ML19290A021
| ML19290A021 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/07/1979 |
| From: | Goldfrank J, Seelinger J METROPOLITAN EDISON CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908280841 | |
| Download: ML19290A021 (82) | |
Text
154
x PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
.______________________________________________x CONTINUED DEPOSITION of METROPOLITA!1 EDISON COMPANY by JAMES L.
SEELINGER, held at Three Mile Island Nuclear Generation Station, llarrisburg, P e nn s yl va rsia, on the 7th day of August 1979,-
l commencing at 8:50 a.m.,
before Robert Zerkin i
l and Stanley Rudbarg, Notaries Public of the State s
of New York.
C
j gg95 228 l
I
~
I AEN.J ANIIN REl'ORTING SERVICE CERTIFIED SilORTilAND REPORTERS l'IV1: IIIII: lim AN STItI:I&
Nr:w voit:(, st:w voien 10038
[212] 374-1138 7908280ff[.)
1 155 2
A P P E A R A N C E S :
3 METROPOLITAN EDISON COMPANY:
4 SII A W, PITTMAN, POTTS & TROWBRIDGE, ESQS.
(
Attorneys for Metropolitan Edison Company 1800 M Street, N.W.
Washington, D.C.
20036 6
BY:
ALAN R.
YUSPEll, ESQ.
7 of Counsel O
PRESIDENT'S COMMISSION ON T !! R E E MILE ISLAND:
9 JOAN GOLDFRANK, ESQ.
Associate Chiet Counsel 10 11 ALSO PRESENT:
t 12 RONALD EYTCIIISON 13 14 000 15 16 J A M E S L.
S E E L I N G E R,
17 having been previously duly sworn, resumed 18 the stand and testified further as follows:
f j
19 MS. GOLDFRANK:
We are continuing t
I 20 the deposition o f Mr. Seelinger.,
2I DIRECT EXAMINATION C
1895 '729 ee BY MS. GOLDFRANK:
'~
Q Yesterday, we were talking about the 23 24 initial drafting of procedures for TMI 2 when 25 you were in the position of Unit 2 superintendent B ENJ AMIN REPORTING SERVICE
156 I
Seelinger 2
for Technical Support, and you indicated that 3
with respect to Surveillance Procedures, certain 4
consultants from NUS and B&W were brought on-site C
5 to assist in that drafting.
~
6 Would the people from B&W that you had 7
during that time, and I believe you indicated there 8
were three people from B&W on-site, were they 9
hired under a separate contract to assist in that?
10 A
They were not part of the normal services that 11 B&W supplied, had we not asked separately for that.
I2 In terms of did we negotiate another contract, I 13 doubt tha t we negotiated a contract.
I suspect we I4 brought them in as an additional task to an already i
15 existing contract.
I don't remember which contract, 16 nor would I probably have ever known which contract.
I do know that we went out with an additional task 17 18 to bring in these people, and it was no t a service
{
19 which was anticipated years in advance and sold 1
1 20 as part of the NSSS package.
21 Q
Were these people brought in for their 22 ability to write on a technical basis or were they 23 also brought in for the engineering expertise, 18 5 230 24 their knowledge in the field?
A They were brought in because of one, their 25 BENJAMIN R EPO RTING S ERVICE
1 Seelinger 157 2
availability; two, their ability; three, their 3
past experience.
Prior to any of these people 4
coming in, we were allowed to look at their resumes 5
and make a decision if we thought these individuals 6
would be helpful to us in our particular set of
~
7 circumstances.
8 Our judgment on the people that we 9
brought in was that their past experience would 10 lend themselves well to the effort that we had 11 in front of us-and we brought them in, the speci-12 fic people, based on that and their availability 13 to be brought in.
14 Q
What in their past experience were you 15 looking at?
16 A
More than anything else, past site participa-1 tion in startup efforts and past site participation IO in Operation and Maintenance of a nuclear unit.
i k
19 In general, the individuals that were brought in 20 had that type of experience.
21 Q
So that they were not relied on bec.ause 22 they were technical writers, but they were relied i
23 on also because of their experience and knowledge?
24 A
Absolutely.
None of these people would I 25 judge to be in the category of technical writers.
BENJAMIN REPORTING S ERVICE
~ ~ ~
1895 231
1 Seelinger 158 2
All had past nuclear experience at various plants.
3 Q
You indicated yesterday that to assist 4
you in writing the initial procedures for Unit 2 C.
5 you had a staff of engineers under you that reported 6
to you and assiated you in that task.
You indicated 7
there were two nuclear engineers, two or three 8
electrical engineers, three Mechanical engineers, 9
two I&C engineers, and then two additional Operations 10 engineers that did not report to you, but that as-11 sisted you in that task, is that correct?
12 A
That is correct.
There was one that I fo rgo t 13 to mention yesterday, a computer engineer.
14 Q
And he would have reported to you?
I 15 A
He reported to me, yes.
t 16 Q
were all these people working full time 17 on drafting the procedures for Unit 27 18 A
At various phases of the startup it comprised i
l 19 the greater percentage of their time. There were 20 other projects and items that they worked on, 21 including problem solutions as maintenance or 22 technical problems developed in the plant, which 23 would occasionally divert their effort from the 24 3,rocedures.
However, during the first year and 25 a half that I was associated with Unit 2,
1895 232 B ENJAMIN REPORTING SERVICE
159 I
Seelinger 2
during which the procedure effort was the biggest 3
effort -- I will star t that again.
4 During the year 1977, in which the 5
procedure effort was the biggest effort, I would 6
say that 75 percent of the time of these indivi-
~
7 duals was devoted to procedure preparation review 8
and approval and 25 percent was devoted to other 9
tasks.
10 During the year 1978, the ratio would 11 have been 25 to 35 percent procedures, 65 percent 12 to 75 percent o th e r tasks, in that the procedures were largely completed in their initial efforts, 13
}
14 andvwhat remained to be done was the ongoing review l
15 and change of the procedures as the pracedures were used and needed revision.
16 17 o
ouring 1977 when a large part of their 18 time was spent in the drafting of procedures, 19 there were approximately 12 people that were working i
on it.
Were these not enough bodies to perform that l
20 21 task?
22 A
Let me go back and say, I just remembered one more body. I had another mechanical engineer who 23 was working on something called the ISI Procedures, 24 25 and then to answer your question, these. people BENJAMIN REPORTING SERVICE
1 Seelinger 160 2
would not have been sufficient in themselves to 3
write all of the procedures during the time al. lotted 4
because of he changes in the standard specifications 5
which I have mentioned previously in this depo-6 sition.
~
7 Q
Because of the standard tech specs, it 8
was a much bigger job than was involved for draft-9 ing procedures for Unit 17 10 A
Yes, and a much bigger job because of the 11 continuously changing specifications whcih required 12 continuously changing the procedures.
13 The technical specifications during the 14 years 1977 and 1978, particularly 1977, underwent 15 a great deal of change and as the change then 16 went back and forth between Metropolitan Edison II and the NRC, the procedures required change to 18 accommodate the technical specifications.
Additional 19 technical specification requirements levied by the 1
20 l
Nac required new procedures.
21 Instead of being able to use Unit l's 22 procedures as a base line and change those procedures 23 to accommodate the Unit 2 procedures, those
~
4 procedures had to be written from scratch and 25 this caused a great deal more effort to BENJAMIN REPORTING S ERVICE
1 Seelinger 161 2
have to take place, so the effort was larger than 3
would have been anticipated in the year, say, 4
1974-75.
5 g
with respect to your position as a 6
Unit 2 superintendent for technical support, how were engineering questions that were raised
>n 7
8 the backshift handled?
9 A
If an engineering question was raised on
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10 the backshift th a t required immediate resolution to proceed, I was typically called, and if I 11 I2 couldn't answer the question I would call out an t
13 engineer to go help in the field to resolve the 14 question.
If the question involved one of compliance with the technical specifications, the shift 15 16 supervisor and I would call him on the phone; if i
i 17 necessary we would get the PORC involved if we highly questionable and we could not 18 felt it was answer the question and we ensured by our reading 19 20 of the technical specifications versus the situation f
we were complying with those 21 in the plant that i
22 technical specifications.
Many times an engineering 23 question that would be uncovered on the backshift 24 and needing an answer did not impede the progress of the Startup and Test Program.
It was such that 25 B ENJ AMIN REPORTING SERVICE
1 Seelinger 162 2
the answer to that question would end up going through 3
a field questionnaire or problem report through the 4
GPU system to Burns & Roe, 5
The Startup and Test engineer who
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6 was a GPU employee, would write tha t document, 7
include on his Startup and Test Procedure an exception 8
or defficiency to a part of the test because of 9
that particular condition.and request resolution 10 from the cognizant engineering agency, being 11 Burns & Roe or B&W.
The test could then proceed I2 but the exception or deficiency would have to be i
13 la ter on resolved or cleared in order for the 14 completion of the test and test results to be l
15 satisfactory.
16 Q
In Surveillance tests today, are 17 similar exceptions or deficiencies logged, if 18 found?
19 A
Yes, although the exceptions and the defic-20 ioncies one would find on the Surveillance Tests 21 wo ul. ' be far. fewer in number than one would expect to find on a Startup Test because the system had 22 23 been in operation and one would expect it to 24 operate in a very normal kind of fashion.
25 A typical exception could result from a plant BENJAMIN REPORTING SERVICE
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1 Seelinger 163 2
condition that would not allow placing the plant 3
in a position to conduct the test.
A deficiency 4
typically means that a component system did not 5
perform as required.
we either raise an exception 6
or a Deficiency Sheet is written out against the 7
Surveillance Procedure, then that Exception and 0
De ficiency Sheet is the result.
9 Q
where would that Exception and Deficiency 10 Sheet be sent?
II A
That accompanies the Surveillance Test results 12 to the Surveillance coordinator and I believe remains-13 in his file until resolution.
I4 Q
Does he assign it out to make sure that it is resolved?
16 A
The deficiencies are logged in either the j
17 control room operator's log or the shift foreman's l
IO log or both, and the deficiency to a surveillance i
19 l
Procedure then must be resolved to declare the t
l 20 system operable, or must be resolved to assure 21 the system -- that is resolved to the point that the system is still considered operable by an 23 engineering judgment.
The Exception a id Deficiency 1895 237 Sheet -- let me back up.
5 If I am not mistaken, and I don't remember BENJAMIN REPORTING S ERVICE
1 Seelinger 164 2
the entire mechanics used by the Surveillance 3
coordinator, but I believe, to call the surveillance 4
complete that the Exception and Deficiency Sheet must 5
be resolved prior to that going on the computer 6
forms that shows that the Surveillance Procedure is 7
complete and signed off.
O A system was set up in Unit 2 whereby 9
the shift supervisor would look at Exception and 10 Deficiency Sheets and make a decision whether those 11 Exception or Deficiency Sheets constituted anything 12 that was reportable, and he would make that initial i
13 determination.
I 14 Questionable ones or ones.that were 15 at all cloudy even after the shift supervisor 16 had made his determination were then consequently 17 forwarded to the PORC chairman.
18 Q
So that the shift supervisor would make 19 the judgement as to whether or not a deficiency 90 was reportable or not?
21 He would make an initial determination.
!!is A
22 c v. termination.
initial determination was not the final i
His initial determination, in case of nut reportable, 23 24 probably would have been more accurate than his 25 of reportabD 238 initial determination in the case 18 BENJAMIN R EPO RTING SERVICE
1 Seelinger 165 2
In other words, if he thought it was reportable, 3
he would submit it to the PORC and the PORC would 4
review it for those that were reportable.
C 5
t If he thought it was not r e po r '_ a b l e, and 6
it was questionable, the Surveillance coordinator 7
would then forward it to the PORC chairman, and 8
I would then take a look at that sheet and also 9
make some-determination on it.
10 when I got the sheets, if I thought 11 they were at all questionable, I would forward 12 them to my lead engineers and let them write i
13 up a resolution as to why the situation was or 14 was not acceptable, 15 Q
with regard to the shift supervisor's 16 initial determination that something was not I
17 reportable, would he consult anybody in making 18 that decision?
19 A
If he had any question, yes, he would have 20 consulted me.
21 Q
If there wasn't any question on his 22 part he would not consult you?
23 A
That is correct.
Q So that the Technical superintendent 25 would not automatically be brought into the process?
BCNJAMIN REPORTING SERVICE jQg 7
1 Seelinger 166 2 A Not on all exceptions and deficiencies, no, 3 but on any that the shift supervisor had any question 4 on, I would get called, and I got called frequently. 5 It was not unusual to get called five times a 6 week on such items.at various times of the day and 7 night. 8 Q When you are not on-site, are you j 9 required to let the plant know where you are? 10 A In general, yes. As you may have noticed, 11 I have a beeper on that in the immediate; area is 12 able to get me when I am not at home. We have 13 a duty roster, have had a duty roster fo r -- I 14 don't remember the date -- w ell back into 1977, I 15 would judge, and we had a duty roster prior to 16 that time as well, although I was intimately in-17 volved in setting up the duty roster tha t we had 18 in 1977, and from there on, and we varied between 19 we started with a two-section duty and eventually 20 got that to a three-section duty where one super-21 intendent would have the duty weekend and he would 22 be responsible for the plant during that period. 23 And he not only had the duty weekend, but had ~ 24 '~ a duty week. It was more applicable on the' weekend 25 than it was on the week from a practical standpoint, 1895 240 BENJAMIN R EPO RTING SERVICE
1 Seelinger 167 2 Licause he usually ended up spending some or a 3 good share of his weekend at the plant. When a 4 person goes on vacation, he could be camping out C 5 in the woods and-be inaccessible, but in such ~ 6 cases someone is designated in his place who is 7 higher or lower in the organization to either sign 8 to be available to the control room to solve the 9 kinds of problems that he could solve. 10 g flow far can you be reached on your 11 beeper? 12 A My beeper can reach me at home, and east of 13 my home I think it probably goes for about five 14 miles, west of my home it goes west o f IIarrisburg 15 somewhere, but I never go west o f Itarrisburg, so 16 I don't know how far it goes; it goes south of 17 liarrisburg at least as far as Dillsburg, and I 18 virtually never go there either. 19 When I have the duty w.eekends and have 20 my beeper on, what I do is I conduct all my business 21 or try to conduct as much business as possible 22 between my home and west toward Harrisburg, so I 23 am always in beeper range. If for some reason I would have to go out of beeper range, I would 25 leave a number with the control room where I could be B ENJAMI N' REPORTING S ERVICE 2 i 1895 241 ~
I I Seelinger 168 2 reached. 3 Q How far is your home from here? 4 A Eight or ten miles. C 5 Q Other than if it was your duty weekend, 6 would you still notify the control room as to your 7 whereabouts? 8 A I usually wear my beeper whether I have the 9 duty or not, and I did that as the Technical 10 Support superintendent in Unit 2 and do that as i 11 Unit 1 superintendent. i 12 I would say that in mest cases the control 13 room is able to get me. 14 Q So that you usually leave a number where 15 you can be reached even though it is not your 16 weekend? 17 A Yes, I usually do.that. On a non-duty-type 18 _eekend, I might play golf on Saturday afternoon w l 19 in Lancaster, which is out of beeper range, and' l l 20 there aren't any phones on the third green, so that 21 kind of situation has a potential for arising, 29 but on a duty weekend I play golf in beeper range. 23 As an example, last Saturday I got beeped 24 after I hit my tee shot on the eighth hole. 25 Q How are assignments made to a. shift of BENJAMIN R EPO R,TI N G SERVICE - 1895 242~
I Seelinger 169 2 licensed personnel? 3 A They are based on the available licenses 4 and the personalities involved, and the respective 5 strengths of the' individual. Any shift will cer-6 tainly reflect the personality of the people on 7 that shift, and we make an e f fo rt. in knowing the O people to try to combine a shift supervisor and 9 shift foreman that we think will work well together, 10 that we think compliment each other in terms of 11 strengths in respective areas, and we try to assign 12 control room operators to that shift and auxiliary 13 operators to that shift where possible we think I4 would blend together to make;that shift as 3 15 workable as possible. 16 Q Who makes'the assignments? 17 A For the most part the assignments have been IO made by my supervisor of Operations, Mike Ross, on Unit 1. On Unit 2, Jim Floyd, the supervisor 90 of Operations made those assignments and the shift 21 supervisors prior to the accident were assigned 22 concurrent duties in both units. 23 Mike Ross was also involved in that ~ 24 assignment of the shift supervisors, so Floyd 25 and Ross worked together with respect to t h'e BENJAMIN REPORTING S ERVICE ~ 1895 243 ~ ~
1 Seelinger 170 2 shift supervisors, and then Floyd for Unit 2 and 3 Ross for Unit 1. 4 Q Concerning the assignment of shift 5 foremen and control room operators, how do you 6 communicate with people at Unit I? 7 A That is a pretty broad question. can you 8 narrow it down at all? 9 g specifically, do you have any type 10 of formal written communication? 11 A Yes. Maybe it would be better if I answered 12 the broad question. i 13 In unit 1, three times a week we have 14 a Plan-of-the-Day Meeting in which we discuss 15 surveillance for the week, any operations or tests I 16 planned, our chemistry conditions, any technical l 17 specification items that we have that need resolu-18 tion, and the ongoing maintenance tha t is planned 19 j for that day and subsequently throughout the week. l 20 That meeting typically lasts an hour on Mondays, i 21 Wednesdays and FriCays. 22 I interface with my supervisor of 23 operations in verbal fashion when I come in in 24 the morning to find out plant conditions and_any 25 items that he has from the night before that may. BENJAMIN REPORTING SERVI
1 Seelinger 171 2 have come up that I need to know about and inter-3 face with him throughout the remainder of the day as 4 it may-come up that I want him to handle with 5 his shift personnel. I interface with him in a 6 writing to confirm some of those items, but not all,; 7 and I interface with him and I put some of those 8 items, depending on the significance of those items, 9 in a tickler system for it to cone out.to tickle 10 my mind that in fact I wanted to make sure that i 11 follow-up action has been taken. I interface with 12 my Technical Support superintendent in like fashion 13 typically once or twice per day on technical items [ 14 and on maintenance planning and project planning 15 kinds of items that I want to make sure on track. 16 Those items could be items that are the result of l7 NRC bulletins or circulars, items that are large 0 maintenance items that require engineering input, 19 responses to NRC concerns and inspection reports, / 20 and so forth. 5 I interface with the maintenance people 2*9 in like fashion at the POD, and probably one other 93 time per day with respect to maintenance problems ~ or priorities, perhaps more in terms of priorities 25 than any other item, to insure that the priorities, BENJAMIN REPORTING S ERVICE 189524i5
1 Seelinger 172 2 those that the operations people are calling as 3 priorities, are on the top of Maintenance's lirt 4 as priorities, r (, ' 5 The gentleman that reports to me as ~ 6 the unit 1 supervisor of Maintenance is currently 7 functioning and has been since the accident in 8 the Startup and Test Group, so conseugently I have 9 been interfacing with the Maintenance superintendent, 10 Dan Shovlin and interfacing with his shift Maintenance i 11 supervisor since the accident, as opposed to the 12 gentleman that prior to the accident reported 13 directly to me, which was the Unit 1 supervisor 14 of Maintenance. 15 now, in terms of written communications, 16 I mentioned the written communication between myself I 17 and the supervisor of Operations. I would say that 18 I have probably more written communication with the 19 Technical Support superintendent in terms of 20 tasking him on specific items and specific follow-up, 21 again using the tickler system when I consider it 22 necessary and probably less formal written com-23 munication with the Maintenance superintendent, 24 but.there is some with the Maintenance superintendent. 25 g Do you issue standing orders? B ENJAMIN R EPO RTIN G S ERVICE 1895 246~
1 scelinger 173 2 A I do not. My supervisor o f Ope r a tio:ss does. 3 o Do you issue operating memoranda? 4 A There are superintendent's operating memc-C 5 randums; there are station superintendent's operating 6 memorandums and there are Unit 2 superintendent's 7 operating memorandums, and I don't know if there 0 are Unit 1 superintendent's operating memorandums. 9 Some of the station superintendent's operating 10 memo randums I have written and Gary Miller has I 11 signed; some of the Unit 2 superintendent's operating 12 memorandums I wrote and Gary Miller signed. I have 13 not had occasion to do so since being in Unit 1. I4 In terms of such communications we 15 have handled those items by supervisor of Operations' 16 memos and memorandums to the Operations Department, 17 because that is where that kind o f action has 18 typically fallen. I We also have, at the NRC's urging back s 20 in 1974-75, eliminated all such memorandums for a period of time because it was the NRC's contention 29 that these items fell better into a procedi:re and ~ 23 required the formality of the procedure review ~ 24 process which could be bypassed if a memorandum 25 were used. We went into a program to eliminate BENJAMIN REPORTING SERVICE t 1895 247
1 Seelinger 174 2 such things, and then somewhere in the 1976-77 3 timeframe, the NRC, a different inspector from 4 the NRC asked to see our operating memorandums, (? 5 which we then did not have, and so we again ~ 6 looked at a program with operating memorandums. 7 It appeared to be somewhat a function of the in-8 dividual inspector as much as what was contained 9 in the operating memorandums versus procedures. 10 Q Was the NRC discussion with respect 11 to operating memorandum during 1974-75, the result 12 of an NRC inspection? 13 A I don't know. 14 Q Do you remember if you were involved? 15 A I was not. 16 Q Were you involved with the different 17 inspector from the NRC concerning the discussion 18 of operating memoranda during 1976-77? 19 A I think I was peripherally involved, but I i 20 don't remember direct involvement during that l 21 timeframe. 22 Q Do you know if this resulted in what 23 was included in an I&E report? 24 A I do not. 25 Q What is contained in the Operations BENJAMIN REPORTING S ERVICE 1895 248
I seelinger 175 2 Department Memo Book? 3 A I have not read it recently, so I don't know. 4 Q What would be contained in that? 5 A A typical. memorandum was one that I saw i ~~ 6 recently that was issued to give guidance on how 7 to use the new NRC phones that have been installed as 8 a result of the TMI 2 accident. O ir idea with that 9 was to provide some interim guidance for the operators 10 until such time as we formally proceduralized the 11 use of those phones. 12 I directed my supervisor of operations 13 to put out an operating memorandum to discuss the I4 use of those. phones. 15 Operating memorandums typically cover 16 administrative things in nature as opposed to I7 l items which involve the direct operation or main-I 18 i tenance of the plant, and at best would only at 19 times tend to amplify the conduct o f business, 20 but would not direct the operation and maintenance of the plant, and " amplify" is the wrong word; 2~9 "cla ri f y migh t be a better word. 23 Q so the operating Department Memo Book ~ would containtmemos from the supervisor of Operations? 2s 1895 249 ^ B ENJ AMIN R EPO RTIN G SERVICE
I Seelinger 176 2 Q And these would be basically on ad-t 3 ministrative questions or issues? 4 A In a generic sense that is true. 5 g what' logs do you review as unit 1 6 superintendent? 7 A I don't have to review any logs as Unit 1 0 superintendent. 9 (continued on the next page.) 10 11 12 13 14 15 [ 16 17 18 19 20 21 L 22 23 24 1895 25~0 25 BENJAMIN R EF13 RTING SERVICE
177) 2/1 1 Seelinger 2 O Did you review any logs while you were 3 Unit 2 superintendent for Technical Support? 4 A I performed a review of the shif t foreman's ( 5 log on a semi-regular basis as Unit 2 superintendent 6 for Technical Support. I did this not because it was I administratively required, but I did this to monitor ~ 8 what I will call the left-hand side of the log. We 9 required the shift supervisor and/or shift foreman 10 to log, in the lef t-hand side of his log, entries as 11 to action statements of the technical specifications. i 12 I will explain'that. The te.chnical specification is 13 a statement that requires operability of certain t l 14 components or systems. Should such a component or t 15 system become degraded, the component or system could 16 then, by technical specification, be operated for a period of time during which it was being repaired i 18 l prior to taking further action with the plant. If 19 the repair were not accomplished in that time frame, 20 then a typical technical specification might require 91 putting the plant in a hot shut-down condition to be 2'9 followed by a cold shut-down condition. Those were 23 some of the more severe action statements; some are ~ ~ lesser in severity and require other items to.be 25 accomplished in lieu of having a particular piece of B ENJAMIN R EPO RTIN G S ERVICE } }}
178 2 1 Seelinger 2 equipment operable. When the plant faced a technical 3 specification that required or that ended up being in 4 a degraded mode, so to speak, in an action statement (~' 5 we required the shift supervisor on the left-hand side ~ 6 of his log to log in that he was in that particular 7 action statement. Then when he cleared that particular 8 condition he would log out of that condition on the 9 left-hand side of his log. i 10 on a regular basis I had the PORC secretary 11 Xerox for me the shift foreman's log so I could monitor l 12 how this was being conducted and how this practice was 13 working to insure, one, that it was working to my 14 satisfaction and, two, that we were seeing some degree 15 of uniformity across 'the shifts in their interpretation l 16 of the technical specifications. f 17 Q In your position as Unit 2 superintendent 18 for Technical Support, I believe you had indicated 19 yesterday you had assumed certain responsibilities i 20 for the position of Unit 2 superintendent, is that 21 correct? L 22 A Yes. 23 Q In those responsibilities had Gary Miller 24 instructed you to review any logs? 25 A No. Per our administrative program, the log 1895~252 B ENJAMIN R EPO RTING SERVICE
I 70 1 Seelinger 3 2 rev.iew is a function of the supervisor of operations, 3 and he is the person who is designated for the log 4 review function. What I did with the Unit ' logs t 5 was done on my own because I wanted to be satisfied ~ 6 that we were conducting business in what I considered 7 to be a proper fashion. 8 Q Is that set out in an administrative 9 procedure? 10 A No. 11 0 This is just a custom or a practice that has 0 12 been developed within the structure? 13 A No. I did it,and I did it because the technical 14 specifications on Unit 1 are not what are called 15 standard specifications. They are technical specifications 16 that were written before the development of the standard II technical specifications, and for each specification l 18 there is not a statement, then action statement, then action. The format is such that they are written more 20 in prose than outline form. The technical specifications 21 in Unit 2 being' standard technical specifications had the b.- statement, action statement, surveillance format, and 23 further, they tied the plant into various modes of 24 operation; that would be Modes 1 through 6, where the 25 modes were keyed to reactivity conFitions and keyed B ENJAMIN R EPO RTING S ERVICE 1895 253
80 4 1 Seelinger 2 to temperature conditions within the plant. 3 Implementing the standard technical specifications 4 was a new item for us. While our people were trained \\ 5 on the technical specifications and while -- let me 6 say that while they were trained on the standard 7 technical specifications, implementing them still was 8 something new to us as a group, and it was also some-9 thing different than was currently being done on Unit 1. 10 I consequently wanted to assure myself that we were I 11 doing it properly so that I did that above and beyond I 12 any administrative requirements. 13 Q Is there an administrative procedure that 14 vests the responsibility for review of logs with the i 15 supervisor of Operations? l 16 A I believe there is. I don't know the number i l 17 offhand. I would guess that it is in the procedure 18 shift relief and log entries, but I don' t know that i 19 for a fact, i 20 Q Do you attend training on the B&W 21 simulator once a year? k-22 A That is correct. 23 Q Do you feel that is enough time on the i 24 simulator training? 25 A The answer to your question is a somewhat subjective BENJAMIN REPORTING S ERVIC E 1895 254
i Ib1 5 i Seelinger 2 one and it is different today than it might have been 3 two or three months ago. I think that once a year could 4 be enough if the simulator program is properly b 5 constructed and properly carried out, and carried out 6 in light of what we have learned as a result of Three 7 Mile Island, Unit 2, and carried out in similar fashion 8 to what we recently accomplished on the simulator during 9 the month of July for our TMI Unit 1 operators. 10 I think that unless any training is 11 carried out in that particular fashion on the simulator 12 that the frequency is not really a material item. 13 Q Prior to March 28th did you feel that the i t 14 simulator training was inadequate? I 15 A No, I did not. 16 Q How has it changed since then that you feel 17 that it has improved? 18 A We have done three or four things considerably 19 differently in the simulator that I was directly 20 involved in setting up that has made it, in my judgment, 21 considerably different in terms of what we take away k_, 22 in the learning process on the simulator. 23 Prior to March 28th, we would send one shift 24 at a time to the simulator with one shif t consisting 25 nominally of about six people, a shift supervisor, a BENJAMIN REPORTING S ERVICE 1895.255
182 6 1 Seelinger 2 shift foreman, typically three control room operators, 3 and maybe one off-shift licensed person from the 4 Training Department or Engineering Department or 5 Administrative Department. The simulator training was l 6 typically conducted such that the group would be split 7 in two, conduct two hours of simulator training, and 8 than go into the classroom for two hours in the 9 morning, and then repeat that sequence in the afternoon. 10 When we went to the simulator during the month of l 11 July, I wanted to have a program that kept the shift 12 as a shift, that functioned to handle a casualty and 13 displayed the team work of the whole shift working 14 together, as opposed to working as random individuals i 15 ' hat although on shift would not necessarily be 16 performing in the same fashion as they would during 17 a casualty or accident. Prior to that time this 18 practice was discouraged because of the -- prior to 19 July, this practice was discouraged by B&W because of 20 the physical size limitations of the simulator, and 21 it was felt that if we had more than three people in L 22 the simulator at any time, one individual would not see 23 enough that he could gain what he should gain from the ~ 24 particular transient. We found that working as a shift 25 with the type of u sualtieu we have performed during.the BENJAMIN R EPO RTING SERV 8*y 5256
183 7 1 Seelinger 2 month of July, 1977 to be quite the contrary, that 3 while one person could not necessarily see everything, 4 he found his niche in the team that would handle that 5 casualty and help diagnose that casualty and learn -M 6 how to talk to the shift supervisor and the shift 7 foreman, would learn where that direction would come 8 from, would learn how to develop a philosophical 9 approach to a casualty as to who would give what 10 particular direction, and how those chains of 11 communications would work, and we tried to get those 12 chains of communication to work the same across the 13 respective shifts. 14 We further did something that we had not done 15 before, and that had never been encouraged before, and 16 that is we carried out the casualties all the way to 17 the end point. Prior to this time in simulator 18 training, casualties had been carried out to the point 19 of let us try to save the plant, and we would attempt 20 to follow the manual -- the automatic and manual on 21 cmergency procedures on which we had been trained, k-22 Once we had experienced an ES situation, and I will 23 say that the ES control panel at the simulator is 24 considerably different than our ES control panel, and 25 we never felt prior to March 28th that we would gain BENJAMIN R EPO RTING S ERVICE .... ~ ~ 1895 257
184 8 Seelinger 2 anything from learning how to manipulate that particular 3 control panel, so seldom, if at all, were any casualties 4 carried beyond getting the ES actuation from either the 5 low RCS pressure or high reactor building pressure on I March 28th, that we realized that was the beginning of
- 7 l
a casualty far from the end point, and so our simulator 8 training in July was geared to carrying out the casualty 9 to the end point. The ES happened early on in the 10 casualty and the casualty dragged on for an hour and 11 an hour and a half typically to insure that we had done 12 everything possible to put the plant in a safe condition. 13 Also to insure that we had properly diagnosed -- 14 this is a separate item, so I won't go into it yet. 15 This training took longer, and it took a more 16 calculated -- I will start over. 17 l So far I have covered two points. I have covered 18 the working as a team, and I have covered carrying a 19 1 casualty to the end point. 20 Thirdly, I wanted to set up a scenario that put 21 { more pressure on our operators in the simulator. Our requalification sessions, while observed by B&W, and 23 while a critique sheet to say what was done was filled 24 out, there was never a grade given in the requalification 25 program for simulator performance. One reason that was BENJAMIN R EPO RTING S ERVICE ~ ~ 1895 258
185 9 1 Seelinger 2 not done, in retrospect, was because the shift never 3 functioned together as a shift. I wanted to carry the 4 concept, the Navy concept of the operational reactor 5 safeguard examination in which a shift is drilled as 6 a shift with difficult drills on an actual plant into 7 the simulator, so I requested that B&W grade our shifts 8 on a pass / fail basis with the pass / fail criterion being. 9 did the shift keep the plant in a safe.:ondition. That t 10 did certain1y put an increased emph sis on the simulator Il training because any time a percan has a grade hanging 12 over their heads, they perform better. There is a i 13 certain incentive that we have as human beings, no 14 matter whether we like grades or not, that we tend to 15 perform better for them. 16 Finally, and I have partially covered this before, l 17 we wanted to develop the philosophy that we learned on 18 March 28th quite painfully in the simulator to make 19 sure that everyone had learned that philosophy. We 20 wanted to take the senior person in the simulator, 21 and we wanted to make sure that he stood back from k" 22 the casualty, that he scoped out the entire casualty, 23 and that then he called the other senior people he had, 24 namely his shift foreman and his shift engineer, if 25 one were assigned to the simulator, and that they went BENJAMIN REPORTING S ERVICE w.. 1895 259
t 186 10 1 Seelinger 2 over in the corner and caucused, as we had learned to 3 do on March 28th, and say, here is what our situation 4 is, do we have a heat sink, and how will we remove i b, 5 heat, and what do we think we have, and what are our i 6 flow parameters, and using that, the shift supervisor ~ 7 would then say, this is our plan of action, and would 8 go up and brief his control room operators at the l 9 control panel, and here is what we think we have, and 10 here is what our plan of action is, and in a formal 11 fashion, say, Joe, I want you to do this, and Bill, 12 I want you to do that, and you guys work together in I 13 controlling these two parameters, and here is how we 14 will attempt to get out of this in this particular 15 fashion. 16 Finally, the casualties that we ran were multi-I i 17 faceted casualties with multiple failures which we had 18 not drilled on to any extent before. 19 What I saw in the response of two shif ts that 20 I observed during this training and one shift with 21 which I participated was a significantly higher morale k_ 22 among the people because they realized that they were 23 developing something here that was extremely important. 24 They realized that if the situation could really be as 25 tough as what they were seeing in the simulator, as what BENJAMIN REPORTING SERVICE ~ ~1895 260
l 187 11 1 Seelinger 2 we saw here on March 28th on Three Mile Island, that 3 unless they had that philosophy and team work i 4 formalized and developed, their chances of handling V 5 it were not very good, and so I came away from the ~ l 6 simulator with a completely different attitude than 7 before in terms of feeling, how it could be used, and 1 8 what it could be used for, versus how it was used in 9 the past. 10 I might also add one other thing that I forgot, t 11 and that is we learned how at the simulator in July to 12 better use the procedures because in the formal 13 communications chain that we tried to develop, this i 14 caucusing over to the side, we also tried to develop 15 who takes the procedure out, and who reads the procedure, 16 and who follows the procedure in a very formal fashion I 17 across all the shif ts. Prior to this time in the 18 simulator we had not done that. We had not had what 19 is now, I am sure, the correct philosophy of procedure 20 use, but rather we had practiced what we knew from the 21 procedures in the simulator, and I feel, and this is 22 a personal feeling and maybe not universal, that we had 23 used our knowledge of the procedures to manipulate the 24 plant instead of using the procedures to manipulate the 25 plant. We had done that, perhaps, with the excuse in BENJAMIN REPORTING SERVICE
i 188 12 1 Seelinger 2 our minds of thinking that our procedures and the 3 simulator procedures are just enough different that 4 using either are slightly difficult, so therefore, we i b 5 will use our knowledge of the procedures and enhance 1 6 that knowledge by simulator operation. Prior to ~~ 4 7 March 28th that seemed very adequate and was good I 8 from a training standpoint because it did enhance l 9 one's knowledge of the procedures; it didn' t teach 10 one how to use the procedures. l 11 I realize I have run on for a while, but I feel 12 very strong about what we are doing. I 13 Q Did you, prior to March 28th, use procedures 14 from the Three Mile Island on the simulator? 15 A Yes, but in the fashion that I have described, 16 which was a limited fashion in the handling of I 17 casualties. They were not used as they were in July f 18 1979. They were used more in the performance of 19 controlling evolutions such as reactor start-up, and 20 in using our procedures for such evolutions we made 21 special efforts.to modify our procedures so that any 22 simulator differences that would be incorporated into 23 our procedures and made a strong effort to use the 24 procedures in those areas, but not a strong enough 25 offort to use them in the handling of emergencies. I895 262 BENJAMIN R EPO RTING S ERVICE
{ DOM 1 13 Seelinger 2 The reason for that, though, was very closely coupled 3 with the number of people that we had in the simulator 4 at any given time. ( 5 In our training in July of 1979, a typical l 6 deployment of people would be a control room operator 7 g operating the primary plant -- I will take that back -- 8 a control room operator handling the feed water portions I of the plant, including normal and emergency feed water, 10 a second control room operator handling the make-up and i 11 let-down system in the primary support systems, a 12 third control room operator plotting the various 13 l parameters and watching pressure-temperature relationships 14 for saturation conditions and margin to saturation 15 conditions, the shift for_ man reading the procedure, 16 the shift supervisor standing back and supervising i the operation in front of him, taking procedural 18 guidance from his shift foreman, as well as the 19 control room operators taking that procedural guidance, 20 and the shift engineer, if one was assigned, standing 21 ( back and monitoring various parameters and coaching the shift supervisor, as necessary, but not directing 23 the operation. 24 Now, prior to March 28th, a particular size 25 shif t in the simulator was three people. If you put BENJAMIN R EPO RTING S ERVICE 1895 263-
NU 14 1 Seelinger o' the shift supervisor supervising the operation and 3 two control room operators, one assigned to feed-4 water and one assigned to primary plant, you come up 5 short trying to read the procedure and supervise l 6 the operation at the same time, which is really not I realistic for a casualty scenario. I am inclined 0 to think that we were somewhat misled in the number 9 of people in the simulator and not using the simulator 10 to develop the shift scenario and shif t handlirig of l II a problem as is actually done during an emergency. 12 Q Prior to March 28th, there were three 1 13 l people in the simulator at a time? I 14 l A That was a typical group in the simulator, yes, and it was, as I mentioned earlier, discouraged to 16 have any more than that number of people in the 17 j simulator at any given time. l 18 Q Now, with respect to the scenario you 19 just described involving senior people, shift foreman, 20 shift engineer, shift supervisor and control room 21 operators, is that the experience which you had!.in-22 July? A That is what we just trained on in mid-July of ~ ~ this year, 1979, as a result of what we learned on 5 Three Mile Island, Unit 2. BENJAMIN R EPO RTIN G S ERVICE
101 15 1 Seelinger 2 Q Prior to March 28th, would a shift engineer 3 be typically sent with a shift to the B&W simulator? 4 A Engineers who had licenses were typically sent C 1 5 to the B&W simulator to practice their operating 6 experience and gain sufficient reactivity manipulations 7 to satisfy the requirements of the requalification 8 program, so in general the personnel that were sent on i 9 a regular basis to the simulator were the requalification i 10 i weekly visits with licensed personnel, and some of these 11 were engineers. I had satisfied that criterion and went 12 to the simulator with the shif ts as they would go down 13 for their requalification program. 14 0 Was there ever a time that somel ;dy was 15 sent to the B&W simulator not for his own personal 16 licensing or requalification? 17 A Yes, and we did this and have done this at various 18 times with almost all of our engineers. We have had 19 some changes in personnel such that there may now 20 be engineers assigned to our staff that have not 21 C been to the simulator, but I would say that up through 22 the 1977 '78 time period that we have had almost all 23 of our engineers go through a one-week course as a 24 minimum on the simulator, and some of our engineers 25 had, prior to that time, gone through a two-week BENJAMIN R EPO RTING SERVICE 1895 265
192' 16 1 Seelinger 2 course on the simulator, so I would have to look at the 3 records tc determine which have not, but it would be 4 of small percentage, say, nominally ten per cent of F 5 the engineers that have not been to the simulator at ~, 6 one time or another. 7 Q That would be for purposes other than 8 their own licensing or requalification? 9 A Yes, the purpora of that strictly familiarity 10 training to enhance their technical knowledge and l 11 enhance their ability to do their job in light of 12 recognizing what the operation of the B&W NSSS 13 and a nuclear plant entailed. 14 Q Do you know the names of the people that 15 did go to B&W for purposes other than their own 16 licensing or requalification? 17 A I know the names.of several that have gone but 18 there are certainly other such persons, and it would 19 entail most of the engineers on the Three Mile Isl'and 20 staff. 21 MS. GOLDFRANK: I would like to request (- 22 that we be provided with a list of the engineers 23 that attended the B&W simulator training for 24 ~ purposes other than their own licensing or 25 requalification, aul the dates of when they attended. BENJAMIN REPORTING SERVICE 1895 266
$00 i 17 Seelinger 2 THE WITNESS: Off the record. MS. GOLDFRANK: Yes. 4 (Discussion off the record.) (? t A The engineer simulator training which we discussed 6 took place from approximately 1972 through 1978, so it ' 7 took place over a span of a large number of years. 8 MS. GOLDFRANK: I would like to expand the 9 request to include non-operators; in other words, 10 management people. 11 A The personnel who attended the simulator for 12 other than their own licensing or requalification 13 training may also have attended the simulator prior to 14 that time for the purpo! ;s previously discussed, for 15 the training that was other than licensed training, so 16 l a typical individual could have attended the simulator i for a two-week program, say, in 1974, when he joined 18 the company or came to Three Mile Island, or had been 19 here for a year and then subsequently have returned to 20 the simulator in, say, 1977 or 1978 for a licensed 21 training program, and then subsequently attended 22 requalification sessions. 23 MS. GOLDFRANK: I would also like to request 24 that we be provided with copies of the record of 25 the July 1979 training on the B&W simulator. BENJAMIN R EPO RTING S E'RVIC E I 1895 267
134 18 I Seelinger 2 O You indicated in your discussion of the 3 simulator training that you have obviously put a lot 4 of effort into what the training was this past July? (' ( 5 A That is correct. 6 0 Was any similar in-depth involvement on 7 your part performed prior to this July? 8 A Nothing similar. I would say that prior to the 9 March 28th accident we recognized at the simulator 10 what we had typically used the simulator for, recognized 11 its value in that particular use, but our minds had not 12 bee n opened to how we could expand its use and 13 consequently we fell much more into a pre-established 14 program that B&W taught ourselves and other utilities, 15 or at least I think other utilities, during requalifi-16 cation type programs. 17 After March 28th I felt very strongly about needing 18 to do something different on the simulator. Frank Kelly t 19 of Persont il Qualification Services, a consultant, was ~ 20 ~ brought in to look at our training area. I discussed 1 21 this matter with Frank and gave him some of my-ideas, 22 and I let those ideas germinate and further developed 23 those ideas with the help of B&W into what we did on ~ the simulator in July. 25 O At any other time prior to March 28th, had BENJAMIN REPORTING SERVICE 1895 268
e 1 105 19 Seelinger 2 you brought in a consultant with respect to evaluation 3 or improvement of the training? I 4 A (, In 1974, prior to some of the early license s exams on Unit 1, consultants were used in examination I 6 of our people prior to their examination by the NRC. 7 l Prior.to that time, I don't know. Subsequent to that 8 time, I don't remember. 9 0 Were any consultants brought in to perform 10 a critique or an audit of the Training Department or i 11 to assist in that prior to March 28th? A I don' t know. I 13 1 0 Who can order a shut-down of the plant? 14 A I can, as the unit superintendent; personnel 15 above me in the chair. of command can; the supervisor 16 g of operations could; the saift supervisor or shift foreman could shut down the plant if they felt I 18 conditions warranted it; the control room operator 19 can shut down the plant if he feels conditions warrant i I 20 it; and the shift supervisor of QC, I believe, can 21 { issue a short sh'ut-down order of the plant. 22 Q Can the control room operator order a 23 shut-down without consulting anybody above him? 24 A Yes. ' Order a shut-down' is not necessarily 25 I the correct words in the case of a control room B ENJAMIN R EPORTING S ERVICE 1 8 9,a. 2 6 9
.136 20 Seelinger 2 operator. A control room operator would shut down 3 the plant, as opposed to ordering a shut down of the 4 plant. f' 5 Q But a control room operator could shut down a plant without consulting anybody above him? 7 A .Yes. Q Is this policy written? 9 A Yes. 10 Q Where would that be written down? 11 A It is in one of our administrative procedures. 12 I don' t know the number of the procedure that it is in, 13 but it is in one of the Admin. procedures. i Q As I understand the administrative procedures 15 are procedures for both Units 1:and 27.. 16 A That is correct. 17 Can I go off the record for a second? 18 r, Yes, sure, i 19 (Discussion off the record.) 20 Q Were you aware of a September 24, 1977 21 incident that occurred at Davis-Besse prior to March 28th? A I was not. 23 Q When did you become aware of that incident? 24 A Some time after March 28th, when I was asked a 25 similar question that you just asked me. 1895 270 BENJAMIN REPORTING S ERVICE
1 107 21 Seelinger 2 Q Do you know who asked you that question? 3 A No, I don't. 4 O .C, Prior to March 28th, were you familiar s with an incident at another nuclear plant that involved 6 a failed open PORV and pressurizer level high? 7 A .No, I wasn't. 8 Q Yesterday I believe you indicated that there was a B&W Users Group Conference that discu.ssed 10 i an incident at Davis-Besse on September 24th that you 11 did not attend, but you believe Gary Miller did attend, 12 is that correct? 13 A That is correct. 14 Q You indicated yesterday, I believe, that 15 you received minutes of that B&W Users Group 16 Conference, is that right? 17 A I, in my present positions, received minutes 18 of the B&W Users Conference. In my position as 19 Unit 2 superintendent for Technical Support, I'was 20 not -- I don't think I was on the B&W distribution 21 of minutes, although I definitely would have received 22 any of Gary Miller's minutes, because he would have 23 distributed them to me. After March 28th, we looked 24 ~ back in the files at minutes of the B&W Users Group 25 to see if any reference had been made to the transient 1895 271 i B ENJAMIN R EPORTING SERVICE s
b 22 1 Seelinger 2 at Davis-Besse; we found in one such minutes a one-line 3 statement stating that they had experienced a problem 4 with the electromatic relief valve, and that was all (~ 5 that was said. There was not nearly enough in those l ~ 6 minutes to understand or garner from the minutes that 7 Davis-Besse had experienced a significant transient. 8 In my review of such minutes there is no way that I 9 would have picked up the fact that Davis-Besse had i 10 experienced a transient of any' magnitude whatsoever I 11 from that statement. I do not remember whether I i 12 specifically reviewed those minutes or not prior to 13 March 28th. I 14 There is one thing I might add. Gary Miller is t 15 a prolific note taker, and I feel certain that if l 16 much had been stated at the conference that he attended 17 concerning the electromatic relief valve, that we would i 18 of had a fairly good indication that there had been a 19 problem from Gary's typical method of taking notes. 20 Q would you please read what we have already 21 marked as Womack. Deposition Exhibit 23. 22 (Handing.) 23 A off the record? 24 (Discussion off the record.) 25 Q Did you ever see this memo before? i BENJAMIN REPORTING S ERVICE } }[]
'i 23 1 330 Seelinger 2 A No. 3 Q IIad you ever seen any memo that discussed 4 the concerns raised in that memo? l 5 A No. 4 6 .~ 0 IIad you ever seen a memo prior to March 28th 7 written by Mr. Mich.e Ison? 8 A No. 9 Q Ilad you ever seen a memo prior to March 28th 10 written by a Mr. Novak? 11 A No. 12 O IIad you ever seen a memo prior to March 28th 13 written by a Mr. Creswell? 14 A Not to my knowledge. Who is Creswell? 15 Q Of the NRC. 16 A No, I can say no on that also. 17 Q In your training either at B&W or i 18 Metropolitan Edison, was the issue of a history of IO i failures of PORV's ever discussed? 20 A No. 21 Q C That is true for training at B&W and at I 22 1 Metropolitan Edison? 23 A Yes, that is true. 24 Q In your training at Metropolitan Edison 25 t and at B&W, what were you instructed as to pressurizer B ENJAMIN REPORTING SERVIC
24 I Seelinger 2 level control? 3 A We were instructed to keep an inventory in the 4 pressurizer and to keep the pressurizer from going 5 solid. ~ 6 0 Was this at Metropolitan Edison and at B&W7 7 A I would say yes, but I don' t think the instruction l 8 in either case, particularly with respect to the solid, 9 was brought out in as clear-cut a way as I have just 10 answered the question. I would say that I have 11 expressed a philosophy in answering the question, but f 12 could not go back to statements in training notes and t 13 dig out that specific statement out of the training 14 notes from either B&W or Metropolitan Edison. I have 15 expressed a philosophy that one keeps inventory in the l 16 pressurizer, and I have expressed a philosophy that one 17 does not take the pressurizer solid, j 18 Q From what did you learn that philosophy? 19 A I would say from study of our operating procedures 20 and limits and precautions associated with those 21 operating procedures, more than any other point. L 22 O The limits and precautions in the operating 23 procedures would have been utilized in your training 24 at Metropolitan Edison and at B&W? 1H S 274 25 A Yes. BENJAMIN R EPO RTIN G S ERVICE
201 I 25 Seelinger 2 Q What were you taught as to the consequences 3 of taking the plant solid? 4 A I don't think that I was ever taught very much 5 about taking the plant solid. I knew from Navy training, 6 and perhaps somewhat from training either here at 7 Metropolitan Edison or at B&W that controlling a l 8 solid water system is very temperature and very volume-I 9 sensitive. I think also one knows with experience that 7 [ 10 should a system be taken solid, such that a relief I 11 valve opens, the probability of the relief valve 12 sticking open exists, and other than those two facts 13 relative to solid operation, I can' t say that I ever I4 [ received any training on the solid operation. 15 0 You indicated that based on experience l 16 you know that an electromatic relief valve sticking I open is likely. What experience is that based on? IO A That is based on experience with nuclear power 19 plants since 1969, and in discussions with various ~0 9 people in the industry that one always is concerned 21 when a relief valve lifts, that it does, in fact, i 22 recede properly. One glaring example of when that did 23 not occur was on TMI 2 on April 23 of 1978, that the fact that the main steam relief valves, admittedly 25 different valves made by different manufacturers, opened [' BENJAMIN R EPO RTING SERVI
02 I 26 Seelinger 2 and hung open for long periods of time caused extremely 3 significant problems, so I think one operates with an 4 awareness of relief valves not using their capabilities 5 unless he is forced to use those capabilities. 6 Q Is there also a concern that they would 7 not lift? 8 A I have never raally felt that concern. O So yore concern would be not that it would 10 be lifted, but that it would stick open? 5 11 A Yes. 12 Q Were you ever taught that in certain 13 instances it would be better to allow a plant to go 14 solid than for something else to happen? 15 A I don' t remember being taught that. l ) 16 0 What is wrong with allowing your plant i l to go solid in Mode 3 other than violating a technical 18 specification? 19 A Since you have asked the question in a generic i 20 i fashion, I will answer the question in a generic fashion. 21 You asked the question, what is wrong with letting a plant go solid in Mode 3, and there is curve that 23 represents brittle fracture concerns that must be 24 respected in operating a plant. With age that curve 25 becomes more limiting because of neutron embrittlement; 1895 276 BENJAMIN REPORTING SERVICE
- eue --
-=w -eu
t Seelinger o that curve could shif t far enough that going solid 3 in Mode 3, which is a temperature range of 200 to 285 4 degrees could present problems with age. TMI 2 did not b' 5 t suffer from the neutron embrittlement situation yet in 6 that it was early in its life. and I would have to look. I at the specific curves versus the temperature to O specifically state that I could take the plant up to 9 the relief discharge point of the code relief valves 10 which is nominally 2500 pounds to insure that I did 11 not violate that brittle fracture curve. 12 O What is wrong with allowing the pressurizer I 13 from going solid while in a Mode 3, while the remainder I4' of the plant is in saturation conditions? A My answer to your question is an enlightened 16 answer, enlightened by the March 28th accident, and i 17 my answer is enlightened by four days of practice on I the simulator doing exactly what you have just asked, 19 and there is nothing wrong with doing that, and in fact 20 that is the way one gets out of one of these particular 21 ( kinds of situations, ending up in a solid pressurizer 22 condition and opening the code relief and operating 23 in a solid condition even if portions of the system are 24 under saturation conditions. I don't know that prior 95 to March 28th I could have given an answer that would be [h}} }[ BENJAMIN R EPO RTING S ERVICE
28 1 Seelinger 2 as correct. 3 Q What would your perception have been prior 4 to March 28th? ( c 5A If I had sat down and analyzed the whole thing and taken a lot of time and had time to talk to a few 6 7 people in B&W and a few people in our own organization, feel likely I probably could have come up with the 8I 9 same answer that I just gave, but I don't know that I 10 independently would have come up with that answer. The i 11 morning of March 28th, and subsequent days took a great t i 12 deal of engineering thought, took a great deal of i 13 engineering perception, and took situations that had 14 not been practiced before, and in fact were practiced i 15 for the first time on the simulator by our crews, and 16 by myself in July 1979. I don't know that independently 17 I would have arrived at the proper answer off the top. 18 I think I would have been led to the proper answer, and 19 I think I could have gotten to the proper answer, but 20 not with a minute or two of thought. 21 Q Prior to March 28th, was this issue ever 22 discussed? 23 A Not to my knowledge. 24 Q r' Not in your training at B6W or at Metropolitan 25 Edison? k t BENJAMIN REPORTING SERVICE t
29 i Seelinger 2 A It was not. 3 0 concerning the requirements of the 4 requalification examination, part of it is on-the-job 5 training, correct? 6 A That is correct. 7 0 How do you insure that as part of that 8 on-the-job training that you have met the qualifications? 9 A How do'I personally insure that I have met the 10 qualifications, or how do I insure that our operators 11 have met the qualifications? 12 O How do you insure that you personally in 13 requalifying for your SRO license, and how do you also 14 insure that licensed personnel under you requalify? 15 A I will start with the licensed personnel under me. 16 They participate in control room operations on a daily i 17 basis. They participate in start-ups and shut-downs 18 and whatever casualties the unit experiences, and 19 consequently get a number of reactivity manipulations 20 in that particular fashion. Further, we have elected 21 to send our people to the simulator on a yearly basis 22 in which 20 hours of operating time that the NRC has 23 judged equivalent to control room time, is able to be 24 counted toward their requirement for operating experience. 25 For the control room personnel that time only really 1895 279 BENJAMIN REPORTING S ERVICE
30 1 Seelinger i 2 accounts for as many of the reactivity manipulations 3 that they go through to meet the requirements of the 4 Requalification Program; that reactivity manipulation 5 requirement is either five reactivity manipulations ~' 6 every year or five reactivity manipulations every two 7 years, and I don' t remember which one right off the top. 8 For off-shift personnel such as myself, I satisfied 9 that requirement also by attending simulator training 10 and by participating in the direction of the control l 11 room activities on an on-going basis both through the 12 direction that is given through the POD-type meetings I 13 which are held virtually daily in the. control room 14 and shift supervisor's office, by visits and directions i 15 given in the control room on things like duty weekends, 16 and in participation on a yearly basis in various 17 emergency grills that we have had each year when we 18 try to take all of our shifts through an emergency 19 planning scenario with site and general emergency 20 simulated conditions which involves direct control 21 room involvement on my part in directing the activities k' 22 of the organization. 23 0 Is a log kept? 24 A Yes, a log is kept and maintained in the control 25 room. B ENJAMIN REPORTING S ERVIC E
l 31 1 Seelinger I 2 Q For each individual? 3 A Yes. 4 Q And is this log reviewed to assure that 5 a variety of experiences are had? ~ 6 A Yes, it is. t 7 0 Who reviews that? 8 A The Training Department reviews that log. 9 Q Does the Training Department report back 10 to you as to whether or not they think a particular 11 , individual should have more experience in a scenario? 12 A If such a situation developes, yes. In general, 13 though, because of the simulator training, such situations i 14 have not frequently developed because of the broad base 15 of emergency training that a person gets when he goes 16 to the simulator. For instance, a person may not get 17 such reactivity manipulations as a control room 18 operator on Three Mile Island 1. If Three Mile Island 1 19 has an extremely good record and is able to stay on the 20 line all year for an extended period of time, 21 power level may not have changed and may not have L 22 experienced start-ups or shut downs, and/or he may 23 have been on vacation, or his shift may not have had 24 the duty when the unit was started up, so he may not 25 be able to get credit for that start-up, so consequently BENJAMIN R EPO RTIN G SERVICE
l 208 s 1 32 Seelinger l 9' we rely on the simulator for the universality of 3 reactivity manipulations to insure that all our 4 operators get the required reactivity manipulations. 5 Q And that is the responsibility of the i 6 Training Department? 7 A The Training Department administers the program. The two requirements are the reactivity manipulations i 9 i and the variety of experience for on-shif t personnel, 10 and when a person is on-shift throughout the year he 11 gets a variety of experience by the nature of shift i 12 operations, and for the off-shif t personnel, the 13 reactivity manipulations and participating in whatever 14 l evolutions are going on during the period of time in 15 the control room is what the requirement is. 16 Q It would be the responsibility of the 17 Training Department to review those logs? 18 A Those are done by the Training Department, yes. 19 Q While you were Unit 2 superintendent for 20 Technical Support, were there system designs that 21 changed over that period? A Yes. 23 0 Who would be responsible to insure that a 24 system description for a design was up-to-date? 25 A The system descriptions up-to-date portion was BENJAMIN REPORTING S ERVICE 189r3 282
I Seelinger 2 insured by Burns & Roe, and we had a commitment from 3 Burns & Roe to give us at the -- I believe it was prior 4 to the end of 1978 was the way the commitment was ( 5 worked out, but whether or not that was ever completed i 6 I do not know, and my date could be wrong, too -- a 7 complete set of.up-to-date system descriptions to i 8 reflect systems as installed in the plant, and that was I 9 going to be a final effort out of the Burns & Roe i 10 group, and that was an effort which Metropolitan 11 Edison insisted upon having so that it would have a good i 12 set of system descriptions for the respective systems. I 13 Q At that point, whose respansibility would 14 it be? 15 A I don' t understand the question. 16 Q You indicated that at the end of 1978 17 Burns & Roe had made this commitment to provide an 4 i 18 up-to-date set of system descriptions. Once they 19 provided that, whose responsibility would it be to 20 keep those up-to-date? 21 A System descriptions were typically used as k_ 22 training in a general document as opposed to a document 23 from which one operated the plant. They were not the 24 print or aperture card from which maintenance was 25 conducted. I don't think that we had evolved into a 1895 283 B ENJAMIN REPORTING SERVICE
I 2[O 1 34 Seelinger 2 program, or I know of no such program that had us 3 updating system descriptions and that I don' t know if 4 we yet had them in hand, and whether or not such a (7'. 5 system will be created, I don't know. t 6 Q How are the system descriptions kept up-to-date on Unit l? I O A They are not. 9 0 they are not kept up-to-date? 10 A They are not kept up-to-date. 'I 11 Q Is somebody given the responsibility to 12 insure that they are up-to-date? 13 A No. I will amplify that by saying that each 14 change that is performed in the plant does not 15 necessarily make its way into a system description. i 16 Many system descriptions don' t go into that much 17 detail on the specific changes such that the change 18 may be far more detailed than the system description I itself. 20 Q On March 28th, were you on site at 4:00 a m.? 21 A No. L 22 O Where were you? 23 A At home in bed. 94 ~ ~ Q At what time did you arrive on March 28th? 25 A At 6:45. 895 284 B ENJAMIN R EPO RTING SERVICE
35 1 Seelinger 2 Q Did somebody call you? 3 A Yes. 4 0 Who called you? l 5 A Gary Miller called me. i i ..a 6 Q What did he tell you when he called you? 7 A He told me that Unit 2 had tripped and was 8 experiencing some problems with pressurizer level i 9 control, and there were some abnormalities. That 10 Gary was slated to go to Oyster Creek that day for a 11 meeting. At that point in time Unit 1 was getting 12 ready to start up following its refueling outage. The 13 two units have two auxiliary boilers that support the 14 heating of.f eedwater in one unit or the other, but 15 not both, and not at the same time and the auxil.- 16 iary boilers feedwater conditions were ready to go 17 critical, which was a matter of hours away, and Gary 18 told me to insure that I didn't give Unit 2 any 19 trouble about steam, which meant to me that unit ? 20 got the steam, so that is what I judged my marching 21 orders to be. 1 22 I got up and attempted to call the Unit 1 control 23 room and talked to the shift supervisor to insure that 24 happened. I did ;.ot reach the shift supervisor. I 25 was told that he was in Unit 2, so I waited about ten BENJAMIN R EPO RTIN G SERVICE 1895 285
212 36 1 Seelinger 2 minutes because I knew that my supervisor of operations 3 would be arriving somewhere between 6:00 and 6:30, and 4 decided that the quickest way to get the message to 5 him would be to call him at the plant and tell him s t ~~ 6 that. I called at ten after six or so and found out 7 that -- I am not sure of that time, ten after ix, but 8 I called and found out that my supervisor c,f operations f 9 was in Unit 2. I judged from -- stop -- at the time i 10 of 0400 on March 28th, we had both a shift supervisor 11 assigned to Unit 1 and one assigned to Unit 2. The 12 reason for that was the outage in Unit 2 and the ongoing 13 activities in Unit 2. Had there not been an outage in 14 Unit 1, there probably would have been one shift j 15 supervisor on site, but in this case there were two 16 shift supervisors on site. When my supervisor of 17 operations was in Unit 2, and I realized he was in 18 Unit 2, I realized I'd better get on site because 19 something significant was wrong, although I did not l I 20 get that indication from the Unit 1 control room, and i 21 I proceeded to the site and arrived at the site at L ??' 6:45 in the morning. 23 Q At what time did Gary Miller call you? 24 A He called me at 5:45. 25 Q What did you do when you got out there? BENJAMIN R EPO RTING S ERVICE i 1895 286 ~
37 1 Seelinger 2 A When I arrived at the site, and going through 3 the security processing center, I heard the word on 4 the page that site emergency had been declared. I had F 5 four briefcases in my hand. I dropped those off in my ~ 6 office and laid them on my desk and realized that I 7 had forgotten to pick up my TLD, ran to the processing 8 center, and got my TLD. I recognized or felt quite 9 certain that the problem was in Unit 2 because Unit 2~ 10 had just tripped, and Unit 1 I knew was not yet 11 critical. I also recognized, as I pulled into the 12 parking lot that the other unit superintendent's car 13 was in the parking lot, and my station per the 14 emergency plan is to go to the alternate unit's 15 control room; recognizing that the other -- that the - 16 Unit 2 superintendent would be in the Unit 2 control f 17 room because of his car being at the site, I proceeded 18 and ran from the processing center to the Unit 1 19 control room, and probably arrived there about ten 20 to seven in the morning. 21 0 What did you do at that point in Unit l? 22 A The first thing we did is I got a quick briefing 23 from the shift supervisor, announced in a relatively 24 loud voice that for the purposes of the emergency that 25 I was the emergency director in Unit 1, and directed that BENJAMIN R EPO RTING S ERVICE 1895 287
214 38 1 Seelinger 2 we break out our topographical maps and isoplats and 3 start trying to plot any plume that may be leaving 4 the site. I further directed that we close the north ( 5 gate, and I tried to close the south gate. In 1 6 retrospect, I don' t know that I was successful in 7 closing the south gate. I was trying to stop traffic 8 on the east side of the river, and I don't know that 9 that happened. In fact, I think it did not happen. 10 I was successful at the north gate in stopping traffic, I i 11 I recognized that it was also seven o' clock in the 12 morning, and our people would be reporting for work 13 right about that time, and that I would need somebody 14 in the observation center to direct the activities of 15 the people that ended up being diverted from the north 16 gate to the observation center, so I had somebody i 17 contact Bill Parker, who is supervisor of administration, 18 to go to the observation center and take charge of the 19
- people, i
20 Furthe r, I recognized that we would be inundated 21 with phone calls in a matter of minutes, and that during (- 22 off-hours our switchboard is controlled through just 23 a single phone in the Unit 1 control room, and that in 24 no way would that be adequate to handle what would 25 have been going on. I also felt certain that there was BENJAMIN REPORTING S ERVICE ~ ~~ 1895 288
> s 39 1 Seelinger 2 not a formal telephone operator on site, so I looked 3 around the control room and spotted one auxiliary 4 operator, a woman who used to be in the clerical 5 department and used to operate the switchboard, and 6 I assigxki her to operate the switchboard and deployed 7 her to operate the switchboard. I established 8 communications on what we call the hot line between 9 the two control rooms in an attempt to ascertain 10 the situation in Unit 2 and attempt to maintain i l 11 communications with the Unit 2 control room and learn 12 what their situation was and how we in the Unit 1 13 control room could assist the Unit 2 control room. 14 0 Who did you speak with on the phone in the 15 control room of Unit 2? 16 A I don't remember. I may well have spoken with j 17 George Kunder, but that particular day I must have 18 spoken with 30 different people on the phone, so I 19 don't know specifically who I talked to in that 20 conversation. 21 Q In that conversation, what did they 22 indicate to you? 23 A I don't remember. 24 0 Did they indicate to you that they 25 needed your assistance in any way? 95 289 BENJAMIN REPORTING S ERVICE
21G 40 1 Seelinger 2 A In the initial conversation, there was no 3 indication that my assistance was needed in Unit 2 4 at that point. 5 0 At any time did you go into the Unit 2 6 control room? 7 A Yes, I did. l 8 0 At what point? 9 A About eight o' clock in the morning I was called i 10 to the Unit 2 control room. I 11 0 By whom? 12 A I don't remember. It may have been Mike Ross, 13 but I don't remember that, and I was told that the j 14 situation was not good in Unit 2, and that Mike I i 15 requested that I come over to Unit 2. 16 Subsequent with that, and from just talking 17 amongst ourselves, and reconstructing what happened 18 that day, Gary Miller -- about coincident with that 19 phone call, Gary Miller had requested my presence i 20 in Unit 2. Whether that was done through Mike Ross 21 or not, I don't remember. I preceded, and I briefed 22 the Unit 1 shif t supervisor with what I thought our 23 conditions were in Unit 1, and with what I thought 24 our conditions were with respect to the off-site 25 release situation. It should be noted that we had B ENJ AMIN REPORTING S ERVICE
217 41 1 Seelinger 2 taken a sample reactor coolant sample earlier in the 3 morning, and its activity was such that it made the 4 Unit 1 health physics area, which is our normal Unit 1 5 control station, somewhat inhabitable, and somewhere 6 in the morning, and I don' t know if it was at that 7 point or not, I don't remember, the emergency control 8 station was shifted to the Unit 1 control room. I 9 think that was prior to eight o' clock in the morning. 10 I don' t remember for certain. l 11 I briefed the shift supervisor, announced in a 12 loud voice prior to leaving the Unit 1 control room, 13 that during my absence the shift supervisor was in 14 charge, and I proceeded to the Unit 2 control room. 15 Upon arriving in the Unit 2 control room, I found -- 16 and helped organize the response to the emergency i' 17 from an off-site standpoint. I did not get dir^ccly 18 involved at the control consoles, those at the panels, 19 with the plant problems that we were experiencing. 20 I insured at various times throughout my stay in 21 Unit 2, which was still about ten o' clock in the L 22 morning, that the emergency plan was carried out, 23 that accountability for the measures in the emergency 24 plan for accounting for people on site was being 25 conducted, that announcements were being made on the BENJAMIN REPORTING S ERVICE
218 I 42 Seelinger 2 page system to attempt to let people know what our 3 si'huation was, that the off-site agencies had been 4 called, and that pretty much had been completed with (' 5 1 the initial notificaticis upon my arrival in the 6 Unit 2 control room, and that we had phone talkers 7 set up between the control rooms, that status boards O were being maintained, that logs were being kept of j 9 ~ the conversations, and that we were plotting the plume i 10 as best as possible. 11 In our practice emergency drills, we executed 19 ~ very formal communications, and had found that was 13 not only impressive but that it worked quite well; 14 that formal communication was very much akin to the i 15 Navy communication that one executes when he relieves 16 as officer of the deck, comes in and after being 17 briefed, states in a loud voice that his name is 18 whatever, and that he has the deck and the con in 19 the Navy. Gary Miller announced in a loud voice i i 20 who he was, and that he was the emergency director, 21 and made several pronouncements in the control room ~ 2 in a loud and commanding voice throughout the day. 23 We had practiced organizaing ourselves, and ~ ~ organized ourselves that day per our practice, such 25 that a minimum of people talked to Gary, and that we BENJAMIN REPORTING S ERVICE ~ 1895 292
210 43 1 Seelinger 2 got inputs for him, and filtered those inputs, such 3 that Dick Dubiel, the supervisor of radiation and 4 protec, tion and chemistry talked to Gary, Joe Logan, 5 the Unit 2 superintendent talked to Gary, Mike Ross, 6 who was supervising the operation of the plant pretty 7 much by that time, talked to Gary, Lee Rogers, who was 8 in the control room of B&W, talked to Gary. Other 9 than that we -attempted to filter all communications 10 so it was handleable during the emergency. I 11 Q You indicated that during the period of time 12 that you were in the Unit 2 control room from eight 13 in the morning until about ten that morning, that you 14 were not directly involved with the control of the 15 operations of the plant? 16 A That is correct. i I 17 Q And how were you indirectly involved in that? j 18 A The methodology that was discussed earlier in this 19 deposition that we developed from the simulator, to 20 drav back from the plant in a corner with the senior i 21 people, discuss the situation in caucus form, and 22 decide what the most prudent course of action to Le 23 used to handle the plant's problems, was used during 24 the day of March 28th. I was involved in those 25 discussions when the senior people drew back in the BENJAMIN REPORTING SERVICE 1895 293
44 1 220 Seelinger SR: 1c 2 corner, in the shift supervisor's office in the con-3 trol room, and tried to assess the plant's chances 4 and tried to assess how best to handle the conditions 5 that we have. 6 Q who else was involved in that? l 7 A At that time I mentioned we were talking to 8 Gary Miller and pretty much the people that were 9 involved. 10 Q That would be Mike Ross and you and Dick 11 Dubie12 12 A Yes, and Joe Logan and Lee Rogers. The shift 13 supervisor may have been involved. I think he was. 14 I can't say that for certain. 15 Q During that time was there ever a discussion 16 that you had that you did not agree with the direction 17 that resulted from that discussion? 18 A No. 19 ' Q When Gary Miller left to go to Harrisburg 20 that afternoon about two o' clock, who was left in 21 charge? (i' 22 A Joe Logan was left in charge in the Unit 2 23 control room. At that point in t3me, I was in the t 24 Unit 1 control room. 25 Q was there somebody who was made emergency BENJAMIN REPORTING S ERVICE I
1 Seelinger 221 45 2 director? 3 A I don't know in that Gary left from the Unit 2 4 control room, and I was not there at the point in time -n 5 that he left. ~ 6 Q Did he notify you that he was leaving? 7 A yes. 8 Q He did not indicate to you who was left 9 in cha-ge in his absence? l 10 A There was no doubt in my mind that Joe Logan, 11 being Unit 2 superintendent, was the senior man in the 12 Unit 2 control room and was in charge during Gary's 13 absence. He did not specifically tell me that Joe Logan I l 14 is the emergency director in his absence during that i 15 telephone call, to the best of my memory. 16 However, I would not have asked the question, i 17 either, because I felt that I knew who that person 18 was during Gary's absence. One name that I forgot 19 to mention that was involved in those discussions was 20 George Kunder. 21 (A brief recess was then taken.) C 22 Q During this time that you were involved 23 with this caucus group, as you described it, between 24 approximately 8:00 in the morning till about 10:00 25 that morning, what did you know concerning the temperature" 1895 295 BENJAMIN R EPO RTIN G SERVICE
1 Seelinger 222 46 2 readings at that time? 3 A The times run together badly, so I don't know 4 the time or if it was at that time, or if it was later 5 in the day. 6 I do remember at one of the caucuses early in the 7 morning, suggesting or being involved in the suggestion i 8 to look at the in-core thermocouple temperatures from 9 the in-core ~ instruments. I remember that at least one i 10 of the printouts that we got back on looking at that 11 had question marks after the in-core instrument printout 12 on the computer. 13 i In terms of the actual temperatures that we got i 14 back, I don't know the timing at all that we got. I 15 just don't remember what time during the day that we 16 started the first attempt to get temperature, nor do I 17 I know specifically what type of equipment we hooked i. 18 up to get those temperatures that first day. 19 g why would there be question marks on the 20 computer? 21 A I don ' t k now. ~ 22 Q Is there a different type of computer in 23 Unit 1 than Unit 27 24 A The computer -- yes, there is a different type 25 of computer. Unit 1 has additional computer capability E BENJAMIN R EPO RTING S ERVICE 1895 296
I Seelinger 223 47 2 compared to Unit 2. It is undergoing a modification 3 to install additional computer capability. Itowe ve r, 4 both units do have the same basic type computer, the 5 Bailey 855 computer. 6 on both units, occasionally, we will get 7 question marks printed out after an input. 8 In other words, on a parame ter printout, be it 9 temperature or pressure or whatever, occasionally 10 question marks will print out afterwards. They may mean J l 11 different things at different times, and I frankly don't 12 know what it would necessarily mean. 13 Q During tha t period of time from 8:00 a.m. 14 to 10:00 that you were caucusing with these other 1 15 people in Unit 2, what'did you know with respect to 16 pressure? i 17 A Well, at all times during that period, I think 18 we knew what our primary pressure was. We had indica-19 tion of primary plant pressure, and the pressure was i j 20 not a. question mark in our minds, at least in terms 21 of what the actual pressure conditions were. 22 I would have to go back and look at a sequence 23 of events as obtained during that period of time what 24 the pressure was. g} 25 Q Who was giving the reading? I I BENJAMIN R EPO RTING S ERVICE }
I Seelinger 224 48 2 A Those readings were on the console, and we had. 3 the control room operators in front of the console and 4 the shift supervisor and supervisor of operations 5 behind them, so pressure was not a question in our ~~ 6 minds. 7 Q You were getting direct readings from 8 those operations people? 9 A
- yes, 10 Q
Between 8:and 10 o' clock that morning, 11 what were you aware of, concerning high-pressure 12 injectio_n? 13 A We had one caucus relatively early that morning, 1 14 between 8:00 and 10:00, in which we discussed our 15 situation of the full pressurizer and in which we 16 had the group that I previously described to you i 17 talking, and it was obvious from our discussion that i 18 we really didn't understand at that point what we had. i 19 We came to somewhat of a hasty conclusion that 20 we should cut high-pressure injection flow back. Within 21 approximately two minutes of coming to that conclusion, G 22 we reconsidered, with the logic being we don't under-23 stand what we have. We know what the safeguard systems 24 are designed to do. We know that we are safer using 25 those systems and putting water into the core than i B ENJAMIN R EPO RTING S ERVICE j 1895 298
1 seelinger 225 49 2 doing anything else, even if we don't understand what 3 we have. Therefore, we will not cut back high-pressure 4 injection flow, and we turned that decision around, and h ( 5 no action was taken on that decision, on the earlier 6 decision that had been made a copple of minutes beforg, 7 and that is the one discussion that I remember that 8 was pertinent to high-pressure injection flow. 9 My judgment would be that that discussion took 10 place somewhere between 8:00 and 9:00 in the morning, 11 but that is an approximation. 12 0 concerning the discussionstthat morning i i 13 between 8:00 and 10:00 a.m., what were the discussions { 14 concerning letdown? i j 15 A I don't remember. 16 Q was there any other period of time, other 17 than between 8:00 and 10:00 in the morning, that you 18 were in the Unit 2 control room? 19 A Yes, I was not I returned to the Unit 2 i 20 control room somewhere in the afternoon in the neigh-21 borhood of 2:30 to 3 o' clock in the afternoon, and I (? ~ 22 was in the Unit 2 control room till :4 :30 or 5 o' clock 23 in the afternoon. 24 I was then back in the Unit 1 control room 1 25 until 8 or 9 o' clock in the evening, probably more B ENJAMIN R EPO RTIN G S ERVICE i 1895 299
1 Seelinger 226 50 2 like 10 to 11 o' clock in the evening, and then in 3 the Unit 2 control room until 3 o' clock in the morning, 4 the following morning. 5 Q When you went back into the Unit 2 control 6 room about 2:30 or 3:00, did somebody call you back 7 into that control room? 8 A Yes. 9 Q -And who was that? ' 10 A Mike Ross called me. 11 Q And for what purpose did he call you to 6 { 12 come back to Unit 27 13 A Mike Ross called me and told me that things were I 14 just not going real smoothly, and that he requested 15 I come over to the Unit 2 control room. Based on that 16 recommendation or suggestion, I went to the Unit 2 17 control room. 18 Q Did he indicate what his particular 19 concern was? 20 t A I don't remember himiindicating that, other 21 than he just felt things were not going very smoothly. .(?L) 22 Q And what was his particular concern when +. 23 you arrived in the Unit 2 control room? 1895 300 24 A Well, at that time, Gary Miller and George 25 Kunder were both 9,ne from the control room and had I i BENJAMIN REPORTING SERVICE
i Seelinger 227 51 2 gone to the Lieutenant Governor's office in Harrisburg, 3 and I had the feeling, upon arriving in the control 4 room, that some of the formality of communication that 5 had been present with Gary as the emergency director 6 was not as present, that there was not as much overall ~ 7 direction or as much movement toward an end point with 8 direction as we had earlier in the day seen with Gary 9 in the control room. I t 10 I judged my function upon arriving in the control t I 11 room with both Mike and the shift supervisors still at i 12 the panel trying to come at the plant, to try to make 13 that movement happen and ensure that that direction 14 was present. l 15 Q And you stayed there until Gary Hiller came 16 back? 17 A Yes. 18 Q And at that time you went back to Unit 17 19 A I think shortly after his return, I returned to 20 Unit 1. 21 Q Since the accident, have you been involved 22 at all with the recovery effort? 23 1895 301 3 yes. 24 Q And in what capaci'/? 25 A starting the day following the accident, either BENJAMIN R EPO RTING SERVICE 6
I Seelinger 228 52 2 the day following the accident or the day following 3 that that is cloudy as to which -- Gary Miller and 4 I went on a port and starboard rotation, back-to-back () 5 watches, as the on going emergency director or operating 6 support for the Unit 2 emergency on-site. 7 We alternated that watch, port and starboard, 8 somewhere into uhe next week, and it was toward the 9 end of the next week, and then we started to phase '.i 10 other people onto that senior person watch bit, such l 11 that we got it into a one in three rotation or a { 12 one in -- I don't remember if it went directly from \\ 13 one in two rotation to one in four rotation and I 14 think it ended up with Gary dropping off that rotation, 15 and I stayed on the rotation, and other peop1'e were 16 brought onto that rotation to relieve me. 17 That would have been in the neighborhood in the 18 4th and 5th, the 6th nominally, of April, when we 19 went from the port and starboard routine to a four-20 section, I think, routine. 21 All of the people that ended up on that four-(11 22 section routine had previously been on the starboard 23 and port watches under me and Gary on the respective 24 sections, and just got elevated up into the same 25 position. l BENJAMIN REPORTING SERVICE 1895 302
1 Seelinger 229 53 2 Starting about the 9th or 10th of April, I was 3 assigned -- I came off shift and was assigned to the 4 Waste Management Group, and was assigned to the Waste 5 Management Group for about a three-week period in 6 time, and then I returned in early May, if I am not 7 mistaken, to my duties as Unit 1 superintendent. 8 Q Which are your responsibilities now. ~ 9 A That is correct. 10 Q Initially during that first week when 11 you and Gary Miller had what you referred to as " port I 12 and starboard watch," was Mr. Logan also involved I 13 in that watch? ? 14 A He was involved under one of the two of us. 15 We were on a different rotation than the remainder 16 of the section, so that we relieved on the port and 17 starboard section. We tried to relieve six hours 18 off the section, so that after the section would 19 relieve at noon, then Gary and I would relieve at i 20 6:00 in the evening. So I had the watch from 6:00 21 in the evening until 6:00 in the morning, and he 22 was 6:00 in the morning until 6:00 at night, and the 23 remainder of the two port and starboard sections ran 24 noon to midnight and midnight to noon. 25 Joe was in the remainder of one of these two SERVICE 1895 303 I SENJAMIN R EPO RTIN G
1 Seelinger 230 54 2 port and starboard sections. 3 Q Why was Mr. Logan not made head of one 4 of these sections? 5 A I was not involved in that decision, so I 6 don't know that I can answer that question. I did 7 have a significant amoun t 0f.involvemen t in Unit 2 8 for a period of two years, and I had practiced in a 9 number of emergency drills that we had had here on-site 10 for some period of time, and I think that I was put 11 as head of one of these two sections because of my 12' involvement in Unit 2 prior to that day and because 13 of practice that I had had in emergency drills and 14 knowing what had to be done. 15 l Q Even though Mr. Logan was Unit
- 2. super-16 intendent at that time?
i 17 A That is correct. 18 Q Who made the decision as to that port and 19 starboard rotation? Who made those assignments? 20 A It was either Jack Herbein or Gary Miller. 21 Q Who. indicated to you as to that watch? ~ 22 A Gary Miller. 23 Q With respect to your responsibilities 24 in the Waste Management Group, who did you report to? 25 A I reported on paper to Jack Herbein. I reported BENJAMIN R EPO RTING S ERVICE
I Seelinger 231 55 2 functionally for that first week to a gentleman by 3 the name of Byron Lee from Commonwealth Edison and 4 in the follow on weeks to Ben Rusche. 5 Q When you reported to Mr. Herbein, you say 6 on papet, were you head of that group? 7 A No. I was the liaison between the Waste Manage-8 ment Group and the plant. 9 The Waste Management Group consisted largely of 10 people from either outside the company or off-site 11 people from outside of the Three Mile Island staff. l 12 Consequently, their familiarity with accomplishing 13 items within Three Mile Island, how to get certain l j 14 things done and the ability to get those things done l 15 were limited without plant contact on a fairly senior 16
- level, 17 I was assigned to be that plant contact and 18 to try to get the Waste Management Group moving in I
19 conjunction with the plant, so things could be accom-20 plished by the Waste Management Group. 21 Q You.have no further responsibilities with G, 22 respect to tha t group now? 23 A No direct responsibilities in my job as Unit 1 24 superintendent. I interface with people from that 25 group as things are done that affect Unit ~1, but only B ENJAMIN R EPORTING S ERVICE }}}
1 Seelinger 232 56 2 insofar as that, in my involvement with the Waste 3 Management Group. Q Who would your contact be in that group? C' 5 A My contacts are numerous. There are currently ~~ 6 two shift supervisors assigned to the Waste Management 7 Group. I talk to them,on occasion. George Kunder is 8 assigned to the Waste Management Group, and I talk to 9 him on occasion. f 10 If I need certain items from the Waste Management ) 11 Group, I could have occasion to either go to John 12 Barton or Ben Rusche within the Waste Management 13 Group. 14 Since March 28th, you have made statements to I 15 various groups concerning the accident on March 28th, i l 16 correct? t j 17 A I have been interviewed on two or three occasions. 18 Q You were interviewed on April 12, 1979 19 by TMI staff along with Gary Miller and Dick Dubiel. 20 Were there any other times th'at you were interviewed 21 by the TMI staff? ([' 1895 306. 2, A There was one other occasion on which members 23 of the TMI staff and Lee Rogers got together and ~ 24 tried to, as best we could, reconstruct what we thought 25 happened on March 28th and what we thought we BENJAMIN REPORTING SERVICE
1 Seelinger 233 57 2 respectively did. 3 There was very little time for note-taking on 4 March 28th. One didn't stop fighting the fire to write CM 5 down how he was fighting it. ~ 6 we did sit down and talk and try to piece to-7 gether what we remembered respectively doing. It helped 8 to do that b e c au:s e, as someone else would say something, 9 it would trigger your mind as to what you were doing 10 at that particular time or what you had done on that 11 particular event, so it might help you remember rela-12 tive to that event. 13 That was the only time that I remember such a 14 proceeding, such a happening taking place. 15 MS. GOLDFRANK: I would like to request 16 we be provided with a copy of that second inter-17 view with the TMI staff. 18 Q You also were interviewed by the NRC on 19 May 8, 1979. Lid you have any other interviews with '20 NRC, other than on that date? 21 A I don't think so. I don't remember any other 22 irite rviews otncr than one session with the NRC. 23 g old you testify before the Udall Committee ~ 24 concerning the accident at Three Mile Island? 2s 895 307 ^ B ENJ AMIN R EPO RTIN G S ERVICE
1 Seelinger 234 58 2 Q Do you remember if you have been inter-3 viewed by any other organizations aside from the 4 President's Commission? 5 A Not to my knowledge. ^' 6 g Have you been informed that subsequent to 7 today you will-be interviewed or deposed by any other 8 organization? \\ 9 A No. 10 MS. GOLDFRANK: At this time I will recess o 11 j your deposition. I have no further questions at 12 the moment. I don't anticipate we will ask you 13 to come back for further questioning, but it is 14 possible that we would have some questions to 15 ask in the future, j 16 Thank you. 17 j (The deposition was recessed at 11:50 a.m., 18 as above noted.) 19 20 James L. Seelinger 21 ({' Subscribed end sworn to 22 before me this___ day of________________ 1979-23 24 1 OOC ~Z A 0 N tary Publi IO7J JUO 25 BENJAMIN R EPO RTIN G SERVICE
I I 235 59 2 STATE OF NUW YORK )) ss.: 3 COUNTY OF NEW YORK ) 4 We, ROBERT ZERKIN, Notary Public, and 4 5 STANLEY RuDBARc, Certified Shorthand Reporter and 6 Notary Public, of the State of New York, do hereby 7 certify that the foregoing continued deposition 8 of METROPOLITAN EDISON COMPANY by JAMES L. SEELINGER 9 was taken before us on the 7th day of August 1979. 10 The said witness was previously duly sworn. 11 The said testimony was taken stenographically by 12 ourselves and then transcribed. 13 The within transcript is a true record of i' 14 the said continued depositis n. 15 We are not related by blood or marriage to 16 any of the i. aid parties nor interested directly 17 or indirectly in the matter in controversy; nor 18 are we in the employ of an/ of the counsel. 19 IN WITNESS WHEREOF, we have hereunto set "4, 20 our hands this.f_T day of August 1979. c ( 22 RO ERT ZERKIN 23 A I _ h m :_ % h - _____ 24 STANLEY RUDBARG, C S R'. 25 i 1895 309 i e BENJAMIN R EPORTING SERVICE _ _ _}}