ML19256B658
| ML19256B658 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/16/1979 |
| From: | Goldfrank J, Hallman D BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908160270 | |
| Download: ML19256B658 (44) | |
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12i DEP05: TION OF CONALD F.
HALL."AN by JCA:i GOLDFRA:.s,,
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13 held at the o#fices of Babcock & '.li l c o x, Old Forest Road, I
14 l L.v n c h b u r c, Virginia 24505 on the 15th day of July, 1979, i
commencing at 10: J5 a.m.
before 'torma Nasuti Costello, certi.
10 fied shortnand reporter.
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BASCOCK & WILC0(:
3 MORGAN, L E'..' I S & BOCK:US, ESOS.
4 Attorneys for Babcoct & '.!i l c o x 1800 ?! Street, N. '. !.
5 Washington, D.C.
20036 6
BY:
KEVIN GALLEN, ESQ.
7 FOR THE COldtt SSION:
g JOAN GOLDFRANK, ESQ.
9 10 11 12 13 g
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16 17 18 19 20 21 1881 021 23 24 i
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INDEX 3
4 i DTEECT
! WITNESS 5:
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! Donald F. Hallman 6
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Princeton, p) 3 Q
In wr.at year' f) ghh l
l A
1950.
4 i
, 'l Q
Where did you receive sour dcctorater j
A North Carolina State, 1963.
6 l
Q And in which years were you in the Air Force?
l 7
A
'50
'63.
l Q
When did you start working at Babcock & Wilcox?
i 9
A
'72, October, I believe.
l i
10 Q
What position did you hold when you started with l
them in October of '72?
l 11 A
Senior Research Encineer, I believe.
I O
And how long did you hold that pcsition?
13 l
A Oh, it must have been through '/..
l 14 l Q
And then what position did you hold?
15 A
Oh, I was Principal Engineer.
16 g.
For how long did you hold that position?
17 A
I worked until September of '76, approximately.
is Q
And what position did you hold?
A Then my current position.
19 Q
Could you tell me where you were emoloyed when you finished your doctorate at North Carolina in '68 until 21 i
I y su started at Babcock Sli l c o x in '72?
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A Yes.
Sequentially it would have been Savannan l
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P,iver Laboratories, '53 and
'59.
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O Did you review it?
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'v, Did you aceive a res onse - : c.
' ' -. <ar 23:n to 1881 025
a n /Rb O g {(s ogjMF 5
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2 this memorandum' s
A I received no written response.
3l t
I Q
Did you receive an oral response?
4 f
A My recollection is vacue, but i did receive --
5 i
I did receive an oral response which to my recollection e!
stated that he did not believe there was a problem.
t Q
Do you remember when that oral response was i
8, given to you?
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t 9
A I don't remember exactly.
It was this year, to after Christmas and sometime before March 28.
Q And what did he inform vcu at 11 that time?
1 I
A Again,-tc the best of my recollection, he informed me that there was no problem.
13 j.
Q And what did that response mean to you?
14 A
That response was confusinc.
I did not realize I^
at the time whether ne meant there was no problem with 16 action or there was no prcblen with coeratcr inaction, and I-I did not ask hin for a clarification at that time cf our conversation.
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4 l
Q You were not clear as to his indication that there was no problem out you did not ask him at that time m
to explain further?
i 21 A
That is correct.
To clarify, the meeting was in
-l tne hall by the drink macnines, and per my memory I asked 23 ! hin if he had reached a decision yet en my August 3 memo, 24,
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l 1881 026
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and t he re v,a s convers a ti on whi c.
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don t believe there's a problem", anc he had to go cff to
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another meeting before we could talk urtner.
4 l
Q Did you contact him sub ecuent to that ~meetinc s
~
in the hall?
6 A
Nc, not to my recollection.
7 Q
Did you contact anybcdy on his staff?
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A Not to my recollection.
9 Q
Oid you send sn6ther eecrandum to hi~m?
- o A
,i o.
ii Q
Did you send another memorandun him ionEBFn-ing the subject?
g A
No, I did not.
13 Q
Was the discussi6n in the hall someti5e a#'ter 14 Christmas the only discussi6n you had in fescanse or concerning this Aucust 3, 1973, 5s50fsndub with Mr. KiFFasch?
M A
No, it wds n6t the only 66e.
I Fsdsil ai leiit
{
C two other conversations.
I can't Be sure about the ti5e.
e One per my recollection was a teis6 hone call to ask his the 4
answer to the meddedndum.
A66ther wss another do6ver5aiidn g
where maybe I went bac~k td his desk or 55y5e it was a66ther tn the haTT after the telephone conversafion wnere : asked n,
i him for a response.
j
=
Q And at that time when you asked him for a rs pcnr3 Oc Ong ;agust 3, f 975,- dsidelidud,- did y6u Fediive a
I 1881 027 r
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<,. om armnnnnr nr 1
3 a
2 a response?
3 A
No, I did nct recesve a response to this l
memorandun.
4
,i Q
What was the content of your telechene call?
A The content was, per my memory, that we needed 6
en answer for this and dio not intend or did not plan to
~
l do anything with the situation until we had his respcnse.
8 Q
That was communicated in a telegncnc conversa-I i
9 tion with "r.
Karrasch?
10 A
Yes.
Q And what did he respond to that answer?
li A
Oh, again per my recollection he said, " '. ' e l l,
we will cet 13
~
on it".
i I
Q Was there a memorandum that followed that 14 i
telephone conversation --
l' 1
I5 i
n ao.
r 1
16 Q
-- written by you?
1~
A No, not written by me.
l Is Q
Was there a memorandum wri* ten by "r.
Karrasch?
l A
Not to my knowledge.
9 l
i Q
Did you take notes of that telephone conversa-2 M
i i
tion?
m l
A No, I did not.
22I i
l Q
Was anybody else a party to that' telephone ri a.!conversaticn?
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2 not clear as to wha: ne mean: 0; :na: inci:a: :n?
A Inat is CCrrect.
Io Cla"'#f,
- "eC0l'ect e
callin: nim cr.ce or twice, but he aas not in :ne 0 #fice.
4
! recolle:: coin bac< 00 nis Of# ice at leas; once.vr.en 5
i ne wasn't there with this sucj ec t in mind, but I don't 6>
i recall the times.
i Q
Is there any record of tines tnat you tried to t
i 3
i get in touch aitn somebody within tne office and were 1
9 unable to?
j i
10 i A
Oh, no.
I have gone through my notebcok and i
l
,1 I didn't see any.
i i
MS. GOLDFRANK: Let the record show you have l
brought with you a notebook.
l BY MS. GOLDFRaNK:
l i
14 Q
Could you exclain to me what is contained in 15 l
that notebook?
16 A
This is a record of some -- exc.se me while I 17 l look tnrough to refresh my memory.
71 i s is ncte of my is meeting ninutes that I have attended.
It is a note of some tele;none conversations which I nave had with our 19 I
2n ;
customers and miscellaneous information which I thought l
wort!, p re se rvi n g.
l 21 ;
I Q
Does it record meetings within
'a=---ek 1 'Vilcox also or just contact with customers?
i B;
A Meetings within Sabcock i '.ilccx, also.
24 i881 030 n
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4 10 a &
Ih d u d Ell 1
a Ish a Q
And you have read.nrougn jour notes anc nave not fcund any notes concerning c i s c u s s '.' e n s a " t h ".
~ s i
Karrastn' i
4 A
No, I have not read throu;n them thoroughly.
i I
I had glanced through them to see i.f tnere was anything 6
i in there that would hel p my memo ry, but ! have not done a i
detailec page by page.
8 MS. GOLDFRANK: I would like to request at this I
3 time i f we could have a copy of Mr. Hallman's notes.
Could
- 0 we go off the record?
MR. GALLEN: I think we can.
,1 (Discussion off the record.)
MS. GOLDFRANK: As the conversation c#f tha 13 l
record concerned production of a handwritten notetock of i
14 Mr. Hallman, that document will be reviewed by Counsel 15 to determine whether or not it contains croo-ietary I
16 information, and if it does, will be produced at Counsel's
!~
office for review by tne Comnission.
i I
is BY MS. GOL3 FRANK:
Q In your review of your handwritten notes contain-gg ed in that notebook, you did not. come across notes concerning discussions with or attempts to contact Mr. Karrasch with i
respect to this August 3, 1973, memo, is that correct?
en A
That is correct, in the review that I made, i
t3 which was not thorough.
i I
I 04 I
'l 881 03 i i
ts!
6
J J
i 2
Q
- n the time, August 2, 1972, unti' "arcn 1979, 3
did you contact anyone en Mr..;arrasch's staff concerning this mer.o?
A I did not write any formal meno to anyone else.
5 6
I don't recollect if I discussed it with anyone else on i
i Mr. Karrasch's staff.
7 Q
Do you remem0er if anybody on "r.
Karrasch's 1
~9 staff contacted you concerning this memo' 9l A
Acain there was no memo that I'm aware of sent j
,I i
10 out, and I don't recollect i f anyone contacted me.
Q You do not recollect any conversations with 11,
l i
anybody on "r.
':a r r a s c h ' s staff?
i l
i A
No, I don't recollect any.
13 :
Q Do you know of any conversations between anyone g
6
~u else on your staff and either Mr. Karrasch or somebody on
(
his staff concerning this memorandum?
i i
i 16,
A No, I don't recollect any.
l l
l 17 Q
Could you explain to me why you wrote this t
I i
is August 3, 1973, memorandum to Mr. Karrasch?
i t
l A
Could you clarify more directly wnat you are j
19 i
I looking for?
20 g
Q What was the purpose for you writing this l
.1 I
I August 3, 1972, memorandum to Mr. Karrasch?
i, 4
2 A
Okay.
The purpose was to reauest a review of 23 possible consecuences that would be involved in following I
0:
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ne re:ormendation:
nat we nan rere' /e d and ncn-LCCA situations, Q
'Is is correct to say inat you were concerned in ettin: soe:1:10 answers 0 One two questions that you i
i raised?
0i l
A Definitely.
i I'
i Q
Could you tell me wnat you dia subsequent to 8
your ::nversation with Mr. Karrasch that indicated to you i
9 that there was no problem' I
l
- o A
To my re llection I waited for a meno stating i
i wnat action we shculd take in response t o thi s nemo, When g
that was not received witnin One tire period, ac.ain oer g
cy re:Ollection o f t r. J weeks or ap;*Dximately, I made a 13 note to contact Mr.
Karrasch and to find out what he meant.
14 i Q
Did you cntact Mr. Karrasch subsecuent to that 15 conversation?
i 16 A
No, I did not make contact, i
0 In tne ::nversation that you had did you I
indicate to him tnat vou were awaiting a memorandum fron
,6 4
I him?
m.
i i
A I don't recall the word "mencrandum' being used per se.
I do recall words ::n=erning I was awaiting 21 l
a resolution.
l Q
You indicated to him that you were awaiting 8
f e
i resolution; is that to say that you were not satisfied with I
1881 033 ai i
I D Mh Nh i
()*Q]1 1
U gemAL 2
- ne ccnversation in :ne hali concerning :nis emcrantur?
3 A
I don't remember the exa:: eords :na: we saia 1
in the hall, other : nan I renember the "no robler" bi:.
4 ;
i I don't recall requesting that he answer nis.
' li Let me back up.
I don't recall -- I just d:n't recall the 6
words that were said.
The intent, as ! recall, was that, yes, get back wi
- me, but I can't renember tne aords that i
8 would have given that information to him in detail.
l l
9 Q
But in your mind that is how you left it, that i
10 he would get back to you in sriting?
A Yes.
In my mind it was lef t tnat he would be 11 I
getting back with me shortly, and I had assumed it would g
13
~
I do not recall statinc tnat it must be in be in writinc.
~
i writing.
14 Q
Do you recall what you said to Mr. Karrasch in that conversation that would indicate to him that you 16 expected a response, a further response?
17 A
No, I don't recall specific words that I said is that would nave indicated that.
r l
I Q
Did Mr. Karrasch say anything to you that 19 would indicate that he understood that he was to get back
~ou?
y 21 A
No, I can't say that I recall specific words.
M
~
Q And you then indicated in previous testimony i
Bil that you waited about two weeks to then try to contact
.Y r.
24 l 1881 034 J
r es t
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2 Karrascn?
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oo) o m
3l 5
YOS-I Q
And wnat nappened unen you tried to :Ontact hin g
4 i
l at tnat point?
3.
i i
A That I don't recall specifically.
I do 20 I
6I I
i recall establishing contact with nim at tha: :cin:, and I 1
don't specifically recall any incidents where I called nim 8
or went back to his desk.
I have a recollection that 'I 9
took some action at that time, but nothing I can pim down i
p) l in memory right now.
Q Did you try to contact anybody else um his 33 I
sta f f ?
12 i
i A
Nn, I d i d n o t p e r ey memo ry.
j i
Q Did you instruct anybody en your s:21" :n try 14 to contact 'me anybocy on his staff?
15 A
fiot per my memory.
i is Q
Would there be any indication of su t 2:temots?
17 A
I don't believe so.
I i
13 Q
What action did you take as a result at yrnr I
{
inability to contact him?
- g i
A Let me think.
I believe that I made a mute to i
myself on a scratch pad of " resolve HPI situation" or words t1 I
to that effect, and I believe tnat I =ade an a: terat, which
-) *1
~~
did not culminate in a contact, but that.as trrowm 2s: with 23 the waste pacer, I am sure, as ay daily n::es are..
I 24 I i
1881 055
- s I
I
I 1
15 2
Q You do not believe ycu still have your hand-written notes?
3l-A I don't believe I could produce them, no.
i 4,
i i
Normally whenever days are past, I discard then.
i a
l MS. GOLDFRANK: I would like to request a search
~
6 I
be made as to wnether or not such a note would be retained.
7 THE WITNES!
Okay.
8 MR. GALLEN: Excuse me.
Could we go off the 9
record a second?
10 (Discussion off the record.)
BY MS. GOLDFRANK:
33 I'
Q Could you explain to me then what you did at that point with respect to your August 3, 1973, memorandum?
9 13 A
At which point?
14 l
Q At the point where you were unable to contact 15 Mr. Karrasch concerning that memorandum?
l 16 A
Gosh, I guess I awaited a resconse.
I have 17 no recollection of past that.
I probably made to nyself 4
13 a mental note that says that I couldn't get in touch aith t
j him again, to try again later when he was available.
19 i
Q So the concerns raised in this merorandum were left unresolved while you awaited further response fr:m Mr.
21 l
Karrasch; is that correct?
=
1 A
That is correct.
23 Q
You did not n oti fy any of the 31W customers as 6
24 I
i
[
- esI, i881 D36 L
h
I D
- T ]D &&&~ h,h
'O wW\\
E/U'udMLu(U1 o i
21 to the concerns raised in this mencrandur' i
I A
Are you referring to the arrascn memorancun, J
my memorandum to <arrasch' l
1 i
y
.he *ugust 3,1975, merc ra ncun, ye s.
5:
A To the best of my knowledge, that's correct.
i i
6 l
Q Is this prior to " arch 23, 1979?
A This memc?
I l
Q No; that you did not infern your customers l
8 l
9l Of the concerns raised in this memorandun.
I to '
A That is correct.
Q Did you since " arch 23, 1979?
g A
Have I what?
12 Q
Informed B&W customers of ne concerns raised 13 in your August 3, 1973 memorancun.
j 14 (Pause.)
i 15 MR. GALLEN: I think we might want to co off f
i 16 the rec _rd for a second.
i 1-(Discussion off the record.)
ANSWER: The answer is we have sent the customers 13 further information to clarify the response to small creaks g
a t 3&'1 plants.
20 l
Q And do you know the days'of when
' ou sent that I
21 l
information?
i A
Ch, the speci #ic da; s I don't have in my memory.
It was during the Aoril, May, time frame.
24l i881 037
- s!,
P i
l Ll J
/r 17 2'
Q And could jou exoiain wnat new instructions you i
3, gave tnose customers' i
I I
A Th-new instructions were essentia',1y more 4
deta'ied c o r. c e r
. n c. the reso0nse to a small break wnich 6
i incorporated the essence of tne two memos by Burt Dunn; 6
i said memos being referenced in my reno t o Ka rra sch.
t 7
l I would like to ask, do you have a copy of s
r,
- and I two Dunn memos?
I made that statement from memory b
9 would like to look at those.
I 10 MS. GOLDFRANK: Why d2n't I introduce the two I
l Bert Dunn menoranda.
One is dated February 16, 1973, and ii i
f one is dated February 9,1973, which are Dunn Decosition l
Exnibit 36 and Womack Deposition Exhi bi t 23.
13 I
(Pause.)
1 14 ANSWER: The question was, did the instructions
!.i which were sent out in the April time frame this year address 16
[
the Bert Dunn concerns?
I 17 Q
Right.
j i
is A
Yes, I believe they did.
Q Could you explain how they were accounted for, 3g how those specific concerns were accounted for in the m
g instructions?
)
21 A
Let's see.
Per my recollection the coerators r
9 22
)
were instructed to plot temperature versus pressure to 23 determine its -- saturation relationships, which is not an l'881 038 24 i
15 l l
l i
(
i e
8 MM fnE[lh{lhh I
t l
rgwn unusuum is 2
exact term -- to determine ne thermodynani c rela ti onsnips of :ne fluid in :ne rea::or cooling systen, and conci: ions
~
i were speci#ied at whien point high pressure re;e: icn should l
be terminated.
5 Q
Let me see if I can rephrase what you said, 6 I i
just said in engineering terms.
At tnat point were you instructing 3&W customers 8,
to analyze tenperature and pressure to deternine the level I
9i of coolant in :ne reactor core and not the pressurizer i
indication level?
I 10 t
A Not exactly.
'le were not instructing then to 7,
do this to determine the fluid level in the system directly.
12 l
We were instructing them to do this to assure that the la.
system had reached a condition at which the core was cooled.
i 14 i It was not a method of determining level, liquid level directly.
It was more a method o f determining that a clant I0 16 is now in a situation where the core is adequately cooled.
1: l Q
And could you repeat for me again what the 8
33 {
instructions were?
A They referred to the speci'ic instrumentation g
by B&W nomenclature and not by plant instruments 10 num er 20 to look at, and they referred'to a curve which said, if you 21 are here, you are okay; if you are not here, continue to r
take further action.
Q And what instrumentation would that be' 23 '
24 '
f i
!881 039 23 ;
i I
f I
D "D
3D %9I p es es J d
, edL d( /
22 i
1 19 i
i l
l 2
A That would be tne temperature sensing instrumen-6 tation in the reactor cooling system and the pressure 3
sensing instrumentation in the reactor cooling system.
i 4
l To clarify -- not to clarify, but to take it l
5 I
somewhat out of engineering termir. ology, it would be 6
measuri.1g the pressure and temperature in the reactor cooling systen.
8 Q
And that is distinquished from the pressurizer 9
indication level; is that correct?
A Yes.
in Q
C )uld you tell'me who was consulted in g
formulating these new instructions that went out sone time in April?
13 l
A I can give you a partial list fron memory.
l 14 0
Okay.
j 15 A
Burt Dunn.
We are discussing April '79?
l 16 Q
Right.
17 A
Burt Dunn, Bob Jones, Bob Salm, Allen Womack, Jim Taylor, Ed Xane, Norm Elliott.
There were others, I 1g believe, in and out, but I don't remember specific names.
Jim Veistro was one who participated part time.
m i
Q Were they included in formulating these new 21 instructions?
Were there formal meetings that these 2
people would have attended, or were there an exchange of 23 memorandum?
1881 040 24 23 I
t f
i
il, i
l 23 l
2i A
There were meetingt I dcn't understand your j
3 !
use of "for 2:
Tney were convened.
Tney we re technical l
discussions.
There wera decisicns made as to wnich was ::7 c 4
best way to 90.
We all tried to esch a decisicn of what 1
5l l
was the best way to prese$t the information :n the coerators.
6' Q
By " formal", I mean were there meetings 7I t
j convened where these pecple were requested to come and Sl participate in the discussions as opposed to an informal l
9 talk in the hall?
i l
1 10 '
A Yes.
They were. requested to come.
By your 3r,
definiti0n they were format meetings.
i Q
Who would have cha rod these meetings?
A To my recollection Ed Kane cnaired the meetings.
13 Q
And would there have been a memcrandum sent 14 around c: king these people to att'end this maeting and wha t 13
{
was going to be discussed at this meeting.
I i
16 A
That I truthfully don't recall.
The meetings 17 were announced and the attencees were tnere.
I don't recall Is.
whether there was a formal memorandum sent saying to be g
there or wnether it was telephone conversations and the people appeared.
i Q
You did attend these meetines?
l 21 A
Yes.
When I say "yes",
I attended at least 22 90 percent of the meetings by my estimate, maybe all, but a'
I an not sure that I attended all.
24 1881 041
- s I
dL
_J' o
21 Q
Would ycu have reviewed tr.e #inal instructions t r. a t went Out?
A Can we co of' the e: 0-d
- r a moment?
t MR. GALLEN: Okay.
(Discussion off tne re:Ord.)
l 6f (Whereupon tne cending question was read.)
'I !
THE WITNESS: I would have reviewed the #inal l
4 !
instructic.!s that went out in the oeriod two to three weeks I
-9 i after March 20 and suosequent ocriod.
I may or may not have I
i reviewed findi instructions which went out Mar:h 23 plus j
.g i
- wo or three weeks due to working cuite heavily on the 11 l
Three Mile IL recovery.
I am not aware of everything that went out in that time period.
j BY MS. GDLDFRANK-1 14,
Q I would like you to look at a November i, 1977, l
!5 memorandum that has already been marked as Womack Decosition j
- 6 !
Exhibit 24.
i Did you receive a copy of this memorandun?
l l
A Yes.
.b a
Q Do you recall reading it?
A Yes.
20 Q
You are familiar with an incident that occurred 21 on September 24, 1977, at Davis-Besse I?
A The term " familiar" needs definition.
I knew 23 i the incident had haopened.
I know sor.ethings and I am sure l881 042 1
3
f l
22 E'JJ" I
1 t> U U U B12u,6 t &$ L3 2
there are some I don't know.
=
0 When did you first learn of this incident?
3 A
I don't recall; but given the nature of my 4
job, I would have lea ned about it, that the incident nad 5
i occurred, and that the plant was down, that day or the day 6
afterwards.
Q Do you remember who told you that this incident t
f 8
had occurred and the plant was down?
I 9
A No, I don't, and we should define "1ncident" i
io as I did before, that the plant was down.
Q Do you remember if you were informed orally 11 I
about this incident or whether or not you received a 12 memorandum concerning the incident?
j 13 A
Let's limit it to the plant ccming down at that l
14 time.
I am sure it would have been oral.
15 Q
But you do not remember who orally told you?
l 16 A
No, I don't know.
I i-Q As a result of being informed that the plant was down, did you talk with anybody?
tg A
I don't remember, but I would be sure that I did talk with somebody about what caused it and how long 20 would it delay our schedule.
21 Q
Delay what schedule?
A The schedule of starcuo for the plant, i
23 Q
Do you recall preparing any kind o f memorinda i881 043 24 i
i 3l i
f i
23 I
f 0
2 concerning that incident?
l
,4 0, I don't r? call.
n 3l l
Q Are you aware tnat One September 20, 1977, 4
incident at Davis-Besse concerned voiding in the core?
5 A
I am not aware that it did.
I an aware 6
of discussions where a synopsis essentially of what occurred was presented, and I remember it being discussed that there 8
was potential voiding in the core, but I do not know that i
9 it has been pinned down that during that incident the core l
to was voided.
Q You indicated 'that there was discussion g
concerning a synopsis of what happened during that incident?
A Correct.
13 Q
When was that discussion?
l 14 A
1 don't recall tne dcte.
The discussion was a 15 resentation by Jce Kelly in one of the large conference 16 rooms which summed up what happened and why.
I 17 Q
Would that have been soon after September 24, 1977?
i
- g i
A "Soon" bei r.; a ma t te r o f wee k s, ye s.
g Q
And Joe Kelly is the individual that described
.m the events?
l 21 l
A Yes.
Q Were you aware that the Se : ember 21 incident 23 i concerned a temporary loss of feedwater?
I 24' i881 044 25l
I
\\0 uv-u us u u u t.m u u u u u da i
24 2l A
Oh, no. Per my memory I was aware ;, f a T.a l f u n c -
4 l
I tion in the feetwater system, but at that time I was'nct 3
aware of specifically. hat the c.alfunction was.
Q Were you aware that tnat incident concerned an 5
open PORV' 6
A My recollection is that that was brought up in I
the meeting, yes, I wa s aware of i t.
8 Q
Were you aware that that incident at Davis-Besse t
I 9
concerned the hian pressurizer indication level?
i to A
At that time I. don't believe I was aware of that.
33 Q
Are you aware of that now?
A I an aware of that verbally.
I have not gone 13 back and read that transient in detail to see exactly what 14 it said.
j 15 Q
Do you know when you would have become aware 16 j
that the transient involved high pressurizer indication it level?
I A
No, I don't recall.
13 Q
Do you remember who might have inforned you g
that that transient concerned that?
20 I
.A Oh, who might have? It may have been Joe Kelly, 2:
because he and I know each other.
It may have been one of my people who was following the startup.
23 Q
Do you know for sure wno informed you of that 24 incident?
!88 045 1
t5l i
o u
e F
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1881 046 4
ii) M [id Ifd O [lI 3 fl O Il h
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J J@ua Quuuum 1
co 2
MR. 3 A L L _ ';
I believe a CODy of :nat has already i
I c
-man re:_e::ed i r.
"r.
.,a l t e - s ' Depcs't : r.
I
?!S. GOLJFF.A.',:. Okay, 1ne.
4
.'..y av,wFnie?.
i o.
a 1
O Could you explain to me, there's on this 6,
I November i, 1977, mencrancun, where it says " customer" it 7
i is indicated ' ge n e ri c ".
Can you explain to e what that 3
neans to you?
I 1
3' I
I A
" Customer guidance"?
l l
i 10 Q
Above that line it indicates customer is it generic.
i A
To me that implies it deals with all plants supplied by 5 & 'J.
Q All plants?
14 A
All nuclear power plants supplied by BSU.
15 Q
Not necessarily more than one?
i l
I 10 I A
I am sorry; I don't think I understand that.
I 17 Q
The distinction I am trying to make is you I
i
- sl indicated " generic" means to you all plants, all 23U i
nuclear power plants?
9, A
Yes.
I 20 l
Q It does not necessarily mean more than one?
21 l
t A
Yes, it means more than one.
l
=!
l881 047 Q
As opposed to all' l
l
~
A I must have said it badly.
l 24 I
i a
i 25; i
h 1
_ ).
2' ME GALLEN; C;uld
,s e ;c c#f tne record for a 3
seconc?
I (Discussion of# cne recort.)
4 1.l BY MS. GOLDFRA'E o i Q
Am I correct that your understanding of " generic" 6
is all B&W plants that are operating?
l A
Yes, plus those that are under construction.
I a~,
i Q
Dkay.
l l
9l A
Let's cla ri fy that by all 35W nuclear plants, l
10l because I don't deal with the fossil plants.
l ii Q
You transmitted this November 1, 1977, memoran-i d u m t o.'ir. Ualters on your staff?
i g
A That is my recollection.
t 13 Q
And did he discuss the memorandum with you?
14 A
I don't recall.
i l
Q Did anybody else on your staff discuss the i
16 memorandum with you?
17 A
I don't recall specifically.
I thought there i
is was one other discussion, but my memory is vague, because it was a long time ago.
tg l
Q Do you remember if you discussed the memorandum with anybody out at 3&W?
A We are referring to this particular Joe Kelly 5
memorandum?
I do not recall discussing it witn anyone l
23l outside my staff.
a!
l881 348-I
- s:
i l
t h
h k b [1ks O
A 23 w
eno?
Q I 40ulc like y0u ;c icok now at a nandsritten l
nencrandu Cated N 0'/ e ~ ; e r 10, 1977, that has alecady teen i
3 introdu:ed anc arked as Dunn :e;osition Exhib"t 35.
Please a
look at that.
5 i
A.
It looks like some if this is cut off en the I
s i
left.
I nave examined it.
Q Have you ever seen thi s mer.c ra ndun be f o re ?
I 8
A Yes.
i 9
Q Did you receive a copy of it in f o v e r.b e r of
- o -
1977?
A I don't think so.
I don't recollect -i t.
u I
0 Have you seen it before tocay?
C A
It was after Maren 28, but the exact date I i
13 don't remember.
I 14 Q
Who gave you a c:py of the memorandum af ter 10 March 2S?
i i
16 A
I recall Frank Walters showing it to me.
l r;
Q Do you recall wny he showed it to you?
A Yes.
i tg Q
Could you explain to me why he.showed it t.o g,
20
-vou?
A I wa s awa r e o f my me mo t o Ka r ras.c h ahich h.ad 21 raised some questions, and this would have been maybe a men n after the incident because o f time press u r.e.s, I had
- j same eack to i::e ame to :-v to +0110w :hrough that chri, i881049-
,I
- s.
h I
h,h,k fl 9
]uJi I
$ b b c/
2-myself as to wnat had haopened.
m 3:
Q And in that you were taixing to Walters?
A Yes.
4 l l
Q And he gave you this memorandum?
i 5
A Yes, that's my recollection.
6l Q
Did Walters talk with you crior to writing this memoc=ndun?
I 3
A I don't recall.
I will just have to leave i
9 it at that; I don't remember.
10 Q
Would there be.any notes on your part if you r
I had discussed this memorandum with Walters?
g A
I certainly don't recall any.
I i
I 0
If tnere were notes, would they be in your 13l i
notebook containing those handwritten notes' i
14 A
If there were notes, yes, they should be in l
15 there.
l 16 Q
Do you remember discussino this memorandun l
1-with Walters af ter he :e it it to Mr. Kelly in November of
'77?
13 ;
l A
I recall a discussion of it.
This would be in the post March 23, 1979, time frame.
I don't recall 20 l
minute details of the discussion.
I ti MR. GALLEN: Excuse me.
The question was whether 22 or not he discussed it with him after he sent it in ?!avember 23 of '77; is that correct?
i881 050 e
1 25 l t
a 30 2
MS. GOL F AN.<:
- r. i g n t.
D
~
l THE WITNE55; I d;d not discuss it in Novemoer 3
of '77 per my recollection.
BY MR. COLOFRANK l
j i
Q You did dir. cuss it after March 23, 1979, after 6!
I you were trying to reconstruct what happened ourse nt to your memorandum to Karrasch; is that correct' i
A Yes.
8 i
9!
Q Do you remember anvthinc about that conversation ^
l 10 A
No, I don't remember any specific thing.
I i
remember that I hadn't seen it befor?, and ! said, " Ghee, 1;
I didn't know ycu had written this", or words to that effect.
10 i and tnen I recall getting a copy of it from him such 13 tnat I could read it.
I 14 Q
Was that a discussion with hin after you did 15 receive a copy of it and read it?
16 A
Yes, there was a discussion, but I don't believe 1-it was a technical discussion per se.
My note at that time l
was what had happened was history, and it would be nice to
- g 1
understand it' and where if there were improvements we
,g could make, we fit them into the system and make it; but as N
far as a detailed postmortem of wny this happened, that's 21 l
of academic interest.
0 Do you remember anything generally about that U
conversation?
!881 051 24 l
25
2 A
No, I truthfully can't.
Well, I rememcer i
3, generally saying tr.at, okay, inis meno responded t: :ne i
4
- menc, and I didn'c knew that it nad been Joe Kellv written, and : rank saying, yes, that he had lockad =* it
.5 i
and he had had some questions in his mind, but he didn't 6
i have time to -- pardon, I am not sure that he said he i
d didn't have time.
He did not nake a formal resocnse because S
of other things that he was doing, bu. he wanted to get i
9 some thoughts down and tnen ge: Dack to Joe.
We did not i
10 per my memory discuss the tecnnical content of it.
I
.I Q
Is it usual that Mr. Walters would rescond 13 i
directly to Mr. Kelly and not go through you?
A
.Yes.
13 i
Q Do you normally review memos that he would 14 write?
j i
1.,
A I review those memos which he considers needs 16 my attention.
I do not normally review every memo that 17 he writes, now.
is Q
What memos does he usually consider needs your attention?
,9 A
Memos on the order of the Burt Dunn memo --
20 sorry -- the memo which he wrote for me to Bruce Karrasch 21 which I signed off, things tnat we recognize being potential
~,
problems, he bring those to ny attention and we discuss'.
23 1
Q What do you mean that he would consider to be 24 l881 052
e 1
E ?E f97DEd PE907D' )N D
JY bidbdJ 2
a potential OrcDien?
acuid requ ; re act"cn un2erneath tne A
Where it 3
I secticns charter, wnich is ? rov
."'".g lr# 3rnatfon to the 4 I t
custcmer on test programs and aisc on certain parts of operation.
It is a judgment thing where if there are s
- around such tnat deal with admini stra ti ve memos ficatinc 1
I 7l-allocations or internal things such that he :a<es care of l
e it and I don't get involved.
Whenever he takes a position
~
i 9l that we take di f ferently f rom pa st positiens, then I get 10 involved.
Q So in his judcment his November 10, 1977, memorandum would not be a problem area tnat he would need 12 l I
to pass by you?
l 13l A
I don't know what Frank was tninking at the 14 time.
I i
15 THE WITNESS: Can we go off the record a minute?
1 16 (Discussion off the record.)
l t
17 BY MS. GOLDFRANK:
tg Q
I would like you to now look at a February 9, 1973, memorandum from Burt Dunn to Jim Taylor that has gg been marked as Womack Deposition Exhibit 23.
20 A
Yes, I have looked at it.
21 Q
Did you ever receive a copy of :nis memorandum?
-M A
I don't believe I received a copy, but I do believe that I saw it.
i 2, I i881 053 i
i 25 t
I I
1
.s Tf 2,
Q Do you knew how jou came ::
JI et
-o A
! don ' t recollect clearly.
3 l
i Q
Do you know when you did see a copy of tnis l
menorandum' i
5, l
A.
I believe it was late February or early " arch 6
j of 1978.
i Q
Do you recall the circumstances under which 8
you came into contact with this memorandum?
I I
9 A
No.
I remember oeing shown it by someone.
I to soreone within Services, but I can't remembe r who that was.
i I
Q Do you remember discussing the.ubstance of 33 this memorandum with anybody?
A I do not remember discussing tr.e technical 13 I
substance.
I remember the last paracraph which said sone-i 14 '
thing should be done and agreeing that it should be looked I5 i
into, so identified it as a serious concern.
l Ib Q
What were your actions as a result o f n o t i n c, 17 that it was of serious concern and act:cn should be taken?
18 A
P r my recollection I believe I had a conversa-tion with Frank Walters who said, yes, we snould follow up g
on.this and determine what actions we snould take.
-Q Were you assigning to him the task of determin-21l t
ing what actions you should take?
- I
~~j A
Yes, what actions plant performance should U
take.
- i 1881 054 I
l0 l] ~
0 tD f9 ')fh t
f u o JJ
'i t
i n
A 3*
Q Was tnere a mercrancur incicatin to "r.
- ', ' Walters tnat it nas his res::nsib;iit. to d2: ermine -hat a,c. t i,o n s p l a n t pe r f o rma n c e snould take?
i i
i A
l10.
j 3!
I l
Q It was just an oral conversation?
f o
A Yes.
- 'I Q
Would you have taken notes of that conversation o
with "r.
Walters?
9i A
I doubt it.
They may be in there but I don't i
I I
to !
r_e. call.taking any notes.
t Q
If you had taken notes, they would be your g
A In my daily book, more or less, yes.
l 1:
.Q Did Mr. Walters discuss with you percisely wh_at,his responsibilities were witt respect to thi:
14
, a,s s i o n.y e n t ?
15 A
I don't recall any formal discussion.
Frank was responsible for l
16 sight instructions or procedure
,,t -
, revisions that would go out to the operating clants.
13
.Q Did you discuss this memorandum nith anybody i
else on vour staff?
19
~
t A
That I don't recall.
I to l
- Q I would like you to lock at a February 16, 1973, ti
_mem_ ora _ndum from Burt Dunn to Jim Taylor that has been marked g-
,as.Dunn Deposition Exhibit 36.
"l Did you receive a cooy of this memorandum?
f' 24 ;
2s!'
f8u*I 0
1C Lsb" t
i
1 35 A
Not fec my recollect;cn, b
Q Have jeu seen it before :::3y?
d i
I A
Yes.
l 4 :
i l
Q Could you tell me when you saa it?
- i
-)
l j
A Approximately a month after Marcn 25th, j
6 i
approximately the same time period I saw the previous 8
I Frank Walters' memc.
l 8
Q And tnat was the first time that you had seen 9
this February 15 memorandum?
i A
This memorandum, yes, to my recollection.
10 Q
Had anyone discussed the subject matter contained in this memoraldum with you prior to you seeing the 12 memorandum' MR. GALLEN: Could we go off the record for a 9
14 second?
i 15 (Discussion off the record.)
l 16 '
MR. GALLEN: Mr. Hallman would just like to I
i gi clarify nis 'ast answer.
I 1_
THE WIT"ESS: I previously stated that I had
,5 not seen a copy of this remu after " arch 23 of tnis year.
19 I hid seen it before then.
I didn't recall it because it
.m was a.part of my letter of August the 3rd to Bruce 7,arrasch.,
1 one of the references, so I did not recall any technical
-n discussions on this letter, and I still do not really recall 3
seeing it before a conth af ter Ma rch 23 of thi s year, but
~4;l i881 056 a
- s; 1
Ii I
36 1 i 2
obviously I did and just dicr't recall i: D 9
i y y r^^""
?
3 1
Q You previously indicated that you did noc draft i
l 4
I I
the meno that went from you to Mr. Ka rra s c h, the August 3,
l 5
i 1978 memorandum?
i 6
i A
That's correct, i
Q Sut you did attach to that memorandum che I
8 February 9 and February 16 memoranda of Burt Dunn?
I 9:
A Yes.
[
to Q
But you did not review the substance
,f either of those memoranda?
g1 A
No, I did not review the substance of this 10 j
memorandum.
I don't recall if I reviewed the substance i
13 of the original memo ra n d um o r r.o t.
I was aware of the 14 original Burt Dunn memorandum, although I was not aware of this memorandum until later.
16 Q
Did Mr. Walters in goinc over his draft meno 1-from you to Mr. Kcrrasch discuss with you the content of I
I the February 16 memorandum?
g A
Possibly.
I just don't recall.
I recall the
!9 I
discussion as being Surt's recommendations deserve attention <,
20 however, there are some cuestions that we have concernina 21 consequences if those recommendations are carried out in i
- non-LOCA situation, so we should request.that Intecration i
U review and resolve these concerns, but I do not recall 1881 057-u.
25 '
l i
f.
L c
specifically gcing thrcugh this F e b r u a r:, 15 meno and saying
)
Onat tnis is the exa:t ccncern that we are addressing, i
f f
0 Did ycu go thrcugn the r ecruary 9 memo at that 4
,i time?
I 1
i l
f A
I believe we did.
6 l
Q Did you go through the substance of the February
'(
9 memo?
l 8l A
I don't recall how deeply we Nent into the 9
substance but I believe we went into the substance.
10 Q
Do you recall at all specifically what you did l
talk about?
ti i
A We talked about that.
I don't recall l
12 specifically.
In general I believe we talked about, yes, 13 for a loca Burt's recommendations are good', but what if
~
(
14 there is an operator error and these actions are taken i n is a non-loca situation, what are the consecuences, and we i
i 16 l f e l t that the ccnsecuences should be evaluated prior to 17 changing the instructions.
13 0
And this conversation was taking place when Mr. Walters had already dra f ted your August 3, 1973 memo?
,9 A
Yes.
to i
.Q And he made the decisicn that there was concern 21 and that Plant Integration should be brought in to answer ttl specific questiens?
I
^3 A
Yes, he made it, and I concur:ed with it.
2' 1881 03 8 i
- sl t
b i
3 u eeuu uguu_d_Jtuu_,
,8 a
I consicered :ne resconsicility mine, even
- hough he had i
,,. r e-2n
-n a,
'i l
i Q
And those concerns are the type that would be t
reviewec by you and be sent under your signature as opposed i
4 5
to going directly fecn Mr.
a l t e rs ?
1 l
A Yes.
It is not necessary that those go out
'under my signature per se.
It is necessary that I review i
l that type before they go ou' l
l l
9l Q
Cculd you explain why this particular memo toI did go out under your signature?
l Ul A
Yes.
We felt that with my signature it was l
more likely to attract attention and get action than with 12 i i
i Frank's signa:ure.
13 i
Q You were the particular individual that 14 l pursued or followed up Mr. Karrasch's response to this memo J
and not Mr. Walters; correct?
16 A
Yes, but with a clarifier.
Mr. Walters reminded i
I 17 me to check with Karrasch to follow up.
So Walters did i
initiate action to try to reach a resolution on the August is 3rd memo.
9 5
Q Do you know how soon af ter August 3, 1973, Mr.
20 i
Walters contacted ycu as to getting a response from Mr.
l 21 Karrasch?
A I don't know per my recollection.
It was no U
longer than two months, and it could have been ea rl i e r.
24 l 188i 059 i
a i
i
M O Idl O fD)[l @ [lhI h j OGUB Guullouuu \\Juta 1
3c 2
Q And now soon a ' t e r t'. r., alters ccntacted you I
3 did you get in touch witn Mr.
- a rra s c h ?
i i
l A
That I don't recall.
I atteneted to get in 4
l tcucn witn Mr. Karrasch witnin a day or two.
I don't 5,
i recall if I made ccntact the first attempt or if it took 6
i several atten s to do it.
My recollection is that it took i
1 "I
j i
several attempts.
l E
Q And you don't renember the exact date or the I
9 time frame wnen you made tnat initial ccntact?
to A
That is correct, per my recollection is was on i
the order of two months.
33 Q
Two months from August 3?
l A
Yes.
13 Q
Meaning sometime in October or !;ovenber?
14 l
A Yes.
i 15 Q
Was anybody else on your staff concerned with 16 or directly concerned with follow-up of this particular 17 nemorandum?
i e
1 33 A
Per my conversations with Frank Walters since f
Marcn the 28th, I believe that he nad nad someone else on g
the staff review it.
I was not aware of that durino m
- the August 3rd time frame.
21 I
Q Do you know wno what individual was?
{
l T.
A Per Frank's comments it was Cal Goslow.
23 Q
Do you know if he had any contact with Mr..
l f
i881 06(1 v-I L
4D 2
Karrascn?
l
.1 A
I don't know.
}
Q Do you kncw i'he had any ccntact with anybody 4
i I
I that worked for Mr. Karrasch?
i a :
I
?
A I don't know.
l I
6 l
{
Q Does Mr. Goslow report to ycu or report to Mr.
i
~l l
Walters?
i I
S A
At that time I believe he reported to Mr.
l l
9 Walters.
He did not report directly to me.
i I
w Q
Do you feel at this point that I have a comolete i
11 picture of the memorandum that arose out of Burt Dunn's i
February 16 and February 9 memoranda?
l 13 A
Is this the package you have here that you are 13 referring to?
i 14 Q
The five memoranda that we have introduced here I
15 and that you have discussed with, which would be 'elly's 16
'lal te r's memorandum to Kelly November 1,
1977, memorandun; 17 dated t!ovember 10, 1977 --
18 A
The handwritten memorandun.
Burt Dunn's February 9, 1973, memorandum;
- 9 Q
i Burt Dunn's February 16, 1973, memorancum; and your y
i memorandum dated August 3, 1973, to Mr. Karrasch.
21 A
Yes, I believe that's all.
22 l
Q Have you preoared any memoranda concerning B
the issues or the accident at Three Mile Island on
a r c h 2;
i881.061 2s i 1
I i
2 23, 1979?
i A
Could you rephrase the questicn?
My " T.e n o r a n d a "
3, t
what do you include?
l 4 '
MS. GOLDFRANK: We can go o ff the record.
l 5
(Discussion off the record.)
i 6
ANSWER: I have prepared memoranda dealing with l
instructions to our operating plants concerning those
~
f events.
I have not to my recollection prepared any internal 3
i 9
memoranda addressing it, to Q
The memoranda would have been addressed to B&W Customers?
11 i
A Yes.
My memoranda would have been addressed 12 to our service managers for transmittal t o-the SaW cu stomers.
13 MR. GALLEN: We will assure you that you have 14 copies of all those memoranda.
i l
BY MR. GOLDFRANK' i
Ml Q
What in particular was your role since March l
l 17 28, 1979, with respect to the accident at TMI2?
i A
I was on shift for two or three weeks during l
ig i
the recovery trying to help it die down.
I was then in g
mode of formulating instructions to clarify to the operators 20 actions that they should take during loca.
l 21 I have been involved in many neetings, formal l
and informal, about how is the best way to handle the 23l situation based on what we have learned at Three MiJ e 2.
i 2'l 1881 062 z,,
I I
9 3
~ $ ~ }Y R._a D
s ovb MdU j.
1 l 42 2
I have also been involved witn discussions looking at the data frca Tncee "ile 2 and figuring cut 3
I how exactly did it happen, what was the sequence of events, i
4 l f
Q You say jou were involved in recovery; were 5l l
you on site at Three Mile Island?
l 6
I A-No, I was not.
I was in our Control Center, l
7 or whatever, here, 3
Q In Lynchburg?
9 A
Yes, in Lynchburg.
l tol Q
What would your speci fic responsibilities i
have been?
13 t
A I was in charce of communications between the 12 site and the S&W tecnnical people at Lynchburg to past data 13 i
and recommendations along both ways.
14
!!S. GOLDFRANK: At this time I don't have any 13 further questions.
I would just like to say that we would 16 recess this ceposition, and in thinking that at such l
f i
{
17 future time we might want to call you back_to ask you further-questions, and would reschedule it at a future date.
l 33 THE WITNESS: Okay.
g MR. GALLEN: I have a few questions I would just 20 like to clarify.
21 l
BY MR. GALLEN:
i
?
I Q
At the time the August 2rd meno went out, did I
%I you feel that pending resolution of the operator to should 24 l i
i i88i 063
-s; i
i
i
~
m m.m
-_-m.
.-m l
43 be questions raisec in that meno, that adherence to 3 l existing operating speci fications would preciace cre ature termination of '4oI?
i i
4 r
i i
A Yes, I did.
l
.5 i Q
More speci fically, was it your understanding 6
about the existing specifications cautioned against termination of HPI i f the R C S ' s p r e's s'u r e d e c r e a s s d below I
8 the HPI actuaticn point?
l 9
A Yes, that was my feeling.
(
to Q
So it was your understanding that the prescrip-l i
~
tion containec in the Burt Dunn memos was designed to 11 1
i provide a further clarification or elaboration of existing i
12 operating procedures?
13 l
A Yes.
14 MR. GALLEN. That's 'all I have.
I0 MS. G0LOFRANK: Okay.
I would like to receat
(
16 that this deposition is recessed.
1 (Witness excused.)
f (Whereupon the examination recessed at 12:15 g
P.M.)
l i
19 i
,i w
I i
l 21 1
22 l
l 23 i881 064 u
i I
f
1 1
,1 j
2l l
3' CERTIFICATE OF RE.:0RTER i
4 1, Norma Nasuti Costello, Certified Court Reporter, i
do hereby certify that : reported the tes timony of the witness {
5 u
l herein, in stenotypy, and that the testimony was reduced to 6
typewritten form pursuant to my direction.
7 I further certify that the testimony hereir, con-8 stitutes an accurate record of the proceedincs had.
9 to Norma Nasuti Costello 11 1.,
13 14 pgg Mkh t^
1e l
17 IS l
19 21 I
r 23 I
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I t4 i881 065 l
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