ML20136H402

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Intervenor Exhibit I-32-J,consisting of Pages 17-28 of Transcript of M Ross 840927 Deposition in Harrisburg,Pa Re Change from Depressurization to Repressurization Strategy
ML20136H402
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 12/14/1984
From: Ross M
AFFILIATION NOT ASSIGNED
To:
References
SP-I-032-J, SP-I-32-J, NUDOCS 8508200301
Download: ML20136H402 (14)


Text

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aa. j UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Ba'ard In the matter of  : .

METROPOLITAN EDISON COMPANY  : Occket Ns. 50-289 (Three Mile Island Nuclear  : (Restart-Management Station, Unit 1)  : Phase)

Deposition of MICHAEL ROSS -

Taken by: Three Mlle_ Island Alert .

Before: . Carol A. Keefauver Beginning: Thursdays September 27, 1984 2:30 p.m.

The.Felends Meeting House Sikth and Herr Streets Harrisburgs Pennsylvania APPEARANCES: p c6 s

LYNNE BERNABE1, Esquire pece:23 o The Government Accountability Project p '

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7' ( c l ;'cu JOANNE 00ROSHOW, Esquire ,v~ .

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The Christic Institute ,

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and su:un arcnanar nosessues LOUISE BRADFORD mb'we-[d-2Y7 m em*:ein.4 I 8 '

m n.e wu es N T), 6

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For - Three Mile Island Alert /

n er ... ,etannend LOIS FINKLESTEIN, Esquire **"""----.--- untrvan V- 1!

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For - The NRC Staff tweewr. --.-

sw:w.r.-. - -_u&APl_QT/ i SHAW, PITTMAN, POTTS AND TROWBRIDGE _ y' .

ERNEST L. BLAKE, JR., Esguire s j Wash lnotono D.C. '"ert**.- A IL]2 For - Licensee ,

1 B508200301 e41214 DR ADOCK C E

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/ . *

's AFFEARANCES (cont'd.): .. .

SHAWS PITMANs POTTS,and TROWBRIDGE ERNEST L. BLAKEs JR., Esguire Washinstens D.C. ,

and ,

LYMAN & SHAW

  • F. FRANK LYMANs Esquire 953 North Glebe Road -

. Arlington, Virginia 22203

, for - Depanent e

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l Q March 28th?

A No.

s Q You remember any discussion about the possible .

seneration- passible chemical reactinn or an exploslans l

. i agains an' March 28th? -

A No. ma'am.

Q Nous in the afternoon of March 28th, there was a chanse made from a depressurization to a repressure stratesys is that correct?

A I don't c'ecall talking to Mr. Herbeln.

J Q Do you remember in any pelar testimony that you stated that Mr. Herbein called you to tell you to repressurize?

A My recallectlan is the word came from Herbeins but I think it came directly 'ta me. .

l.

Q Do you remember any prior testimony which you said--I will repeat the question.

A Okay.

Q Had Mr. H'erbeln called you to tell you to repressurize?

A Called me personally? Called uss yes. I do l remember. ,

Q Called us. When you say uss you mean?

A Called in. .

Q Called in?

A Yeah. \'

Q And at what time was that? -

.; .y

'A I don't remember the time.

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. A Q And from where was Mr. Herbein callins?

-A News I'm not sure of that. '

Q And whos other than yourselfs did he call?

A I don't remember who he talked to. .

J Q Mr. Herbein save the direction regarding repressurizations is that correct?

A That's my recollection.

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Q News do you remember whether it was at-a time when Mr. Miller was at the sites or Mr. Miller was absent from the site? .

A My recollectian is Mr. Miller was at the

- site 3 l Q Are you certain of that?

A It's my recollectioni it's five years old.

Q I'm asking you are you certain of that. If you're i

not, I can understand that.

A No, I'm not certain.

Q Do you remember if Mr. Herbein called you d'irectly, or you heard about it from another source?

A He did not call me directly.

[ Q- To whom did he place the call?

r j A l's net sure who he called.

'O And how did you learn about the change in strategy

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l ordered by Mr. Herbein?

A I believe it came from Mr. Miller to me. .

Q And was Mr. Miller at the site at the time he

". i informed.you of this change?

A That's my recollection.

Q Nous it 8 s fair to say that Mr. Miller was away from the site for about a two-hour period, is that correct? Twas

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two and a half hourse about 2 to 4:307 A He was away for some time. Agains I'm not exactly I

- sure of the amount of time..

Q And during that times did you have any conversations with hims whether by telephone, by radios or by other means of communication? .

A With him as Mr. Mill'er? .

Q Yess I'm sorry.

. A No.

Q Did you have any communications with Mr. Herbein?

4

A Not that I'm aware of.

Q Not that you're aware of?

A No.

Q I'm sorry-- ,

i A The answer was. Not that I'm aware of. Not that I remember.

Q Not that you remembers okay. To your knowledge did Mr. Miller have any communications with the Unit-IIscontrol l room,during the time he was away? ,

A Not that I remembee. yw Q Do you know if Mr. Herbelr had any communications

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- with the control room during the time Mr. Miller was away?

A I don't remember.

Q On March 28the did you at any time speak to ,

Mr. Herbein directly about anything soins on with TMI-II?

A I don't recall.

Q You don't recall?

A No. ,

Q No.

j Q Do you know that Mr. Herbein had radio t

communication wi(h the Unit-II control room?-

A I recall radio communications, but I'm not sure it was March 28th or sometime after.

Q It may have been the 28th?

4

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A I saids. I'm not sure.

Q Okay. And that was between Mr. Herbein and the Unit-II control room, is that correct?

A There were radio communications between Mr. Herbein and the control room.

Q And Mr. Herbein was located, was he not, in the observation center?

A Yeah. And I' don't recall exactly what day that was. But pass he was there sometime.

f .

Q Now, leaving aside for the moment what the date was, if Mr. Herbein--at the times Mr. Herbein communleated with the control ecom, with whom did he communicate?

A I don't recall.

Q Uell, would it have been Mr. Miller?

A I den't recall.

'bD~ . -- . .

j

'. Q So it could have been. You don't remember if he i communica.ted solely with Mr. Miller or with others? .

A .

I don't ' recall. No. .

! Q. Mr. Herbeln had a good understanding of--or he would appear to have a good understanding of what was sains i

on at Unit-II, would he not, during this period? I'm talkins

+

aboute nous during the afternoon time of March 28th.

A I don't know. I'm not in that position to know what his understanding was.

O Wells there was some communications was there nots r

between the Unit-II control room and Mr. Herbeln?

A I'm not sure. ,

l I Q Do you know if Mr. Herbein was being informed of what was scing on at the Unit-II7 A Nos I don't.

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l Q You have no idea? i A I don't know if he was belns informed or not.

] Q Okay. Do you have indication on the basis in which  !

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. Mr. Herbain ordered repressurization in the afternoon or  ;

evening of March 28th?

A No.

, Q So you don't know what information he had available l to make that decision? .

A No.

Q Do you know of any participation by Mr. Arnold in any.cf the decisions regarding the reactor on March 28th?

A Nos ma'am. -

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. Q Do you know any stratesies or other recommendations

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. . - - - , - . - - - -.= - . -- .

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  • 4 Mr. Arnold or his.GPU Service Company engineers recommended?

A ,

No. . t 1

Q It's fair to say then you were not familiar with .

! the discussion surrounding the decision to repressurize?

A I was involved in discussion on repressurization in the think tanks yes, ma'am.

Q Now, we're talking about the afternoon, is that 4 correcti not the morning, the afternoon?

A Yeah. They kind of run together for men but the afternoon we had made a decision to repressurizes also.

f Q Okay. And you're not sure when that decision was made?

- A No.

But Mr. Herbein was the one who save the.

Q Okay.

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. order to do its is that correct?

4 A That's my recollection. j

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Q Now, the discussions' you're familiar with, who was  ;

included in those discussions?

l A You're talking about--

4 Q To repressurizes I'm sorry.

i A Wells the think-tank group made some decisions on i

i repressurization ands in fact, were Instituting that when the word come to do it. ,

G Oh. Okay. And what decisions were taken?.

A To start a repressurization action.

Q Okay. Who were in on those discussions?

A There were a group of peopisi Mr. Millers Mr. Rogers, myself Mr. Kunder.

Q Anybody'else?

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A I bolicvo Mr. Lecon.

, Q How about Mr. Chwastyk?

A Mr. Chwestyk was not a member of the think tank.

Q ,

You don't know what time's decision was made, is -

that correct?

i A No. I'm not sure of the exact time.

Q Nous if I understand your testimony rights some of l

, the decisions were made in the think tank and some were made by otheess is that correct?

A Wells the information was belns relayed from the think tanks at s'ame times back and forth.

l I Q Back and forth to where? , ,

A On the site area. I'm not sure who Mr. Miller was

. talking with at that time. But some decisions were made in 4

the think tanks and they were trying to be relayed to other interested personnel. I'm sure B & W was being told some' 4

Information at that times also.

Q Okay. So I've not you correctly, there were discussions in the think tanki information from those discussions was relayed to off-site persons, is that correct?

! A Yes.

Q And I assusa you mean, Met Ed or GPU Servies l Company?

A Yes.

Q And as well as to B & W7 A Yes.

i Q Now, to whom was this information relayed in terms of the GPU Servlee Company or Met Ed people?

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b . A That I'm nut ouro.

Q To Mr. Herbeln?

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A Again, I stated previouslys I'm not sure.

  • Q Do you know any one of the Individuals to whom this

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Information was relayed? .

A I did not talk to them myself.

Q How about the B & W people?

A Againe I did not talk to them myself.

I Q That's not what I asked. I said, do you know any one of the individuals who was consulted or who salned knowledge of ,the think tank discussions?

A News Mr. Rogers had discussions with somebody in the front office.

Q Do you know of any discussions with any* individual in Parsippany concerning your discussions in the think tank? '

A I don't know specificallyi I do not talk to them.

Q That really wasn't my guestion. I asked yous do you know of anyone to whom information about the think tank l-was relayed?

A No.

Q It's your testimony that some of the discussions

regarding repressurization were made on sitel some were made  ;

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off site?

A I don't know if the final decision was made totally l on site. I'm saying the discussions, and our desire was to do that. Mr. Miller relayed what he wanted done. Where he got his information, I'm not totally sure. Some of it came cut of the think tankt some of it, I'm sure, came off 9

t site.

Q You say relay. Was he at the site at the time he relayed what he wanted done? ,

A, Mr. Miller? He was with use yes.

Q It's still your testimonye however, that ,

Mr. Herbein ordered the repressurirations is that right?

A My understanding is that he ordered its at least the words I got that he ordered it to be repressurized.

Q Ands of course, Mr. Herbein is above Mr. Millers is that not right?- .

l A That's correct.

l 4 Q Did it appear to you, at the times that those 4

- instructions Mr. Miller was transmitting were backed--

authorized by Mr. Herbein?

A Could you ask that agains please?

O Sure. You said that Mr. Mill ~er was giving some kind of instructions regarding repressurizationi were thoses in your understandings authorized by Mr. Herbein?

A My understandings yes.

Q Okay. So it is fair to say that Mr. Herbein was giving the authority to Mr. Miller to make any decisions he made? In other words: he wasn't acting counter to any instructions or guidance from Mr. Herbein?

A I have no way of knowing that.

Q As far as you known all directions or orders Mr. Miller save were authorized by Mr. Herbeln, is that .

correct?

. A I have no way of knowing that all orders were given

'- ' - by hic.

Q You have no reason to believe that Mr. Miller's orders or directions were not by Mr. Herbein, is that careect?

A I have no reason to believe that.

Q News prior to Mr. Miller giving any Instructions or -

directions regarding the repressurization stratesys Mr.

Herbein had authority or directed its had he not? In other words: Mr. Herbein's direction was previous in time to Mr. Miller's directions or instructions?

A That I'm not sure of. My recollection is that we were in a process of starting a repressurization action when that came through.

i Q And it is fair to say that the first act or action which Mr. Herbein ordered was the closing of the block valve?

l Is that correct?

4 A I don't recall :.ha t .

4 Q But he did directly order closing of the block j valves did he not?

A I don't recall that.

l

{ Q Let me ask you thiss that is a part of the .

repressurization stratesys is it not?

A Yes.

Q News do you remember testifying at any prior time -

that Mr. Herbein ordered closing of the block valve?

A I don't recall.

Q Okay. Mr. Rosss I'd like to cite from a portion of Mr. Kunder's testimony before the Senate a'nd ask you to

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refer to it and see if that refreshed your recollection of )

any order Mr. Kunder excuse mes Mr. Herbein might have given ,

regarding closing of the block valvw. Specificallys I'm

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going to refer you to Page 28 and 29 of Mr. Kunder's l testimony before the United States Senate Subcomalttee on Nuclear Regulation of the Committee on Environment and Public Works. August 22s 1979.

A Nos ma'ans that doesn't refresh.my memory.

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Q Just so that I understand yous the think tank had  !

made decisions and taken certain actions to repressurize at the time Mr. Herbein gave instructiones is that correct?

A My recollection is that we had discussed it and either had taken some action or were talking about action when the order came through.

Q News if you remembers what actions were taken to repressurize? I'm talking about the specific action of the reactor.

MS. WAGNER Are you talking about before or after?

MS. BERNABEI I'm talking about before any repressurization took place.

BY MS. BERNABEI Q Mr. Rosse do you understand me?

A No.

Q Okay. Okay. What steps were taken in the repressurization strategy?

A That I'm not sure of.

O Welle any chronology?

r .. >

A I don't recall. ,

l Q Or seguence of events would show thats would it not? And of the numerous seguence of events that have been done in the accident? .

A: I don't knows they should.

Q Do you know of any Instructions or directions by Mr. Arnold or the GPU Service Company people regarding the repressurization strategy at any time in the afternoon of j

March 28th7 MR. BLAKE: Objection to the question.

MS. BERNA 8EI You can answere Mr. Ross.

4 MR. BLAKE: Go ahead and answer.

i THE WITNESS: Could you restate the guention. 18 e sorry.

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,. BY MS. BERNABE!: ,

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Q Do you know of any instructions or directions Mr. Arnold or his people from Parsippany gave regarding the f

repressurization strategy in the afternoon of March 28th?

A No.

MS. BERNABE! I have no other guestions.

1 (Whereupon, a belef reces was taken.)

i CROSS EXAMINATION i

BY MR. BLAKE:

Q Mr. Rosse earlier in Miss Bernabel's examination you testified in response to a guention from Miss Bernahei that you heard a noise about 1:50 p.m., March 28th when you l

were in the Unit-II control rooms is that correct?

A That is correct.

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