ML19256B642

Deposition of B&W by Jj Kelly on 790713 in Washington,Dc. Pp 1-37

ML19256B642
Person / Time
Site:	Crane
Issue date:	07/13/1979
From:	Joseph Kelly BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE
To:
References
TASK-TF, TASK-TMR NUDOCS 7908160242
Download: ML19256B642 (37)

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held at the offices of Morcan, 1

Lewis & Bockius, 1000 M Street, 4 v N.W.,

Washington, D.C.

20036 on the 13th daywof July,

'.979, commencing at 12:20 p.n.

before Simon Eanks, Jr.,

a ';otary

...I Public of the District of Columbia,

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v.:m e n, r. i s se MORGA", LENIS & 30Cr:US, ESQS.

3 Attorneys for Sabcock & Wilcox 1800 M Street, Wasnington, D.C.

20035 I

6, BY:

GEORGE L.

ECCAR, ESQ.

of Counsel I

-and-l j

JOHN G. MULLIN, ESQ.

House Counsel a*, i i

l 10! FOR THE COMMISSION:

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S T A ri L E Y ft. GORINSON, ESO.

Chief Counsel i

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' ' I f; T H R O P A. ROCKWELL, ESQ.

Assoc a te Chief Counsel f,

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i WIT *!ESS DIRECT Joseph John Kelly, Jr.

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PR0CEED INGS r

3 DIRECT EX AMI:: ATION CONTINUED l

MR. R O C K'..' E L L.

The records should reflect that at tnis time we are resumina the depositicr. Of Jcsepn Jonn r:e l ly,

I lJr.,

whicn was recessed at 12:30 p.m.

on July 7, 1979.

g Mr. Kelly, are you able to hear me?

i f

THE WITNESS:

Yes, I can hear you.

i MR. ROCKWELL-Because we are taking this deposi-s

! tien over a conference call, it is particularly important that t I finish the question before you begin to answer and that I 9

will try to let you finish the answer before I start another question, Okay?

l n,

,, i THE WITNESS:

Okay, I understand.

t MR. ROCKWELL:

If you do not understand the u'l question, please tell me and I will be glad to read it back M

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or repeat it so you will have the question clearly in mind

4 i when you respond, Okay?

3 I

U'i THE WITNESS:

Okay.

i MR. ROCKWELL:

The appearances for this deposition 16l ii would be the same here in Washington.

I i

I j

Are the appearances still the same, John, in gl Lynchburg, namely, are the people in the room the same?

'9 i

I MR. MULLIN:

Mr. Dunn has left.

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Walters and

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~ ! I are present with Mr. Kelly.

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l882 253 i

'Jhereupon, l

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JOSEPH JCHN KELLY, JR.,

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$I having been previously sworn, resumed the stand and testified s

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as follows:

By Mr. o.o c k w e l l -

Q.

Mr. Kelly, you understand you are still under the 4

! oatn administered to you 2t the beginning of your depcsition on July 7?

- i n

A.

Yes, I understand.

- i MR. ROCKWELL:

I guess the record should also reflect that the continuation of Mr. Dunn's deposition and Mr. Kelly's deposition and Mr. Walter's deposition, is pro-ceeding under agreement of counsel.

i f

Is that correct, George?

i MR. EDGAR:

Yes.

Sy Mr. Rockwell:

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Q.

Mr. Kelly, referring you to deposi tion Exhibit 24, d

.. ' which is your memorandum of November 1, 1977, to distribution.

I

!?'!Doyouhavethatexhibit before you?

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16l A.

Yes, I do.

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nf' Q.

You refer in that exhibit to, primarily to a September 24, 1977 transient at Davis Besse, but you also

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lrefertoatransientwhichoccurredonOctober 23, 1977.

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Do you have any more details on tnat October 23rd m

i

., t.ansient since your last deposition?

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'1 l A.

No.

I don't know anything else about it since I

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- i my last deoosi tion.

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2"l Q.

I believe we have covered,this ground, but let e

n i882 254 I.

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me just cover it again, quickly.

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Do yCu kr.ow whether it invol ved a f ail-to-open PORV' A.

No, I do not.

6 l

Q.

Do you know whether it involved the loss of all n

I feed?

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A.

I seem to recall that the incident started on a loss of I

feed water.

I don't remember any details cbout "all" feed.

If you mean by. "all" feed you are includinc enercency feed

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n i water also, I don't remember hearing anything about emergency feed l

l water.

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Q.

By "all" feed, I do mean main feed and auxiliary I

' feed.

Would your answer still be correct assuming that?

14.!

A.

If I understand your question, I will repeat my j

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i answer.

I seem to remember that the incident started with a i

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Wl loss of their normal feed water, I don't remember speci fics,

17 any specifics about what happened to emergency feed wa ter.

Q.

Okay.

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Do you know whether that transient reflected a l

,,,l pressurizer level high and a reactor coolant system inventory

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! low?

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A.

No, I was never told any of those details.

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Is it your understanding that there was, nowever,'

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i 23l premature termination of HPI in that pransient?

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1882 255

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f1y understanding is tnat it was bypassed and never allowed to initiate in tne October 23rd transient.

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That was a concern of yours in mcking the decision

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i to out cut your. November 1 c.ecorandum, is that correct?

A.

Yes, that is correct.

t

,8 Q.

Did you make, a t that time, an investigation as I. to why HFI had been by-passed?

'J A.

No, I did not.

As I stated in my earlier cesti-9 many, someone else would have been assigned to investigate j

i that transient.

I would not.

liy only interest was that here p3 was a second relatively close together incident of what I was 1

'l concerned about, the operator reaction of high pressure 1

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! Injection, ni i

Q.

Do you know whether at the time that you heard 14 l about the 'ctober 23rd transient, you wen t to the licensee l

If' l e v e n t report or site problem report for information on that?

m' A.

No, i did not.

l Q.

Did you do any reactineter data?

i A.

No, I did not.

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Q.

Did you go to any source to flush out your unde -

l standing of that transient?

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A.

No.

My only interest in it again was when I 21 !

I was not l

...,' heard that they by-passed high pressure injection.

l concerned about any more details of that incident.

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Q.

Referring to Exhibit 24, which is your f

24

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1882 256 I

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November 1, 1977 mencranoum, you state, I believe in the tnied sentence.

r.e operator stoppec HpI..nen pressurizer level began to recover *:ithcut regard to crimary pressure.

i Was that a r.

inferer.ce on your part, or was that a matter of direct knowledge of what was in the mind of the i operator?

I A.

That was an inference on my part.

i Q.

How did you draw the inference?

i 9 i A.

Now, we are talking about the September 24th l

e incident?

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Q.

That is correct.

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A.

Having reviewed that in some detail at the time, la l e

l I knew that they had resaturation in the, saturation condi-tions in the reactor coolant system loops when they had turned

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" l high pressure injection on.

So, I was inferring from that g

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that they could not have recognized the relationship between

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Saturation temperature and saturation pressure in the primary loop when they turned high pressure injection on.

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i Q.

Did you attempt to confirm the inference which i

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you have advised me that you drew, by calling or contacting the people at Davis Besse in an attempt to find out what nad l

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been in the operators minds at the time they made the decision f

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to terminate HPI in the September 24th transient?

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A.

No, I did not.

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23 Q.

Did anybody else make any contact with Davis Sesse b

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1882 257 E

w in order to determine what, in fact, tne operators had been looking at and relying cn, to your knowiecge?

I A.

Not to my knowledge.

t 4

Q.

At the time, did you make any review of operator

i l procedures to see what they might have been relying'en?

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j A.

No.

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'l Q.

Would it be fair to say that you did not take I

.i I any of those steps, either with respect to the October 23, t

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9; 1977 transient?

f A.

After the October 23rd transient, I did go down as in I previously stated, to the nuclear service area where the l

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! simulator instructors work and talked to them about what 12 '. they were teaching operators 'on when to secure high pressure la injection.

14 Q.

And that was your conversation which you already

l told us about with Mr. Lind?

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'6 A.

Yes, that is correc*

t-l Q.

Did you ask Mr. Lind or anyone in the training i

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to simulate on the B&W simulator, either the g l depa rtment,

! September 24th or the Octocer 23rd transients?

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i A.

No, no I did not,

.v Q.

Do you know whether anybody else did?

n A.

I don't know, j

f Q.

Did you know Mr. Lind before you went down and 3'

talked to him that day?

NI 1882 258 o

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9 A.

I'm sorry, I missed the first word of the cuestion.

,i Q.

Did you knew Mr. Lind before you went cown and

! talked to him in reference to the ransient?

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A.

Yes, John Lind worked with me at Crystal River,

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l Unit 3 start-up for a period of time.

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Q.

How long have you kncwn John?

A.

Excuse me.

Did you say how long did ! knew him?

Q.

Yes.

A.

It's in the order of magnitude

r. months as B

l opposed to years.

I would think he was ;own there, to my p,

knowledge, maybe six months at the same time I was.

Q.

Had you had much contact with him during that t

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period of time?

A.

I saw him from time to time during the week, yes.

i Q.

In what regards?

What kind of dealings did you

!^ i have with him?

t

n A.

John Lind was a shif t supervisor augmentor in I

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' Crystal P.iver Unit 3, and he was in those responsibilities often providing advice.and consultation i

g l in the control room, to the Florida Power Corporation snif t sucervisors on watch.

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and my duties as technical superintendent

,' In that resoect, L

i during that period, placed me in the control room Quite often l

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monitoring the progress of various tests.

So, -in :na t con-i a:

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", text, I ran into John, as I said, severai times a week,

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i882 259 t

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Q.

You had occasions to talk to him and discuss I

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things with him?

3 A.

Yes.

4 Q.

Have you ever krown John to express any dcubt about a

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a position he held?

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A.

Can you rephrase the cuestion?

I'm not sure I f

understand what you are asking?.

8 Q.

Sure.

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9 Had.you ever known John Lind to express any doubts' 6

f 10 about his opinion on a subject, or his knowledge or under-c standing of a subject?

11 f

A.

I can't recall any incidences.

John normally g

spoke positively.

13 Q.

When you had the conversation with him at Lynch-14 burg in reference to the two September and October transients, I

j 15 i

did you ask him specifically how the operators were instructed t

16 with regards to termination of HPI?

17 A.

I asked John what instruction they gave to the 18 operators, if that is your question.

Q.

Yes, it is.

7g A.

That is what I asked him, what instr.sctions did 20 we teach operators on when to secure high pressure injections.

21 Q.

And he gave you an answer that indicated what the instruction was that they were to look at pressurizer andreactorsystempressure,isthatcorredh002 b

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Di d you ask hin wnsther sufficien; enonasis, in s

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Didn't ask tna; scecific cuestion, but I was

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after that t.v,oe of ansaer and J;hr. said -hat he was convinced

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high Dressure inje : ion na d :een ter-ina ted orematurely?

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1. 9 John tc Degin witn, and

c:d hi- :nat.

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Dic you emonasize :

• i-that s o m e v. h e r e t n.a t instructics seas

.ct getting across to tne coerators?

4 6

A.

I may have.

I don't rememrer using those ecrds a

either.

I remember leaving there witn One incression :nat the subject was beinc taucht by the simulator instructors, and t

I fel t tnat if I ::uld get aspecpriate words, i f they were needed, published. tnat in my ninc, it would have been adequately i

covered at that point.

I i

In ctner words, I thought the operators were j

g, being taught it in the simulator, but maybe it needed to be i

l reinfor:ed in wri ti ng.

i.>

Q.

Did you tell John that he ought to take immediate t

ia j steps to reinforce tha t instruction?

A.

No, I did not.

I told him I was going to write i

!5! a letter to Don Hallman or nuclear service, maybe I didn't i

I i

isi use Don's name.

Again, as I statec earlier, I cannot net it l

.-; straight in my nind wnetner I was talking in future tense, I

leforpast tense.

I either had just written that memo or was going to.

19 !

Q.

Did you tell Lind that there ought to be a review

. l m

, within the training department to see what, in fact, had been i

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put out, and to make sure that what was being put out j

22 to operators was sufficiently clear and precise, so that there

, would not be a repetition of the kind of premature termination.

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1882 262 ni 6

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13 of HPI tnat had occurred in Statercer and again at October at Davis Bes:e?

A.

I con't remember making sucn a suggestion to f

John Lind.

Q.

At :ne time you wro:e your.90vem:er 1 memorandun, a

Mr. Kelly, were you aware of a procedure available within i

i the S&W organizatien for nandling basic concerns' A.

Yes.

i Q.

Were you aware of the existence of something j called a prelimina ry sa f ety concern form?

a) l A.

I don't recall ever having seen one but I am sure 11 4

that there must have been a form tha t went along with it.

12 Q.

Were you aware t;1at Mr. Taylor, in the licensing

1. '. I section, was the in-house administrator of that procedure?

s i

A.

Yes.

' 7' Q.

Did you consider putting your November 1 memo-1 1

n ' randum on a preliminary safety concern form?

i.

f I

i n;

A.

No, I did not.

i i

Q.

Did you believe that your November 1, 1977 memo-I! randum would be plugged into the system for nandlirg basic 19 !

! concerns that was then i n exi s tenc e wi:n i n E S'.i?

J') !

A.

Would you repeat the first part of that.

I j

don't know what you were asking me.

22 I (Whereupon, the pending question was read by the il reporter.)

l 1882 263 L

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By Mr. Rockweil-e Q.

Do you n2ve tne cuestion in ?.ind?

A.

Yes, I do.

t When I wrote that memo, I didn't know wrether it would be a preliminary safety concern or not.

My intent was I

6I I

to get it in front of the people who would know.

I think my

^ I memo says that additional guidance may not even be recuired.

L 2

j

In other words, there was doubt in my minc, and I thought by writing this memo, tnat I would get to the people who woulJ know what information was being put out in detail, and that i.,

?

if it had to be revised, they would revise it.

And, as to k

whetner it was a oreliminary safety concern or not, I didn't f

feel like it was of sufficient importance at that time.

I

?

mean, I didn't feel I had enough information even to make that a

decision.

I didn't know whether we were telling the right

"'. things or not, and that's why I wrote the memo.

I6 Q.

Did you talk with anyone before you wrote the memo-t

i randun or af ter?

A.

I talked to, as I pointed out, I talked to my immediate supervisor, Eric Swanson, t

g, I

O.

I am sorry.

I did not finish the question.

m Did you talk to anycne before you wrote your memo ;

21 i randum or after as to whetner the concern you had was the kind-

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, of concern nat ought to be expressed in a oreliminary safety l concern form?

1882 264

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A.

No, I don't remember discussing that.

Q.

Did you nave that preliminary safety concern pro-I I.

cedure and form in mind as a possible..ay cf pursuing fcur concerns at the time you wrote your memorandum?

I I

i A.

I don't remember considering that.

(

i i

i Q.

I know we nave gone thrcugh whc the people on the 7 ! distribution of your memorandum are, and what ;ositions they l

i hold.

I don't have that directly in f ront o f me.

But, my recollection is that ene of the persons or. distribution is t

I" in the licensing section, am I correct?

A.

Not on my November 1 memo, no.

There is no one i;

in there tnat at the time was in licensing.

Q.

Okay.

Referring now to decosition Exnibit 35.

Do you f

4 have that exhibit before you?

i la e A.

Is that Frank Walter's memo?

I f

Q.

Yes.

That is correct.

I I

17,

A.

Yes, I have that.

I m

Q.

Let me read the first paragraph of the memorandum.

A.

Was that a question?

n,.,

i i

Q.

No.

I am just getting something.

.,g lI Let me read the first paragraph of the memorandum.'

b il And this is a memorandum from Mr. Walters to yourself in

t response to vcur November 1 memorandum, is that correct?

1882 265

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16 J

Q.

"In talking with training cersonnei and in the r

0 inion of tnis writer, the operators at Toledo rescond in j a correct manner", it may be " responded", "ia a correct manner i

l considering how :ney had been trainec and the reasons behind t

J j the training."

nl an accurate readir.g of the first paragraph' Is that i

I

~' of the memo?

A.

Yes.

{

s 3

Q.

Did you understand what he meant by that?

i l

A.

I think I do.

p, Q.

What did he mean?

I am referring to your know-ledge at the time you received it?

'./

A.

Fran( is saying that ne talked to training pecole and whoever he talked ta and Frank both believed that the

!4 Toledo people did the right thing.

If I'm answering your l

l questior.

i i

i i

!6 Q.

The right thing in light of how they had been i

i i

i trained?

gl A.

That is wnat he is saying.

j i

I Q.

Did you ever ask Mr. Walters how the operators 19,

had been trained wnich would suggest tnat they had responded 20 i l

I properly?

T

• A.

I never talked with Mr. Walters about this memo

..., i

-i at all until in the past couple of months.

23 Q.

Did you wonder when you read that paragraoh, what 1882 266 24 i

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4 training th e c ce ra t o r s

.,e -e ge t t i n g

..t i :n w oul d suggest that tneir reaction hac ceen correct in light of their train'ing?

l A.

No.

I had already talked to John Lind by this a

time, and when ! read this ! just got the impression that Frank Walters was confused and decided to go ahead and esca-6 !

l late it after talking to Bert Dunn.

Q.

Did it ever occur to you that John Lind had been i

confused?

9 i A.

No, because at the time I was talking to John i

Lind, there were other simulator instructors there, and I l

in t

!! believe 1 mentioned it the last time, Harry Helayer was one 11

!I of them and there was more than two, and they were all in agreement that they were teaching he correct things.

)

Q.

Would it be fair to say that Walters' first para s

u' graph in his memorandum is in dir'ect conflict with what Lind t

i U' i had told you when you went to talk to Lind?

l i

mi A.

Yes, I would think that that is a fair reading l

g l of the words.

Q.

And did you understand that Wal ters had written j

I

• l his first paragraph a f ter talking with three former B&W train--'

ing instructors?

'm i

I don't know who Frank talked to about when he A.

i

-> 3 says "with training personnel", I don't know who he talked to.

I 22 i

Q.

At the time you read the memorandum?

01 A.

At the time I read the memorandum I did know. What i

24

<882 267 c.

I l

13 t

1 I am saying is I dar.'t believe tnat now I still snow who he f

f talked tc, I

MR. R O C K',i E L L :

Off the record.

i 4

i (Whereupon, there was a brief discussion off the record.)

bI

{

(Whereupon, the pending question was read by the I

- I j repo rter. )

MR. EDGAR:

And you do not today, is that correct?,

l i

9 TH E '.1! T N E S S :

I don't think so.

I con't think I i

do.

If you ask me to name those people, I couldn't say who i

p, I

Frank talked to, even right now.

t By ftr. Rockwell:

1:

Q.

Would it be f air to say that at the time you

, read the memorandum, you did appreciate that Walters' fi rs t I

paragraph was in direct conflict from what Lind had told you? l i

l

A.

Yes.

That was in direct conflict with what John 16 Lind had told me.

t i-Q.

Did you take any steps to try to resolve that i

conflict at the tima?

A.

I talked to Eric Swanson, my supervisor, about it, and we decided to go ahead and I told Eric at the time, v

that I thought that Frank was confused about what my intent j

21 was and Eric and I agreed that we should go ahead and escalate; 22 it and get Bert Dunn involved, because Bert Dunn was the unit i

i 23 manager, have him write a letter to try and get some resolution!

28 1882 268 l

s I

-=u mum-i

8 19

n m;. :orcerns.

That <.as tne steps ! ::ck.

i Q.

Did jou real;;e 3: th:: :i e that i'..~ 2 l t e r s

r. a d been talking witn trainina cersonnel and had arrived at the enclusion that he excresses in his #irst paragra h,

that one grouc of pecole wnc. at least at one time had been training instructors at 27. W, and then the current training instructors, tnrough "r.

Lind, were saying things acout what coe ra to r instructions were directly in conflict.

A.

Reading the entire mem I got the impression that ml Frank may have nut even been asking the correct ques tions of the

! training people.

73 I

Q.

Did you ever go back to him and point that cu:: and try to get it resolved as to whether he was asking the correct questions of the training people that he was talking to?

14 A.

No, I did not.

I jus; escalated it to Bert Dunn.

I.>

Q.

Referring to the second paragraph.

N "My assumption in the training assumes, first, 4

1 i that RC pressure and pressurizer level will trend in the same I am having troucle reading s ! direction under a LOCA for" l

this.

Let me ask you to read it, the second paragraph.

g, THE WIT, NESS-

"My assumotion and the training

! assumes, firs t, that RC pressure and pressuri:er level will 21 ! trend in the same direction under a LOCA.

For a small leak i

i 22 :

they keec the high pressure system cc up to a certain flow to i

4 "1 l mai nta i n p res s u ri ze r l evel".

g j

24 i

e

l 20 2

0 Thank you.

a A.

Do you want me to continue?

Q.

Let me ask you a cuestion now.

4 i

MR. EDGAR:

Joe, let's make certain we understand what wo rds we are dealing with here.

t This is how you read tne words, is that rignt?

THE WITMESS:

Yes.

I am trying to read the words as they look to me.

By that I mean he didn't say "high pressure system, he said "t!P" system and he has run the words "a" and i

"small" together.

pi By Mr. Rockwell:

i Q.

We understand your reading of that paragraph is 4

what you see there and is your interpretation of what is

t written down in the ense of what it says --

14 l

A.

G rama ti ca l corrections and things like that.

Q.

(continuirg) -- there may be, there may be some i

16 l dif ficulty in reading some of the handwriting here I under-1-fstand,but referring to that second paragraph, the second j

sentence indicates for a small leak they keep the HP meaning, i

,e i

i l high pressure systems, up to a certain flow to maintain I

pressurizer level.

20 What was your understanding at that point of f

21 ! what operators were suoposed to do in terms of maintaining l

,,, 4 i

cressuri:er level ?

23j A.

You mean back in November.when I read this?

188'2 270 2'

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During a LOCA?

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1882 271 e

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I

wh A.

Yes.

0.

Was it your un erstar. ding.at the tire,that RC pressure and Dressurizer level would trend in the same direc-4 tion?

.~>

A.

Not under small LOCA conditions, no.

M Q.

In fact, you have gotten that understanding only review of 52ptember 2tth and Octooer 23rd transients, from your is that correct?

A.

That is correct, except that I never reviewed the m

Oc to be r 23rd transient.

But my information at the time was based on the September 24th transient.

Q.

Okay.

But at least on September 24th transient.

you had gained clear understanding that pressuri:er level i n ne RC system cressure had not been trencing into the same n, di recti on ?

i'"l A.

That they do not necessarily trend in the same

'6 I direction under those conditions, that's right.

Q.

In fact, under those conditions, they had not i

! trended in tne same direction?

l 3l A.

Right.

n.

O.

Did you make any inquiries of John L i r. d as to

.:q l whether the training program instructed opera tors that under nt I certain :ircumstances, at least including the kind of cir-i

~,

cumstances tha t occurred i n Septenter 22 n Davis Besse transient,

nat pressurizer level and RC pressure would not trend in the 3

1882 272

~

-m+

-ee

l 23 1

same dire::ior?

A.

I con't remember asking Jcnn 'ind that, no.

O.

Did it occur to you that that question oucht to 4

oe asked of :ne training program at tnat ooint?

A.

Tnat's why I wrote my Teme, yes, to see if we were covering adec ately what the operators should be getting on guicelines to secure high pressure injection.

O.

And is that why you put Mr. Norm Elliot on I

l 9

distribution of your memo?

j l

I to,

A.

At the time I put Mr. Elliot on the memo more for

\\

information.

My intention was to get the procedures written and

'. If they needed to be, to get the procedures changed first, and tnen through the system thct would filter down to Mr. Elliot l and into his training program, if his training program was in,

u adequate.

15 Again, I thought, after having talked to instruc 1

> tors, I thought his training program at that time was adequate'.

" i Q.

Did you recogni:e at the time you read the Wal te rs ' memorandum, that the first sen:ence of the second l

ii paragra;h g

A.

a s tna t a cuestion?

2' i Q.

I have not finished it yet, i

2!

(Continuing) -- that the first sentence of the

. '. ' l s e c o r. d paragraph made an assumption about training or made I

q~

an as umption about what the operators were trained to de l

1882 273 e

i 0

l i

g 2,,

that was not re fl e c t ed in the training program a; that t i T.e ?

?. c, that questien is wrong.

Just a second, Fr.

r' e l l y. '

Did you realiae when you read the eirst sentence of :ne second paragraon tnat tnere was an assumotion in the training program which was no longer ac: curate in light of i

l the Davis 5 esse transient, namely that pressurizer level in RC pressure would trend in tne same direction when, in fact, I

' ' the experience at Davis Be:se was that they.sould not, at least under certain conditions' 6

A.

I still dicn't hear that as a questicn.

I'm sorry.

Could you have him read it back and see what you are asking?

u (Whereupon, the pending question was read oy the

' reporter.)

11 A.

Okay.

I understand the question.

l When I read that sentence it say.s "my" assumption

! or "my" as beinn Frank Wal ters.

And I had read the entire i

i memo once or twice at tha t point before I ma_de up my mind, and my assumption, Joe Kelly,was. that Frank Waltges was, con-i fused, not the training department.

Q.

In ether words, you understcod or you pelieved at m

' t hat time t h a-t Wa l te rs ' as s ump t i.on a b.o u t w h att $he training R

l wa s, was s imply inaccurate?

t A.

Yai, 'I be l-iev e.tn.at F r.a n k Wa l te r.s ' ' a s s ump t i on s p,

W Te w T7n g.

1882 274 m

~

J e

f s

l 25 f

O.

Again, did you go back to training in orcer to I

cationalize or Oc resolve this apparent conflict between wnat Walters was saying and what John Lind nec toic ycu?

4 I

A.

I made no attempt to co that because it was John Lind and c.arry Helmyer and others who, Harry tal ked to them as a group, convinced me that they were teaching it.

So, !

I just assumed that Frank was the one who was confused.

i I

Q.

But you did not 90 back and present them with i

tnis memo. I take it, and ask them for an explanation?

l i

in i A.

No. I did not.

i i

Q.

What does fir. Walters nean when he refers to 3;

"hydroing" in the third and fourth paragraphs of the memo, and if you want to take a moment to review those paragraphs, M

o please do.

14 i A.

I'm reading that right now.

i 15 -

(Pause.)

When I read that, to me, Frank is saying, that 17 leaving hign pressure injection on will fill up the reactor i

coolant system completely, including :ne steam volume and I

pressurizer and continue when it gets into a solid water con-g, dition, continue to increase reactor coolant system pressure up to i

! code safety pressure and that is what he is saying when he i

at,

is sayinn hydroing, hydrostatically testing, this is what that.

22 '

l words means to me.

1

+t

- j Q.

So hydraing means taking c,he system which includes 887 275 l

t j

i

-es l

t

~

l 2o j

the RC coolant systen and pressurizer uo to a solid condition and bringing it up against, presumatly, 0 set pcints for the various release valves, is that correct.

A.

Yes, of course, in a formal system hydro, you go to much higher pressures than the code safeties.

But you have e,

to take them out of the syste' and blank them off.

In this

~

' case, I understood that he aeant going up to the code safety release valve at that point, Q.

Then, referring you to the fourth paragraph.

u gi l Let me read it.

"If you intend to go solid, wnat about problems with vessel nechanics".

What does he mean by that?

A.

I assume he was talking about brittle f racture.

O.

And what do you mean by "bri ttle" f racture.

A.

Hardened steel under conditions of pressure at low'

'n temperatures will break brittlely like glass.

-i Q.

So, you understand that he was expressing a ccncern g f in tne first sentence of the fourth paragrapn about cotential failure?

A.

Thi s confi rms a more of -- in.my mind about the

.v confusion that I thought Frank was under because in the con-

.m i

ditions we are talking about, reactor vessels would be hot i

l enough 50 that brittle f racture would not be a problem.

So, t

i

--,., i' again, on that statenent, I was under the impression that I

I at Mr. Walters was confused.

I s

1882 276 b

8 m

i 27 J

Q.

Did you go back and attemot Oc clarify that con-fusion or that apparent conflict,witn your own understanding with "r.

Wal te rs ?

A.

No, I did not, because at that time I dismissed that concern as a result of his confusion and it really was P

c not in the realm of my objective of giving guidelines on when to secure high pressure injection.

To me it was a different tyce of problem v:han you talk about brittle f ailure, and even 9

talking about brittle fracture had nothing to do with letting the high pressure injection system run even up to the code n,,

safety problem, code safety check points, because the vessel was hot under those condi tions and bri ttle 'ailure would not be a problem.

li i l

I Q.

P4 ferring yo u now to the second sentence of the i

fourth paragraph.

Let me read it:

"Also, will the code in the electromatic valves b

M l relieve water (via steam) at significant fl ow rates to keep the RCS from being hydroed."

j i

Is tnat a correct reading of the last sentence l

gl i of the memorandum?

I a,

A.

Yes, that is what it says.

Q.

What did you understand he meant by that?

n, A.

At that point, Mr. Wal ters ' memo had me confused i

also, because I could not understand the use of the word

1. l

" hydro" in that sentence.

How that correlated with his use i882 277 4

i

$ ~t

I j

og 1

i 2

Of tr.e word with hycro in the third paragraph tnat we have f.

not talKad 3 bout.

In other words, i f the code relief and electro-4 matic relief are lifting and relieving water, primary pressure will stay at 2500 pounds.

It will not go up to hydrostatic test pressure at 3125 GSIG.

t the time you received that memorandum f rom Q.

At Mr. Walters, did you understand that there were any restric-tiens or concerns abcut going solid?

i A.

About going, about taking the reactor cooler

o system solid during a los: of coolant incident, is that what ycu are asking, or at any time?

Q.

Any time, other tnan for hydrostatic tests?

i MR. EDGAR:

Let's take it both ways.

t By fir. Rcckwell:

Q.

Okay.

Let's take for loss of coolant incident ni l fi rst.

I.

16 A.

Loss of coolant incident, I was aware of no 3,

l n,

i i

conce rns about taking tne reactor coolant system solid.

j i

y '!

Q.

Were you aware of any concerns about taking l

g,

'"lreactorcoolant system solid other than during a LOCA?

- i A.

Wouldn't do it during normal operations.

l i

2: i i

?

Q.

Why not I

A.

Well, because the 3dvantage of having a steam 2'

bubble in the p-essurizer is the fine pressure ragulation and t

i i

i882 278 meme eme

29 Control tnat you have with the stear turble tnere to cusnien Cnances in tr.e reactor 001300 system 'n~2ntory.

If you take o

a pressurizer solid durir.g normal C;eritions, you forfeit tn3 advantage Of Dressure control during normal operation.

Q.

At that time during the Fall of 1977, rehat c,

operator instru:tions existed which advised the operators that it was permissible to go solid during LOCA transients?

i A.

I don't know what instructions would have told i

's them tna t.

That was part of my original reason for writing m ! the letter, to see what instructions we were putting out to tne customers and to the opera tors, when to secure high i

g pressure injections during a LOCA.

Q.

Did you ever followup in nailing down exactly

a

! what ins tructions were being given to operators wi th respect i

4

to goino solid in a LOCA transient ~after you put out your November i memo?

A.

I don't remember looking for instructions tnat talked about whether or not you could ce solid durina LOCA, g: no.

I never followea tnat up.

Q.

Would it be fair to say, ta king the Wal te rs ' memo-

• randum as a wnole, that because of what you perceive to be mis-ei !

I understandings or inaccuracies on the part of Mr. Walters in l

21l!the memorandum, that you essentially dismissed it?

~~-.!

l A.

That is a f air statement.

5

" i To me, the value o f Frank,Wal te rs ' memo was in i

a, 1882 279 I

~'

t i

(

I

30 i

o its cro-nting me o escalate the procles to Bert Cunn to get 5

i

'--antion on ti, en my concerns.

--a O.

Curtng your, the first chase of your deposition s,

' in Lynchburg, you indicated that af ter you returned from. Davis l Besse, following Septemoer 20th transient, and after your brief-l ing, to, I think you said some 30 people at Lynchburg, that ai I

_ i a plane load of peccle went back to Davis 5 esse.

Do you know who went back to Davis Besse on that i

plane?

A.

I think, still the only one I can remember was j

o interested in going back was Joe Lauer, and if you ask the cuestion that way, I can't even say that he actually went back.

He may have changed his mind sometime between I

', that briefing, and when the plane actually left.

t I

l i

O.

Are you aware that tne plane did go ultimately 14

'l back to Davis Besse with some people from Lynchburg?

l A.

That is my recollection, yes.

i l

How often do you personally go out to investigate l-l Q.

transients?

g I

A.

I have left Lynchburg to investigate two, the l

t

t. u.

cne at Davis Besse and the one at Three Mile Island on i

i i

28.

21l March l

Q.

Of '79?

l "i

A.

Yes.

0 Is it a practice of S&W to send people to a site r

1882 280 ammam==.

-.=--====e_

...-=.ww

..m, 9g

i i

I 31 wnere a transient nas cccurred and accears to ce s i n n i f i c a r. t in some way?

A.

Yes, if its chosen to be a significant transient, it is i

i our practice to send someone out to the site, 1

Q.

How often, to your knowledge, does that occur,

r. a n e l y, sending someone out to investigate?

A.

I can remember Sob Wings going out to investigate L

a transient and smoke SMUD, that's the only other one that presently comes to mind.

Q.

Did Dunn ever see the Walters' memo?

Did you show it to Dunn?

i 3., (

A.

I don't remember ever showing it to Mr. Dunn.

f Q.

Did Swanson see it?

.\\

[,

r A.

If I didn't show it to Eric, ! told him about it.

l 14 !

I don't remember showing it to Eric.

i Q.

What was his reaction to either seeing it or to

' hearing about the substance of it from you?

17 A.

At the time, if I didn't show it to him, I would s

have given him my opinion of it and reccamended to Eric that we pursue a dif#erent path, and as a result of tnat conversa-i.,

tion, we decided to talk to Bert Dunr. and get Bert again to write a letter.

a Q.

And the opinica of the memorandum that you would have aiven to Swanson, was that Mr. Walters apoeared to. be mistaten or not understanding the issues involved?

l i

NN 1882 281

...d I

i i

l 32 A.

That.tould be a

1. air caraohrasing of what I said, t

0.

Is Mr. Karrasc-neac cf your unit:

l A.

Yes.

Q.

Did you have any conversations witn Mr. Karrasch i

1 at all f-om the time of the Davis Besse transient to the time of the T"I2 accident about the issues raised in your and i

Bert Dunn's memorandum?

A.

No, I don't remember talking to Mr. Karrasch about that.

Q.

Was it he wno referred Dunn's memorandum to you?

in No, excuse me.

You were on the distribution of Dunn's memo-randun, weren't you?

A.

Yes, o

I Q.

You do not remember having any conversations with n' him at all during the time period from September 24,

'77, to March 23, '79?

N' A.

No, I do not.

?

0.

I think you said i n your l a s t section of your

~ deposition at Lynchburg, that you had had a brief conversation-y with Mr. Karrasch in the hall about what had happened with Hallman's memorandum of August 3, 1978, came to him, is tnat i correct?

3 A.

But that was af ter the Three Mile Island incident.

Q.

Rignt.

But you did have a brief conversation i

1. afterwards?

n.

1882 282 I

4 i

23 A.

Yes.

i C.

And -ecap tulat: that 'cr m. e,.euuid you?

A.

That was early in June, first week in June, Den Hallman :alled me on the phone and wantec to go over this series

}

of memos.

I finished talkina to Don and Frank Wal ters at a

that time.

I just left Don's office and <!as walking back

+o my own desk when I passed Bruce K2rrasch in the hallway.

At that point I asked him what he knew abcut that memo and I don't remember his exact response, but it was on the orcer 1

to of shrugging his shouldtes or saying he couldn't recall it at that time.

This was briefly in the hall as we passed each other and talked.

O.

Is that s::n and substance of that contact?

l A.

As I can rerember.

Q.

And is that the only contact wnich you nave had with "r.

Karrasch on this subject up to the present?

A.

No, I talked to tir. Karrasch again this Monday.

i Q.

Did he have any comment?

I A.

It was the beginning of this week.

n, Q.

Did he have any comment as to what had g,

happened in the handling of the concerns raised by your i

28) a

! memorandum and Bert Dunn's two memoranda?

21 l

A.

That is what I assumed your previous question was when you asked me if I had talked to him about it.

Yes, we talked about what happened to the memq.

i 1882 283

34 2

0.

Right.

But you said ycu had a second conversation g

witn r. i r within the last week?

A.

Ye s, th a t wa s fionday.

Q.

Okay.

And what was said in :nis conversation?

l A.

I told him that, a brief summary of what nad happened while he was on vacation in this area and about f

my previous testimony, and I asked him what had happened to

~

t 3

that.

i l

o Q.

What did he say?

j f

A.

He said that he had the memo, he had gotten the f

I meno and that he sat on it for a few months, and that 12 -

l periodically, Don Hallman had called nim and asked him what k

l the resolution was and Bruce says that around the turn of the

4 year, Christmas time or early January of 1979, we are talking about now, that he reread the memo from Don Haliman, decided i

that he agreed with Bert Dunn and that he called Don Hallman I

7 and told him 2:

i 3

That was the essence of what Bruce had told me happened to him.

Q.

Did r,c say wne:her he hac ever sent a memo back ft to Hallman?

1'.

He specifically said he did not.

It was all A.

telechone conversation.

l O.

Did ne indicate wnat Ha11 man's response was at 188? 284 u

g-25

35

)

the time ne called Haliran anc told nin tnat he was in agree-ment and that he nac notr.ing more to acc7 A.

No, Eruce didn't tell,e 2 hat Don Hailman's response was.

O.

Have you talked to Hallman about that, aoout o

Karrasch's call.

A.

No.

Q.

Around the beginning?

9 A.

No, I just had conversation with Mr. Karrasch on f

'n i Monday, and I haven't seen Don Hallman since.

I Q.

Have you had any conversations with Hallman about g

!Hallman'scontactswith Karrasch following August 3, 1978?

a!

A.

The last I talked to Don Hallman about this was l at this early June meeting that I mentiored, and at that time, it ii I don't renember Don saying anytning about conversations with l

Bruce following the August memo.

i D'

Q.

What was the substance of that early June meeting l

J 7

between you and Hailman, or conversation between you and l

t Hallman?

i t

i A.

That is the one that I'm saying was there also f

4 i

with Frank Walters and we went over the series of menos that

,6 l

j deal with this subject and talked about what we had thought

. 1

had happened to them.

l Q.

Did Hallman, at that time, nake any reference to J'

j the fact tnat Karrasen nad callee hi=,back ane tale him tnat 1882 285 4

D

36 i

ne,.arrasch, was satis'ied with Dunn's prescription and i

r.otning more need be added b;.

f' r. Karrastn's departrant's clanned integration.

A.

No, he didn't bring that up, net that I remember.

MR. 20CK'.-l ELL-Off the record, (Brief discussion off the record.)

By Mr. Rockwell:

i Q.

Mr. Kelly, that is all I have for the time being.

At this time we will recess your depesition again leaving you

n i subject to recall for further testimony should it be needed l

I as usual.

If it is needed we will advise you through counsel.'

4 l

Thank you.

(Whereu;on, the deposition was concluded, y

t i

l n!

Joseph John Kelly, Jr.

I Subscribed and sworn to C'

\\

before me this ____ day 8

i' i

of ______________ 1979.

I i

f

9,

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i 2'.

! Notary Public l

2:

5 22 5

i n.

5 l

u 1882 286 2"

on 6

W

,.J/

C,-

Pn,.t'.

c n'. t. r I c /, t r x r

c v

I, Simon Banks, J.D.,

Certi#ied Court Recorter, do hereby certi fy that I reported the cestimony of tne witness herein, over speaker obone, in stenctyoy, and that the testimony was reduced to typewritten form pursuant to my direction.

I f urtner certify that the testimony herein con-stitutes an accurate record of the proceedings had.

Simon Banks, Jr.

t 1; 1 1.*>

I

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f I

i 1882 287 8