Document rpm91Z83neJY6vnXVk3Rn6OQE

<K 3/16/93' DIEHL 1 1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 4 NEVADA POWER COMPANY, 5 a Nevada corporation, ) ) 6 Plaintif f, ) ) 7 vs . ) ) CASE NO. 8 MONSANTO COMPANY, a foreign ) CV-S-89-555 ) LDG-LRL corporation; GENERAL ELECTRIC ) 9 COMPANY, a foreign corporation; ) WESTINGHOUSE ELECTRIC ) 10 CORPORATION, a foreign ) corporation; and DOES I through ) 11 XXV, inclusive, ) 12 Defendants. ) __________________________________________ ) 13 14 15 DEPOSITION OF JOHN H. DIEHL 16 Taken at Law Offices of Alverson, Taylor, Mortensen & Nelson 17 3821 West Charleston Boulevard Las Vegas, Nevada 89102 18 On Tuesday, March 16, 1993 19 At 11:30 A.M. 20 21 22 23 24 Reported by: 25 CHERYL GARDNER, CM, RPR C.S.R. No. 230 3/16/93 ' DIEHL 26 1 Clark? 2 A. Dale Inglebrecht' (phonetic), 3 and I was going to spell it for you but -4 Q. I'm not going to require you 5 to. Were the operations manuals for the three 6 smaller transformers removed at the same time back 7 in 1988? 8 A . N o , sir. 9 Q . What happened to the operating 10 manuals for the three smaller PCB transformers? 11 A. Well, at Clark they did not 12 remove them at that time at Clark so I made an 13 error. At Clark the small ones were removed I 14 believe in *90, some at that time. 15 Q, At that time the manuals were 16 removed as well? 17 A . Yes. 18 Q. All right. Let me just focus 19 on the six PCB transformers we talked about at 20 Clark. In 1988 three of them were removed, 21 replaced with dry type transformers, and the 22 manuals were removed at the same time; is that 23 correct? These were the larger transformers. 24 A . Yes. 25 Q . And then two years later in LAURIE H. WEBB, LTD (702) 386-9322 i |A 3/16/93 DIEHL 27 1 1990 what you referred to as the smaller PCB 2 transformers and their manuals were also removed? 3 A . Yes, sir. 4 Q . T h a t l e a v e s t h e three 5 retrofilled transformers that are still at the 6 Clark station; is that correct? 7 A . Th a t 's true. 8 Q. Where are the manuals for the 9 original manufacturer's manuals for those three 10 retrofilled transformers located? 11 A. Controlroom. 12 Q. Who manufactured the three 13 retrofilled transformers? 14 A. I think those were G E . 15 MR. TATLOCK: Counsel, I don't believe 16 those manuals have been produced, but I'd 17 appreciate it if you'd check to confirm whether or 18 not they have been produced, and if they haven't , 19 I'd like to get copies of the original transformer 20 manuals for the three Clark transformers as well 21 as any supplements. 22 MS. STRAUB: I'll check into that. 23 MR. TATLOCK: Thank you. 24 Q . How many PCB transformers were 25 located at the Sunrise generating plant? *#*#* LAURIE H. WEBB, LTD. (702) 386-9322 i 11 .i 3/16/93: .DIEHL 28 1 A. I wasn't involved with that 2 project, s o , I'm unsure. 3 em Who -would -- who at Nevada 4 power would have the best information about the 5 PCB transformers located at the Sunrise generating 6 plant? 7 A. I can only think of Dale. 8 Q. Mr. I think Inglebrecht? 9 A. (Nods head affirmatively.) 10 Q. But I believe you have 11 testified that there were PCB transformers located 12 at the Sunrise generating plant. 13 A. Yes. I was going to tell you 14 they were retrofitted, but I would have been -- 15 that's only my memory. 16 Q. Are there manuals for the PCB 17 transformers located at the Sunrise plant, 18 operating manuals? 19 A. That would be an assumption. I 20 don't remember seeing them presently. That's our 21 procedure, though. So, it's Nevada Power's 22 procedure. 23 Q. Well, what is Nevada Power's 24 procedure with respect to operation manuals for 25 generating plant transformers? LAURIE H. WEBB, LTD. (702) 386-9322 ik 3/16/93 DIEHL 29 1 A. They are kept in the control 2 room. 3 Q . A t .al1 times 7 4 A . At all times. 5 Q. And if the equipment is removed 6 from the system, actually physically removed from 7 the generating station plant, is it also Nevada 8 Power's policy to remove the manual at the same f 9 time? 10 A. In the procedure that I v 11 described before having any turnover package 12 everyone saying it is complete, the job is done, 13 new manual, old manual. 14 Q. And the procedure at the Clark 15 station you described for the retrofilled 16 transformers, was that the original transformer 17 manual stayed in the control room because the 18 transformer stayed in the generating station. Is 19 that also the practice? 20 A. Yes, then only the portion no 21 longer applicable would be exchanged. 22 Q. Let's go back to the Clark 23 substation -- excuse me -- Clark generating 24 station transformers. What portion of the manuals 25 would no longer be applicable for the Clark vs-i&IpKe&k,*--' LAURIE H. WEBB, LTD. (702) 386-9322 i t-e *r n ____x. u j. J--------------- j - * " IT ;& .k 3/16/93 DIEHL 30 1 retrofilled transformers? 2 A. The PCB information as to 3 insulating value, procedures, et cetera, 4 to do -- the insulating oil portion would be no 5 longer valid. 6 Q. So, any portion of the 7 operating or instruction manual that dealt with 8 PCB insulating fluids would be removed from the 9 manual as part of the turnover package; is that 10 correct? 11 A . That's true. 12 Q. So, if there were anything in 13 the manual in the control room for those 14 retrofilled transformers relating to storage, 15 handling, replacement fluids, or the PCB 16 insulating fluids, that would no longer be in the 17 manual if we were to go look at it today? 18 A. That's true. 19 Q . And is it also accurate that 20 Mr. Turley or Mr. Inglebrecht would be responsible 21 for replacing those sections of the original 22 transformer manuals when the turnover took place? 23 A . That is true. 24 Q. And at the Sunrise generating 25 plant the transformers, as you recall, were fr 5' LAURIE H. WEBB, LTD. (702) 386-9322 __________ ih_______________________ -w_____ __________ 3/16/93 DIEHL 31 1 retrofilled or retrofitted, the insulating fluid 2 sections of those manuals would also have been 3 replaced? 4 A. That is true, sir. 5 Q. At the West Side Diesel 6 generating plant, how many PCB transformers were 7 located there? 8 A. None, sir. 9 Q. Never were? 10 A. Never w e r e . 11 Q. How many transformers were 12 located there during its operation from *64 to 13 90? 14 A. One large. That should do it. 15 Q. What capacity was that one 16 large transformer? 17 A. I'm not sure, but I believe it 18 was a 10 KVA. 19 Q. Did the generating department 20 maintain a record of the documents that were 21 destroyed when the PCB transformers were changed 22 out? 23 A. Yes . 24 Q And who has that list of 25 documents that were destroyed when the PCB LAURIE H. WEBB, LTD. (702) 386-9322 ^ 1 1 GA n f ^ f V\ C 4- A+* T.ae \7 a * * On 1 a ^  i l ____________________________________________________ - L. 3/16/93 DIEHL 32 1 transformers were changed out? 2 A. The project department, GE&C, 3 generation, engineering and construction. 4 Q. So, if the original manuals for 5 the PCB transformers that were removed from 6 service at Reed-Gardner had been destroyed, GE&C 7 would have a list by title of the manuals that 8 were destroyed; is that correct? 9 A. Yes, sir. 10 Q . For the Clark generating plant 11 transformers that were retrofilled, is it also 12 accurate to say that the GE&C Department would 13 have a list of those sections of the operating 14 manuals that were destroyed when the retrofilling 15 took place? 16 A . Yes, sir. 17 MR. TATLOCK: Counsel, I also believe we 18 have not received copies of the indexes or lists 19 that M r ; Diehl just described concerning the 20 manuals that were destroyed when the transformers 21 were changed out at Reed-Gardner and Clark and 22 probably Sunrise if his testimony is accurate 23 about the retrofilling, and I request that we get 24 copies of those as well. 25 MS. STRAUB: I will check into it. LAURIE H. WEBB, LTD. (702) 386-9322 R1 7 firm f h Qt li C f r a a f T.ae V a n a c Hairarla ogi n i DATE: ~P-_________ /'/- *F3 TO : PBQQy A. Leen, Esq. c?*sni^L FRO M : D & . b o r G*h> f*\.a ,} FAX **: (TOS) 366-0327 PHONE 4f*: (7Q2) 366-0622 C LIE N T/M A TTE R : Nevada Power v. M onsanto, Qt al. C LIE N T/M A TTE R N O .: 11927.2 OOCUMENT(G) DESC RIPTIO N: C of*-/ e>/~ s~3 O '* - A j r - z -5*^ ^ =V *- 1 - - o s~ c * -e , NUM BER OP PAGE6 (In o lu d ln g o o v o r p a g e ): MESSAGE: Cot^y /e ^iV /'V * ^ A . <s//* < --3 IP YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, 1 5a s kplease call (702) 305-4202 and fo r: Robert O atorloh, Ext. Q TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT ** TOTAL PAGES SCANNED : 4 TOTAL PAGES CONFIRMED : 4 *** SEND *** No. REMOTE STATION START TIME DURATION #PAGES MODE I PEGGY LEEN 7-14-83 2:20PM 2 '36" 4/ 4 ___ NOTE: No. OPERATION NUMBER 48 PD POLLED BY REMOTE SF MB SEND TO MAILBOX PG TOTAL 0:02'36" 4 4800BPS SELECTED EC STORE & FORWARD RI POLLING A REMOTE MP ERROR CORRECT RELAY INITIATE MULTI -POLLING RESULTS COMPLETED 9600 G2 G2 COMMUNICATION RS RELAY STATION RM RECEIVE TO MEMORY