ML19256B640

Deposition of B&W by Jj Kelly on 790707 in Lynchburg,Va. Pp 1-56

ML19256B640
Person / Time
Site:	Crane
Issue date:	07/07/1979
From:	Joseph Kelly BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE
To:
References
TASK-TF, TASK-TMR NUDOCS 7908160238
Download: ML19256B640 (56)

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Sabcock & Wil:cx, C'd Fores: Road, Lynchburg, Virginia 4505, en the 7th._ day of July 1979, ec==encing at 11: 05 a.=.,

before Stanley Rudbarg, certified w.3.=.d

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.e. a. e of New Y0rk.

P00R ERM.

1882 193 79 0g1 G O&Sg,

BEN.I A. MIN REPORTLNG SERVICE

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ROCKWELL, ESC.

14 Associate Chief Counsel 15 1'

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A_ L_ _S C_ _ P _RE_ S_ E_ N_ C_ _-

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RCNALO M.

EYTCHISCN 19 C00 n0 at 1882 194 3

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_o SENJAMIN R EPC ATIN"3 E ERVICE

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a been firse duly swern by Mr. Rockwell, was called as a witness and testified as fellows.

(Resume of Joseph John Kelly was =arked

=

o Kelly Deposition Ixhibit 108 fer ifentification, this date.)

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3Y MR. ROCKWELL:

10 g

state your full nane.

11 A

My name is Joseph John Kelly, Jr.

in Q

Your current emp;cyer?

g A

Babcock & Wilcox Co=pany.

l-a Q

Your current business address?

A Post Office Box 1260, Lynchburg, Virginia.

15 Q

Your current position with Babcock & Wilcox7 1O A

a= in the Plant Integratica Unit, principal 1 i engineer.

13 Q

Have you brought with you today, Mr. Kelly, 19 a resume which we have now marked as Kelly Deposition 3)

Exhibit 109?

1882 l95 A

Yes, I have.

ny Q

Oid v.ou prepare that?

nn A

Yes, I did.

.3 Q

s it accurate and up-te-date?

A Yes, i-is.

SENJAMIN R E. C R"*! N G S ERV!CE

2 Kelly 4

q Mr. Kelly, your resu=e indicates that you 4

a.i e cur ently a principal engineer in the Plant 5

Design Section Of the Nuclear ?cwer Generation Oi.isien, 6

is that correct?

A Yes.

4 q

Does that place you in a unit known as Plant Integratien?

9 A

Yes.

Integratien is a unit of Plant Design' 10 Section.

1*1 Q

And you have been in Plant Integratien in-since June of 1977?

D A

That is correct.

14 Q

Mr. Kelly, in the fall of 1977, did you become familiar with a transient tha: occurred at la-the Davis-Besse plant, specifically en September 24, le, 1977?

14 A

A Yes.

18 Q

Can you tell =e when you beca=e aware of 19 that transient.

Give

=e your best esti= ate.

20 A

don't reme=ber exactly, but : believe it was 21 the day the transient occurred, which would be the 24th.

na O

And how did ycu becc=e aware Of it?

3,_a A

My supervisor told =e that there had been a transient at Oavis-Sesse.

a-

_s 3ENJAMIN R EPO RTI N G 3 ERVlOE P00R ORG!NAL

1 n

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2 Who was your superviser at the time?

A Iri: Swanson.

RC:

5 0

What did Iri: Swansen tell you?

A A

don't re=e=ber the dialocue, but he was describing that there had been a loss of feedwater, and he had a depressurizer transient, and he wanted me to go up := the site and investigate it.

9 0

Did you go up t=

the site?

10 A

Yes, I did.

11 Q

Was that ner=al tperating pr:cedure for l'

you er sc=ecne such as yourself :: ge and investigate 13 an operating transient?

=ean, we de 14 A

If the transient is unusual not send sc= eons for every reacter trip, but if it 1 a-was an unu;ual transient, we would be sending people lo, up to investigate, yes.

1-O When did you ge to Toledo Idisen Oc 13 investigate this transient?

Again I a= asking fer you 19 best estimate.

20 A

eas either probably the day after it happened 21 or in that time frame; certainly no =cre -han twe days

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22 after it happened.

g How long did you stay there?

lbb2 f9[

A Jus: two days.

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Whc did yeu talk t?

EENJAMIN R EPO RTIN G 3 ERVICE

1 2

nelly 6

s A

The sitt Operatiens =anager at the ti=e, Fred Faist, was =y principal centact.

3 Q

He was a 3GW e=ployee?

0 A

Yes, he is.

Q What did Fred tell you?

A Well, he showed =e what data was available g

describing the transient, and =y responsi;-ility up 9

nere was to try to sift through that data and 10 deter =ine the sequence of events and =ake a report 11 back to Lynchburg.

Fred assisted =e with that; he lo and I did i:

ogether.

13 g

rid you sa;k with anyene else wnile you 14 were there?

15 A

I talked to Jack Evans, he was the p; ant superintendent for Toledo, and attended a meeting la, with various Teledo representatives, 3&w representa-1,.

tives, and ; don't reme=ber all of their m.a=es.

18 Q

What was the =eeting devoted te?

19 A

They were talking primarily about the steps

^0 invelved with recovery frc= the transient, and =y 21 interest in that was, as : said, te deter = int the 22 sequence of events and then go back and ge: 3&W's

.m rece==endation en their ability := -- well, te a

present the data to 3&W so 3&W 00cid =ake a rece:-

=endatien en their return :

pcwer.

"8 l%DR ORG N:L 3 ENJ AM A N R E. CRTING 3.ERVICE

4

v. e 1

2 While you were there, did you =ake a 4

deter =ination of wha: to you were the i=portant 5

features of the transient?

A Yes.

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Q What were they?

3 A

I went over the sequence cf events, and they 4

had lost feedwater -- they had a peculiar syste=,

10

a differen syste= up there than : was used to looking at, which would be a stea= generater, so=ething g

that would isolate an incident of a =ain stea

line, and so=ething triggered that syste= and they ics:

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feedwater from a icw power level.

14 The nor=al results of'a pcwer loss of a feedwater 1o.

is a high-pressure transient in your reacter coolant systa= and a reactor trip, and that occurred 10 l~

pressure in the pri=ary sys e= was high encugh to

[g lif: thcir electre=atic relief valve, or pilot-operated relief, which =ay be another ter= for the g

same thing, aad then it depressurized, and reviewing the plots, it became apparent to me that, you know, n1

hey suffered -hen an under-pressurised transient en and an initiation of high-pressure injection.

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turned off the high-pressure inje:-ion with an

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increasin: cressuri:er level, and 3 =ewhere in =

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1 it was s==ewhere 25 the ::ansien they rea~ized E ENJ AMI N RE:CR~IN:3 3 ERVICC

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a relatively sher:1y inte it, say :: :: 25 minutes, 4

and do:': know exactly wha: ti=e it was, but 5

sh ::17 after they realized the elect :=stic relief valve was open and re=ained open, and showed theOpen 6

electre=atic relief block valve and subsequently i

repressurized the plant and recovered f c= the 3

ansLent.

9 Q

Did you determine why it took the= 23 10 to 25 =inutes to recognize that the PCRV had re=ained

,I open?

12 A

1 don't re=e=ber why it teck the= that 1:ng.

13 Mayss if I reread all the repor s en that transient, i

it would ce=e back to =e again, but don't r e = e =b e r -

t,.

why 1: sock the= that long.

.i.O Q

Did you write the reports on that transient?

A No.

My assign =ent was to reduce the data 1.

present the available data, the plots of reacter 7,o coolant syste= pressure and te=perature,reacter o

19 syste= ficw that were available f ce tha: ::ansient, 20 the sequence of events fro = the alar = =eniter -- gather 21 this data and construct wha: : :all a sequence of events, and then present the reper cf the transient en whi:h was written up in a site proble= reper: =ade bv the Nuclea Service Cepart=ent.

2 In -hat =ee-ing that you des::ibed a:

1882 200 25 S E Nw* A M I N R EFO RTIN G S ERVICE

P00R ORIGINAL

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=ake a presentation cf the sequence of events that 3

you had been able to reconstruct?

A

't e s.

S Q

• o whc=?

9 A

Fred Faist, and : =ade a ;:esenta-ion to what 10 must have ':een 30 people there.

Oc you want a list 11 cf who can re= ember?

Is that what ycu are asking?

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on Montge=ery was there.

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'9 MacMillan was there for a while, and it is ust a e0 s.....

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A

don't re=e=ber Nc:= being there.

4 Q

Ecw about Hall =an?

A

think Don was in, yes.

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6 Q

Hw abcut Mr.

Kane?

A

don't re=e=ber Id being there, ne.

Q Was Mr. Roy there?

,a A

! don't re=e=ber.

o.

Q Was Mr. Cids there?

10 A

don't re=e=ber hi= being there either.

11 Oc you know whether there would have Q

in been a recc:d of who attended the meeting?

13 A

No, I don't think there would have been a 1,.

written record.

Q Was there sc=eone who was the convenc: cf

c-the =eeting?

1. o, A

There must have been, but don't re=e=ber that

1..

either.

I was just flown in, get off at the airport, 13 and had these reperts, and they said, "Oc=e to the ic training rec = and tell us what happened," and : don't 0

re=e=ber even --

21 Q

The session was held in the training roc =7

., n A

Tes.

Q It was likely, then, that sc=eene frc=

. resent?

the ::aining Depart =ent was A

was a training rec =

ex: :: the cafeteria, 1882 203 stsu-s a t.= : e s :

sem==

700R BREM v.

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3 which is physically re=oved fr== the Training Oepart=ent.

Q

thought when y:n said " training roo=,"

you were referring to the Training Depart =ent.

s A

No, I don't re=e=ber the nu=ber, but it is the o

one right beside the cafeteria.

Q You got off the airplane at the airport and ca=e directly to this =eeting?

O.

A Frc= what I can re=e=ber, yes.

10 Q

And there were 30 people present?

11 A

Yes.

1.,

2 Who =pened the meeting?

Was it ycu and 13 Fred Faist?

14 A

Yes, Fred and I.

3-Q You =ade a presentatic: cf the facts as o

you had reconstructed the=?

lo, A

Yes.

1..

./

Q Did you present any cen:1:siens or any

,a sJ opinions which you had fer=ulated based en your review 9

19 cf the facts?

20 A

think at the time every-hing : vaid was =y 21 conclusien and epinien.

I don't understand.

22 Q

take it that you night have held up a chart which shows pressure and said, "Here is the

,ressure trace," :: you would have held up ancther show;ng the pressurizer leve* and saying, "Here is 4:

-a pressurizer level"; -hose, I take it, were not E ENJAMIN R EPC R71 N 3 3 CRVlllE

PDDR BRGMAL Kelly 12 conclusions or opiniens but a presentation of facts?

,1 A

Yes.

5 Q

And take it you would have ob ective 6

data to which you would have referred er shown the=

to illustrate certain facts about the transient, would

~

a that be correct?

In other words, showing that at such w

a ti=e, HP: was initiated?

g A

Yes.

10

(

And that at such-and-such a time, EP!

1I was started back?

t. _o A

Yes.

13 Q

n other words, it was a factual presen-14 tatien?

15 A

was showing the :: ace of primary pressure; 16 when it went through 1600 pounds, I wculd have said

1882, 205

^

"That is when EP: was initiated."

1_

Q Eaving reviewed what the facts were that you could extract fro = the data availshie to you, er 19 in the process of reviewing the facts, did you then

_9

^

=ake any observations about what ycu thought was m

the significance cf these events or the cenclusi=ns

~*

s nn that could be drawn frc= these events?

23 A

can reme=ber talking abcut the pressuricer I'= sorry, the pri=ary pressure gcing down and reaching saturstien ccaditions in the iceps, and G

E ENJ AMIN R E F O R""; N 3 3-IRVIC E

P00RORGIN!L 1

f 2

Kelly 14 2

pressuricer level gcing up.

q And you were talking abcut pri=ary pressure going down and pressuricer level going up?

3 A

Yes.

o C

Were there any other observatiens c:

conclusions that ycu made?

3 A

can remember Fred reaching -- at that poin 9

in ti=e, we had get en the information that there was 10 a relay =issing on the electrc=atic relief valve 1;

circust that would ner= ally have been installed to in provide a dead band between the relay, opening pressure, and closing pressure.

As a result, with that lockout

,3 i

relay =issing, when the pri=ary pressure get down to T.,*

the relief valve set point, the relief valve i==ediately

..to shut, and then a very slight pressure increase of, for 16 instance, a few pounds, would cause that valve to recpen t-again, and that would relieve pressure and drop, and 13 the valve cycled several ti=es, and at that point we 19 speculated tha: that was prehably the cause of failure 79 cf the electrc=atic relief valve, rapidly opening and closing and =issing a relay.

Q Oid you present any other conc *usions s

0: opinions er interpretations of the data in the

.n.

=eeting?

1OO9

?AL 1OUL cVU A

c t that : can re=e=her.

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a ed

P00RORGNAL

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v. e.,./

Q How long did the presentation take?

a 4

A 4'

=inutes an hour.

5 C

Did you er Mr. ?ais

=ake any reference to the termination of the HP, whether it was appro-5 priate?

A No.

8 Q

Did you =ake any reference to the time 9

that it :cok -he opera:crs to reali:e that their 10 POR7 was open?

I'f A

Again, I =ay have, but don't reme=ber.

12 will say that a= sure that we pointed cut when 13 it was shut, but ; don't reme=ber the details of how we knew that.

A: this peint, *: don't reme=ber.

1,.

Q My questien is really addressed te any 1

interpretation you =ight have effered as to why there le was a delay in the operators' reali=ing that their i-ei PORV was open.

18 A

don't re= ember.

10 Q

Old Mr. Fais address any of the questions 20 tha: I have just mentioned to you?

21 A

He is the one who led the discussion on the that rapid cha-tering elect c=acic relief ne 7

open and shut.

Q Eave your answers tended c reflect only what you 1882 207 3, ENJ A MI N R EFC RTIN G SERV!CE n

300R ORG NAL 1

Kelly is 3

A No, both what I said and what ! =an reme=ber 4

Fred saying.

Q Oid anyone in the : cm during that meeting respond er :== ment in any way to the =aterial o

you were presenting?

A There were questions en details; that is why 8

re=enber tha Ocn Montgomery was there because he 4

~

said he wanted to write down all the details cf the 10 electroma:Le relief wiring diagram to show the 11

=issing relay, and : reme=ber him asking that question, 12 and from that : re=e= der he was there.

did talk about when pri=ary pressure reached r

.3 saturation temperature that we had to consider possible

,4 1

boiling in the core and whether there had been any l a, fuel damage, and nothing happened ---

don't reme=ber 15 a response during the for=al part of that meeting,

1..

but when the =eeting broke up, I got inte discussions 13 Bob Cones works fer with 3er Ounn and Scb Jones 1 ^?

3er-Ounn, and =aybe you have picked that up, and 20 Scb cones told =e at that peint, no, that he didn'-

21 shink there was any fuel da= age.

They were sure the analysis would show there wouldn't be any fuel da= age, and 3er Ounn ::1d =e that he was concerned because they had turned off high-pressure inJe

ica, and he said that he accid pestulate scenaries

ha:

25 1882 208 3 ENJAMIN REOCRTNG S ERV!CE

PDDR OR E L

v. e.~ ~..

3 would lead to possible fuel damage if they turned 4

the high pressure injection eff toe soon, so Ber:

was concerned as a resul: ef : hat briefing tha: they 5

had turned off high-pressure injection sco soon.

O Q

Was that the first ti=e that that concern had come to your attention when Bert mentioned it 3

you?

O_

A Yes, that is what prompted my thinking alcng 10 those lines.

It was after the formal part of that 11 presentation, in, discussions with Bert and Seb Jones 12 after the meeting.

13 Q

Oid anyene else come up to you during those discussicas after the meeting, or to participate in the discussions after the =eeting?

l o, A

Yes, there wt e Licensing people; Joe Lauer came 16 up, se he must have been at the =eeting, sco, so if T-you want to put his on your lis: there, and they were 13 talking about another planelead of people te go back up to : avis-Besse to help them with their interfacing 19 20 with NRC to perform the Licensing function that_ we:

., t provide.

Q Joe Lauer came at what point to the discussions after the nee:ing?

Was that when yo"

.4,

i8 2 209 a

were talking := Jenes and tunn?

)

A No, this was a separate eenversati:n.

his was we 3 ENu AMIN RE CRTING 3 ERVICE

?00R BR M 1

.3 after it had happened that : spoke with Ounn.

Q Oid ycu talk with anybody else in the 5

after=ath of the =ee-ing while you were still in 5

the roo=?

A Not anything that I can re=e=ber of any signifi-cance.

3 Q

You said Lauer is in Licensing?

A He was a-that time.

a= not sure if Joe

1. 0 still is.

!.1 Q

That is what :

a= interested in, at that ti=e.

p*

A Yes.

14 Q

Where was Montgomery at the time?

15 A

Ocn Montgo=ery was -- : don't knew the title but he is on John MacMillan's staff, and reported

3. o-directly to Jchn MacMillan.

Q Oc you know if anycne else was involved 18 in the discussion that you and *:unn and Jones had?

t o.

Was anyone else present i:: the discussien?

^0

~

A I don't re=e=ber anyone e'se.

a1 Q

Was your boss, Swansen, at the =eetin~'

1882 210 A

don't re= ember.

s Felieving the =eeting, did you de anything

^

e 4

=cre in connecticn with -ha: Oavis-5 esse transient?

A

censinued :

refine the data, =ake the p '. c t s

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P00R BRIGINAL

g. 8..,;,

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h..= #

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..... j.

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. a

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4

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., q..u.gge a

e x

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g.

. w.. a.,. e, a.< : a.;'

.e e'se k.. -w a.e 4.a.s, g

about c: had anycne else been exposed :: Ounn's c.. n a y c.....a....

....a.a.a

... c ' ' '. '. ' ' '.

8

.a

.e.,a.,.,

a.s.a...

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a.

. u. a.. p.z..,

-..,. a u...:. a.a. e u..e a. a 10 about the second incident o' high-pressure injection 1.1 sho..

a.e.e.

. s. a.

,4 s.. one.

12 v.

ea

. s. e c, e 4.

.. eve w.. e _

4

.,, e,.,.,.

... w.. e_.

...,4.....g

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,3,;

a i

Q A: Oavis.5 esse?

A Yes.

3. a.

... e a. e. ' a.' s. '..'.

v. o. -.-ted ove.-,. o

.w n.

.1 16

a. a.-.ce.-v.d. e, was

..'.e - *.

. e.# a. - a.. - a.

c,..., e -..

.s about the pre =ature termination O'

 ? ~ ?

1Q A

No.

9.A 4

Q m.1 4.. 33

.C

. %..J e e., J..,

s.4e.

. b. a.

.f C L.

• e a s

.,b

'O 4.. g.

g.ee. 8%

.o, Ca. yCu

.e..i e

.g.6. &.

.f, u

. i

...B $.2 212 a

s.

.33 a D C.... k. a.

4

.8

. e. a.4.. s s. s. a. Se. a C.e.

.f. C V.o e C.e

.3

,a a

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.'.a..

w.,. s

.'.. *. s.. ;... #.

J.. r =.

gy.

g., w..a

. s. q..

. 4 a.s ai e

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• '*..I*

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.....'..f c

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. 2. a..

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u., 2 a s _4. _a _*,.

r v

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....4_

incident, and a

-ha: ti=e the Opera :: had bv..assed

. '. e S...',".

y-e s s u.- a.

_..da....'...

.. -. a-w.'.

to operate.

By "si=ilar,"

mean it was another o

icss of feedvater fr== low power level.

.a.s.

e.'

• v.

" w h.. a. ~..'. e

.c. seq"en e

',.'d

• ed 3

Of the bypass of HP: had been?

o en..eme se e

A e.

.. e d4a,.- a w

10 g

would you be able to ge back and figure 11_

out when this transient occurred by referring te

.l a records tha-v. e u have available :

v. e u ?

A

could go back into the Nuclear Service

,,u

._.,c.2..

a _. a

<4 a

4..

. s.. e. e

v. t. a s_ e a S _4..

P.,

e.

e

i. 4 Report en that ene also,

i. a-2 Would you de that, and veuld ycu provide

,-m us a copy of tha* Site Pr:ble= Report for :nat e.4 a

4.

si

.-.. 4.. a 4

4.ae.,

4.,

ot e

A Yes.

9 19 And you are sure that you wculd have 3

mentioned the concern about premature ser=inatica of H?! to Swansen at least by the time you heard

., 3 a.k., o u. ~..'. e s e c o..'.

_ a..s.' e..,.' "

a. c ~. s.' *. e _-.. '..

1. .# - s. '.

A As a result of the se:Ond, 0: =aybe it was s...

_...a se....

a.,

3.

1882 213

==e, we=-

a=d alkee==

ri: swa=sc=.

""*_a.g

s. am 8'"

ei. m. ps..e o g B

m I $

.up.

OM W

P90RORBINAL

., e....

3 g

Oo you re= ember the substan:e of the 4

dis:ussion?

5 A

t o l d hi: that Ser Ounn had expressed a concern over the firs: transient.

I said that they jus:

6 recently had a second transient, and it bypassed i

high-pressure injection, and I was concerned that perhaps we hadn't given the= specific enough instrue-9 tiens en when to ter=inate high-pressure injection, 10 and Eric listened to this and said, why don't :

11 write a letter on it and see if we can't get some w

action.

13 Q

Old you talk to Bert again before you wrote what we have previous _1y =arked as Deposition

3.,4 Exhibit 24?

3.3 A

don't re=e=ber talking to Sert before I wrote this, but if : didn't talk to him i==ediately 7

O bef re it, I did afterward, I just don't re= ember 18 of events, that I went to talk to Bert the secuence 10 and told hi= that they had a secend incident and 20 they bypassed high-pressure, and : don't recall 21 the verb tense, whether it was befere er after, and don't re=e=ber or ne, whether : told hi: : v %e 2 214 sa a =e=orandu= cr a= geing :

writa a

=e=0.

-a Q

What was his rea::icn-A He said it was a g:ed idea :: wri:a the me==

s:

= :. n_ _ VI.

M.m.i___.N-

=r_NJAM1N e

P00R ORRNAL t

v._...,.

3 and see what comes cut of it and see :.f you can 4

get the infer =ation disse =inated.

v, - "

w.-.e

.'.e "e -

. S. e..' e. '. a.

r.,

g which we have here as Exhibit 24, had you brought v

. s.. e a..e.a.

. s.

a..f o. e C. s. e

.w&

D.... s s Cc....

Eric Swansen?

3 a

n..e.

s. e sec..e

.4_e, a;

.a,.4 g.

e2.,

nv wendered :: =yself what we were putting out to the 10 cperaters, sc went down and talked to the si=ulators--

1'

• 1 sc=e of the si=ulater instructers about what we were

_n e a. k..' n, -.. e..'.. a..'.a =..

a..'

5.. _4 '.. f.. s s " -.

. V. e.. _' o..

13 Q

who did you talk te?

. s..

., _a

a..

.a

.4._

a

.. e

s. e x...,

1,,

a Q

Oo you re=e=ber talking to anyone else?

l a.

A

"*h e r e were other peop'e there.

.6 Q

When you go dcwn to talk te the si=ulater

1..

4, s.... c... s d e va..

..S. e. e w k. e. e. *. e.d.- o.'.'.'. e s,

..' =

13 Carsen could have been there and Harry Heil =eier could 9

lo have been there, but I don't re=e=ber specifically n0 talking te them.

21 Q

'4 hat did you ask Jch: *ind?

~.,

A

asked hi= what instruction de we give, er what instructiens de we teach during si=ulate

,,_a training to the operaters en securing high,ressure

,?

u

_ _ N,., A M I N r:_-

.Nw-

= =.m Vt- _

__2 wr

=-

M ORIGINAL.

3 "What did he say?

A

hn said that, yes, they dc sca:b high pressure--

when 20 secure high pres:ure inje:-icn, and the o

instructiens that they gave were en the order of o

stabilized average temperature and increasing d

reactor coeling pressure and stabilized pressuri:er 3

level; the transient was under contrei and, you kncv, o

I went away with a war = feeling after talking to 10 John about whc: they had been teaching the operators.

11 Q

Oid aither you c: John ever address the 13 question if they had been teaching that, why had twe

ansients cecurred invclving prs =ature terminatien

..u o.s u,. v,.

1. +.

A I said that is why :

a= here because of the

1. o-things that happened, and Jchn said he didn't under-43" 1

stand why that had happened, because they had been t-teaching that, and that is where we dropped it.

18 Q

Oid you ask Jchn whether he had any l'

i=pression as :: whether the operaters understood what they were being taught?

39

! c

t reme=ber A

No, I didn't ask hin that asking it.

,n 0

Sc Jchn was _eassuring :n the subje:-7 A

Yes.

O 3asica;17, he said there was ne prob'e=,

that we are teaching it?

-~

1882 216

~ ENyAMIN R E C R"*: N G ERVICE

=

v.,....

3 A

Well, by " reassuring," : neant that : couldn't--

4 felt like they were teaching when := s e'c u r e high-pressure injection.

It still wasn't clear to

=e that we were effic'ar.ly putting it out to anybcdy, g

c: what we were putting out in writing :: the various utilities about securing high-cressure injection.

3 g

At the time that you went dcwn and talked to John Lind, did you also check on what ycu were 10 putting out in writing, and "you" meaning B&W7 11 A

Not th.at : re=e=ber, no.

10 Q

De you re=e=ber talking with anycne else 13 about your =encern and Ounn's concern of pre =ature ter=ination of HP: before this =e=crandum, which is

,1,,

dated Ncve=ber 1st, and which is identified as l a.

e_ x h.4 _w 4..,

10 A

No.

After u L%ed to 00hn and found out wha-1-

4.

we are teaching the operators, I still vent back

'S and talkad to Eric abou 3er: Ounn's concerns and then 9

to

=y evn concerns at that point, and then we decided 20 to go ahead and put this =e=c cut and see what 21 response we :ould get to start se=ething being disseminated to ths custe=ers.

n C

When you were talking with Jchn Lind, did

-a ycu make any suggestion 0 hi

-ha: the :ve' transients s

at Oavis-Besse in Septe=ber and again in 00:cher sh uld i882 217 3 EWAMIN R E CRTING EE9VICE

P00RBRGN?L

..e..y

.c be reviewed and dis:ussed with Operators in the 2

4 course of teaching

-he=

about EP: ter=ina-icn sc that 5

they c=ders: cod these kinds :f pctential situa ', ens?

5 A

No, I wouldn't re=e=ber suggesting -ha.

Q Did he indi: ate that he had any intention G

of doing that?

,a A

- don't re=e=her.

c.

.Q Did you give hi= any infer =ation about 10 the transients in a written for= at the ti=e?

11 A

No, just verbal discussion.

16 2

Do you re=e=ber whether you gave hi= a 13 description.' what in your =ind were the significant

1. +.

features cf the transients at the ti=e of the dis-cussion?

l a.

A

went over the sequence of events of the first lo, ene.

I didn't know what the sequence was in the second.

18

.4 2 c.

.e,,

4.d a.....a.

...e

. s..a..

'9 Dunn was cencerned and -hat you were ;cncerned spe-29 ifically about pre =ature termination of H?!?

21 A

Yes, and I don't re=e=her the verb tense again, either told him that : had, or I was geing to la but I write this =e=c to yet sc=ething prehably going; that

.s

- we ended Our conversation.

is the wav

.T Jus-fer the re:crd, you did wri e na M ::. y m e.I N,.a f m. -

Nem m

M e

=, NJAMIN m

4

P00R ORGINAL 1

Kelly

~

3 Exhibit 24, is chat correct?

4 A

Yes.

3 Q

You k.ad it distributed sc the people shown on the distribution?

c A

Yes.

Q What would be the normal fashion that 3

a =e=o such as this is distributed, and a= talking o

about the =echanics of distributien?

10 A

My secretary types it.

I read it and sign it, l'

and then she would =ake the necessary ecpies and 12 put an arrow next to each na=e en the distributien 13 indicating that was their copy, and then pr.: the in the internal = ail syste=, and it would he 3,.

i distributed.

la.

Q That would be just the rubber sta=p of 16 an arrow?

1.

A A rubber sta=p, er she would write an arrew.

13 Q

And the =ethod of distribution is an in-e lo house mail syste=?

n0 A

Yes.

21 Q

yelicwing distributien cf that

=e=0, did any of the seven people shewn en the distributica lis en contact you in regard to the substance of the =e=c?

A No, not that re=e=ber.

seve..jjpgype}jg Q

Oid you go te any cf the m N,. A M I N m :. ~ f M 6,INeM

= ::.nVt M M m

WM

.s O=

MM

.,.e_...,

3 fc11 ewing the distributien of the meme and say, " Wha:

4 de you think?"

5 A

No.

6 Q

Oid anyone ether than the pecple shewn en the distributien =ake any contact?

A

get a letter back frem Walters.

Q Yhat wculd be what we have marked as y'

Deposition Exhibit 35?

10 A

Yes.

11 Q

Did you just get the ne=c frc= Walters 12 by itself, or did Walters step by and talk to ycu 13 about it as well?

A No, Frank didn't ccce by; I just get the meme.

.i.4 Q

You had a chance te review tha en er

.0 about the time he shows the mecc having been dated, 16

.amely, mid-Nove=ber of 19777

1..

A Yes.

,,.s Q

Oid you get back te Walters after you

[c

~

reviewed his menc?

20 A

No.

21 Q

Oid anyone else c her than Walters, and o ther than these shown en the distribution,centact you in any way about the substance of the secte r andud?

~

A Nc, net that : remember.

O Cid Iric Swansen ever inquire w

E EN. AMIN R E* CETING 3 ERVlC E

PD:-i DRG NAL T

., e. y s

had happened in response to the menc?

A Oh, yes, Eric asked =e, and : Scid hi=,

"I ge:

5 the 'e:ter frc= Frank."

6 C

Did you show his Frank Walters' le: er then?

A

don't remember showing it to Iric.

I told Eric that I didn't --that Frank was apparently 9

confused, and I was not happy with Frank's respense, 10 and Eric and alked about it for a while, and it decided to gc talk it over with Ber:

Dunn.

Q sc you went and shot the breece with 3er:

,n 13 cunn abou: this subject?

[4 A

Right.

l e-Q With reference to that conversation with Swanson, did Eric Swansen =ake any particular

, o.

t suggestion as te what you should de at that point?

1 4 A

I don't reme=ber, except that : came away frc=

so 40 talking with Eric knowing that I wanted to ta*k with 10 Sert.

What a= hesitating about is : don't knew 20 whether : suggested i: to hi= c he suggested it to

=e, 21 but I wanted 20 talk c 3ert and teli 3ert that -here s

^^

was se=e confusien in Frank's mind, and in the Nuclear Service, and encourage Ber-20 pursue this farther.

.s 2

Tha-was kind cf a :ensensus be ween the two of veu?

25 1882 22i

~

_ _ _ b l

_c.

_,____.N_.

_ _ N.a A M I N Oss M.ni:

=L

1

., e..,,

3

?

A Yes.

4 2

You did not reach a decision :: de any-thing other than that?

A No.

o Q

take it you did in fact go and talk :c Bert?

3 A

Yes.

9 Q

About when do you think that was?

10 A

Within a couple of days after got this thing, 11 so we are still talking about toward the end of 12 Nove=ber.

13 Q

When you say "this thing," you =ean

3.,.

Deposition IxFtbit 357

. x.u..z s..a.

,e.

a

Yes, 3e)

Q Wh.: was the substance of your conversation 16 with Ber: Durn +: hen you went and talked to hi= in the latter part of Novenber?

13 A

asked Bert to get : gether vich Nuclear Service, 19 and we talked about Frank's

=e=o, and to see if he 20 cocid not work out the details Ef eli=inating the 21 confusionand getting sc=ething published to our ao cust==ers on when Oc secure high-pressure inie

ion, if se=e hing additional was needed?

i882 222 Q

1e he agree== the ?

A Yes, he did.

s.

.3 3 ENJ AMIN R EFC RTI N G 3 ERVIEE

P00R ORGINAL t

4 1

,.e_.y 3

Oif you have any =cre conversations with 4

Ser-Ounn after he put out his =e=crandu=, whi:h we 5

have id*::ifi*d 28 I*hibit 237 A

No.

o C

You are fa=iliar with Exhibit ~37 (Handing.)

A Yes, I a=.

8 C

You got it and read it about the ti=e he Q

wro*e it?

10 A

Yes.

11 So you had just the one conversatien with 12 Ounn fcilowing your conversation with Swanson and 13 before Ounn wrote his_first =e=c?

A Only one that : rene=ber.

We are pretty close 3.

physically, and we =ay have talked about it at another l a.

ti=e.

14V Q

You indicated that you were going to l _.

ask Ounn to get together with so=eone in Nuclear 13 Service.

Oo you know whether he did in fact do that?

e 19 A

No; only this Exhibit 23.

20 Q

You =ean to the exten that this,was a

getting together with Nuclear Service?

al A

Yo =e this was the next thing in the chain tha en

was aware of after talking to Bert.

Q Oid yeu talk o anyone else, and : a:-

n.,.

referring to the

-i=e period between the publication 2

1882 223 EENJAMIN E EPC RTIN G 3 EEVIC E

P00RORGUL

..e...

cf your Neve=ber i

=e== and the puh**:ati:n Of Ounn's February 9,

• 973 =e=c; did you talk to any:ne else 5

0-her than -he people you already described about the 6

concern that ycu and Ounn had?

A Not*that can re e=ber.

C And you were net conta: ed by anyone g

else in regard to that concern?

A Nc.

10 Q

You were on the distribution list of 1.1 Cunn's

=e=o, so you get it directly, is that ecrrect?

,e A

00 ree.

3 C

Oid anything happen at that point, as far 1'

14 as you were concerned?

Were -here any =cre dis-13 cussions, or was there any more action?

he A

No.

He was writing that to Jim Tay; :

3. o.

was going to wait to see if thev. had a meeting and if 4

I would be invi ed to it, and very shortly after that i.3 a secon: Ser: Dunn me=o showed up.

.9 Q

Why did you think Ji= Tayler was

~O A

When said "he,"

! =eant 3er-Ounn.

., t Q

Was there an expecta-i:n that Taylcr 22

=ight have called a =eeting :: discuss this?

'?

A Nc en =v =ar.

• ~

1882 224

~"

Q That is =y rues-icn.

A No, !

ust :hecgh: 3ert wculd ca*1 a meeting

.w 0

m w

P00R BRGINAL 1

.v e....

. ~. ~

.z-a....

=-. e

.a

,.a.e.,

,.....i.,

c.

v.

3 and I was just ene of the icwer echelen people, and e....

-e

.e..

y..;

,. e..

.u

.e

.., u n,.u...

a c 4..

Q n vour understanding, why would Ser o

have addressed the me=c to Taylcr?

A

don't know why he would have addressed it to B

Taylor.

. can only speculate.

a Q

Give me your best speculation.

10 M.R. "DGAR:

Give him ycur knowledc.e.

You l'i are ne required to speculate.

12 A

don't knew why he sent it to Taylor.

I asked 13 hi= to talk to Nuclear Service about it.

3 Q

Was there a procedure in existence at 4

early 1975, fc handling that ti=e, namely, late 1977 i

concerns that =ight arise anywhere within the Nuclear 1o.

3. owe.. Ge.e

..a...c.

n. 4. 4 s.4..,

1..

A Yes.

13 Q

What was that procedure?

e

,W

.a.cn..

.me.s-e

. s. e. u. -ue.

c., 4 a

n0 Q

den't mean the nu ber, be: what was the 77C 1882 eCJ 21 substance of the procedurs?

~

" "... ' ~. h. a '

.c

...n'~.

~ e ~. _' ~.v o. v e '. v '..

4' w

., e

.........a.-~:

s a.' e.v.

' o v '. ~. "..

"..'.q sa'e.y

-...e.-.s a.'

~~=

.n

. a ec cerns and things like this, if you have a safety

.......... a -.....

.n.

-.,. N o-

= ::. n VI. -

N., A M I N, m-.

n

.s

=_

a

300R ORGINAL

.s e _ _ y 2

3 g

De you knew what the procedure was at

?

that ti=e for filing safety concerns, er where ycu 5

weeld send the=?

A No.

! never read the procedure to that point.

3 Q

Do you know sc which department safety concerns were addressed?

eo A

It would ge to Licensing.

c.

Q Were you aware of that at that ti=e?

10 A

don't re=e=ber.

11 Q

So you received the Ounn

=e=c, read it, and thought to ycurself, !.ill see what happens 13 next; is tha-essentially it?

3,.

A Yes, that is ccrrect.

thought thac the =atter was best handled by Bert Dunn.

was d.n his area g

and ' e -said of concern, and : transferred it ever, h

that he would write a =e=o and initiate sc=e actien.

16 Q

Oid anything happen between the ti=e of 13 Sert's first =e=c and the time of his secend =e=e on ic yebruary 16, 1978, and I show you that =e=o which has 20 been =arked as Exhibit 36?

21 A

No, nothing that I can reme=ber happened.

Q Do you re=e=ber receiving 3ert's second

'~

^^

me=c?

,__a A

v.. s, _- 2 _4, 7_ 726 2'

m a

n._..,

.w_.

C., ENJ A M I N RE CR7?NG S ERVIE E

Kelly 25 3

A Yes.

4 0

Cid anything happen then?

5 A

A that point thought the proble= was ever and selved because of the way this thing is written and 6

the wroding in it.

Q Tell =e why you believed the pechle= was 8

cver and solved.

9 A

knew that--as I said earlier--that Nuclear 10 Service had so=e problems with it, and that is why 11 I went Oc 3ert after I got F r ank *a' alt e rs '

=e=c, and that is why I went := 3ert and asked Bert :: please in 13 take it over and see if he can resolve it, and the first sentence of this =e=o ss.ys-

7.,.

"?ield Service has recc== ended the follewing la-procedure for ter=inating high-pressure injection following a 10CA," and then he lists these two sen-1.

tences, and the last sentence:

18 find tha: this scheme is acceptable fro =

to the standpoint of preventing adverse long-range 20 proble=s and is easier to i=plement.

Therefore, :

21 wish to med fy the procedure requested in =y first an

=s=o to the one identified here."

Se := =e he get concurrence of Tield Service and ICOS that they have cere te an agree =ent en wha sh=uld be prc=ulgated.

27 c

_s 3 ENJ AM!N R E* C R"*I N G S ERVICE

P00R ORGINAL r,,....

.c 7

9 You figured at thato:in: it was the a

s nechanies of getting it out, and that should have been in Field Servi:e's real=?

3 A

Yes.

o Q

And " Field Service" is the.sa=e as " Nuclear Service"?

3 A

Yes.

Nuclear Service; he is calling it " Field 0

Service."

10 Q

su: " Field Service" was a ter= ce==caly 11 used to apply to Nuclear Service, er is that Bert Ounn's implicatien?

3..,

it is a A

"Tield Service" is ce==enly applied 1_

smaller branch of Nuclear Service, the pecple who l,'

... e e.

e., d.

.o e t._ 4

.w

1. o-Q But it is ce==cnly understood that they 16 are part of Nuclear Service?

A Synony=ous, essentially.

13 Q

C her than reading Bert Dunn's seccnd 19

=e=c and ce=ing to the cenclusiens that you s: de s:-- bed,

were you av,are o f anything happening af ter Tehruary 16,

.0 j a. < o s.

.1 A

'"ill today?

., n Q

• regard :: that issue, and le: us say

't

_e up to March

'3, 1979?

A Oh, locking back en it, a : uple

=f ti=es since 1882 228

~

EENJAMIN E EPO R~lN G E ERVIC E

P00R ORIGIN 2

..E..,

s 3

-his

=e=o, Frank Walters and : ::cssed each c:her

.. y....a..

_e

.ae u,a _,.,, E

.a v.

y.

s a _a.s, " c.,. s a-.n.,

ga.a

.. y

.u to vou about = v. me=o yet?" and said, "No,"

and he

says, "I have sent Bruce a

=e=o, and didn't hear g

any more about it.

Q Did you talk to Bert again about this 3

issue at all?

y A

No.

10

e....

.w.e y o.. 2.4d.o.

.a,.,.<..

s.. _4._ a a.,.,

s t'

time you received his February 16, 1975

=e=o up to Ma

.a S,

, o., o..,

.a

._. e,

14 2

Showing you what has been =arked as 15 Exhihit 37, have you seen that before? (sanding.)

4.

A Yes.

to Q

Eave you seen it before March 28, 1979?

A No.

L 2

But you have since :o=e to understand 1Q that that was the =e=o that Frank Walters was referring 9

to when he ran into you?

-.l yes.

,a 2

Q other than -hose two casual references 2

that Walters =ade to you about whether you had seen 2

..... ' s.

-s, o.

-.-4..._,...

e_

2.._._

_3 2.:2

...s a.a

.e

.._-.e.-.

_2e 1882 229 m.. =

r,. I N.,.=

-t,/l _ _

= __ N.. A M I N

P00RORGIL v.. e

..=

3 relating to ter=ination cf high-pressure in ecticn 4

ever come up in any other centext with any other 5

person?

4 A

Net that I knew of.

v Q

A: the ti=e that Walters said to you,

" Hey, have you seen =y =e=c that I sent :

Bruce,"

did you go and talk :

Karrasch and ask hi=,

"What 9

is this =e=o that Walters is referring to?"

10 A

No, I did not.

1'1 Q

Since the 28th of March, have you asked

,n i-Karrasch about the

=e=o that Walters had been 13 referring to?

A Yes.

+

Q Tell =e about that.

What did you ask hi=?

3.a A

That was after I saw this

=e=c, and I saw this 16

=e=c after talking to Ocn Hall =an, and I a= talking bb about early June of 1979, and don't re=e=ber the to exact date, and Hall =an showed it to

=e, and I was

'o t

~

walking back to =y desk after having talked to Den 20 Hall =an, and ran into Bruce in the hall, and I said 21 this =e=o had been prc=ulgated, and asked Bruce an what had happened to it, and if he had any knowledge of it, and he jus: laughed and said he didn'

~

,,_a

/

re=e=ber -- he had not read it, and he us: said tha

-- you kncv what I a=

saying -- I dide' wave 3 ENJ AMIN R E. C R""! N G 3 E7VICE

P00R BRENAL 1

. e.

..e...

s 3

it in front of hi= and say what had hapoened Oc the 4

=e=c, but : asked if he had read it, the

=e=c, or 5

whe:her Hallran had asked you sc res ;ve this high-5 pressure injection p:=ble= las: August, and I hadn't seen any = ore of it since, and 3ruce didn't say any

= ore about it.

3 Q

Oid he respend to your question?

o.

A He didn't say -- I a= not sure if :

a= quoting 10 hi= correctly when he said he didn't re=e=ber -- I

'l a=,not sure of any respcase other than just indica-ing 12 that he didn't reme=ber and i

=ay have been a shrug 13 of the shculiers er se=ething.

i,.

Q Have you had any other cenversations with Karrasch about the =e=c we have =arked as Exhibit 37?

10 A

No.

10 Q

None at all up te today?

1-o A

No.

13 Q

Have you talked with anyone else beside 9

t'c Karrasch about this =e=c which we have =arked as 0

r x.s. 4 w a.

a 77 21 A

talked to Don Hall =an, and that is the

=eeting I was talking about, -he brief conversatica

,a talked :: Hall =an and Frank Wa*ters.

2 What did.Mr.

Hall =an say when y:n talked s.e o.

w

.w 4

_C E ENJ AMIN R EMC MT:NG 3 ERVICE

3 A

Ee asked ne af I had seen this, and said no, and that is when ?:ank said that that is what he 5

was referring :: when he was asking

=e in the hallway when he ca=e back to me, and these were ius: casual o

re= arks as we were walking along, and Hala=an asked

=e if I knew what Bruce had done with it, and I said, 3

no, I didn't know what Bruce had dene with the =e=o.

c.

don't re=e=ber.

It was along those lines 10 Q

Did Hallman say whether he ever contacted 11 Bruce after he sent the me=c?

12 A

No, he didn't say.

13 Q

Did Hallman =ake any other co==ent about the =e=o or about the handling of the concern, when

3.,.

you talked to hi=?

l a_

A Can you be =cre specific; you =ight jeg my =e=ory.

10 MR. EDGAR:

I take it that is an "I

don't 1_.

know"?

18 Q

No, I cannot be =cre specific because 10 I do not know either.

0 A

We went over the whole sequence of these =e=os n

21 that you just brought out.

Q You and Hall =an and Walters?

..i g h t, and we just talked abcut that, that with A

_a all :1.is paperwork, sc=e:hing should have happened, and we were at a 1:ss as :: why 1 didn't.

l882 232

~

E EN jAMIN R EPO RTIN G 3EMVICE

90RBRGNAI.

.. e.. y

.s 3

Q Oid anycne effer an explanatien of why

.a.. a.a.a

.c.,

5 A

No, we ;ust ca=e te saying, "What did Bruce a.

wi..

_i.,"

0 Q

Oc you knew of anyene who has talked to Karrasch about the =e=c that Eall=an sent to 8

Karrasch, other than yourself?

o.

A No.

10 Q

Do you knew whether Mr. Karrasch has 11 checked his own file to see whether the =e=c is 10 there, in fact?

13 A

No, I don't.

Q s there any questien in anybcdy's =ind 1 +.

-hat Karrasch received it?

10 A

don't know how to answer that.

If it was 1.6 addressed to hi=,

it went through the = ails and he

t..

got it.

You have to ask Bruce if he got it er not.

18 Q

Do you know of any other docu=ents which e

'o relate to the Dunn ne=crandu= or your me=crandu: er 20 any of the issues raised in those =e=oranda?

a.t A

Pric: to March 2S?

Q Right.

,a A

No.

y O

Oc you know cf any Other facts whi:h shed

.s,.

any light er how -he issues raised in y:ur =e=crandu 1882 233 3ENJAMIN R E C R"'I N G SERVICE

?00R BR M L

..g..,

3 and Ber: tunn's ne==:andu=s were handled?

4 A

c, I think that we

:vered everything I knew abCut i.

3 3,

a.'...-.

.h. e a..' ' e.a.. a.' ". "... e e v..'.' e. s.' a...',

O have you talked about the handling of the Dunn = emes with anybcdy else other than we have already talked 8

amc.,..

Q MR. IOGAR:

Ixelusive of unsel.

10 A

can re= ember, : quess, talking to people 11 about the sequence of events.

Whe?

in A

mentioned it Oc Bob 3rockman.

n

.s

'.' d h. e S.'.~ ~..'. e s "..'. d.e..

"v.'.'..

v. e ". '.

^

w lt e

a' a-

.a.'.'<.'..~

a. o w.= ". c u. a.#

• e.-

.......,g

. - ".. a ' w- "..

3 1-

.D the existence of Exhibit 37 here and the paper trail 1O and what had happened := it.

can't reme=ber l _'

speaking to anyone else specifically.

18 Q

Has anyone from any part of =anagement o

19

me to ycu te ask vou about v. cur understanding cf 20 these documents and the handling of the concern expressed?

A Since March IS, v=u mean?

1882

.734 nn

.,s.

79

.0

.a.

v. v..._

v....e...n..

A

.a.s <,a.

.w..

ne n.u. a.. ' s.'

v.. w- -....v.'.'..-.. "< =-.- s a v. ?

+

3-

= ENJ AMIN

.O. E.:C RTI N G SERVICE

P00R BRIG Nil..

1 v, e., y A

He asked

=e if I had ever talked t: 'i-abcut

~

3 it, and

old him, ne, I never alked to hi= about 4

it bef:re that, and the only reason : put hi: On a

.e

- 3.

4 s.... ' - ~. was.' o

'...' s 4..." -. a..d a..,

4.... '.....

24 though the instructions ought to ec=e out of the e

Nuclear Service f==,

say, Hall an's group, and that when we pro =ulgated the words, if they had to be 8

changed, they were sent cut to the customers, then 9

expected the ficw path to go fre= -hat p 0=ulgation 10

. a. - a.'.'.s...a.~.'.ans

.. - -. -, w "...' c '.

?.

3".ess d o w a..

11 is a long way of saying -ha: I again en;7 put hi= en 12 there for infor ation, and he asked

=e, and that was 13 in essence what our conversation was, how he was Irie involved 34 Q

Oid he say whether er not he :=nsidered

.0 bringing the =atters in the =e=c in = the ::aining 1.o' progra= at the ti=e your se=o went out?

1 d A

No, we didn't talk about it.

18 Q

What did Nor: Illict: say regarding e

l9 whether he had an i=pression ene way or another when 20 he read your =e=o?

'1 MR. IDGAR:

Let us start first with whether he read his

=e=c.

l882 235 en rea the A

don't rese=ber Nor= saying that he

., 7

=e=o when it was issued.

He had read the =e=c

s.,.

when I was talking :: hi=,

and : a:

alking abeu-E ENJ AMIN R EPC RTIN G S ERVICE

300R OR'GINAL 1

elly 4

3 talking

= hi= last week; he read it at that poin-4 in time.

3 Referring you to runn :epositi:n Ixhibit 23, have you seen that docu=ent before?

6 A

No.

I O

You have not seen that docu=ent before 8

tcday?

9 A

Right now, but not bef:re new I haven't seen it.

10 Q

Had you ever heard anybody refer to a 11-concern rai,s e d by Mr. Novak at the NRO before the 16-

e..a. s.

o.e

.u. a. w 1o,,9?

13 A

0:n=ern about what?

ube seals in the pressurizer surge line?

a Yes.

la.

A Nc.

16 q

Tc the best of your knowledge, was the ke substance of either your ne=c or Be - Dunn's =e=os 18 c=== uni =ated :

the operating ctilities using B&W's

~

lo NSSS sys e=s Nefore March 22, 1979?

20 A

No.

21 Q

To the best of your kncwiedge, was 33 infer =ation about these concerns centsyed to the NRO before Mar:h 25, 19~9?

.m.

'882

?

4 I

4 V

A Nc, net

= ny knowledce.

s.

Was there a rea:-i=eter at :av;s-3 esse SENJAMIN R EFO RTIN G E ERVICE

P00R ORG NAL 1

n v.....

,. =

..e

_a a_.

s

. 9.,,.

4 A

Yes, there =ust have been.

3 2

There =ust have been because you had 6

reacti=eter data?

A My picts were hand-drawn by =yself, but

=us t

have been getting the input frc= a reacti=etsr.

g Q

Could you check and see if the reacti=eter

,y data fo r the September 24 transient is available, and 10

-also for the October 23 transient at Davis-Sesse, 11 and if you find it, please provide a =cpy to us.

l' A

don't knew how readily available

_t

=ight be.

13

=ight be on =ag tape.

14 MR. EDGAR:

Do you knew where to look 15 f

it?

THE ~4:TNESS:

I would start with Nuclear lo, Service and start tracking dcwn there. Again, somebody who it is through the SPR syste=

18 is the keeper od the tapes.

l o.

Q The data =r the curves?

^0 A

The curves would be in the SPR.

}

77 7

Q For both of the=?

c 63

-+

22 A

Yes.

I haven't seen the one frc= the late

_m, Oct:ber ine dent, but if they exist, that is where they'd be.

2 Ha te asked you fOr the 3 P.' ' s fOr b0th 3 ENJ AMIN R EPC RT!N G E ERV;C E

P00RORIGM 1

.;elly 46 1

cf those transients?

A

think ycu just asked f:: the second one.

5 2

Les =e ask for both of the=,

and the 6

reason : refer Oc October 23 is because believe you did refer to that second transient in your =e=c as being en Oct ber 23.

A Yes.

Q Q

Have you ever been at a criti:a1 Operating 10 reactor using an NSSS syste= supp1'2d by 3&W?

11 A

Yes.

I.n

• k..J.o.h.

,es?

e, n.

13 A

was involved with the initial criticality 14 and power escalation testing at Crystal River Onit 3.

15

is on the details there.

MR. EDGAR:

Referring te what?

le, THE WITNESS:

In =y resu=e.

1 s v.x.su....

u

.v.

. v. G a. n

.ac.

s S

1 8 8~2

? 7 o' THE WITNESS:

Yes.

cJU 10 Q

Other than that, have you ever been at a a0 critical operating reae:Or of 3&W's?

21 A

No.

I assu=e you are taking that werd " ritical" 22 literally.

I have been :: =any of the plant sites, a;

but net while they were criti a1 and operating.

2 Other than Irystal River, have y:n ever Onserved pcwer ran:e : erations at a 3&W plan:7 S ENJ AMIN R E=":ETIN G S ERVIC E

PDDR ORG NAL 1

n Kelly 47 e

A Observed the=, no.

Q Mr. Kelly, have you nade any statenents 4

5 in conne :ien with your knowledge cf the handling of the Dunn =escranda, the paper trail that you have 6

been referring to, or with respe : to the events surrounding er arising out of the TM: 2 a==ident, and by "a statement,"

mean anything that you have 9

reduced to paper or =emorialized or anything that 10 anybody else has reduced te paper or memorialized, 11 based on what you said?

in A

Anything te do with Three Mile Island, you are 13 saying?

14 Q

Yes.

A Yes, : have been interviewed by the nac.

15 Q

Have you received a transcript Of the lo, interview?

1.

A Yes, I received a tape.

It was a tape recording.

13 Q

Eas the tape been transcribed?

1882 239 A

My secretary transcribed it.

"O Q

You do have a transcription?

21 A

Yes.

M May have a c o.e v. ?

^6 A

read my transcription.

There were s==e gaps.

3 I haven't.croefread it and nade all the editerial n,.

rrecticas, but it is available.

They weren't sign fL:anz.

EENJAMIN R EFC R"*!N G 3ERVICE

900RORGNAL 1

n

v. o.--]

,. c s,.

a 2

What was the substance of your interview 4'

with the NRO?

5 A

They were interested in the first day of the 6

in cident and =y in7olvement with the first day.

Q What was your involvement en the first day, briefly?

3 A

again came into work and fcund cut that there had been a deprassurization incident at Three 10 Mile Island Unit 2; myself, acb Winks and Bob Twilley 1.1 put on a charter plane and flew-up to Harrisburg that la

~

scrning te investigate the sequence cf events, similar 13 to wha: : had done at avis-Bessa.

14 Q

Did you continue to do tha jcb in the 15 days ahead, he construction cf the sequence of events?

A Yes, that job, at least as to the data readily 16 available, and then teck over watches in the centrel 44 roc =.

18 Q

At Three Mile Island?

9 1882 240 A

Yes.

o Q

When did that start?

ol A

was en the third day I was there.

nn

~

Q When did you ge: Oc Three Mile Island?

23 Oid yo : ge: Oc Three Mile Island on the Sth of March?

34 A

Literally, nc.

I got := Earrisburg early that afterncen, checked into the nctel, and then called

.s

"'" me esa

= c, N w, A M l N M r m.. N, sum

= L m VLsu. -

= ame use me -eng summ u

c

P00R BRS R t

s Kelly 49 3

Greg Schaedel, and the three of us spent the whcie 4

day at his house because we weren't allowed a: cess

the Island, and didn't get access until Thursday.

3 Q

Was Greg servir.g as the loop closer?

e A

Yes, if you =ean by that, taking =essages fro =

Lee Rogers and calling Lynchburg, yes.

-a Q

So the phone was ringing with calls fr==

9 Three Mile Island to hi= and then calls frc= Lynchburg 10 to him, and then calls initiated by hi= in both 11 directions?

12 A

Never called the site, to =y kncwledge.

13 Q

Oid you bece=e aware of any reco==endations being =ade which were passed fr== Lynchburg to the site 1,

during the time that you were at Greg Schaedel's hcuse?

la_

A Not that I can re= ember of anything specific.

It 16 was an infermation relay; Greg was ge: ting infer =ation 1.*.

about what was happening and sending it te Lynchburg 13 and trying to get a reco==endation frc= Lynchburg en 9

10 restarting the reactor coolant syste=.

We went out 20 to dinner that day after 1: beca=e obvicus that we 21 weren't readily going ec get in:0 the site, but by the ti=e we ca=e back frc= eating that supper, they had

,e restarted the reacec: ecolant pu=p, and things were

]gg} }

j back under apparent centr:1.

2 Have yu sin:e bec:=e aware Of any EENJAMIN R EPC RTIN G S ERVICE

300R OR E L

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A Yes.

4' g

s it at the site er here?

3 A

kncv they were here.

They say also have been 6

at the site.

You know, I den't know what happens to the ones at the site.

~

MR. RCCKWILL:

Mr. Edgar, would those be g

included in tha: log which was supplied?

9 MR. IOGAR:

Yes.

The leg that we fur-10 nished to you in addition to the docu=ents we 11 furnished to you based on that icg.

l..o Q

! think we have been covering statements lea other than your interview with NRC.

Have ycu =ade 14 any other statements?

13 A

No.

You are my second interview.

^

And the statements :

a= referring Oc

1. o-x include anything ycu would have wri: en devn, too.

1.

Is there anything that ycu have written?

A No.

19 Q

We vill recess your deposition at this e0 time, leaving you subject to recall for further 61 testimeny should that be recuired.

We do net have

~~

nn any present plans to recall ycu fer further testi=eny, nn

_J bu: shculd we find that we need :

recall ycu, we will a;

advise your ecunsel, and he, in turn will a i e)- )

c ycu.

S ENJ A MIN R ERC RTIN G 3 ERVICE

1 2

Eelly Sta 3

(Whereupen, at 12:22..=., the wi-hin

,4 deposition was recessed.)

O

. C.e r P.o.

. C m..

.r.-..

v.,.....

e Subscribed and sworn to before me th i s _ _ _ _ _ d a v.

3 of _____________1979-9 10

,3.a.y_ _ _ _ _ _ _ 3. _. _,. _. _. _ _ _ _ _ _ _ _ _ _

11

l. _o n.a

?@ DUlRE 14 15 16 18 19

o 21 1882 244

=_

OO A

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3 ENJAMlN R EPC R"*I N G SERvt:E

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a Oirert Witness Joseph John Kelly, Jr.

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E.X H I B T S 8

Kelly Deposition 9

.f o..r I d e n. t i f i c a t i o n Page 10 108 Resume of Joseph John Kelly, Jr.

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n Reporter and Notary Public, and ROBERO ~IRKIN, 6

Notary Public, of the State of New York, de hereby certify that.the foregcing deposition of SA3 COCK & W * *,0 0 X by JCSEPE JCEN KZ,.Y, JR. was taken before us on the 7th day of July 1979.

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The said witness was duly sworn before the ec==encement of his testi=cny.

The said 10 testi=cny was taken stenegraphically by curselves 11 and then transcribed, to i_

The within transcript is a true record of the said deposition.

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We are not related by biced er carriage to 1O any of the said parties ner interested directly 16 cr indirectly in the =atter in centroversy, ner are we in the e=picy of any of the counsel.

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18 IN WITNEES WEERICT, we have hereunte set

__.1.Aday 19 of July 1979.

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