ML19256B646

Deposition of Jf Walters (B&W) on 790713 in Washington,Dc. Pp 1-35

ML19256B646
Person / Time
Site:	Crane
Issue date:	07/13/1979
From:	Rockwell W, Walters J BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE
To:
References
TASK-TF, TASK-TMR NUDOCS 7908160254
Download: ML19256B646 (35)

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-i.. .y.n-..; ; .v..,. ; m.g7. 9 .aun n ,l.................................. l i ~ l, u. i pi i I 11 I i .l i t;I DEPOS ITION OF J A!iES FRAtlKLIN ',lALTERS, by j l 3., j WINTHROF A. ROCKi! ELL, COUlSEL Ofl BEHALF 0F TH E C0:!MI S S I0tl, j l Il held at the of fices of Morcan, Lewis & Sockius, 1500 M Street, l 11 i hH.W., Washington, D.C. 20036 on the 13th day of July, 1979, i r }

commencing at 1

00 p.m. before Sinon Banks, Jr., a flo ta ry Public of the District of Columbia.

t-i I g 14 l i l i n .u >I i ~ l l l 1883 163-i i i j P. 79 0 816 0 ppf s 9 i b

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M O R GMi, L E'<.'I S S S O C K : L'S, Esis. Attorneys for Babcock !..i i l c o x 1500 i' S t ree t, N.'.. 4ashington, D.. L--a 4L - BY-GECP.GE L. EDGAR, ESO. Of Counsel ~ i -and-JOHN G. MULLIN, ESQ. l House Counsel 1 u d l I in! FOR THE COMMISSION: l l f STAfiLEY M. GORINSON, ESO. ,1 Chief Counsel 12l WI?!TH ROP A ROC K'.iEL L, E SO. Associate Chief Counsef E 1:i l t u ALSO PRESENT: i I JOSEPH JOHN KELLY, JR. 1, I .c t n: i j 1m 1s i i 1883 164 2:1 ! i = I e I 24 ! i '.I l 'A l t l

2 e INDEX W i ~'! E S S DIRECT I t James Franklin Walters 3 s t 9 e 4 i i 9 4 1 f 10 I. l i i a l i I 6 IJ [ i 4 1:1 b i l 14 l \\g y '! l'i i* t I 1A I l i t o n, i i h 2'I f 21 1 1883 165 l u, 2:1 i j s l 24 l 25 1 i i i

? C' OCEED: N 3 5 c........-,s - - -.f. m........... ..-.bi L. i..en,!VI. 13. ViMT PR. ROCKWELL: Is "r. Walters ready to go? I ~ MR. "ULLI'G: Yes ne is. l MR. ROCKhELL: Okay. At this time we a re re-conveneing the cecosition of James ~ranklin '.ialters, which j was originally cegun on July 6, 1979, and recessed at 1:30 p. I c on that da te. i. t Mr. Walters, because we are takir.; this deposition t ' ' over the telephone, it is particularly important that you wait i ' until I firish asking my question until you begin to respond 8 9 i g, j and if you do not hear my question, will you please tell me ,l so that I can repeat it. Is that agreeable? THE WITNESS: Yes. i

2 l MR. ROCKWELL:

For purposes of having the proper 1 1:: i appearances, am I careect in understanding that Jonn Mullin s i is en the other end at this point as counsel for B&W and that 13 I i I f* j Mr. Walters is the only one in the room? j l,.

s MR. MULLINS:

Mr. Kelly is also present. i MR. ROCKWELL: Is Mr. Kelly staying for this g [ !.. ! deposition? t I MR. MULLINS: Yes he is. '!9 i I MR. ROCKWELL: The appearances should reflect o i that fact. 1883 166 I o i i. Whereupon, i 1 2 JAMES FRANKLIN WALTERS, i t t ! Having been previously sworn, resumed the stand and testified -9i l i I 21 l .r., e

t 2 i !, as follows: By Mr. Rockwell: Q. Mr. Walters, do you rac0gnize that you are still under oath? g A. Yes, I do. r. Q. Mr. Walters, do you have before you, deposition Exhibit 35, which is a November memorandum from you to Kelly? A. Yes, I have a copy, yes. Q. Mr. Walters, there has been some confusion in the date of your memorandum. I had thought that it was November p,,

13, others had thought that it was November 10.

There is a i 'l little difficulty in interpreting your handwriting. Can you 12 ! t i resolve the conflict. ~ i r, i si A. I am sure that it is November 10. !4 Q. November 10? Okay. Referring you to Exhibit 35, the first paragraph, Di let me quote it. "In talking with training personnel and in i the opinion of this writer, the operators at Toledo responded i in the correct manner considering who they had been trained g I and the reasons behind the training?" s 1 w How have you determined, Mr. Walters, how the 1883 167 i t joperatorsahdbeentrained? 21 A. As I have testified before, I had talked with i i l l X-trained personnel about a particular sucject that was

1. i addressed to Mr. Kelly's letter.

We d,iscussed certain things, I i a ~'4 b i 2; ! i I n I i l 9

_,! not ali inclusive of which was how or tnair training of the operators when here for training; our discuss' ins ran.essen- ! tially along the line, as I remember it, of my concerns as l are addressed drafted in that particular meno. What I, a t this point remenber, as I came to the conclusion, since ! i was not; I had done no direct analysis of the Toledo tran- 'i ~ sients that were in o'im Kelly 's memo, that they had, indeed, l resconded to the situation that they were in, maybe not in f l the correct order, but they had found that they had a, ei ther t stuck-open release valve or a small LOCA, had closed the I release valve, and then had throttle back on their HPI. j U Q. Okay. 12 i Referring again to your phrase in the first para-i i:; graoh,"considering how they had been trai ned," wha t did you F 4 o ! dete rmine bef ore you wrote that ' memorandum, as to how they l 15 I had been trained? What specifically did you understand with i respect to their training when you wrote that memorandum? s I A. I am not sure at this time what I had in mind at g i I that tine. What I actually obtained from tne training people l i I can list as point XYZ. That is what they had trained. l 4 Hl l Q. Mr. Wal ters, the court reporter is no clear on i ~ your answer, would you please repeat it? }883 }68 .y l I A. I said that I was not sure at this time, what I l' information that I can quantify to you that they gave me. It l ei was a general conversation, and when I went back and drafted b i 4 i ).* i i

o

nis memo, I so stated the words tnat

.v e r e in cuestion, but g to try to go back and Dull out what actualiy we talkec about in de :a il, I cannot do that. l Q. Did you have an understanding when you wrote the !memoastohowtheoperatorsweretrainedwithregardtothe c.i subject of your memo, the subject matter covered by your j

memo?

i A. I must have, but like I say I can't go back and I l 3. give you details of i. saying that all you know about how they l Q. Are you p,, t i had been trained is reflected in the memo? A. And with my previous statement just a few moments l ago. f Q. So, am I correct in understanding that, in fact, t 14 as you are seated here now, you don't know, you don't know t l l ' how they had been trained, at least at that time, specifically, i 6

o,

A. I reckon the answer to that is I do not know ) exactly what was taught to them in their training classes e-t l g{herewithinthetrainingdepartment. liost of my information i i 6 l that I probably used in referring to -- writing this memo, e 19 i a was obtained from contacts in talking with pecole, were they l l operators, or from our training personnel or other engineer-i l ing people. I was never present, that I knew of, during I actual training sessions inv'.i 1g nur training personnel and ' t =, 1883 169! ,3 - custoner operators. - I i i I i 24 ! I i } 05i I

I O. Well, is it then fair to say that the first para-Crap-af your memorandum is simply a re:etiticn of what same-body else told you? A. No, I don't think so. I think it's truly, my opinion, as I said in the first line, the ceneral conversa-tions that I have had over a period of years with quite a few di fferent people. Q. Let me go back to my first question. In reference 9 to tne parase you used, "considering how they had be'en train-l 1 in ! ed", did you have any specifics in mind when you used that l 1 I phrase? i M i A. Well, I think that my conversations with many i '2 :: people over many years, led me to believe that operators had n the idea that they followed pressurizer level doing quite a few transients. That was the information that I remember it MI frem the many years of talking with dif ferent people. I know 16 ' that not to be the correct reaction, but I do have that c i n f o rma t i o.,. At least I see, over a period of years, that's

g. my sum of what I have neard.

i Q. You said you know that not to be the correct l reaction. You nean not to be the correct reaction by opera-s ' tors when f aced with certain 10ca circumstances? l ei ! A. Well, I can also state that I know other things --.,i within the, what I do know to be the cases of training. We i M are picking out a specific point here. He are talking about i 24, 1883170\\ Iai i

1 8 i f a specific case, whether we are talking now of nc-mai Opera-t tions or of abnormal transients, how Tuch have tne acerators I 4 l been trained or tauent to. I know that they have been taught, at leasi from my own training and assumptions for ouite a few years, that they should not, in all cases, de;end upon one c. single piece of instrumentation. l Q. Well, let's go back to that first paragraph. You indicated in that first paragraph that they, "the operators 9 responded correctly in light of their training", correct? m[ A. As I previously stated that the Toledo operators I g ; found that thay had a leak, they did find i t, they shut it off and then they throttled back on HPI when they saw pres-lsurizerlevel recovering. u Q. What specifically in their training, led them to 14 l do that, to your knowledge? I A. I can't testify as what specific knowledge they 16 ' have had from the training department, only by my assumptions, 17 ! in talking, in general conversations. Q. What specifically did you rely on other than p assumptions and general conversations in making the statement g that "-he Davis Sesse operators responded correctly in light m: of their training?" Can you give me any specifics? n, i A. I think tiie sum of my response was essentially -- } like I said. My training, my understanding with conversation: 4 l

1. l with people, whether it be operators, or pecple within the t4 s

.-l 1883 171 s I l i

i 9 2 B &',! o r g a n i z a t i o n, and the brief exoosure to, I recken, it was t i the first Toledo transients, at wnich ! saw the variations in p.essuri:er level, and had only walked away with the idea 4 that once the operator found his leak, once the pressurizer level and pressure was recovered, or at least pressuri:er n level was recovering, that he then, his response was to take -i

the HPI off.

That's all at this time I know I used in making 'lthat paragraph. i"; 0. You said that you had a general understanding I to ' based on your own training, understanding and conversations, that the response of the Davis Besse operators to the Septem-11 I in light of their training, ,.,'l ber 24 transient was correct Okay. 13 l l What, in your own training, your own personal I 14 training, led you to beleive that they were responsive and in correct in light of their training? I" A. I reckon my assumption is that I had thought and l

7 had been convinced by conversations that operators would rely I

is on pressuri:er level as indication, as an indication during i g, certain conditions. j I Q. Was there an operating instruction or procedure -v: I I that would have led them to rely on pressuri:er level? 21l A. I know of no procedure that states that they j l should only rely on pressurizer level, no. l .. 3 Q. Were you taught, in your own training, to rely ~ i 1883 172 3 t i

i i 10 l i L r 2 on pressurizer level in throttling HPI? A. No, the, I can only resp 0r.d t0 that in that the 3 i,,' procedures and all that we have written do not entail an f i instruction that should be considered that the inventory at , P.CS is dependent only on pressuri:er level. The emergency r, crocedures do state that the -- both oressurizer level and l ! P.CS c res su re s houl d be us ed. i i Q. But, that's not what you say in the first para-l I i grapn of your memorancum? Is it? 4 A. I reckon that can be said. o Q. You reckon what can be said? A. That my paragraph, my first paragraph contradicts known cocuments, m O. Let me come back to the cuestion that I have been i u! Can you give me any specifics on which you based the, lasking. } 1' conclusion in the first paragraph that the Toledo operators i i i 16 l' had responded correctly in light of their training? n A. The only specific that I can testify to is that, as I have already stated, that I assumed that the operator g,q I was responding correctly as he did in taking HPI off af ter 19 the pressurizer level had started to recover and he found un his system leak. f 21 Q. Okay, and when you make that assumption, what do j you rely on? l f I A. I reckon the inadequate training or conversations, i v, l883 173 o: i i i

11 that I have nad tr.rouanout tne number of -vears. l 0. unat conversations, specificali;' A. Conversaticns with mcs: anyoocy eithin this I, industry that I have been in contact with that we nay have r, I develcoed a discussion over so...e subject along this line. n. I don't know gene rally, who wi th, engineers, operators. l t - t Q. Can you name or.e person that you h a '.: e had tnese I conversations with? i A. 'ih a t conversation? l I l Q. You just referred to the fact that~you relied on g f conversations with people in coming to the conclusion that I the oper' tors at Davis Cosse resp 0nced correctly in light of their t r a i r. i n g. Now I want to know who jou had these conver-sations with? i l A. I don't know that I had con *,ersations with any-M: body that I went away with the idea that the operators at i 16lDavisBessehadrespondedcorrectly. As I said, that was my .. ' opinion. i i l Q. What did you base your opinion on? 1% l l A. I reckon my lack of underst2nding of the particu-49 ' lar information that we were talking about. I to j Q. I will say the question again. What did you base t ~ your opinion on? i I 22l A. Well, as I have already stated, it's just my i 23i general understanding of the, what I felt to be the training n, 1883 174 t e

12 ) the operators had received. Q. Anc where did you get your general understanding, 1 i from conversations? i i 1 A. Yes, more or less. Q. Okay, conversations with whom? l r A. That's a very difficult question to answer. In t fact, I can't answer it. I've been to two or tnree different sites, was there for years at a time, I've been employed with B&'d for 10 years, and I've talked to probably a thousand 19. people in that time. I am not saying, and have not said that l 'I any one person gave me information that I wrote in this memo. i ,1 I This memo is my opinion. It would be very difficult for me 12 i to try to give you one person's name at this point in time.

1 i l

Q. I am not asking for only one person's name, I am ) j 1: laskingyou if you can remember any names? l A. Asking me of one name of the discussion that j l l' M occurred on what subject? l l } n' Q. I am asking you if you can remember any person { with whom you had a conversation wnich led you to believe and g contributed to ycur general assumption that the operators at i e ' a m! l ' Davis Besse responded correctly in light of the train;ng they yl received? j } i dI A. I can't give you any name on that. ? -{ Q. Okay. . >., i l B I =: woule it be fair to say tnet the first paragraph e t 1883 175 24l c.1, f

13 [r 2' of your cemorandum is based on the sum total of your experi-6 i thee, conversations and training while you have been at BSW, i - and that the sum total of those expe riences, conversa tions + e and training, is that, in your mind, the operators at Davis { i Besse respondec correctly in light of the circumstances they c l were f aced with? 1, A. Well, I reckon I'll have to answer yes to that. 1 Q. okay. i l A. "y rea c ti on in November, '77, was, once he had i i

o i found the leak, he closed it, the pressurizer level had l

i } , recovered, that I thcught he had acted in a correct manner. O. Would it be fair to say that the throttling back i of HP1 in those circumstances, to the best of your knowledge k '. and understanding at that time, was based on pressurizer i 14 level? l "' l A. That is true. I ) Q. And that it should be based cn pressuri:er level? G; A. My knowledge says that it sculd be based on i i

. j pressurizer level.

t I I Q. That is right, your knowledge back in the fall of [9

1977?

Is that correct? 2, ? A. I reckon that is correct. I think so, yes, i t i R Q. And, is it correct tnat to the best of your l ", knowledge and understanding, based on your experience and p, ", irlining in the Fall of 1977, was that HOI could be terminated' 1883 176 j -._,m-4 i

14 ( based on pressurizer level alone? I i A. Well, I can't answer that. That is wnat .said, 3 i !> but I know that is not the case. 4 Q. I am asking you about your knowledge in the Fall j i i of 1977, not what you kncw. l I h '. A. No. Like I said previously, the operators had l i had more training, I have more training. And just to relieve a but when you ask me the question I have i pressurizer level 9 to say yes. ? I Q. You have to say yes, that determination at HpI on pi i I the basis of pressur. e-level alone was appropriate in terms t I of your Knowledge in the Fall of 1977, is that correct? \\ n A. Yes. s ) l Q. Referring you now to paragraph two of your memo- { 14 l randum, i first sentence: l I { l l "My assumption in the training assumes first tnat 3 i l' t 16 ! RC pressure and pressurizer level will trend in the same l l I r

! direction under LOCA".

I I i I Is that an accurate readinc of the first sentence, g 1 I ' i of the second paragraph? 1 w: i I A. Yes. a, Q. And that was your understanding in the Fall of c 21 l l 1977, correct? l ~ A. That is correct. l M Q. And to the best of your knowledge at that time i I 1883 177 i 29 1 t o

15 ) the training assumed that a s ..;e l i, c:rrect? 1 A. You saic the training assu ed that as well You I 1 1 - department? mean t h e B &'.1 traininc i Q. Well, I refer you to the sentence: "You said my assumption and the training assumed that RC pressure and ci pressurizer level were trend in the same direction under LOCA", i ~, i correct? A. Right. That sentence shauld read. "My assumption t and trainin;". I am referring tc my own training, and that lo is Correct, i O. You were referring to your own training? A. That is correct. Q. 'd h a t traning? n A. Since I have never been qualified as an coerator, ti,1 } ' I have never had formal operator training from B&W instructors. li Q. Well, you just indicated that you were referring j I '{ 16 to your training. f 2 17 A. That is correct. My training comes from wnat s knowledge I had gleamd in the period of time working within the B&W, conversations I have had with different pecole within la, mainly service organizations, I reckon. l i 20 i i Q. In preparing this memorandum you did confer with 4 "I i three former training instructors in the B&W training depart- "" t i' I ment, is that correc i .a } A. I did, yes. 1883 178 2' i 4 n; i

16 O. In referring to the ~irst sentence of tne second paracraph, jeu say in part, "the trair.'ng assumes that. } l ;ressure and pressurizer level woul trend in the same di rec-4 ! tion". a s t ha t based on your conversations with these three k ' former inscructors? i 6 A. No, I would say not. That is my assumption and 7 g my assumption alone. Q. Dic you ask those former training instructors what the training dic assume? I A. I can't remember, but I do not believe I did. p, O. When you refer to "the" training in the first sentence of your second caragraph, you were referring to S&W training, is that correct? p A. As I stated a mir.ute ago, tne sentence s.hould read, li, "my a s s ump ti on and training", the training I have had. ,. 4 "*j Q. But that is not it says, is it? m A. That is ccrrect. l i Q. It says my assumption and "the" training. j 1- ) i l ,, 1 A. That is correct. I. i Q. Were not you referring to 3&W training? i ) 49, l A. I am referring to my training received as the m sole experience by working here for the numbers of years. 1 l Q. Were you referring to the utility training when i ~~ I

you used the term "the" training?

I

I A.

You mean the 3&W training 0f the utility cperators? l 'l883 179 s I .m eme *. ~

t 17 i. Q. I mean tne trainir.g given by utili ties to their Own operators. A. No, I am not. 4 i MR. ROCKWELL: Off the record. 3: [ (Discussion of' the recced). 6' l Sy Mr. Rockwell: 1 Q. Referring you to the thi rd ar.d fourth paragraphs [ j 'of your memorandum, what did you mean "hydroing? l A. Okay. There is about three words left that I am m using synonymously here, the word " solid", the word "hydroing", and I can also inject loss of indicated pressurizer level. i j l To me in the context or in tr.e concerns.' had mean essentially 4 the same thing. This is that we would have enough water to put into the RCS, reactor coolant system, such that we would go k u l i i up against the code release valve, essentially a solid I, D I water system. i 16 i Q. All right. And you indicated in the first sentence of your fourth paragraph, the fourth paragraph is the t i last paragraph: i g "If you intend to go solid what about problems with vessel mechanics". i 20 l What problems in reference to vessel mechanics 2 21 were you concerned about? e A. I was concerned about the problem of availability,i I { dj if you want to so-call it as such, in the scenario that we s ? 1883 180 =. t _f -e-w

13 are talking acout, wnen we go against the code's you are going 2500 pounts er above it. T n e i n s t r u e r. t a t i o n is r a n g e'd only l zero to 2500 pcur.ds. b!nen you de this : was asking the question would we nave to do to get the RCS back availatle to "What I i produce power, would it be a simple reanalysis of the vessel 6 l mechanics", meaning what stress had we put the RCS itself and [ the core under through doing this, and secondly was it possible for us to do any damage to the RCS by putting it t " ! through this transient. l i 1 Q. Did you have any knowledge at that time of what 1 to ), fdamagemight be done by going solid to the RCS and the core? g A. The only thing that I had in my mind,that I can think of is,if we do do this we would go up against the code l release valve or the electrostatic release valve and whether or not they opened and whether they would be damaged so that it wouldn't receive -- so you would have cool down and repair h' i them. That was first and foremost, : reckon, in my mind. j + l i-; Secondly, I reckoned the fuel itself. I i h i Q. Were you concerned that the FORV or the code l g ' ! safety might not open if you went solid? 6 19 f' i I A. No, I wasn't concerned that they would not open. 20 I was concerned that they would open and then not receive and , therefore you would have a loss of coolant. 0. But referring you again to the first pa raga ra ph, i \\ .v3,i the fi rs t sentence of your fourth para, graph, you were 1 l i883 181 e o t

1^ re f erring to a c ro bl e r..>i tr. vessel mechanics. Do you in-cluce the probler of receding of the valves as a orcblem of vessel mechanics? t A. Well, the only thing I had in mind, the only thing was that I did not know whether or not this code release w I valve could release the quantity of water that the HPI pumps i could pump into the RCS. If they could not then yes, it t !' might cause some problems. I don't know, I have no idea. 1 9 !That is the reason why I asked the question, could it cause i, to! a problem in damaging the RCS. l l I Q. Am I correct then, that the problem you foresaw ,i, I if your HPI is shoving more water into the system ! is that than can be discharged through the PORV and the two code l' safeties, that you might potentially face a situation where i is i the reactor and the pressurizer vessels would be over-pressuii:ed above 2500 pounds which might stress them and 4 do damage? -l A. That is correct. I l I g Q. And the specific damage that you were concerned l I about was damage to the core, is that correct? { g A. Yes, in that I do not think we would cause any 20 l 2 lphysicaldamagebutit is pr.bably outside of what the plan i il Ii is licensed by the technical specification requirement, there - ..., lIfore it might be that the plant would have to shut down and ~~ y' . stay down long enough for us to rectify the problem paperwise. 24 .i, 1883 182 i

20 l f Q. And i f the sys*1m was cres s;rizac 2 cove the l ac:ectab'e levels, ;hatever they a re, :ne sn;tdowns would be i a l e n c. t n.v e n e, is that correct, because all parts of the i syster '.:ould have to be exanined to make sure that there had s i not been any overstressing which might lead to failure down i i o the road? i -s A. Essentially, yes, that is what : nac in my nind, i j yes. i Q. Okay. How long does that kind of analysis, to 9 l i l the best of your understanding,take? i g A. I can't really say. I would say at least, you ,a.' know, my own experience would be that it would be greater d than a coucle of weeks. Il ! Q. Could it be a matter of nonths? I y l A. I think with.NRC involvenent it possibly could be. I F' Q. Did you check to see whether the rated flow, i m maximun flow of HPI would exceed the rated maximum discharge i ? of the three valves in ouestion, t h e P O R'l a n d the two safeties, t ! the two codes safeties? i H t I l A. Yes, I did check with certain people, probably I .e 19 i,

not the correct people, but I did talk with certain people.

l eu Q. Who? j 21 A. My answers were -- 6 Q. Who? t i' i II A. I don't remember who, but I suspect it was the l } t 24 ! l s 1 -i i 1883 183

21 same three guys tna: I talked aoout in this m.emo, the e [ /,-training 7ersonnel, Cal Goslow, "e ro Smi th and Bill Street, i I Q. And what did they tell you? t 4 A. I tnink the result of tne ccr.versation was that 3 if the release isn't steamed. Engineering had told us we had i no p roFlem, but we were never sure whether or not we could I pass the amount of water through these valves, solic water ' i that is. i j l Q. Was this analysis based upon the assumption that 9 I l to there was no main feed, no aux feed? i t i l l A. I have no idea. I do not know. g e i Q. Okay. And the subject we just have been talking 12 I I ' about is the subject addressed in the last sentence of your n, ,' memorandum, is that correct? 3 14 A. That is true. l Q. Going to the last sentence of the first paragraph 1 16 which is on page two of your memorandum: i "If this is the intent of your letter and the 6 n' thoughts behind it, the operators are not taught to hydro l I I the RCS every time the M?I pumo is initiated." m Were the operators taught to hydro the RCS at any } 20 i ! time? l i 21 l A. No, the operators are not taucht to hvdro the

2 l l

' RC3 at any tima I 23 Q. In fact, would it be fair to say that they were i 14 l 23i i883 184 s

i i. I 22 2 never taught to hydro the RCS? A. I think nat is a fair statement. 3 Q. Under any condition? A. That is true. 1 Q. That is your best knowled;a and unders tanding +, based upon some ten years at B&W? A. That is true. Q. Why do you think, or what do you think the reasons were that operators were taught never to hydro the RCS? f i to ' A. The first thing that comes to my mind is essen-I f tially you have two situations, one would be when your reactor 3, i i is critical and at one point is not. Both problems gel 12

• together most of the time.

Mainly, you do not want to go i.i j solid because you have no pressure control. Mi Q. Any other reasons? A. There is no reason for it during normal o p e r a t i o n s. t '; Q. What about non-normal operations? A. Well, my meno was addressing this tyne of thing. I Q. What type of thing? g i A. A overcooling transient at which time you loose 19 pressurizer level or close to loosing pressurizer level and >., i j the recommendation that, if you do get low pressure in 21 il energize -- you might leave the !!?Is of f for some long period of time. In a case like this I expect you would wind up going d: solid in the RCS and it is not something that you want'to do. 1883 i85 3 8 0 l

1 23 i i Q. So that is another reascn <hy o p e r a t o r s.. e r e taught nesee to hydro tne oC5 beca;se of tne canger that might I ' pri_e feca nydecing t.ne RCS in an overcooling transient, s 4 I I I correct? I 1 t A. Again, I can't address that they. sere trained not r, to do that. To me as a engineer, that is something that you 7 would not want to do. That is true. l l Q. Anc you believe in your own mind that that would a ce one or the reasons why the operators were taught never to I m ; hydro the RCS? l A. In my own mind that is true. g l Q. Is it your impression or understanding, Mr. Walters. g 12 I i own traininq and understandinc, that you should lthatyour id ij never hydro the RCS is a reflection of training and under- ! I lstandingofoperators in the field at the various utilities? A. W9uld you repeat th a t? j i 16 (Whereupon, the pending question was read by the i n reporter.) ?!R. ROCKWELL: Did you understand that or do you l w i want it read back again? m I i l THE UliNESS: Please read it back acain. an (Whereupon, the pending question was again read 21 I by the repo rter. ) i 1 THE WITNESS: That is true. I i P Sy !!r. Egekwell: i ai 1883 186 i 25 I i { l i y y k.

e I 24 3 Q. Mr. Walters, directing your attention from the time period from February 15 to Augus: 3, 1973, do you'have i any direct knowledge tnat "r. Dunn was ever informed that you l satisfied personally with the prescription outlined were no: in his February 16, 1978 memorandum? c' A. I cannot. I cid not know personally that he was t instructed as to my concern. I assumed that Goslow conversed with him on the matters of these concerns. l 2 Q. Have you ever checked with Mr. Geslow and asked m-him whether he ever did advise !1r. Dunn that you all were not yet satisfied witn the prescription as outlined in Dunn's I

February 16 memorandum?

A. To the best of my knowledge, I did talk with 1 j Kal and Kal did converse with.'ir. Dunn about these concerns.

?

Q. When? When did Goslow indicate he conversed i t I. ' with Dunn? i I 1". A. It must have been early '78. I cannot give an i { n1 exact date. l Q. But has Goslow told you he conversed with Dunn g after February 16? 19 i A. To the best of my recollection he said he did, 20 i I yes. 21 : l Q. You specifically asked him that? t A. I think I probably asked him about had he talked M l with the people in engineering in thaq context. 24 i i> i 2.' 1883 187 i f t

l t 9: Q. nink vse ha ve e s ta bl i s hed that Mr. Goslow may I I have talked with 'i r. Dunn stween Fet uary 9 and Feoruary 16 3 in arriving at a realized instruction, is that correct? A. That is correct. Q. And now soecifically my cues tion is, has Mr. r, Goslow tol d you whether he tal ked to Dunn after February 167 A. To the best of my recollection he says he has, he had talked to 'tr. Dunn and Mr. Cartin at plant integration. But I only knew of Mr. Cartin in the last month, j 4 ni Q. When did Goslow say he talked to Dunn after j Feb rua ry 16? i. A. I didn't get the fi rs t we rd. Q. When did Mr. Goslow say he talked to -- strike I U j that. Let me rephrase the question. k i 3 1: ; P i Did Mr. Goslow say a t what time after February 16 ~

of 1978, he talked to Dunn?

[ i i (" A. It is certainly possible that he did tell me such, I e s n l but I do not remember a t this time. l l I 3 Q. Did he tell you how many times as of February 16, j 1978, he talked to Dunn? I 1,,, i i A. I testified already that at least once or twice. 2" i More than once. t i i n; j Q. And what did he say that he told Mr. Dunn in those i ... ' conversations af ter the 16tn? I i A. I don't remember the specif,ics of his conversa tions i "*l 1 t 1883 188 i

s i

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l i 25 2 or any of the conversations. All I r e r.e m b e r is tnat he did say he talked witn him about tne concerns and e s s e n t i a.i l y. l 3 I that is it. He talked to hin about tne concerns. 4 Q. What specifically were ycur concerns about the i I prescription as set forth in the February 16, 1973 memorancum' 6i Do you have that available to you now? A. Yes. My specific problem was related to what we have 4 just been talking about a few minutes ago and that was Mr. Dunn recommended that once HPI had been put on that it pi, i be left on for some period of time. And I think here he says 10 minutes. i Now, we have got to realize that Mr. Dunn is ti; referring to a LOCA incident.

i I have never, and I'm not, addressed a LOCA.

I 4,l talked about an overcooling transient. And in that case, I

G was concerned that if I left the HPI pump on for some period I

n ; of time as that I would then get into my scenario cf a few minutes ago, of going solid in the RCS and the ensuing g i p problems there. At no time did we ever disagree with his scenario ' 'l ) We were simply addressing a problem where we on the LOCA. ..i did not have a LOCA, a normal transient, overccoling transient. ~ ~ i Q. Let us assume, Mr. Wal ters, your concern about going solid with anovercoclingtrans1;ent, is there any way ' i i n; 1883 187 I

s } I l 27 .l that an Operator could know, during the course of the I i transient, wnether he was faced with the dar.cer of an over-c cooling transient and therefore know that going solid should 4 i be avoided in those circumstances? i l A. I think it depends mainly on what time period we al are talking about. If we a re talking about, say, less than l - I two minutes, maybe not, say, in a period of five to ten' i minutes, certainly, yes. i 9 Q. Is there any instruction or operating procedure i i to that distinguishes, and I am referring now to the Fall of ,, i.., 1977, that distinguishes between those situations where an 8 12 l overcooling transient is possible, and therefore, those i i I situations where going solid is to be avoided from those r situations where an overcoolino transient is not a concern? 14 A. I think there are. But, I'm not familiar with i very little information. I believe the main-steam line l 16 : break scenario and a few other ones are covered, but I'm not I i I n familiar witn any of the details. I ig Q. Am I correct in understanding that to the best l l of your knowledge, because of the danger of going solid during; g an overcooling transient, and because of the concern that en i going solid leaves you without pressurizer control, that the i 2: operators were instructed that you should not go solid at "l all? i A. Would you receat the questien? 4, u! i 1883 190 i n. I

28 ( '.!h e r e u p o n, ne pending cuestien was read by the repcrter.) MR. EDSAR: In : nose cases cr ever? 4 THE WITNESS: Well, -- l MR. R O C K'..' E L L : Ever, at all is the cuestion. THE WITNESS: Well, I can only speak as an engineer. I do not know that was or was not addressed within the training departnent. To me, as an engineer, no, I would 1 not. v. MR. EDGAR: Mr. Walters, there is at least some confusion in my mind at this point as to where we are and I wonder if you could exo',ain the basis of your concern? 12 Am I correct that the basis of your concern is , that if the Dunn prescription were applied literally without

s regard for a class of initiatinc-events, such as undercooling,

1. ' l that that prescription could lead to overpressurization.

Is 16 1 that what your concerns consist of?

i THE WITNESS

Yes, George, that is essentially I ii it. My problem was, at no time had we brought into the situa-i i g 5 i i tion a LOCA. That is Bert Dunn's area. We were saying if w i , you do bring this prescription, can we indeed get into a 20 i problem with an overcooling transient where we still have i, the inventory in the RCS and we know as soon as you can I i ~~,Il stop the overcooling transient that tne cressurizer level, as 23l well as the fluid in there is going to expand and you are t 1883 191 J l.

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30 cossitie to create instructions '.vnich distinguish #ar them those ci rcums tances 'inere gcing solic is a danger, and.tnero-fore, it snould be avoided and/or distinguish those situations where going so'it is not a danger? A. Yes, I tnink tnat procecures and instructions n , can be worked out if it is not a problem. l Q. To your knowledge, has tnat every been done before, March 28, 1979? i 9 A. To my knowledge, no, i in ! Q. During the time period frcm February 16 to August f 3, what specific efforts did yoe make to get a response from ,7 plant integration to your concerns, your continuing concerns about the Dunn crescription contained in this Feburary 16th memorandum?

4 A.

The only contracts I.had were with Gosicw through a i n tea ra ti on. 'inat efforts did Goslow nake? Q. i c A. As I repeated earlier, he says, as far as : remember, that he contacted f!r. Cartin in plant integration ,,, ' and talked about the subject. Later on this was interrupted < by times when ne was sent out of town to di#ferent sites for Co l work, came back and so it was interscaced with maybe three 21 l i or four weeks f rom time to time. We would go back and ask again. We were not getting what we considered resolution on the subject. Then I went to Mr. Mclim.an and said that we v 1883 l93 s

31 t should m3ybe tra t a memo a nd s e r.d i t cut t o r. Karrasch e see i# we coulc get some, a respon:e

• .o and we d'd..and that was in tne Augus: 3 memo as a resul t of nat.

a Q. Did you ever take any steps cersonally to get plant integration or "r. Cartin specifically to rescond before i the August 3 memo? A. No, I took no personal conversations, had no 'i personal conversation witn Mr. Cartin. i 1 9 l Q. Following the August 3 meme, did you personally j take any steps to followup on it, to see that plant integra-9, 1i tional finally did respond? 1r i I A. I think as I have already testified before, I

2 i talked to "r.

Kelly a couple of time aoout whether they were going to rescond to that particular memo which I now -- i 1 i O. Right. Other than your conversation with I* Mr. Kelly? l

'il A.

No, I did not talk with anybody else. Q. And I think you indicated before that Mr. Hollman i I may have contacted Mr. Karrasch a couple of times, is that i I correct, after the August 3 memo? { .. i ' i A. That is correct. i no ' Q. And that he mentioned that he wanted a response 21 from Mr. Karrasch, is that correct? A. That is correct. 3 Q. And, what was Mr. Karrasc.7's. response as best you 24 l 1883 194 4 3

1 32 uncerstand it? A. . ' m s o r ry, I missed the first word. Q. What was "r. Karrasch's response to Mr. Hollman's contacting.iin to the best of your knowledge? A. To tne best of my knowledge, I don't believe t Mr. Hollman ever conveyed to me any conversation wi th ~ i Mr. Karrasch other than to say he had contacted him on the i subject. l 'l Q. You were present during the deposition of I i ni { lit. Kelly this morning, cc. rect? I I { A. That is correct. t1 i i Q. Did you hear the exchange in which Mr. Kelly i 12, indica ted that Karrasch had called Hollman around the turn , of thq year, Christmas time, of '78, and told Mr. Hollman i u: that hq, sarrasch, had no problems with the Dunn prescription? A. Yes, I heard him tes ti fy as to such. I 1 Q. Do you have any independent knowledoe of that 7 j I t L1, tammunication from Karrasch to Hollman a t around Christmas y, Line_ of 1973? { l ~ A. I have no independent knowledge of what the con- %,i ,i vqrsA.ti.cn was about and I don't know the exact date that he may have ta l k e d. 2: That may have been one of the conversations i P whegg he,had talked with Mr. Karrasch. l t ~ ~~ Q. Did Mr. Hollman ever tell you that Karrasch had i

1. ' t

_! gr.tla n. 51c k to nim and said no proclem, go ahead? L u! i 3 +

p. '

1883 195 i t

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l 33 } A. That is correct. 4 l Q. Mr. Holinan did tell you that? A. He did not. At no time did he tell me that a Mr. 'a r a sch hac said that. Q. At any time before Ma rch 3, 1979, did you urder-I stanc nat plant integration through Mr. Karrasch had i L ~ essent; ally cleared the Cunn memorandum, the Dunn prescrip-tion? A. No, I have no information that tnat ever-occurred O. Have you ever asked Mr. Hollman about that? p, A. I only asked Mr. Hollman, had we got any informa-tion back from Mr. Karrasch on the August 3 memo. u Q. And v: hat was Mr. Hollman's response? I ^ The only response that I can remember is that he

s said he had not received anything definitive from Mr. Karrasch, Q.

That is up to March 28, of '79?

o -

A. That is true, t Q. Do you know whether operaters a t any of the S&W operating utilities were ever i.;tructed before ftarcn 28, 1979, g! , to ignore pressurizer level in those situations where reactor ,m. coolant pressure was dropping? ." i, A. I have no personal knowledge they were every 21 i told so. Q. To the bes t of your knowledge, they were not told i 23 so, is that correct? b383196 a! a J m we

34 2 A. That is correct. 1 Q. fi r. Walters, I am going to recess your deposition i , I at this time as we have in the past, leaving the subject to 'i I further recall should we need additional testimony from you, [) in that event, we would contact your counsel and let you sl know what that means. i for being available this morning. Thank you (Whereucon, at 1: 45 p.m., the depcsition was l recessed, as above noted.) l

o i

l ti ; l l 12l James Franklin Walters I

i '

4 Subscribed and swcrn to n l' before me this ____ day 1.; i I of ______ e_______1979. is l I i t i 4 17 i l _______________________ l ' !!otary Public g i I 1 i i -m, I I et : i l l __ i l i l 2d 1883 197-l I .l I i t e==e .e i-... h I

a: a ,- : :::r .:q. Cre,,t-rCn.:.a. r ar. t I, Simon Banks, J.D., Certi fied Court Oe: rter, t that I reported the testinony of tne <iitness , l do hereby certi fy I herein, over speaker phone, in stenotyp/, and that the testimony was reduced to typew-itten form Jursuant to ny direction. ! further certify that the testimony herein con-stitutes an accurate reccrd of the pecceedincs had. ^ i 10 l Simon Sanks, Jr. i i 11 I i 12 11 i f

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l 16

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ta l .m i 1 l I 21 ! I t, L' I 2::, .t . l i 1883 198

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