ML20100J977
| ML20100J977 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 12/06/1984 |
| From: | Blake E, Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| CON-#484-519 SP, NUDOCS 8412100526 | |
| Download: ML20100J977 (16) | |
Text
30 g .
,, LIC: 12/6/84
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DOCXETED USS?C
'l UNITED STATES OF AMERICA s
- mRY OMSSION '84 DEC 10 A10:37 i L FF CE .7 EEUi T*yv BEFORE THE A'ICMIC SAFETY AND LICENSINGI B'OARDW 'UEEVI J In the Matter of )
)
MLTROPOLITAN EDISON OIPR1Y ) .
) ' Dockst No.'50-289 SP (W ree Mile Island Nuclear ) (Restart-Managment Remand)
Station, Lhit No.1) ) -
STIPUIATION ON MAIIGRN1 EVIDENCE In accordance with the Licensing Board's ruling and suggestions during its Prehearing Conference on Novmber 13,1984, (See Prehearing Conference Tr. at 27,928 to 27,944) arx1 in order to obviate the asserted need for 'DIIA to call Robert C. Arnold as a witness, Licensee hereby stipulates as follows:
- 1. Licensee will not object to the admission into evidence of pages 90 to 100 of robert C. Arnold's October 4,1984 deposition (attached) in which he discusses a September 17, 1980 mmorandum frm E. G. Wallace which has 'been admitted as 'IMIA Mailgram Exhibit 15 in this proceeding.
- 2. % e job titles of Donald H. Reppert, Scott L. Guibord, and William H. Behrle, at the time they cmpleted the work contained in an attachment to the Septm ber 17, 1980 m morandum, were as follows:
8412100526 841206 O PDR ADOCK 05000289 O U I PDR ' '
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Donald H. Fappert - Engineering Associate Sr. II, Safety and Licensing, GPUSC Scott L. Guibord - -Analyst II, Licensing, GPUSC William H. Behrle - Engineer Sr. I, ' Generation, Met-Ed -
Respectfully subnitted '
SHAW, PITIFAN, POITS & TROWBRIDGE Ls c M.
Ernest L. Blake, Jr., P.C.
Counsel for Licensee Dated: December 6, 1984 I
.. 1 Attachment l 90 1 0'eE b bt Q Prior to talking to !!r. -BetKIUiiji?
2 A Yes. I_may have talked to him twice that-evening with 3 bicofante.
hir. {De;ikam@'s conversation being in-between two of them or 4
after the two of them. I have a sense that I talked to hlr.
5 Wilson twice, but I don't have a recollection of two con-6 versations.- The only specific information I can recall in 7
whatever conversation I had with him was his identification 8
of his discussions'with Mr. Volmer of the NRC. And I 9
, don't remember what information hir. Wilson gave me or what 10 were the subject of conversations between him and Elr. Volrre r .
11 Q Do you remember whether or not you received any 12 information prior in time to these conversations with 11r.
IU t
-\ Wilson about what that site group was finding?
1-1 A I do not have any recollection of that and I don't 15 l have any information from what I have reviewed that would 16 indicate what specifically I got from them on Thursday, if 17 anything.
18 Q I would like to refer you now to 5'oore Exhibit One, l 19 Ignoring the top sheet for the moment, that is, page one of 8
the exhibit, have you seen that document before (handing)?
. 21 A This is the top sheet you are referring to ignore (indicating)?
23 q ygg,
" l A I haven't had a chance to read it yet which if you D. -VM- v want to ask questions I will butgfMl answer g+your question is k
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yes, I saw it today befdre'this interview in terms of seeing 2 the document.
3
.Q Now, referring you specifically to page one, that is 4
a memorandum addressed to you from Mr. Wallace; is that 5 correct?
6 A Yes, ma'am.
7 Q It is dated September 17th, is that correct, 8
September 17th, 1980; is that correct?
9 A Yes, ma'am.
10 Q Now, did you receive that at or near.the time it is 11 dated?
12 A I don't know but I don't know anything to the con-13 trary. And I was told yesterday I believe that this was 11 obtained f rom r:y office files or the files I had at the time la.
IdL&Or 00rp.
I was with the [nu, clear corbQ so the best o f my information 16 is yes, I got it but I don't have any recollection.
17 Q Now, given the time frame of September of 1 9 8 0 ,-
18 do you remember whether you got that in the course of pre-19 paring for interviews conducted in the inves',igation of 20 reporting failure by the NRC7 21 A Can I have time to read it, try to refresh my 22 memory because I. don't have any current memory of it.
23 Q Sure.
21 A May I have the question again, please?
25 Q Yes. Alter reviewing that, do you have any laemory
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r 1- of reviewing - let me ask the question again.
2 Given the time of~the document and the date, that is, 3 September 17, 1980, is it your understanding that that was 4
prepared _for you in preparation for the interviews conducted 5 by the NRC's investigators into reporting failures?
6 A That's not my understanding, but I don't have a 7 contrary understanding, either. -s l 8
-Q Do you have any idea why that document was prepared 9 for you by atr. Wallace?
10 A Could you use something other than any iden?
11 I think that --
12 Q Do you have any information as to why Str. Wallace y 13 prepared that for you?
A.
11 A. I don't have any information that I am awa re of as (Ukrj l 15 to [whatner]1!r. Wallace prepared it . p 1
elt I
16 ~Qncr bel, #
Q The subject matter is internal work related to p'py 17 GPU for damage following the Tf!I accident; is that correct? 4 8'" f' n2t\50t a B A That is the subject, yes.
19 Q This is approximately a year and a half after the 20 accident; is that correct?
21 A Yes, ma'am.
22 Q Do you.have any reason to belleve that -- well let 23 qe -- there are cc's to two attorneys, E!r. Blake and 11r.
Seitelo 21 gpriq?
pg , ge, PI) 3 A Only Str. Blake is an honored att orney. 1!r. $+n4ey) k
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m 1 is an engineer. Honored engineer.
2 Q Do you have'any idea at this time why the memo was 3 . prepared on September 17, 1980?
4 A I do not. In terms of what I know about the subject 5 matter it goes back to earlier efforts, as I think that the 6
memo identifies but what prompted kind of pulling together 7
the earlier effort at this time I don't have any information 8
as to why that was done that I can recall, anyway.
9 Q Now, the first portion of this document -- the first 10 enclosure is Mr. Moore's note, is that correct, ten pages 11 of notes? -
12 A I understand them to be Bir. Pfoo re 's , though I 13 certainly don't know anything to the contrary.
11 Q Did you read those notes or that attachment at or 15 near the time you received this memorandum?
16 A I don't have any recollection of that.
ved 17 O. Would you in the normal course of business hav ' eud.
anMnd 18 read the enclosures to him and this memorandum?
B
~ (('{.hYg A It depends on why it was being prepared at the time.
20 I f. --
21 Q I am asking you a more simple question. In the 22 usual course of your business in your position do you review 23 the attachments or enclosures to memorandums of this nature?
21 A And I'm answering you that it depends on what the 25 purpose of the work offort was that I -- in some cases the s -
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answer would be yes; in other cases would be no.
2 Q After reviewing this memorandum and the enclosure, 3
do you believe that this type of memorandum and the type of 4
enclosure in the normal course of business you would have 5 reviewed?
6 A My expectation is that I would have had scanned 7
through it but not looked at it in a great deal of detail.
8 Q Why is that? In terms of your expectations that you 9
would have scanned through it, why is it your expectation 10 you would have not read it thoroughly?
11 A I think --
U Q I am asking now about the enclosures including the 13 Moore notes, 11 A I understand. I think the draft TDR115 I was aware 15 of and probably had looked at closer to the time of prepara tion ,
16 which would have been in 1979, I think.
17 Q So you mdst likely had reviewed that prior to 18 receiving this memo with that document as an enclosure?
D A Yes. Closer to the time when it was responding 20 to the acsignment of its preparation.
21 Q Mr. Arnold, to shortcut this I am talking now 22 specifically about the Moore notes. You had never seen those, 23 I assume, prior to receipt of this memorandum on September 17, 21 1980?
15 A s -
I don't know if I did or did not.
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I l 95 k I Q So~you may have?
2 A Yes.
3 Q Now, are those the kind -- is that the kind of 4
information you would have reviewed carefully at the time?
5 A- As I indicated earlier, I don't think so. I think
- p 6
that in scanning through it I became interested at the level 7
at which I would suggest careful reading of it) I would have 8
gotten together with the preparer of the notes to deal more 9 directly on it.
10 Q tir. Wallace?
11 A 31r. Lloore I think we said it was.
12 Q I-am sorry. I thought you meant the person who
'{ 13 prepared the memorandum, lir. Wallace.
Il 11R. KIRSCIIBAU11: That is not what he said.
15 BY !!S. BERNABEI:
I6 Q You said you would have gotten.together with the 17 preparer of the notes?
18 A Yes.
19 Q That is tir. Lloore?
20 A Yes.
21 Q Nowi so what you are saying is you may not have 22 read them carefully but it is likely that together with !!r.
U atoore?
28 l A No. I am saying if at that time I had -- and I E
am answering a speculation because that was what the question L
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d 1 asked me to do.
2 Q I am not asking for speculation. I am asking in 3
the usual course of business what you do.
4 First of all, you told me you scan it. Then you 5 said, listen, I have seen some of this before. )!y usual course 6
of business is enclosures of this sort I would have scanned 7
and I said to you it seems pretty important to you.
8 A That is not what I said.
9
!!R . KI RSCllB AUll: Let him finish.
10
!.1S . BERNABEI: He is not answering my question.
11 BY hts. BERNABEI:
12 Q These notes, would you have read them carefully in 13 your usual course of business?
It A I don't know.
15 Q You don't know. How would you have determined 16 whether to read those notes carefully or not given the copy 17 of the memorandum to the notes?
18 A
And I don't think I can answer that without knowing 19 what prompted the preparation of the memorandum and the 20 pulling together of those. It may have been something that 21 was just pulling into a particular documentation, something 22 that I was already familiar with, although I don't in this 23 case have a recollection. I get probably literally tons 01 21 documents in the job I was in at that time and I don't read 25 all of them thoroughly. I had to make a judgment or I had to s
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2- Q Did you ever read Str. h!oore's note prior to a few 3 days ago in preparation for t.his deposition?
4 A 1 read %!r. hiocre's' notes during the time in which 4 5 response to interrogatories were being provided.- I don 't i
6 recall looking at ten full pages of them.
- 7 Q Can you remember what time period we are talking i 8 about?
9 A Four weeks ago maybe. .
10 Q Four weeks.ago. Now, when you reviewed those notes
! 11 at'that time did you remember that you had reviewed them at a
! 12 prior tim 6?
b '
13 A No, I did not.
} l1 Q Did you remember whether you had spoken to t!r. Moore i
15 about the information contained in those notes at a prior 1
j 16 time?
i 17 A I have no recollection of ever talking to 5!r. Moore 18 about this note.
{
I j 19 Q Do you have any recollection that you obtained the j 20 information contained in those notes regardless of whether 1
j 21 you talked to 1!r. h!oore personally about that information?
- 22 A Obtained it when?
! 23 Q At any time. '
i St A hell, I'd have to go t hrough them item by item.
25 i Q Let me ask you a specitic point. Do you have any i /
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' indication that )lr. Moore wa.s in formed on Ma rch 2Sth tha t in-
- - 2 core temperature readings over 2500 degrees were indicated at 3 Three Mile Island?
4 A Not to my knowledge or recollection.
5 Q It is your' testimony that Mr. Moore never informed 6
- you either himself or through others on March 28th or 20th 7 .about his learning that fact?
8 A Yes, ma'am.
9 Q And it is your tastimony that that's true even-10 thotagh Mr. Moore has testified that he believed those 11 temperatures indicated to him core damage?
12 A Well, I don't know what he testified to but my
', 13 answer --
14 Q I am telling you.
15 A My answer stands with regard to your previous 16 question.
17 Q And even though Mr. Moore said he reported these A
to Mr.go$ro03h4n cal and he believed it was common information in 19 the observation center?
20 MR. BLAKE: Excuse me. What was that representation?
21 BY MS. BERNADEI:
22 Q That other people in the observation knew about it 23 and he would believe, had communicated it.
Si
!!R. KIRSCl!DAUM: You are asking whether that changes 25 this witness' testimony?
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It doesn't change my testimony.
A 2
BY h!S. BERNABEI:
3 -
- Q You still contend 1!r. h!oore never told you about those 4
temperatures y eMhl@
either himself or through others such as Mr.
5 op.hlr. Wilson?
6 A Yes. I would even go further and say that I'm
~
confident that in the time frame you are talking about I had 9
no know1dge of any temperature indication of in-core 9
l thermocouples in that range.
10 Q Now, to ydur knowledge, did anyone undernoath you II
- have information of that sort on hiarch 2Sth and 2. larch 20th? .
12 i I am talking about in your organization, servien corporation. {
- 13 A The only knowledge I had about any possibility of Il l that being the case is whatever is meant by these notes with j 15 the one entry I believe that -- which I don't know myself what 16 i
l it means and the awareness that I guess one person indicated II i
1 in response to a questionnaire that all of us filled out, 18 i
! that he know*something on Wednesday but all of that is I9
} very recent awareness. Nothing in the time frame of 1978 --
E the time frame of the accident in !! arch of '79.
al Q Who is this person you are referring to, somebody '
i ~
knew on We nesday --
23 Id n .
A Q}e*Mnh I think is the individual that -- at least ei s' his initial answer.
, Q You are familiar with --
1 .
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A Let me just clarify, I may he wrong in my under-2 standing. I did not look at his survey answer.
3 Q Now, you know of tir. s mail-o-gram to 4
Congressman Udall; is that correct?
5 A Yes.
6 Yeedw?
Q Did 5!r. M consult with you about that mail-o-7 gram or any of the in formation on that mail-o-gram?
8 A Not to my understanding.
9 Q Now, were you at a Board of Directors meetint prior 10
-- or any of the surrounding meetings prior to an annual II meeting that wa s hel d on 5!ay 8 t h o r 9 t h ?
12 A Of 1970?
13 Q Right.
l'I j A Do you recall where it was held?
15 5!R . BLAKE: I think I'll be happy to represent that 16 I think it was in the Johnstown area and I say that because I 17
'eQVowf know 11r. aikamd's mail-o-gram came from the Johnstown area.
18 I don't really know for sure, but that is my understanding.
19 A 11y, my recollection is that I did not attend that 20 annual meeting. I don't think I have ever been to one that 21 was held in Johnstown and if we had time there's a funny 1ittle en story as to why I remember I wasn't there.
23 BY hts. BERNABEI:
21 Q So you remember no conversations or consulLations D. Wte C.NM with h!r. IMamp fregarding the mail-ee-gram prior t., its being
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UNITED STATES OF AMERICA NtX1 EAR REGUIA'IO:N OGMISSION BEFORE THE A'IGiIC SAFE 1"I AND LICENSING DOARD In the Matter of )
)
MEITOPOLITAN EDISON CNPMN )
) Docket No. 50-289 SP
('Ihree Mile Island Nuclear ) (Restart-Managcment Rcmand)
Station, Unit No. 1) )
CERTIFICATE OF SERVICE A copy of " Stipulation on Mailgram Evidence", dated Deccnnber 6,1984, was served this 6th day of December,1984, by hand delivery to the parties identified with an asterisk and by deposit in the U. S. Mail, first class, postage prepaid, to the other parties on the attached Service List.
Respectfully subnitted, SIIAW, PITINAN, POITS & TPOGRIDGE b
Ernest L. Blake, Jr. , P.C.
Counsel for Licensee
r
~,e. s. ...
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING SOARD In the Matter ) *
)
METROPOLITAN EDISCN CCMPANY ) Docket No. 50-289 SP
) (Restar Romand on Management)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
SERVICE LIST Nunzio J. Palladino, Chairman
' U.S. Nuclear Requiatory Cc= mission Administrative Judge Washington, D.C. 20555 John H. Buck Acc=10 Safety & Licensing Appea; Ihc=as M. Rcherts, Commissioner Board U.S. Nuclear Regula: cry Ccmmissien U.S. Nuclear Regulatory Ccmmiss; Washington, D.C. 20555 Wasning cn, D.C. 20555 James K. Asselstine, Cc=missioner Administrative Judge U.S. Nuclear Regulatory Ccmmission Christine N. Xchl Washington , D.C. 20555 Atomic Safety & Licensing Appea*
. Board Frederick Sern hal, Commissioner U.S. Nuclear Regulatory Ccamass; Washington, D.C.
U.S. Nuclear Regulatory Commission 20555 Washingten, D.C. 20555
- Administrative Judge Lando W. Zack, Jr., Ccmmissioner .. Ivan W. Smith, Chairman U.S. Nuclear Regulaccry Cc= mission Atomic Safety & Licensing Scard U.S. Nuclear Regulatory Cemmass; Washington, D.C. 20555 Washington, D.C. 20555
' Administrative Judge ,
Gary J. Edles, Chairman
- Administrative Judge Atomic Safety & Licensing Appeal Shelden J. Wolfe Board Atomte Safety & Licensing 3 card U.S. Nuclear Regulatory C0mmission U.S. Nuclear Regulatory Ce mass.-
Washington, D.C. 20555 Washingten, D.C. 20555 L.
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- Administrative Judge Mr. Henry D. Hukill Gustave A. Linenberger, Jr. Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation '
U.S. Nuclear Regulatory Commissicn P.O. Box 480 Washington, D.C. 20555 Middletcwn, PA 17057 Docketing and Service Section (3)
Office of the Secretary Mr. and Mrs. Norman Aamcdt R.D. 5 U.S. Nuclear Regulatory Commission Coatesville, PA Washington , D. C. 20555 19320 Atomic Safety & Licensing Board
- Ms . Louise Bradford Panel TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C. Harrisburg, PA 17102 20555 Atomic Safety & Licensing Appeal
- Joanne Doroshow, Esquire Board Panel The Cnristic Institute U.S. Nuclear Regulatory Commissica 1324 North Capitol Street Washington, D.C. Washington, D.C. 20002 20555
,,ynne Bernabei, Esq.
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- Jack R. Goldberg, Esq. (4) G vernment Acccuntability Office of the Execu :ve Legal _S5Ci"C -
D ~' ~-
~ a***c... :sa Connecticut Avenue -
U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Washingten, D.C. 20555 Ellyn R. Weiss , Esq. -
- Th;=3s Y AG, Esq. 3armen, Weiss & Jordan
- 00L 5 Street, y.x,' '...
s Office of Chief Ocunsel W a s P*" ~* - ' ' "~ ' D'"
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l Oecart=ent of Envarenmental '
i 3escurces Michael F. McBride, Es~,
303 Executive Mcuse P.O. Ecx 235' *aaceuf, Lamb, Leiby & MacRae Harrisburg, PA 17120 1333 New Hampshire Avenue, g*w*
setze troo Washingten, D.C. 20036 William T. Russell Deputy Director, Division Michael W. Maupin, Esc.
of Human Facters Safety Hunton E Williams Office of NRR Mail Stop AR5200 707 East Main Street P.O. Box 1535 U.S. Nuclear Regulatory ~
Rich cnd, 7A Commission 23212 Washington, D.C. 20555 f
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