the NRC monthly i
l 24 operating report.
~
(~h 25 Q Is there anything else on the page from V
6
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!- 1 Harbin 286 i
2 what you can tell?
,'- A 3 No.
4 Q How about on the attachment 11 which is 1
5 dated 11/30/77, the second page there might be a 6 little bit clearer?
7 A They changed their format from one report to 8 the next.
1 9 Although in the second document it is referred 10 to as system -- systems and component problems.
11 -
Q Yes?
12 A What I read in that section of the report is 13 also similar to the information that would be 14 contained in the operating summary of the NRC monthly 15 operating report.
j 16 Q Mr. Harbin, could you please look at i
17 the next attachment, attac'hment 12, it is titled 18
" Current Events-Power Reactors" and the document 19 indicates it was published December 1977.
20 Would you take a moment to review that, l 21 please?
22 A Yes.
23 okay.
24 Q Have you seen this-document before today?
25 A Not that I recall.
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4 1
Harbin 287 2 Q Would this document be one that you 3 would receive and review in the normal course of 4 your job responsibilities, this type of document, 5 that is, Current Events-Power Reactors?
6 MR. MacDONALD: Not necessarily this 7 document?
8 MRS. VAUGHAN: -That's right.
9 A Yes, I received this for some period of time. ,
10 Q In other words, when you have testified 11 previously about receiving Current Events, this is 12 the document you recall that being?
I 13 A Yes, that's correct.
14 Q You, however, do not recall receiving 15 or reviewing this particular one; is that correct?
1 16 A That's correct.
17 Q Do you recall that this was the Current 18 Events-Power Reactors document that Mr. Brown was
! 19 looking for?
20 A Do I recall correctly that you had stated
} 21 that he was looking for a document concerning an 22 event dated September 24, 1977?
23 Q uo.
24 Do you recall looking at this now that
~% 25 this wac the document that he was looking for?
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1 Harbin 288 MR. MacDONALD: That is your recollection.
O 3 A No.
4 Q You don't recall that?
") .
D A No.
6 Q Looking at this now does not refresh
~I your recollection in that regard?
A That's correct.
9 Q Do you recall that in December 1977 the 10 Unit 1 superintendent was receiving copies of 11 Current Events-Power Reactors?
1*
A when?
13 Q In December of 1977.
14 A Yes.
15 Q And you were reviewing that publication 10 in December of 19777 17 A ones that were received, that I received, yes.
18 Q Would you receive all the ones that he 19 received?
20 MR. MacDONALD: Are you asking whether 21
) he received this document or was this 22 particular publication one that was being 23 received by the Unit 1 superintendent and 24 therefore would he look at it?
25 MRS. VAUGHAN: The latter. If that was e
u . .
1 Harbin 289
,_ 2 a publication that was being received by 4
(' ' ' ' /
3 the Unit 1 superintendent in Deceiaber of 1977 4 and whether in December of 1977 he reviewed 5 for the Unit 1 superintendent Current Events-Power 6 Reactors.
7 A Yes, ones that --
I reviewed ones that I 8 received.
9 Q And my question to you now is: If you 10 didn't receive them is that because the Unit 1 11 superintendent didn't receive them?
12 A I don't know that.
13 Q Do you know that there-were issues of fh
(,) 14 this publication that you didn't get an opportunity 15 to review?
16 A I don't know that.
17 Q When you say you reviewed the ones you i 18 received, what did you mean by that?
19 A I meant that I kept no log or had no mechanism 20 for tracking those that I received and therefore
) 21 did not receive.
22 When I received them I reviewed them.
, 23 Q Would it ever happen that somebody else 24 would take the issue before you had an opportunity l -(~T 25 to review it?
%Y l
I I . . . . . - .- .,. . - - - - - . - - - - - ,- -.- - - - - - - - -- - -- - - - ~ ~
] l 1 Harbin 290
./ g 2 MR. MacDONALD: Did that ever happen?
L) 3 MRS. VAUGHAN: Yes.
4 A I have no knowledge of that ever having 5 happened.
~
6 Q so if you didn't receive an issue it 7 would be because the mail didn't get to you, is tnat 8 a fair assumption, deduction?
9 A Could you repeat that, please?
10 Q In other words, when you say you reviewed 11 the ones you received, do you mean that it could 12 happen that they didn't come to you through the 13 mail as opposed-to you didn't receive it because of O
' k 'g 14 some internal administrative mechanism?
15 A I really don't know why I wouldn't have. If 1
16 I don't receive something I have no knowledge of 17 why that-might be or why that would be.
18 Q But you were supposed to review the ones 19 that the unit superintendent received;-is that 20 correct?
- ) 21 A Yes, that's correct.
4 22 Let me make a clarification. A publication 23 like the B&W newsletter was issued weekly and the 24 NRC Current Events publication was received a lot less
{) 25' frequently. I think you had said earlier once every d
e g d e t- r g *eg - -y w -e gto- - - f- e y e-awe r-r-*-W T"* '
1 Harbin 291 2 two months and at the time of the accident I recall r)\
k- 3 having a recollection or I recollect having thought 4 that the NRC in their distribution of that publication
') 5 was not very consistent either in the title of the 6 publication, the f ormat of the publication and the l 7 dates when the publication was distributed and from 8 that standpoint I didn't consider it a very reliable s
9 source of information.
10 Q Did you know this particular publication 11 to exist at any time during your employment under 12 a different title?
13 A I knew of publications that existed that
() 14 were very similar in nature to this publication that i 15 existed under different titles, yes.
16 Q But as to this publication, did you T
17 ever know it to exist under a different title from 18 the NRC?
19 A The publication, Current Events-Power Reactors, 20 is the title of the publication. -'
l 21 Q And has always been the title of the
' ) 22 publication as far as you know?
l 23 A The title stands au the title.
24 Q Do you know the NRC to have put out-erent name at any time?
i l '
i
. . - _ _ . . .. . . . . _ _ , , - . _ . . . . . _ - . . . . . _ , _ - . _ . . , ~ , , - - . - . _ _ . . . . . - _ .. - __ . , - _ . - . .
1 Harbin 292 2 A I just said that I recall publications published 3 , by the NRC that were very similar in nature to this 4 publication but that it had different titles.
5 Q Which ones were they?
6 A There were two others and I don't recall the 7 titles.
8 Q Did you receive or review those as part 9 of your job at any time?
10 A Yes.
11 Q But you don't recall the titles?
12 A No, I don't. ,
13 Q Do the publications exist today?
14 A I don't know whether they do or not.
15 Q Do you recall the time when you reviewed 16 them?
17 A No. I don't.
18 Q Are they any of the ones, if I read 19 througn that list of names that you gave today, those 20 publications, are any of those the ones?
21 A No, they are not.
22 Q This Current Events is dated December 1977.
23 Do you know this publication Current 24 Events-Power Reactors to exist today in 19817 25 A Yes, I do.
. l
1 Harbin 293
(
2 Q Is it in essentially the same format
/ \ "
\/ 3 as it was in 1977, that is the same format as what 4 you have here, essentially the same?
) 5 A No, I don't believe it is.
6 Q How does it differ?
7 A The publication that I've got here as exhibit -- or 8 is enclosure what, 117 9 MR. MacDONALD: 12.
10 MRS. VAUGHAN: 12.
11 A Appears to categorize events by component 12 type or cause, for example, I see two events or 13 two different occurrences listed under valve
( 14 malfunctions, the first event covers the September 24, 15 1977 Davis-Besse incident and the second event covers 16 two events at the Trojan nuclear power plant and to 17 my knowledge Current Events, the publication Current 18 Events-Power Reactors today categorizes events not 19 as to cause but simply as listing of certain events 20 with no categorization.
( , -
21 MRS. VAUGHAN: All right, why don't we 22 break now.
j 23 MR. MacDONALD: All right.
I i 24 (Time noted: 4:50 o' clock P.M.)
- (' 25 l k.)S RONALD STEPHEN HARBIN Subscribed and sworn to before me
- *hia amu af 1o01
__ , ., , . , m - - - . , , _ - - - - . v- -+ --
--e-' - * - - - ' * "' ' ' ' * ' ' ' "'
.1 294 2
CERTIFICATE fl s/ 3 STATE OF NEW YORK )
- ss.:
COUNTY OF NEW YORK )
4 i I, CHARLES SHAPIRo , a Notary Public of the State of New York, do hereby certify that the continued deposition of RONALD STEPHEN HARBIN was taken before me on July 8, 1981 consisting of pages 147 through 293 ;
I further certify that the witness had
, been previously sworn and that the within transcript is a true record of said testimony; ,
O That I am not connected by blood or V 14 lo, 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 thi's' d} day of DV L'l , jggi, 4
i l)
I 23 y
CHARLES SHAPIRO, C.S.R.
24
- ' 25 -
l
July 8, 1981 -
295 I N DE X
) WITNESS PAGE Ronald Stephen Harbin (resumed) 148 E X H I B I T S B&W EXHIBITS FOR IDENT.
204 Letter dated May 20, 1977 to 149 Mr. Klingaman from Joel T.
Janis, service manager at B&W 205 Copy of minutes of a B&W Users 153 Group meeting held on June 27 and 28, 1979, dated July 24, 1979 with an attached cover memo from J. L. Seelinger to .
distribution with a copy to Harbin O 206 Letter dated July 25, 1978 186 addressed to Mr. Brummer from Mr. Herbein 207 Three-page document headed 187
" Appendix A, Notice of violation" 208 Letter dated August 30, 1979 257 from Mr. R. C. Arnold to John G. Kemeny with 18 attachments
. 1
.- .- -. . - ._ _ .- . . . .-- .- -- . - .