ML20072J072
| ML20072J072 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/19/1982 |
| From: | Keaten R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-04, TASK-05, TASK-1, TASK-10, TASK-2, TASK-3, TASK-4, TASK-5, TASK-GB NUDOCS 8306290907 | |
| Download: ML20072J072 (137) | |
Text
_- _ - - - --.
I 628 dt/3 UNITED STATES DISTRICT COURT O SOUTHERN DISTRICT OF NEW YORK
_________________________________________x GENERAL PUBLIC UTILITIES CORPORATION, :
JERSEY CENTRAL POWER & LIGHT COMPANY,
'h METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. :
_________________________________________x Continued deposition of ROBERT s
i KEATEN, taken by defendants pursuant to adjournment, at the offices of Davis, Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Tuesday, January 19, 1982, at 10:40 o' clock in the forenoon, before Catherine Cook, a Shorthand Reporter and Notary Public within and for the State of New York.
8306290907 820119 PDR ADOCK 05000289 T PDR DOYLE R EPORTING. INC.
O CERTIFIED STENCTYPE REPORTERS 369 LE x t N GTo N AvgNyt WALTER SH APIRO, C.S.R. New Yong. N.Y. 10017 CH ARLES SH APIRO, C.S.R. TatspwoNE 212 - 867 8220
_ _ _ _ . _ _ _ _ - - _ _ _ _ - _. __. q . , -. . - . . , .,m ,. -. . . . . . , , ,, , _ . ._.._.m , _ _ ,
629 -
1 2 Appearances T
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue New York, New York By: STEVEN GLASSMAN, ESQ.,
6 of Counsel 7
8 DAVIS, POLK & WARDWELL, ESQS.
Attorneys for Defendants 9 One Chase Manhattan Plaza New York, New York 10 By: ROBERT F. WISE, ESQ.,
11 of Counsel i
' 12 ALSO PRESENT:
O ~
Nina Ruffini 14 15 16 17 18 KEATEN, having been previously R.O B E R T 19 duly sworn, resumed and testified further as 20 follows:
l .
21 EXAMINATION (continued) 22 BY MR. WISE:
i 23 Q Mr. Keaten, you recognize you are still 24 ' under oath in this deposition.
f
- i. -
25 -
A Yes, I do.
i A , - ~ ,-er- yn-_w ,m- - , . + -esne,r.n- e,w,,- e,gy ,
1 Kocton 630 2 MR. WISE: I would like to begin this 3 morning by simply identifying and marking for 4 the record a series of drafts of the llg 5 investigative task report. Earlier in the 6 . deposition we marked as B&W 347 a copy of the 7 first draft of the interim summary report, 8 which I believe you testified you prepared.
9 It is attached to a cover memo dated September 10 28, 1979. The next document I would like to 11 mark as B&W Exhibit 349 is a copy of the GPU 12 Task Force Interim Summary Report which is
() 13 labeled on the front page "Second Draft, October 14 6, 1979." .
15 (Copy of GPU Task Force Interim Summary 16 Report, Second .Dra f t , October 6, 1979, was 17 marked B&W Exhibit 349 for identification, as 18 of this date.)
~
19 g gr. Keaten, I am not going to ask you any 20 specific questions about the document this time. My 21 only purpose is to understand whether or not you O 22 recognize this as a copy of the second draft of your t
23 report.
24 MR. GLASSMAN: So the record is clear, 25 there is some. handwriting on there and I want
i
, 1 Konton 631 i
() 2 to know if t'e n question is directed to with or without the handwriting.
l 3 4 Q Is the document in its typewritten form what it purports to be, a second draft of your interim e,
5 gg i 6 summary report, or the interim summary report of the
) 7 task force, and then I will ask you about the 8 handwriting that appears on this particular copy.
4 9 A on the basis of a very brief inspection, 10 I believe it probably is a copy of the second draft 11 of the report.
! 12 Q Do you recognize the handwriting on this 13 particular copy?
14 A Not for certain.
I Are you familiar with Mr. Broughton's
- 15 Q J
i 16 handwriting?
17 A Yes, I am generally familiar with his i
18 handwriting.
1 19 Q Does this appear to you to be Mr. ,
20 Broughton's handwriting?
21 A I really cannot tell.
O 22 Q Do you know whether you ever saw this 23 draft with the handwriting that appears on this 24 particular copy which we have marked as Exhibit,3497 25 A To my knowledge, I did not see it.
1 Konton 632 I
I would like to mark next as
( 2 MR. WISE:
3 B&W Exhibit 350 a copy of what appears to be l
l 4 the third draft, dated October 17, 1979, of i
(gg 5 th,e GPU Task Force Interim Summary Report.
6 The draft is preceded by a one-page cover 4
7 memorandum dated October 17, 1979, signed 8 apparently by Mr. Keaten and addressed to the 9 Investigative Task Force. There is also some
'10 handwriting on the document which appears to 11 have been signed by Mr. Long.
I 12 (Third Draft of GPU Task Force Interim
() 13 Summary Report, dated October 17, 1979, with cover memorandum, was marked GPU Exhibit 350 14 15 for identification, as of this date.)
16 Q Mr. Keaten, again with the same general 1
17 approach, do you recognize the draft and whatever 18 handwriting may appear on this particular copy?
1 19 A In general yes, I recognize it. I 20 should clarify that if you are asking me to identify 21 this as the third draft, I am doing so primarily on O 22 the basis of the title page. It would take a lot of 23 review of the internals of the document to make sure 24 which draft it was.
25 Q Recognizing that we have a number of
1 i
1 Konton 633 ,
2 drafts here, some of which I have marked and some 3 more that I am going to mark, and that it is 4 impossible for you today to go through word for word g 5 and swear to us that we haven't tricked you and put 6 in one page or another that should be there, my 7 questions are really directed at whether in fact 8 there was a third draft during the october period 9 and so on.
10 Let me ask you first with respect to the 11 cover memo that appears on the front of the document, 12 do you recognize that as a memo that you wrote and 13 sent?
14 A Yes, I do. l 15 You have no reason to believe that the Q
16 document attached to it on this particular exhibit 17 which is labeled " Third Draft October 17, 1979" 18 is anything other than what it purports to be?
19 MR. GLASSMAN: The witness said he can't 20 tell without reviewing it carefully.
21 MR. WISE: He can't swear whether it is O 22 or isn't. I can ask him if he has any reason 23 to believe it is not.
24 MR. GLASSMAN: I am not sure what kind l
O 25 of review you wanted. His answer was' based on
l 1 Kseton 634 A 2 a very quick review, if that's satisfactory
()
3 for the question.
4 MR. WISE: It is. _
5 A Based on a very cursory review, I have no qgg 6 reason to believe that it is not the draft.
7 Q There is some handwriting contained in 8 various parts of the document. Again, without asking 9 you to look at every page and swear that there isn't 10 any comment in there that might be by you, because 11 I don't want you to take the time to do that, as a 12 general review, do'you recognize that as any of 13 your handwriting? You might look at the page marked 14 for this litigation as 8342.
15 A That does not look like my handwriting.
16 MR. WISE: Next I would like to mark as 17 B&W Exhibit 351 a copy of a memo dated October 18 29, 1979, which purports to be from Mr. Keaten, 19 addressed to Mr. Dieckamp and Mr. Arnold.
(
20 The subject is Investigative Task Force 21 Interim Summary report. Attached to the O 22 memorandum is a copy of what is labeled "GPU 23 Task Force Interim Summary Report," bearing 24 the date October 29, 1979 and a series of l 25 signatures, including one that purports to be
- ~ w- ,, -- ~ , - - -
Koston 635 1
2 that of Mr. Keaten.
(copy of memo dated October 29, 1979 3
4 and attached GPU Task Force Interim Summary
, 5 Report, dated October 29, 1979, was marked
.gg 6
B&W Exhibit 351 for identification, as of this 7 date.)
8 Q Mr. Keaten, first let me ask you, do you 9
recognize the cover memo that is part of B&W Exhibit 10 3517 11 A Yes.
12 Q Is that a memo that you prepared and wrote? l l
13 A Yes, it is.
14 Q Looking at the first page of the attached 15 report, do you recognize your signature next to the 16 typed notation "R. W. Keaten"?
17 A Yes, I do.
18 Q Was Exhibit 351 intended to be the final 19 copy of the GPU Task Force Interim Summary Report?
20 MR. GLASSMAN: Intended by whom?
21 MR. WISE: By its authors of whom Mr.
O r
22 Keaten was one and also the chairman of the 23 task force.
24 A I frankly don't recall any discussion r,'} 25 that the task force had as to whether this was
1 Konton 636
,((s) 2 necessarily the final version of the interim report 3 or not.
4 Q Did you in fact send a copy of this to
- 5 Mr. Dieckamp and Mr. Arnold? ,
6 A To the best of my knowledge, we did.
7 Q Did you receive any comments from them?
8 A Yes, I did.
i 9 Q Did you receive them from both people or 1
10 from one or the other?
11 A I remember discussing this version of the 4
12 task force report with Mr. Dieckamp. I do not i
() 13 remember whether I received comments from Mr. Arnold 14 on this version.
15 Q What was the occasion for your discussion j 16 with Mr. Dieckamp concerning this report?
i 17 A He asked me tocome to his office for the 18 purpose of discussing it.
i 19 Q How long after your distribution of your 20 memo and the report was that? A matter of days, 21 weeks, months, hours?
O 22 A I don't remember exactly. I believe it 23 is fair to say it was not hcurs and not months.
l s 24 Q So it was either days or weeks. How
\
25 long a discussion did you have with him about this
l 1 Konton 637 l
2 subject?
3 A I don't remember the specific lengths of 4 time involved.
5 Q Was it a full day?
gg) 6 A To the best of my recollection, it was not.
7 Q Can you put any order of magnitude? Are 8 we talking about something that lasted minutes, 9 hours, half day, the better part of a day?
10 A To the best of my recollection, the time 11 that we spent discussing this draft was of the order 12 , of one or two hours.
13 Q Did Mr. Dieckamp give you any written 14 comments?
15 A I do not recall ever receiving any formal 16 written comments from him.
17 Q Did you make any notes of your 18 discussions with Mr. Dieckamp?
19 A I don't remember.
20 Q What did you and Mr. Dieckamp discuss t 21 about the report?
22 A We discussed his interpretation of the 23 words that were written in this version of the report 24 and whether.or not what he read from the words was 25- consistent with what the task force was trying to say.
l 1
f 1 Konton 638 I
( 2 Q Do you remember any specific sections that 3 ho discussed with you?
4 A one which I remember specifically is gg 5 Section II-B.
6 Q That's the section concerning the rationale 7 for the control room and staff personnel response?
8 A That's correct.
9 MR. GLASSMAN: We are referring to page 10 marked for litigation purposes 82877 11 MR. WISE: That's the one I am talking 12 about.
() 13 THE WITNESS: And also me.
14 Q What was his comment with respect to that 15 section, as best you can recall?
16 In order to answer the question, I will Q
17 first~have to tell you that I had had previous 18 discussions with Mr. Dieckamp about some of the 19 material which ended up being discussed in the report.
20 In those discussions we had talked about my and I 21 believe the task force's and I believe his perception, 9 22 that one of the very significant factors associated 23 with the operator response was the particular 24 location of the leak, n amely , in the steam space in the 25 pres'surizer, and the' fact that that gave a set of
_..__-__l-------__-__-_._- - - - - . - - . , - - , - - - -
1 Kocton 639 symptoms which were different from what the operators
() 2 3 had expected to occur in the event of a loss of 4 coolant accident. I don't remember the exact words 5 he used, but his principal comment that I remember gg 6 on this section was that he did not feel that the 7 way the section was written made that clear. He 8 asked me whether the task force had concluded that 9 that was not important, and I am sure that I answered 10 that we believe that it was important and that we had 11 intended for that to come out in what was written here.
12 He commented then, in the way the f'/
s_
) 13 information was presen'ted here, that that did not 14 come across very clear to him.
15 Q Do you remember any other comments that 16 Mr. Dieckamp had with respect to the report?
17 A I do not remember other specific comments 18 sitting here, but I do remember that the nature of 19 his comments was to point to a particular sentence or 20 paragraph and to say that he read it to mean such-and-21 such, and then to ask, was that what the task force 9 22 intended.
23 Q Did he make any suggestions that portions !
p- 24 of the task force report be rewritten?
(
'^'
25 A In cases where he asked a question like
= -- _-.
1 Kooton 640 h 2 "did the task force mean such-and-such," and I
[O 3 answered no, then he would suggest that we clarify 4 the wording so it accurately communicated what we 5 were trying to say.
6 Q Were there any matters that you can now 7 recall as to which Mr. Dieckamp disagreed with the 8 conclusions or findings of the task force as reported 9 in Exhibit 3517 10 A As I indicated earlier, there were cases 11 where Mr. Dieckamp interpreted the words that 12 were on the paper in a fashion which upon discussion 13 became clear was different from what the task force 14 had intended the words to mean. But his questions 15 were, to the best of my memory, always in the 16 direction of "is this what the task force was trying 17 to say," and if not, I would agree with him if he 18 read it in a fashion that the task force intended, 19 it needed to be reworded so it was clearer.
20 Q Is it your testimony that to the best of 21 your recollection, all of Mr. Dieckamp's comments 22 were simply directed towards clarification of the 23 task force's intent? !
< 24 A I believe in general that there were O 25 other types of discussions that went on which were
, e .- ~ , - ..m- .- -
Konton 043 1
2 directed toward, in some cases, what was the basis 3 for information that was in the summary report, and 4 other cases was directed toward, to the best of my 5 recollection, additional work that the task force g
6 might do before it got to the final report. But 7 it is my testimony that to the best of my recollection, 8 ever time that Mr. Dieckamp made a comment on this 9 or, for that matter, later versions of that report, 10 that his instructions to me were that the report 11 should not put anything in or take anything out 12 or revise it unless it was consi. stent with the best .
(} 13 belief of the task force.
Did Mr. Dieckamp suggest that this report 14 Q 15 be revised further?
16 MR. GLASSMAN: Asked and ans wered.
17 MR. WISE: He suggested a number of 18 instances where there were differences'in 19 interpretation of the language. My question 20 now is directed specifically at whether Mr.
21 Dieckamp in conclusion or as an overall O 22 directive based upon those discussions asked i
23 that this report be redone.
I 24 A My memory is not very specific on that s 25 point, but to the best of my recolle.ction, it is
l 1 Konton 642 I
, 2 that I suggested that it be revised.
3 Q Did he agree with that?
l 4 A I don't remember any specific comment g 5 he might have made on that point.
6 Q Did you discuss Mr. Dieckamp's comments
.i
~
7 with Mr. Arnold?
i 8 A I remember at some point in time telling 9 Mr. Arnold that I had discussed the report with Mr.
! 10 Dieckamp, but I don't remember whether it stopped 11 there or whether I might have discussed some of Mr.
12 Dieckamp's comments. I don't have any memory that
, 13 I ever went through any detailed discussion of Mr.
14 Dieckamp's comments with Mr. Arnold.
15 g' Was a revision of Exhibit 351 actually 16 prepared?
17 MR. GLASSMAN: You are talking about the
'IO attachment to 3517 19 MR. WISE: Yes.
20 A My recollection was that.there was a 21- revision prepared.
22 Q Who did that one? ,
23 A My recollection is that I somewhat 24 restructured Section II-B to try to clarify what the 25 task force -- I had thought the task force wanted
__ _ _ . , _ . . ~ _ _ . . _ -- _..._, _ - _ , . . _ . _ _ . -
1 Konton 643 to say and had at least not come across to Mr.
( ') 2 Dieckamp as effectively as we had hoped. I convened 3
4 a meeting of the task force and my memory is that we 5 went through the report and jointly discussed Mr.
6 Dieckamp's comments and any others that might have 7
been there at that time, including some of my own when 8 I read the report. And we jointly tried in all 9
cases to decide on a wording which accurately 10 reflected what the task force was trying to communicate 11 and which the members of the task force believed 12 was accurate.
O .
13 (continued on the following page) 14 15 16
'17 18 19 20 1 21 h 22 23 24
[/3 s.
25 i
l
_. -- -. - -- ._ - ~ . . . - . .
J
. hd1 1 Koston 644 Did you have any documents or writings for
( 2 Q 3 the task force at the time you convened that meeting 4 which embodied Mr. Dieckamp's comments?
l 5 A The best of my recollection is that in g
6 preparation for the meeting, I took the version of the 7 report which is attached to the memo labeled B&W Exhibit 8 351 and attempted to improve the wording in those areas 9 where the discussion that I had had with Mr. Dieckamp 10 led me to believe that he read what was written as 11 conveying something different from what I believed that
) 12 the task force had intended to say. And I don't remember
.[
13 whether I got it retyped or whether I simply had a 14 marked-up version of the report, but in any event, I did 15 it in such a fashion that I could call out to the task i 16 force membars on a word-by-word basis what were the 17 changes that I thought were an improvement, and we 18 discussed those, and in most cases literally on a
. 19 word-by-word basis.
20 Q was another draft prepared as a result of 21 that task force meeting?
O 22 Mr. Keaten, perhaps that seems to be not 23 eliciting a quick response. I can move things along by 24 ' showing you what I would like to have marked as B&W O 25 Exhibit 352, which is another copy of the task force
.,~ _ _ _ _ _, . . _ _ _ _
2 1 Keaton 645 2 report labeled "GPU Accident Review Task Force Interim 3 Summary Report" dated November 28, 1979. This also 4 contains a list of the task force members with 5 signatures next to each of their names. At the top of 6 the list is R. W. Keaten.
7 (Another copy of the task force report 8 labeled "GPU Accident Review Task Force Interim 9 Summary Report" dated November 28, 1979 was marked 10 B&W Exhibit 352 for identification as of this 11 date.)
12 BY MR. WISE:
13 Q Mr. Keaten, do you recognize B&W Exhibit 14 352?
15 A With the same reservations that I have 16 stated earlier, I believe that I do.
17 Q Do you recognize your signature there on the 18 front page?
19 A Yes, I do.
20 Q Does this help refresh your recollection as 21 to whether another draft of the interim summary report
~
22 was prepared after the draft which is part of B&W 23 Exhibit 351, dated October 29, 19797 24 A At the time you asked the earlier question, 25 I had no difficulty in remembering this particular
3 1 Konton 646 1
2 draft.
3_ Q You are referring to which one now?
4 A The.one which is now labeled B&W Exhibit 5 352. My puzzlement was whether there was another draft I
6 that was intermediate between B&W Exhibit 351 and B&W 7 Exhibit 352.
8 Q Are you able to recall whether there was or 9 wasn't?
10 A I do not.
11 Q In any event, eventually there came to_be 12 prepared B&W Exhibit 352, which is yet another revision 13 to the interim summary report.-
(
14 A That's correct.
i 15 Q Was Exhibit 352 the final version of the 16 interim summary report that you can recall?
17 A' To the best of my recollection, it was.
18 Q Did you receive any further comments from 19 Mr. Dieckamp with respect to this version?
20 A I recall a' general comment from Mr. Dieckamp 21 that he felt that the discussion was clearer with 1
22 respect to some of the items.
23 Q Aside from wording changes and restructuring 24 the format of the report, do you recall any' specific L'
25 -investigative work that had been done by the task force
4 1
.Kentan 647
() 2 between October 29, 1979 and November 28, 19797 3 A It is very difficult for me to remember 4 specific dates, but the investigation was continuing 5 during that period and past.that period in several of 6< the areas that were covered by the report. In fact, to 7 the best of my recollection, there are statements in, I 8 believe, both of these versions of the report and in 9 some areas that investigations were continuing. We 10 didn't do that in every area. In some areas'it was 11 true.
12 Q By October 29, 1979, isn't it true that with
~
13 the exception of Mr. Mehler, M-a-h-1-e-r, the task force
-(
14 had completed its interviews of operating personnel?
15 If it would help you, you may wish to refer 16 to B&W Exhibit 351, which is the October 29, 1979 draft.
17 The third page of that exhibit has a list of investigatior 18 participants. At the bottom of the page is a list of 19 plant staff discussion participants a number of names 20 are listed there.
21 Can you now recall-whether, in fact, at the h time this was written, those people had been interviewed?
22 23 A I believe that it is true that at the time 24 B&W Exhibit 351 was issued, that the people shown there <l l 25 had been interviewed at least once. However, some of
Kosten 648 5 1
() 2 those people were interviewed more than once, and I 3
don't remember whether all of the interviews with them were finished prior to that time or not.
4 I I
5 Q Do you remember having more than one g ;
. 6 interview with Mr. Logan?
7 A I only recall one interview with Mr. Logan.
8 Q Do you recall more than one with Mr. Kunder?
- g. A* I'm not sure whether there was one or more.
Q Were all of your interviews with plant 10 11 participants done on tape?
12 A No.
Did you have any interviews with Mr. Kunder
() 13 Q that were not taped, that you can recall?
14 15 A I do not remember.
Did you have any interviews with Mr. Zewe 16 Q 17 that were not taped?
18 A To the best of my recollection, and I admit 19 this is foggy, I had at least some discussions with Mr.
20 Zewe which were.not taped.
Q When did.those take place?
21 O 22 A I am trying to remember the specifics. My . ;
I 13: recollection'is that we had. interviews in which Bill
[
i
.24 Zewe participated, which were held in a conference room.
l 25 And.at least the'first ones of those were taped.
l
[
L
__ . _ . _ . - . . . _ _ _ . ,_ __i
i Koaton 649
/1 1 ,q ,
I have a vague recolle tion of having
( 2 3 discussions with Mr. Zewe on specific aspects relating
, 4 to the investigation that were not a formal interview qg 5 ,per se. It was simply me talking to him, I believe 6 in person, to ask him about some specific thing, and 7 those would not have been taped.
8 Q My question was whether you could recall t
9 the time frame of those discussions. Did they continue 10 for some period of' time or were they limited?
11 A My recollection is that they did continue
, \
i 12 for some period of time, although as I have said earlier, 13 I really can't remember specific dates. I believe that
( ,
14 it is also true that other persons who were 15 partici;pating in the task force investig'ations had 16 similar types of discussions, but I don't remember 17 withwhom and I don't remember in what time fram'e.
i 18 Q Did the task force keep any record ofsthese 19 non-taped discussions? ?-
N 20, ,' A The task force made no attempt to keep a i
1
~21 , complete file of documents.and notes and so forth, but ,
- % \
l
' 22.. rather relied primarily upon the developing understanding l 23 that the' task force members were getting as to what l
s ,
24 were thejsignificant factors. 'T ' '
g
- ~,
' ~
37 t.
- \ 's w.
2O( } ,
In some cases there may have,been notes.
l l ~% N,
! 1
,,, ,. . . . . . . -. - - . --.?' ,
.s---. ,, , ,
1 Keaten 650
() 2 In my own personal case, I don't recall that I made any 3
particular attempt to keep careful notes.
4 Q Did you have more than one discussion with Mr. Sheimann?
gg 5 6 A I frankly don't recall.
MR. GLASSMAN: Off the record, 7
8 (Discussion off the record.)
9 Q Mr. Keaten, perhaps we can shortcut this 10 somewhat. During the last session of your deposition, 11 I believe we marked as B&W 346 a typed transcript of 12 the recorded interview that you had with several of the
() 13 operators. I believe Mr. Zewe was present, Mr. Faust 14 an'd Mr. Frederick:
15 Let me ask you, you do recall having 16 that interview session with those individuals as 17 reflected in B&W 3467 18 A Yes, I do.
19 Q I believe during your earlier testimony, ;
l 20 you were uncertain as to the date on which those ,
I 21 conversations were held. Without burdening the record O 22 now, we have other indications that they were held in 23 late August 1979. Does that help in any way refresh 7, 24- your recollection as to whether that is approximately l
- 25 the right time period for the interview which is l
- .- ._ ~ - . . - - .
Konton 651 1
l
() 2 reflected in B&W 346?
3 A My recollection is that that would be very l 4 aPProximately about the right time frame.
1 5 Q Is it your recollection as well that Mr.
ggg
)
6 Sheimann appeared, I believe it was the next day, and !
7 joined the discussion?
8 A I have a vague memory that that is correct.
9 Q Regarding that conversation with Messrs.
10 Zewe, Faust, Frederick,and I believe the following day 11 Mr. Sheimann, can you recall any other interviews, 12 other than- that one, of those individuals?
j
() 13 I know you have testified about some 14 informal contracts with Mr Zewe and now I am asking 15 if there is anything else that you-can recall.
16 A I remember the discussions that we had with-17 this group of individuals. I further-remember 18 discussions that the task force had with at least some 19 of these people talking to them individually rather l
20 than as a group.
21 I frankly don't remember whether we had 22 another formal discussion with the group as a whole.
I i
23 (Continued on following page) :
94 t
! 25
1 Konton 652
) 2 Q Do you remember e. bout how long after 3 the late August interviews, part of which are 4 reflected in B&W Exhibit 346, the individual 5 interviews that you just referred to were held?
ggg 6 I don't want this to be a memory test. I will tell 7 you that we do have tapes that have been provided 8 by counsel for GPU of these interviews. There was 9 another set of interviews, as indicated by the tape, 10 sometime in September and'some in October.
11 Does that help refresh your recollection 12 as to when the discussions you are referring to I took place?
D) 13 14 A It is consistent with my memory that 15 there were discussions going on in the September and 16 October time frame. The problem I am having is 17 simply that we talked to a lot of people. In some 18 cases they were formal and in some cases informal 19 discussions and in some cases most of the group of 20 the task force and its sponsers were there and in other 21 cases much smaller groups. In other cases we went O 22 back to talk to them again after talking to them the 23 first time. We did so much of that.
7- 24 The one easier to remember is the first
() 25 one, that is the one you asked me initially. After i
l I. .
1 K3aten 653
( 2 that, who we talked to when is j ust beyond my present 3 powers.
4 Q Perhaps later in this deposition we will gg 5 go through some of the transcripts and simply mark 6 them for identification so we will have the reccrd 7 complete on that.
8 What I am trying to zero in on is that 9 the work of the task force had been completed by 10 the time that the interim summary report, in 11 particular Exhibit 351 which is dated October 29, 12 1979, was distributed to Mr. Dieckamp and to Mr.
13 Arnold.
(
14 Let me put the question to you this way, 15 given that you have a hazy recollection with respect 16 to exactly when various interviews took place, can 17 you specifically recall that you did in fact interview 18 any operator other than Mr. Mehler following October 29, 19 19797 20 A I just plain don't remember.
21 Q Looking at B&W Exhibit 352, which is O 22 the final version of the interim summary report, 23 dated November 28, 1979, to whom was that report sent,
. 24 as best you can recall?
25 A I believe that I recall sending it to-
1 Keaten 654
( 2 Mr. Dieckamp, Mr. Arnold and to members of the task 3 force. I do not recall whether it received any other 4 distribution than that, ggg 5 Q How did you determine who was on the 6 distribution list?
7 A I don't remember.
8 Q Do you know whether Mr. Arnold or 9 Mr. Dieckamp distributed it to anyone else?
10 A I do not know.
11 Q Did a copy of it go to the NRC?
12 A To the best of my knowledge, it did not.
() 13 Q Was the interim summary report made 14 public, to the best of your knowledge?
15 MR. GLASSMAN: What do you mean by 16 "public"?
17 MR. WISE: Was it released to the ,public 18 at large.
.19 A I do not know of any such release.
20 Q Did you have any discussions with 21 Mr. Arnold or Mr. Dieckamp concerning the appropriate 9 22 recipients of the interim summary report?
23 A I don't remember. .
.O 24 Q Did you ever ask anybody who it should be-G 25 sent to? You people put in a fair amount of work f
1 Kocten 655 b
g 2 preparing this document.
3 MR. GLASSMAN: Objection to any 4 implications regarding the diligence of g 5 the witness in making some decision as to 6 distribution. It is totally unfounded here.
~
7 MR. WISE: Just so the record will have it 8 without the comment.
9 Q Did you ask anyone to whom this should 10 be sent?
11 A I still just don't remember. Let me 12 repeat what I said earlier, that my best recobection Q
\s 13 is that the idea of an interim report was mine. To 14 the best I can recall today, my intent in preparing 15 an interim report was to give the people responsible 16 for the task force's formation and activities an 17 opportunity to redirect us if we were not working 18 on the things that they had intended when they. formed 19 the task force. And for that reason, my recollection 20 is that the intended audience for.the interim report 21 was in fact Mr. Dieckamp and'Mr. Arnold.
O 22 Q Had some doubt arisen in your mind during 23 this time period, October and November 1979, as to 24 whether the task force was carrying out the charter O 25 that Mr. Arnold had established and which you had
. . ~ .
l l 656
-1 Konton i
I
[ 2 participated in the drafting of?
3 Let me separate that.
4 I understood your earlier testimony in 5 this deposition that you'had received a charter ggg 6 from Mr. Arnold. I believe we referred to that
- 7 and I believe it has been included in each of the 8 drafts of the interim summary report.
9 Do yoa recall that charter?
10 A Yes, I do.
11 Q It is also my recollection that you 12 participated in drafting that cht.rter for Mr. Arnold?
3
( 13 A I'believe what I testified to or at least 14 what my current recollection is that I participated 15 to the extent of doing some minor editorial type 16 revisions to the version that I received from Mr.
j 17 Arnold.
18 Q Which were eventually incorporated into
, 19 the final draft?
20 A I believe that's correct.
21 Q Now my question is, given that background,
, 22 had some doubt arisen in your mind by october and 23 November of 1979 as to whether the task force was 1
24 in fact carrying out that charter?
25 A I do not recall that there was any specific i
-, ,6 .~n_, .. , , -- . . . , . . - , - , - . , , - ,.v-. , - , , - . .
i l
1 Keaten 658
() 2 perhaps management, as you have used that term, 3 might decide after it saw what the task force was 4 doing, that it did not want the task force to go ggg 5 any further?
6 A I don't remember any such expression.
t a
7 Q When you used the term in one of your 8 answers, " change of direction" or whether you were 9 going in the right direction, what other direction 10 did you have in mind than the one you were going in?
11 A As I said earlier, I don't remember any i
j 12 discussions of alternative directions, but simply
( 13 a discussion that this would provide Mr. Dieckamp 14 and Mr. Arnold an opportunity to review what the 15 task force had done so far.
4 16 MR. WISE: Let's take a break.
I 17 (Whereupon, a recess was taken.)
18 (Continued on the following page.)
19 20 21 0 22 23 94
~
- O 25
. - . _ . . = - . .
1 Kaaten 657 e
2 doubt that had been introduced or that had arisen as to whether we were following the charter. I do 3
4 have a recollection of discussions at at least one 5 task force meeting along the line that preparing qg) 6 an interim report would be a useful cross-check 7 as to whether the detailed activities of the task 8 force are what the management had had in mind.
9 Q Did anybody express the view that 5
10 management may have had something else in mind 11 besides what you were doing?
12 A I don't recall that anyone suggested an
(
s.
13 . alternate that we should be doing or not doing but
{ 14 as I said, that I do recollect a discussion that this 15 was a, or could be a useful opportunity for management 16 to give the task force any revised or new direction i 17 regarding things that we should be doing.
1 18 Q By " management," you mean'Mr. Dieckamp t
19 and Mr. Arnold?
i 20 A That's correct.
21 And the reason for that was that during 22 the period of the activities associated with the 23 task force it was those two individuals that I 24 periodically discussed the task force activities with.
25 Q Did anybody ever express the concern that e
, - . . ..e..- ..w, r- e ser +--r ,tw-,--- --vr-,,-----m~ w,-,,-*-t a- --wv --w-r- *-----+--r ~,- 7
K/1 1 Koaten 659 2 Q Mr. Keaten, I am trying to understand the Purpose behind the interim summary report.
3 4
Let me ask you this: Did the task force as a result of your submitting the interim summary g 5 6 report change its direction in any respect?
7 A The.re' were no substantial changes in 3 direction, but I believe I have a general recollection o f-9 receiving suggestions from Mr. Dieckamp, and I believe 10 at some state from Mr. Arnold, that they would like us-11 to look a little bit more deeply into something that we 12 had found.
13 Q Do you recall receiving any writings from f-] '
D 14 either Mr. Arnold or Mr. Dieckamp with respect to areas 15 that they wanted you to look more.. deeply ,into?
16 A No, I do not.
17 Q Before the submission of the October 29, 18 1979 draft, which has been ma'rked B&W Exhibit 351, did 19 you have any concern that the report might be too 20 critical of Met Ed or GPU Service, and for that reason 21 might not be desired by management --
that is,Mr.
O 92 Arnold and Mr. Dieckamp?
l 23 A As we discussed earli'er, I understood, and 24 I believe that the task force understood, that the 25 task force was not intended to try to establish blame E _ .- - . . - - . . _ . . -
4 Keaten 660 1
7 for the accident, but simply to look into the items that we had been asked to investigate by Mr. Arnold's 3
memo and to report back as clearly and as accurately
- 4 as we could do what we found.
5 D I think that was my belief at the beginning 6
of the task force investigation and it continued to be 7
my belief until the end of it.
g Q Do I take it from your answer that you had no such concern?
A I think the task force was concerned to try to make its report factual and clear and accurate and to,present it in su'ch a fashion that it communicated the task force conclusions as a result of its findings, and that is what we tried to do.
15 Q I derstand that. I understarid that that 6
is what the task force was trying to do.
My question is really a different one, Mr.
gg Keaten. I am not so much concerned at this point with 9
the fact that the task force was trying to do that.
l I want to know whether you, in fact, had a concern before the October 297 1979 interim summary report was prepared and distributed that the results that g
l the task force was coming up with were in fact too 24 l
Critical of the Company, and that they might.therefore l
,. , . , , . - - , - .._y , . , , -
3 E 1 Konten 661 not be desired or a report might not therefore be
( ) 2 3
desired by management; namely, Mr. Arnold and Mr.
4 Dieckamp.
5 A That is a complicated question. In the first ggg 6 place, when the task force found something that it 7 disagree.d with or something that it thought might be 8 improved, the task force did not concern itself with 9 whether that was a problem: associated with Met Ed or 10 with somebody else. That wasn't part of our charter 11 and we didn't worry about it.
12 We had been specifically asked to prepare a
() 13 report. I don't recall ever having any concern that 14 as a result of our findings,that that direction would i
15 change.
16 Q You are doing an excellent job of evading i 17 my question.
18 MR. GLASSMAN: I object to the implication 19 here. You asked the question twelve different i
20 ways. That is not evasion; he is being as
, 21 cooperative as he can.
22 You might note until counsel's comment,
' 23 I have not made the slighest objection.
,, 24 MR. WISE: He has answered every question
, 25 but the one I have asked, which is whether he
,t---- -, , , -. ,.--.yr-- m --
- - - - , - - , - , - - - - - - - ~ , . . - - + , . - - -
I 662 !
i Keaten
/ i harbored any concern that the results of the 2
()
task force might not be --
strike that. I 3
think perhaps the record is obvious at this 4
Point.
(g 5 MR. GLASSMAN: The record is obvious that 6
7 the witness has tried to answer both clear and 8
unclear questions as best he could.
I bject to any implications that counsel 9
seeks to leave on the record by some statement 10 i
11 of his own.
i j 12 MR. WISE: I have asked repeatedly whether 13 there was a concern about the conclusions and
}
the results of the task force work. I have 14
- 15 received a series of answers as to what the task 16 force was trying to do, but no answer as to 17 whether there was er was not such a concern.
18 Instead, I have been told repeatedly what the charter was. That is the reason for my comment.
! 19 20 In any event --
21 MR. GLASSMAN: I think the record will reflect that the witness answered not only 22 l
23 in the fashion the you have described, but 24 also answered as to what the particular concerns 25 of the task force were, and in fact used those 1
1 Kenton 663 2 precise words. I think the record reflects 3
whatever it reflects.
4 MR. WISE: Yes, it does, pretty clearly.
Let me have marked as B&W Exhibit 353 a g 5 6 memorandum dated December 3, 1979, which purports l l
7 to have been prepared by Mr. Keaten with a carbon g copy to Mr. Arnold. The subject is TMI-2 g Accident Review Task Force - Open Items List.
10 (Memorandum dated December 3, 1979, 11 Prepared by Mr. Keaten and entitled TMI-2 12 Accident Review Task Force - Open Items List, 13 marked B&W Exh,1 bit 353 for identification, as l
14 of this date.)
15 (continued on following page)
{
16 17 18 19 20 21 0 22 23 24 O 25 t
664 jlk 1 Ksatsn 2 Q Mr. Keaten, is B &W Exhibit 353 a 3 memorandum which you wrote on or about th e date 4 that it shows?
5 MR. GLASSMAN : Let's note again for ggg
. 6 the re cord that there is some handwriting 7 on the report.
8 MR. WISE: Absent whatever handwriting 9 might appear and then we will come back and 10 discuss the handwriting specifically.
11 A Yes, I believe that it is.
12 Q As your counsel has noted,at several 13 points on the document there is some handwriting, 14 particularly the first, second, and I believe there 15 is also some througnout.
16 Do you recognize that handwriting?
17 A I cannot be sure whose it is.
18 Might it be yours?
Q 19 A I don't believe so.
4 20 Q Did your secretary keep notes of this 21 type on this memorandum?
O 22 A Under certain conditions, she might 23 keep that type of notes, yes.
24 Q Do you know whether or not that is her
' O- 25 h an dw riting?
i
.,.,.__y , , - - - _ , - , . , , , . ~ . _ , _ _ _ _ , . . g y_ , . - - , , . . . . , , . __m_,
- m. - . _ . -
665 1 Keaton I am not sure, b ut it might be .
) 2 A 3 Q This memorandum is dated;.De cembe r 3, 4 1979. The final version of the inte rim s ummary 5 report is . dated Novembe r 28, 1979. That is g
6 B&W Exhibit 352.
7 Do you recall whether this memorandum 8 was written in response to any comments or 9 directions that you may have received from 10 management, namely Mr. Arnold and Mr. . Die ck amp ,
11 on the interim s ummary report?
12 A In general my recollection is th at 13 the memo was prepared by me based upon reviewing 14 the interim summary report dated November 28, 1979 15 and identifying areas whe re it w as either clear 16 from the report itself or where it was my opinion 17 based upon the work that had gone into preparing 18 the report, that there was additional work that 19 needed to be done to complete the task force 20 inves tig ation. I don't re c all whe th er any of 21 those items were based upon comments by Mr.
O 22 Dieckamp or Mr. Arnold.
23 Q Why did you send a copy of this 24 I memorandum to Mr. Arnold?
l 25 A I believe it was my practice to t ry l-
3 Konton 666 1
D 2 to send Mr. Arnold a copy of most, if not all, of
()
3 the things that I prepared relating to the task 4 force. I don't recall that the re w as any specific 5 reason why I s ent him this particular one.
g ,
6 Q Did you receive any comments from Mr.
7 Arnold with respect to this memorandum?
8 A I don't remembe r any.
9 Q Do you remember whether you had any 10 discussions with him conce rning it?
11 A I don't recollect any such discussion.
12 Q Following each of the items listed in
(} 13 Exhibit 353 for further action, a name has been 14 typed in. Do you know who made those assignments?
15 A Yes.
16 Q Was it you?
17 A Yes , it was .
18 Q Did you communicate these assignments 19 to the people listed i'n the exhibit?
20 A You me an other than by s ending the 21 memo?
O 22 Q Did you s end copies of this memo to anyone 23 be side s Mr. Arnold?
24 A Although the memo does not indicate,I sent g
V 25 it to the members of the task force and to others
4 1 Kocten 667
(). 2 whose names appear- here.
3 Q Do you recall if there was any other 4 communication with those individuals as to what 5 their assignments were?
6 A My recollection is that many of the 7 items that we re in this memo had been discussed at 8 one or more meetings of the task force and that I 9 was simply documenting what people had already 10 agreed to do. In other cases, I believe there we re 11 s ome r new. items .
12 Q Was this memo intended to be a compilation 13 of the various items that you believed needed to be ,
14 completed *before the report could be put into final 15 form?
16 A It was intended to be a compilation of 17 those things that came readily to my mind as a 18 result of a f airly quick review of this particular
'19 version of the interim summary report. As is noted i 2o h in the irtroductory paragraph in this memo, I h ad 21 no confidence that that was a complete list of 9 22 things that needed to be done.
23 Q Did you ever prepare a follow-up memo on 24 this, including additional items?
O
25 A I do not recall any follow-up memo.
5 1 Kocton 668
) 2 Q The exhibit contains a list of 36 items.
3 Did you try and include those items which you l
4 believed were the most important in Exhibit 3537 5 A I tried to include, to the best of my 6 recollection, all of the items that occurred to me 7 when I reviewed the interim summary report. But I 8 did not take any spe cial e ffort other than reviewing 9 .that report to make s u re th at the list was complete.
10 Did you have any sys tem or procedure Q
11 for keeping track of the progress of the work on 12 ~
each of the 36 items listed in the memo?.
- 13 A Not any spe cific formal sys tem, no.
14 You didn't keep a log or anything of Q
15 that nature that would allow you to know in essence 16 when one of the items had been closed out or 17 completed?
18 A I did not keep a log,-to the best of 19 my recollection.
l 20 was there ever a time when you sat down Q
21 and went through this list in order to determine how g 22 many of the items had been completed?
i
)
23 In other words, did you ever go back 24 at some later time and look at this memo-and say, l
O 25 "Here are 36 items on he re . How many are we finished
! e g
o f.
l
K 1 Konton 669 T'h 2 with and how many still remain open?
O A I believe that I did use this memo as a 3
4 part of the process of preparing the final version of the report.
g 5 6 MR. WISE: Let me mark as B&W Exhibit 354 7
a copy of the report which is now titled g "GPU Accident Review Task Force, Final Summary 9 Report." This particular copy is dated March 24, 10 1980.
11 (Multipage document entitled "GPU Accident 12 Review Task Force, Final Summary Report," dated March 24, 1980, marked B&W Exhibit 354 for j }
13 14 identification, as of this date.)
15 Q Mr. Keaten, as I am sure you can recognize, 16 we have to work with the copies that we have that were 17 provided to us during the file search. I note that this 18 copy contains some handwritten notations that you may 19 not recognize.
20 Putting aside those handwritten notations 21 and markings, can you identify B&W Exhibit 354 as the
, 22 March draft of the final summary report of your task 23 force?
24 ! A Consistent with the same kind of limitations l (~h
~' 25 tnat we discussed earlier, this does appear to be a i
1 Kocton 670 fD
\.s' 2 draft of the final summary report.
g Do you recall after the final version of 3
4 the interim summary report was prepared and distributed 5
in late November 1979, that is B&W Exhibit 352, whether ggg 6 or not it was approximately the end of March 1980 7
before the first version of the final summary report was g prepared?
g A Again, I can't recall the specific dates.
10 Generally, that is consistent with my recollection of 11 the kind of time interval that was involved.
12 g To whom was the March draft distributed, as
() , 13 best you recall? Is that something kept internal with 14 the task force or did it go out to management as well?
15 A My recollection is that this draft was 16 distributed only to the people who were participating in 17 the task force activities.
18 Q I note on the cover page that the list of 19 task force members had shrunk to four. Was there any j 20 reason for that?
21 A Yes, there was.
22 Q What was the reason?
23 A The reason was that the fifth member of the 24 original group, Mr. Ron Williams, had left GPU at that 25 time.
Keaton 671 1
Q Do you recall why a draft was prepared in
'} 2 late March 1980 of the final summary report?
3 A I believe that this was my attempt to 4
arrive at a final version of the final report.
5 6 Q Did you have any time schedule in mind as to when the task force might get the final version out?
7 g A I don't remember that specifically in late 9
March, that I had a particular date in mind. But I do remember a general concern on my part that the 10 11 investigation had lasted considerably longer than we 12 had originally intended.
13 Q Was there any investigative work still going 14 on in March 1980?
15 A Yes, there was.
16 Q What do you recall was still proceeding by.
17 as late as March 1980, in general?
18 A Again, I have a very hard time distinguishing i
19 between March and February.
Q It's all right. In that general time frame.
f 20 21 A In that general time frame, I do recall that l 22 there was still work in progress directed toward the final sequence of events of the accident. There was 23 34 work which had continued associated with the start of
! O' ' . 25 the transient, and some of the items which had been
i 1
Konten 672 found in the secondary side of the plant. There was 2
w rk still underway in defining the pathways that led 3
to the release of radioactive material. The task 4
5 force had not completed its discussions of the state of i 6 knowledge of the operators with respect to the degree 1
7 of core damage as they perceived it on March the 28th.
8 I don't remember when the final work was done with 9 respect to the relationship between the surveillance 10 procedure on the emergency feedwater system and the 11 tech spec requirements with respect to having that 12 system out of service -- I don't remember whether it was 13 as late as this or not. It might have been.
(
14 There was work relative to the PORV. Those 15 are the ones that I recall right at the moment. I am 16 not sure that is a complete list.
17 Q Was there any further work being done on
. 18 the ra tionale for the control room operator response 19 during the first two hours of the accident?
20 A I believe that there was some effort 21 continuing in that area, although I don't recall the k specifics of it.
~22 23 MR. WISE: The record should reflect that l 24 the witnese, before answering the question,
, 25 referred to B&W Exhibit 353, which was his l
l L ,.- - , ---. . . .. - -
1 Keaten 673 2 December 3, 1979 list of open items.
Q Mr. Keaten,did you find any items in your 3
4 quick review of 353 directed towards the rationale for 5
operator response?
g 6 A I found some items which are relative to the 7 material that is discussed in that section of the r,eport.
g Q Which items?
9 A These are, for example, items 9, 10, 11, 12, 10 13, 14, 15, 16. Those are the ones I see.
11 Q Isn't it a fact that every one of the items 12 that you listed refers to the need to develop a 13 recommendation with respect to one subject or another?
~s 14 A Yes, I believe that in most or all of the 15 cases, that it was directed toward developing a 16 recommendation.
17 Q Isn't it a fact that the investigation 18 had been concluded as of December 3, 1979, and 19 certainly by February and March of 1980, into the 20 rationale for the control room operator response during 21 the first two or three hours of the accident?
22 MR. GLAS SMAN : I think that has been asked 23 and answered. He can try again.
l 24 A I think a great deal of the work had been l [\ ~
I 25 completed by that . time frame, but I can't sit here and
. Kosten 674 1
recall that as part of the recommendations that were
) 2 3
requested in the memo,that there might have been some 4
final, for example, discussions with the members of the 5
plant staff.
qgg 6 Q Did you request the other members of the task 7
force to give you comments on your March 1980 draft.,
8 B&W Exhibit 3547 A My recollection is that I did.
9 10 Q Was any time period set?
11 A My general practice in sending something out 12 for comments has been to request comments by a specific 4
I don't recall,what that time frame was in this
() 13 date.
case.
14 15 Q Do you recall whether in March 1980 you had 16 any time in mind for completion of the final version?
17 Were you thinking in terms of getting it out in matters 18 of weeks, months, years?
19 A certainly not years. I don't recall whether 20 I had a specific date in mind other than, as I said 21 earlier, a sense on my part that we should try to complete 9 22 it as quickly as we practically could.
23 Q Did you receive back comments from the l
o4
~
members of the task force?
- (~%
's_) 25 A .I believe generally I received some commentsJ l
y _ - - -
1 Keaten 675 I don't remember the specifics.
( 2_
Q Let me try it another way. After the March 3
4 1980 draft was prepared and circulated to the task force, what, as best you recall, happened next in getting this e .
5 6 report finalized and out? i 7 A I have a general vague recollection of 8 receiving some comments. To the b'est of my memory, I g incorpotated the comments and I frankly don't remember 10 whether we reconvened the task force as a group for the 11 purpose of the final review of the report, or whether I 12 did that by either circulating a revised draft or the
~
! 13 final version or whatever.
14 I remember the process finally terminated 15 by circulating the final version for signatures. I am 16 just foggy on what happened in between those times.
17 Q You prepared B&W Exhibit 354 in March 1980.
18 Do you recall how long it took to get a final version 19 out?
20 A- I don't recall the specifics but.I remember 21 'it took longer than I had thought that it might.
G 22 MR. WISE: Let me.have marked as B&W 23 Exhibit 355 a copy of yet another draft of the 24 final summary report. This one has a cover letter
\ 25- dated May 12, 1980, signed by Mr. Keaten,'it
1 Kacton 676 appears, addressed to the task force, subject is
'/^)
\~/
2 Final Report.
3 4
(Multipage document with cover letter dated 5
May 12, 1980, addressed to Task Force, "
Subject:
g 6
Final Report" marked B& W Exhibit 355 for 7
identification, as of this date.)
g BY MR. WISE:
g Q Mr. Keaten, let me ask you if B&W Exhibit 10 355, and particularly the letter dated May 12, 1980, it which is actually the second page of the exhibit, was 12 prepared by you?
A You are asking me about page 2 specifically?
(- 'N 13 V;
14 Q Yes. I will limit my question really to 15 the letter dated May 12, 1980, 16 A I believe that it was.
37 Q That letter reads "
Subject:
Final Report.
18 " Attached is the latest draft of the task 39 force final report. I have incorporated your comments 20 to the extent that I understood and agreed with them.
21 In some cases I feel further discussions is necessary lk 22 prior to resolving the comment.
I 23 "A meeting is scheduled in Parsippany on l
24 Friday, May 15, Room 202, starting at 10:30 a.m. to obtain 1 $ !
l 'x.s' 25 final resolution of the comments. I am hoping that O
1 r%
l l
KootGn 677, 1
'}"^ . 2 this can be the final meeting of the task force.
U. "Please review the draft report carefully j 3 ,
4 in preparation for the meeting."
You sent carbon. copies to Mr. Arnold, Mr.
5
'6 Clark and Mr. Wilson. T'he addressees are the -task 3
s
'7 force members,plus Mr. Broughton, Mr. Walsh and Mr.
'8 Wallace. .
9 First let me ask you, do you recall whether 10 in fact,there was a meeting held shortly after the 11 preparacion of thDs draft to discuss final comments?
i 12 A This memo does jog my memory a little bit.
13 I believe th'at I remember that we did have a meeting g N., .
() ,
\
in that particular room.
~
I cannot remember at the moment 14 i
t $ _15 s which of the addressees were able to make that meeting.
16 I would also like to note that kessrs.
[
4 < ,
17 Arnold, clark and Wilson were sent only the memos and 18 not the attached report.'
19 Q Do you recall that as of May 12, 1980, you s
20 were hoping that the task force could complete its work 21 within the week? ,
\
i i . ,
W 22 A I was hoping, to the best of my recollection l}
l'(2 .
today, that we would' be able to at that meeting agree
[1 4 i
- l. , , N
24 on the risolution of all of ,the comments,-prus any other ss s , -, ' -
7- 3 m k-) 25 changes that were suggested, and that we wo,uld'be able s ,
t i
s .'
s ..
s 1 KontGn 678
]'^')
\>
2 to finalize the wording of the task force report, and as 3
best as I can remember, I was hoping then that the only 4 other action that would be required would be simply to 5 circulate the final report for signature.
6 Q As of May 12, 1980, had the task force 7 completed its investigative work?
8 A As is indicated h this memo and is consistent 9 with my recollection, there were still --
there were 10 some comments that I had received that I felt merited 11 further discussion by the task force. And in an attempt 12 to really understand the comment and to act properly on it 13 and to the extent that that is part of the investigative
(^)N
(_
14 effort, thdt still remained to be done.
15 Q Aside from any comments that the task force 16 was going to discuss amongst its members, do you recall 17 whether, in fact, there was any further field work to be 18 done, if I can use the term field work to mean
'19 investigative work, other than discussing things amongst 20 yourself?
21 A There was field work which was continuing G 22 in this time frame and even later.
23 Q Mr. Keaten, how were you possibly going to 24 put in a final report of the task force if you believed i :
I k.)-
25 on May 12, 1980 that investigations were still
/
l
1 Konton 679 2 continuing.
3 A Because I had come to the conclusion that 4 there were at least some areas where it was not clear i
i 5 how long the investigation would have to continue in 6 order to be successful,or.in fact whether the 7 investigation would ever be successful or not.
8 In those areas, I recommend and I believe 4
9 the other members of the task force agreed with me that i
! 10 it was best for the task force to simply reflect in its 11 final report the current state of knowledge, and recognize i
12 that in some areas there was some residual uncertainty.
13 In fact, in some of those areas, activity i O- did continue subsequent to the completion of the task 14 I - 15 force final report.
, 16 Q Do you recall whether another draft of the i report was prepared as a result of the May 16th meeting, 17 l 18 if that is when it occurred?
19 A As I said earlier, I am a little fuzzy as to
- 20 how many drafts were prepared during this time frame, i
21 I simply don't recall whether the report that was i 22 prepared as a result of this meeting referred to in l
23 the memo ended up being the final version or not.
24 MR. WISE: Let me have marked as B&W
')
-/ 25 Exhibit 356, a GPU Accident Review Task Force,
Kooton 680
^
Final Summary Report, dated December 15, 1980.
3 (Multipage document entitled GPU Accident Review Task Force, Final Summary Report, dated December 15, 1980, marked B&W Exhibit 356 for identification, as of this date.)
BY MR. WISE:
7 Q Mr. Keaten, do you recognize B&W Exhibit 356 as the final version of the task force report?
I note on the front page, this copy bears your signature.
A That is correct.
13 Q Did you sign more than one version of the l 14 final summary report?
A I d t recall signing more than one 5
version. Based on a quick perusal, this would in fact g purport to be the final version.
18 Q There is a gap of seven months between the g May 12, 1980 draft, B&W Exhibit 355, and the final version, B&W Exhibit 356, which is dated December 15, 1980.
22 Was y r task force still trying to resolve g the open comments for those seven months?
MR. GLASSMAN: Which open comments are we 25
" * #* ***'"9
1 Konton 681 2 MR. WISE: The open comments referred to 3
in Mr. Keaten's letter dated'May 12, 1980, i
4 which I read into the record a moment ago.
5 A I will have to confess that I was surprised 6 when I saw the date on this final report. I had not 7
remembered that there had been that long of a gap. I g don't remember why it took so long.
9 Q Isn't it a fact, Mr. Keaten, that the final 10 report was circulated to a number of people in order to 11 allow them to make additional comments, particularly 1
12 management people such as Mr. Arnold and Mr. Dieckamp?
13 MR. GLASSMAN: May I have the question read 14 back?
15 (Record read.)
16 MR. WISE : As Mr. Glassman points out, the 17 question is vague because there were a number of 18 versions of the final report. Let me clarify.
19 Q Isn't it a fact, Mr. Keaten, that between 20 the Ma y 12, 1980 version of the final report and the 21 actual final version on December 15, 1980, the report 22 was circulated to management other than the task force ,
i members in order to obtain management's review and I 23 24 comments on the report before it was put out in final 25 form?
1 Konton 682 2 A My recollection, as I testified earlier, is i 3
extremely vague, but I believe that Mr. Dieckamp may 4
have reviewed the report before the final was issued, but 5 I am frankly not sure.
ggg 6 Q Maybe we can assist your recollection.
7 Who is Mr. Clark, P. R. Clark?
8 A Mr. Clark is the executive vice president 9 now of GPU Nuclear.
10 Q Have you ever met a Mr. Seltzer?
11 A Yes, I have.
12 Q Had you met him as of May 1980?
I don't remember when I first met him, but I
(} 13 A believe it was prior to May 1980.* -
14 15 Q Do you recall whether you distributed 16 copies of the May version of the final report, or any 17 subsequent versions of the final report, to Mr. Seltzer 18 for his review?
19 A I frankly dont r& call.
20 Q As I said, maybe we can help your 21 recollection.
22 MR. WISE: I would like to have marked as l
23 B&W Exhibit 357, a copy of a memorandum dated l 24 , September 2, 1980, signed by Mr. Keaten and f
25 addressed to Mr. Dieckamp, Mr. Arnold, Mr. Clark r- - we -
r - e- w
Konton 683
^p 2 and Mr. Wilson. The subject is the Accident V
Review Task Force Report.
(Memorandum dated September 2, 1980, from Mr. Keaten to Messrs. Dieckamp, Arnold, Clark and 5
O Wilson, "
Subject:
Accident Review Task Force 6
, Report" marked B&W Exhibit 357 for identification, as f is date.)
8 BY MR. WISE:
10 Q Mr. Keaten, is that your signature above g the typed version of your name on Exhibit 357?
A I believe that it is.
12 13 Q The memorandum reads, "At the request of 14 Mr. Clark, I have marked the task force report to indicate 15 where there are significant differences from the interim report. These areas are denoted by a line in the right-16 g hand margin.
18 "I hope this may assist you in your review 19 f this report."
90
~
Does this help refresh your recollection as to whether you sent copies of the task force report to h 22 management, particularly to Mr. Dieckamp and Mr. Arnold, 23 f r their review before it was put into a final version?
A Yes, I believe that it does help me and I r\
l V. 25 I believe now that I remember doing that.
Kcaten 684 1
t.
Q Also on this copy of the exhibit, there is 2
~~f'T s_/
4 a good deal of handwriting. Someone has put the initials 3
of RWK at the top of the page, and then drawn an arrow 4
down to a list of handwritten names. It appears to be i somewhe're in the order of fifteen to twenty names, 6 .
beginning with Mr. Kuhns -- do you see that --
then Dieckamp and Verrachi, Bartnoff, Arnold, Clark, R. F.
Wilson, G. K. Hovey, I believe the next name is i
H-u-k-i-1-1, Mr. Berbein, Mr. Conrad, Mr. Cherry, R. L.
I Long, Mr. -- I believe this is supposed to be Finrock I although it says Finfrock --
12
- ,A It's supposed to be Finfrock, i
Q JRT-Garb, Chairman,.who would that be?
14 A Mr. J. R. Thorpe.
I Q Mr. Tsagg?
i 16
} A I believe that is a shorthand notation 1 17-
, for Mr. Tsaggaris.
.[ Q The next name is R. Seltzer, and then Mr.
j 19 van Witbeck, and'then the initials RWK. Do you know whose handwriting that is? I 21 A I am a little puzzled because I am not llh sure it is all the same handwriting.
l Q Do you recognize any of it?
g
() A The part down toward the bottom,
_ - _.=_
Keaton 685 1
~ including the initials RWK, I believe may be the 2
handwriting of my secretar". I am not sure that the 3
first part of the list is. In fact, I rather think it 4
was not.
I Q Do you know whether you, at the time that 6
you wrote this memorandum, distributed copies, either 7
of this memorandum or the report which was attached, 8
J which we don't have here today, to the people that appear 9
in handwriting on this exhibit?
10 A To the best of my recollection, I did not.
11 Q Do you have any knowledge or information 12 as to the meaning of this handwritten list of individuals that appears on the face of B&W Exhibit 3577 14 A To the best of my recollection, that this 15 was a suggested distribution list for the final 16 sign-off report.
17 Q Do I understand your testimony to be that 18 the list that appears here does not relate to the 19 September 2, 1980 distribution that went with the 20 typewritten memo?
21 A To the best of my knowledge and recollection, that is correct.
l 23 -
l Q _
Do you recall whether you in fact sent a i 24 1
copy of the proposed task force final report to Mr.
Os. 25 i
1
1 Konton 686 2 Seltzer before the December 15, 1980 copy was finalized, 3
B&W Exhibit 3567 4 A I have no recollection of having done so.
g 5 Q Do you recall who directed your secretary 6 to write the list of names which you believe is in her 7 handwriting at the bottom of the page?
8 A No, I do not.
9 Q Do you recall whether you did that?
10 A I frankly don't specifically recall. It 11 may have been me.
12 MR. WISE: Let's take a break for lunch
^
13 at this point.
14 (Luncheon recess.)
15 00o 16 17 18 19
- 20 l
21 0 22 23 o4 l 25
hd1 1 687
) 2 AFT ERNOON S E S S I ON 3 (Time noted: 2:00 p.m.)
4 ROB E RT W. KEA TEN, resumed.
ggg 5 EXAMI' NATION (CONTINUED) 6 BY MR. WISE:
7 Q* Mr. Keaten, I would like you to go back, if 8 you would, to B&W Exhibit 353, which is your December 9 3, 1979 memo listing open items as of that time. I 10 have some questions directed at the memorandum. If you 11 would take a look at the second page of the memo and 12 take a look specifically at item 6, which reads:
13 " Develop a more specific recommendation for a suggestion 14 system which guarantees feedback of information to the 15 suggester."
16 Had your task force as of the time you 17 wrote this recognized that further recommendation was 18 needed for such a suggestion system?
19 A I believe that at that point in time, the 20 task force felt that such a suggestion system might have 21 certain desirable features. I don't know that the task O 22 force ever concluded that was needed in the absolute 23 sense.
l 24 Q Was your task force able to conclude one 25 way or the other whether such a suggestion system was in l
)
l 2 1 Konten 688 2 existence before the Three Mile Island accident?
)
3 A The task force, to the best of my recollectior ,
4 was informed that there was a formal suggestion system, 5 but the task force, they concluded that the nature o'f ggg 6 the formal system which existed didn't make it really 7 easy or make it automatic that the suggestor would 8 always get feedback on his suggestions.
9 Q What was the suggestion system as the task 10 force found it?
11 A I don't remember the specifics. I remember 12 being told that there was a formal suggestion system, and
N 13 I remember also being told that sometimes'it was used by 14 the operators and sometimes the operators would submit 15 suggestions in a more informal fashion.
16 The best of my memory associated with this 17 recommendation was that the task force felt that a 18 somewhat simplified system that gave a better guarantee 19 that the suggestor would have feedback might have 20 advantages.
21 Q Who told you about these things?
O 22 A They arose, to the best of my recollection,
- 23 during our discussions with members of the plant staff.
24 I don't remember specifically which individuals.
25 Q Would you look at item 7, which reads:
i l
3 1 Kenten 689
" Develop a recommendation which would result in the
( 2 3
plant superintendent or other management personnel 4 having an annual fund of resources which can be readily 5 applied to resolve small problems as they are detected."
ggg 6
You are listed as the individual responsible 7 for taking action on that item.
8 Do you recall whether the task force had 9 found that the plant superintendent had a fund of 10 resources available to resolve small problems before the 11 accident?
12 A To the best of my recollection, I believe 13 the task force was led to understand that items which
(
14 were funded from the capital budget had to be identified 15 as a specific item in the budget.
16 I believe, my recollection at least is, that 17 the task force felt that there would be advantages to 18 having a relatively small amount of funds set aside not 19 associated with any specific item, so that as small 20 items were identified during the course of the year that 21 the plant manager could simply elect to use those funds O 22 without having to go through a revision or a new issue 23 of the capital budget.
l 24 Q From whom did you gather this information?
25 A Again, my recollection is that it came out
4 1 Kenten 690 2 as part of our discussions with the plant staff and I 3 don't remember specifically which individual.
4 Q Do you remember whether Gary Miller suggested g 5 this?
6 A I don't remember specifically one way or 7 the other.
8 Q Do you recall whether the investigation g received any comments from Mr. Miller or others that the 10 lack of such a fund had hampered them in their ability 11 to solve small problems before the accident?
12 A I do not recall the specifics of the discussion on this matter with Mr. Miller or anybody
( 13 14 else. I simply recall that the task force came to the 15 conclusion that providing this type of fund would have 16 some benefits in the opinion of the task force.
17 Q Would you look at the next item, item 8, 18 which reads: " Develop a recommendation for how the
~
19 secondary side of the plant should be treated with i 20 respect to QA, periodic inspections, maintenance, etc.,
21 which will eliminate the discrepancy between the general O 22 status of the secondary and primary side of the plant."
23 The persons listed for action on'that are 24 Mr. Van Witbeck and Mr. Long.
O 25 What did you mean by the discrepancy between
- , . , +. - . , - - , - . ,- --
,w-
l l
5 1 Keaten I
. 691 2 the general status of the secondary and primary side of 3
the plant?
4 A To the best of my recollection, I was 5
referring to the types of items which were listed in ggg 6 the interim summary report that I was working from when 7
I prepared this, and those include items that we have 8 discussed earlier. In particular, the fact that there g were some changes that had been made to the plant where 10 the task force was not able to find documentation for 11 those changes.
12 Q I guess what I don't understand is what was 13 the discrepancy between the secondary side of the plant 14 on the one hand and the primary side of the plant on the 15 other.
16 How was there a discrepancy? Discrepancy of 17 what?
18 A one of the principal discrepancies that, to 19 the best of my recollection I was thinking of here, was 20 the discrepancy in the completeness of records.
21 The primary side of the plant, since it is largely 9 22 classified as safety grade, had regulations which 23 specified record keeping requirements and so forth. I 24 believe it was my feeling at this time that the secondary 25 side of the plant which largely was not classified as l
I 6 1 Konton 692 1
D(_)
2 safety grade, did not have the same level of care with 3 respect to things like keeping records.
4 Q In the beginning of your description of this gg) 5 item, you mention quality assurance, periodic inspections, 6 maintenance and so on.
7 A Yes.
8 Q I don't see any mention there of record 9 keeping.
10 Is it your testimony that you were only 11 concerned about record keeping as far as this discrepancy 12 was concerned?
() 13 A 'N o . I would not say I was exclusively 14 concerned about record keeping. I think I was also 15 referring to what appeared,at least to the task force, 16 to be a lag in carrying out some maintenance activities 17 that the task force felt could be advantageously 18 carried out more promptly and thoroughly. The reference 19 to "QA," which stands for quality assurance, I believe, 20 to the best of my recollection at least, probably was 21 specifically directed at the records aspects.
O 22 Q What was the source of the task force 23 information concerning the lag, as you put it, on the f- 24 secondary side with respect to maintenance?
l L_)S \
25 A I believe there was more than one source.
i l
7 1 Konton 693 I believe maintenance practices on the secondary side
( ?.
3 were discussed with members of the plant staff. They 4 were also addressed in some of the investigations that 5 were performed for the task force of people that were ggg 6 stationed at Three Mile Island.
7 Q Are you referring to Mr. Lanese's report?
8 A That is one, yes.
9 Q He wrote a report concerning the secondary 10 side, I believe?
11 A That's correct.
12 C Would you look at item 10. It says:
13 " Develop a recommendation which addresses some of the
(
14 specific deficiencies found in the training program such 15 as lack of training in taking the plant solid, lack of 4
16 training in natural circulation, and lack of training in 17 how to respond to unplanned events and/or multiple 18 casualty situations."
19 The individuals listed as responsible for 20 action on that item were yourself and Mr. Broughton.
21 Someone has written,in hand underneath the item, the O 22 word " cancel."
23 rirst, let me ask you: Do you know whether 24 this action item was, i.n fact, cancelled at some point?
O 25 A No, I don't know. I remember having some
8 1 Konten 694 2 discussions with others involved in the task force about 3 the recommendation related to training, but I don't 4 remember the specifics. I would really have to look at
,ggg 5 the interim and the final reports and compare them to 6 see what changes were made and to wh'at extent that met 7 this action item.
8 Q What was the source of the task force 9 findings concerning the specific deficiencies that you 10 mentioned in item 10, deficiencies in training, that is?
11 A Again, I believe these came from more than 12 one source. I believe they stemmed in part from the '
) () 13 discussions that we had with members of the plant staff, 14 and I believe it also stems from work that was done in 15 support of the task force activities and a looking into 16 some of the training that had been given.
17 Q Who did that work?
18 A I don't remember specifically.
19 g was it someone within the GPU organization 20 or an outside consultant?
21 A I don't recall any case where the task force O 22 itself instigated work related to the training program 23 by outside consultents. But the problem. I am having
^g 24 in remembering the details is that there were reviews of lY 25 the training that were carried out by outside
_ _ _ , , , - _ , - , - . , , or -
9 1 Konton 695 2 organizations which were instigated by others, and I 3 don't remember the extent to which their findings may or 4 may not have influenced the task force.
(g) S Q So you don't remember now what you had in 6 mind when you wrote item 107 7 A My only recollection is that I believe when 8 I wrote this that I felt that the recommendation 9 relative to training that had appeared in the interim 10 summary report was rather general in nature and that 11 when I read the interim report in the process of I 12 constructing this list, I felt that there might be an
() ~
13 advantage to getting in more specific recommendations on 14 these particular points.
15 As I say, I just don't remember what we 16 finally did with that item.
17 Q I guess my question was really whether today 18 you have any specific recollection of where you got the 19 information which led you to conclude what you did in 20 item 10.
21 MR. GLASSMAN: I am not sure there is a O 22 conclusion.
23 Could you rephrase it? It is confusing to 24 me.
25 MR. WISE: The conclusion is that specific
l t
(^ 10 1 Konton 696
) 2 deficiencies were found in the training program such as 3 lack of training and taking the plant solid, et cetera, 4 as I earlier read into the record.
5 The question now is solely trying to pin ggg 6 down the source of that conclusion. Where did it come 7 from? Did it come from something done in the company?
8 And, if so, who was responsible for that? If it came 9 from outside the company, where did that come from?
10 That is all I am trying to do is get some discovery and 11 try to find out who I should talk to in connection with
- 12 this issue.
13 A My memory is that this item in the memo in
(
14 B&W Exhibit 353 arose out of my review of the section of 15 the interim task force report which discussed the task 16 force's understanding the degree to which the operator 17 had been trained on these items. That section in the 18 task force report, in turn, came from discussions that 19 we had with members of the plant staff including 20 licensed operators and members of the training staff and 21 others. I do not recall any specific input on these O 22 particular items that came to the task force other than 23 part of its own investigation.
24 Q Do you recall interviewing the members of O 25 the Met Ed training staff as part of your investigation?
l
11 1 Kenten 697 2 A Yes, I do.
3 Q Did you interview them together with Mr.
4 Long, I believe?
ggg 5 A I, frankly, don't recall which of the task 6 force members were there at the time.
7 MR. WISE: I would like to have marked as 8 B&W Exhibit 358 a copy of some handwritten notes 9 which were produced to us from Mr. Keaten's files.
10 (Copy of some handwritten notes from Mr.
11 Keaten's files was marked B&W Exhibit 358 for 12 identification as of this date.)
() 13 BY MR. WISE:
14 Q Mr. Keaten, do you recognize these notes?
15 A I believe that I do.
16 Q They are headed " Training Department 17 Interview 10/18/79."
18 Are these in your handwriting?
19 A I believe that they are.
20 Q Do you recall having an interview with 21 members of the Met Ed training staff in or about O 22 mid-October 19797 23 A I remember having an interview with the 24 training staff. My recollection today, I don't remember .
25 exactly when that was.
12 1 Konton 6b8
) 2 MR. WISE: Let me also have marked as 3 B&W Exhibit 359 copies of another set of 4 handwritten notes which bear the heading Keaten ggg 5 Task Force Inperviews 0910 hours0.0105 days <br />0.253 hours <br />0.0015 weeks <br />3.46255e-4 months <br /> 18 October 1979.
6 These were produced to us from the files of Mr.
7 Long, I believe.
8 (Set of handwritten notes bearing the 9 heading "Keaten Task Force Interviews, 0910 hrs.,
10 18 Oct. 79," was marked B&W Exhibit 359 for 11 identification as of this date.)
12 BY MR. WISE:
()- 13 Q First of all, let me ask you, do you ,
14 recognize the notes that we have marked as B&W Exhibit 15 3597 16 A No, I do not.
17 Q The notes reflect at the top right-hand 18 corner the names " Dick Zechman," Z-e-c-h-m-a-n, " Marshall 19 Beers, Frank McCormick," and over at the right-hand side 20 of the page, "R. Keaten, R. Long, E. Wallace" and "R.
21 Williams."
9 22 Are.you able to recall a meeting which 23 included the individuals listed here in mid-October 19797 24 A Again, I have no memory of the exact date 25 . other than what I see on these memos. I do remember a-
_- - . .- .. . _ _ _ . = . -- -. _ _ . . . -
13 1 Kooton 699 2 meeting with some of the training staff. I remember 3 that Dick Zechman was present, and I remember that 4 Marshall Beers was present, and those are the only 5 specifics of my present memory.
ggg 6 Q You can't remember Mr. McCormick?
7 A I do not.
8 Q Would you look at B&W Exhibit 358, which 9 are your notes of the meeting. Would you take a look 10 towards the bottom of the page. There is a notation at 11 the left-hand side of the page: "1979." Do you see 12 that? It may be 1978.
() 13 A I see what you are referring to.
I will be 14 honest, I don't know if it is an 8 or'a 9, even though 15 it is my handwriting.
16 MR. GLASSMAN: You are talking about the 17 first page of this exhibit?
18 MR. WISE: Yes.
19 Q Next to th'at notation, there is the comment 20 "30 percent attendance."
21 Were you told during that meeting that O 22 training classes had only-30 percent attendance?
23 A We discussed during the meeting the g- 24 attendance at the training classes, and I remember being D 25 told that the attendance during the time frame that we l
14 1 Ksaton 700 2 were discussing was low, although I would not have 3
remembered the specific number. I believe that we were 4 discussing primarily requalification training, and I 5
don't remember whether it was this meeting or whether ggg 6 it was in other discussions or both that we were told 7 that one of the problems with the attendance in the 8 requalification program was that it tended to be a 9 review of material that had.been presented previously 10 and that it didn't have in it more interesting material.
11 And specifically, I remember the comment 12 that whoever I was talking to* felt that if there had 13 been more information on events at other sites, that 14 this would have helped revive the interest in this 15 requalification program.
16 Q That is very interesting.
17 Did you ask anybody whether Met Ed had 18 taken any steps in order to get more information on 19 operating transients at other sites?
j 20 A I remember very vaguely some discussion of 21 what the training department received in the way of 9 22 material that might be of interest to the training 23 program, but I don't remember who they said it came
.24 from.
4 O)
(_ 25 Q Let me ask you this: At the time that you I
l 1 Konton 701 15
(} 2 had these interviews, had you become aware that there any program within Met Ed to formally contact other 3 was 4 utilities in order to gain information about operating g 5 events?
6 A I don't think I was aware one way or the 7 other.
8 Q Did you ever become aware that Mr. Miller ,
l 9 had instructed Mr. Seelinger and Mr. Floyd in setting i 1
l 10 up such a program in 19787 11 A Not to my recollection.
12 Q You never saw a memoranda from Mr. Miller 13 to Mr. Seelinger and Mr. Floyd? That didn't come to J
14 the task force's attention?
c.
15 A Not that I recollect.
16 Q Did anybody explain to you why nothing had 17 been done before the accident to attempt to gain more 18 information concerning operating events at other plants?
19 MR. GLASSMAN: Objections contains an 20 assumption which has no foundation on the record 21 Could I have the question?
O 22 (Question read) 23 MR. GLASSMAN: Supplement my objection 24 by noting that the assumption counsel has in the
,b
\/ 25 question, namely that nothing had been done, is,
16 1 Konton 702
+
2 in fact, contrary to testimony in this case. It 3 is contrary to questions that have been raised 4 regarding important operating events of which the 5 questioner is aware. It is totally unfounded and, gg 6 highly objectionable.
7 BY MR. WISE:
8 Q Mr. Keaten, was it your information that, in 9 fact, the training department was giving information to 10 Met Ed trainees about other operating plants? Maybe I I
11 misunderstood your testimony earlier.
12 A My recollection is that we were told that 13 the training department did include some of that type of 14 information to the extent that they had it. My earlier 15 testimony was directed toward my recollection of the 16 discussion with someone which was that the requalificatior.
17 training program was largely a repeat material that had 18 been given earlier. Who ever , I was talking to was 19 making the point if it had more new material in it, .
20 that , in his opinion at least, it would be improved.
21 Q What did the task force find as to why the O 22 requalification did not have more new material in it 23 before the accident?
t 24 MR. GLASSMAN: Objection; unfounded.
)
(_/ 25 Mr. Keaten testified what comeone toll him,
{ l
17 1 Kocton 703 2 not about the conclusion of a task force.
3 MR. WISE: I will take my chances with the 4 question.
A I think I should reiterate once again that G S 6 the task force was not attempting to place blame on 7 things that it found. In this particular area, my 8 recollection is that I had already had discussions with g managers above me about steps that GPU intended to take 10 with respect to providing.information to the training 11 department and the operators andoso forth.
12 And so the intent of the task force's 13 discussion in this area, to the best of my memory, was 14 directed not at what had happened in the past, other i
15 than what I have already said, but rather an understanding 16 what we thought should be done in the future.
17 Q Underneath your comment about.30 percent 18 attendance is a comment, " Missing requires ' CARE' 19 package written by instructor."
20 What do you recall being told that prompted 21 you to write that note?
22 A My notes which are addres. sed to myself i
23 sometimes require a little interpretation in order to be -
24 accurate. My memory of the discussion was that the point 25 was made to the task' force that when an attendee missed 1
18 1 Konten 704
(~3 2 a class that then the instructor made up a makeup Ci 3 package which was given to the trainee who missed, in 4 place of the actual attendance at the class. And that 5' the preparation of those packages constituted a work load ggg 6 on the instructors.
7 Q The following note says: " Required about 8 2000 packages / year."
9 Do you recall being told by the training 10 staff about sending out 2,000 packages a year?
11 A At this point in time, I can't honestly 12 recollect a number. I recollect it was a large number.
("N, 13 Q Did the training staff indicate to you that 14 they had taken any steps before the accident to find 15 out what could be done to reduce the number of Care 16 packages that had to be sent out when operators missed 17 classes?
18 A I have a recollection of being told that 19 one c :- et re cembers of the training staff had sent a 20 mt s tc a plant management on the subject of the 21 attendance at the training classes.
O 22 Q Who had done that?
23 A I don't remegber.
24 Q Was it Mr. Zechman or Mr. Beers?
(~~N Y 25 A Again, I just don't remember.
3 3 t
,_ r.
705 19' T, Keaton
- y. ,
, n
' /7
= \j 2' Q What response had they received to their 1
[3 memo, if they told you and if there was any?
(> >
~
4' MR. GLASSMAN: Thank you for straightening
%y g
5 out the objections before they were made. _a 6 A I, frankly, don't remember one way or'the 4
.q x * ,
+
-y 's N w "/ eother. s
. , s y _
's ' 8< Q Would'you look at',tha next page of your 6 -
t t
, 'i (s "-
9 handwritten notes. I recognize'that it is a very door
. . ;; ~ - w 10 copy. Unfortunately, this i s, the best we can do working l -
~~ %
l 4 % ~
< t - rfrom the microfilm that we had.
s_ 11 7
y- -
? 11 ,
12, Looking' at the third comment down from Yhe s,
13 ' top of the page, the one' that begins and reads: "No O
~
.~ :
14 club to enforce attendance except licensing exam."
- s. .
'lj 15 t Do you see that?
\s(
16 A I think that's whAt,it s.s y s ,
w 17; Q Did members of the training staff complain
.s that before the accidant'they had no way to enforce
., s 18 )t ., x, - s
~'19 attendance at trairling se'ssions other than the threat "
-s 20 of possible failure of the licensing exam?
3- 21 A I believe thEt I recollect that a comment' as e
h '( 22 to that regard was made.
I don't remember specifically ;
s s
s.
N
. 23 whether it was a complaint or~ simply a comment. - '
,. ,, s
. a ', T s 24 Qg Do you know who mItde the c o m m e n t , , M r' .
+
1;
, s- Zechman or\Mrs. Beers?
~
25
. *g ,
.~ N l
-7 ,
' ss
.s s
~
3 .,. '\
. 1
- e. ,% ' t i
KGaton 706 20 1
/~)
(m/
2 A I believe, to the best of my recollection,
. 3 it was made by Mr. Zechman.
4 Q The next comment reads: "Some people felt 5 that training was not relevant to the job (such as ggg 6 calculating shielding)."
7 Do you see that comment? Again, it is a 8 very poor copy, but I think you can make it out.
9 A Yes, I see it.
10 Q Do you remember who made that comment?
11 A No, I don't.
12 Q Then that would have been either Mr.
13 Zechman or Mr. Beers?
14 MR. GLASSMAN: Excuse me, is that a question 15 or a statement or a search for a presumption. I 16 don't understand.
17 MR. WISE: Maybe we can clear this up.
18 Q You made these notes during the course of 19 the meeting, I take it?
20 A I believe that's correct.
21 Q Was it your practice to note down what the O 22 people you were interviewing said, not verbatim but the 23 substance?
24 A Yes, or my conclusions from.that.
's 25 Q- So that these notes were based on things you
21 1 Kosten 707 O
a 2 were told by people you were interviewing, is that 3 right?
4 A I believe that is true.
5 Q Your recollection, as I remember, is that ggg 6 the meeting included Mr. Zechman and Mr. Beers?
7 A That's correct.
2 8 Q Mr. Long notes also, note that there was a 9 Mr. McCormick present, but you don't recall him being 10 there one way or the other?
~
11 A t's correct.
- 12 Q Do you recall anyone else from the training
- 13 staff being present aside from Mr. Zechman and Mr.
l s 14 Beers?
l 15 A I don't recollect one way or the other.
, 16 Q So that, to the best of your recollection, 1 .
I j 17 as it stands today, these are notes of things that were i 18 told to you by Mr. Zechman and Mr. Beers?
i 19 A I think that's oversimplifying it. To the 20 _best of my recollection, these are notes of things 21 that came up during that meeting. I admittedly don't j 22 remember everyone that was there.
23 Q Can we at least agree that these were notes 24 of things told to you by the Met Ed training staff?
< \ 25 MR. GLASSMAN: You are talking about all of l
,, ,, ,,-,,--,.,7
1 Kon, ton 708 2 the items on this list, on this piece of paper?
3 MR. WISE: The notes as to comments on
{
4 things that people told him, yes.
l 5 BY MR. WISE:
l l
6 Q In other words, these aren't notes that you 7 read out the President's Commission review or Rogovin 8 Commission? These are notes of things that were said 9 at that meeting, is that correct?
- 10. A To the best of my memory, that's correct.
11 Q Going back to the comment that got us 12 started on this detour, the one that reads: "Some people ,
1 13 felt,that training was not relevant to the job (e.g.
14 calculating shielding)," did whoever made this comment 15 to you, whether it*be Mr. Zechman or Mr. Beer or someone 16 else, explain why people felt training was not relevant l
17 to the job?
'18 MR. GLASSMAN: "(eg. calculating shielding)"?
19 Q Let me ask, first, as to whether the general 20 statement that is made on the face of the page was 21 explained. If the witness wants to expound upon it, I am O 22 sure he will. He hasn't hesitated in the past.
23 A As I indicated earlier, I think, I have only 24 a very vague memory of this discussion, but my memory is 25 not that we were told that people felt that none of the
1 Konten 709 2 training was relevant to their job, but rather that we O}
(
3 were told that they felt that some parts of the training 4 program were not directly relevant to their jobs.
gg) 5 Q Did you have any discussions with the 6 operators on this subject?
7 A Excuse me, which subject?
8 Q The question of whether training was 9 relevant to the job.
10 MR. GLASSMAN: In general?
11 MR. WISE: In general.
12 Q Let me state it this way: Isn't it a fact 13 that you received comments from some of the operating 14 staff,that training was a waste of their time or words 15 to that effect?
16 A I recall that we did discuss training with 17 the operating staff, but I am having difficulty standing 18 here remembering the specifics.
19 Q Well, we have some transcripts. Maybe we 20 can help refresh your recollection later on.
21 Would you look a little bit further down O 22 the page. There'is the comment, "Added instructors 23 would have allowed more classroom sessions for 24 replacement operators - which is first exposure to
\_
25 reactor theory, heat transfer, et cetera."
A Excuse me -- I have a question.
1 Kecten 710 2 Q Sure.
3 A Is it clear on your copy that the word 4 is " replacement" and not equipment?
ggg 5 Q Yes, it is rather clear.
6 A It is not clear on mine. That's the reason 7 for the question.
8 Q Do you remember speaking about equipment 9 operators?
10 A Yes, I do remember discussions about
- 11 equipment operators.
12 Q Do you remember discussions about replacement 13 operators?
14 A Yes, I do.
15 Q In particular, a comment concerning exposure 16 to reactor theory, heat transfer, and the like would 17 refer to replacement operators, wouldn't it?
18 MR. GLASSMAN: You are asking for the 19 witness' current understanding of some term or his 20 recollection of what was meant in this memorandum?
21 MR. WISE: His recollection of what was j 22 meant.
23 Q- If that appears to be in context with the 24 rest of the comment, would that help you identify ,that . it 25 was replacement operators you were talking about and not
1 Koaten 711 2 equipment operators?
3 A Frankly, it doesn't help one way or the 4 other.
ggg 5 Q Immediately beneath that, the comment 6 continues: "Early in Unit 1 -
was 48 week classroom 7 training program - later water down due to nuclear navy 8 people,=
9 Do you see that?
10 A Yes.
11 Q Then "
- became 24 week for Unit 2." It is 12 very hard to read, but we have spent time trying to 13 decipher it. I don't know if my reading it to you helps 14 you to identify or to piece out what is said there.
15 Do you have any recollection of having any 16 discussion w ith the training staff at Met Ed on the 17 subject of which was basically what I have just read to 18 you?
19 A Yes, I do have a general recollection of 20 those discussions. The problem I am having is that I 21 don't remember which stage of operator progression O 22 this particular item of training it was addressing.
23 Q This comment was talking about either 24 auxiliary or control room operators, is that right?
25 A I believe that is correct.
1 Kecton 712
, 2 Q Is it correct that Met Ed had reduced the 3 initial classroom training program from 48 weeks to 24 4 weeks at some point before the accident?
i gg) 5 MR. GLASSMAN: You are asking Mr. Keaten's i
6 current knowledge? -
His recollection of what he was 7 MR. WISE:
8 told, or his current knowledge if he based it on 1
9 some other meeting that is different from this 10 one.
11 A As far as I know, these notes were based 1
12 upon that meeting. I believe that I recollect being 1
- 13 told that there had been a reduction in the length of a J 14 training program. My trouble is I am having a hard time l 15 remembering which specific phase of the training program i
16 that was.
l
! 17 Q Do you remember being told that the classroom i 18 sessions for replacement operators were their first
- 19 exposure to reactor theory, heat transfer, and the like?
20 MR. GLASSMAN: Can I have that back?
I 21 (Question read) k 22 A I have a general vague recollection of 1
23 discussion of first exposure to reactor physics and heat 24 transfer theory, but I can't remember the specifics of O
k/ 25 how that fit in -- where it fit into the total program.
- - - - - , , y ,
1 Keaten 713 I
I 2
( Q Didn't the task force conclude that one of l 3 the problems with the training of operators had been 4 .the lack of sufficient instruction on the basics, if lll 5 you will, of reactor theory and heat transfer? .
6 A I think the task force concluded that more 7 instruction in those areas would be desirable for the 8 operators.
9 Q That was instruction that they received from 10 Met Ed , was it not?
11 A The task force never made any attempt to 12 determine who was responsible for particular portions
. 13 of the training.
{~}/
s-14 Mr. Keaten, isn't that exactly what you were Q
15 doing in your interview on October 18, 1979 with various 16 members of the training department --
attempting to 17 find out who was responsible for what kind of training?
10 A No. We were trying to find out what kind of 19 training the operators were.given and we were trying to 20 find out from the training staff any comments that they 21 had regarding items that either caused difficulties for 22 them or areas where they would like to recommend 23 improvements, but we were making no attempt to I
24 distinguish what was Met Ed versus what was anybody 95 else.
1 Konton 714
['\ 2 Q Continuing down the page, the next comment GI 3 reads: "After autoprogression program became two weeks 4 for auxiliary C, six weeks for auxiliary B..." --
ggg 5 something I can't read -- ".. 90 days during probation.
6 The water down occurred during, union negotiations."
7 Do you remember being told during your 8 meeting with the training staff that as a result of 9 union negotiations the training program had been watered 10 down?
11 A No, I do not recollect that.
12 Q, Didn't the task force learn as a fact that 13 the training program had been reduced as a result of N_,
14 union demands?
15 A I do not today recall any discussion of 16 union demands. What I recall with respect to the 17 training of the auxiliary operators is that the task 18 force was informed that the amount of formal training 19 in the sense-of maintaining signed records of the 20 training had been reduced.
21 Q Do you have any recollection as to what O 22 you meant by " union negotiations" in your note as it 23 appears on this page?
24 A I, frankly, don't remember that note at all.
O2 25 Q Isn't it true that before becoming a control
\
1
1 Keaten 715
() 2 room operator, an individual vsaid have served as an 3 auxiliary operator for some period of time?
4 A I believe that's correct.
lg 5 Q In other words, the initial training one 6 receives on the way to becoming a control room operator 7 is through the auxiliary operating training program?
O A Yes, I believe that's correct.
9 Q The next comment in your notes is " Shift in 10 emphasis was from theory to hardware based on assumption 11 thet navy nuclears would have basics bac) ground, but with 12 autoprogression not necessarily navy nuclears."
13 First of all, what did you mean by the
(~}
%/
14 term " navy nuclears"?
~
15 A I believe that I meant individuals who had 16 served in the nuclear navy.
17 Were you told by the training staff at Met Q
18 Ed that as a result of hiring a number of people who had 19 training in the nuclear navy, there was a shift in 20 emphasis away " rom the basics and toward hardware?
21 A I don't presently recollect that discussion.
22 Q The final comment reads: "Recently have 23 had verbal feedback (mid-1978-79) from shift 24 supervisors that training in basics was lacking."
7, l
U 25 Were you told by the Met Ed training staff I l
l
1" Keaten .716 "T 2 that during the middle of 1978 and into '79, the shift (G
3 supervisors had reported to them that the training and 4 the basics of reactor theory were lacking among control 5 room operators?
ggg 6 A I have a very vague recollection of a 7 - discussion of that type.
8 Q The final page of your notes reads: "No 9 formal training and crossover between units."
10 Is that a comment that was made to you?
11 A I don't remember that one at all.
12 Q Do you know whether any of the operators 13 who were on duty on the morning of' March 28, 1979 had 14 had training on Unit 1, that is the operators who were 15 on duty at Unit 27 16 A I do not know.
17 Q I would like you to look for a second at Mr.
18 Long's notes of that meeting, which have been marked as 19 B&W Exhibit 359. I recognize that these are also rather
- 2'O difficult to read, although I think by using the 21 microfilm photocopies we got a slightly better result than O 22 we did on the Xerox machine with your notes.
23 MR. GLASSMAN: I would like to note for the 24 record that while counsel keeps on referring to 25 this as Mr. Long's notes, it doesn't appear to y y .
, , _ _ _ . . _ ,,,.g. -. ,
1 Koaten 717 2 have been established here, and the witness just 3 testified earlier that he did not recognize these 4 notes.
5 MR. WISE: The notes of someone who appears 6 to have been at the meeting. I think we can 7 identify it later. I think they were produced 8 from Mr. Long's files.
9 Subject to tying them up at a later time, !
l 10 I want to know if these notes refresh this )
l 11 witness' recollection of what the notes purport to 12 show had been said was, in fact, said. If they 13 don't refresh his recollection, that's fine, and 14 they are being used only for that purpose.
15 .MR. GLASSMAN: I object to this line of 16 questioning. I should note that counsel for B&W 17 has frequently barred any questioning of witnesses 18 with regard to documents which they did not recall.
19 I might add even documents that they themselves, 20 the witnesses themselves, had authored. So asking 21 Mr. Keaten about notes that he doesn't recall that O 22 aren't his would seem to be inappropriate and not 23 in line with the objections previously raised by i
24 B&W and directions not to answer which were given.
N- 25 MR. WISE: You have entirely misconstrued I
i -
1 Keaten 718 l
2 what I want to do. Let's examine without the
-3 n tes. I thought I was being helpful. I thought 4 having the notes would refresh his recollection.
5 I am g ing to ask the same questions. I was not ggg 6 going to ask him to interpret the documents, which 7 is the objection we have posed many times and 8 which, I think, would be quite proper in asserting g an objection if I had attempted to do that. I 10 was not attempting to do that. I thought these 11 might refresh his recollection. I can read these 12 to him. I thought it would go faster if he had 13 the copy in front of him.
Q 14 MR. GLASSMAN: The objection stands. I 15 don't know what purpose we serve by reading 16 somebody else's notes that he doesn't recollect 17 into the record and try and figure out if this 18 has any current impact on Mr. Keaten's current 19 recollection..
20 BY MR. WISE:
21 Q Do ycu remember being told at the meeting O 22 with respect to the replacement reactor operator or 23 training program, all but two weeks of the program 24 consisted of self-study?
25 A I remember a discussion associated with the
. m. , _,- , ,s-~,
\
i 1 Kosten .719 self-study aspects of the program. I don't remember the 2
3 specific portion of it that was self-study.
4 Q Wasn't the program a nine-month program? l 1
5 A Again, I don't remember the specifics. I
- ggg 6 am also still very fuzzy as to wh'ich specific training i
7 -program this was. -
4 1
8 My only recollection is that it was a 9 training program for some stage of auxiliary operator as 10 contrasted to a training program . for the control room 11 operators.
12 Q Do you remember any discussion of the 13 syst9ms training?
14 A Systems training for auxiliary operators?
] 15 Q The fir'st step in becoming a control room 16 operator is to be an auxiliary operator, as-I-thought l 17 we had established.
i 18 'Q Yes, it is true that control room operators i
19 normally gain experience as auxiliary operators before 20 they go into training as control room operators. That's i 21 not the same thing as saying that the training program l 22 for auniliary operators is the first step in the training 23 . program for a control room operator. That's the 24 distinction I was trying to make.
i
(' 25 Q Whether we are talking about the training that l: .
3
- 1 Kenton 720 5
2 was received during the auxiliary operator course or 3
during a control room operators course, do you recall l
! 4 whether you discussed with the training staff at Met Ed 5 systems training for either both or one of the other?
g g
6 A I do recollect having discussions with the training staff on the subject of systems training. The i 7
$ 8 discussions that I recall today, and I have no idea-(
! g whether they were at this meeting or not, were en the t
! 10 subject of systems training for control room operators.
, 11 Q Do you remember the comment being made that
! 12 many elements of the training were missing, particularly
):- 13 if the trainees did not-have prior navy nuclear l- .
j 14 background and, in particular, that the training staff i .
15 was required to give simple math instruction to the l 16 trainees?
5 17 A No, I do not recollect that.
- 18 Q Do you remember Mr. McCormick making the i
19 comment concerning training staff needs that operators i
20 were not taking training seriously?
I 21 A- As I indicated earlier, I frankly don't 22 remember the presence of Mr. McCormick at the meeting, i
23 so I don't remember him saying anything.
24 Q Do you remember the comment being made by 25 Mr. McCormick or anyone else that training had been
1 Keaton 721 I
(~N 2 looked upon as something " nice to have," but not a 3 need?
4 A I do not remember any such comment. If it 5 was made, I would question the context in which it was gg 6 made.
7 Q Now, I would like to go back, if you will, 8 to Exhibit 353, your December 3, 1979 memo on open 9 items.
10 would you look at item 11 on the second page 11 of your memo, which reads: " Develop a recommendation 12 which addresses the issue of whether training to pass 13 NRC exams is an adequate philosphical basis for the
.i \/
l 14 program."
15 someone has written in beneath that, in 16 handwriting, "(not adequate)." Action is indicated for 17 Mr. Broughton. Someone has also written in, in 18 handwriting, the word " cancel."
19 First of all, do you remember writing that 20 item?
I l
21 A Do you mean the typed portion or the
@ 22 handwritten portion.
23 Q Typed portion.
24 A I h, ave a vague recollection, yes.
25 Q Do you know whether that action item was 1
1 Kanten 722
/ 2- actually cancelled at some point?
3 A My memory is that the task force concluded 4 that training which is simply directed toward passing g 5 the NRC exam was not in the opinion of the task force 6 all of the training that the' operators should receive, 7 and I believe that I remember that we somehow got that 8 thought into the final version of the task force report.
9 Q Had the task force concluded as of December 10 3, 1979 that prior to the accident, the philosophical 11 basis for Met Ed's training had been training to pass 12 the NRC exam?
13 A Again, the task force made no attempt to 14 distinguish between Met Ed's training and somebody 15 else's training. That was not one of the issues that 16 we investigated. But the task force was told that the 17 training program was largely, if not totally, directed 18 toward enabling the operators to pass the NRC exam.
19 When I am talking about "this training," I am talking 20 about the training of Iicensed operators.
21 (continued on next page) 9 22 l 23 24 25 l
/1 1 Kooton 723 2 Q As part of your investigation, did you 3
visit the B&W simulator down in Lynchburg?
4 A I did not. I don't remember whether others 5 associated with the task force investigation did or not.
ggg 6 Q Did you interview any members of the B&W l
l 7 training staff in connection with the task force 1
8 investigation?
I g A As part of the general investigation, some ,
members of the task force talked to various people 10 11 associated with the TMI training program, and I don't 12 know whether any of those were B&W employees or not.
13 Q In any event, you did not talk to any B&W
- 14 employees on the subj ec t of simulator training?
15 A I had some discussions with members of the' 16 training staff outside of the meeting that we have 17 earlier been discussing, and I have a memory that one or 18 more of those was a contractor'rather than'being a Met Ed 19 employee, but I don't remember today and I don't know 20 whether I ever knew who they worked for.
21 Again, it is an illustration of the fact 22 that we were not trying to distinguish between Met Ed 23 versus other trainers.
24 l Q I am trying to find.out what your group 25 did. You did not visit Lynchburg?
l 1 Konten '
724 1 1
2 A I did not visit Lynchburg for the purpose 3
fg ing to the simulator.
4 Q Or interviewing B&W simulator personnel?
5 A That is correct.
ggg 6 Q, .You don't know whether anyone else did or 7 not?
8 A I don't remember. Part of my problem is 9 that since that time, there have been some people who were 10 involved in this investigation who have been at the 11 simulator and I just don't remember at what point in time 12 that was. Their purpose in going down there, to the best l 13 of my knowledge, was not to investigate the simulator.
14 Q At the time that you wrote your comment in 15 item 11 concerning the philosophical basis for the 16 program, you were not basing your comment upon any 17 discussions that you had with B&W personnel or visits to 18 the simulator, were you?
19 A Could I have the first part of that question 20 read back?
21 (Record read.)
9 22 A At the time that I wrote that comment, to 23 ,
the best of my recollection, I wasn't making any attempt 24 to distinguish between classroom training versus 25 simulator training. It was directed rather toward
1 Keaten 725 2 the general understanding that the task force had 3 received that the training program, in its totality, had 4 been geared primarily to passing the NRC licensing exam.
5 Q All I am trying to do, Mr. Keaten, is to Jgg 6 determine where you got that information from. You 7 didn't get it from B&W, did you?
8 MR. GLASSMAN: I think he answered the g question at least three times, saying he didn't 10 know where he got it from.
11 Q Is that your testimony, you don't know what 12 you based comment 11 on?
13 MR. GLASSMAN: You are now simplifying 14 counsel's comments. I am getting upset because 15 the witness has tried to answer the same or 16 similar question fully, at least three times here, 17 and counsel now seems to be putting words in
-18 his mouth and asking the question yet a fourth I
I 19 time.
20 It seems to me we are getting nowhere fast.
21 We have already occupied at least six days of 22 a deposition and'I hope we can get on with it.
23 - MR. WISE: What was the pending question? i
. l 24 (Record read.)
s 25 Q Mr. Keaten, I will withdraw that question.
g Koston 726 I
2 I don't mean to be cross with you, I am just trying to V'
find out as best I can where you were in December 1979.
3 4 There is a comment here which I am interested in and all 5
I am really trying to do is to simply establish that as 6 f the time you made the comment that you did, whatever l l
7 you meant by it, that the sources of your information )
f 8 had been as a result of an investigation made internally l 9 in the GPU organization; that is what I am trying to 10 establish.
33 If you recall that you were down in 12 Lynchburg and you spoke to B&W people, that is fine.
13 If it is not the fact, I would appreciate us putting this O 14 n the reccrd and going on to the next question.
15 A I will try to answer as best I can, j 16 MR. GLASSMAN: I would like to note an 17 objection that this is a repeat. He just i
18 answered a question before , talking about 19 contractors or employeet whom he did not identify.
20 The question assumes that the only place 21 B&W people might be located is in Lynchburg, 22 Virginia, and it is not a fact.
23 MR. WISE: If this witness has information 24 that the B&W philosophy was to pass NRC exams,
.\ 25 and if his testimony is attempting to be Eague
1 Kooten 727 l
() 2 enough to allow them to come into court at some 3
later time that someone from B&W told him about it, ;
J 4 I want to know and I want to know now. I have a i 5 right to get that answer.
gg 6 MR. GLASSMAN: If you want to ask him a 7 proper question, go ahead.
l 8 MR. WISE: I have been, and I am getting 9 vague answers and I am trying to clarify them 10 so I know one way or the other.
11 If this witness has some information that 12 B&W subscirbed to the philosophy here, I want to 13 know now. I am entitled under discovery.
14 I am not g&tting it. -
15 MR. GLASSMAN: Now that I understand what 16 you are attempting to elicit, fine, go ahead.
17 A The investigation of the training program 18 by the task force was done by several people. I was not 19 one of the'particular leads in that area.
20 For myself personally, I have no recollectior 21 that I ever discussed simulator training with anyone O 22 who worked for Babcock & Wilcox at the Lynchburg 23 facility. I did have some discussions with respect to R l
24 training with personnel at the TMI site.
25 I recall,.I believe, that one or more of
1 KGaton 728 2 those people were contractors and I don't recollect what 3
rganization they came from and I am not sure I ever 4 knew.
5 Q Just to end this matter, did you ever learn 6 as part of the investigation what B&W's philosophical 7 basis, if it had any, for its training program was?
8 A The task force, as is indicated in the task 9 force report, was investigating activities as they 10 related to the TMI operators and was not specifically 11 investigating any outside organization as such.
12 The philosophy that is referred to in this 13 item that we have been discussing comes from the 14 statements in the version of the task force report that 15 gave rise to this list which were, as I recollect, along 16 the general line that that was one of the principal 17 driving motivations of the training program as it was 18 presented'to the TMI operators.
19 The task force carried that no further in 20 terms of trying to say is that a Met Ed philosophy or 21 is that a B&W philosophy. I don't remember that we had O 22 any d'iscussions on that subject.
23 Q Would'you look at the next page, Page 3, 24 the first comment on that page.is item 13: - " Review
_/%
> 25 the recommendation regarding provision of technical
I 1 Keaten 729 2 data to the plant staff to see if additional specifics 3
need to be included. In addition, address the need 4 to perform a continuing analysis of plant transients."
Isn't it true, Mr. Keaten, that one of the gg 5 6 conclusions and recommendations that your task force 7 investigating the April 12, 1978 transient at TMI-2 had 8 made was that there be some effort to continue to review g and address and analyze plant transients at TMI?
10 MR. GLASSMAN: Wait a second. I am confused 11 by the question.
12 First, the question seemed to be reading p 13 a portion of a document relating to events in.
V 14 1979, and now there is a separate question that 15 seems to be relating to some earlier transient; 16 is that my understanding?
17 MR. WISE: I think you understood the 18 question quite well.
19 Q Isn't it true, Mr. Keaten, in fact, this 20 recommendation in item 13 is the same one that had been 21 made as a result of the April 1978 transient but never O 22 carried through on?
23 MR. GLASSMAN: Objection as to form. It 24 - seems to have a number of assumptions involved o
-- 25 in there which have not been established.
1 Keaton i730 I
A I believe that this recommendation is I 2
addressing the same topic which was addressed in the 3
4 April 1978 transient, but I do not agree that it had never been carried out. On the contrary, from the time of gg 5 6 the April 1978 transient until this time, there has been 7
an increase in the capability to do such analyses and 6 that increase in capability had been done with the 9 explicit knowledge and support of GPU top management, 1
10 and to the best of my recollection, that was simply 11 addressing the fact that we neeeded to continue to do it.
12 Q Did your task force attempt to find out 13 whether-the operators had been given any training or O 14 instruction with respect to the transient that had 15 occurred at TMI-2 on March 29, 19787 16 MR. GLASSMAN: Could I have it reread, 17 please?
18 (Record read.)
19 A As I stated earlier in the' deposition, I 20_ do recollect that we discussed, to some degree, the 21 March 29, 1978 event with some of the people that we 22 held discussions with.
23 I don't today_ recall any specific discussion 4 of how that was factored into the training program.
25 g well, in writing item 13 in your memo, i
, , , . _ . . , .,, - - - - ~ vaw - ~
.. .~_,
-y _ . _ . . _ _
. l 1 Keaton 731 l
2 and specifically that~ portion of it that speaks about
.O.
, 3 addressing the need to perform a;co.ntinuing analysis of
\:
4 plant transients, did.you have_in_ mind a recommendation 5 concerning the' communication of the;results of that gg 6 analysis to the people who were running the plant; namely, 7 the control room operators and their supervisors?
8 A The best of.mp recollection is that-that i g recommendation was direct'adstoward,orLthat suggested 10 recommendation I should say was yirected toward continuing 11 todevelopthecapabilitytopehformsuchanalysesand to i-have it understood that any timesthere was a significant !
12
, 13 transient that was experienced'by the plant that some 14 type of an analysis, such as,:for exampla, a RETRA'N
- 15 analysis would be performed.. Certainly one of the reasons 16 that such an analysis would be desirable would be to feed
.17 back information to the operating staff.
.18 Q Let me-refer you to your first-draft of the 19 task force. interim summary report prepared septemb'er 28, 20 1979, which has been marked as B&W Exhibit 347.
l 21 Would you turn to Page 25'.of the. report. On
.h 22 ' that copy you may need to refer to the numbers at the 23' bottom of-the page, it;is page 1880-marked for purposes v r .
24 of-this litigation.' - t
^ ^
! 25 The'second full paragraph on that'page j n .
'L f~,- .
g
1 Kocton 732
(~') 2 reads, "There is evidence that even transients at TMI
(_/
3 were not used effectively to upgrade the training and 4 procedures. The March 1978 transient for example in which 5
the PORV first stuck open received very little attention.
gg 6 No attempt was made to use the experience from this 7 transient to upgrade the procedure for response to a 8 stuck open relief valve. In particular, no attention was 9 paid to the use of the temperature detector as a means of 10 detecting an open valve. Had this transient been fully 11 analyzed, and the procedure upgraded to include specific 12 guidance on the temperature readings to be expected if the g- x 13 valve stuck open the operators might have had sufficient
< i v
14 information to recognize the stuck valve much earlier 15 in the transient."
16 Does that help '.efresh your recollection 17 as to whether the task force made an investigation 18 concerning whether the operators had received 19 instruction and training concerning the March 29, 1978 20 incident at TMI-27 21 A Let me first point out that we are back now O 22 to the very first rough draft of this report where I have ;
23 previously stated time and time again that my principal l
, I I 24 I intention was to get words down on paper to trigger
- l l
N. _/ 25 discussion, rather than being concerned for the purposes !
1
y -_
1 KoaSa'n- 733 2 of this first rough draft as to the exac ' accuracy _of 3 eyerything that is said.
M. .i 4 ; , Q If you would like, we can refer to the final x '
~
5 copy,~the one marked December 15, 1980.
6 iA I. think that would be preferable.
3 I -
7 Q Which contains virtually identical wording 8 with some editing changes. That is B&W 356. You a s 9 probably would want to refer to Page 14 of the report, ,
, , 10 the second full paragraph. The question remains the same.
11 ' MR . GLASSMAN: What is the question ncw?
12 MR. WISE: Does this refresh the witness' 13 recollection that l'n fact the task force had made 14 an investigation concerning the degree to which 15 the operators had received training as a result 16 of the March 29,.1978 transient at TMI-2, that is s
17 training on that transient, and the degree to 18 which that analysis of that transient had been 19 effectively communicated to the operators.
20 5 I think the wording of t'his paragraph as it
, t 21 appears'in the final report bettdr reflects the s ~
1, 3 22 understanding that the task force reached with respects s ,
a N 23 to this item. ,
n
.24 As I have stated earlier, I-do recall a.
?u ,
)
i 25- ^ discussion of that and I recall the discussion associated 1
4
, h
- + ,
\
,X- t i
J gs } }. \
1 Konton 734 2 with installing an indicator light in the control room 3 as a result of that transient.
4 The paragraph as it appears here in the final 5 report is addressing the fact that the analysis of the ggg 6 transient on March 1978 addressed the events which 7 occurre in March 1978 but did not go one step further 8 and address other things which might have occurred of a g similar nature, such as different failure modes for 10 the valve. ,
11 It is not my recollection that this 12 paragraph was intended by the task force to reflect any 13 Problem that the task force had found with respect to 14 the transfer of information from the March 1978 event 15 to the operating staff.
16 Q Let me go back to your original draft, 17 Exhibit 347, where you state, "No attempt was made to 18 use the experience from this transient to upgrade the 19 proceduro for response to a stuck open relief valve."
20 That sentence does not appear that way in the final copy.
21 A That is correct.
22 Q I would like to know what attempts the task
%) force was able'to find had been made to use the 24 j experience from the March 29, 1978 transient to upgrade.
O' 25 the procedure for response to a stuck open relief valve.
. g ._, .,y-.. - - -
1 Kocton 735
/~T 2 A I have a very vague recollection of being V
4 3
told that there were changes to the procedures as a 4 result of that incident, but it is a very vague recollection and I don't remember any of the details at Jg 5 6 all.
7 Q Did the task force ever attempt to verify 8 whether the procedure for a failure in the pressurizer 9 system had been revised since 1977, or whever it was 10 originally established?
11 A I don't remember that level of detail.
12 Q The next sentence in your original draft
~
13 reads, "In particular, no attention was paid to use of 14 the temperature detector as a means of detecting an 15 open valve."
16 MR. GLASSMAN: You are reading now from 17 B&W 3477 18 MR. WISE: Yes.
19 Q Was the substance of that sentence carried 20 forward into the final report?
21 A Yes, but with a qualifyi,ng statement.
O 22 Q Who suggested the qualifying statement 23 which reads, "since the monitors were not installed 24 for this purpose"?
25 A I don't remember who suggested those specific i
l
1 Konton 736 2 words.
3 Q What is the basis of your belief that the 4 monitors were not installed for that purpose?
5 MR. GLASSMAN: You are asking for Mr.
9 Keaten's current --
6 7 MR. WISE: No, M'r. Keaten's belief as 8 chairman of the task force and --
9 MR. GLASSMAN: At the time --
10 MR. WISE: Chief author, if you will, of 11 the final task force report in December 1980.
12 A This was the understanding that the task 13, force was given as a result of all the various 14 investigations that it did, and I do not remember 15 specifically how that was communicated to the task force.
16 Q You don't remember who suggested that change?
17 A The change was made because the members of 18 the task force felt that that more accura'tely reflected 19 their understanding of the situation. I don't remember 20 which particular person raised that as an issue. Again, 21 this final report was written by members of the task 22 force taking a critical look at the earlier drafts 23 and trying to identify areas where the draft-did really 24 reflect what the task force was trying to say.
(~~s (m/ 25 Q Let me go back to B&W Exhibit 353, your
I
- 1 Konton 737 2 December 3, 1979 list of open items.
3 MR. GLASSMAN: Do you want to ake a break?
t 4 (Recess taken.)
5 BY MR. WISE:
ggg 6 Q We are continuing to discuss Bsw 7 Exhibit 353, which is Mr. Keaten's list of open items 8 dated December 3, 1979.
9 On Page 3 of your list, would you look at 10 item 18, it reads: "Under section II.B.2 'Information 11 Flow' develop a story that the plant management and 12 Met Ed management were immediately drawn into 13- communication problems with state agencies rather than 14 being free to concentrate on the plant condition. Develop 15 a recommendation that casualty managers have a 16 communication system which leaves them free to concentrate 17 on the plant."
18 was the task force ever able to develop a 19 story that the plant and Met Ed management were drawn 20 into communication problems with state agencies?
21 A The task force did investigate the O~ 22 communication flow between the plant operators and the 1
' 23 state agencies. I am trying to remember the '
24 circumstances that.gave rise to this item. I am having 25 trouble. .I believe it was a comment that somebody had
1 Kcoton 738 tO
%J 2 made that maybe that had contributed to some of the 3 confusion during the day of March the 28th, but I don't 4 recall that the task force in fact took the position that 5 this was a significant contributor.
ggg 6 All I remember coming out of this was I 7 think a fairly universally agreed to idea that responding 8 to an event of this type really required a larger staff 9 than had been immediately available on March the 28th.
10 Q Do you recall interviewing Gary Miller as 11 part of your task force work?
12 A Yes, I believe I do. ,
13 Q Gary Miller was the station superintendent 14 at the time of the accident, isn't that correct?
15 A I believe that was his title.
16 Q Do you recall that Mr. Miller had arrived 17 at the site sometime during the morning of March 28, 19797 18 A Yes, I believe he did.
19 Q Isn't it true that your task force 20 determined that Mr. Miller had been called away from the 21 site sometime subsequent to that in order to meet with O 22 certain state government officials?
23 A Yes, I believe that is correct.
24 g Q Do you recollect that Mr. Miller made the
(~N i
\-) 25 statement that sometime after his arrival at the plant,
\
1 Kocton 739 2 but before he left, he had directed the operators to 3 maintain full HPI flow?
4 A Yes, I do recollect that statement.
5 Q Do you recollect whether the task force g
6 also received information from the operators indicating 7 that that direction from Mr. Miller had not been fully 8 communicated to them?
g A I believe I remember the task force being 10 told by at least one of the operators that he did not 11 recollect that direction.
12 Q Did the task force reach any conclusions 13 concerning the degree to which Mr. Miller's absence
($) 14 from the site, in order to meet with government 15 officials, may have contributed to some confusion or 16 misunderstanding or whatever by the operators concerning 17 Mr. Miller's direction about HPI flow?
18 MR. GLASSMAN: Could I have that read back?
19 (Record read.)
20 A I don't recall that the task force received 21 any information that led it to believe that Mr. Miller's 22 absence on the afternoon of the 28th caused any 23 demonstrable difficulty.
24 Q Would you look at item 19 in your 25 memorandum,which reads "Somewhere in Section II.B address
1 Koston 740
(~% 2 the fact that senior plant management didn't arrive d
3 until about 7 a.m. and by that time the core damage 4 had basically been done."
5 The person listed as responsible for action ggg 6 on that item is R. W. Keaten.
7 First let me ask whether it is a correct 8 statement that by 7 a.m. the core damage had basically 9 been done?
10 MR. GLASSMAN If that's a conclusion of 11 the task force?
12 MR. WISE: Obviously it is written here 13 and I want to know if he has any information that 14 leads him to believe today that that is not 15 correct. -
16 A This statement I don't think intended to 17 imply any great precision with respect to exactly 18 when the core damage occurred in detail, but rather was 19 intended to imply, as best I can recollect, that by that 20 point in time it is not clear that there were any i
, l 21 alternative actions which might have been taken which
, 22 would have had a substantial impact on the degree of-
, 23 core damage.
24 j Although the task force never placed great s 1
( 25 emphasis on exactly how the damage occurred once the
1 Konton 741 2
last coolant pump was turned off, I think this was consistent with the general understanding of the task 3
4 force.
Q what was the task force's general 5
ggg-6 u,nderstanding based on? Had there been knalyses either 7
inside or outside GPU that led you to this conclusion?
8 A The analyses which I recollect being 9
discussed by the task force were those which were done 10 by the Nuclear Safety Analysis Center, but I don't I
11 recall that we discussed them in any particular depth.
12 Q Have you ever reviewed those analyses up 13 to the present time?
O 14 A As far as myself personally, I have read 15 through the Nuclear Safety Analysis report --
Nuclear 16 Safety Analysis Center report on the TMI-2 accident, which 17 includes, among other things, a summary of their 18 evaluation of core damage. Again, I don't recall that I 19 studied it in any particular depth.
I 20 Q Do you know whether anybody, either in 21 connection with the task force or otherwise, within O 22 the GPU. organization or Met Ed, has ever attempted to ,
l 23 perform any analysis to determine the time periods f II 24' during which core damage occurred?
25 A we discussed earlier some analysis that was
1 Konton 742 r"T 2 done by GPU with respect to the likelihood that core 3
damage occurred before the last coolant pump was turned 4 off.
5 While I still don't remember any details, ggg
. 6 the documents you showed me did refresh my memory that 7 we had done that and that the conclusion had been that i
8 the core could be cooled to the extent that analysis 9 was accurate by a reasonably high void fraction of steam 10 in a two-phase mixture.
11 I do not recollect any specific work done 12 by GPU with respect to the timing of core damage past 13 that point in time. I mentioned earlier that there was 14 some work done by GPU regarding the probable extent of 15 core damage but I don't remember that that went into 16 the timing question.
17 Q Who did the work on the extent of core 18 damage?
19 A That was done by the nuclear fuel section 20 at that time.
21 Q Do you remember the name of the individual O 22 who was responsible?
l 23 A Mr. Gordon Bond was the second manager, ;
}
24 and I am not sure, exactly sure which of the engineers l
25 under him participated in that.
w
1 Konton 743 2 Q If I understand your testimony correctly, 3 whatever information you had when you wrote item 19 was 4 based on the analysis done by the outside group, the 5 Nuclear Analysis and Safety Center?
6 A I don't remember whether it might have 7 also included other analyses by other outside 8 organizations that were generally available.
9 Q You have never come to read anything or see 10 any conclusions that lead you to believe that the 11 statement as it appears here in Exhibit 353 is incorrect?
12 MR. GLASSMAN: Which portion of the s'ca temen t 13 are we now talking about?
Os .
14 MR. WISE: The statement that core damage 15 had basically been done by 7 a.m. on the morning 16 of March 28, 1979.
17 A I have a general recollection that some of 18 the Nuclear Safety Analysis Center work cast some doubt 19 on exactly the timing of the damage, and I don't remember
- 20 the details of it.
21 In the context that I put the statement O 22 earlier, namely that I believe that by the time that 23 senior management arrived at around 7 a.m., that it is 24 not clear that there were any alternative, is that ss 25 would have substantially affected core damage tothebestl
Konton 744 I
of my knowledge is still true.
O' 2 Q Let me refer you to Page 5, item 28,which 3
reads, " Expand the investigation of the status of 4
knowledge of core damage. This should include interviews with personnel such as Brian Mehler have not 6
yet been interviewed by the task force. Expand the 7
write-up of Section II.G and develop any' corresponding 8
recommdnations."
9 The people responsible for action are 10 yourself and Mr. Bond.
11 To what were you referring when you spoke 12 of the investigation of the status of knowledge of core damage?
~
14 A one of the issues which was raised by other 15 investigations of the TMI accident was whether any of the 16 TMI personnel had more knowledge of the probable extent 17 of core damage on March the 28th than they communicated 18 to outside agencies such as the state agencies in the 19 NRC. That was the issue which led to the specific item 20 in the charter of the task force which this was directed 21 g towards.
The question had in part been raised by 23 comments made by some of the TMI plant staff during, 24 3 for examplo, interviews with some of the investigators 25
1 Konton 745 which led some people to conclude that they knew more thar.
r had been communicated outside.
3 4
Our investigation was to attempt to understand ourselves as to whether that was true. This 6
was directed towards that.
- Q You said some people had concluded, based on interviews with the plant staff. Who do you include within "some people"?
A I have a real problem in distinguishing between who I was thinking of when I wrote this and 12 who I think now when I ask that question. '
Q Let's take it both ways.
~g 13 A I am not sure I will be able to totally 14 distinguish. This was to the best of my recollection an issue raised in the original NRC I&E investigation. 1 I believe the issue was also raised during the Kemeny g investigation. I just don't remember right at the moment.
Q Why did your note include a specific 21 reference to Brian Mehler?
llk A Because Brian Mehler had made a comment and I don't remember the exact words, along the line that he
.. lhadrecognizedearly that there was some core damage,
[\_)'t - 25 and my recollection is that that comment had been taken
l 1 Koston 746 2 and used out of context to try to indicate that people 3
in the control room knew more than they were communicating .
4 I wanted personally to talk to Brian and see what he had 5
meant when he said that comment and what he thought he ggg 6 knew about the extent of, core damage.
7 Q Did you tape that conversation with Mr.
8 Mehler?
9 A My recollection is that I did not because 10 we were actually having the conversation while he was on 11 duty and the place where we ended up talking, there 12 was enough background noise that the tape would have 13 been worthless.
O 14 Q Did you make a memorandum after your 15 conversation with him?
9 16 A I believe I did something along those 17 lines.
18' (Continued on Page 747) 19 20
(
l 21 22 l
23 21 25 ,
l hd1 1 Kocton 747 I
I') 2 Q Item 30 on page 5 reads " Develop a specific b
3 statement in the cor.clusion section regarding the impact 4 of management attitudes on the TMI accident.
gg) 5 Correspondingly develop specific recommendations for 6 future improvements."
7 The person reflected for action on that is 8 R. W. Keaten and others.
9 Why did you feel such a conclusion needed to 10 be developed?
11 A My recollection is that in the interim 12 summary report the comment was made along the lines that 13 the task force investigation into any possible role of 14 management was incomplete or hadn't been done. I don't 15 remember the words, and that I put this in recognizing 16 that what was in the interim report had to be further 17 developed before it would be appropriate for a final 18 report.
19 Q Did you ever complete that work?
20 A I recall the task force as part of some of 21 its subsequent discussions addressing this item and O 22 coming to the conclusion that on the basis of what we 23 had done to date, that there really wasn't anything
( 24 useful that we could say in that regard. And that as l D-l - 25 far-as any further investigation in this regard, it was 1-
. _ _ . _ . .~ , _ . . _ . . __ _
2 1 Konton 2
( made virtually impossible by the fact that there had 3 been an almost complete reorganization by this point in 4 time.
ggg 5 so my recollection is that the final report 6 simply reflected that that's not something that the task 7 force had been able to do.
8 Q Let me read to you from the final report, 9 which has been marked as B&W 356, on page 37. I am 10 reading from the next-to-the-last paragraph in the 11 conclusions section of the report.
12 It reads:
"The task force did not perform 13 a thorough review of the role played by TMI management 14 relative to the identified problems, primarily because 15 the management structure was significantly changed from 16 that whic.h existed at the time of the accident. The 17 task force did, however, develop some recommendations 18 for future management actions, as discussed in the next 19 section."
20 Is that the result of the considerations you 21 mentioned with respect to item 30 in your December 3, 9 22 1979 memo?
23- A Yes, I think that's, correct.
24 Q Did the task force find that it was
\
(~l
\- 25 impossible to determine what the management structure L
l
., . , . . - - r -r , -
s '"
3 1 Konton 749
() 2 was as of March 28, 19797 3 A No.
4 Q Did the task force find that it could get lll 5 any information concerning what effect the management 6 structure, as it existed on March 28th, had with 7 respect to 'the accident?
8 A I think it is necessary to be careful in 9 understanding what the task force was trying to
?
10 accomplish and what it was able to accomplish here.
11 In the first place, as I think we have 12 discussed earlier, the task force within its char'ter 13 was investigating items which were really not viewed as
}
14 being direct and, in some cases, not even indirect 15 contributors to the accident, but simply factors that 16 came out as a result of the accident and as a result of 17 some of the subsequent investigations. ,
18 In talking about here (indicating) --
19 talking about the role played'by TMI management relative i
20 to the identified problems, that sentence, to the best 21 of my recollection, was not intended to imply the 9 22 relevance to the fact that an accident occurred, but was
~
23 a much broader statement of the variety of things that 24 is discussed in the task force report.
25 - I do not recall ever reaching the' opinion
4 1 Keaton 750 2 myself that the management structure which existed at l 3 the time of the accident contributed to the accident 4 in any way that I can identify, and I don't recollect 5 that anyone else ever suggested that to me.
ggg 6 Q What about management attitudes, as you used 7 that term when you wrote on December 3, 1979 "regarding 8 the impact of management attitudes on the TMI accident"?
9 A I don't remember exactly what I had in my 10 mind when I wrote that. I am not sure that I was being 11 very careful in the way I used the term "TMI accident."
12 As a matter of shorthand during the
~
13 investigation, we frequently referred to the task force 14 activity as an accident investigation, even though all 15 of us understood thac that was not a particularly 1G accurate definition of it. It was a convenient way of 1
17 referring to it. That may have been the way in which I 18 was using the term there.
19 Q Did anybody on the task force think that the 20 management attitudes had anything to do with the TMI 21 accident?
O 22 MR. GLASSMAN: Did anyone think?
23 MR. WISE: Whether it came up in any 24 ;
discussions that he had, or discussions that he
[l
\-
T 25 had as chairman of the task force, whether that I
l.
5 1 Konton
/'N 2 ever floated through his head at any point.
3 A I do have some general recollection of 4 discussions of management attitudes and the role that ggg 5 they may have played in some of the things that we 6 found at TMI, both good things and things that the 7 task force would prefer to see impre ed.
8 I don't recall the specifica, but I have a 9 vague recollection of some discussions as to whether 10 there was any management attitude or management l 11 decision which could be directly linked to the accident 12 itself. I don't recall that any such was ever identified.
13 I will go further and state that I believe 14 if anything like that had been identified by the task
- 15 force that it would appear in the report.
16 MR. WISE: Could I have his answe* read 17 back?
18 (Answere read) 19 Q So, as I understand what you have said, after 20 all of the task force work was done, to the best of your 21 recollection, the task for ce was unable to identify any 9 22 management attitude that had an impact on the TMI 23 accident?
24 A I believe, to the best of my recollection,
't s) 25 that it is correct to state that the task force did not
1 2
6 1 Konton 2 identify any management attitude where the task force 3 could see a direct link to the fact that the accident 4 occurred.
lgg 5 Q How are you using the words " direct link"?
6 Are you saying that it had some impact, but not 7 distinguishing something out called " direct. link"?
4 8 A No, I wasn't trying to say that. I am 9 having difficulty trying to be very precise in what I am 10 saying. The task force made some recommendations for 11 things which are related to management actions where it 12 felt like there would be adyantages in doing things 13 different in the future. My memory is that the task 14 force did not feel, at least to the extent that I know 15 what the people felt, that those could be --
any of 16 those could be pointed to and say " Hey, that was one of 17 the reasons why the accident occurred." It was rather 18 that there were things in the context of the broader 19- investigation of the task force concerning more than 20 just the issue of the accident itself, but also periphera]
21 factors that came in. That there were areas in which O 22 changes in management practices might be an advantage.
23 Q I guess what I am having trouble with, Mr.
24 Keaten, is your item 30 written in early December 1979 25 states, as something for you to act upon, the development
7 1 Kocton 753 2 of "a specific statement in the conclusion section 3 regarding the impact of nanagement attitudes on the TMI 4 accident."
When I read the final report, what I see in lll 5 6 response to that is a statement that "The task force I'
7 did not perform a thorough review of the role p' layed by 8 TMI management..." et cetsra.
9 What I am trying to understand is what work l
i 10 you did following the writing of your December 3rd memo 1 11 in order to arrive at the conclusion that appears in the 12 final report that the task force had not performed a
(~T , 13 thorough review. The final report was dated December V
14 1980, about a year and a week or two following your 15 De'cember 3rd memo.
16 MR. GLASSMAN: When counsel, in the last 17 question, talked about the task force not 18 performing a thorough review, I assume that counsel 19 was reading a portion of the sentence which says, 20 "The task force did not perform a thorough review ,
21 of the role played by TMI management relative to O 22 the identified problems, primarily because the 23 management structure was signi~ficantly changed 24 from that which existed at the time of the
(
25- accident"?
8 1 KOctGn 754 2 MR. WISE: The whole paragraph for that V[ h 3 matter.
4 BY MR. WISE:
5 g I don't understand how you got on December llg 6 3rd a statement ought to be developed in a conclusion 7 section to a position that a thorough review had not been 8 performed and, therefore, no statement is made about the 9 impact of management attitudes on the TMI accident.
10 MR. GLASSMAN: Is there a specific question 11 pending? I'm sorry, I don't understand.
12 Q In fact, Mr. Keaten, as early as the March 13 24, 1980 draft, you had already drafted and inserted'the 14 paragraph which appears and which we refer to in the 15 final report. You may want to refer to B&W Exhibit 354 16 at the page that has been marked for purposes of this 17 litigation as 7772. I think it is page 32 of the draft.
18 It is essentially the same wording as appears in the 19 final.
20 So, I guess, the question, Mr. Keaten, is:
21 Between December 3, 1979,when you wrote as an action G 22 item to develop a specific statement, and March 24, 1980, 23 when the draft was prepared including the paragraph 24 stating that the task force had not performed a thorcugh 25 review, et cetera, what had'you done in order to try to I
l
~ . , , . _ . . , - _ _. . . _ _ . . _ . . . .-.. ,
1 9 1 Kocton 2 carry out what you had listed as a specific action item.
3 MR. GLAS.SMAN: " Thorough review" again 4 refers to the particular question and not some lll 5 general context?
6 MR. WISE: Yes, to the impact of management's 1
7 attitudes.
8 (Question read) 9 A As I have stated earlier, I have a continuing 10 problem remembering exactly what I did when, but my 11 recollection is that the primary thing I did was to 12 review in my own mind what we had learned relative to 13 management's, at TMI, practices and policies and tried 14 to consider what the task force could, in my opinion, say 15 on this subject that would be accurate and defensible 16 and useful.
17 My conclusions were, as I stated earlier, 18 that with respect to the extent itself, I did not identify 19 any t raceable link from a specific management policy or 20 attitude or action to something that I could point to 21 and say that really was a contributor to the accident.
O 22 I came to the conclusion also, in some of the peripheral 23 issues, that were investigated by the task force that l
'4 there was evidence that a different management philosophy l (^T st l
25 or practice might have some advantages. And that really i
I 10 1 Koston 756 2 is, I think, what was intended by the words, as they
(~T V
3 finally ended up in the task force report. And I think 4 it reflected the general views of the task force.
5 MR. WISE: A few more questions, then we 6 will stop.
7 Q I understand what you have said. What I 8 want to know is not the conclusion that you reached.
9 We have that. It is in Exhibit 354, which is the March 10 24th draft. It is in the final copy of the report. We 11 know the conclusion that you ended up with.
12 What I want to know is what did you do 13 specifically between December 3, 1979, when you wrote CE) 14 your memo saying that you were going to develop or that 15 you would look into developing a specific statement on 16 this issue, and the time that you came to the conclusion 17 on March 24, 1980 that you hadn't performed a thorough 18 enough review, et cetera, as quoted more thoroughly 19 earlier in this transcript. I want to know what you 20 base that conclusion on, Mr. Keaten.
21 Did you go out to make a study? Who did you 22 talk to? What documents did you review? How did you f
23 get from where you were on December 3, 1979 to the 24 point where you were on March 24, 1980 where you wrote
/~T
'\_) 25 what you wroce. That is the direction of my question.
11 1 Kcaton 757
. 2 A As I indicated, my recollection is that one 3 of my principal activities was reviewing in my own mind 4 the information that the task force had obtained as 5 a result of all of the various interviews, discussions 6 and so forth that it had had with various and sundry 7 individuals at quite a variety of levels within the -
8 organization.
9 I believed, during that time period, that I 10 had some additional discussions. I don't remember 11 specifics other than the interview with Brian Mehler 12 that you mentioned earlier. I have a vague recollection 13 of having discussions w$th one or more other members of 14 the task force and trying to help pull my ideas together 15 on this. Those are the kind of activi' ties I remember.
16 Q You don't remember making any specific study 17 or having a TDC performed or anything of that nature?
18 A No, I do not.
19 MR. WISE: One or two more questions on this 20 general area.
. 21 Q Did you become aware in. late 1979 or early l
22 1980 that the Nuclear Regulatory Commission had cited j l
23 Met Ed for certain alleged violations of regulations?.
24 A I was aware in a general sense of that
.(_) 25 activity. I was not personally, heavily involved in the l
l
12 1 Konton 758
() 2 response to that.
3 Q Were you aware that they had made 4 allegations concerning management failures at Met Ed jgg 5 as contributing factors to the accident?
6 A I recall that I read through the document 7 from the NRC which cited Met Ed as you indicated. I 8 don't recall that I made a particularly close study of 9 it, but I did read it.
10 Q Did you have any consultations with anybody 11 who was involved in the preparation of a response to 12 the NRC notice of violation?
13 A Yes, I did on some parts of th'e response.
14 Q Specifically ,with respect to the comments 15 that the NRC had about management?
16 A I don't have a recollection of being involved 17 in the discussions on that particular part of the 18 response, no.
19 Q Are you aware that Met Ed did file a response 20 to the NRC notice?
4 21 A Yes, I am.
O 22 Q That was in late 19797 23 A I don't remember the date.
24 Q Do you recall seeing a letter and statement i
25 by the NRC in early 1980, sometime before March 24, 1980 L
l
. l l
13 1 Kooton 759 I might add, stating that they stood by their comments
) 2 3 concerning Met.Ed management? ,
4 A I recall seeing the NRC response to the Met ggg 5 Ed response. I recall having read certain parts of 6 that. I am not sure whether I read the whole thing or 7 not.
8 Q I believe that was in January 1900. Does 9 that help refresh your recollection?
10 A I'm sorry?
11 Q Do you remember if it had any impact or 12 influence on the work that you were doing on item 30 in 13 your December 3, 1979 memo concerning the impact of V(~'N 14 management attitudes on the accident?
15 A I, frankly, don't remember one way or the 16 other.
17 Q Finally in this area, are you aware that 18 a review of management structure was conducted by Fred 19 Glickman of GPU Service?
20 A Yes, I am.
21 Q were you aware that that review was taking 9 22 place while you were on the task force?
23 A I was aware that the review was taking place 24 while it was taking place. .
\/ 25 Did you ever make any effort in connection Q
l t
(
l 14 1 Konton 760
()
\ ,/
2 with your work on developing a specific statement on the l 3
impact of management attitudes to check with Mr.
4 Glickman and get the benefit of whatever investigation he had performed at that time?
ll) ,5 6 A I did not, to the best of my memory, 7 although frankly I am not certain. I have sort of a 8 vague memory that I might have asked for that report, but 9 in any event, I remember talking to Mr. Glickman as 10 part of his investigation and discussing items such as 11 those that appear in the task force report. I dcn't 12 remember what happened with respect to whether I saw
(}
G' 13 the results of his investigation prior to issuing any 14 particular draft of the task force report. I do not 15 have a memory that I ever learned anything as a result 16 of that investigation that had any particular impact on 17 the task force report. And since that investigation was 18 clearly independent of the task force investigations and 19 was also a report to GPU management, I do not believe 20 that I felt that it was essential that that be reflected 21 in our particular task force investigation.
O 22 Q Isn't it a fact that GPU management wanted 23 to separate out that aspect of the review and that that 24 was the reason why Mr. Glickman's report was done
/~T s' '
/ 25 separately from the GPU task force on the accident?
/, .- -
15 1 Kensen
, 761 2- A I'was.not part of any discussions that I-
~
4 s
3 can recall with respect to setting up Mr. Glickman's
- 4 investigation, so I don't.know what may have been the g 5 motivations for doing it. ,
6 MR. WISE: Let's resume tomorrow.
7 l
(Time notead: 5: 10 p.m.) t r
_8-9
- ROBERT W. KEATEN; 10 subscribed and sworn to 11 before me this day 12' of 1 9 8 2 .-
l ,
1 L
~
j 13
- 14 -
16 I 17 " -.' -
t
. o 16 ,
- ' 19 ' ' '. , ,
p
~ '
20 ., .
-r \ '
T' .,
21 h .
22J- .a
)\e
'i a ,
i y
i, >? ) <
g3 / .*
5- .y
,, rl f , s ' *.' i ~.
, ' k, &
~~' - '
25
,~, t
" Y 'h
- s
,',4
,\
f .
'a .y i -
h s ; ,j !
' l'Y ,_,
%.- , , , , ., _ . . . , , . , , -. .-- ,... . - , , . - . . , _ . _... .,s , _- t . . , - -- . . - - - . , , . - ,
f i
16 1 i 762 i CERTIFICATE 2 jj O- >
STATE OF NEW YORK )
3 ij : ss.:
!! COUNTY OF NEW YORK )
4- j I, CATHERINE Cook , a Notary S Public of the State of New York, do hereby 6 -
I certify that the continued deposition of ROBERT W. KEATEN was taken before 8
me on Tuesday, January 19, 1982 consisting of pages 628 through 761 ;
I further certify that the witness had been previously sworn and that the within l l
transcript is a true record of said testimony; i 13 That I am not connected by blood or 14 marriage with any of the said parties nor interested directly or indirectly in the matter l 16 in controversy, nor am I in the employ of any j II l
of the counsel.
18 I IN WITNESS WHEREOF, I have hereunto set my 19 j
! hand this 3rth day of k\hlalb J -
,1982. [
20 l g j l
91 i
22 . L) ) g
&AMd I
fM L .
23l ,
CATHERINE CVoK ,
l
- o. ,
l
~
T to Janunry 19,.1982 763 IN DE X
['s} s l 1
WITNESS PAGE ;
q Robert W. Keaten 629 EXHIBITS B&W FOR IDENT.
349 Copy of GPU Task Force Interim Summary Report, Second Draft, October 6, 1979. 630 350 Third Draft of GPU Task Force Interim Summary Report, dated l
October 17, 1979, with cover t - -
memorandum. 632 351 Copy of memo dated October 29, 1979 and attached GPU Task Force Interim Summary Report, dated October 29, 1979. 635 352 Another copy of the task force l
report labeled "GPU Accident Review Task Force Interim Summary Report" dated November 28, 1979. 645 353 Memorandum dated December 3, 1979, prepared by Mr. Keaten and entitled TMI-2 Accident Review jlk Task Force - Open Items List. 663 pd
l 18 January 19, 1982 764
}
INDEX OF EXHIBITS (CONTINUED)
B&W FOR IDENT.
g 354 Multipage document entitled "GPU Accident Review Task Force, Final Summary Report,"
dated March 24, 1980. 669 355 Multipage document with cover letter dated May 12, 1980, addressed to Task Force,
Subject:
Final Report." 676 356 Multipage document entitled GPU Accident Review Task Force, Final Summary Report, dated December 15, 1980. 680 357 Memorandum dated September 2, .
,f'T 1980, from Mr. Keaten to k_/ Messrs. Dieckamp, Arnold, -
Clark and Wilson, "
Subject:
Accident Review Task Force Report." 683 358 Copy of some handwritten notes from Mr. Keaten's files. 697 359 Set of handwritten notes bearing the heading "Keaten Task Force Interviews, 0910 hrs., 18 Oct. 79." 698 e e e .
j lIl 1 1
1