ML19256B653
| ML19256B653 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/06/1979 |
| From: | Rockwell W, Walters J BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908160261 | |
| Download: ML19256B653 (41) | |
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3w-w JAMIS F RAN K *.,
- N WAL* IRS, held at the offices of 3abc0:k & Wil:0x, Old Fores Road, Lynchburg, Virginia 24505, en the 6th day of July, 19~9, cc==encing at 12:25 p.m.,
before Stanley Rudbarg, Cert:.fied Sh:rthand Reporter and 50:ary ? b1:.: Of the State of New York.
9 0 816 0gs q BENJAMIN REPORTING SERN~ ICE
' ')0 1885 140
.,.. ~ = sn x ua.~ = as. m 1.e FIVE BEEKM.tN '5N m YonK. New YORK lCO38
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MCRs.y,
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an Attornevs for Babecek & "a'ilcox 5
1sco a 'S:reet, N.W.
Washington, 0.0.
20038 6
3Y:
GEORGE L.
EDGAR, Esq.
-and-8 K... N w n.
.I,
SQ.
of Counsel 9
_ _ _ _ _ M.M_ _I S _S _I O N :
CO 10 F O_R_ T_ H E 11 W:NTEROP A.
ROCKWELL, ESQ.
Associate Chief Counsel lo 13 A_ L S _O _ _P RE_ _S E_ N_ T_ :
14 RONALD M.
EYTCHISON 1O 16 1.
18 19 3
o0o o1 s
en n3
~1885 141
.~:
SENJAMIN REPCRTING SEnvl:E
.. s
1
_a o,
2
. M s s
,.. y a
-a n...,
a n..
s 4
having been duly sworn by Winthrop A.
- Rockwell, Esq. was called as a witness and testified as o
follows:
DIRECT EXAMINAT:CN t
3Y MR. ROCKWELLs 3
Q What is your cu rrent employer?
Q A
Sab=0ck & Wilcox.
10 g
What is your business address?
11 A
Old Forest Read.
12 Q
What is your present position with Babcock
& Wilcox?
13 A
- am supervisory engineer in the Plant Performance Services, operating Reactor Group.
la, Q
s that in the Customer Service Department 16 of 3&W?
1 4 A
Yes.
18 Q
Formerly knosn as Nuclear Service?
19 A
That is correct.
20 Q
Have you prepared and brought with you 21 today a resume which we have narked as Walters Deposition Exhibit 1047 1885'142-en A
Yes, I have.
(Resume of James 7:anklin Walters was marked Walters Oeposition Ixhibit 134 fe
_6:a SENJAMIN R EPORTING SERvtCE
1 2
Walters 4
3 identification, this date.)
4 Q
Did fou prepare that?
A Yes, sir.
O Q
- s it accurate and complete?
6 A
To -he best of =y knowledge.
t Q
Mr. Walters, showing you what has 8
previeusly been marked as Womack Deposition Exhibit 24, 9
can you tell me whether you recognize that document?
10 A
Yes, I recognize it.
11 Q
When did you first see it?
A I as uncertain as to when I first saw it.
in Q
Give me your best estimate.
g A
Well, depending on the documents you have got laying there, it has to be before the 10th.
15 g
But did you see it in the fall of '77?
16 A
Yes.
Q How did it come to your attention?
18 A
- arrived in my in-basket evidently from 19 Mr. salinan.
He is =y present bossman, immediate bossman.
Q And was he your bossman at the time this
,1 11385 143 meno came out in roughly November 19777 no A
Yes.
23 Q
Did he. When he sen
-hat me=o to you, =ake o,.
any suggestions as :: what you should do?
,-0 Ei ENJAMIN R EFC RTIN G S ERVICE
1 2
Walters 5
e A
- am not sure.
I believe he.ut on there, "Take s
a::icn on this" er something of that order; "What do
,+
you think about ;;," something like that.
I'm not o
sure about that.
6 Q
Oid the copy of that me=o which came to t
you from Hallman end up in your files?
8 A
Yes.
9 Q
Is it still there?
10 A
Yes.
11 Q
Could we have a copy of it?
A Sure.
In Q
And your recollection is that the hand-written note on the memorandum had something to de 14 with requesting you to take action?
15 A
or requesting me to look into it further, some-16 thing like that.
l~'
Q s it your recollection that Mr. Hallman's 18 note was written right on the copy of the memo?
19 A
Yes, sir.
Q Showing you what has been marked as Dunn Deposition Exhibit 35, do you recognize that document?
.1 A
Yes, sir, n.n Q
- s that a memorandum fres you to Mr. Keliy?
.3 n
A It certainly is.
64
_4 Q
Oid you draft that me=crandu= following a"-
1885 14'4 EENJAMIN R EPC RTING S ERVICE
1 Walters 6
3 your receipt of Kelly's se=orandu= through Hall =an?
4 A
Yes, I did.
0 Cid you consult w th anyone in drafting o
that memorandu=, Exhibit 35?
o A
Yes, I did.
h Q
Who did you consult with?
8 A
I consulted with certain people in Customer O
service about their opinions on this particular subject.
10 Q
Who?
11 A
As I state in the first line, I said, "In talking 12 with training personnel".
I reckon we should make clear at this ti=e that : should have said "ex-training 13 personnel that are presently e=picyed within the rest 1,,
o f Customer Service. "
1o.
Q Can you give me names?
lo A
Yes, Cal Goslow, Herb S=ith and Bill Street.
1.
Q Did you talk to anyone else in your 18 department?
s 19 A
- do not re=e=ber at this ti=e.
- may have.
20 Ma. GALLIN:
Could you clarify one thing.
You said they were ex-training personnel.
n.i 1
Ix-training personnel at the time you talked to them or ex-training personnel now?
_3 THE WITNESS:
They were ex-training n_,.
personnel at the time : talked with them.
.1885 143 EENJAMIN R E;:C RE N G S ERVICE
1 2
Walters 7
3 2
- e us.ake then one at a time.
Mr. Geslow, what was
- b. i s positien at that time that you talked to 4
hi=?
o A
He is an engineer in the Startup Reactor Group.
Q Was he one of the ex-training people?
A Yes.
8 Q
Where and when had he been involved in 9
training before that?
10 A
He was involved in B&W simulator training of the 11 plant operators.
13 Q
When?
A I don't know exactly when.
He came sometime in
.,u
'72, I reckon.
I don't know.
Something in that area.
I don't know when he asked to come in Service.
I 15 reckon about early
'77.
16 Q
To the best of your knowledge he had been 1 $
in the Training Department from
'7 to '77?
13 A
No, he was actually in the'33R Group before he 19 came to Service, : think about a year or so.
Mayhe it 20 was '76 when he actually got out of Training.
ny Q
What is the 33R Group?
A That is a group that is assigned to work on the Mannheim project in Germany.
6*
Q The Brown 3cveri Reacter?
64
.+
A That
.s correct.
a-
.3 S ENJ AMIN P.EPC RTI N G SERVICE
1 m
Walters 3
3 2
a= still not clear as t wha Mr. Ges':w's 4
involvement in Training was.
O At one time when he was in Training, A
Okav.
believe he was chief er senior instructor down there.
O Q
Down where?
i A
- n 3&W's training for the operators.
3 Q
So he was in the Training Oepartment?
3_
A Yes.
10 Q
And you indicated dates of '72 to either 11 late '76 or early '77?
12 A
That is correct.
13 Q
Was that the time period when you believe he 'was in the Training?
1,,
A Yes.
1O Q
Full-time?
16 A
Yes.
1.
Q And then he either came directly to Nuclear 18 Service er came by way of some other department briefly?
19 A
That is correct.
20 Q
Do you know what Mr. coslow's speciali:a-n1 tion was with respect to training?
Did he focu= on any particular area?
,o A
- do not know that.
I am not familiar with what 23 his speciali:atien is, s
2 Sut he is an engineer, is that what you 1885 147 23 EENJAMIN R E:CRU N G S ERVICE
1 Walters 9
3 said?
4 A
F. e has the : tle with S&W as engineer.
I do no:
know if he is a formal college graduate, if tha: is 5
what your que s tion as.:s.
Ele:
Q Why did you consult Mr. Goslow?
t A
Because of his past training and experience 8
with the operators here at S&W.
9 Q
When you consulted with him, did you show 10 him the Kelly memorandum?
'll A
- Yes.
In Q
And then did you show him the draft of 13 your response, or were you formulating your response at that peint?
14 A
was formulating my response at that time.
le.
Q What was his reaction when you showed hi=
the Kelly =e=crandus?
1.
A
- don't reme=ber at this ti=e.
We discussed, 18 you know, the general context of what the statements 19 were and what they would. lead to in our opinion, but 20 the specifies : don't remember.
21 Q
Did he end up mak'ng any suggestions to nn.
you?
1885 1
A I don't reme=ber.
Q You iust draw a blank as to the substance 3,.
ef your conversation with hi=,
is that what you are w
saying?
EENJAMIN R EPC R*1 N G SERVICE
1 Walters 10 n
3 A
That is true today, yes.
4 Q
Have you ever =ade any notes as to what the substance of your ccnversatien with hi= was?
o Have you ever written anything down that you remember?
O A
Nothing more than this =e=o to Kelly.
Q After you wrote ycur =e=c to Kelly, did 8
you send Goslow a copy?
9 A
No, I did not.
10 Q
To the best of your recollectica, did you 11 talk to Goslow once or = ore than once?
In A
More than ence.
E
- *** Y*"#
13 of his background in Training?
A Right.
15 Q
Mr. Herb S=ith was another person that 16 you indicated you talked to?
17 A
Yes, sir.
18 Q
What was Mr. S=ith's position at the time 19 you talked to him?
'O A
don't know his exact position.
He is e= ployed in the Mechanical Equip =ent Section of Custo=er Service.
3 What his title is, I don't knew.
nn Q
Is he still there?
,e 1885 149 A
res.
2 And how about Mr. Geslew; is he still n
in his pcsition?
E ENJ AMIN R E F"" RTI N G SERVICE
1 2
Walters 11 A
Yes.
aJ Q
Was Mr. S=ith one ef the persens who
,4 vac an ex-trainer?
3 A
Yes.
O Q
What was his background in training?
~
d A
His background, as far as I know, is he is 8
ex-Navy, and he had also been a senior instructor 9
in the B&W Training Group.
10 Q
And during what years, to the best of 11 your knowledge, had he been senier instructor in the B&W Training Group?
77 A
I am not sure exactly when he arrived as senior instructor.
He was in the Training Group from 14
'71 to
'76, too, I recken; in that area.
1O Q
Did you show hi: Kelly's =ecorandu= when 16 you spcke with him?
1 A
Yes, I did.
18 Q
And do you recall what his response or 19 reaction was?
A believe his response was that there was too "O
many "and's" in the instructions frem Kelly.
,1 Q
Yes.
What does that mean?
nn A
Well, the scenario here was that we were trying no
_s to understand what was being said, and how could we S4 break it down in si=ple and straightferward instructions to the operaters?
l885 150 3
SENJAMIN R EPO RTIN G 3 ERVICE
1.
2 Walters 12 We thought chat there was tec =uch fer hi: Oc 3
reme=ber in the particular 1:structions that Mr. Kelly had written about it.
We were trying te find a simpler a
way of passing it on to the operators.
-0 Q
Did Mr. Smith question the underlying e
assu=ption or concern of the Kelly memorandum, or 3
did he accept it as being valid?
9 I think he accepted it as being valid.
10 g
cid it appear to you to be valid?
11 A
The concern, yes.
Q How about Mr. Goslow; did he appear to 7n accept the cencern as valid, to ycur recollection?
A
- think so, to the best of my recollection.
- l.,a Q
Were the substance of your conversations 1a.
with Goslow and Smith addressed te the instruction that 16 Mr. Kelly had formulated and its appropriateness?
l' A
Would you repeat that.
18 Q
Yes.
Was the substance of your conver-19 sation with Goslow and smith addressed more to the instruction, to what should be told to the operators?
^0 A
Yes.
.1 Q
And you consulted Goslew and Smith nn because of their contacts with cperators in the past?
.mno A
3ecause of their past training and experience,
., e s.
1885,151 23 3ENJAMIN R EPC RTIN G S ERVICE
1 Walters 13 n
3 Q
Ycu thought they wculd be able to help you fermulate that instruction in ter=s which =ight be clearer?
a A
Yes.
Mr. Kelly was asking for comments on 6
4 this subject, and we were trying to draw together 4
something that we thought would be very aasily 8
remembered by the operators, something that we o
~
cecid give to them, in effect.
10 Q
How about street?
What was his position 11 at the time you talked to him?
A I'm not sure what his position was, but
- knew In he was in the New Equipment Section of Cus cmer g
Service.
14 Q
Was he a f ormer instructor?
15 A
Yes.
16 Q
- n the B&W Training Section?
1 A
That is correct.
18 Q
And := the best of your knowledge, when had 19 he been an instructor in the Training Section, what
- g years?
A About the same time as the other two, the same y
_i area.
dont know exae:1y when he case.
Q Do you have any understanding as te why n-
.a Goslow, S=ith and Etreet had =oved frc= the Training n.
Section to the section where they were when you talked a:
l885 152-S ENJAMIN R EPCn71NG 3ERVICE
1.
Walters 14 n
3
- = the=?
A did not know their reasons for : ving, no.
Q Oid you shew Street the Kelly memorandum o
as well?
O A
My best recollecticn would be yes, but as 6
not sure.
8 Q
o you remember what his reaction was to 9
what you told hi= e.nd what you =ay have showed him 10 in the fers of the Kelly memorandum?
11 A
No.
12 Q
Taking all three of the conversations that you had with Goslow, Smith and Street together, what 73 is your recollection of their collective advice or wisdom on the subject?
15 A
I think our total input frem them was essentially 16 that there should be an investigation made as to whether or not this -- we should go ahead and pass 18 this along.
I don't remember exactly what we 19 talked about.
What I did was think ever what they had told 20 me and then draft my letter to Kelly, but trying to y
take back and remember soecifics fro = what each one
,n of them told, I can't reme=ber at this time.
,,a Q
When you say there was a sense that an 24 investigation should be =ade before ycu passed it n-.a 1885 i53 E ENJ AMIN R EPC RTIN G SERVICE
1.
2 Walters 14a 3
along, what do you mean by that?
4 A
=eant that we should follow up and pass along 5
to thes to K*ll7 C Pl***
23 'T "*i ^'
e thoughts on what he was asking, as an instruction to O
give the operator.
t (Continued on Page 15.)
8 9
10 11 12 13 14 15 16 1.
18 19 20 21 nn e-
.s S4 1885.l.54
.3 EENJAMIN R EPC RTIN G S ERVICE
1 n
Walters 15 sr/ew 3
Oid you talk :: Hallman at all before you forwarded yeur me=orandum, which
.3
=arked as Exhibit 3.1
- 4 35, to Kellv?
O A
- don't remember.
o 2
Do you re=e =be r wh e the r you talked to Hallman at all from the time ycu received Kelly's 8
memorandum through Hallman up until the time of, say, 9
January 1,
1978, about this sub;ect?
10 A
- don't reme= der, but I would say yes, I had to 11 talk to his someti=e, but ! d o n t re= ember the details
- 1. 6 or the time.
3, Q
Why do you.think you would have had to as talk to him?
A Well 1s.
Q Would you normally send out a memorandu:
16 such as you sent to Kelly without Hallman's reviewing 1 4
.Je. S.
18 A
res, : could have.
19 Q
- s there some other standard procedures 00 within your group which, lead you to believe you would 21 have talked to Hallman?
A No, not really.
On this particular me=o, that Kelly memo, I'm not sure that : talked with Hallman at i885 155
- 1 g
After you sent yeur ::mment :: Kelly, m:
EENJAMIN R EPORTIN G S ERVICE
1 6
2 Walters 16 2.:
see that you sent. carbon 0 0. y Oc Finn;n?
3 A
Yes.
4 Q
- s Finnin in your Nu: lear Sertice Depart-3 ment?
6 A
At the time of the =emo?
Q Yes.
8 A
Yes.
Q Q
Why did you send a copy to hi=?
Had you 10 consulted with him?
11 A
se, : had not.
Do v. o u recall whv.
- v. o u sent hi: a :Opy?
1n v
s.
A Secause he has the same position did, excep
.3 with some startup reactors, instead of operating reactor 14 group.
I became aware that the subject, since he had
- 1. c-not seen this memo yes, he must have seen this =emo.
16 Q
When you say "this
=e=c" you are referring 1
. x -.4.w.a..
.t o. 2 %,.
. w
._ o 18 A aight.
I must have copied his on it because he 19 was copied on this one.
1 Q
But you didn't copy any of the other people on the distribution of the Kelly memorandu=.
I just
,3 wonder why you sent i: to Finnin.
What did you have in mind, if you can reme=ber?
at A
3ecause he is essentially in the same position :-
n, a= within Servi:e, except he has two startup.:; ants.
25 1885 156 SENJAMIN RE CRTING S ERVICE
1 o
Walters 3.3 So for his infor=ation,
=y
=c=ments en this particular 3
letter.
4 MR. IOGAR:
He was your :ounterpart for O
starzup?
O THE WITNESS:
Yes, for startup plants.
g Why would he need to see your me=crandu=
8 any more than any of the other people that received 9
the Kelly me=crandu=?
10 A
- reckon the answer to that is he didn't.
11 g
- t was just.that he was in your =ind in particularly?
A Yes, he sits right beside me.
la.
Q.
Did you ever talk with Mr. yinnin about either the Kelly =emorandum er about your response to it?
1o.
A
- don't recall.
16 Q
=ean did you ever talk to him about it?
A
- don't recall.
I may have.
18 Q
Oid Kelly get back to you after he received 9
19 your memorandus?
20 A
- d n't remenber whether he did or not en :his particular item.
It is a little confusing in my own
,3
~
=ind, coing back this far, versus the next round of en menos tha: came cut.
ae 2
We will ge: to those in a =inute.
By "the S4
.+
next round of me=cs",
I take i yeu mean the firs and 25 1885 157 SEN AMIN R EFC RTIN G 3ERVCE
1 n
Walters is 3.4 3
second Dunn =e=os?
4 A
That is correct.
Q Up to the poin: =f the first Dunn memo-s du=,
which was on February 9th of 1973, do you o
recall any other discussion or any other questions 4
raised about the Kelly memorandum or your response to 3
it or the issue in general?
9 A
No, I do not.
10 Q
- as showing you now what is marked as 11 Wo=ack Deposition Exhibit 23, identified as the first 12 Dunn memorandum, dated February 9,
1978.
A Yes.
i.3 Q
Did you receive a co.p y of it or read it on or about the date it was put out?
1-so A
Yes, I did.
16 Q
And once again you are
.o t shown on the 1 6 distribution, are you?
18 A
That is correct.
19 Q
How did you receive it?
20 A
I think aili street brought it over to me, and, 21 we conversed, and the area of the procedures was probably more in my area than in his particular area.
e, Q
How did Street get a copy of it?
_-a n
A He received it from Mr.
R.
F.
Pittman, who was
,4 1885 158
== the carbon :=py.
E ENJAMIN R E =C RTI N G 3ERVICE
1 0
Walters 19 3.5 3
2 Pitt=an is in your departmen as well?
4 A
He is in the Custo=er Service Department.
Q Did Hallman get a copy of the Ounn me=o-o randun?
O A
To the best of my knowledge, he did not.
s Q
once it ca=e to your attention, did you in 8
turn bring it to Ha11 man's attention?
9 244 4
v_ e s,..
10 Q
Did there follow a se Les of discussions 11 with Bert Dunn about the prescription which he offered 12 on Page 2 of his memorandum?
.o A
Yes.
There were ensuing discussions abou: those.
w Q
Who was involved in these discussions?
14 A
I think.=ainly Cal Goslow and 3i11 Street were.
lo, Q
How about yourself?
16 A
No, I never talked to Bert Dunn about that 1.
particular =e=o.
18 Q
How about Hallman?
19 A
- don't believe that at the present time, but 20 later on, within two or three weeks of that, : did.
21 Q
No, the question is whether Hallman talked to Dunn and was involved in the discussions with Ounn.
y A
I a= not aware o f anv.
mm a
(Continued on following page.)
i885 159 SENJAMIN REPO C NG SERVICE
R 4 10 1
20 Walters 3
Q After Street showed you the Cunn se=c, 4
did you do anything in particular?
5 A
Yes, : asked cal Goslow and Mr. street, "What 6
shall we do about this?" because it did raise a couple of questions in our =inds, and Mr. Street and Mr. Goslow 4
went down and talked to Mr. Dunn about his particular suggestions en Page 2.
Q Q
Did they tell you what the result of 10 their discussion with Dunn was?
11' A
The best remember, they ca=e back and said lo they agreed upon changing his present suggestions in 13 his February 9th
=e=o, and there was still so=e 14 uncertainty as to how we should actually phrase it, if ""
8*"d i*
- ** th*
P****i"7 Fi""*8-15 Q
Did they tehn work with you in ter=s of 10 an effort to rephrase it?
1.
A Not as I reme=ber.
18 Q
To your understanding, did Goslow and 19 Street continue to work, either among themselves or 20 back with Dunn, to work out the final wording?
21 A
think the best : remember is that that a o.
brought it to a halt until Mr. Dunn produced a second memo.
y
_e Q
And would that be the February 16th me=crandu= from Dunn to Taylor, which we have marked a-1885 160
.s 3ENJAMIN R E F C R""l N G 3ERVICE
1 2
Walters 21 3
as Exhibit 36?
4 A
Yes, it is.
5 C
Oid th*: d C :*nt CC*
7 ::
- 'in or about the dat: that it was distributed?
O A
- am not sure when it ca=e to =y attentien, but c
it was in that area, yes.
8 Q
Within a few days or a few weeks?
9 A
I can't recall, but I'm sure it must have, yes.
10 Q
What was the next thing you understood to 11 have happened?
12 A
Well, I think Mr. Goslow and I talked about the 13 situation.
We still -- I had reservations about a couple of things thatthis would get us into.
1,,
Q I want to =ake sure : understand where lo.
you are. You are now talking about it in the light 16 of Ounn's second =emorandus?
1.
A That is correct.
1'8 Q
Okay.
You still have a couple of 19 reservations?
20 A
Yes.
I reckon still had reservations that
_a t they didn't like the two recom=endations as worded, as Dunn had worded it in the second meno.
We discussed
.,n this, and I told them--I t-Ank I instructed Mr. Goslow
,,_a to see if we couldn't get agreement between Services and Integration and ECOS Analysis en =y concerns and 25 1885 161 E ENJ AMt N R ERC RTIN G SERVICE
1 3
Walters 2
3 see if we could ce=e to an agreement on some solution.
Q Cid Goslow proceed to de that?
A To tua best of =y knowledge he did.
o Q
What did he do?
A That I'm not sure.
All : can say is that he did i
have conversations with someone in Integration and 8
with Bert Dunn.
I am not sure at what time c the 9
details of conversations he went into.
This is like
- 0 occurring over the nent, I don't know, two, three, 11 four =enths.
12 Q
You say there were = ore discussione with Ber Dunn in two to four months followinc Dunn's u
second mescrandum?
14 A
To the best of my knowledge.
15 Q
Were you ever a participant in these 16 discussions?
1.
A No, I wasn't.
18 Q
Cnce the first Sunn me=crandu: came into s
19 the Nuclear Services Oepartment, who in the department 00 was in charge of coordinating the respcase te it?
A
- reckon the answer is really, no one was.
31
!885 162 Q
Who was taking the lead?
s.
A I reckon once Mr. Pitt:an gave the letter :
n-
_a Eil' Street, he ca=e over and talked with me, and :
n,.
accepted respcnsibility for acting en 3-
_a S ENJAM!N R E = C MTI N G S ERVICE
1 m
Walters 23
~
2 Pit:=an talked to street?
Would you say 4
that again?
5 A
Bill street at that ti=e worked for Roger Pit:=an.
5 Therefore, he gave the me=o to Bill Street.
Bill Street looked it over and talked to Pitt=an and said, t
"This is more in the area of Plant Performance Section."
8 He therefere brought the memo over to me.
We discussed Q
and I told him I would take action on it er respond 10 to it.
1 *1 Q
Then after that point, you went to Goslow in and instructed Goslow to fellow up with Dunn to 13 resolve the concerns you had still re=aining, even 1 +.
after Dunn's second me=crandu=, about the rece==enda-tio n to the operators, is that accurate?
la-A Yes.
inst cted Mr. Goslow to talk vich 1O Sert Sunn and Integratics, I think, to discuss these 1 4 concerns, yes.
13 Q
Did Goslow report back to you frc= ti=e
~.
lo to uime?
20 A
?. e s.
21 Q
What did he tell you was happening?
an A
- re=e=ber very little of what he cid =e, to s
tell you the truth.
Q Co you re=e=ber anything of what he told yeu?
A Mainly it was that he came back :: se and siid, a
S ENJAMIN R EPO RT;N:3 SERVICE
1 2
Walters 24 3
"I have talked with certain people, Integration pecple, or with Bert, and we finally came to the conclusion tha: Integration is the best area Oc recen-cile the concerns I had had and the cencerns that O
Bert Dunn had."
As remember it, he said he then teck over 8
with people in the Integration, Plant Integration, to c
try to resolve this problem.
Gesicw sai_ that.
10 Q
At what point did he start having dis-11 cussions with people at Plan Integration?
After February?
in i_
A The specifics don't re=e=ber.
Q Referring to Deposition Exhibit 37, !
14 think that Hall =an came back cnte the scene with 15 respect ec their discussion at some point, is that 16 correct?
l' A
Yes.
13 (Centinued on Page 25.)
.a
,1
_c 1885 164
,3 SENJAMIN R E:C RTIN G E ERVICE
1*
n Walters 25 310 3
How did Hallman get brought in?
r-/aw 4
A Well, I had discussed before August 3rd, wh9n this me=o was written, I discussed with Mr. Hallsan, o
I don't knew how many times, but a few times, concerning the Bert Dunn memos and the reactions we t
were getting from Plant Integration.
8 Q
What did you tell him?
9 A
- told him tha
- thought we were getting little 10 response and that we needed to take more action on 11 them.
10 Q
Then what happened when you told his you were getting little response?
What was his reaction?
g A
- am not sure, but I.think it was along the lines of "What should we do to see if vs can hurry it 1o.
up and get a response to it,"
and evidently the answer 16 was, "Let's try writing a letter to Karrasch, manager 1 a of Plant Integration."
13 Q
Was that your suggestion?
,88 3
I 19 A
Yes.
a0 Q
Actually it was a memo to Karrasch?
A Yes.
n.i Q
Who had you been dealing with up to the ti=e the me=orandu= went from Halinan to Karrasch on at
-s Augus 3rd?
Who had you or Oosiew been dealing with
- m.,.
in Integration?
e-
.o SENJAMIN R EPCRTIN G S ERVICE
1
..a., t e r s o
a A
- am not sure.
you have := ask Geslew that.
10.0 0
- believe it was a guy named ou Cartin, I bel. eve, 4
in Integration.
Somebody had been in contact.
o Q
! take 1: Goslow had had a number of 6
conversations with Cartin?
A As far as I know, yes.
3 Q
What was Cartin's position?
o A
That I don't know.
10 Q
Mr. Hallman's memorandum to Karrasch was 11 sent to Mr. Karrasch because Mr. Karrasch is head of Integration?
yn A
Manager, Plant Integration.
s Q
- s it fair to say that the =e=orandum was 14 sent to shake some action out of Plant Integration?
15 A
The memo was written to express two concerns 16 that we had over the suggestions or instructions from l~
the 3er: Ounn me=os and ask Integration to let's try 13 to reconcile these so we could establish either a 19 change in our policy or a change in the procedures to our operating plants if they were indeed needed.
Q take it the original reason for sending
,1 the memorandum, although the memorandum addressed nn
- ertain techni:al issues, was to prompt some action?
1885 1.66 23 A
res.
24 Q
The technica; issues addressed in the m
.a S ENJAMIN R EPC RTING SERVICE
1 Walters 27 3
memorandu: had already been raised n d scussion
- 4 between Mr. Goslow and Mr. C a r t i... :o the best of your knowledge?
o A
That is true.
6 Q
Then what happened after this August 3rd a
memorandum went out?
8 A
very little.
Nothing is written down.
Mr.
9 Hallman told me that he had centacted 3ruce Karrasch a couple of times on the memo.
I, in turn, talked to 10 11 Joe Kelly once or twice about the memo and later i:
10 turned out that Joe Kelly had no previcus knowledge of this particular =emo, but I didn't know it at that g
ti=e.
14 Q
Of the August 3rd memo, you mean?
15 A
That's correct.
16 Q
What did Mr. Hall =an say his conversations 1
with Mr. Karrasch covered?
A He never said anything of any particular nature.
13 19 He said I contacted him, and that was about it.
O Q
Contacted him in what regard?
n A
We were going to supply a resolution or answer the particular meno.
Q Oid you ever go to Plan: :ntegration and ne
_a talk to someone and say, " Hey, are we gcing to g e t.
a 1885 167 3.
response",
m:
.a S ENJAMIN R E;:ORTIN 3 3 ERVIEE
N 1
2 Walters 23 n
.0.4 3
A Like said a moment age, the O n l,. person I was 4
going to was Ice Kelly, and at.tha: time he was no:
aware of the me=o : was talking about.
0 Q
When did you speak t0 hi=?
O A
Sometime during the su==er.
I said, " Hey, Joe, t
when are you going to respond to that
=e=o,"
and he 8
didn't know what I was talking about.
9 Q
Had Joe Kelly told you that he was 10 continuing to be involved in the issues raised by the 11 Dunn memorandu=?
12 A
No, he had not.
[3 Q
You just addressed this comment Oc Kelly because you knew he had been involved in the previous 14 fall?
13 A
- assumed that he wro e the Nove=ber 1,
1977 16 memo, that he was still involved, which was erroneous.
tt Q
He was never invcived after that, is that s
18 what you learned since?
19 A
That is what I thought it was, but I didn't say 00 he was never involved; I do not know, y
Q Do you know if any:hing else happened other than what you have :01d ne, between the time of no the August 3,
1978 =emo and. March 29, 1979, and when
,-a refer to "anything else happening," I a= speaking n4 in terms cf advancing the res012 tion of the issues 6-a SENJAMIN RE CRT*NG S ERVICE
1 Walters 23 n
1,.5 3
outlined in the August 3rd =e=c?
4 A
a= net aware of anything else ha: followed up on this c: preceded the August 3 me=c.
o Q
ta :he best of your knowledga, when this issue came up again following the TM I accident, as e
of that =oment had Plant Integration done anyting 8
toward resolving the issues?
9 A
- can only speak te what I a= aware of, and as 10 far as : know, no.
I can't speak for the whole 11 ce=pany.
d6 12 Q
Oid you talk to anyene in Plant Integration on the day or two er three after the Three Mile Island
.s accident about this subiect?
14 A
To the best of my knowledge,
- r. o.
la.
Q Have you ever talked since the accident 10 with anyone fro = Plant Integration?
1 4 A
Yes, I have.
18 Tell =e who you have talked to?
10 A
Joe Kelly.
Joe Kelly is the only one.
00 Q
what was the occasion for your conversation 21 with Joe Kelly?
A General discussion of the TM 2 accident.
en Who brou~vht u.: the question of the Oun?
- w
,,s
=e=crandu=, you or Mr. Kelly?
,.4
~ _ _.
- s i885 169 SENJAMIN R EFC RTING S ERV1llE
,n Walter:
6.5 3
Q What did you say, er wha: did you ask h27 A
don't recember what : asked him in parti:ular.
It had to de with pressuricer level and the ensuing 3
scenario frc= TM: 2; the specifics do not know.
O Q
Were you relating the Ounn =emorandum to i
the TM accident?
Was that the substance of your 8
discussion?
o A
No, really I wasn't.
10 My two concerns are really not LOCA concerns as 11 Bruce Dunn's se=o's addressed.
My two==ncerns were 12 straight het and normal operation with some =inor transient that did not result in a LOCA such as an' y4 everecoling transient getting es into a more serious 14 p roble =' becaus e of the Bert Dunn rece=sendation, so =y la,
=e=o, the August 3rd memo, really does net intend to 1.6 address a LCCA as such.
It really is trying to ask 1
E the question, could we cause a small break or LCCA 18 through the 3ert Dunn recommendation during nor=al
.A operation cause a trip cf the plant and ever:coling 20 transient ensuing and therefore get ourselves into 18B5 170-ni bigger problem than would be necessary.
\\
Q Has your concern been resolved as of t= day?
on A
- think I have been en the periphery of the
.3 n
sub e t of the TM 2 analysis only but think the R,4
- ncerns have essentially been resolvt d now, yes.
n:
.a i:.i ENJ AMI N R EFC RTIN G O ERVICE
1 o
-. a. e.-.
n 6.'
3 2
Are they rescived insofar as there is a 4
prescr;ption in Sulletin 79-05?
Are you satisfied with that prescription?
Are you familiar with that?
a A
- am not sure ! knew what is in 79-05.
b Q
Det me refer you to a supplementary operating instruction which was sent from sabecek &
8 Wilcos to the operating utilities approxi=ately a week o
/
after the accident.
(Handing.)
10 were you involved at all in reviewing and 11 approving the coerating instructions set out in that 12 document whi=h is cids Depcsitien zxhibit 1c27 A
- was not involved in the r e vi e'v of this.
g Q
Those recommendations reflect substan-1,,
tially the reco=mendations that 3ert Dunn had arrived is, at back in February 1978, is that correct?
16 A
- think that is corre:.
1t 2
Dc you know whether these recommendations, 18 as they are set forth in Olds Depositien Exhibit 102, 19 are acceptable to you or rescive the concerns that 20 you had during 1978?
21 A
No, they do not resolve =y specific concern.
MR. EDGAR:
Have you read that completely 7 n
I885 171
- ake your time.
A Well, the one particular ite= in it, the leaving
_ n,e of EP: pu=ps on f: 20 minutes, is the cuestion I was a:
-a 3ENJAMIN R E:C RTING E ERVICE
1 Walters 6.5 3
asking essentially in my August 3rd me=c, and that has 4
net been resc1ved.
Q so if I understand correctly, your concern a
re=ains, although the instruction has gone out to the 0
operating plants?
i A
Yes.
8 MR. EDGAR:
Cn the basis of that instruc-9 tion and that instruction alone?
10 THE W : Ness-Yes.
11 Q
Now, referring you to Olds Deposition l'
Exhibis 103 which is a revision in the operating n
instruction would you take a moment to review that u
Exhibit if you are not fa=iliar with it.
(Handing.)
1,,
A All right.
O Q
Do the changes reflected in Olds Deposition 16 Exhibit 103 address your concern?
1.
A
- think they do address my concerns, yes.
18 Q
Do they resolve it?
s 19 x
- yes, 00 g
were you involved in the revision in the m.i procedure from the for it took in the April 4th s
distribution to the for it took in the April 17th distribution, referring respec-ively to Ilds Deposition a;
0.,,.
.e,
,x.w.4 b.4.s
- m.,.
A T: the bes
=f =y kncwledge, I wasn't.
!885 172
~
S ENJ AMIN R EPORTING
'3 ERVICE
n Walters 23 0e 3
2
?cu were not?
4 A
was not.
5 Q
Did 7 ever t^1k tC 3*
2 :
"ft*: th'
^*9"** 3'
8
"***#""d** ##
- 3" 6
about the subject of his =e=orandu= and before March 28, 1999?
8 A
If I reme=ber correctly, I have never talked to 9
Sert Dunn about his ne=orandu= or the August 3rd 10
=e=orandu=.
11 Q
Would that be true up to and including 12 today?
[3 A
Ch, about the specific'=e=os, that is true, !
have not triked.
3,,.
Q Have you talked with Ser-Dunn about the la, general subject =atter addressed by the =emos?
16 A
have talked wid: Bert ab o ut the general subje::
- 1. 4
=atter of TM 2 when we were rewriting procedures or 18 right after the eve n t: up there.
!iew, whether or not s
10 these particular =e=os er the subject ca=e up, !
20 don't know.
21
. Continued on following page.)
,,.c 1885 173 2*
6:
.s SENJAMIN R EFC RTIN G S ERVICE
R-
. n.
1 Walters 34 Q
To the best of your knewledge, had the 4
suaject of the concerns raised by the Kelly =escranda 5
and the two runn me=cranda,and :he infor=ation re-flected, ever been transmitted to any of the operating 6
utilities before March 28, 1979?
4 A
To the best of my knowledge, it wasn't.
8 Q
It was not?
9 A
It was not.
10 Q
You referred to Exhibit 37 as "=y me=o-11 randu=."
Oid you write it?
12 A
Yes, I did.
13 Q
And it went eut over Mr. Ha11 man's 14 signature?
A Yes.
la.
Q Aften that memorandum went out, did you talk to anybody again between August 3,
1978 and 1.
March 28, 1979 about the subject that you had been 18 addressing through the Kelly mescrandum, the Dunn 19 memoranda and the August 3rd memoranda?
20 A
The only person ! reme=ber talking to after 01 this was asking Hallman had he gotten a reply from s
an Karrasch.
Q And Mr. Halisan said that he hadn't?
g A
He had contacted hi verbally, and no, he had ac: gotten a written reply frem him.
n:
1885 174 SENJAMIN R EFC RTING S ERVICE
1 Walters 35 n-2 Q
You made that one ce==ent to Mr. Kelly
~~
3 which apparently Mr. Kelly did not understand because 4
he had never seen the me=orandum, is that right?
A That is correct.
o Q
Do you reme=ber any other actions that you took in that time period fro = August 3, 1978 to a
March 28, 1979?
8 A
No, I did not take any.
9 Q
Do you know whether Mr. Hallman took any 10 actions during that time period other than his eenver-11 sations wi'th Karrasch to which you have already 12 referred?
A I 3 3
"""#8 f
^^7*
H*
37 h8'**
13 Q
Do you have any.other knowledge of any 1,,
other facts which would shed any light on the 15 handling of the Dunn memoranda other than what we 16 have already covered, and I am talking about your 1.
own knowledge, obviously?
18 A
Would you repeat the question.
19 (Last pending question read.)
20 A
- do not have any other information concerning what Mr. Dunn might have done.
My own knowledge is 21 as i have already stated.
Q Has anybody told you anything which we n~
.a have not covered which would shed any light on the handling of the Dunn
=e=cranda?
1885 175 25 EENJAMIN R ECC R""I N G SERVICE
i*
2 Walters 26 3
A Nc.
Q
- n other words, the picture we have drawn in the deposition up to now is a co=plete picture?
g A
As far as I know.
6 Q
As far as you know, that is right?
4 A
Yes.
8 Q
Mr. Walters, since the accident at Three 9
Mile Island, have you made any statements concerning 10 your knowledge of any of the events surrounding the 11 Three Mile Island accident and including the whcle 13 sequence of events involving the Kelly me=crandu:
""d
""" "*" **"d*
""d
" *h#*"Th'
""d DY "" *******"*'~
13 a= referring te anything you have written down which is a recounting of your own knowledge er an
,15 interview which you may have given which may have been 16 recorded or transcribed?
~
1 885
!76 1
A No, I haven't.
18 Q
Mr. Walters, we are going to recess your 9
19 deposition at this time, leaving you subject to
- 9 further recall fcr testi=ony, should the need arise.
We will let your lavyer know if the need arises.
~
_n1 MR. EDGAR:
Off the record.
no.
(Discussion held eff the record.)
_o3 Q
f there is a question in your mind as 94
.+
to what : 4: referring to, for instance, have ycu n-
_a SENJAMIN R EPO RTING 3 ERVICE
1.
..aa_ters 2,
3 been interviewed by the NRC?
4 A
No.
5 Q
Do you wish to add to your an:ver in any way?
MR. EDGAR:
Oo you understand the question?
-o THE WITNESS:
Yes, I understand the t
question.
3 A
have not had any deposition taken, nor have 9
I talked to anyone on the subject of TM: outside of 10 B&W, nor have I talked to anyone about all these 11 me=os we have talked about here.
12 Q
Eave you written down anything regarding 13 the history of the handling of these =emos, or given any of your superiors a recou'. ting of hew the memos 14.
were handled, or what anybody's actions were in regard la_
to the handling of the Dunn memcranda?
16 A
- have written nothing down, nor gave to anybody 1 s anything on the s c enario of these memos.
18 Q
How about the TMI 2 accident generally?
19 A
Have I written anything down?
I have produced 20 a sequence of events for the TM: 2 accident scenario, 21 is all.
- n Q
How detailed is that sequence of events?
A It is a ecmpilation of what came off the plant a,.
ce=puter during the incident, tr/img to explain,
.n4 because of a lo ef excess information in there, i885~l77 S ENJAMIN R E C RTI N G S ERVI::E
1 n
Walters
, e_
3 exactly whac happened, at least as far as what the alarm signals that came en the plant co=puter was.
4 MR. ROCKWELL:
Was this the sequence o
that was produced to us, Mr. Edgar?
0 MR. EDGAR:
No.
E Cff the record.
8 (Oiscussion held off the record.)
o Q
Mr. Walters, in constructing the sequence 10 of events which you constructed, did you find anything 11 which you thought was significantly new or different f cm what you =ay have been exposed to in other g
sequences of events?
,3 no, I have not.
A No 1,.
Q Have you had a chance to review other 15 sequences of events in putting yours together?
A I have seen them all, I think.
I885 178 l~
Q With that, we will recess your deposition 18 with the qualifications already stated.
19 (The deposition was adjourned at 1:30 p.m.)
."O
~
James Franklin Walters n3 Subscribed and sworn to on.
this,,,, day,
before me om ce________________1o o*
n.4 Notary Public n.
E ENJ AMIN REPCRTING S ERVICE
1 SQ 2
-N-D-E-X U b 25'*.33 bEb55 4
James Franklin Walters a
3 6
t E-X-H-I-3-I-T-S 9
... _.. _, R S. e., C S..
h, an 3 --
. O R_ _, D :.i _. _... - -. _ O,,,
_ _ u_
s_
. _ _.. _. _ _* w n_ _ _.
11 104 Resume of James Franklin
- J.t. :s 3
1, 13 000 14 1,.
16 1 b 1B 19
,1
.2 1885 179 n-
_0 S ENJAMIN R EPO RTIN G S ERvt::E
4 M
- v o
.e. n. r-_
me
.L-n
- v. O..K s,
)
ss.-
3 We, STANLEY RUDSARG, Certified Shcrthand O
Reporter and Notary Public of the State of New York, and ROBERT ERK!N, Notary Public of 8
the State of New York, do hereby certify that 9
the foregeing deposition of SA3 COCK & WILCOX by JA.MES FRANKLIN WALTERS was taken before us on 10 the 6th day of July 1979.
.1 The said witness was duly sworn before i.n the co==ence=ent of his testi=cny.
The said 13 testi=eny was taken stenographically by ourselves 14 and then transcribed.
The within transcript is a true record ef.
16 the said deposition.
17 We are not related by biced c: =arriage to any o' the parties herete nor interested 13 directly er indirectly in the =atter in centro-79 versy, ner are we in the e= ploy of any of the counsel.
61 IN WITNESS WHERZOF, we have hereunto set w
on our hands this Mrc day of July 1979.
~~
r m-4
.5
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23
_ _ _/_ _ _ _ _ _ _ _ _ _ _ _ _ _ _._ _._. _ _
. - _.,.,.. /
,n.n_,-
. e r...
6 s oes.
3ENJAMIN R EFC RTIN G SERVICE 1885 180
Resc=e cf Jcrer ? anklin Wal:ers Address:
402 Lakev=ed Street lynchburg, VA 24501 Iduca:1==: 3SNI,1965 N.C. State College Work Experience vi:h 35W:
2/77 - ?:esen:
Supervise: E=,gineer 1: Plan Performance Services See:ic of Nuclear Service. Supervised plan: restart testi:g and ccc-
- act supplied infc::atics.
4/75 - 2/77 Seuier Engineer in Mechanical Equipmen: See:1c of Nuclear Service.
9/73 - 4/75 Tes Coordinate: f=: initial star:up testing on A?&L AND-1.
12/72 - 9/73 Firs:-of-a-Kind Test Engineer, Assistant Shif: Insineer and Shif t Engineer ic: 3&W Advice and Censultatic: tet:
fer initial startup cf Ocesee I.
9/71 - 12/72 Engineer assigned : v:ite test spe:s. and ::ai: Operaters in varicus aspects of startup physics tes:ing.
/69 - 9/71 Perf or:ance Engineer in Sten: Genera:c G::up of Cc=pecent Engineering. Assigned various tasks f== code devel:pten Oc R&D testing of scale p;c:ctype ef full size OTSO.
Werk I:perience with 3:cv Engineeri:g:
9/65 - 2/69 Perf or:ance Engineer assigned varicus tasks cc operatics sud develep en:al :esting cf large H /02 ::cke: engine (J-2) f::
2 Satur 5 recket.
Mos ecteably was simula:ed envi c =en:al testing (app cxi-
=a:ely 100,000 feet) of J-2 a: AI C.
Also foll:wed :esting 4
cf sa:e a: MSFC in Hun:sville, Alabama.
Was assigned task of info =ing NASA (MS7C) people c: cpera-
- ic and con:::1 of NE?.VA rocke: engine until pr:g ::
folded.
>{
- / <,f
- 7
{y(/I
/*-
g M CUsTR Z OM 12 32t.:AM'N 1.
1885 181