ML20072J053
| ML20072J053 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/07/1981 |
| From: | Harbin R METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-04, TASK-11, TASK-3, TASK-4, TASK-GB NUDOCS 8306290898 | |
| Download: ML20072J053 (146) | |
Text
.
- sc UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK j
___________x GENERAL PUBLIC UTILITIES CORPORATION,
'~
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-l THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
________________________________________x Deposition of RONALD STEPHEN HARBIN, taken by defendants, pursuant to Notice, 4
at the offices of Davis Polk & Wardwell, c
Esqs., One Chase Manhattan Plaza, New York, New York, on Tuesday, July 7, 1981 at 9:36 o' clock in the forenoon, before Charles shapiro, a Certified Shorthand Reporter and Notary Public within and for the State of New York.
l DOYLE REPORTING. INC.
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PDR ADOCK 05000 89 389 t.zmuoren Avesue New Yestsc. N.Y.
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1 2
2 Appe arance s :
<x 3
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS,
~
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York
)-
5 BY:
ANDREW MacDONALD, ESQ.,
6 of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS, 9
Attorneys for Defendants One Chase Manhattan Plaza 10 1
PATRICIA M.
VAUGHAN, ESQ,,
12 of Counsel 13
()
14 Also Present:
15 KATHI BROWN 16 17 18 19 IT IS HEREBY STIPULATED AND AGREED by 20 and between the attorneys for the respective 21 parties hereto, that the sealing, filing and 22 certification of the within deposition be, 23 and the same hereby are, waived; and that the l
24 transcript may be signed before any Notary 25 Public with the same force and effect as if
(
1 3
2 signed before the Court.
b)
(_/
3 IT IS FURTHER STIPULATED AND AGREED that 4
all objections, except as to the form of the
)
5 question, are reserved to the time of trial.
6
't 7
8 9
RO NALD S T E PH EN NA RB I N having 10 been first duly sworn by the Notary Public 11 (Charles Shapiro), was examined and testified 12 as follows:
13 EXAMINATION BY MRS. VAUGHAN:
()
14 Q
Would you please state your full name 15 for the record.
16 A
Yes..
It is Ronald Stephen Harbin.
17 Q
And your current employer?
18 A
Metropolitan Edison Company.
19 Q
And your current position with the 20 Metropolitan Edison Company?
s 21 A
Technical analyst, senior I,-Nuclear,
)
i.t 22 Q
Mr. Harbin, have you previously given 23 any depositions to either the Kemeny Commission or 24 the Rogovin Commission?
25 A
No, I have not.
1 Harbin 4
2 Q
Have you been interviewed by either of
'(~
3 those bodies?
4 A
No, I have not.
)
5 Q
could you please state your educational 6
background, that is, what college you attended, what 7
degrees you have earned?
8 A
I attended the University of Kansas and received 9
a B.S.
in business administration.
10 Q
And when was that?
11 A
Between 1973 and 1976.
12 Q
You graduated in 1976?
13 A
Yes, that's correct.
14 Q
Did you study at any time at the University 15 of Kansas anything related to nuclear energy?
16 A
No, I did not.
17 Q
How about post-graduate degrees, do you 18 have any post-graduate degrees?
19 A
No.
20 Q
None at all?
21 A
No.
22 Q
Did you attend any other collegt 5esides 23 the University of Kansas?
24 A
Yes, I did.
25 Q
What was that?
4 1
Harbin 5
2 A
Penn State University.
3 Q
And when was that?
4 A
1977 to 1978,
)
5 Q
And what were you studying?
6 A
Excuse me, to 1979 7
Q 1977 to 19797 8
A Yes.
9 Q
What were you studying?
10 A
I was working toward a Masters Degree in 11 administration.
12 Q
What courses did you take?
13 A
Principally management type courses.
I i
14 Q
Do you have that degree yet?
\\_/
15 A
No, I don't.
16 Q
How far are you away from getting that 17 degree?
18 A
I was about half way through the program.
19 Q
Are-you still studying?
20 A
No.
21 Q
Why did you stop?
22 A
The accident.
The TMI-2 accident.
It was one 23 of the causes.
24 Q
Could you now please list your employment 25 since your graduation in 1976, I believe you said, from
1 Harbin 6
2 the University of Kansas?
With whom were you 3
employed immediately after graduation, if anyone?
4 A
I was employed by Metropolitan Edison Company.
)
5 Q
In what capacity?
6 A
You want me to list titles or functional 7
posicions?
-8 Q
Titles and functional positions.
Titles 9
first.
10 A
Okay.
The titles have been --
11 Q
And let's go in order.
The first one?
12 A
I think it was engineer II, assist the Nuclear II.
13 Q
Yes?
()
14 A
That was for approximately a year and a half, 15 Q
Where was that position?
16 A
In Unit 1,
reporting to the Unit 1 superintendent, 17 Q
Who was the Unit 1 superintendent at 18 that time?
19 A
Joe colitz.
20 Q
We have here and we will mark as an 1
21 exhibit, if you would like, and at this point I don't 22 know what the numbering system is-so I don't know 23 how we should mark this.
24 MR. MacDONALD:
I don't know what the 25 last number was.
O
1 Harbin 7
2 MRS. VAUGHAN:
And we are all taking
\\-)
3 depositions simultaneously, 4
off the record.
')
5 (Discussion off the record.)
6 Q
Mr. Harbin, I have given you a copy of 7
an organization chart that says at the top "TMI 8
Supervisory "; is that right?
9 A
Yes.
10 Q
And at the bottom right-hand corner I 11 believe it is 1/1/77.
12 Does that look correct to you?
13 MR. MacDONALD:
Are you asking him if 14 that is what he reads at the bottom?
15 MRS. VAUGHAN:
Yes.
16 A
I am not sure that it is a one in the center.
17 Q
All right.
But it looks as though it 18 would be a one so it would be January 1977?
19 A
It appears to be that.
20 MRS. VAUGHAN:
I will ask to have this or'anization chart marked as B&W Exhibit 200 21 g
22 for identification.
23 (Organization chart dated January.1977 24 entitled "TMI Supervisory',' marked B&W Exhibit S
25 200 for identification, as of this date.)
x_)
+
-1 Harbin 8
2 Q
Mr. Harbin, I will' admit this is difficult 10
' k-3 to read but I believe under Unit 1 under the column 4
marked Unit 1,
the second name there?
)
5 A
Yes.
4 6
Q Would that be yours as far as you can tell?
7 A
It appears to be.
8 Q
Whose name would be above that?
9 A
J.
J.
Colitz.
10 Q
Is that the name of the individual that 11 you mentioned before?
12 A
Yes, it is.
13 Q
How does he spell his name?
()
14
(_j A
C-o-1-i-t-z, 15 Q
And Mr. colitz was the unit superintendent i
16 at that time for Unit 17 j
17 g
y'e s.
It says unit superintendent Nuclear.
1 j
18 Q
Mr. Harbin, did you have anyone else 19 reporting to you in this position?
20 A
No, I did not.
21 Q
What were your job responsibilities while 22 in this position?
Can I get you to describe the 23 title again?
Engineering assistant?
24 MR. MacDONALD:
As it reads on this page l
25 here?
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1 Harbin 9
2 MRS. VAUGHAN:
Well, as he knows it.
'O(-)
3 MR. MacDONALD:
Well, or as he understood 4
it at the time.
)
5 MRS. VAUGHAN:
Yes, as he understood it 6
at the time.
I think I make out engineering 7
assistant to/ Nuclear.
8 A
Yes.
Dash, hyphen, Nuclear.
9 Q
Is that the position that you described 10 before, the title that you described before?
11 A
I am not sure that it was.
12 Q
Do you understand that you had a different 13 title?
(
14 A
No.
I believe that this was the title.
15 Q
With that title what were your 16 responsibilities?
17 A
Primarily reviewing mail received by the Unit 1 18 superintendent.
19 Q
All kinds of mail?
I am sorry.
20 A
Developing, coordinating input for and 21 developing reports that were signed by the Unit 1 22 superintendent on various projects.
23 Q
Let's start at the beginning.
24 Reviewing mail that was received by the rN 25 unit superintendent; is that correct?
l l
~
J l
Harbin 10 t
2 A
Yes.
O k-3 Q
What kind of mail?
i 4
A I'did an initial review of all mail.
)
5 Q
All the mail that the unit superintendent 6
received?
7 A
- Yes, i
8 j
Q Would that include personal mail?
9 A
No.
10 Q
Could you describe the type of mail that 11 the unit superintendent would receive?
12 A
Two broad categories would be internal and 13 external, external being correspondence from vendors
()
14 such as B&W, Nuclear Regulatory Commission.
Those
~
15 are the two primary outs'ide sources.
16 Internal from other -- correspondence from i
17 other department heads and subordinates.
I l_
18 Q
What would you do with that mail when l
19 you reviewed it?
20 A
Primarily one of three things, I would either 21 pass it on to the superintendent or I'would send it
. )
22 to one-or.more parties that may have reported to the 23 superintendent or may not have either for action 24 or for information.
I guess one of four things, or I
25-I would discard it or simply file it.
s 1
Harbin 11 2
Q when you say you pass it on to the 3
superintendent, did you mean the unit superintendent 4
himself, Mr. Colitz?
'f 5
A Yes, the Unit 1 superintendent.
6 Q
You didn't mean the station manager?
7 A
No.
l 8
Q Does that mean that Mr. Colitz wouldn't 9
see the mail before you saw the mail?
In other words, 10 you would be the first person to look at it?
11 A
Excuse me, I don't believe there was a 12 station manager then.
13 Q
In 19777 14 A
That's correct.
15 Q
All right.
16 Does that mean that Mr. Colitz would 17 not have opened his mail first and then given it 18 to you to review?
In other words, you would have been 19 the first person to have looked at his mail?
20 MR. MacDONALD:
You are talking about 21 all his mail?
h 22 MRS. VAUGHAN:
The mail that he has been 23 describing.
24 A
I don't recall whether I was the first one to 25 open the mail.
It may have been a secretary.
.O NJ
1 Harbin 12 2 l Q
But you would have been the first person
~.
)
%,/
3 to hav6 reviewed it and looked at it for substantive 4
purposes; is that correct?
)
5 A
That's correct, with the exception of personal 6
and some confidential mail.
7 Q
Is there any other kind of mail that 8
Mr. Colitz would have received that you did not l
9 review besides the personal and confidential?
10 A
There may have been.
I don't recall.
11 Q
So Mr. Colitz would have received internal 12 correspondence and then the external correspondence 13 you indicated from either the NRC or B&W?
14 MR. MacDONALD:
Only from those two 15 sources?
I think he gave that as examples.
16 I don't think he said those were the only 17 types of external mail he ever received.
18 MRS. VAUGHAN:
All right.
19 Q
Other than the personal and confidential 20 mail that you were talking about that you received?
21 A
There was a lot of other mail but those were 22 the primary sources.
23 Q
All right.
24 A
For example we would get correspondence from 25 General Electric but for one letter from General
1 Harbin 13 2
Electric we would get ten from B&W.
(
\\
3 Q
Would you get mail from other utilities?
4 A
Yes.
Very infrequently.
)
5 Q
Mr. Harbin, how long did you hold the 6
job of engineering assistant II Nuclear?
j 7
A I believe I stayed there a year and a half.
8 Q
What does the Roman Numeral II signify 9
in the title?
10 A
It signifies pay grade.
4 11 Q
Is there a Roman Numeral I?
12 A
I don't know.
13 Q
Would Roman Numeral I be considered lower 14 or higher?
15 MR. MacDONALD:
You mean as opposed to 16 engineering assistant II in this job category 17 here, not just generally?
18 MRS. VAUGHAN:
Yes.
19 A
If it existed, I would understand it to be 20
- lower, 21 Q
What was the job title that you held 22 after this one?
23 A
Technical Analyst III - Nuclear, Roman Numeral 24 III.
22 Q
Just so that I understand, you prepared 23 and sent to Licensing these reports during the.
24 time period you were working for Mr. Colitz; is that s
1 gs 25 correct?
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I Harbin 20 2
A Yes, that's right.
Let me also mention the 3
fact that some of the reports for example the 4
environmental reports were station reports but the
)
5 reports that dealt with statistics and operating 6
experience were primarily Unit 1 only.
7 Q
Where would the information for the 8
environmental reports come from?
9 A
A portion of the input came from the Operations 10 Department,'those being flows and temperatures, and 11 chemistry information came from the I believe it 12
)
was then called the Rad-Con or HP and Chemistry 13 Department, excuse me, HP and Chemistry Department.
f')
14 Q
Were these environmental reports reports v
15 that were generated by a specific request from say 16 for instance the NRC?
17 A
The environmental reports?
18 Q
Yes.
19 MR. MacDONALD:
Are you asking if he knew 20 where the requests were generated from?
21 MRS. VAUGHAN:
That's right.
22 A
I know the two agencies that requested reports 23
. were the Environmental Protection Agency and the 24 Pennsylvania Department of Environmental Resources.
25 Q
And to whom would they make that request?
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)
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1 1
1 Harbin 21 I
l 2
Would they make it to the Licensing Department?
\\ms 3
A I don't recall who the request was made of l
4 at that time.
l
)
5 It was not the practice to make it of the 6
Licensing Department.
7 Q
What was the practice?
8 A
A member of upper management.
9 Q
Someone other than Mr. Colitz?
10 A
Yes, that's correct.
11 Q
someone perhaps like Mr. Arnold?
12 MR. MacDONALD:
I object to the form.
13 Are you asking specifically whether the request
(
14 was generated to Mr. Arnold?
15 MRS. VAUGHAN:
That's right.
16 A
I said I don't recall at the time who the 17 requests were made of.
18 Q
Mr. Harbin, statistical reports that you 19 mentioned, you described as those I believe relating 20 to outages or availability; is that correct?
21 A
Those are two examples of the kinds of statistics.
22 Q
For whom would you be preparing those 23 kind of reports?
Again I am looking at just 1977, 24 A
As I said, I didn't prepare the reports, I
25 assisted in preparing the reports.
s/
1 Harbin 22 2
Q
'That's fine.
1 3
Let's take it this way.
With whom or 4
4 for whom were you assisting?
Whom were you assisting?
)
5 MR. MacDONALD:
I think we have two r
6 questions.
7 Q
Whom were you assisting?
8 A
I received input from other people on the' 9
staff so in that respect I assisted them and in 10 another respect I assisted the superintendent.
11 Q
In what respect did you assist the 12 superintendent?
13 Let me ask it this way.
Was the
()
14 superintendent the individual who was asked to put-15 together this statistical report and then turn 16 around and ask you to gather the information for him, 17 is that what you are describing?
18 MR, MacDONALD:
You talk of this i
19 statistical report.
He said he prepares 20 statistical reports of which he gave a 21 couple of examples of types.
Are you asking
]
22 about generally these types?
i-j-
23 MRS. VAUGHAN:
Generically, yes, that's 24 right.
25 A
There existed a need to have someone coordinate s-6
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1 Harbin 23 I
2 for the staff various reports and the superintendent 3
was a focal point in the unit and as his assistant 4
he delegated to me the responsibility for coordinating
)
5 the input for and issuing those reports.
4 6.
Q How did you know what was to go into a 7
statistical report?
8 A
Most of the reports consisted of forms that 9
were completed.
It just consisted of filling out 10 the forms.
11 Q
Were those forms internal forms?
12 A
Not all of-them, no.
13 Q
If they were external forms, where would
()
14 the forms come from?
15 A
I can't say in all cases.
16 An example -- an example is the NRC monthly 17 operating report, the form for that report is 18 provided in a regulatory guide.
19 Q
Would these statistical reports be the 20 kind of a report that would go to the Licensing 21 Department for their review?
22 A
Some of them.
23 Q
And how about the operating experience 24 reports that you have described?
t.
25 A
The correct title of that report, that I was
)
1 Harbin 24 2
referring to, is the NRC monthly operating report.
(-
4\\
3 What was the question?
4 Q
The question was:
For whom were you
)
5 preparing that report?
6 MR. MacDONALD:
Preparing in the sense that I
he has already testified to?
O MRS. VAUGHAN:
That's right.
9 A
The report was sent to the Licensing Department I
10 by my office.
11 Q
Were there any other responsibilities 12 that you had while working for Mr. Colitz?
You have 13 indicated the review of mail and the generation and 14 preparation of certain kinds of reports.
15 A
As the Unit.1 superintendent which was a focal 16 point type position as I just mentioned, a lot of 17 action items were received from other parts of the l
18 o rga ni za tion.
I 19 Q
Excuse me, did you say ac tiran items?
I 20 A
Yes.
And they were either already assigned to I
l 21 members of his staff or he assigned or reassigned the i
22 items to members of his staff.
23 Q
Excuse me, "his" is the unit superintendent?
24 A
Yes.
~
25 And one of my responsibilities was to insure
i 1
Harbin 25
)
2 that action -- the appropriate action was taken in f-N k--)
3 a timely manner.
4 Q
Were you supposed to review the action
)
5 that was taken from a substantive point of view?
6 A
Sometimes.
7 Q
When you say "sometimes," does that mean 8
that there were some kind of subject matters that 9
you did not review and some subject matters that you 10 did review?
11 A
I wouldn't say that.
12 Q
Then why was it sometimes you reviewed 13 them substantively?
()
14 A
It may have depended on how busy I was, it 15 may have depended on the subject matter, it may have 16 depended on who it was assigned to, a variety of 17 things.
Those are three examples.
18 Q
If for instance you were too busy to 19 review them from a substantive point of view, did 20 somebody else undertake that review?
21 MR. MacDONALD:
You are asking for his 4
22 specific" recollection of times when he may 23 have been too busy to review?
24 MRS. VAUGHAN:
Yes.
25 MR. MacDONALD:
Can you recall such?
u
1 Harbin 26-2 A
I don't recall any specific instances.
'A 3
Q' Do you recall any instances in which you 4
were too busy and an action item was not reviewad,
)
5 substantively?
6 A
It wasn't my responsibility to review the 7
response to the action item or to follow up to 8
insure that action was taken.
It was usually -- for 9
any action items that were received the organization 10 or the individual that had issued the action item 11 was responsible for doing that follow up.
12 Q
I thought I understood you to say that 13 you reviewed the action items substantively.
14 MR. MacDONALD:
I object to the form.
15 A
I didn't testify to that.
16 MR. MacDONALD:
I object to the form.
I 17 don't think he testified to that.
18 MRS. VAUGHAN:
Let me make sure I 19 understand.
20 Q
You did not review these action items 21 substantively; is that right?
22 A
No, I didn't say that.
23 Q
What did you say?
24 A
I said I reviewed some for substance.
25 Q
All right.
And then my question was:
Why
~. _.,,.,,
1 Harbin 27 2
did you-review some for substance and some you O(_/
3 didn't. review for substance?
4 A
And I gave you three reasons as examples.
)
5 Q
And then my question was:
If you were 6
too busy and you did not review an action item for 7
substance, does that mean it did not get reviewed 8
for substance?
9 MR. MacDONALD:
I object, He said he 10 had no recollection that ever specifically 11 happened.
He put out three examples of 12 possibilities, not that any one of them ever 13 happened but as examples to try to fully
()
14 answer your question.
He didn't recall any 15 speci fic o'f ever being too busy as a recollection 16 that that ever happened to be able to give you 17 an answer.
18 You can ask him again.
19 Q
was it your job to review these action 20 items for substance?
Was that your responsibility?
21 A
No, I don't recall that it was.
22 Q
What was your specific responsibility with 23 respect to the action items?
24 A
To keep track of selected items and to remind l
25 those that were responsible of due_ dates, that it was l
\\_
l l
1 Harbin 28 2
the primary responsibility,
-,O
' '/
3 Q
When you say to keep track of selected 4
items, does that mean that there were some action 5
items that you were not to keep track of?
6 A
I was not assigned action items that I was not 7
to keep track of, no, I don't think you could say 8
that.
Or I was not provided action items for other 9
people that I was not to track.
10 Q
What did you mean when you used the 11 words" selected items"?
12 A
Well, I made a decision in many cases on which 13 items I would follow and which I wouldn't.
)
14 Q
How did you make that decision?
15 A
Based on the importance of the item is one 16 example as I perceived it as to whether or not it 17 ever got resolved, based on my knowledge of the 18 staff, members of the staff and their reliability 19 for following up on action, action items, that's 20 another example.
21 Q
Did you use any kind of a log to keep 22 track of the action items?
23 A
Just so we are all talking about the same 24 thing, we are talking about during the time period r^g 25 that I worked for Joe colitz?
v) t
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1 Harbin 29 2
Q That's right, 3
A The're was one system that I recall, there may 4
have been more.
)
5 Q
What was the system that you recall?
6 A
It was a system that was managed in the Reading 7
office and I believe that the system, the normal 8
description of the system was the action item 9
service request tracking system.
It was a computerized 10 system.
11 Q
Could you describe how that worked?
Would 12 you get a computer printout of action items, is 13 that the idea?
%..)\\
14 A
Yes.
15 Q
Then you would just use that yourself as 16 a guide to see which ones were being followed up on 17 or when their due date was?
18 A
Yes.
19 Q
Would that computer printout tell you 20 who was working on the action item or to whom it was
)
21 assigned?
22 A
It usually did.
It wasn't always correct.
23
.Q During the time you were working for 24 Mr. colitz, do you remember any other kind of system 25 gg being used?
s_)
1 Harbin 30 2
MR. MacDONALD:
You are talking now for 1
3 action items?
4 MRS. VAUGHAN:
That's right.
5 MR. MacDONALD:
Of the type he has 6
described?
7 MRS. VAUGHAN:
Yes.
8 A
I don't recall if there were any others.
9 9
Q In addition to the computer printout that 10 was generated from Reading, did you employ any 11 system yourself, individually, to keep track of the 12 action items?
Again in this time frame when you 13 were working for Mr. colitz, 14 A
An informal system of keeping open items on
+
15 my desk.
1 4
16 Q
Any other system?
Did you.ask your 17 secretary to keep a log or a lis t of any kind?
18 A
Not that I recall.
19 Q
were there any other job responsibilities 20 that you haven't described when you were working for 21 Mr. Colitz?
22 MR. MacDONALD:
That he can recall?
23 MRS. VAUGHAN:
Yes.
24 A
various project type responsibilities.
(~)
25 Q
What do you mean by project type of
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1 Harbin 31
.2 responsibility"?
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A An example two examples, I maintained the 4
company cameras, I had a file cabinet full of camera
)
5 equipment.
6 Q
You are talking about regular cameras?
7 A
Yes, that either I used to photograph occurrences 8
on site or loaned out to other people to photograph 9
occurrences.
10 I played a part in planning for tours tours 11 of the plant, assisted in preparation and planning 12 for various meetings.
13 Q
Meetings involving Mr. Colitz?
(A) 14 A
Sometimes.
15 Q
Anything else?
16 A
Those are examples of projects.
A lot of 17 other projects related..
18 Q
Any others that you can remember in this 19 time frame?
20 A
No.
21 Q
Do you know whether your job responsibilities 22 as distinct from the title that you held at that time 23 was performed by somebody -- did you have a predecessor?
24 A
No, I didn't.
"'S -
25 Q
You were the first person to perform
'u ]
1 Harbin 32 2
these kinds of responsibilities for the unit
/~kT i
l 3
superintendent?
4 A
No, 1 don't think you can say that.
)
5
.Q Do you know whether the responsibilities
't 6
were performed by other people prior to your taking 7
on that job?
I 8
A Some.
Some I know of.
9 Q
Which ones do you know of?
j 10 A
Preparation of reports was handled by an 11 individual that also dealt with personnel.
12
-Q Who was that individual?
13 A
I recall that Peters was his last name.
- [ )\\
14 Q
Is he still employed by Met Ed?
15 A
No.
16 Q
Is he employed by GPU?
17 A
No.
18 Q
Did he leave when you assumed your a
j 19 responsibilities?
4
'20 A
I-recall that he left before I assumed my 21 responsibilities.
22 Q
Before you assumed your responsibilities?
23 A
Yes.
24 Q
Is there anyone else you can recall who em) 25 had some of your responsibilities?
y)
=_
1 Harbin 33 2
A Somebody named Walt Poyck kept the cameras.
3 Q
Anybody else?
4 A
Not that I can recall.
)
5 Q
How about reviewing the correspondence 6
that was received by the unit superintendent?
7 A
No, no one.
8 Q
No one?
9 A
That I knew of.
10 Q
How about the preparation of any specific 11 reports that you have mentioned for instance 12 environmental reports?
Were they all prepared by 13 Mr. Peters or were they prepared by somebody else?
()
14 A
I don't know that for sure.
15 Q
Do you know about the statistical reports?
16 A
I don't know that.
17 Q
And the operating experience reports?
18 A
The NRC monthly operating experience or monthly i
19 operating report?
20 Q
Right, as one of them, if there are others, 3
21 I would like to know those, too.
)
i 22 A
I know again I believe that the reports that I 23 prepared were the same reports that he prepared but 24 I don't know that for a fact.
25
- Q Mr. Peters?
(
4 a-,
,o.
~
1 Harbin 34 2
A Yes.
3 Q
Did Mr. Peters ever have an opportunity 4'
to give you any guidance on how to go about preparing
)
5 these reports?
6 MR. MacDONALD:
I object to the form.
7 Are you asking him whether he ever did or 8
whether Peters before Harbin had the opportunity, 4
9 I mean opportunity --
10 MRS. VAUGHAN:
I used the word opportunity 11 because he indicated Mr. Peters left before he 12 assumed the job responsibilities.
13 Q
Did Mr. Peters ever brief you or give
()
14 you any instructions?
15 A
No.
16 Q
Did he leave you any files?
17 A
Yes, he did.
18 Q
What were the 19 A
He also left instructions.
20 Q
He did leave instructions?
21 A
Yes.
22 Let me add, too, that after he left a Mr. Hahn, 23 Garry Hahn filled in for the responsibilities of 24 filing reports for I believe a.two-month period and d
1 g
f 1
Harbin 35 2
instructed me as to the responsibilities of performing
\\/
3 that function.
4 Q
And then after Mr. Hahn you picked up
)
5 the function; is that correct?
6 A
'Yes, that's right.
I 7
Q Do you know why it was decided that these 8
various responsibilities and functions should be 9
centered in one person?
10 A
Did I know that then?
I l
11 Q
When you were being interviewed did 12 anybody in discussing the job with you indicate why 13 it was that they were looking for an individual to
(
14 assist Mr. Colitz and to perform these various 15 responsibilities?
~
16 A
When I was being interviewed there wasn't 17 much discussion as to what the responsibilities would 18 be.
19 Q
What job did you understand you were 20 being interviewed for?
21 A
The functional position was assistant to the 22 Unit 1 superintendent.
23 Q
And at the time you were being interviewed 24 was there any discussion at all as to the responsibilitie s 25 that you would be undertaking?
x i.........
1 Harbin 36 2
A I don't recall what they were.
Ns) 3 Q
Do you reca11'that there was a discussion?
4 A
If I don't recall what they were, then I don't
)
5 recall that there was.
6 Q
Was there, before you assumed your job 7
responsibilities, an assistant irrespective of what 8
the title was to the unit superintendent?
9 A
Not in that functional capacity, no.
10 Q
In any other capacity?
11 A
Well, like I said, reports were prepared before 12 I came.
13 Q
Did anyone discuss with you why they e( s) 14 felt there was a need for an assistant to the
%_J 15 superintendent?
I 16 A
Yes.
17 Q
And what was said, what was that?
18 A
I don't recall specifically but I know again 19 that there were many administrative responsibilities, 20 some administrative responsibilities that the Unit 1 21 s up erinte ndent had that I could relieve him of.
22 Q
What kind of responsibilities were you 23 relieving the unit superintendent of?
24 A
one example is reviewing all his mail.
g-25 Q
Any others?
UI
1 Harbin 37 2
A Assisting in the preparation of or for h(_/
3 meetings, tours, presentations.
4 Q
When you were interviewing did you
)
5 interview Mr. Colitz, when you were interviewing for 6
your job?
7 MR. MacDONALD:
Was he interviewed by 8
Mr. Colitz?
9 MRS. VAUGHAN:
Excuse me, yes.
10 A
Yes, he did.
11 Q
Did I understand when we were talking 7
12 about your educational background that you said you 13 had not taken any courses in nuclear energy?
()
14 A
No, I didn't say.that.
15 Q
Do you have any scientific or did you 1
16 take any courses of a scientific nature?
17 A
Yes, I did.
18 Q
Which kind of courses were they?
19 A
My last year in high school I took a vocational 20 electronics course.
I g
21 Q
How about just in college?
\\
)
22 A
Well, none in college but in the military.
I i
23 had some technical training.
I 24 Q
When were you in the military?
S 25 A
From June of '76 to March of I am sorry, June x_)
1 Harbin 38 2
of '67 to March of
'72, r) xl 3
Q Do I understand that to be after high 4
school?
5 A
Yes.
6 Q
And before 7
A college.
8 Q
college.
9 Which branch of the service were you in?
.10 A
The Navy.
11 Q
What were your experiences, work 12 experiences in the navy?
13 A
I went to school for almos t half of the time
(
14 that I was in, the rest of the time I was an 15 -
electronics technician on a submarine tender and 16 the remainder of the time I stood watches on a nuclear 17 submarine.
18 Q
Which nuclear submarine?
19 A
The U.S.S.
NATHAN HALE.
20 Q
Where was that stati.oned?
21 A
The submarine itself was home ported in Guam.
22 Q
How many years were you attached to the 23 Nuclear Navy?
24 MR. MacDONALD:
On that particular sub?
(~}
25 A
A year and a half.
\\%/
1 Harbin 39 2
Q Were there any other nuclear subs that (D '
w/
3 you were attached to?
4 A
No.
)
i 5
Q Did you, during the time you were in 6
the Navy, have any training in nuclear background?
7 A
Yes,.I did.
8 Q
When was that and what kind of training?
9 A
The Navy has a standard program to qualify 10 three different rates in the nuclear field and as 11 an electronics technician I went to the program that 12 was geared for a reactor operator and it consisted 13 previous to-the nuclear training, it consisted of O()
14 a little over a year of electronics training and 15 the first nuclear training was six months of textbook 16 and classroom schooling in California and that was 17 followed by six months of prototype training in Idaho 18 and that was followed by three months of submarine 19 school and after that I was assigned to a sub, a 20 submarine and while on the submarine I was in 21 training the entire time I was on the submarine 22 qualifying for various positions and going to various 23 specialty schools when we were in port.
24 Q
When you say qualifying for various 25 positions, what kind of positions do you mean or what O( 3 ^
i
1 Harbin 40 2
kind of positions did you actually receive training
(
\\
3 for to qualify for?
4 A
By title?
I 5
Q or description.
6 A
one was tunnel watch, one was the machinery II, 7
upper level watch, one was reactor operator and one 8
was shutdown maneuvering area watch.
9 Q
Were you licensed or are you licensed as 10 a reactor operator?
11 A
I was.
12 Q
While in the Navy?
13 A
Yes.
O
(,;
14 Q
Was the nuclear system that you were 15 trained on in the Navy the same as that which is 16 used at Met Ed, TMI?
In other words, is it a 17 pressurized water reactor?
18 A
Yes, they are both pressurized water reactors.
19 Q
Was your Navy nuclear background a 20 consideration when you were applying for the position 21 as an assistant to Mr. Colitz?
22 MR. MacDONALD:
Are you asking him whether 23 he knows whether Mr. Colitz considered it or 24 told him?
25 MRS. VAUGHAN:
Or whether it was in fact
'(.-
/
1 Harbin 41 2
a job qualification that the person who was O
~I 3
an assistant to Mr. Colitz have some nuclear
-4 background experience.
)
5 A
I don't know whether it was a job qualification.
6 I know it was a consideration.
7 Q
You know it was a consideration?
8 A
Yes.
9 Q
How did you know that?
4 10 A
It was discussed at the time of the interview.
11 Q
Are there any other responsibilities 12 that you can recall while you were working for 13 Mr. Colitz that we haven't already mentioned?
OV 14 A
No.
15 Q
when you were working for Mr. O'Hanlon 16 MR. MacDONALD:
Is this a good time to 17 take a short five-minute break?
18 MRS. VAUGHAN:
Sure, that's fine.
19 (Recess taken.)
20 BY MRS. VAUGHAN:
21 Q
Mr. Harbin, you have described your 22 responsibilities while you were working for 40c. Colitz 23 or as an assistant to Mr. Colitz, 24 Did those responsibilities change in any
/~T 25 way when you worked for Mr. O'Hanlon?
U
1 Harbin 42 2
A I don't recall that they did.
.O 3
Q You mentioned earlier, I believe, that 4
when you became a technical analyst III that you
)
5 assumed some additional responsibilities; is that 6
correct?
7 MR. MacDONALD:
Are you asking him if 8
that's what he has testified to earlier?
9 MRS. VAUGHAN:
That's right.
10 MR. MacDONALD:
Or is that a question that 11 you are posing to him now?
12 MRS. VAUGHAN:
Is that a correct 13 characterization of his earlier testimony.
s
[')N
(_
14 MR. MacDONALD:
I object to the form.
15 The record will speak for itself on what he 16 said.
17 You can ask him that question again if 4
18 you like.
I think what he said is on the 19 record.
20 Q
You can answer.
s 21 A
What I said earlier is correct.
()
22 Q
What I characterized it as?
23 A
I don't recall if that's exactly the way you 24 characterized it.
25 Q
Did your responsibilities broaden under
1 Harbin 43 2
Mr. O'Hanlon as you became a technical analyst III?
(~)
\\
J 3
MR. MacDONALD:
From his responsibilities 4
that he had under Mr. Colitz or during the
)
5 time that he 6
MRS. VAUGHAN:
Let's take it this way.
7
. Q During the time that you were unde.r Mr.
8 Colitz and an engineering assistant II, that was 9
your job title.
Under Mr. O'Hanlon at some point 10 and I can' t tell, maybe you can answer whether you 11 became a technical analyst III before you started 12 working for Mr. O'Hanlon or when you started working 13 for Mr. O'Hanlon?
C%
(,)
14 A
It wasn't concurrent with my starting work for 15 Mr. O'Hanlon.
16 Q
Did you become a technical analyst III 17 before you started working with Mr. O'Hanlon?
18 A
I don't recall.
19 Q
A technical analyst III is a promotion 20 from an engineering assistant II; is that correct?
21 A
There was a pay increase associated with the 22 change in titles.
23 Q
Were there additional responsibilities-24 associated with the change in titles?
( (-}
25 A
I already answered that.
' \\,_/
i l
y c,-,--.+-egy.-
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-'*---T--w-&---
- +. ' - --
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iw-
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1 Harbin 44 2
Q Could you repeat your answer, please?
N_ -
3 A
There was no step change in responsibilities 4
that I recall.
)
5 Q
what was the change in responsibilities, 6
if any?
7 A
well, as I already testified both prior to i
8 and following, the change in titles, an example of 9
increased responsibilities was that I reviewed and 10 acted on more correspondence received by the Unit 1 11 superintendent or addressed to the Unit 1 superintendent.
12 Q
I would like you to, if you can, describe l
13 the additional correspondence that you were reviewing l
14 for the unit superintendent that you did not review 15 as an engineering assistant.
16 MR. MacDONALD:
Are you asking whether 17 it was different types of correspondence or 18 just more of the same correspondence?
19 MRs. VAUGHAN:
He has indicated --
20 Q
Let me ask yo-,
was it different types 21 of correspondence or more of the same?
22 A
Neither one.
23 Q
what was it?
24 A
It was the same.
f 25 Q
It was the same correspondence?
A
__._____m_
1 Harbin 45 1
t 2
A Yes.
O
\\/#
3 Q
When you say you reviewed more correspondence,
4 what did you mean?
)
5 A
I didn't say that.
6 Q
What did you say?
7 A
I said I acted on more correspondence.
8 Q
And what did you mean by that?
9 A
I_mean that from the time that I was employed 10 by the company because of some initial training that 11 I had within the company, and because of my 12 familiarity -- increased-familiarization with the 13 staff as far as who was responsible for what, that
()
14 I became more knowlegeable on who handled what type 15 of items and therefore was able to make more decisions 16 on my own as to who was assigned action on'various 17 pieces of correspondence.
18 Q
Did you yourself assign action on various 19 pieces of correspondence?
20 A
In some cases.
21 Q
In what kinds of cases?
22 A
Well, one type of correspondence would be one 23 that was received, that the unit superintendent 24 received for information, received a carbon copy
1 Harbin 46 2
or engineers, members of the staff for information
\\-
3 only, it is not an example of something for action, 4
it's a matter of interpretation.
)
5 Q
Did you pass on something for action?
6 A
.I don't recall any specific piece of correspondence 7
that I passed on for action.
8 Q
Before you assumed, I gather your 9
testimony is that this is an additional responsibility 10 that you assumed, that is some of the items of mail 11 that the unit superintendent would receive on 12 which he would be copied and you would pass along 13 for information to others, was that an additional 14 responsibility that you did not have earlier as an
~
~
15 engineering assistant?
16 A
No, I didn't say that.
17 Q
I was seeking examples of additional 18 kinds of responsibilities that you had dealing with 19 the correspondence.
20 A
Yes.
I just don't remember any specific 21 increased responsibilities that I took on when I 22 accepted the position of technical analyst III.
23 Q
Is it fair to say then that your 24 responsibilities were the same as the technical r~N 25 analyst III.as they were as technical analyst II?
N.
1 Harbin 47 l
2 A
No.
3 Q
They were different but you don't recall 4
4 what additional responsibilities you had, is that
)
5 your testimony?
4 I
6 A
I testified that I was an engineer assistant II.
7 Q
Right.
8 A
For a year and a half.
t 9
Q Right.
10 A
over that year and a half period my responsibilitios 11 changed.
I don't think it is fair to say that as an 12 engineer assistant II my responsibilities were the 13 same as they were as a technical analyst III and I
<(
14 testified that there was no step change.
15 g
All right.
What do you mean by a step-J 16 change?
i
]
17 A
The day that I I would define a step change l
18 to mean that on the day that the title became effective, i
19 that I accepted some responsibility that I didn't 20 have before.
i c
I 21 Q
All.right.
On the day that you accepted
)
22 the job as an engineering analyst II, at that point 23 in time was it your responsibility to review all of 24 Mr. colitz' mail?
25 A
I never held that title.
(~)'s
\\.
l s
t.
1 Harbin 48 2
Q Excuse me, engineering assistant II.
('/)
\\_
3 A
What was the question again?
4 Q
On the day you accepted the position
)
5 as an engineering assistant II Nuclear, was one 6
of your job responsibilities reviewing Mr. Colitz' 7
mail?
f 8
MR. MacDONALD:
You are talking about 9
the first day he started work?
10 MRS. VAUGHAN:
The first day.
11 A
I don't recall.
12 Q
At what point in time do you recall that 13 your responsibility was to review his mail?
()
14 A
I don't recall how that transition took place 15 or when.
16 Q
Was there a time when you did not review 4
17 his mail?-
18 A
I don't recall.
19 Q
Did you review Mr. O'Hanlon's mail when 20 you started working for him?
21 A
I reviewed some mail that was addressed to him 22 as Unit 1 superintendent.
23 Q
Was the mail that you reviewed, which 24 was addressed to alm, different in any way from the g3 25 mail that you reviewed for Mr. Colitz?
U
1 Herbin 49 2
MR. MacDONALD:
In terms of types rather
/^
t
\\
3 than each specific piece of mail received?
4 MRS. VAUGHAN:
However he remembers it.
)
5 If he remembers it by type, if he remembers 6
it by specific piece, either way.
7 A
Well, certainly not by specific piece.
8 In general, yes, by types in that they both 9
held the position, the Unit 1 superintendent and 10 most mail that I -- well, the mail -- mos t mail that 11 I reviewed for both Colitz and O'Hanlon was mail 12 that was directed at them in Unit 1 superintendent.
13 Q
Di d Mr. O'Hanlon ever say to you "I
()
14 don't want you to review this kind of mail because I 15 will look at it first"?
16 A
I don't recall him saying that.
17 Q
Do you recall Mr. O'Hanlon saying that 18 he wanted you to review a kind of mail that you had 19 not reviewed for Mr. Colitz?
20 A
No, I don't recall him saying that.
21 Q
When you were working for Mr. O'Hanlon, 22 did you have responsibility for reports, statistical 23 reports?
i 24 MR. MacDONALD:
Excuse me, can I just p
25 hear that question again?
\\j r
1 Harbin 50 2
MRS. VAUGHAN:
Yes.
3 Q
when you were working for Mr. O'Hanlon, 4
did you have responsibility for generating or
)
5 preparing statistical reports?
6 MR. MacDONALD:
In the same sense that 7
he --
8 MRS. VAUGHAN:
Testified to earlier.
9 MR. MacDONALD:
Which he testified to i
10 before which I don't think was necessarily 11 the sole preparation.
That's the only reason 12 I raise that.
13 MRS. VAUGHAN:
Sure.
I) 14 A
Yes, I don't recall if they were exactly the
'V 15 same reports, in most" cases the same reports, the 16 same type of function.
17 Q
Did you have the same type of function 18 with regard to operating experience reports that 19 you had described before while you were working for 20 Mr. O'Hanlon?
21 A
I really don't recall that.
22 Q
You do not recall whether you had that?
23 A
No.
24 Q
Do you recall that you did not have it?
g 25 A
No.
U
1 Harbin 51 2
Q what about environmental reports?
Did
(~'/\\
\\_
3 you have that responsibility with Mr. O'Hanlon?
4 A
I performed essentially the same function for
)
5 Mr. O'Hanlon as I did for Mr. Colitz with respect 6
to environmental reports, yes.
7 Q
while you were working for Mr. O'Hanlon 8
did you have responsibility for keeping track of 9
action items?
10 A
I don't recall.
11 Q
You don't recall whether you did or 12 whether you didn't one way or the other?
13 A
I don't recall whether I did.
(-}s 14 Q
Did you have responsibility while you 15 were working for Mr. O'Hanlon to maintain the camera 16 file?
17 A
Yes, I did.
18 Q
Did you have responsibility while working 19 for Mr. O'Hanlon with respect to setting up tours of 20 the plant or arranging for tours of the plant?
21 A
Handling the planning for.
22 Q
Did you, while you were working from 23 Mr. O'Hanlon, also assist to prepare for meetings?
24 A
Some meetings, yes.
j i
25 Q
Does that include helping Mr. O'Hanlon v
i
i' 1'
Herbin 52 2
himself prepare for the meeting?
bi
\\>
3 A
Could you rephrase that?
4 Q
Does that include helping Mr. O'Hanlon
)
5 himself prepare for the meeting?
In other words, 6
would you gather materials for him to review?
7 A
Yes, I would.
8 Q
I am talking now of something other than 9
just the administrative function of actually setting 10 up a meeting.
11 Is-the answer still yes?
12 A
The gathering of information that I did I 13 still considered administrative in that I primarily l
r~)j collected it from other sources.
\\
14 l
15 Q
Would he te'll you what information he 16 wanted?
17 A
Yes, basically.
18 Q
In addition to these responsibilities 19 that we have just gone,through,are there any other 20 responsibilities that haven't been mentioned that 21 you had wt.ile you were working for Mr. O'Hanlon?
22 A
Not that I recall.
23 MRS. VAUGHAN:
I would like to have 24 marked as B&W Exhibit 202 an organization chart 25 dated 1/1/79, the top of the chart reads v
1 Harbin 53 2
"TMI supervisory."
(~N
)
k-3 (organization chart dated 1/1/79 headed 4
"TMI Supervisory" marked B&W Exhibit 202
)
5 for identification, as of this date.)
6 (Handing document to the witness.)
7 Q
Mr. Harbin, under the column marked 8
Unit 1 your name appears under Mr. Seelinger's; is 4
4 9
that correct?
10 A
Yes, I believe it does.
11 Q
Is it also correct that you still held 12 the job title technical analyst III - Nuclear?
13 A
Yes.
()
14 Q
And I believe this chart also shows that 15 the unit sup erin tenden t for Unit 1 at this time was 16 Mr. seelinger, is that also correct?
17 A
At the time that this exhibit is dated, 1/1/797 18 Q
That's correct.
Does this exhibit show 19 Mr. seelinger as the unit superintendent for Unit 1?
20 A
Yes, it does.
21 Q
Do you know when Mr. Seelinger became 22
. the unit superintendent for Unit 1?
23 A
No, I don't know that.
24 Q
Do you know that at the time this chart
/N 25 is dated he was not the unit superintendent?
b
1
- Harbin, 54 2
A No, I don't know that, 3
Q Did your job responsibilities,while you 4
were working for Mr. Seelinger remain the same as
)
5 those that you had while you were working for 6
Mr. O'Hanlon?
7 A
To the best of my knowledge.
8 Q
Do you recall whether any particular 9
functions that you had previously performed you 10 ceased performing?
11 A
No.
12 Q
Do you recall that there were any 13 additional functions that Mr. Seelinger asked you to
(
14 perform that you had not performed for Mr. O'Hanlon?
15 A
No.
16 Q
Did you review for Mr. Seelinger as you 17 had for Mr. O'Hanlon all the mail that came in 18 addressed to the unit superintendent with the exception 19 that we had mentioned before of personal or confidential 20 mail?
21 A
Yes, that was the standard practice under 22 Mr. Seelinger.
23 g
while you were working for Mr. Seelinger, 24 did you have anyone working or reporting to you?
25 A
No.
g-)
V
1 Harbin 55 2
Q Is that also true for while you were N/
3 working for Mr. O'Hanlon?
4 A
Yes, that's correct.
5 MRS. VAUGHAN:
I would like to have 6
marked as B&W Exhibit 203 for identification another organization chart, this one dated 8
1/31/80 and it is titled " Metropolitan Edison 9
Company, Three Mile Island, Unit 1."
10 (Organization chart dated 1/31/80 titled 11
" Metropolitan Edison Company, Three Mile 12 Island, Unit 1" marked B&W Exhibit 203 for 13 identification, as of this date.)
14 (Handing document to the witness.)
15 Q
Mr. Harbin, do you see your name on this 16 chart?
17 A
Yes, I do.
18 Q
Technical analyst - III; is that correct?
19 A
Yes, it is.
20 Q
And at this point in time,according, to 21 this chart,to whom did you report?
)
22 A
cary Miller, manager of Unit 1.
23 Q
when did Mr. Miller become the manager 24 for Unit 1?
(~%
25 A
I don't-recall.
U g-r,
-.,,7--e, n,
-r-
1 Harbin 56 2
Q Have you worked for him since he has O(>
3 become the manager for Unit 1 at all times he was 4
the manager of Unit 17
)
5 A
Excuse me.
This conflicts with what the paper 6
says.
I don't know that he was the manager of 7
Unit 1.
8 Q
What do you know he was?
9 A
It was my perception at the time that he was 10 acting unit superintendent.
11 Q
He was acting unit superintendent?
12 A
Yes.
I am not saying for a fact that this is 13 wrong.
()
14 Q
Do you recall when he became acting 15 superintendent for Unit 17 16 A
To the best of my knowledge when Mr. Seelinger 17 left.
18 Q
Do you remember when that was?
19 A
No, I don't recall.
20 Q
Is Mr. Miller still the acting 21 superintendent for Unit 1?
22 A
Well, let me just restate that to the best of 23 my knowledge that was his title.
I don't know that 24 so -- and you are referring to him as that.
~N 25 Q
Is Mr. Miller either acting or superintendent.
(Y
1-Harbin 57 2
or manager for Unit 1 at this point in time?
%/
3 A
No, he is not.
4 Q
What is he now?
)
5 A
I am not sure what his title is.
6 Q
Who holds the position of superintendent 7
for Unit 1?
8 A
There is no position.
9 Q
For whom do you work now?
10 A
Let me explain what happened to the position.
11 Q
Sure.
12 A
Mr. Miller was -- he was holding the capacity 13 of Unit 1 superintendent, whatever the title was
()
14 after Mr. Seelinger left and until a Unit 1 replacement 15 was found and that replacement was Mr. Toole and 16 that was -- I don't recall exactly what the period 17 of time was that Mr. Miller filled that position but 18 approximately five months and I reported to him during 19 that period of time.
20 Q
Reported to Mr. Miller?
21 A
Yes.
22 Q
Yes?
23 A
And then Mr. Toole became the Unit 1 24 superintendent,sometime thereafter he became the gg 25 manager of Unit 1 and sometime after that he became b
1 Harbin 58 2
the operations and maintenance director, Unit 1,
O)
\\_/
3 which is the position he holds now and so that the 4
unit the position, Unit 1 superintendent no
)
5 longer exists nor at the present day, nor does the 6
manager of Unit 1 exist.
7 Q
Are the functions to the extent they 8
are necessary at this point in time that were 9
performed previously by the unit superintendent now 10 performed by Mr. Toole?
11 A
I would rather not comment on his functions.
12 I know that organizational 1y there have been c.
13 changes.
(%)
14 Q
For whom do you work at this time?
E 15 A
Ron Toole.
16 Q
Have your functions at this time changed, 17 your responsibilities as we have been discussing 18 them at this point in time, not today.
19 A
Since this time (indicating)?
20 Q
Yes.
21 MR. MacDONALD:
Meaning 1/31/80.
22 Q
Well, as of today have your job 23 responsibilities changed from what we have previously 24 been discussing?
rN 25 A
Yes, they have.
()
l
~
1 Harbin 59 2
Q Could you describe those changes?
m 3
A some responsibilities some examples of 4
responsibilities that I have given up are preparation
)
5 of some of the reports, maintaining the camera 6
equipment, the review of certain industry publications, 7
some responsibilities that I picked up, examples 8
of some responsibilities that I picked up are the 9
review of outstanding regulatory correspondence, 10 review of changes to procedures, review of 11 modifications to the plant, some modifications to 12 the plant.
j 13 Q
Do I understand from what you have said
()
14 that you do review some of the correspondence that 15 would come to Mr. Toole but not all of it?
16 A
Yes, that's correct.
17 Q
Let's go back to the organization chart 18 marked 203, B&W Exhibit 203, the one dated 1980.
19 A
Yes.
20 Q
During this time period when Mr. Miller 21 was either acting superintendent or manager of 22 Unit 1 as the case may be, or even superintendent, 23 did you perform for him the same functions which 24 you had previously performed for Mr. Seelinger?
25 A
No.
NJ
1 Harbin 60 2
Q What was it that was different about f'h k-3 what you did for Mr. Miller?
4 A
one thing was that I spent 20 minutes a day
)
5 briefing him on correspondence that was received 6
or that was directed at the Unit 1 superintendent 7
and he would make some indication as to what action 8
should be taken and I would either assign that out 9
in accordance with his direction or take whatever 10 action he recommended.
11 Q
Could you describe more specifically 12 how that differed from what you did when you reviewed 13 correspondence for Mr. Seelinger?
()
14 A
There was less rapport between Mr. Seelinger 15 and myself.
16 Q
Does tha t mean --
17 A
on a daily basis.
18 Q
Does that mean that you would not brief 19 Mr. seelinger personally for 20 minutes or so?
20 A
In general.
Tha t doesn ' t exclude my briefing 21 him for 20 minutes.
There were times that I did 22 that but not as a general rule on daily correspondence.
23 Q
In other words, it was more regular and 24 more a part of your daily routine with Mr. Miller; p
25 is that correct?
i l
L
1 Harbin 61 2
A Yes.
The purpose of that was, as I perceived 3
it, was because until that time he wasn't that ss 4
closely associated with the functions of the office
)
5 of Unit 1 superintendent.
6
-Q Mr. Miller was not?
7 A
That's right.
And so that he could be familiar 8
with the kind of things coming through the office he 9
wanted to know in more detail about correspondence.
10 Q
Would Mr. Miller give you more specific 11 directions with respect to correspondence than 12 Mr. Seelinger did?
13 A
Not necessarily.
(
14 Q
Would Mr. Seelinger tell you where 15 to send, forward on the cor'respondence that you had 16 reviewed?
17 A
The general practice was that if I reviewed 18 correspondence and gave it to him, then he decided 19 where it went and sent it on or gave it to his 20 secretary.
21 Q
This was Mr. Seelinger?
22 A
Yes.
23 Q
All right.
24 A
If it didn't go to him then I made that 25 determination.
O.
e y.
,.._.,,-y
,w.rr
1 Harbin 62 2
Q Other than the correspondence, what
-s 3
else was different about the functions that you 4
p erformed, f o r Mr. Miller as opposed to what you
').
5 had done for Mr. Seelinger?
6 A
I don't really recall any other specific.
7 Q
While you were working for Mr. Miller 8
were you still involved in the generation or 9
preparation of the reports that you have described 10 previously?
11 A
Some of the reports.
12 Q
Do you recall any specific reports that 13 you were involved with while you were working for
()
14 Mr. Miller?
15 A
NRC monthly operating report.
16 Q
Anything else?
A 17 A
Well, by ti tle, the two environmental reports 18 that I discussed earlier.
19 Q
Anything else?
20 A
Those are the only ones I recall.
21 Q
Were you involved while you were working 22 with Mr. Miller in the preparation or generation of l
23 any reports dealing with the accident on March 28, 24 19797 25 A
Could you repeat that question?
3 i
+
ep.
- - +.
,e
-ry
1 Harbin 63 i
2 Q
While you were working for Mr. Miller Ok-3 were you involved in any way with the generation 4
or preparation of any reports having to do with the
)
5 accident at Three Mile Island on March 28, 19797 6
A Not that I recall.
7 Q
Do you recall preparing or generating 8
any' reports on the accident while you were working 9
for Mr. Seelinger?
10 A
could you repeat that for me, please?
11 Q
Do you recall preparing or generating 12 any reports on the accident 13 A
No.
/m I
i 14 Q
-- while you were involved with Mr. Seelinger?
V s
15 Were you involved in any way in any of the I
16 reports,in any reports on Three Mile Island on the
~
l 17 accident?
j 18 A
With the preparation?
r 19 Q
Whether it be preparation, generation, 20 review, gathering of information, anything at all, 21 in any way.
22 A
I performed some minimal review of reports 23 that were generated but in no way had any input to 24 the preparation that I recall.
gy 25 Q
Which reports were they?
U
1 Harbin 64 2
A The Kemeny report.
3 Q
Why were you reviewing them?
4 A
As a matter of interest.
)
5 Q
Were you reviewing them at someone else's 6
request or just your own interest?
7 A
My own interest.
8 Q
Apart from that kind of review are there 9
any reports at all that have come out in which you 10 were involved in any way?
11 A
Other than that kind of review?
12 Q
Yes.
4 13 A
No.
Not that I recall.
pm
(_)
14 Q
If you would, would you look at B&W Exhibit 15 202 for a moment, please.
That's the organization 16 chart dated 1/1/79.
17 A
Yes.
18 Q
Under the column marked Unit 2 Mr. Logan, 19 J.B.
is that?
20 A
Yes.
21 Q
Logan is listed as the unit superintendent 22 for Unit 2 and then under his name is the name of 23 I believe a Mr. Shaffer; is that correct?
24 A
Yes, that's correct.
(~)
25 Q
Are those initials M.B.
Shaffer?
%)
1
1 Harbin 65 2
A M.R.
s
\\~
3 Q
M.R.
Shaffer.
4 Am I correct in assuming that he is your 5
counterpart at Unit 2 or was at this time?
6 MR. MacDONALD:
Are you asking whether 7
he performed all the same job functions as 8
Mr. Harbin did for Unit 1?
9 MRS. VAUGHAN:
Essentially, yes.
10 A
I don't think you can say I don't think it's 11 fair to say that he performed the same job functions.
12 Q
Do you know in what respect his 13 responsibilities might have been different from yours 14 or were different from yours?
i 15 MR. MacDONALD:
The question is were 16 different?
17 MRS. VAUGHAN:
Yes.
18 A
I don't really know that much about his job 19 responsibilities to make a comment on that.
20 Q
Do you know Mr. Shaffer?
21 A
Yes, I do.
22 Q
Do you have at this point in time, 1/1/79, 23 did you have much contact with him on a professional 24 level?
("'
25 A
Yes.
One area of responsibility-that I recall V]
l
1 Harbin 66 2
dealt with tours.
It was usually tours usually g-3 involved both units or when they did it involved 4
both units, both he and I had to do some planning
)
5 as far as me for Unit 1 and Mr. Shaffer for Unit 2.
6 Q
Do you know when Mr. Shaffer was hired or 7
was moved into this particular job position?
8 A
No, I don't recall that.
9 Q
Do you know whether, prior to the time 10 he was a technical analyst III-Nuclear for Unit 2,
11 he was already employed by Metropolitan Edison or 12 GPU?
13 A
could you please reword that?
("%
()
14 Q
In other words, do you know whether 15 Mr. Shaffer had been previously employed by 16 Metropolitan Edison or GPU prior to his assuming 17 the position of technical analyst III Nuclear for 18 Unit 27 19 A
No, I don't know that.
20 Q
Did you have any input into the selection 21 of Mr. Shaffer as a technical analyst for Unit 27 22 A
Let me clarify something.
23 Q
Sure.
24 A
Technical analysts generally is a pay category.
rg 25 g
would it be more correct for me to call
1 Harbin 67 2
him an assistant?
\\ -
3 A
Yes, I would say so.
That was the position 4
he held.
)
5 Q
Assistant to Mr. Logan?
6 A
Yes.
7 Q
Did you have any input into the selection 8
of Mr. Shaffer as an assistant to Mr. Logan?
9 A
I don't recall whether I did.
10 Q
Do you know that you did not?
11 A
No, I don't.
12 Q
Did you ever discuss with anybody the 13 qualifications that you thought were needed to
()
14 perform that function?
15 MR. MacDONALD:
You are talking about 16 prior to the time Mr. Shaffer assumed Unit 2 17 responsibilities?
18 MRS. VAUGHAN:
Yes.
19 A
Do I recall discussing with anyone?
20 Q
Yes.
21 A
No, I don't recall any specific discussion.
22 Q
Does there exist a job description for 23 your position as assistant to Unit 1 superintendent?
24 A
No.
3 25 Q
Is there anything that would be called a G
1 Harbin 68 2
job description that is not specifically titled a
,]m.
t 3
job description that basically describes what you 4
do?
5 A
Yes, there is.
6 Q
what is that called?
7 A
I believe it is po sition description for 8
technical analyst senior I-Nuclear.
9 Q
Does that description describe something 10 different than what would be required for an assistant?
11 we have just before this distinguished between 12 assistant and technical analyst.
I am not just 13 interested in a technical analyst.
I am interested es,)
14 in one that describes your position as assistant.
15 A
I know that a position description exists for 16 the position technical analyst senior I that describes 17 the responsibilities of assistant to the unit 18 superintendent.
19 Q
Do you know where that position description 20 can be found, that is in what office or whose office?
21 A
I am not sure.
)
22 Q
would the position description be found in 23 your office?
24 A
No, I don't believe it is.
']
25 Q
would it be found in Mr. Toole's office?
(Q
1 Harbin 69 2
A No.
I believe I've got the file on position
/T i
4
\\#
3 descriptions in my home and I believe that the 4
Personnel Department would have a copy of that position
)
5 description.
6 Q
Is there a reason why you have it at your 7
home?
8 A
I don't know.
i 9
Q Do you normally keep files at home?
10 A
No.'
11 Q
This one just happens to be at home?
12 A
That's right.
13 Q
Were you working with it?
O(,j\\
14 A
I took it to my home two months ago and, gee, 15 I needed it at' work two weeks ago and couldn't find i
16 it and looked all over for it and found it.
j 17 Q
At home?
i 18 A
At home.
4 19 Q
Are there any other files at home?
l 20 A
Working, work related files?
3 21 Q
Work related files.
22 A
Yes.
23 Q
Which files are they?
J
.l q
24 A
I keep a file on I guess personal matters
{~')
25 related to my employment, information on the company, s_/
,~
1 Harbin 70 2
information on the industry, nuclear industry.
I 3
have some training documents.
That's all that I can 4
think of.
)
5 Q
What kind of training documents?
6 A
I went to the B&W simulator in Lynchburg and 7
received three or four volumes of binders of 8
procedures, I am not sure what it contains, be.cides 9
procedures.
10 Q
But all of the training documents are those 11 from the simulator at Lynchburg?
12 A
No, not all of the training documents.
I don't 13 know if they are all of them.
()
14 Q
No.
You said that you had some training 15 documents at home.
16 A
Yes.
17 Q
And my question is:
Are the documents 18 which you have at home only the B&W simulator 19 training documents or are there other training
~20 documents at home?
21 A
That I required since my employment with Met Ed?
22 Q
Yes.
That's right.
23 A
That's all that I recall.
24 Q
So of the training documents that you have
(~'
25 at home,the only ones you can recall are those that
]
1 Harbin 73 2
organization chart in 19787 m
3 A
No, I don't.
4 Q
Is he still an assistant to Mr. Logan?
)
5 MR. MacDONALD:
Mr. Shaffer?
6 MRS. VAUGHAN:
Yes.
7 A
No.
8 Q
Does he work for Met Ed?
9 A
Mr. Shaffer?
10 Q
Yes.
Still.
11 A
I am not sure whether he works for Met Ed or 12 GPU.
13 Q
But he is employed by one of those two?
fn()
14 A
Yes, he is.
15 Q
Do you know where he is employed?
16 A
Yes, on the island, Three Mile Island.
17 Q
Do you know what job he holds?
18 A
No, I don't.
19 Q
Mr. Harbin, you indicated that you 20 earlier on took some courses or had some training 21 or something as part of your employment with Met Ed, 22 A
Yes.
23 Q
what kind of courses or training did you 24 have or have you had since you have besn employed
~%
25 by Met Ed?
(O
1 Harbin 71 k
2 relate to the B&W simulator training that you 3
received in Lynchburg; is that correct?
4 A
Yes.
)
5 Q
How about the documents that you characterizo 6
as information on the company, what kind of documents 7
are they?
8 A
Propaganda, literature that the company puts 9
out to visitors.
10 Q
Is there a reason why the training 11 documents are at home?
12 A
I don't recall why I took them home.
13 Q
When did you take them home?
()
14 A
Following the one week period that I spent at 15 the simulator.
16 Q
And when was that?
17 A
As I recall, the latter part of 1976.
18 Q
Mr. Harbin, I don't recall whether I 19 asked you this but let me ask you again.
Did you 20 say you knew or you did not know when Mr. Shaffer 21 assumed his responsibilities as assistant to 22 Mr. Logan?
23 A
I don't know that.
24 Q
on the organization chart that we have 3
25 marked B&W Exhibit 201 for identification which is
%. -)
o
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.-w-
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7
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m-
-*t-*
v'r s4---
~
1 Harbin 72 2
dated January 1,
1978 he is not listed as an
,/
i
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3 assistant to Mr. Logan.
He is listed in 1979.
4 Do you have any reason to know that the
)
.5 organization chart for 1978 is not correct?
6 A
No.
7 Q
So is i t --
8 A
For 1978.
9 Q
That's right.
10 A
That's right, no.
11 Q
So, sometime between 1978 and 1979 12 Mr. Shaffer --
13 A
I don't know that.
14 Q
But looking at the organization charts j
15 MR. MacDONALD:
Are you asking if that's
~
i 16 what the organization chart indicates or can 17 he independently verify that because he doesn't 18 know that.
I 19 MRS. VAUGHAN:
I am not asking him to 20 independently verify that.
I am asking if he 21 knows any reason why looking at these organization 22 charts one can't deduce he came between 23 January 1,
1978 and January 1,
1979.
24 Q
Do you have any knowledge which would 25 indicate that he should have appeared on the
.m..
.y
1 Harbin 74 2
A Just after I was employed in June of '76 I 3
spent approximately five months sitting in on a 4
program that was held for two people, Mr. Seelinger
)
5 and Mr. O'Hanlon and the program was designed to 6
result in their receiving an SRO license.
7 Q
SRO meaning senior reactor operator?
8 A
Senior reactor operator, and I sat in on 9
approximately two-thirds of that program.
4 10 Q
Why were you sitting in on that program?
11 A
Well, because I had -- I had prior experience 12 that was nuclear related and they felt that sitting 13 in on this program would give me some plant specific 14 knowledge that would help me perform my responsibilities 15 of my job.
16 Q
Who was it, if you recall, who specifically 17 suggested to you that you sit in on that program?
18 A
I don't recall.
19 Q
Did Mr. Colitz suggest that to you?
20 A
I don't recall.
21 Q
Specifically when did you begin employment 22 with Met Ed?
23 A
I don't recall the exact date.
It was June of 24 1976.
25 Q
Okay.
Was this program given commencing
1 Harbin 75
'i 2
in June of '76 or July of '76?
-(O
/
3 A
I don't recall when it commenced.
4 Q
Do you recall when it ended?,
)
i
)
5 A
No.
6 Q
But is it fair to say that it commenced 7
shortly after your employment began with Met Ed?
8 A
No.
It may have' commenced before.
9 Q
Let me ask you this.
How long'did the 10 program last?
11 A
I don't know.
I testified already that u
12 Q
You said five months.
13 A
Yes, approximately five months.
1 i
t
(~)\\
14 Q
Was that the length of time you sat in t
x
+
i 15 or your understanding of how long the program 16 A
I said that that was two-thirds so I would.say 17 my estimate is that the prcgram lasted seven months.
18 Q
Who conducted the program?
19 A
could you be more speciS5:t s
s
'20 Q
Who gave it"
%.o are the instructors?
\\
21 A
The instructors were members of the VMI Tra'inir 22 Department.
23 Q
And where was the program given?
~
y 24 A
On site at TMI.
Excuse me, part of ths'progran 3
E i
l 25 or the program is culminated in a period of time at f-)s s
\\_
A w
( i.'
1 Harbin 76 2
the simulator.
That was part of the program.
3 Q
And did you go to the simulator as well?
4 A
I didn't go to the entire portion of the i
)
5 simulator time that was apportioned to the training 6
program.
I went for one week and I don't recall how 7
many weeks Mr. Seelinger and O'Hanlon were at the 8
simulator.
'9 Q
Was this program the kind of a program 10 that would take place every day or would there be 11 one or two days a week or one or two hours a day in 12 which the program was being conducted and the rest 13 of the day would be business as usual?
(O 14 A
As I recall it was three to four days a week, j
15 a half a day each day.
16 Q
The program was given only for Mr. Seelinger 17 and Mr. O'Hanlon; is that correct?
18 A
The classroom portion, yes, j
19 Q
You are distinguishing classroom from 20 simulator?
21 A
Yes.
22 Q
Did anyone else sit in as you were?
23 MR. MacDONALD:
You are speaking about 24
. regularly or intermittently?
g-25 MRS. VAUGHAN:
At any time he was there.
\\,.
1 Harbin 77 2
A Yes.
O(_)
3 Q
others sat in?
4 A
Yes.
)
5 Q
Do you recall who?
I 6
A N o '.
7 Q
Do you recall any names at all?
8 A
No.
9 Q
Do you recall whether it was more than one 10 person who sat in?
11 A
No.
12 Q
No, you don't recall?
13 A
That's right.
I don't recall.
14 Q
Do you recall that it was just one person?
15 A
No, I don't recall how many.
16 Q
When we were talking about position 17 descriptions you mentioned that there was a position 18 description for technical analyst senior I which 19 described the responsibilities or duties or functions 1
20 of an assistant to the unit superintendent.
21 A
Yes.
22 Q
And my question is:
What is the 23 difference between a technical analyst senior I and 24 a technical analyst III?
rs 25 A
Pay grade.
k_
1
l 1-Harbin 78 l
[
l 2
Q Is a senior I more senior to a III?
LO L
3 A
Yes, it is.
4
'Q Are you now a senior I?
-]-
l 5
A Yes, I am.
6 Q
When did you become a ' senior I?
7 A
I don't recall.
i 8-Q In 19807 9
A I don't recall.
10 Q
On the organization chart we have marked 1
11 Exhibit 203 for identification you are still listed 12 4
as a technical analyst III.
4 13 A
Yes.
l 14 Q
Is that correct?
l 15 A
I don't know whether that is or not.'
16 Q
Are there any records which would indicate 17 when you were promoted to a senior I?
4 18 A
I don't know that there are.
19 Q
would there be pay records that. reflect i
20 that, payroll?
21 A
I really don't know that much about the pay 22 system.
23 Q
And you don't recall when you~were 3-24 promoted to.a senior I?
/
25 '
A No, I would have_that in my file at home.
1 Harbin 79 2
Q Do you have an approximate time in mind?
O 3
A The spring of 1980.
4 Q
Were there any other training courses
)
5 that you took or sat in on?
Training may not be the 6
right word.
Let's just say courses that you took 7
or sat in on since you have been employed by 8
Metropolitan Edison.
9 A
To date?
10 Q
Yes.
11 A
Yes, I sat in on a one-day seminar in time 12 management.
13 Q
Anything else?
(~N,)
14 A
I started a program approximately six months 15 ago that was designed to result in a certification.
16 Q
Certification for what?
17 A
I am not sure.
Certification -- I don't know 18 whether it's a license, the NRC right now -- it's my 19 understanding that the NRC is at least considering a 20 program for certifying people as opposed to licensing 21 people so that not everyone will have to stand shift, 22 stand watches in the control room but yet they will 23 still have to have the same knowledge level, just j
24 not as much hands-on experience.
('T 25 Q
Certification would be a level less than O
1
l-Harbin 80 2
licensed, is that what you are suggesting?
O
_ k.)
3 A
No, I am not suggesting that.
4 Q
Is that what you understand in any way?
)
5 A-No, I understand two things, that it would mean 6
that you don't get paid the shift differential which 7
shift people get paid, you don't stand shift, watches, 8
that you don' t get paid a bonus for a license, and 9
that y'ou don't have to stand any shifts to maintain 10 a license.
11 Q
Are you still continuing with that 12 program?
13 A
Not right now.
14 Q
When did you stop?
15 A
About three months ago.
16 Q
Why?
17 A
For personal reasons.
18 Q
When you used the phrase " stand shift,'"
19 are you referring to the operators in the control 20 room at the time or those people in the control room s
21 at anp given point in time?
)
22 A
Not necessarily.
I am referring to anyone 23 that works other than continuously -- continually i
24 works daylight hours.
f-25 Q
Would people in the control room fall
(
l
-,-.,...- ~,
1 Harbin 81 2
within your description of standing shift, people 3
who are regularly assigned to the control room?
4 A
Yes.
)
5 Q
Are there any other training programs 6
or anything of the kind we have been describing that 7
you have participated in?
8 A
No, not that I recall.
9 Q
You mentioned having some simulator 10 experience at B&W in Lynchburg.
I 11 A
Yes.
12 Q
Are the documents that you described as J
13 being at home those documents that you got at the
(~)
(_/
14 simulator program that was at the end of this session 15 that Seelinger and O'Hanlon were in?
16 A
Yes.
17 Q
Have you been to the simulator other 18 than that time?
19 A
No, I haven't.
20 Q
Do you remember when you were at the 21 simulator, when that training took place?
22 A
To the best of my recollection in the fall of 23
- 1976, 24 Q
Do you recall the names of any of your
(}
25 instructors when you were down there?
1 Harbin 82 2
A No, I don't.
O 3
Q Do you remember the nama of the head l
4 instructor, the person that seemed to be leading it?
5 A
No.
6 Q
Do you recall who from Met Ed'or GPU 7
other than Mr. Seelinger and Mr. O'Hanlon attended 8
that session?
9 A
I didn't say that I knew that they did.
10 Q
I am sorry, I thought you indicated 11 that they went at the end, at the culmination of 12 this training session that they were in for an 13 SRO license was the simulator and you went at the R
id 14 same time.
~
15 A
They went at the end of the training program.
1 16 Q
Yes.
u 17 A
I don't know whether it was the same period 18 of time that I went.
I was there for a week, they 19 were there for longer than a week.
They may have 20 gone in the afternoons, to the simulator.
I just 21 don't recall when they went.
I don't recall being -- I g
J 22 don't recall being on the simulator panel with them.
23 Q
All right.
24 Do you recall who else was there other
..a{^}
25 than yourself?
1 Harbin 83 2
A Yes, I recall Chuck Adams.
E-d-a-m-s.
O 3
Q E-d-a-m-s?
~
4 A
A-d.
)
5 Q
Anyone else?
6 A
No, i
7 MRS. VAUGHAN:
This is a good time to j
8 break if you want to or we can keep going if 9
you want to and we can break later.
10 MR. MacDONALD Let me talk to Ron.
11 MRS. VAUGHAN:
All right.
12 Off the record.
13 (Discussion off the record.)
)
14 (Recess taken.)
15 BY MRS. VAUGHAN:
16 Q
Mr. Harbin, you indicated earlier I
~17 believe that as part of your job responsibilities 18 with Mr. Colitz, with Mr. O'Hanlon and with 19 Mr. Seelinger and with Mr. Miller that you reviewed 20 the mail for them.
21 A
Certain correspondence, yes.
22 Q
Let me ask you if any of these publications 23 were part of the review that you did.
I am not 24 sure whether you would call this correspondence as
(^}
25 you described them but let me just ask you.
.kJ
--,.,r
-- e v-
- r w=
l 1
Harbin 84 i
2 Would you review as part of your I
f~)
a c
\\
\\_/'
3 responsibility Atomic Energy Clearinghouse?
4 A
That was a publication that I reviewed.
I
)
5 don't recall whether I reviewed that publication at 6
the time I was reporting to all of those people 7
that you mentioned.
8 Q
Do you recall that you reviewed that 9
with Mr. Colitz?
10 A
while I was working for Mr. Colitz?
11 Q
Yes.
12 A
No, I don't recall whether I did or didn't.
13 Q
Would you call the Atomic Energy b
(/
I4 Clearinghouse, would that be part of what you 15 would call the correspondence that you reviewed or 16 did that come under something else that you reviewed?
17 A
Correspondence.
18 Q
Correspondence, all right.
19 How about any of the NRC's monthly 20 computer runs on LERs?
21 A
No, I don't recall ever reviewing any of those.
22 Q
Are you. familiar with those computer 23 runs?
i 24 A
I know that they exist.
.()
25 Q
when did you first learn that they existed?
1 Harbin 85 o
A I don't recall.
3 Q
Did you know that they existed before 4
the accident at Three Mile Island?
5 A.
I don't recall.
6 Q
Do you recall how you found out they 7
existed?
8 A
Yes, in discussions with members of the -- or 9
any member of the Training Department.
10 Q
Who would that be?
11 A
I believe it was Mr. Skip Brown.
12 Q
Is he Mr. Nelson Brown, Skip?
13 A
Yes.
x,/
14 Q
Do you recall the circumstances 15 surrounding that knowledge that you got?
In other 16 words, do you recall why you might have been talking 17 with Mr. Brown and how it came about that you found 18 out about the LER computer runs?
19 A
No, I don't.
20 Q
Would you as part of your job responsibility i
21 receive and/or review Current Events
}
Power Reactors?
22 A
Yes.
I don't recall the specific period of 23 time but I do recall reviewing that publication.
i 24 Q
When you say you don't recall the specific
/^\\
25 period of time, you don't recall what time you might
%)
i e
r
1 Harbin 86 l
L l
2 have reviewed that?
j 3
A I don't recall what period of time I did review t
4 it.
')
5 Q
Do you recall that once you started 6
reviewing it it was a continuous process or were 7
there times when you would review it and then there 8
would be months when you didn't see it?
9 A
From the time I started reviewing them it 10 was the general practice that I would review those 11 that were received.
12 Q
Do you review that publication now?
13 A
Yes, I do.
14 Q
Do you now review any computer runs of 15 LER's?
16 A
No, I don't.
17 Q
Co you now review the Atomic Energy 18 Clearinghouse?
19 A
No, I don't.
20 Q
When did you stop reviewing'the clearinghouse I
}
21 documents?
22 A
I. don't recall exactly when.
23 Q
Approximately when?
24 A
Approximately January,of 1980.
f 25 g-Why was that that you stopped reviewing s
~,
1 1
Harbin 87 2
them?
(~h
\\/
3 A
That responsibility was given to another 4
member of the staff.
)
5 Q
To whom was it given?
6 A
Dave Carl, C-a-r-1.
7 Q
Why was he given the responsibility to l
8 review that publication?
l 9
A I don't recall exactly why.
10 Q
Do you have a general sense of why?
11 A
Well, you want me to answer 12 Q
What is your understanding of why?
13 A
What my understanding was at the time?
14 Q
Yes.
15 A
At the time, in general, it was that it was a 16 review that took a considerable amount of time and 17 he was qualified to perform that review and I 18 didn't have the time.
19 Q
Is your understanding today different 20 than your understanding in January of 1980?
21 A
There is no reason for it to be.
22 Q
But is it?
23 MR. MacDONALD:
I will object to the 24 form.
25
{')N '
A I really don't sm I
1 Harbin 88 2
MR. MacDONALD:
What we are dealing
\\'J 3
in htere is recollection.
4 MRS. VAUGHAN:
I am asking him for his
)
5 present understanding.
6 MR. MacDONALD:
I know.
7 MRS. VAUGHAN:
He has to recall that.
8 MR. MacDONALD:
You want his understanding 9
as he sits at the table which is not necessarily 10 what we are here to establish.
We are here to 11 establish facts in and around the time that 12 are relevant to the date of the accident.
13 MRS. VAUGHAN:
He indicated he had a 14 different understanding.
15 THE WITNESS:
No, I didn't indicate that.
16 Q
You did, because you asked me if it was 17 today's understanding or the understanding at the time 18 which is why I asked.
19 MR. MacDONALD:
I think you can just 20 clarify the time.
Maybe it was something else.
21 Q
Do you have an understanding today.that 22 is different from the understanding you had at the 23 time in January of 1980?
24 A
No, no, I don't.
(~)}
25 Q
Do you possess facts now that you didn't
'm 1
1 Harbin 89 2
possess in January of 1980 that would make your
("
k 3
understanding different?
4 A
No.
)
5 Q
so your understanding today is exactly i
6 as it was in January of 1980 as to why Mr. Carl took 7
on this function?
8 A
I am not sure what you mean by -- you know, 9
the thing that confuses me a little is what you mean 10 by my unders tanding today about -- if you are going 11 to ask me about my understanding today, could you 12 please rephrase the question?
13 Q
How would you want it rephrased?
(O) 14 A
Well, at this point I can't even. remember.
15 Q
All right.
16 A
What the concern was.
17 Q
I asked you originally if you knew why 18 Mr. Carl was undertaking to review the Atomic Energy 19
. Clearinghouse documents, a function which you had 20 previously had as part of your job responsibility 21 and your answer was I believe that you didn't i
22 understand -- you didn't know exactly and so I said 23 do you have an understanding, a general understanding 24 of why it was and you listed a-couple of factors and 25 all I am asking now is your understanding today the
~}
(2
~
1 Harbin 90 2
same as it was back then?
Did you have a different
-s 3
understanding of why Mr. Carl undertook that?
4 A
No, I didn't.
)
5 Q
All right.
6 I believe you said that Mr. Carl was able 7
to review these documents because they took longer, 8
some amount of time to review that you didn't always 9
have the time and that he was qualified to do that.
10 A
I didn't say that he was qualified.
11 Q
That he had the' qualifications to do that?
12 A
No.
13 MR. MacDONALD:
I will interject here for
[)
14 a minute.
Are you asking that as a new question?
v 15 MRS. VAUGHAN:
I was going to ask him what 16 he meant.
17
'MR. MacDONALD:
Well 18 MRS. VAUGHAN:
I was going to ask him 19 what he meant by he had the qualifications.
20 Q
If I am wrong, I am sorry.
I would be 21 happy to have your answer read back if we can find it.
22 A
Yes, I would like to do that.
23 MRS. VAUGHAN:
All right.
24 (Record read by the reporter.)
rx 25 A
The thing that I was concerned about was the
(
1 Harbin 91 2
remark that I made preceding that.
(~ ~'N 3
Q Well, let me just ask, what did you mean 4
by qualified to do?
5 A
What did I mean by qualified?
6 Q
Yes, when you used it a,s you did in the 7
answer.
8 MR. MacDONALD:
Let me state if there is 9
something he is concerned about in the answer 10 that he gave prior that affects how he $nswers 11 your question, it might be best that we go 12 back and look at it in the record.
13 THE WITNESS:
Yes, I would like to do I
14 that.
15 MRS. VAUGHAN:
That's fine.
What do you 16 want to do?
17 THE WITNESS:
Look at what was 18 MR. MacDONALD:
The question and answer 19 before the one that was read.
20 THE WITNESS:
Yes, before the answer that I
21 he just read.
22 (Record read by the reporter.)
23 Q
My question is:
What do you mean that he 24 was qualified to perform that review?
(~'3 25 A
That he possessed some knowledge of the plant V'
,.p-,,
-~
l r
1 Harbin 92 2
staff and the organization and the nuclear plant in
! I)
\\/
3 general.
What I want to do is qualify that.
4 I was not in a position to say that he was
)
5 qualified and I am not saying now that at the time that 6
I felt that he was qualified.
That decision was made 7
by my s up e rio r.
You asked me why it was turned over 8
to him and I said that my perception was because of 9
that being one reason.
10 Q
Were there any technical qualifications 11 or qualifications of a necessary technical background 12 that was needed to review that document?
13 A
I don't know.
14 Q
Were you in any discussions at the time 15 i t' was decided that he should review that document?
16 Were you involved in any discussions with anyone 17 relative to that decision?
18 A
Yes, I was.
19 Q
With whom?
20 A
I don't recall for sure, 21 Q
Who made the final decision to have 22 Mr. Carl review the Atomic Energy Clearinghouse?
23 A
-It is my recollection that it was a joint 24 decision made between Gary Miller and Joe Logan.
~}
Q Do you know what Mr. Carl's job was either 25 v
e w
, - - + -
i Harbin 93 2
at the same time he was reviewing the Atomic Energy O
i k/
3 Clearinghouse or prior to that time?
4 A
No, I don't recall what it was.
)
5 Q
For whom does he work?
6 A
I don't know that.
7 Q
Is he --
4 8
A Are you asking excuse me, for whom does he 9
work now?
1 10 Q
Yes.
11 A
I don't know, i
j 12 Q
For whom did he work then in January of 13 1980?
14 A
I don't recall.
15 Q
Do you know to whom he reported?
4 16 A
To the best of my recollection Joe Logan.
17 Q
And in 1980 Mr. Logan would still have l
18 been Unit 2 superintendent?
1 19 A
I don't know that.
20 Q
Why is it that you know he reported to g
21 him but you don' t know what Mr. Logan's position --
i J
1 22 A
I don't know that he reported to him.
I said 23 to the best of my recollection.
24 Q
Had Mr. Carl previously been working for
~
25 Met Ed before taking on this responsibility?
i t
i v
v
-r.
1 Harbin 94 2
A Yes, he had.
3 Q
Was he in the Licensing Department?
4 A
I don't recall.
- )
5 Q
Was he attached to Unit 17 6
A No, I don't believe he was.
7 Q
Was he employed on site?
8 A
I-don't recall.
9 Q
Was he on site at the time after he 10 took on this job?
Was it a job that was performed on r
11
. site?
12 A
Yes, it was.
13 Q
Was it a job that was to involve him
( ))
14 full time or was it an additional responsibility 15 to other things that he had to do?
16 A
I am not really qualified to discuss his 17 responsibilities.
18 Q
Just in terms of your knowledge, that's 19 all.
20 A
In terms of my knowledge at that time it was an 21 additional responsibility, i
22 Q
Do you know whether he had an engineering 23 background?
24 A
No, I don't.
l gg 25 Q
As part of your job responsibility did you N-]
l i
i
1 Harbin 95 2
ever receive and/or review any information coming
(~
(_)/
3 from EEI, Edison El+ctric Institute?
{
4 A
At the time of the accident?
)
5 Q
At any time when you wera.an assistant 6
to the Unit 1 superintendent.
7 A
could you please rephrase the question?
8 Q
Sure.
9 A
or repeat the question.
10 Q
As part of your job responsibilities as 4
11 an assistant to the unit superintendent, did you 12 ever receive and/or review any publications from 13 EEI, Edison Electric Institute?
O 14 A
Yes, I have reviewed publications, not (j
15 necessarily directly from EEI.
16 Q
But as sent out by EEI?
17 A
EEI publications.
18 Q
What kind of publications?
19 A
I don't recall.
20 Q
Do you recall any names of any publications?
21 A
No.
22 Q
Do you recall that there has ever been 23 -
correspondence from EEI that may not be a publication i
24 as such?
25 A
No, I don't recall.
. v s
1 Harbin 96 2
Q Do you recall ever reviewing any LER's 3
that would have been sent by EEI?
4 A'
No.
)
5 Q
Any LER supplements?
6 A
No.
4 7
Q Any information about other utilities 8
that EEI might have sent?
9 A
I don't recall any specific correspondence.
10 Q
From EEI?
11 A
From EEI.
12-Q But you do recall reviewing material from 13 EEI; is that correct?
i 14 A
Yes.
15 Q
Do you recall ever receiving and/or 16 reviewing any material from the Nuclear Power 17 Experience as part of your job responsibilities as 18 an assistant to the unit superintendent?
19 A
To this date?
20 Q
Yes.
21 A
When?
For a three or four month period 22 subsequent to the accident.
23 Q
What was it that you were reviewing?
What
' 24 kind of publications?
(7) 25 A
Nuclear Power Experience.
s y
y.-,
w w.,
,-,---,m
--r i%. -,,. ~, _
. - - ~ - -
c 1
Harbin 97 2
Q What was in them?
What were you looking 3
a t, just the publication in general?
4 A
The service that publishes the document
)
5 sends out a periodic update to the document that 6
gives a summary and categorizes events that have 7
occurred at other plants and highlights to some 8
extent various events and I reviewed the summary 9
and in some cases the in addition to the summary 10 also a description of the event or failure-or finding 11 was provided and in some cases I would review those.
12 Q
This is after the accident; is that 13 correct?
14 A
Yes.
The TMI-2 accident.
15 Q
Right.
16 Why was it that you started reviewing the 17 material after the accident?
18 A
I felt that it was a good publication.
19 Q
When did you first become aware of the 20 publication?
21 A
After the accident.
22 Q
How did you become aware of it?
23 A
I don't recall.
24 Q
Did somebody draw your attention to it?
/~T 25 A
I don't recall.
\\
v
1 Harbin 98 2
Q Did you make the decision that the unit
)
3 superintendent should receive it as a publication?
4 A
I don't recall that I made the decision that
)
5 the unit superintendent should receive it.
I don't 6
know that the unit superintendent did receive it.
7
,Q How did you receive it?
Was it addressed 8
directly to you?
9 A
I don't recall.
1 10 Q
Did you get it from someplace else on
)
11 site?
12 A
No, initially I got it I got the updates from I
13 the GPU library in Parsippany, New Jersey and after 1
14 two or three months of receiving Xerox copies of 15 these updates to the document I acquired a set of 16 the entire set of documents myself.
17 Q
Would you describe the set of Nuclear 18 Power Experience to me?
Is it a looseleaf publication?
19 I mean is there a binder into which you slip 1
l 20 A
Yes, there are several three-ring binders.
21 Q
When you say you got a complete set, do 22 you mean that you got back copies as well?
23 A
That's my understanding.
24 Q
How far back does it go, do you know?
(~
25 A
I don't know.
\\, )g
1 Harbin 99 2
Q How was it that you came to get copies 3
from the library?
4 A
I told the I don't recall who it was that
)
5 I made the request of but I placed an order for the 6
publication.
7 Q
From the library or are you now talking 8~
about the publication itself?
9 A
I don't remember who I placed the order with.
10 I don't remember whether I did it through the 11 Purchasing Department, through the library in Reading, 12 through the library in Parsippany.
I don't recall 13 but somehow I acquired from the publisher a set.
p(,)
14 Q
of the materials that they published?
15 A
Yes, right.
j 16 Q
But prior to receiving a full set of the 17 materials you were receiving Xerox copies of updates 18 from the library?
19 A
Yes, that's correct.
20 Q
What else does the publication contain?
21 Was it just a compilation of weekly or monthly 22 reports plus these updates or is there something 23 sort of a basic volume and then --
24 A
I really don't recall.
{
Q Do you have it in your office now?
25 s
(
l
1 Harbin 100 2
A No.
3 Q
Where is it now?
4 A
I am not sure where it is now,
)
5 Q
Why don't you have it anymore?
6 A
Because it was felt that the shift technical 7
advisors should have the set and review the updates 8
when they came out.
9 Q
So it is correct that the material is 10 still being received and reviewed but it's not being 11 received and reviewed by you; is that correct?
12 A
It's not being received and reviewed by.me.
13 I don't know that it is still being received.
14 Q
But at some point it was given over to
./
15 the shift technical supervisors, is that what you 16 called them?
17 A
Technical advisors.
18 j
Q Technical advisors?
19 A
Yes.
20 Q
Who might they be?
Do you want to look l
21 at 203?
22 MR. MacDONALD:
Are you talking about who i
23 are they at a point in time?
24 MRS. VAUGHAN:
Yes, who are they now.
("%
25 MR. MacDONALD:
Today?
N.
c l=
Harbin 101 1
I l
f 2
MRS. VAUGHAN:
Let's look at 1/31/80,
(
)
~
3 B&W Exhibit 203.
It may not be on there but 4
they may'be or you can tell me where it would l
5 be.
l 6
A They are not on there.
7 Q
Who are shift technical supervisors?
8 Have I got that term correct?
9 A
Yes.
10 g
Who are they now?
11 A
It's a position.
12 MR. MacDONALD:
Off the record.
13 (Discussion off the record.)
((
14 MRS. VAUGHAN:
I am sorry, it's advisors.
15 A
STA's.
16 Q
I got it.
17 A
It's a position, the position itself did not 18 exist before the accident and one of the recommendations 19 that came out of the accident was that there be 20 degreed engineers on shift and various engineers in 21 the company were recruited into those positions.
20 Q
And they are known as shift technical 23 advisors; is that correct?
24 A
Yes.
25 Q
By degreed engineers, you mean engineers
i Harbin 102 2
who have attained a college degree or a graduate i
Q-k_)
3 degree of some kind; is that correct?
4 A
That's my understanding.
)
5 Q
To whom does a shift technical advisor 6
report?
7 A
Now?
8 Q
Yes.
9 A
They report to a Mr. Pat Walsh who is the plant 10 analysis manager.
11 Q
Is that also a new position since the 12 accident?
13 A
Yes, it is.
()
14 Q
Have the shift technical advisors always 15 reported to the plant analysis manager?
16 A
No, they have not.
17 Q
To whom did they report before they 18 reported to the plant analysis manager?
19 A
Joe colitz.
20 Q
Is that the same Mr. Colitz that you worked 21 for?
22 A
Yes.
23 Q
And what was his position at the time.
24 they were reporting to him?
25 A
I don't recall the specific title, t
v l
1 Herbin' 103 2
Q Do you recall what his function was?
3 A
Yes.
4 Q
What is that?
)
5 A
Manager of site engineering, Unit 1.
1 6
Q site engineering?
i 7
A Yes.
Let me change that to plant engineering, s
8 manager of plant engineering, Unit 1.
1 9
Q Do you know why they stopped reporting to 10 him and started reporting to the plant analysis 11 manager?
~;
12 A
No, I don't.
13 Q
Who is,the plant analysis' manager?
(
14 A
Mr. Pat Walsh.
15 Q
other than those documents which I have 16 identified already, the Atomic Energy Clearinghouse, 17 the monthly computer list of LER's, the Current 18 Events-Power Reactors, publications by the EEI or 19 correspondence from the EEI and the Nuclear Power 20 Experience, are there any oth6r publications,that you 21 would have reviewed as part of your responsibilities 22 as an assistant?
23 A
Yes.
s 24 Q
Which ones?
(}
25 A
The Federal Register was one.
The NRC, Nuclear V.
k
1 Harbin 104 2
Regulatory Commission's bulletins, circulars and O
r 3
notices, weekly B&W newsletters, I don't recall the 4
specific name or title.
)
5 Q
Go on.
6 A
That's all that I recall.
7 Q
Do any of the utilities put out any kind 8
of a weekly, monthly or annual bulletin or newsletter 9
.that they circulate among the other utilities?
10 A
Not that I know of.
p 11 Q.
You reviewed internal correspondence as 12 well that came to the unit s upe rin t en den ti is that 13 correct?
)
14 A
Yes, that's correct.
15 Q
Was there anything of a regular nature 16 that you would review?
17 A
Well 3
18 Q
Was there any internal weekly newsletter 19 that you would review?
I'*
20 A
During what period of time?
21 Q
Any, period of time from the time you took 22 the position as an assistant II.
23 A
'One that'I recall.is a weekly significant' events 24 report, that's only been published in the last year.
1
{~}-
25 Q
And what kind of items are included s_
$ff '
34
.- l
.):-
'll.l
.,\\ ;., _.. _,. _
- ~ ~ ' ' ~ - - " *~
1 Harbin 105 2
within that?
3 A
Primarily it's a compilation of the major 4
efforts in various divisions within the GPU nuclear
)
5 corporation.
6 Q
Relating specifically to the clean up 7
process or anything in general?
8 A
Relating to whatever their efforts are.
9 Q
Would it contain reports on what the 10 Pennsylvania Public Utility Commission might be 11 doing as regards Three Mile Island at this point?
l 12 MR. MacDONALD:
Are you asking has it ever 13 contained that?
(
14 MRS. VAUGHAN:
That's right.
15 A
I don't know if it's contained that.
16 Q
Are there any other recurring kind of 17 reports or publications or correspondence that you 18 would review?
19 A
Budget reports.
20 Q
Anything else?
21 A-overtime summaries, manpower summaries.
22 Q
Anything that related to the operation 23 of Unit 1 or Unit 27 24 A
Not other than the weekly significant events 25 report that I recall,
7-1 Harbin 106 2
Q Would you ever review compilations of l
3 LER's filed by Unit 1 or Unit 27 4
A To the present day?
)
5 Q
Yes.
6 A
Yes.
7 Q
Would those compilations be prepared and 8
sent to you for your review?
9 I will strike that question.
Let me 10 ask you, in what format would those kind of documents 11 be?
12 A
The only compilation that I recall is one that 13 was provided in certain issues of the Atomic Energy
()
14 Clearinghouse document.
15 Q
I am sorry, I am still on internal 16 generated correspondence.
17 A
Oh, I am sorry.
18 Q
Did you ever receive or review an internal 19 document that summariced LER's filed?
20 A
Yes.
21 Q
In what format was that document?
22 A
The Unit I superintendent's office keeps a 23 running summary type log of LER's, all the LER's that 24 are generated in Unit 1 are reviewed and approved by x
25 the Unit 1 superintendent so that although they A.
1 Harbin 107 2
usually don't originate from our office, they --
T i 3
Q The LER's don't?
4 A
That's right.
They go through our office so i
)
5 we keep a log that gives a one sentence summary of 6
what the event or finding was, the date, LER number.
7 Q
Would you or your office or anyone else 8
take that information and put it into a single form and 9
then generally publish it or make it available to the 10 employees?
11 A
I believe that portions of it have been made 12 available to other emp'loyees.
That's not a general 13 practice.
()
14 Q
How about LER's that would have been 15 filed by Unit 27 Would you ever have cecasion to M
receive and/or review any kind of a report prepared 17 about those LER's?
18 A
Yes, not a compilation of them though.
19 Q
Not a compilation?
20 A
That's right.
l 21 Q
Would you see any of thcae LER's?
22 A
Yes.
23
.Q Under what circumstances would you see 24 those?
This is Unit 2 now.
(~
25 A
Under the circumstances that for some period of L}
-=_
I 1
1 Harbin 108
)
2 time the Unit 1 superintendent or the person holding O
\\/
3 that equivalent position, since it's been abolished, 4
has been on distribution for Unit 2 LER's.
)
5 can I just make a clarification?
6 Q
Absolutely.
7 A
You know, for the purpose of this testimony, 8
can we just assume that my making reference to the 9
Unit 1 superintendent that we mean both the Unit 1 10 superintendent, the manager of Unit 1 and the operations 11 and maintenance director of Unit 1 or would you rather 12 not?
13 Q
That sounds all right wi th me.
(
14 I assume what you are saying is that 15 there is sonebody who is essentially performing 16 those functions but the jcb title changes or has 17 changed?
In other words, it's the same problem we 18 had with Mr. Miller earlier on, he was an acting 19 superintendent for a while or manager of Unit 1 and 20 then Mr. Toole came in?
21 A
Yes, that's right,but since Mr. Toole took 22 that position, as I said before, I am really not 23 qualifled to discuss it, how his responsibilities i
24 has changed but the organization has changed and g
25 the groups that are reporting to him have changed.
J
1 Harbin 109 I
2 MR. MacDONALD:
My only problem with 3
using the same terminology would be that it 4
shouldn't be implied that necessarily the job
)
5 responsibilities were the same even though 6
the titles changed.
I don't think that should 7
be an implication that is drawn from the record 8
on this.
9 MRS. VAUGHAN:
I think I understand, to 10 the extent that we can assume it is the same 11 we will.
12 MR. MacDONALD:
All right.
13 MRS. VAUGI!AN:
Otherwise we will bring 14 out those differences.
15 Q
Are there any other internal Met Ed 16 documents, or whatever, that you can recall having 17 received or reviewed at any time as an assistant?
18 Would there be for example an annual report to the 19 employees?
20 A
Yes.
21 Q
And when would that usually be issued?
22 A
Annually.
I don't recall what month.
23 Q
Was that issued by GPU or Met Ed?-
24 A
I recall them having been issued by Met Ed.
I
-/N 25 don't recall if they had been issued by GPU to me.
\\
1 Harbin 110 2
Q Do you recall whether there have always 3
been those reports since you have held the position 4
of assistant to the Unit 1 superintendent?
)
5 A
I recall annual reports having existed.
I 6
don't recall that they have been sent to me.
7 Q
By annual reports I am not referring to 8
the annual corporate reports that would be issued, 9
I am talking about something different than that.
i t
i 10 A
I am talking about the annual financial report.
1 11 Q
All right.
Is there anything else you 12 can recall?
13 A
As far ac what?
(
14 Q
As far as internal reports or internal 15 documents that Met Ed or GPU would have issued.
16 MR. MacDONALD:
On a regular basis now,
~
17 is that what we are dealing with?
18 MRS. VAUGHAN:
I am talking about on a 19 regular basis.
20 A
Yes, I recall that there was at least one l
21 annual report to the employees.
22 Q
when was that?
23 A
I don't recall.
24 Q
Do you recall who you were working for at 25 the time?
O t '.
1 Harbin 111 2
A No.
()
\\,_)
3 Q.
Do you recall what it said?
4 A
No.
')
5 Q
But you recall there was an annual report 6
to the employees?
7 A
Yes.
8 Q
Was it before the accident?
9 A
I don't recall.
10 MR. MacDONALD:
Can we take just five 11 minutes?
12 MRS. VAUGHAN:
Sure.
13 (Recess taken.)
()
14 BY MRS. VAUGHAN:
15 Q
Mr. Harbin, with respect to the Atomic 16 Energy Clearinghouse documents when you did receive 17 and review them, from whom would they come?
18 Let me rephrase that.
Were they always 19 addressed to the Unit 1 superintendent or would they 20 have been sent someplace else and then forwarded to 21 the unit superintendent?
22 A
I know that for some period of time they were 23 sent directly to the unit -- Unit 1 superintendent.
24 Q
Do you know what period of time that was?
gS 25 A
No, I don't.
d.
1 Harbin 112 2
Q When you say they were addressed to the s
3 unit superintendent 4
A Unit 1 superintendent.
I 5
Q
-- Unit 1 superintendent, would they be 6
addressed by name, for instance Mr. Seelinger?
7 A'
I don't recall that.
8 Q
Do you know if at any other period of 9
time they would have come to you bp a different way,
-10 that is, they would not have been addressed directly 11 to the unit superintendent?
12 A
I don't recall.
13 Q
Do you recall if there was ever a time Q(_j 14 when they would be forwarded to you from the library 15 at Parsippany?
16 A
Yes, I recall that they weren't.
17 Q
They were not?
18 A
That's right.
19 Q.
Do you recall at any time that they might 20 have been forwarded to you from another department, 21 for inst'ance, Licensing?
22 MR. MacDONALD:
Can you ask him.whether 23 they were, j
24 MRS. VAUGHAN:
From another department.
/~}
25 MR. MacDONALD:
Only_
they might have, that u
~.. -
l-Harbin 113 2
A Not that I recall.
3 Q
Do you recall that there was a time when 4
they came to you but not by way of being mailed 5
directly to the unit superintendent?
6 A
No, 'i don't recall.
7 Q
Do you know if anyone else received the 4
8 Atomic Energy Clearinghouse documents at the same 9
time that the Unit 1 superintendent was receiving 10 them?
11 A
I don't know of that.
12 Q
Have you heard that somebody else received 13 them?
O w.
14 A
I recall that there wac some discussion about 15 having some member of the Training Department receive 16 copies of that document directly from the source in 17 addition to the Unit 1 superintendent.
18 Q
Do you remember whan those discussions
'19 took place?
20 A
No, I don't.
21 Q
Was it before the accident?
22 A
I don't recall.
23 Q
Do you recall whether any action was taken 24 on that suggestion?
25 A
I don't know if any a'etion was taken.
~,
w-e w,
e
1 Harbin 114 2
Q I believe you testified that you received
,~
3 the Current Events-Power Reactors; is that correct?
4 A
Yes, I believe that's the name of the publication.
)
5 Q
And you did receive it and review it?
6 If it will be any help, this is an NRC 7
publication that comes out bi-monthly.
8 A
Issues that I received I reviewed as a normal 9
practice.
10 Q
Do you recall how they came to you, in 11 other words, were they addressed directly to the 12 unit superintendent or were they routed to the unit 13 superintendent from some other source?
(
14 A
I recall that there were issues that came 15 directly to the unit superintendent.
1G Q
Do you recall that there were ever issues 17 that did not come directly to him?
18 A
I don't know if thers weren't.
19 Q
Are you aware of any time during which 20 they were not coming directly to him?
21 A
I don't have any knowledge of that.
22 Q
What about the NRC bulletins, circulars 23 and noticos, would they also come directly to the 24 unit superintendent?
25 A-From the time of my employment to the present
. O,
1 Harbin 115 2
day?
O
(_/
3 Q
That's right.
4 A
There were some periods of time in which they
)
5 did.
6 Q
And were there some periods of time in 7
which they did not?
8 A
I am not sure.
I don't know that.
9 Q
Do you recall any period of time when you 10 would have reviewed a bulletin, circular or notice 11 that it did not go directly to the superintendent?
1 12 A
Yes.
13 Q
You do recall a period when it did not?
()
14 A
Yes, but 15 Q
Go ahead.
16 A
If you are trying to relate that to the previous 17 question that you asked, then the answer I gave is 18 totally unrelated.
19 Q
I am just trying to figure out whether 20 there was any time when you would have reviewed a 21 bulletin, circular or notice from the NRC that did 22 not go directly to the unit superintendent.
23 A
Yes.
24 Q
There was a time when you reviewed one s
erintendent?
I
=
1 Harbin 116 2
A Yes.
[/\\
(-
3 Q
When was that?
4 A
I don't recall.
It depends on the circular,
)
)
5 the bulletin or :he notice.
6 Q
so is it true then there is not a general i
7 practice that sometimes they would come to the 8
Unit 1 superintendent directly and sometimes they 9
would not or let me ask it this way:
Did all the 10 bulletins go to the Unit 1 superintendent?
11 A
I can't be sure that from the time of my 12 employment to the present day that the Unit 1 13 superintendent was on distribution for all notices,
/"N 14 bulletins and circulars.
j i
15 Q
All right.
16 Maybe we better go back and make this 17 clear.
I am trying to establish which ones would 18 have been sent directly by the NRC or by whomever 19 published these various documents that we are talking 20 about.
21 A
Yes.
22 Q
To the unit superintendent as opposed 23 to his being on distribution from some other source.
24 A
- Yes, 25 gg Q
All right?
d
I Harbin 117 2
A Yes.
{%
3 Q
Do you recall reading an NRC bulletin 4
that did not go directly to the Unit 1 superintendent?
5 In other words it might have been routed from somebody 6
else within the organization.
7 was it the general practice that he would 8
receive them directly?
9 MR. MacDONALD:
You have two questions 10 now.
11 MRS. VAUGHAN:
I will take the second one.
12 MR. MacDONALD:
You want the second one?
4 13 MRS. VAUGHAN:
Yes, I am just trying to 14 help him.
15 A
I am sorry, could you repeat the second 16 question then?
17 MR. MacDONALD:
Can we hear the pending 18 question, please?
19 (Question read by the reporter.)
20 MRS. VAUGHAN:
Let's make it clear that
}
21 it is the last question I am asking now.
22 Q
Was it the general practice that the 23 Unit 1 superintendent would receive NRC bulletins 24 directly from the NRC?
/~S 25 A
Yes, that's correct.
0-
4 1
Harbin 118 2
Q Was that also t,he practice with respect 3
to circulars and notices from the NRC?
4 A
Yes, 'tha t 's' corre c t.
)
5 Q
With regard to the B&W weekly newsletter 6
that you referred to earlier, was it the general 7
practice that that publication would be sent directly 8
to the Unit 1 superintendent?
9 A
For some period of time.
I don't recall how 10 long.
He receives it now and I don't recall how long 11 that practice has been in existence.
12 Q
Do you recall a time when he received 13 the weekly newsletter from B&W from another source
(
14 iother than B&W directly?
15 A
I don't recall any specific instances of that.
1G Q
Do you recall how long the B&W weekly 17 newsletter has been coming to the Unit 1 superintendant?
18 A
No, I.said I don't recall that.
10 since before the accident.
20 Q
With respect to your review of these I
21 various publications that we have been talking about, s) i
~
22 did anyone ever give you any directions as to, or J
23 instructions, as to what you should be looking for j
24 when you reviewed these documents?
25 A
Yes.
O
- =
1 Harbin 119 2
Q What were those directions?
("'N
\\-
3 A
For example with respect to the Federal Register, 4
which sections or which agencies published
)
5 e information that might apply to TMI or the nuclear 6
industry or the company in its dealings.
7 Q
What about with respect to the NRC 8
bulletins or the Atomic Energy Clearinghouse documents?
9 What direction did you have with regard to reviewing 10 those publications?
11 MR. MacDONALD:
Are you lumping all of 12 these together or --
13 MRS. VAUGHAN:
At this time I am lumping 14 all of them together but if it's not 15 appropriate --
16 A
I would like to take them one at a time.
17 Q
What about the NRC bulletins, notices 18 and circulars, do you want to lump those together?
19 A
Yes, we can lump those together.
l 20 What was the question?
21 Q
What directions, what directions or 22 instructions did you receive regarding your review 23 of those documents?
i 24 A
I don't recall any specific verbal directions.
25 I recall seeing action taken by the unit' superintendent
-Os i
1
,-e-,-
1 Harbin 120 2
and by other members of the staff with regard to
("%
k-s 3
those documents and reading responses to those 4
documents.
I would consider that on the job training.
)
5 Q
What is the difference between a bulletin 6
and a circular, an NRC bulletin and an NRC circular?
7 A
I don't really know what the difference is.
8 Q
Do you know what the difference is between 9
a bulletin and a notice?
10 A
I have never read a description published by 11 the NRC as to what the differences are.
12 Q
From your experience reviewing these 13 documents can you describe what the difference is?
14 A
It's-been my perception that the difference is 15 in level of severity of the event or finding and 16 potential for applicability, the effect on nuclear 17 safety.
18 Q
Which one would indicate the most severe?
19 A
Bulletin.
20 Q
Does a bulletin require specific action 21 by a utility?
g
.J 22 MR. MacDONALD:
Are you stating just 23 because it's a bulletin, just because of the 24 nature of the publication?
~3 25 MRS. VAUGHAN:
That's right.
(J
1 Harbin 121 2
Q Is a bulletin something that requires
,(-)
i 3
specific action by a utility, an NRC bulletin?
4 A
Not necessarily.
If it requires a response, it
)
5 is stated in the bulletin that it requires a response.
6 Q
After you would review a bulletin, a j
7 circular or a notice from the NRC, what would you 4
8 do with it?
9 A
When?
10 Q
Well, let's go back to when you were 11 working for Mr. Colitz.
12 A
My general
'the general practice then was 13 that I would highlight certain portions of the
()
14 document and pass it on to him.
15 Q
How did you know which' portions to l
16 highlight?
17 A
By reading the document, l
]
18 Q
Did you ever get any instructions or i
1 19 directions from Mr. Colitz as to the kind of items
}
20 he would be interested in and he wanted to see?
g 21 A
Not that I recall.
J 22 Q
After you highlight-. certain portions 23 would you pass the entire document on to Mr. Colitz?
24 A
That was the general practice.
f 25 Q
And then what would Mr. Colitz do with it
(~S
\\_)
1 Harbin 122 4
2 when he received it?
4 r
3 A
It would depend entirely on the document.
4 Q
What were the possibilities?
)
i 5
MR. MacDONALD:
Are you asking what he j
6 knows colitz did with it at various times?
l 7
MRS. VAUGHAN:
Yes.
8 MR. MacDONALD:
I guess'anything is I.
9 possible.
3 l
10 A
Yes.
I don't recall specifically what he did 11 with any notices, bulletins or circulars,
{
12 Q
Well, did he pass them on to some 13 individual on his staff to take specific action?
f"%
()
14 A
I don't know.
15 Q
Did you ever see a bulletin, circular or 16 notice again after you had passed it on to Mr. Colitz?
4 17 MR. MacDONALD:
Are we dealing now with 18 all three or just one?
l 19
~MRS. VAUGHAN:
We lumped them together 20 and if it is appropriate to break them out.
21 please do so.
If it is appropriate to answer 22 the question lumped together, that's fine, too, i-23 Mk. MacDONALD: :My only problem was that 24 I thought he had testified'or said a few i
i 25 moments ago that he highlighted portions of the
)
I l
t u-.
. 1..
1 Harbin 123 2
bulletin.
I didn't know whether that was D) tx_/
3 applicable to circulars and notices and now we 4
are lumping them together.
Perhaps the
)
5 practice was different.
I am not sure.
6 Q
Did you highlight the specific portions of 7
the circulars and notices as well 8
A I am not sure that notices existed 9
Q back in '777 10 A
--back when Mr. Colitz was the superintendent.
11 For circulars, yes.
12 Q
With respect to circulars and bulletins 13 you would highlight certain sections and send that
()
14 section to Mr. Colitz?
15 A
Yes.
1G Q
Did you ever see one of those again after 17 you sent it to Mr. Colitz?
18 A
I don't recall that I did.
19 Q
was there a file kept of these bulletins 20 and circulars at that time?
21 A
Yes, there was.
22 Q
Where'was that file kept?
23 A
In his office.
To the best of my recollection.
24 Q
Is there a file today of bulletins and 3
. 25 circulars and notices?
~)
1 Harbin 124 2
A Yes, there is.
3 Q
Do you know whether that file goes back 4
as far as 1977 when Mr. Colitz was the unit
.5 superintendent?
6 A
Yes, it does.
7 Q
Would that file contain the documents 8
as you had highlighted them?
9 A
I don't know that.
10 Q
Did you ever see that file?
11 A
Yes, I did.
I2 Q
Did you notice when you saw it whether 13 your highlights were there?
g 14 A
I don't recall.
15 Q
What does the file actually contain?
16 A
You know, it's hard for me to say because I 17 don't know specifically what file you are talking 18 about.
19 Q
I am talking about the file that would 20 contain the NRC bulletins, circulars and notices.
21 A
okay, the file was broken down by bulletin 22 number so that they are filed sequentially and we 23 kept a file on each bulletin.
24 I can't testify as to what each file contains 25 now.
1 Harbin 125 2
Q All right.
3 A
or what was placed into that file.
4 Q
Did you ever have occasion to look at
)
5 any of those files?
6 A
Yes, I did.
7 Q
Is it still your testimony that you don't 8
recall when looking at that file let me ask you 9
this.
Did that file at that time contain an actual 10 NRC bulletin?
In other words 11 A
The bulletin files contained bulletins.
12 Q
All right.
Did they contain any information 13 with respect to whether or not there was action'taken
)
14 regarding the bulletin?
15 A
I can't -- I can't say.
16 Q
You don't know?
17 A
That's right, I don't know.
18 Q
Who keeps the files today or in whose 19 office are they, where would they be found?
20 A
What files?
21 Q
The files containing the NRC bulletins.
22 A
For what period?
23 Q
If it differs for the period that goes 24 all the way back to 1977.
(~}
25 A
Some of the files are maintained by Pat Schlegel
\\_/
l
-.*a
_s
_.4 m
u4 a+.
1 Harbin 126 2
who is Ron Toole's secretary and I believe that
\\-
3 those are files from 1981 and 1980 and files for 4
years previous to 1980 are maintained by Al Stove
)
5 in Unit 2.
l 6
Q They are maintained for Unit 1 and Unit 27 7
A I don't know about Unit 2.
8 Q
But Mr. Stowe is at Unit 2?
9 A
Let me rephrase that.
10 Q
Sure.
11 A
They are maintained by Al Stowe in the Unit 2 12 administrative building.
13 Q
Would the NRC circulars be kept on a
(
14 continuing basis?
15 A
Yes, that was the general practice.
16 Q
Back in 19777 17 A
Yes.
18 Q
And is that true today, too?
19 A
Yes, it is.
20 Q
Would those files, those circulars be 21 kept in the same area as the bulletins?
22 A
Yes.
23 Q
And is that also true with regard to the 24 notices from whenever they came into existence?
25 A
- yes,
1 Harbin 127 2
Q So that if I wanted to get copies of 0)
"(,
3 bulletins, circulars or notices say for 1978 4
Mr. Stowe would have those?
)
5 A
He might.
G Q
Are you saying he might because you 7
don't know whether he has all of them?
8 A
That's correct.
9 Q
Do you know whether somebody else has 10 them?
11 A
No.
12 Q
In 1978 at the time you were working for 13 Mr. O'Hanlon did you do anything differently with
(
14 regard to your review of the NRC bulletins, circulars 15 and notices?
16 A
Not that I recall.
17 Q
In other words, you highlighted portions 18 of those documents and forwarded them on to 19 Mr. O'Hanlon?
20 A
That was the general practice.
21 Q
All right.
Did Mr. O'Hanlon indicate 22 to you any directions or instructions with regard 23 to your highlighting of those documents?
24
'A
-Not that I recall.
25 Q
Did anyone indicata to you any instructions v
1 Harbin 128 2
or directions?
(h
\\-)
3 A
Hac anyone ever?
4 Q
Did anyone up to that time.
)
5 A
To that time, no.
6 Q
Now, with regard to Mr. Seelinger, when 7
you worked for him, did you have the same general 8
practice regarding your review of these NRC bulletins, 9
circulars and notices?
10 A
Yes.
11 Q
Did Mr. Seelinger give you any instructions 12 or directions?
4 13 A
Not that I recall.
()
14 Q
And with respect to Mr. Miller, would 15 you also highlight for him portions of the bulletins, t
16 circulars and notices published by the NRC7 17 A
I don't recall whether I did or not.
18 Q
Would you discuss with him those bulletins, 19 circulars or notices?
20-A I don't recall.
21 Q
Did he give you any instructions or 22 any directions?
23 A
Not that I recall.
24 Excuse me, fs 25 Q
Go ahead.
I I
V
1 Harbin 129 2
A I recall that while working for Mr. Miller O
3 there was there were discussions relating to 4
how action would be assigned on bulletins, circulars 5
and notices.
6 Q
Were you involved in those discussions?
7 A
Yes, I was.
8 Q
Nas there anyone else involved in those 9
discussions?
10 A
Yes.
11 Q
Who oise?
12 A
Joe Colitz and Roy Harding.
13 Q
And why did those discussions come about?
14 A
As I recall it was because the Licensing 15 Department had moved from a corporate office in 16 Reading to an on site office on the island and they 17 underwent some transformation in how action items 18 were generated, how assignments were made on the 19 various documents.
20 g
When did that take place, that discussion?
21 A
During the period of time that Mr. Miller was 22 acting as Unit 1 superintendent.
23 Q
Which was after Three Mile Islands is 24 that right?
(}
25 A
Yes, that's correct.
I Harbin 130 2
3 Q
After the accident?
3 A
After the accident.
4 Q
Did you get any instructions or directions
'}
i 5
at that time?
Were there any instructions or 6
directions discussed with regard to reviewing these?
7 A
Not specifically with how they were reviewed 8
but the answer is yes with respect to what the 0
responsibilities were surrounding review and assignments 10 for action.
11 Q
You mean whose responsibility it was to 12 review and assign for action?
13 A
Yes.
14 Q
Was it determined at that time that 15 somebody else should be reviewing them?
16 A
Somebody besides who?
17 Q
Besides you.
18 A
No.
10 I mean there was no decision made as far as 20 who reviewed the documents that that should be any 21 different.
g 22 Q
What decisions were made?
23 A
Decisions relating to the mechanism for 24 receiving, assigning action,following up, responding
/~N o.5 if necessary, documenting, action taken, those are (j
a mi
1 Harbin 131 2
examples.
3 Q
was there any discussion to the effect 4
that the review prior to that time had perhaps not
)
5 been adequate or that the follow up on action items 6
hadn't been adequate?
7 A
No.
8 Q
Was it just a matter of reorganization 9
essentially?
10 A
Yes.
11 Q
Is there a document setting forth a i
12 procedure to follow when these action items are
,\\'
13 assigned or how they are g)ing to be assigned or who i
(_)
14 does the assigning?
15 A
Is there now?
16 Q
- Yes, i
17 A
Yes, there is.
18 Q
Is it a memorandum of some kind?
19 A
No, I believe it's a procedure.
20 Q'
An administrative procedure?
21 A
I-don't k ow.
22 Q
DoesNit have a number or a name?
23 A
It has a number.
I 24 Q
Do you know the number?
73 25 A
No.
N J' t
s,
e s
e t.
- + - -
~'
1 Harbin 132
$~s_
3 O.
2 Q
Let me ask you this:
When was this
\\--
3 Procedure written, that you are referring to?
t 4
A I don't know.
')
5 Q
Was there a procedure prior to the one 6
you just referred to?
7 A
I don't know if there was or not.
8 Q
Was the procedure you just referred to
+
9 in existence at the time of this discussion that, f/ ;
5 10 you were talking about, the discussion with Mr. Miller i
C-11 and the other two gentlemen?
t 12 A
Not to my knowledge.
4 13 Q
Do you know whether there was any 14 written direction with regard to making assignments L
15 on action items?
s 16 A
At the time of our discussion?
17 Q
That's right.
. it 18 A
I don't know.
IV Q
Did you ever see one?
20 A
Did I ever see one what?
21, Q
A written memo?
- 22 A
I don't know of any.
~"'
y
~.H j ' V' 23 Q
All right.
l 24 You never heard Mr. Seelinger or Mr. Colitz
.tv i
)
('^g i,25[
or Mr. O'Hanlon refer to one?
j
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if c
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i
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l' Harbin 133 i.
2 A
Hear them what?
(~
l b >
l 3
Q Refer to any kind of written memo.
j 4
A Not that I recall.
l' 5
Let me make a clarification.
I said that the 6
Licensing Department moved from Reading to the I
7 Island.
It was when that move occurred that these 8
discussions took place between Mr. Harding, Mr. Colitz, i
9 Mr. Miller and myself.
And before that change in 10 organization the documents were handled by the 11 Licensing Department in Reading from a corporate 12 point of view, the documents were also received in 13 Reading, responses were generated by Reading.
O)
(_
14 Q
Which documents are you referring to?
15 A
Bulletins, circulars and notices, and responses 16 to those documents.
17 Q
Were received in Reading?
18 A
Yes, that's correct.
19 Q
As were the responses?
20 A
The responses originated -- no, they didn't 21 originate, they -- it is my knowledge that they 22 were approved and sent approved by a member of 23 management in Reading and sent, if a response was 24 required by the NRC, sent to the NRC from Reading.
("'Nw.)
25 Q
Does that.mean that somebody in the i
1 Harbin 134 2
Licensing Department in Reading would assign M(/
3 somebody to follow up with an action item?
4 A
I don't know that that's the case.
5 Q
When you say that the Licensing Department 6
in Reading received the NRC bulletins, does that 7
mean they received a duplicate set that the unit 8
superintendent was receiving?
9 MR. MacDONALD:
Are you trying to find 10 out exactly whether he knows that the bulletin l
I 11 the Unit 1 supervisor may have received was 12 also the same bulletin received by Licensing 13 in Reading?
()
14 MRS. VAUGHAN:
That's right.
15 Q
In other words, were two copies of the 16 bulletins sent, one to the Unit 1 superintendent 17 and the other to Licensing in Reading or did Licensing 18 in Reading get it first and then send it to the 19 unit superintendent?
20 A
The latter is not the case.
21 Q
All right.
22 A
The former was the general practice for at 23 least some period of time.
24 Q
With regard to your review of the B&W
^$
25 weekly newsletter, when you were working for
~J c
1 Harbin 135 i
l 2
Mr. Colitz, did he indicate to you what kind of fN_/
3 items you should be looking for or basically what i
4 the purpose of your review was?
)-
5 MR. MacDONALD:
I object to th e form of, 6
the question.
I don't think that the witness 7
has testified that he has reviewed these 8
B&W weekly newsletters when he was working for 9
Mr. Colitz.
I think his testimony was he 10 couldn't recall necessarily when the review 11 took place but he did recall receiving those 12 at some point in time.
You have only built 13 into your question that it took place when he
(
14 was working for Mr. Colitz.
15 Q
Do you recall whether while you were 16 working for Mr. Colitz you reviewed the B&W weekly 17 newsletter?
18 A
No, I don't recall it, i
19 Q
Do you recall any instructions from 20 Mr. Colitz regarding the B&W weekly newsletter?
g 21 A
No,
)
i 22 Q
Do you recall when you were working 23 for Mr. O'Hanlon you reviewed the B&W newsletter?
24 A
No, I don't recall.
4 25 Q
Do you recall Mr. O'Hanlon ever giving s_-
. Harbin 136 2
you any instructions with regard to the B&W weekly a
3 newsletter?
w 4
A No, I don't recall that.
)
5 Q
How about while you were working for 6
Mr. seelinger, do you recall reviewing the B&W 7
weekly newsletter?
8 A
Yes, I do.
9 Q
Do you recall any instructions from 10 Mr. seelinger with regard to your review of that 11 newsletter?
12 A
Yes, I do.
13 Q
what were those instructions?
(
14 A
Following the TMI-2 accident Mr. Seelinger 15 directed me to review the weekly newsletters for 16 events occurring at other B&W plants and initiate 17
'a program that~would be designed to track various 18 types of events, look at trends, those kinds of h
19 things.
20 Q
Did you design a program?
21 A
Yes, I did.
22 Q
Can you describe that?
23 A
I don't recall it very specifically but l
24 examples of things that would be recorded from the I
(~'
25 newsletter was the date of the incident, the plant
-(
1 1
Harbin 137' 2
name, whether it caused -- whether the event caused
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3 a forced outage, a shutdown, reduction in power 4
level, what components were involved, if any, what
- )
5-the cause was and at the time that it was designed 6
it was intended to enter that kind of information 7
into a computer that could be sorted then by components 8
for example.
9 Q
Is that program still in existence today?
10 A
No.
11 Q
When was it discontinued?
12 A
It was never really -- the information was 13 never entered into the computer.
()
14 Q
Why is that?
15 A
A decision was made by members o f GPU 16 that enough other organizations were doing similar 17 things so that it was not cost beneficial.
18 Q
Do you remember any of the organizations 19 referred.to by name?
20 A
INPO, Institute of Nuclear Power Operations was 21 one, an internal organization.
22 Q
An internal organization?
23 A
Yes, an internal organization called the Plant 24 Analysis Group.
Those are the only two that I can rs 25
.think of that I know of.
k m
1 Harbin 138 2
Q Did those two send on a regular basis
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T s.
3 this information or did they exist and you could go get 4
it when you want it?
')
5 A
Could you repeat the question, please?
6 Q
Sure.
7 Do those two organizations 8
A Excuse me, do they?
I',
9 Q
Yes.
10 Do those two organizations send you some 11 kind of a weekly, monthly or every other month report 12 or can you go to them for the information when you 13 want to?
()
14 A
I don't know of any periodic reports and I 15 don't know that
--I have never'gone to either one 16 for information so I don't know.
17 Q
Do you recall reviewing the B&W weekly 18 newsletter before Mr. Seelinger asked you to put 19 together this program?
20 A
Yes.
21 Q
Do you recall how much before?
22 A
Before the accident.
23 Q
Do you recall whether your review of.the 24 B&W weekly newsletter was new with Mr. Seelinger?
In gx 25 other words, was he the first person who asked you N.
1 Harbin 139 2
to review the Bsw weekly newsletter?
Nj 3
A No, I don't recall that.
4 Q
Do you recall that you did not review
)
5 the weekly newsletter when you were working for 6
Mr. O'Hanlon?
7 A
No, I don't.
8 Q
You just don't recall when you started 9
reviewing the weekly newsletter?
10 A
That's right.
11 Q
Do you know who else might have received 12 the weekly newsletter within Met Ed or GPU?
13 MR. MacDONALD:
I object to the form.
14 MRS. VAUGHAN:
Why?
?
15 MR. MacDONALD:
Did he know who else did 16 receive it?
17 MRS. VAUGHANA Yes.
18 MR. MacDONALD:
Might have, there are 19 many people that might have.
20 Q
Do you know who else received it?
21 MR. MacDONALD:
If he knows, fine.
22 A
As of what time period?
23 Q
As of any time period from the time you 24 started your employment with Met Ed.
g 25 A
I know that Mr. Hank Hukill received it.
'%)
.1 Harbin 140 2
Q What is his job?
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t i
3 A
He is the vice president, Unit 1.
4 Q
Anyone else?
)
5 A
Not that I know of.
6 Q
What would you do with the weekly 7
newsletter after you reviewed it?
You would highlight 8
portions of it?
9 A
No, I didn't say what I would do.
10 Q
What would you do with it after you 11 reviewed it?
12 A
During what period of time?
13 Q
Well, the period of time that you can 14 remember is with Mr. Seelinger so we will take that.
15 A
one thing that I did with it was to route it 16 to various Unit 1 department heads and engineers and 17 indicate initials in the margin as to the portions of 18 the report that might have applicability to those 19 specific members of the staff.
20 Q
Would that be in addition to sending it 21 on to Mr. Seelinger for his review?
22 A
I don't recall.
23 Q
Would it be just'the one newsletter or 24 would you make copies and send it to everybody 25 simultaneously?
t I
Harbin 141 2
A I don't recall.
'/
3 Q
was it always the same lis t of people who 4
would get copies or would you vary it?
5 A
It would vary.
6 Q
Depending on the items that were reported?
7 A
That's correct.
8 Q
How would you determine which items were 9
important to which person?
10 A
Based on my knowledge of the responsibilities 11 of various members of the-plant staff.
12 Q
Would the newsletter itself or copies of 13 the newsletter be returned to you so that you could 14 be assured that they had been received by the person?
15 A
I don't recall.
16 g
Were copies of the newsletter returned 17 at all, ever?
18 A
I don't recall.
19 Q
Is there a file of the newsletters, of 20 old copies?
21 A
I have maintained a file since Mr. seelinger 22 made the request that I referred to a few minutes ago.
23 Q
And when was that request made?
Was it i
i 24 after Three Mile Island?
25 A
It was after the accident.
1 Harbin 142 2
Q But you don't know whether there exists
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3 a file prior to that or you don't recall any file 4
prior to that?
)
5 A
I don't know whether there exists a file.
6 Q
You do not have one in your office' at 7
this time; is that right?
8 A
That's correct.
9 Q
And you have no recollection of having 10 sent all the B&W newsletters for 1978 to a central 11 filing place?
12 A
That's correct.,
13 Q
Is it true that
)
14 A
Excuse me.
I recall that I did not send B&W i
15 newsletters to any central file before that time.
16 Q
Do you recall why you kept all the 17 copies after the accident at Three Mile Island?
18 A
I didn't keep all the copies after the i
19 accident.
I kept all the copies after Mr. Seelinger
-20 directed me to start that program, i
T 21 Q
Do you recall why that was that you sJ 22 kept them from then on?
23 A
Yes, because I -- I was gathering information 24 for this program and for some period of time it was 25 simply a matter of getting a data base established L
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i I
~.. -.,. ~, _
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i l
1 Herbin 143 2
and reviewing of reports with the intent of designing js k.
3 the program.
1 4
I didn't feel that you could design a program
)
5 after reviewing one report only to get a good sampling 6
of the kinds of incidents, the kinds of failures, 7
things like that.
8 Q
At the time Mr. Seelinger instructed you 9
or asked you to design a program, did he indicate 10 why he wanted that program designed?
11 A
I don't recall if he did.
12 Q
was his instruction or request of you 13 made in writing or verbally?
(
14 A
I recall that there was some direction given 15 in writing and some verbally.
1G Q
Do you recall responding in writing in 17 any way to his request?
18 A
No, I don't.
19 MR. MacDONALD:
Off the record.
20 (Discussion off the record.)
21 Q
Prior to Mr. Seelinger asking you to 22 establish this program, did he give you any other 23 instructions or directions with regard to the B&W 24 bulletin?
25 A
Not that I recall.
O v-
~
l Harbin 144 2
Q So that this instruction and request was l'~)
k/
3 the first time you had any discussions with him 4
regarding the bulletin and what you should be doing
)
5 with it?
6 A
Yes, that's correct.
7 Q
Did he ask you to coordinate with anybody 8
else in designing this program?
9 A
No, not that I recall.
10 Q
Did you?
11 A
I recall that I talked to other individuals 12 concerning programs that might already exist that 13 would serve the same function.
(
14 MRS. VAUGHAN:
Okay, why don't we adjourn 15 for the day.
16 (Time noted:
4:31 o' clock P.M.)'
17 18 RONALD STEPHEN HARBIN 19 20 Subscribed and sworn to before me
.y 21 this
~ day of 1981.
,)
22 23 24 p-25 O
1 145 2
CERTIFICATE 3
STATE OF NEW YORK
)
- ss.:
4 COUNTY OF NEW YORK )
(')
5 i
6 I,
CHARLES SHAPIRO a
7 Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9
of RONALD STEPHEN HARBIN was taken before 10 me on July 7, 1981 11 That the said witness was, duly sworn 12 before the commencement of his testimony and 13 that the within transcript is a true record of said O
l 1
14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set
}
my hand this dl day of 30LT 3 g g t ',
21 22 C
A equh CHARLES SHAPIRO
.S.R.
f
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25
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$T'l]l
~ July 7, 1981
~
146 l
I ND E X i
WITNESS PAGE l
Ronald Stephen Harbin 3
f E X.H I B I T S B&W EXHIBITS FOR IDENT.
200 Organization chart dated 7
January 1977 entitled
",T M I Supervisory" 201 Organization chart dated 14 1/1/78
,202 Organization chart dated 53 1/1/79 headed "TMI - Supervisory" 203 Organization chart dated 55 1/31/80 titled " Metropolitan Edison Company, Three Mile i
Island, Unit 1"
g f
b o
9 l
I
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