ML19305A703
| ML19305A703 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/04/1979 |
| From: | Hebdon F, Seyfrit K NRC - NRC THREE MILE ISLAND TASK FORCE, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001240591 | |
| Download: ML19305A703 (74) | |
Text
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NUCLE AR R5GULATORY COMMISSION O
'V IN THE MATTER OF:
THREE MILE ISLAND:
INTERVIEW OF KURL V.
SEYFRIT EDDR?0RBlgi Place -
Bethesda, Maryland Dete.
Tuesday, September 4, 1979 Pages 1 - 74 r.r.o on.:
n (202)347 3700 ACE - FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street 8 0 0124 ON/
Washington, D.C. 20001 NATIONWIDE COVERAGE DAILY
1
'l UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
X 4
In the Matter of:
5 THREE MILE ISLAND 6
X
-7 INTERVIEW OF KARL V.
SEYFRIT 8
Room 405 9
Arlington Road Building 6935 Arlington Road 10 Bethesda, Maryland il Tuesday, September 4,1979 12 l
i BEFORE:
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13 FRED HEBDON 14 FRED FOLSOM 15 16 16 l l
I 19 !
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2C :1 21
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23 24 i Acs.Federst Reporters, Inc.
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MR. HEBDON: - Would you$ raise your right hand, 2
. plea se ?
Do you swear-or affirm that the testimony that you 3.
are about to give stall be the truth, whole -truth and
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4 nothing but the truth, so help you God?
-5 MR. SEYFRIT I'do.
6 EXAMINATION 7
Whereupon, o
KAHL~V. SEYFRIT 9
was called as a witness and, having been duly sworn, was 10:
examined and testified-as follows:
11 BY MR. HEBDON -
12 0
.Have you read and do you understand the letter I 13
-have just given you concerning your rights as a witne ss in 14 this proceeding?
j_
15 A
Yes.
lo O
Do you have any questions or comments concerning 17 it?
16 A
No.
19 0
Would you please state your name?
20 A
Karl Seyf ri t.
21 0
What is your current position?
22 A
I am the director of Region IV of the Office of
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i 23 Inspection &.Enf orcement, U.S. Nuclear Regult.ary I
24 Commi ssion.
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25' O
What was your position' in late 1977?
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A I _was the Assistant Director for Technical 2
!)rograms in the Office 'of Inspection & Enforceme'nt.
3-0 That was here in headquarters in Bethesda?
'( )
-4 A
' That was here in headqu eters, yes.
5 0
Approximately how many people reported to you at-o tha t time?
7 A
-About eight, I don't remember the exact number.
8 0
To whom did you report?
Y A
Well, le t's see.
I'm not really sure at this 10 point.
There was a c hange which took place and I can't 11_
recall when it took place.
It was either to Boyce Grier, 12 who later moved up to be the Director of Region I, or to 13-Harry Thornburg, who replaced Mr. Grier at that time.
14 0
Would you describe your employment history,
'J 15 including positions held at the NRC?
Just a brief 10 description.
17 A
Just the NRC?
Id 0
No, your comple te employment hi s tory.
19 A
Okay.
I graduated from the University of Kansas 20 in 1950 and went to work for the General Electric Company in 21 hanfora, Washington.
I worked for them for a period of 10 22 years and.during that time held various positions, costly 23 involving the chemical se parations plants at Hanford.
24 Following that, I went to work f or the ci ty of -
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25-Pickwell, Ohio, who was the. operator of an AEC-owned
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I demonstration reactor, and I was there for about nine years 2
during which time I handled -various positions, Shif t 3
' Supervisor, Operations Engineer, Operations and Maintenance l
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4 Supervisor and ' finally a Plant Superintendent.
5 When that plant was closed down in 1969, I went to 6
work for the old AEC in the: Chicago office.
I believe we 7
were then called the Division of Compliance.
And I worked 8
there until either-late '72 or '73 when I came to 9
headquarters.
10 I worked in the office of -- I think we were 11 called then the Directorate of Regulatory Operations or 12 some thing like that --
we changed names rather f requently 13
-- for a few months and then I was loaned to the Reactor 14 Saf ety Study anu I spent about a year on the Reactor Saf ety
- f,3 IS Study under Dr. Rasmussen, and then returned to the 16 headquarters office as Chief of the Technical Assistance 17 Branch.
16 And then, a f ew years later during our 19 reorganization tha t position, while it was essentially the 20 same position, was changed to an Assistant Director's job.
21 0
The organizations that you mentioned, I believe it 22 was the Division of Compliance?
23.
A Yes.
24-0 Tha t is basically or functionally the same (T
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25 organization as what is now the Office of Inspection
5
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1-
& Enforcements-is that correct?
2 lA
'Yes.
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0 So you've basically been with I&E since you came T~'i 4
to -the L AEC and now NRC7 y.J.
S-A That 'is correc t.
6 0
Wha t is your educational background?
7 A
I have,a Bachelor of Science in Chemistry f rom the 8
University of Kansas.
As f ar as formal education is Y
concerned.- Of course, my on-the-job kind of training -has 10 been~ 1argely in the nuclear business and I do hold a
'll prof e ssional engineer's license.
12 0.
In nuclear engineering?
13 A'
In nuclear engineering, yes.
14 0
I would like to ask you some questions concerning O.
15 an' incident. that occurred at Davis-Besse on September 24, 16 1977.
I am particularly interested in the knowledge or the 17 understandings that you had. prior to the accident at TMI.
le Specifically, prior to March 28th, 1979, what knowledge did 19 you have concerning the incident tha t occurred at 20 Davis-Besse on September 24th, 1977?
21 A
Well, my memory of the de tails are a little bit on 22 the weak side.
And I must admit tha t they 'were mostly 23 stirred up as a result of a previous deporition f or the
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24 Kemeny Commission.
So this is not really total recall.
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_26 Bu t to the best of my knowledge, or to what
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happened --
2 MR. FOLSOM:
Legally it doesn't make any 3
'dif f erence how your. memory _ was ref reshed.
-[v) 4 THE WITNESS:
The. reason I mentioned this is 5
~because I have not had available to me the documents that o
relate to 'that event since those are all here in 7
headquarters and I have been moved out.
And so I didn't 6
have.a chance to actually review the documents themselves Y
before I was called for the deposition.
10 And I can't recall, as I remember it, there were 11 ac tually two separate events at Davis-Be sse. -And I'm not 12 sure withou t looking a t some documents which one you are 13 ref erring to.
They had some_ similari ties but there were 14 some differences, too..
15 BY MR. HEBDON:
16 0
I think I know the two incidents you're ref erring 17 to, and let me see if I can refresh your memory a little 16 bit.
ihe September 24th incident was an incident where the 19 plant had been operating and they had a reactor trip.
And 20 then subsequently -- or excuse me, they had a turbine trip.
21 And then subsequently a reactor trip.
22 The PORV in that particular design functioned as it was 23 expec ted to do in that ty pe of a t ran sien t, but due to some 24 probler..s with a missing relay, the valve cycled several
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times and then eventually f ailed open.
And than as a result s_
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I of.that they had basically a depressurization accident or a 2-small loss of coolant accident.
It took them about 20 3
. minutes, I believe, to find out that the PORV was open.
(Y 4
Tha t is the incident that I would like to talk abou t first.
%j 5
A Okay.
Well, I do remember the incident.
As I 6-recall, the level in the pressurizer did indeed get somewhat 7
below the level indication range.
6 0
Unless I am mistaken, now, I think you are a 9
little confused.
There was another incident tha t occurred 10 in November of '77, which was a cooldown transient and that, 11 I tnink, is the one where the loss of pre ssurizer level 12 indication was a' concern.
13 Now, for this Davis-Besse incident, if it might 14 help you ref resh your memory a li ttle, on the wall behind 15 you here is a graph that was prepared by Leon Engle who was 16 the Project Manager f or uavis-Besse at the time.
And this 17 is a plot of the September 24th incident and some of the 16 various parame ters.
lv A
Well, I have to say that my memory is not that 20 good, and in terms of trying to remember the details of the 21 transient, I simply can't.
If you have specific questions 22
'maybe I could get to that.
23 0
We have discussed the details with some of the 24 people who were more extensively involved and I'm really 4/
25 more - concerned with how the system -- the system meaning the
4812 O_I>07 8
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NRC - responded to - the incident.
-2 How did you become aware of the incident in the 3
first place?
Cb you recall?
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4
.A
.I don't recall specifically.
But typically it 5
would have been with a telephone call from the Regional 6
office.
7
'O Now why would they have called you?
e A
Well, they would have called me if they felt that 9
there was an event that was reportable by the licensee and
-10 if they felt that there was reason for concern about the 11 response of the system.
And it seems to me that subsequent 12-events would indicate that they probably had such a concern 13 and therefore I expect that I was called.
14 I can remember having conversations with people in kJ 15 NRR on this subject.
And I understand now that we actually 16 had a meeting -- again, i t may be the other event.
There 17 was a group of people from NRR who were sent to the site to 16 look into this thing, and when they returned a group of us lv sct down in Roger lJattson's office and discussed the matter.
20 0
I believe the meeting you ref er to was associated 21 with this particular event.
22 A-Okay.
23 0
What significance did you a ttribute to this 24 incident?
r p i
kJ 25 A
Well, I didn't really, myself, on the basis of i
- 812 01 08 kapHEE l'
this.particular event attribute a great deal of significance 2
to'it.
It seemed to me that it may have taken a longer 3
' period of ' time to recognize that the valve had not
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4 completely reclosed.
5 I was somewhat disturbed by the f act that it opened and 6
closed several times, but in my mind I sort of attributed 7
this to the. f ac t, as I recall, there had been a piece of 8
electronic equipment that had been removed and not replaced 9
in the control system for the valve.
And I don't remember 10 specifically what tha t wa s, 11 0
If I could refresh your memory a little, I think 12 that was the relay that caused the valve to stay open for a 13 short period of time and allowed the pressure to blow down 14 before the valve reclosed.
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IS A
But at any rate, I pretty much attributed the 16 problem-to the fact that the valve rather than opening, 17 relieving pressure and then reclosing and remaining closed, 16 cycled back and forth and assumed since when those valves lv open and close it is a pre tty physically demanding eff ort --
20 I mean they slam open -- that there may have been some 21 damage done af ter a number of openings and closings, that 22 prevented it f rom reclosing.
23 So I pretty much attributed it to the f act that 24 there had been a maintenance error, if you will, that lef t
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25 part of the system out of service.
This relay, or whatever m
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- 812 01 kopHEE.
I-i t was 'that had -been removed and not been put back in, or -
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maybe it was n'ever-in to begin with.
I don't really know, 3
but it was; that kind of def ec t.
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And in spite of. tha t, and for a period of time it 5
~ was recognized that the valve' was still open -- and I 6
believe they then closed the manual valve ahead of that one, 7
which stopped the transient.' And it seems to me that that 6
is the sort of thing that we really anticipate is the proper 9
way -to handle such transients.
10 0.
Did you send anyone to the site to review this 11 particular incident?
12 A
I am not sure whe ther I did or not.
I'm sure that 13 the Region III office sent people to the site.
14 And in fact, again, I was shown earlier a copy of
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s-15 a handwritten report that was made by -- what was his name?
Io One of the flRR people who went to the site.
17 0
For the record, this is a trip report prepared by lo Mr. Maze tis.
It'is entitled DB-l Abnormal Occurrence 19 9/24/77.
It is a handwri tten report.
Is that the report
- 20 that you were shown?
21 A
Yes.
And I think somewhere in here, or maybe it 22 was in an inspection report, there was a list of people who 23 were at the site when the se f olks me t.
Yes, here it is.
24 And out of this group there are a -couple f rom the Region III O
A_J 2S of fice, Terry Harpster, Bill Li ttle and I ~ guess that's it.
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But I don't recall-having sent anyone f rom f2 headquarters out t he re.
'3 0
Was it normal for headquarters not to send anyone tT 4
on an incident such as this?
%J 5.
A Yes, we normally do not send anybody out from 6
headquarters unless the Regional Office requests 7
a ssi s tance.
Or if we have an ongoing generic study of some 6
sort that this would fit into, then we might send somebody 9
out.
But it is not certainly the normal thing to sena 10 somebody from headquarters any time you have something like 11 this.
12 0
Did you request that Mr. Mazetis or any of the I3 people f rom NRR go to the site as a result of this incident?
14 A
I don't recall my requesting it.
I may or may not 15 even have discussed the f act that they were going prior to 16 their appearing on the si te.
I don't know.
17 0
Would i t have been normal for you to request that to DSS send some people?
19 A
Not again in this kind of a thing.
I don't think 20 that that would've been normal, for me to request that they 21 send somebody.
22 0
Do you --
23 A
As I say, based on the information that was j
24 available to me a t the time I did not consider it that 25 serious an event.
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1 0
All right. 'This trip report that you were just 21 looking at,1 this tendwri tten 're port, do you recall ever 3
seeing this report before -
prior to the time it was shown 4
to you 'by the-Kemeny Commission?
5 A
No, I don't.
6 0
As far as you know, you never saw or received a 7
copy of this report?
6 A
No.
I don't recall ever having received a copy of 9
i t.
10 0
All right.
11 A
It may have been shown to me in the meeting that 12 followed this trip.
But I don't have any positive 13 recollecticn that it was.
14 0
Okay.
Did you talk or meet with any-15 representatives of the utility?
16 A
If I did, it was only in the context of a meeting 17 that would have been called by NRR if the licensee came'into 16 headquarters to discuss the matter.
j
'19 0
Do you recall if such a meeting was held?
20 A
I do not recall.
I must say that during this time 21 span. tha t we're talking about I probably attended on the 22
-average of three or four meetings a week with NRR people and 23 various licensees and to try to remember or pick out 24 specific one s -- I just simply can't.
ry
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25 0
Do you recall any specific meetings with people
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I f rom' NRR, other than the briefing that was held in 2
Dr. Mattson's office?
3 A
I. don't, although that certainly doesn't mean
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4 there may not have been some.
I just don't recall.
5 0
Do you recall discussing this incident with anyone 6
else?
7 A
Well, I can recall discussing it some with Leon 8
Engle who, as you mentioned, was the Project Manager.
I 9
can't recall the specific nature of the discussions but I 10 know that we had some discussion on the telephone.
And
'll there was some question at the time as to whether NRR should 12 f ollow up on this ma tter, or whether I&E should.
13 And I think we decided mutually that I&E would be 14 responsible f or a ssuring 'that the licensee answer the right
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15 kinds of questions.
And I can recall vaguely being given on 16 the telephone a list of additional questions that I think 17 it was Denny Ross f elt ought to be answered as part of the 16 licensee's response to us.
19 I am sure you are f amiliar with the fact that 20 typically a licensee, af ter an event of this kind, would 21 write a licensee event re port to the Commi ssion.
And 22 initially that report generally just said something 23 happened.
And i t doe sn' t a ttempt to explain why or to 24 describe what may be done to prevent it f rom happening Ch
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And later there is a more complete report tha t gives
M12 01213' k pHEE-I additional details and includes some actions that would be 2
taken to prevent a recurrence of a similar incident.
3 I believe that this was done in this case,
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4 although-I can't recall the specific reports.
'S Q
Do you recall what the concerns were that Mr. Ross o
. felt should be addre ssed?
7 A
I don't remember them specifically.
I_think he 6
had some concern about the operators' reaction to the V
event.
I don't remember now what they _were.
10 0
Do you recall what you did as a result of the il concerns that he had raised to you?
12 A
Well, I believe that I called the Regional Office 13 and told them that they should convey this information to 14 the licensee and make sure that he, in his response, in his ATJ 15 final report, covered the se i tems.
Io Q
Do you recall who you spoke with at the Region?
17 A
No, I don't.
I don't remember now who it was.
10 0
Do you maintain a telephone log that might have 19 some more detailed inf ormation concerning these phone calls?
20 A
No.
21 0
For the record, wha t I have here is a note to Karl 22 Seyf rit f rom Mr. Ross.
The subject is Davis-Be sse 1 23 Abnormal occurrence v/24/77, and it is dated October ?O, 24 1977.
Do you recall ever seeing that document?
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25 A'
This is the one that -- well, I thought it w is a t
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talking about.
I think he called me first and then maybe 3
_sent this over confirming it.
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4
'O Do you recall what you did with that note?
l: xs 5
A
. Well, as I said, I think I called the Region, and 6
it may well be that I sent them a copy of this thing.
But I 7
don't have a specific -recollection of which way it went.
My 6
normal response would have been to call if-I had a telephone Y
call and a piece of paper.
The normal response is to send 10 them a copy of it.
11 0
The reason I ask is we've talked with a lot of 12 people in the region who were involved in this incident and 13 no one recalls ever seeing che no te.
And I believe 14-Mr. Keppler., who is the Regional Director, has reviewed the
'(3 xs' 15 files and they have no record of ever receiving the note.
16 And so, one of the things that we're trying to identif y is 17 basically what ha ppened to it.
16 Do you have any sort of records or do you have any
~19 recollection that might help us identify what did happen to 20 thi s no te ?
21 A
No..
I really don't.
As I said, my normal 22-procedure would've been to either telephone them and give 23 them this inf orma tion or to send them a copy of it.
If they 24 can't fino a copy, obviously I did not ' send them a copy.
So p
k_J 25 I. mu s t ha ve telephoned and merely said, these are the
5812 01 15
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things that are of concern to NRR that the licensee should 2
addre ss in his re port.
3 0
But you don't specifically remember making a phone
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4 call?
5 A
No.
6' O
Or you don't remember who you talked to?
7 A-No, it could have been any one of several 8
di ff erent 'peo ple.
I don't know.
V O
Who could it have been?
10 A
We ll, a t that time I think Gaston Fiore111 was the 11 Chief of the Operations Branch in Region III.
Let me think 12 a minute.
Bill Little was.the Section Chief.
I may have 13 talked to him.
I am trying to remember who the assigned 14 inspector was, m.-)
IS o
Could it have been Tom Tambling?
16 A
Yes, that is-the name, and I may have talked with 17 Tom.
1erry Harpster was helping out but most of his work Id was in a diff erent field and I doubt that I would have 19 discussed it with him.
20 0
Did you receive the licensing event reports that 21 Toledo Edison prepared as a' result of this incident?
22 A
rell, I am reasonably sure that I did.
If they 23 were prepared.
If I might look, I think maybe those were 24 appended to the de posi tion that I made before, although,
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25 again, I'm not certain.
1 (Pause.)
CR6812 17 HEER t.2 jl 1.
1 THE WITNESS:
Let's see.
This is an inspection 2
report that deals with the subject.
3 (Pause.)
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4 THE WITNESS:
No, I don't see them in here.
I don't 5
have any specific recc11ectica..
If they wrote one, which I'm 6
reasonably sure they did, I would have received a copy of it 7
in my former position.
And it would be on file in the head-8 quarters office.
9 BY MR. HEBDON:
10 0
But you don't recall any specific details the 11 report or any concerns that it might have raised?
12 A
No.
I do have a copy in here of something that was
_()
13 put together by the Office of Management and Program Analysis.
14 They may not have been that at the time.
I think they were 15 OMPIC or somethino like that which describes this event.
And 16 this information is normally taken from a Licensee Event Report, 17 which makes me feel fairly certain that such a report did exist.
18 Q
For the record, this is a document entitled Current 19 Events Power Reactor."
It's prepared by the Nuclear Regulatory 20 Commission, published in December of 1977.
21 MR. FOLSOM:
And it is marked Exhibit 7 to the
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22 President's Commission deposition taken of this witness.
23 THE WITNESS:
Yes.
24 BY MR. HEBDON:
Ace Federd Reporters, Inc.
25 Q
Do you see or discuss any other reports produced as a i
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18 1
result of ' the investigation or analysis of this incident?
2 A
I Probably did, but -I do not have specific recollec-3.
tion of them at this point; I just don't.
4 Q
Were you aware that a Mr. McDermott of the Quality 5
Assurance Branch in NRR conducted an investigation of the 6
Quality Assurance implications of this indident?
7 A
I don't specifically remember that having been done, 8
but it would not at all surprise.
And he may have even men-9 tioned it to me.
But it' did not register as something that 10 jogs my memory.
11 Q
At any time in the review of this particular incident 12 were you concerned that the investigation was not being con-(~)T 13 ducted in an orderly or systematic manner?
~,
14 A
I don't have any specific recollection of any con-15 cerns along those lines, no.
16 Q
Did you consider the generic implications of this 17 incident?
d 18 A
Well, I think it is fair to say that we always 19 attempted to consider generic implications.
And as I indicated 20 earlier on, I _think that my feeling about this particular 21 incident was that it was really largely a result of the
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22 incident that had been lef t in an inoperable condition -
that
'23 is, with the one piece missing -- so it couldn't really perform 24 in the way that it was intended.
Oce. Federal Reporters, Inc.
25 And that, to me, does not really indicate a generic problem i
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per se.
2 Q
Did you consider at all the generic implications of 3
an incidence similar to this that might be initiated by some s
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4 other cause of the PORV failing open?
5 A
No, I don't think that I specifically had that in my 6
mind.
There was somewhat later an event at another reactor.
As 7
a matter of fact, it was at Three Mile Island.-- I don' t think it 6
was Unit 2; I think it was Unit 1, but I'm not sure of that 9
either -- in which the relief valve failed open because of an 10 instrument failure of some kind there, or a power failure --
11 I've forgotten now which.
Again, the details escape me.
12 And as a result of that, we had an inquiry from Region 1,
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13 where they had asked us to lo~ok at the question of whether or 14 not there needed to be some special study made or something 15 done, because of the potential for this valve to fail in the 16 open position.
17 And what was done in that case was to take a look at the 18 safety analysis report, and the accident or the event involving 19 Chat valve being stuck open had been specifically analyzed and 20 was, based o?. the safety analysis report, an acceptable design 21
-- that is, the valve could fail open, and the backup systems
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22 were sufficient to prevent anything of any consequence occur-23 ring.
24 Q
Do you re call approximately when that incident b Federal Reporters, Inc.
25 occurred?
.jlL4 20 1
A I don't remember, but,again, I know that one is in 2
here.
It would have happened in ' 78.
3 Q
Approximately when?
(_ i 4
A Someplace around in March of ' 78.
5 Q
Okay.
6 I believe the memo you are referring to was written 7
by Mr. Sternberg of Region l?
8 A
Yes, that's right.
9 Q
We will discuss that in a little more detail later 10 on.
11 Now, you mentioned that you attended a briefing in 12 Bethesda, shortly following the incident at Davis-Besse, in
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13 Dr. Mattson's office.
Do you recall who gave that particular 14 briefing?
15 A
Well, I really don't have a personal recollection of 16 the briefing.
The handwritten trip report, plus some other 17 discussion -- I think -there was maybe a set of meeting minutes 18 written; I'm not sure.
But apparently Mazetis is the Gne that 19 gave most of the discussion of what had been found when they 20 went to the site.
21 Q
Do you recall what the concerns were that were
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22 raised during that briefing?
23 A
Well, I dcn't have a real recollection of it, no.
I 24 can read what he has in his report.
And I assume those are the l Ace Federal Reporters, Inc.
25 same concerns that he raised then.
But I just, frankly, don't I
21 jl 5 1
remember specifically that meeting.
2 Q
You mentioned that you thought a meeting summary of 3
that meeting might have been prepared.
Do you have any O
4 specific knowledge of whether or not a meeting summary was 5
prepared?
6 A
No, I de
't.
Although it was not so much an internal 7
meeting, but in nsetings where the Licensee was involved, they 8
almost always write up a set of meeting minutes.
And I j ust 9
don't know whether there was one prepared for this one or not.
10 0
Do you remember if the Licensee was involved in that 11 meeting?
12 A
I don't believe that he was, based upon what has been O(_j 13 discussed with me since then.
14 0
What actions did you take as a result of that 15 meeting?
16 A
I really don't remenior specifically what was done.
17 I can only talk to you in terms of what we typically would have 18 done.
And as I told you earlier, I think that it was agreed 19 that I&E would have the responsibility for following up on the 20 incident.
21 AnY time that we have this kind of a thing, the regional n
(_)
22 office will make special inspections, investigations, what 23 have you, to try to determine exactly what the cause of the i
24 matter was and what the Licensee has done about it.
l
- Ace Federel Reporters, Inc.
25 And the Licensee, in turn, is required to do his own l
i l
22 jl 6 l
i I
review of the event, to make a detailed report on it.
2 The only thing that I would _have done, again, would be to 3
relay to the region the specific conerns that had been raised, 4
and ask them to be sure that these were covered in their review 5
of the matter.
6 And in those cases where it was something we wanted from 7
the Licensee, to make sure that he addressed.
And that is 8
about all.
9 I am sorry, but I don't have a good recollection of the 10 specific details of this event or the discussions involved with 11 it.
12 O
Do you maintain a meeting log that might contain any
()
13 more details concerning this meeting?
14 A
No, I do not.
15 Q
Do you recall briefing the ACRS during October 1977 16 and again in November 1977 concerning this incident?
17 A
Once again, I did not remember that specifically, but
- 8 I assumed, when I was deposed for the Kemeny Commission, that 19 such a briefing would have taken place, because it is typical 20 of the way we do business.
And I understand that.
Actually, I 21 talked to them twice about this matter.
I requested that tran-
[')
22 scripts of those two discussion be provided to the Kemeny v
23 Commission, but I personally have not seen them yet.
So I 24 haven't had an opportunity to review am.
AwFWeal Rgorurs im.
l 25 Q
For the record, what I have here is a copy of a memo l
i
jl 7 23 1
sent to a Mr. Helfman of the President's Commission.
It is 2
dated August 15th,1979.
And it states that the enclosed are 3
the transcripts that you. Mr. Seyfrit, had promised as a result O-4 of your. interview.
And enclosed is a document labeled "210th 5
ACRS Transcript, October 7th, 1977," and another document, 6
"211th ACRS Transcript, Novebmer 3rd, 1977."
7 I would like to ask you some specific questions about 8
that transcript in a moment.
But, first, why were you called 9
upon to give the ACRS a briefing concerning this particular 10 incident?
II A
Well, in my position in headquarters at that time, I 12 performed the function -- as sort of liaison with the ACRS.
(~)T 13 And whenever the ACRS had questions about the events that had m
14 occurred, or if we felt that an eve..t was of sufficient 15 importance that they ought to hear about it. I normally got the 16 information from the regional office and then made the presen-17 tation to ACRS.
18 Now, on ocassion, we also called people in from the 19 regions to make the presentation.
I 20 Q
Do you recall how this particular briefing was 21 initiated?
Was it at their request or at your request?
( })
22 A
I don't really recall for sure.
I just don't know 23 which way it was.
24 Q
Okay.
meFWed Coorters, inc.
l 25 A
It could well have been either way, since it was
24
-31 8 1
. done fairly soon after the event, as I recall, this first one.
2 I think the chances are pretty good that we initiated it, but 3
I'm not really sure.
O 4
Q How did you get the information that you used in the 5
briefing?
6 A
I got it from the regional office and probably from 7
Tom Tambling for the most part.
Although, again, I'm not sure 8
who I specifically talked to.
Generally, I would talk to 9
either the section chief or the branch chief and ask them to 10 get the information together for me and cand it in.
11 Q
But you don't recall specifically talking with anyone 12 to try to get the information for that particular briefing?
()
13 A
No.
Please understand, again, during this particular 14 time, I had so many different events, so many different inter-15 actions with people on so many different subjects, that I can-16 not sort them out.
I can't remember the specific contents over 17 any other.
18 Q
Do you recall, by ary chance, either as a result of 19 your recollection n(w or as a result of some of the discussions 20 you've had with the Kemeny people, for example, that you 21 provided any graphs of parameters, such as pressurizer level
()
22 or reactor system pressure or any of that sort of material?
23 A
I don't remember it right now.
If I could read
(
24 through this, I may have my memory refreshed.
But, again, that
' Ace.Federd Reporters, Inc.
25 was fairly typical of the kinds of things that we did.
And l
l
i 31 9 25 1
these would be either copies of charts from the plant or graphs 2
that may have been prepared by the inspectors from those 3
graphs.
But I don't really remember whether I had any in this fi 4
particular presentation or not.
5 0
You don't recall if, by chance, you might have had 6
this graph that was prepared by Mr. Engle that I believe was 7
used for the briefing that Mr. Mazetis gave?
8 A
I don't remember specifically whether I did not not.
9 It is entirely possible, but I don't recall.
10 MR. HEBDON:
Why don't we take a break for a few 11 minutes and give you an opportunity to review the transcript.
12 And then I will have a couple of questions I would like to ask.
()
13 (Recess.)
14 MR. HEBDON:
Let's go back on ti a record.
15 BY MR. HEBDON:
16 Q
Mr. Seyfrit has just taken the opportunity to review 17 the transcript of the ACRS meetings during which he discussed is this particular Davis-Besse incident that occurred on 19 September 24th.
20 Referrring, first, to this graph that we have on the 21 wall here dhat Mr. Engle prepared that was used for the brief-
'(3
(_)
22 ing by Mr. Mazetis, a couple of points you might want to 23 notice:
24 One is that at approximately four-and-a-half minutes Ace Federet Reporters, Inc.
25 into the transient there,is a note that the high pressure t
l
jl 10 26 j
1 injection pumps were secured.
2 And then, at a point about 20 minutes into the 3
transient, there's a note that the block valve was closed,
\\~
4 which I believe is the block valve or. the PORV.
5 Did you realize at the time that the operators had 6
secured the high pressure injection before they had isolated 7
the cause of the leak?
8 A
1 don't think that it particularly registered with 9
me, but I believe the description that I gave in here included 10 that kind of a statement.
11 Q
Do you recall where in there you made that statement, 12
-because I've also read that particular transcript, and that is
(
13 the question that I had, that I did not see any reference to 14 the fact that the operators secured the high pressure injection 15 before they isolated the leak.
16 A
Well, I don' t think that it came across that 17 specifically.
But I believe, if we go through this completely, 18 that it comes out that way.
'. 9 Let me take a minute to look.
20 MR. HEBDON:
Certainly.
21 (Pause.)
()
22 THE WITNESS:
Well, here we say the operator turned 23 them off.
24 BY.MR. HEBDON:
- Ace.Federet Reporters, Inc.
25 O
Excuse me.
Is there a page number with that?
)
27 jl 11 1
A 348.
2 O
Yes, 348.
3 A
Mr. Ebersole had asked me if the high pressure ECCS O
4 pumps had come on and started to inject.
5 Answer:
"Yes, they came on. "
6 And he asked me if it charged the system with water, 7
and I said, "No.
The operator then turned them of f; yes. "
8 Q
But as I understand it, the ECCS, the high prer sure 9
injection pump 7. did charge the system to some extent.
10 A
Well, for a very short period of time.
11 Q
For dbout four minutes.
12 A
Yes.
That is not a very significant amount really.
()
13 And I think his question, raally, following the previous dis-14 cussion, he was really asking me, did the high pressure system 2
15 continue to keep pumping water and keep the core covered that 16 w ay.
17 And the answer is "no,"
because they shut it off.
la Q
But there wasn't any specific reference to the fact 19 ! that they had shut it off before they had isolated the leak?
l 20 I
A No, I guess that is true.
I sort of inferred that i
21 from my reading of the thing.
I guess it doesn't really say T) 22 that.
i l
23 Q
Do you recall at all why that point wasn't made?
l l
24 A
tha, I don't.
'Am-FWeJ Roorters. Inc.
25 Q
In hindsight, would you have cons idered that to be a i
28 jl 12 1
particularly significant point in this transient?
2 A
Well, obviously, when you look at what happened at 3
Three Mile Island, one would be a little bit crazy not to O
4 consider it, but I think, for the purposes of this discussion, 5
that I sort of have to separate myself from what happened at 6
Three Mile Island later.
7 And in light of what we knew and what actually trans-8 pired at Davis-Besse, I don' t think it was a question that 91 would have really floated to the top and have been of great 10 concern.
11 Q
But looking back just a little, that is one of the 12 concerns that Mr. Mazotis raised in his note to you, through i
(}
13 Mr. Ross, of concerns he had about this particular issue.
So 14 it was raised by him as an issue.
15 A
I did not read that that closely.
16 Q
This, again, is the memo from Mr. Ross to you, item 17 number 2.
He seems to be raising a concern about the fact that 18 the operators secured the high pressure injection as early as 19 early as they did.
20 A
Well, his concern was, really, why did they make the 21 decision to secure it when the did?
He says it should be
('-)
22 explained.
I think that perhaps it was explained, and in the 23 explanation we perhaps didn't reach as far as one ought to 24 reach..
Ace Federst Reporters, Inc.
25 It was secured, essentially, for the same reason it i
1
31'13 29 1
was secured at Three Mile Island.
The pressurizer level was Dnd t2 2
going up; they thought they had plenty of water, tcrt t3 3
0 If you'll notice on this particular graph, again
(~)
\\'
4 referring to Mr. Engle's graph, at approximately four-and-a-half 5
minutes into the transient, the operator secured the high 6
pressure injection system.
And at that point in time the 7
pressurized level was increasing, then it turns and starts to 8
back down, which you would reasonably expect because of the 9
fact that the plant was continuing to cool off.
10 But at about six minutes into the transient, the 11 pressurizer level turns and goes back up rather sharply and 12 crAtinues to increase until the pressurizer is completely full,
()
13 at about cight minutes, and then the pressurizer remains full 14 out to about 28 minutes, at which time the pressurizer level 15 drops very sharply.
And, in fact, the pressurizer level goes 16 from off-scale high to off-scale low, in what would appear to 17 be a matter of about a minute or two.
18 What would be your explanation of that particular 19 response?
20 A
Well, I don't know that I have specific explanation.
21 Frequently, when you have readings that vary consi'derably from
()
22 what you would expect, die answer has to do with perturbations 23 of system pressures that cause f aulty readings.
It is not too
-24 uncommon, depending upon what kind of instruments you have and Ace Federal Reporters, Inc.
25 what -these instruments -- how they are hooked up -- to have an l
30
~$1 14 1
instrument show you either an erroneously high level or an 2
erroneously low level, because there are differences in pres-3 sure between what I will call the reference leg and the leg
(
4 thct is trying to measure what is sitting above it.
5 I don't offer that as an explanation in this case.
6 Let me relate, to say that is the kind of thing that may is the 7
kind of thing that may happen when changes are taking place 8
very rapidly.
Instruments do some strange things.
I don't 9
think that is probably the case here.
I don't really offer 10 that as an explanation.
I don't know.
11 Q
Do you recall if anybody raised a similar concern 12 about this particular response during the briefing that
()
13 Mr. Mazetis gave?
14 A
I really don't recall what was discussed at that 15 briefing; I just don't.
16 Q
Could it be that that particular response is due to 17 the fact that boiling was taking place in the reactor coolant is system and that boiling caused an insurge into the pressurizer?
19 A
Certainly, that is a possibility.
And it may even l
l 20 be the most likely probability, given all that we know at this l-21 point, yes.
l
()
22 Q
Do you recall if this particular response was 23 addressed with the ACRS as part of Ehe briefing at the ACRS?
i 24 A
I don't recall specifically whether it was or not.
Ace Federet Reporters, Inc.
25 I don't think it was.
15 jl 31 1
'O Do you have an idea why it wasn't addressed?
2 A
Well, I think probably because it just hadn't made an 3
impression on me or the others who were preparing the informa-O 4
tion for me to give to the ACRS.
That is the only explanation 5
I can come with.
6 Q
This is an issue I've been having a difficult time 7
coming to grips with.
A lot of people have told us that 8
pressurizer level is, in their mind, one of the key indications 9
that the operators use for monitoring how the plant is perform-10 ing.
And yet here you have pressurizer level following a II rather anomalous looking response for what is going on else-12 where in the plant.
Do you have any idea why apparently no one 13 seemed particularly concerned about this particular response?
I4 A
Well, I think that perhaps there are two parts to 15 the question that you raise.
16 Certainly, during reactor operation, while the I7 reactor is operating, pressurizer level some people watch, and I6 they have a concern for.
I don't think that typically they I9 ' have the same degree of interest in the pressurizer level per 20 se once the reactor is shut down.
That is not to say they 21 shouldn't have, but I don't think that the same thought process AV 22 is there.
23 I think there is also a sort of mental block that l says since the reactor vessel and the pressurizer are connected 24 Ace Federd Reporters, Inc.
25 with the pipe, that if you've got water at this level up here,
I
jl 16 32 1
you must have water down here.
I don' t think that people 2
really, prior to Three Mile Island, gave serious consideration 3
to the fact that you could void a part of the reactor vessel O(3 4
and still maintain the level of the pressurizer, although it 5
is obviously something that can be done if you drop below the 6
saturation temperature-pressure curve.
7 But I just don't think that people really thought 8
about it.
9 Q
Well, one of the points that I think has been raised 10 as a result of the accident at Three Mile Island is possibly 11 that the operators, during accidents, were placing too much 12 reliance on pressurizer level as an indication.
()
13 A
I think that is obviously the case.
14 O
And so it seems that the feeling was that at the time 15 pressurizer level was one of the most essential indications 16 available to the operator.
17 A
It tells you that you've got water, yes.
is O
And yet here we have a rather stange response from 19 pressurizer level, one that doesn't seem to be consistent with 20 the other principal parameters.
And yet no one, as far as I 21 can tell, seemed to be concerned that the pressurizer responded
()
22 in this way.
23 A
I think that is probably true.
And I would 24 respectfully suggest that you may perhaps not raise the same Am-Federal Reporters, Inc.
25 question, had it not been for Three Mile Island.
l l
33 jl 17 l
1 Q
That is very possibly true, and I recognize that.
2 A
It is the hindsight.
3 Q
Hindsight is a wonderful thing.
)
~
4 A
But I don't think that any of us really gave it that 5
kind of thought before.
6 Q
On page 344 of the transcript, you make a statement 7
that the transient was completely terminated at about 15 min-8 utes.
9 Do you recall what the basis was for that statement?
10 A
I think the basis for that statement was really that 11 is what I had been told by the folks out in the region.
I 12 think that by this time -- well, I'm not really sure -- the IllI 13 one thing that this did was to put enough water in the second 14 steam generator, to give you the additional cooling.
And I 15 believe that by this time the manual block valve had been 16 closed.
Therefore, there was no further loss of water.
17 Q
That is why I found that statment to be a little bit la curious, because the PORV wasn' t shut, the block valve for the l
19 ;
PORV wasn't shut until 20 minutes into the transient.
And at l
20 '
about 36 minutes into the transient the pressurizer level went 21 !
from off-scale high to off-scale low and wasn' t recovered until r\\
x_)
22 some 50 or 60 minutes into the event.
I 23 A
We ll, I think that the thing that people were looking l 24 at -- and I think my response would have been much the same --
Aa-FMwal Reprters, inc.
j 25 was that at the point where we got the second aux feedwater
34 jl 18 1
pump delivering at full flow, that there was really no further 2
concern for additional loss v2 coolani _Ed overheating of the 3
core -- I don't remember what the temperature was at this point l' 'i
\\/
4
-- and how fast this brought down.
I can ' t give you that.
5 But, of course, you know unless the level in the 6
reactor vessel -- and I don't think any of us really thought 7
about it being terribly low at that point -- unless the level 8
was down close to the top of the core at the time you got this 9
second pump started, you've got some boil-off time before you 10 uncover the core.
And I think basically that is what we were 11 thinking about.
12 O
On page 350 of the October transcript, and again on
()
13 page 183 of the November transcript, Mr. Ebersole raises a 14 concern about what would have happened if the plant had been 15 operating at 100 percent power, at a higher power level.
And 16 I believe you make a statement to the effect that you didn't 17 feel it was possible or likely for this particular incident to is occur at that high a power level.
19 What was the basis for that conclusion?
t 20 A
Well, at this time they didn't have the main turbine 21 rolling.
They were dumping steam through the back end of the
-i/,i 22 condensor, through a bypass valve.
They were operating on wJ 23 start-up feedwater flow, rather than full feedwater flow.
24 The conditions, if they had been operating at full Ace Federal Reporters, Inc.
25 power, would have been quite different.
And the point was not
35
@l-19 1
so much that it couldn' t happen, but that there would have been 2
different systems in operation.
And a trip, under these same 3
circumstances, would not have gone in the same direction.
O 4
Q Well, if they had a turbine trip and, say, they had 5
been operating at 100 percent power and had had a turbine trip, 6
wouldn't they have followed basically the same scenario as what 7
happened here, assuming that the relay was missing and that the 8
pressurizer level increased, and the precsure increased, so 9
that the PORV opened and short-cycled.
10 A
It is not clear whether they would have or not.
And 11 I would have to look into this a little further.
Again, at the 12 time, I probably had a better rationale than I've got at the p
13 moment.
Q 14 I believe that the parameters which triggered this i
15 feedwater rupture, or steamline rupture --
16 Q
Steam and feedwater rupture control system?
4 17 A
Yes -- would not have been triggered if they had been 18 operating.
19 0
Well, the event that triggered the steam and feed-20 water rupture control system was a spurious trip anyway.
21 A
Yes, but after it trips, what happens?
I think there
()
22 are some different things that would have happened if they had 23 been on main feedwater instead of the start-up feedwater
-24 system.
Ace Federd Reporters, Inc.
25 I can't really give you a direct answer to your l
t
jl 20 36 I
question.
I just don't remember now.
2 O
Is there any way that you could reconstruct what the 3
rationale was for that particular conclusion?
4 A
I think, probably at this point, the only way I 5
would be likely to would be to go back and talk with Tambling 6
and those who have supplied the information to me.
I presume 7
you have already talked to them, or intend to talk to them, so 8
you may get a better answer from them than you can get from me.
9 I just can't answer that.
I don't know.
10 0
I would like to ask you a couple of question concern-11 ing some of the specific parts of this particular scenario.
12:
And I think we have already discussed these, at least to some
( );
13 extent.
But I would like to just make sure that we have a 14 complete record.
15 As a result of your review of this incident at the 16 time that it occorred, and as a result of the briefing that you 17 attended that Mr. Mazetis gave, did you realize that steam is formed in the reactor coolant system during the transient?
19 A
I can't really say what my thoughts were on that 20 basis.
Obviously, reading this transcript, I did make the 21 statement that boiling had occurred.
And I am well aware that
()
22 if boiling occurrs, there would be some voids formed in the 23 reactor vessel.
24 I think that, based on the overall timing of the Ace Federal Reporters, Inc.
25 event, that our cenclusions -
and I can't remember now how l
l
jl 21 37 1
_ these were reached -- it strikes me that there were some people 2
who did. sore calculations to try to determine how much volume 3
may have been lost, that it wasn't very significant.
4 Q
Do you recall who made those calculations?
5 A
No, 1 don't.
l 6
0 What significane would you assign to the fact that 7
boiling or void formation occurred in the reactor coolant 8
system.
And I recognize this is going to be colored an awful 9
lot by the TMI accident, but trying to separate what you know 10 now, as opposed to what you knew then.
11 A
Well, I think that there was no question that I would 12 have recognized, and did recognize, that the boiling that
)
13 occurred would displace some water out of the reactor vessel.
14 And the only place that can go is up to the pressurizer.
And 15 I think that is one reason that I wasn't terribly surprised to 16 see some increase in pressur1.
level.when you weren' t feeding 17 any water in.
IB Q
What significance would you have assigned to this I9 fact, that the pressurizer level would be increasing while 20 boiling was taking place in the reactor coolant system?
21 A
Just what I told you.
22 O
Would that have been of part icular. concern to you, 23 that pressurizer level was going up as a result of void forma-24 tion in the reactor coolant system?
- Ace Federd Reporters, Inc.
25 A
I don't think that it would have been of partic21ar i
$122 38 1
concern, depending upon the amount that it goes up.
What you 2
are really concerned with is the overall coolant inventory in
'3 the reactor vessel.
And as long as you don't have an indica-
- f'r
(/
4 tion that you are losing enough to give you reason to believe 5
that you're going to uncover the core. then I don't think you get that concerned about it.
7 And I think, in this case, we did not have that much 8
concern.
XXXX 9
BY MR. FOLSOM:
10 0
Where would you get the indication that the core 11 was in any way threatened by loss of coolant?
12 A
Well, you just know intuitively that if you don't
/'T 13 keep water over that core --
V 14 Q
But how do you know water is over the core?
15 A
Well, that is the $64 question at this point.
You 16 know that water was over the core to start with; there is no 17 question about that.
You know that you lose some water through 18 this valve that was stuck open, and the quantity -- you don't 19 really know how much that is.
The valve opened, closed, opened, 20 closed.
g 21 You know that you don't itse any water from over the
- - ( )
22 core until you reach the point where the temperature and 23 pressure are such that boiling can occur.
24 O
Which is the fact here?
Ace Federd Reporters, Inc.
l 25 A
Yes.
But, now, how long can that take place before
39 jl 23 1
there is a boil-off rato and you can calculate what that is?
j 2
And I think that, intuitively, the people who were involved 3
here were not boiling that rapidly, so we have still got water rm.
(-)
4 down there.
Yes, it is boiling, but it is still there.
5 To give you an actual measurement, no, there is no 6
way.
I think there is no question that that is one of things 7
from the Three Mile Island event that needs to be looked at 8
pretty carefully.
We need to have a way of having firm informa-9 tio'n as to what the liquid level is in the reactor vessel, aside 10 from what is in the pressurizer.
t XXXX 11 BY MR. HEBDON:
12 Q
Do you feel that that same conclusion could have been
('^)
13 reached as a result of the incident at Davis-Besse?
x_/
14 A
We ll, I think it is obvious that it could have been 15 reached.
It is also obvious that it wasn't reached.
- Now, 16 20-20 hindsight -- again, I don't think that I would charge 17 the fact that it wasn' t reached to negligence on anybody's part.
18 I don't think that anybody intentionally overlooked the fact 19 ] that this might be the case.
But, obviously, we did overlook 20 '
it.
21 Q
Do you recall ever discussing this incident or any
()
22 of the issues raised by this incident with a Mr. Kelly or a V
23 Mr. Dunn or any other employees of B&W?
l 24 A
I don't believe that I had any such discussions,
Ace Federal Reporters, Inc.
25 unless they were in the form of a meeting with NRR.
l
jl 24 40 1
Q But you don't recall any specific discussions?
2 A
No, I don't.
3 0
I would like to go on now and discuss an incident 0'.
4 that occurred at TMI on March 29th, 1978.
This is an incident 5
that I believe you referred to earlier in our discussion.
6 Prior to March 28, 1979. prior to the TMI accident, 7
what knowledge did you have concerning an incident that 8
cccurred at TMI on March 29th, 1978?
9 A
Well, that event was reported by means of what we 10 call a preliminary notification, which means that our Region 1 11 of fice had had a report from the Licensee, and that was the 12 initial report which talked about a reactor trip and subsequent O
13 bl wdown with the emergency system actuation.
14 They described the cause of the event as the loss of 15 a vital bus.
The reactor tripped, and then because of the 16 electromatic relief valve was supplied from this same vital 17 bus, the electromatic relief valve failed open on loss of power, 16 '
and that resulted in a depressurization of the primary system.
19 i I think the next information that I got about the i
20 event was a memo which was written by Dan Sternberg.
And I've 21 forgotten now to whom he addressed it.
It was written to me
()
22 through his section chief, and he then pointed out the PN that i
23 I just mentioned.
24
. And the question that was asked was -- it was Ace Federal Reporters, Inc.
25 requested that the adequaqr of the design approach -- that is,
jl 25 41 1
the. valve f ailing open on loss of control power -- be reviewed 2
on an expedited basis for B&W facilities in general and Three 3
Mile Island in particular.
4 The question really relates to is the design for this 5
system adequate?
6 In response to that memo, I had a member of my staff
-7 check into it; and I can't tell you all of the places that he 8
might have checked, but he wrote a memo then, for my signature, 9
to Mr. Brummer, which in essence says that the failure of the 10 valve in the open position was covered in the FSAR.
And since 11 it was part of the application which had been reviewed by NRR 12 '
previously, that desig: was an acceptable design as far as we C
on,~\\.3 13 were concerned.
And that was the way the request was answered.
s s t.4 14 Q
Do you remember any of the details of the incident 15 itself?
16 A
Not really, no.
17 Q
Now, you mentioned this memo that Mr. Sternberg is wrote concerning the design of the electromatic relief valve.
191 Is the review of such issues a normal function of your job?
2c A
Well, I am not quite sure what you mean by the ques-21 tion.
It was a normal function of my job to resolve questions n
-( b 22 of that kind that were raised by people in the field.
23 O
So it was normal for Mr. Steruccrg to send such a 24
_ memo to you for resolution?
Ace Federal Reporters, Inc.
25 A
It is a little bit surprising that Mr. Sternberg sent j
f
$1 26~
I it to me directly, because normally this would be something 2
that would come over his branch chief's signature.
But it is 3
not that unusual either.
4 Q
But it was sent through his branch chief?
5 A
Yes.
Right.
Not through his branch chief, through 6
his section chief; Mr. McCabe was the section chief.
7 Q
Well, I don' t think it's worth going to into in 8
great detail, but Mr. McCabe was acting branch chief at the 9
time Mr. Sternberg was the acting section chief.
10 A
No, he was acting chief of the Reactor Projects 11 Section, not branch.
12 Q
And Mr. McCabe was the acting _ branch chief of the
()
13 RO&NS Branch.
14 A
You're right.
I apologize.
15 0
That's not a big point, obviously.
But it was Pormal 16 for you to review such issues?
17 A
For my office to review them, yes.
18 Q
In Mr. Sternberg's memo, he mentions that it does not 19 ;j appear that the valve is safety-related.
Did you give any i
-20 consideration to whether or not the valve should be safety-21 related?
p)
(_
22 A
No, I did not.
The determination as to whether or 23 not these things e safety-related or whether they belong to i
24 systems that are specified as being safety-related is one that
(
l Ace Feded Reportee., enc.
{
25 is, again, made by NRR.
And they had reviewed these systems.
I i
43 jl 27 1
And I think it is f air to say that none of the plants 2
that had this kind of a setup had these valves listed as 3
s afety-re late d.
I can't vouch for that, but I think that, in
^(3
/
4 general, these valves, as well as the feedwater system and the 5
steam system, are not typically listed as safety-related sys-6 tems.
7 Q
Then, as I understand it, you didn't give any indica-8 tion or any consideration to possibly sending a memo to NRR 9
recommending that this valve be included in the list of safety-10 related systems?
11 A
No, I don't think that we did that at that time.
I 12 think that there may have been an occasion since that time to
()
13 have suggested that it might -- ought to be a safety-related 14 valve.
But that I sent such a memo, no.
15 Q
Would that have been before or after Three Mile 16 Island?
17 A
I suspect it was af ter, but I don't really remember.
16 Q
Now, you mentioned that Mr. Sternberg's memo was l.
19 j referred to someone on your staff who reviewed the issue?
h 20 '
A Yes.
21 Q
Do you know if any contact was made with anyone in
(')
22 NRR?
23 A
I am not positive whether there was or not.
But I 24 would suggest that typically there.would have been some con-Acs Feder:J Reporters, Inc.
25 tact, at least with the project manager.
But I can't, at this
jl 28 44 1
point, say positively that that was done.
2 O
You don't know of any contact, and you didn' t make 3
any contact yourself?
(~
\\
4 A
I did not make any myself; definitely not.
5 0
What, in your mind, or what did you think should he a 6
been done with this particular memo?
What did you think at 7
the time should be done with the memo?
8 A
From Mr. Ste rnberg?
9 0
Yes.
10 A
I felt that it should be answered and that it should 11 be answered on the basis of the questions that he raised, which 12 is what I instructed Mr. Woodruff to do.
And it was answered f) 13 on that basis.
v 14 Q
Now, Mr. Woodruff prepared a response that you signed 15
-- and it is a memo -- on May 3rd, 1978.
16 A
Yes.
17 Q
In that memo he references a section of the FSAR, 15 l Section 7.4.1.1.6.
Did you review that particular section of l
19 the FSAR in the course of concurring in this memo?
I 20 A
I don't recall whether I specifically did or not.
I 21 '
believe that Roger brought that in for me to read and that I i )
22 looked at it.
I am just not absolutely sure.
23 0
I have here a copy of Section 7.4.1.1.6 of the FSAR 24 for Three Mile Island.
And if we could. I would like to take AwFL J Reonm, lm.
[
25 a moment and have you read the particular section that refers
jl 29 45 1
to the electromatic relief valve.
2 And let's go off the record for a moment.
3 (Discussion off the record.)
g-V) 4 MR. HEBDON:
Let's go back on the record.
5 For the record, Mr. Seyfrit has been reading from 6
Section 7.4-3.
Excuse me, from page 7.4-3 of the FSAR for Three 7
Mile Island.
8 BY MR. HEBDON:
9 O
In reading this particular section, do you read it.:
10 all to imply that the PORV is assumed to fail open as part of 11 the safe shutdown analysis?
12 A
Yes.
I think that it is rather clear that it talks j
13 about the fact that in the event that the relief valve were to 14 f ail in the open position, so it recognizes that it might fail 15 in the open position.
16 O
Do you read in that any implication that it must fail 17 in the open position?
la A
No.
I9 Q
But isn't the discussion there, concerning the 20 redundancy of the function of relieving reactor system pressure, 21 based on the assumption that that valve will fail open?
22 A
That is true.
But by the same token, if they recog-23 nize that it is going to fail open, it is recognized that it 24 may fail open and still have the opportunity to control the Am.FWereI Rmorters, lm.
25 pressure by cycling the manual block valve.
i a
i
ji 30 46 1
By the same token, you have the option of closing the 2
manual block valve to serve the function of a closed valve if
/,
3 that is the position it ought to be in.
So I think that both 4
situations are covered.
5 Q
But if the valve, if the PORV were changed to fail 6
shut, wouldn't you lose the capability to control pressure by 7
cycling the block valve?
8 A
Yes, that's true.
9 Q
So then wouldn't that seem to indicate that the valve 10 was supposed to fail open; or there was an implication, or even 11 a requirement, that the valve fail open as part of the safe 12 i shutdown analysis?
./m
()
13 A
No, I don't think that is necessarily true.
14 0
Well, if the valve were changed and designed to f ail 15 shut, how would the redundant capability to control pressure 16 be provided, since cycling the block valve would not longer 17 have any e f fect?
l 16,
A Well, you still have relief valves.
You have code l
M f safety valves that would operate it.
I 2C ji O
But the operator can' t control the code safety valves,
t 21 A
That's true.
,m:
i,,)
22 0
The only way they would get involved is if the i
23 pressure reads their lift point.
24 A
That is true, but then they would close again and l
.Am.FMer J Reporters, inc.
25 then cycle back and forth there, so there is a backup to a I
l l
^
r 47
-jl 31 1
degree.
But I don't think this was intended to mean that that 2
was the only purpose fot that discussion.
That may be your 3
interpretation; it is not mine.
4 Q
Were you aware that the utility, in fact, later 5
changed the PORV to fai3 shut on. loss of power?
6 A
No, I'm not aware of that.
7 Q
Would that normally have been something that would 8
have been brought to your attention?
9 A
Not necessarily.
And it may well have been brought 10 to my attention at the time.
I just don't have a recollection 11 of it, but I don' t remember it.
12 l The reason I say that it would not necessarily have
()
13 been brought to my attention is the fact that the Licensee may 14 make changes in design to his facility without prior Commission 15 approval so long as he does a safety review in-house and 16 determines that it doesn't substantially change what has been 17 described in the SAR.
18 This valve -- going back to the question of is it 19 'i safety-related or not? -- had not been so designated before,
20 and that makes it easier for him to make changes, because he is 21 not really changing a " safety component of his system," which
()
22 may or may not be a good idea, but nevertheless that is sort of 23 the way things go.
24
-Q Well, that was the other point I wanted to get back Am-Federst Reporters, Inc.
25 to, the functioning of this valve to permit a reduction, or to i
48 ji 32
[
]
permit controlling reactor coolant pressure, is discussed in the 2
safe shutdown analysis for this particular system.
Aren't 3
components that are involved in the safe shutdown of the plant 4
normally safety-graded?
5 A
If they are required for safe shutdown of the plant, l
6 that is true; but I don't think that what you're reading here 7
would necessarily imply that this valve was required for a 8
There are other ways of achieving safe shutdown 9
other than by use of that valve.
10 Q
The particular section, the opening sentence of the 11 discussion on the electromatic relief valve control says,
Th e
)
12 electromatic relief valve is required to ensure the capability
(')
13 of controlling reactor coolant pressure."
14 Now, that would seem to indicate, to me, that the 15 valve is required for safe shutdown.
16 A
I think you're reading into that something that is 17,
not there.
But I don' t want to get into an argument with you.
I l
is l I would suggest that perhaps you ought to talk to the NRR folks i
i.
who review these.
I don't believe that that -- that this is
'9 rl i;
20 l necessarily a discussion of a safe shutdown capability of the 21 plant.
This is a description of the pressurizer controls, and
.()
22 it talks about those things that are available.
But it does 23 not, in my view, necessarily say these things must function, as 2.
described here, to provide safe shutdown.
hm-FMeral Rmorters, lx.
This merely says here are some things ' and this is the !
25 I
jl 33 49 I
way they function, and this is what they were designed to do.
2 But it doesn't say they are required for safe shutdown.
3 o
O Again, I guess the thing to do would be to discuss V
4 4
this with NRR, but I think it should be noted that the heading 5
of Section 7.4, of which Section 7.4.1.1.6 is a part, is titled 6
" Systems Required for Safe Shutdown."
And that would seem to 7
indicate that these are the systems that are, in fact, required 8
for safe shutdown.
9 A
Some of those are backups for other systems in case 10 something else doesn't work.
They are not all required at the II same time.
12 O
Let's go on.
(,
13 At the time that you prepared your response, do you Id recall what your understanding was with respect to the indica-15 tion of PORV position that was available to the operator?
16 A
I don't think there was any specific position indica-17 tion available to the operator.
And the devices that were used M
at that time to determine whether or not there was leakage i
" ! past the valve or temperature indications in the downstream h
d 2C piping on the discharge side of the valve --
21 Q
Did you feel that those indications were adequate?
22 A
At the time, I must have felt that they were adequate 23 or I would have asked that they be changed.
I had no reason 24 to belief otherwise at that point.
l Ace Federd Reporters, Inc.
25 Q
Were you aware that some additional indication was I
50 ji 34 1
eventually provided on the PORV at Three Mile Island?
2 A
I was aware after the fact.
I don't recall that I 3
was made aware of it at the time the change was made.
I learned p
Ns 4
this during the deposition for the Kemeny Commission.
- Again, 5
that is not to say that some piece of paper might not have 6
crossed my desk that said it was being done.
But my memory is 7
just not that good.
8 Q
Were there any other aspects of the March 29th, 1978, 9
incident at Three Mile Island that are relevant to the March 28 10 March 28th,1979, accident at Three Mile Island?
11 A
Without reviewing the details of the earlier incident, 12 I am unsure of the documents in that question.
()
13 Q
To your knowledge.
A Well, yes, didn't the original PNs say something l
14 I
15 l about the loss of feedwater?
No, it was the reactor coolant is pump.
I don't see anything else in the brief description that 17 ;
I have here that really triggers anything.
The depressuriza-is tion was, of course, because the valve was open, i
- 9 Q
One last question on this particular incident at g
0 20 i Three Mile Island:
Did you give any consideration to the 21 possible generic implications of PORVs failing opin on loss of
()
22 power or any other aspect of this particular incident?
23 A
Well, yes, I think we did.
And that was, while not 24 specifically stated in the answer, I think implied we reviewed
'Am Federal Reporters, Inc.
25 other B&W plants, and they all had essentially the same kind of I
i
jl 35 51 1
a statement in them regarding the fact that there had been 2
consideration for the valves failing in the open position.
3 Q
Did you give any consideration or did you review the
(~%
kJ 4
indication that was available to the operators at other B&W 5
plants?
6 A
No, we did not at that time?
7 Q
Did you at any time?
8 A
No.
It is not a question that was ever raised in our 9
minds; frankly, we always assumed that the temperature indica-10 tion in the tailpipe would be sufficient to tell them that the 11 valve was either open or leaking through.
And, indeed, there 12 l were some limitations, and they weren't supposed to operate
({)
13 with significant leakage in that valve.
14 I understand, at Three Mile Islatid, that the valve 15 had been leaking for some time, which perhaps contributed to 16 their problems ; I don' t know.
17 1 Q
I would like to go on and ask you some questions that 1
is are considerably more general in nature, and they particularly i
H i relate to the relationship between I&E headquarters and I&E 20 regions, for example, or NRR and various other organizations.
21 li What is your general perception of the relationship
()
22 between I&E headquarters and the I&E regions?
23 A
Well, having been in both places, I guess I have a 24 fairly broad perspective.
But I think that there tends to be, Ace Federd Reporters. Inc.
25 at times, some degree of adversary relationship between the i
52 jl 36 1
field offices and headquarters.
But I think that is a f airly 2
minor thing.
3 overall, I think the relationships have been pretty
\\_/
4 good.
I think that probably personalities turn out to be very 5
important in the relationship between the field offices and 6
headquarters, and it depends a great deal on who the individuals 7
are that are making the contacts back and forth.
8 I don't perceive of there being the kind of tension 9
between the field and headquarters daat really gets in the way 10 of doing the assigned jobs for either the field or headquarters.
il l Q
Would you briefly describe the I&E Vendor Inspection i
12 l Program?
()
13 A
Well, the Vendor Inspection Program was instituted 14 a few years ago and has been designed to be largely one of 15 looking at certain vendors -- and by " vendors," we mean those 16 people who supply equipment or services to the utilities ;
17
" vendors" include the nuclear steam system suppliers who design la j the plants, the architect-engineers who design and balance the ll 17, plant; and even in some cases the constructors of the plants, 0
20 g but that is generally handled from the field offices directly.
21 It also includes the suppliers of large pieces of equipment, em
(
22 the people who build the reactor vessels, for example, steam 23 generators, the large pumps, motors, what have you.
24 But that program, unfortunately, was conceptualized Ace Federal Reporters, Inc.
25 and instituted as one primarily of checking the implementation l
i
jl 37 53 1
'of quality assurance programs.
It was not designed to -- and 2
in most cases has not been used to really look at the quality 3
of materials that flow from the vendor or from the architect-4 engineer, or from the nuclear steam system supplier, but rather 5
to-look at his system for controlling these things.
6 MR. HEBDON:
Why don't we go ahead and take a break 7
at this point?
ond t.4 8
( Recess. )
9 10 11 12
'13 14 15 16 17 l
i I6 I
I9 ;!
i I
-1 20 l 21 22 23 24
- Ace.Federet Reporters, Inc, 25
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I i
54 fr-6812 g
MR. HEBDON:
Let's go back on the record.
3-5 310-1 BY MR. HEBDON:
-2 3
Q Is there any mechanism by which the vendor 4
inspectors can' exchange information with the inspectors who are 5
involved with the plants who have equipment that is manufactured 6
by a particular vendor?
7 A
Well, there is a mechanism by which this can be 8
done.
Unfortunately, I don't think that in the past it has been 9
done as well or as often as it ought to be.
Since the 10 vendor inspection program now hr, run out of my region, I am 11 attempting to make some changes in that area and we are indeed 12 at the point doing more of what I would call reactive inspections
()
13 than programatic inspections.
That is, we are reacting to 14 problems that are raised by the regional offices or by 15 information that comes to us from whatever source.
And we are 16 attempting to become a little bit more oriented toward looking 1-at the p10 duct that comes out of these organizations that we 18 inspect.
It is a difficult line to walk.
I don't think that 19 it is appropriate for the NRC to be the acceptance inspectors, 20 if you will, for the utility, and therefore I don't want to see 21 us getting into the position of having to give our stamp of
()
22 approval before something gets shipped.
I don't think that is 23 an appropriate stance for the NRC.
~
24 On the other hand, I think that we do need to look I
AeFWeral Rmomrs, le.
l 25 more deeply into whether or not the a;tual work in terms of i
55 als-2 i
fabrication of components is performed adequately or not 2
performed adequately.
Whether indeed the designs that are 3
put out by the people that are doing the designs are (sh/
4 appropriate, whether they have considered the proper design 5
principles and so forth.
We don't have right now the kidd of 6
people that we would need in any great detail, but I think we 7
can make an effort in-that direction and improve our work.
8 Q
Then as I understand it, your involvement with the 9
vendors has historically been more in the context of the 10 physical products that they produce rather than any consideration 11 of their design analyses?
12 A
Well, I think it is not even that.
I think it has
()
13 been more in the system that they use to produce their product, 14 whatever it is.
As you know, 10 CFR 50, Appendix B, which 15 describes the kinds of quality assurance program that people 16 should have.
That basically has been what has been what we have 17 inspected against the quality assurance program and its 18 I implementation.
19 Now, you can have on paper a tremendous quality 20 assurance program.
And if all you do is look at paper, you can 21 say, " Gee, they are doing this in great shape."
But, you go 4
l
()
22 and look at the weld that was made using that progrem, and it 23 may be a lousy weld.
That is the kind of thing -- the 24 difference.
Au FMerM ReporMrs, lm.
25
-Q Now, when you are talking about this quality I
56 010-3 1
assurance program, would that quality assurance program 2
also cover such things as design analyses?
3 A
- Yes, h' ')
4
-Q So, it would consider that sort of thing?
5 A
That's right.
6 Q
By quality assurance, then that is a broader context 7
than just quality assurance of a physical component?
8 A
That is correct, yes.
And, indeed as I indicated 9
earlier, we do look at the nuclear steam system suppliers and 10 the architect engineers.
And, of course, since their product 11 is primarily a design, what we are looking at and what we have 12 traditionally looked at is the quality control or quality
()
13 assurance system that they use in terms of internal reviews of 14 design and that sort of thing to make sure that the guy that 15 does the design originally isn't the one that sides off as 16 approving the design, but it gets reviewed by somebody else, 17 Those kinds of things.
18 Q
Would that inspection also include such things as 19 how the organization respor.ds to concerns that are raised by 20 peopic within thu organization?
i 21 A
It doesn't lend itself specifically to that.
And i
()
22 one of the problems is that you don't really always know when 23 somebody within the organization has raised a question, and it 24 is not clear to me how our inspection program would necessarilyl 3
- ASFaferd Reprters, lrm.
25 uncover that kind of thing to the extent that we are aware that!
i l
I
57-somebody has raised the question.
We may look into the
)l0-4 i
2 resolution of it, but we don't really become aware of those things usually unless somebody tells us that it has happened.
3 1N-4 O
Would your inspection include the licensee's 5
procedures for complying with 10 CFR, Part 21?
6 A
Not in the vendor inspections.
Well, yes, excuse 7
me.
I was thinking of a different part.
Yes, you are talking about the business of whether or not known deficiencies that 8
might lead to problems are reported to us and so forth.
9 10 Q
Yes, that is correct.
11 A
Once again, to the extent that we are aware of the l
known deficiencies and the circumstances under which it is 12 l
13 reported.
We would look into it, yes.
()
14 Q
So, if the deficiencies and reporting under Part 21 15 were to come to your attention, that would be something your 16 inspectors would be involved with?
17 A
Well, it would not always necessarily fall to the 18 vendor inspection program to look at it, but it might be one of 19 the other regional offices that would look into it.
20 Part 21, if it dealt with the licensee, for 21 example?
fs) 22 0
What if it dealt with he vendor?
~
23 A
If it dealt with the rendor, that should come to us.
24 Q
Are you aware of some concerns about a possible 2ce-FMerd Rgane ;, lrm, 25 Part 21 violation that were raised by Mr. Creswell of Region IIf?
t
58 010-5 i
A I am not aware that he raised any questions 2
about a Part 21 violation; no.
3 Q
Were you aware of a meeting that was held at B&W Cs]
4 in February of '79 that included a.Mr. Kohler and Foster 5
from Region III, and I believe a Mr. Anderson from your 6
region?
7 A
I think that probably is the meeting that Mr.
8 Anderson attended.
I am only aware that he was present at the 9
meeting and actually let me see if I can remember what I've 10 been told about this.
11 Mr. Anderson had a meeting with Kohler and Foster 12 prior to their discussions with the B&W folks.
I don't think
()
13 that Anderson actually participated in the discussions with 14 B&W until they had a close-out interview, and I think he sat 15 in on that.
I am not sure of the details, but I believe that 16 is the way it was.
17 Q
Are you aware by any chance of why Mr. Anderson 18 was there?
Do you know if he was sent there specifically 19 because of that meeting or was it coincidental or what?
20 A
It is my understanding, and I really should know 21 this better because he was working for me at the time.
When fs(_)
.22 was that meeting?
23 Q
It was in February of this year; February of
'79, 24 A
His brr.nch chief, I believe, ask;3 him to go down l
Ace-Federti fleporters, Inc.
25 there because we had been told that Region III was sending some
59 D1c-6 inspectors into B&W and he was asked to sit in with them and j
discuss with them what their purpose was in going to the 2
3 meeting so that if there were things that we needed to follow up on he would be aware of what those were and basically, that 4
is the reason that he was there.
5 6
Q What is your perception of the relationship between I&E and NRR?
7 A
Well, I think again there is perhaps a pretty strong 8
9 adversary relationship between I&E and NRR on some subjects.
10 I would have to say that I think there is a concern for guarding 11 each other's turf, to some degree.
I think there are sometimes 12 perceptions that that organization can't do it as well as this
()
13 organization, whatever that is, and that there are some 14 difficulties in communicating with each other, particularly 15 when it comes to working on specific problems.
I wouldn't 16 really be able, I think to comment on why this is so, other than 1
my own perscnal be).3fs, and I think it perhaps is a problem 18 that goes back a great number of years and that it probably has 19 again a lot of personality problems associated with it that 20 the difficulties, the tensions between the two organizations 21 are more acute as far as certain individuals are concerned,
(])
22 than they are with others.
23 Q
Does I&E headquarters review plant procedures?
24 A
Not as a general rule.
The procedares generally are l OwFMerd Rgenen, inc.
25 reviewed by the regional offices.
Back several years there was !
I
60 31c-7 i
an attempt to do something in the way of reviewing plant 2
procedures at the headquarters level and the regional offices 3
were requested to send in copies of certain plant procedures
(_s) but that was not an all out effort, certainly, and it was more 4
5 to try to look at consistency from plant to plant.and see what 6
kind of quality these procedures were more than anything else.
7 Q
What was the conclusion of that effort?
8 A
I don't t hink it ever concluded.
The effort that I 9
am talking about took place just prior to a fairly substantial 10 reorganization within headquarters I&E, I've forgotten which 11 iteration it was.
I believe they were going from regulatory 12 operation to something else.
I've forgotten.
But the folks 13 who had been doing that wound up with some different assignments
(}
14 and I think that just sort of went by the boards and nothing 15 much further was done with it.
16 Q
Do you recall who was in charge of that particular 17 effort?
is A
I think Bob McDermott was doing a great deal.
He 19 wa s working for I&E or Compliance or whatever we were at that 1
20 time.
I think as I recall, Bob had one group with reactors and 21 Trank holan had th( other, and the two of them combined doing
()
22 most of the work, as I recall.
23 Q
What is the difference in your inspection procedures 24 and inspection philosophy for safety related versus nonsafety l
A&FMerel Reorters, im.
25 relate d systems?
I I
I l
61 010-8 A
Well, I think that the major difference is that we j
2 1 ok a lot harder at the systems that are defined as being 3
safety related than we do those that are not certified.
O) k-For example, in terms of something that I could 4
5 put some numbers to, start-up procedures, the preoperational 6
testing procedures.we review in detail.
I believe all of the 7
start-up procedures relating to safety equipment we review 8
only a small percentage of those that are marginally related 9
to safety and only assure that procedures exist for others to that are even farther removed from the safety systems.
11 So, in general it is a matter of the depth with 12 which we look at it.
()
13 0
What is the basis for deciding that a system is 14 safety related or it is not safety related?
15 A
I am not sure that I can articulate that accurately.
16 This is something that the licensee and NRR agree upon, 17 basically.
But in essence, any system that can prevent or 18 mitigate accidents are considered to be safety related.
I 19 don't know whether that gives you the kind of answer that you i
20 are looking for or not.
21 Q
That is fine.
I
()
22 Does I&E ever become involved with the determination 23 of whether a system is safety related or not?
j l
24 A
Only in the sense that we may question whether or i
Su-FMerd Rnmrters, inc.
25 not scmething ought to be safety related or ought not to be, I l i
62 010-9.
j suppose.
I can't think of any case where we save gone in that 2
direction, but we may make suggestions or question NRR's 3
decisions and ask that something be reviewed in perhaps a p)
\\-
different light.
4 5
Q How frequently, from your experience, has I&E 6
recommended that the decision that a system is nonsystem 7
related be reviewed and possibly reconsidered?
8 A
I wouldn't really have any good idea.
9 Q
Would you say it is frequent, infrequenti often?
10 A
I would say occasionally would be the best descrip-11 tion.
It is not a terribly frequent thing, but it is not I
12 unheard of.
()
13 BY MR. FOLSOM:
14 Q
Can you recall any instance?
15 A
Well, I think that there have been some questions.
16 Let me preface this by saying I am not sure that what I am 17 about to say has been formally recorded as a recommendation or 18 not, but there have been some questions raised about the 1
19 requirements that relate to the steam and feed water system in 20 pressurized water reactors, particularly when you are looking 21 at the failure of steam generator tubes which then gives you a
()
22 path between the primary and secondary system.
And yet, to 23 deal with that kind of an accident, we do rely on the operation I
24 of some secondary systems which have not been designated as Ace Federal Reporters, Inc.
25 safety related.
And in my view I think we perhaps ought to take i
I
63 31e-10 1
another look at that and we have had some discussions along 2
those lines.
3 Another one has to do with some control systems and O
4 I can't really pin this down specifically, but there are in some 5
Pressurized water reactors some control systems that are 6
associated with the actions that are taken at certain pressure 7
levels that have not been designated as safety related.
And 8
again, there is a question that perhaps they ought to be.
9 They are not redundant at the present time, and maybe they should 10 be redundant.
I've forgotten the specific details, but one of 11 my inspectors in Region IV has raised this question with a 12 licensee.
()
13 Q
What has been the probability of success of people 14 who have raised issues about systems that they felt ought to be 15 safety related?
16 A
I don't know that I can give you any kind of numbers.
17 There have been some successes and some failures, I think, but 18 I couldn't give you hard evidence in numbers.
19 0
Well, I didn't really mean down to a decimal place, j
20 but is it a 50-50 chance, ten percent, ninety percent success?
21 A
I would say that it is certainly less than 50 22 percent, but I think there is a good reason for that.
I think
)
23 that in general most of these systems have been pretty thoroughly i
24 reviewed and the fact that I, an inspector out in the field,
' Ace FWerd Resmners, lnc.
25 raised the question about whether something should or should not i
l 64 clo-ll i
be safety related.
I am not sure that I, as that individual 2
inspector, has the same degree of knowledge about this matter, 3
this system that we're talking about, as the people back here
(')
k/
4 who have spent a lot of time reviewing it.
And they may have 5
already considered the kinds of things that concern this 6
individual and still concern it.
7 They decided it was okay and obviously he is not
'8 going to win, he is not going to have his position prevail.
9 On the other hand, if it is something that has not been 10 thoroughly considered, if it is truly a new issue, then his 11 chance is pretty good I think.
12 Q
Do you believe that the designation of systems as f^)
13 safety related is applied in a consistent and rational manner?
xs 14 A
I think that it is open to some degree of question.
15 I would be hard pressed to give you specific examples, but I 16 think that there are cases where a particular item or system or 17 function, while it may not of itself create an accident and it I6 may not of itself be able to mitigate an accident, it may have I9 the potential for causing the failure of something that can -- l 2C How far removed do you need to get, and I don't think we have l
I 21 really considered that terribly thoroughly.
()
22 Q
Well, one example that was cited to me by one of 23 the earlier interviewers is the fact that the diesel is a 24 safety related system, but the air start system and the fuel p.?-Federal Reporters, Inc.
25 for the diesel are not safety related.
Now, would it strike yod i
1 r
65 010-12 I
as very surprising if that, in fact, is true?
2 A
It would indeed strike me as surprising if that is 3
true, and I think it is not true.
I)
's -
4 Q
As I said, it was cited just as an example, and we 5
haven't done any particular efforts to verify it.
6 A
I was thinking of another situation, and we have 7
right now a question that you were asking about, raising 8
questions to headquarters that my office has raised which 9
relates to the nozzle design of some boiling water reactors, 10 and whether or not the thermal sleeve and the feed water 11 sparger ought to be safety related.
Right now they are not so 12 designated, but there are some,
~
f' )
13 Let's see how I can explain this:
A weld tnat is i
(/
14 made on the base material of either the piping or the reactor 15 vessel is safety related.
A weld that may attach something 16 else to tnat piping, likewise is safety related.
But a weld 17 that is made in a component that inserts in there like a 18 tnermal sleeve is not. safety related at the present time, 19 and yet, I believe, that there are cases where the failure of 20 the weld on the thermal sleeve could lead to failure of the:
21 pipe that is associated with it.
(')
22 Q
So, this is a failure of the weld then.
Is it 23 associated with two parts of the thermal sleeve?
24 A
Right.
Sm Feco neponus ine.
l 25 Q
So, the weld of the thermal sleeve to the nozzle
?
s.,.
66
'010-13 i
would be safety related?
2 A
That is right.
3 Q
But welds in the thermal sleeve itself are not?
O
- En_ 2-5 4
A That is right.
t-6 5
And yet, I think it may have the potential and we 6
have asked NRR to look at that.
7 Q
Do you know of any other precusor events that are 8
relevant to the accident at TMI?
9 A
I do now only because I read about it in the 10 newspaper.
The event in -- where was it -- Switzerland.
11 A foreign reactor, at any rate.
And that is the extent of my 12 knowledge.
(
13 Q
Do you have any additional information that might 14 be relevant to our inquiry into the events surrounding the 15 accident at TMI?
16 A
No, I don't think that I know of anything.
MY 17 involvement at TMI did not occur until some three days after 18 the accident.
I arrived up there on Saturday, I believe it 19 was.
And so, I was not present during the initial phases of 20 the accident.
I was there while we were still very concerned 21 about the bubble.
I guess most everything I was involved in
(])
22 after that is really not that germane to the inquiry.
23 0
Have we failed to elicit any information in areas 24 that you believe to be in accordance?
Ace Federal Reporters, Inc.
25 A
Well, I don't think that you failed to elicit any, i
67 11c-14 I think that perhaps I might have expanded some, and you j
2 probably have a copy of the letter that I wrote shortly 3
after my first stint at Three Mile Island.
k
4 Q
Yes, I believe this is the letter from you to a 5
Mr. Greer of Region I?
6 A
Yes.
And in that I expressed some of the things 7
that we talked about today in terms of the difficulties of the 8
two organizations working together at Three Mile Island, and I 9
think certainly there must be something done to reduce the to degree of friction to make cooperation easier and the more 11 routine between those two organizations.
12 O
Have you ever written a memo similar to this memo h
13 that you wrote to Mr. Greer concerning this issue of the 9
14 lack of harmony between I&E and NRR?
I don't believe that I have ever written such a 15 A i.
16 memo before.
I never really had specific occasion to do it.
17 I think as I've said several times, and I don't like to make too 18 much of an issue of it, but I think the problem in a great 19 many respects is one of personalities, and I know during my 20 time here at headquarters whether it is false modesty or 21 immodesty or whatever, I really feel that the relationship i
I
(~(y) 22 between I&E and NRR headquarters was working pretty well, In i
23 those contacts that I had, the office as a whole had some i
24 reservations, and while I have not written this kind of a memo Ace Feder:I Reporters, Inc.
7 l
25 in the past, there have been times when I have discussed with I
i
68 1c-15 i
some of the I&E management who may have complained about the 2
actions of one or more of the NRR people, that in my view they 3
shouldn't be complaining.
That NRR was nerforming its
(~)
(
4 functions, and we shouldn't be so doggone sensitive to their 5
doing things that we maybe normally did.'
6 I have had some of those kinds of conversations, 7
yes, but I don't think I ever formalized it in writing.
8 Q
How do you feel that particular problem could be 9
alleviated?
10 A
Well, I think that it is largely one of personal 11 education at the top level.
I think, quite frankly, that a lot 12 of it is going to be resolved by virtue of the fact that the 4lhl 13 head of I&E is a former NRR man, and I think that Vic and I 14 both feel very strongly that this has to come about.
He and I have talked about this matter on a number of occasions,l 15 16 and in fact we discussed it some while we were at Three Mile 17 Island.
It turned out that Vic and I r maybe we ought to go i
i 18 off the record on this point.
l 19 MR. HEBDON:
Okay, letts go off the record.
[
l' 20 (Off the record discussion.)
21 MR. FOLSOM:
Let's go back on the record.
r,
(_,)
22 The'offEthe-record discussion indicated that you 23 feel, and I wonder if this is a fair statement:
l t
24 0
That in the administration of he emergency at Au-FWud Reporters, lm.
25 Three Mile Island there was something less than full exchange i
69
- c1c-16 of information between NRR representatives at the site and j
I&E personnel at the site.
2 A
Yes, I think that is a fair characterization.
3 A
I
\\/
At the time I arrived at Three Mile Island there were a fair 4
5 number of people from I&E and a fair number of people from NRR.
I don't know what these numbers were precisely, but I would 6
guess that they numbered in the twenties or so for each 7
rganization.
8 There was a certain amount of duplication of effort.
9 10 There were a number of people from NRR who were attempting to 11 get operational information from the control room, and I&E was 12 attempting to get that same kind of operational information.
l (em) 13 There were people from NRR who were looking for 14 radioactive material numbers, that is what the concentration of 15 certain isotopes might be in this sample or that sample, and 16 there were I&E individuals attempting to get the same kind of 17 information.
18 So, from that point of view there was duplication 19 of effort.
l 20 I think there also were some occasions where I&E 21 assumed that NRR was taking responsibility for a certain function.
()
22 NRR assumed I&E was taking responsiblity for that function, i
i 23 And as a result, nobody was actually watching it for a period l
24 of time until it was realized that'that was the case, Those Am.FMer-I Reporters. lm j
25 things did happen, and I think there was a period of time when I
f 70 11c-17 i
it wasn't really clear who was in charge of the NRC contingent 2
at Three Mile Island.
3 Q
Let me go back, if I may, to the Sternberg
~N (s_/'
4 memorandum of March 31,
'78. dealing with the incident at 5
Three Mile Island the day before.
6 This is the memorandum that we referred to before.
7 Do I understand it correctly that the response from your office 8
to this memorandum was that NRR had considered the components 9
and particularly the pressure operated relief valve and its 10 back-up valve, and considered that an adequate and safe 11 assembly?
12 A
Yes.
It is my understanding that NRR had reviewed
'3 13 the matter and that they considered this an acceptable design.
b'eJ 14 Q
Now, what I'm driving at, is your office il effect 15 deferred to the NRR preconception of that design?
16 A
I am not sure that I would agree with that 17 characterization.
What we agreed with was the material that was 18 written in the final safety analysis report which describes 19 situctions in which that valve would fail in the open position 20
_and it was recognized that that valve could fail in that open
\\
21 position, but that was an acceptable design,
(
22 Q
Is this per chance a kind of reverse rivalry that 23 isgoingonwhereyourofficedidn'tdoanindependentstudyaf!
l 24 the problem but accepted the FSAR analysis?
Am FMetal Ruorters, lm.
{
25 A
No, I don't believe that is the case, I think that l
1
~
71 Olc-18 1
there is a clear separation between the responsibilities of the 2
two offices, as I see it in general terms, at least.
3 The Office of Inspection and Enforcement's role is to ensure r")
ks' that the rules and regulations of the Commission as set forth 4
in 10 CFR 50 and as amplified by the technical specifications 5
that are issued for each plant are adhered to by the licensee.
6 The Office of Nuclear Reactors Regulations' 7
responsibility is to review the application for license which 8
9 includes a review of the design of the plant and a review in 10 general of the intent of the utility as far as their plants 11 were operating the plant.
12 The review of detail procedures is one that has Nlhh 13 been the responsibility of the Office of Inspection and 14 Enforcement.
So, I think there are those divisions, and this 15 is a case where the matter that was in question was one of 16 design which is an NRR responsibility for review and not an 17 I&E responsibility.
18 Q
Looking at the third paragraph, there seems to me to 19 call for something more than design of the specific plants at 20 TMI, but rather a review on an expedited basis, and I'm 21 quoting,"for B&W facilities in general and Three Mile Islani
(_O) 22 in particular."
Was the response intended to say that B&W
?
23 designs in general were satisfactory under that standard that 24 you just suggested?
A&Feerd Reponm, W.
l 25 A
I think that I would not suggest that the total l
l i
72 J10-19 design necessarily was satisfactory, but we are really only j
questioning the design of this one valve.
Is it okay for this 2
valve to fail in the open position, and I think the answer is 3
(7,)
4 yes.
It is okay for this valve to fail in the open position 5
f r any of the B&W plants.
0 In hindsight, would you say that that is still 6
true?
7 A
I w uld still say that is true providing the 8
responsible and proper actions are taken in ohner areas.
The 9
fact that this valve failed in the open position of itself did 10 11 not create the Three Mile Island event.
There were at least --
12 0
There were concomitant actions and other elements of I
MhP the plant that did contribute to it; that is correct.
/
13 14 A
Well, what I was going to say is that there were 15 a number of events, if you will, rather than a single event
~
16 that contributed to the final situation that occurred at Three 17 Mile Island.
I think that it is fair to say that in our 18 requirements and in our philo_ophy, we do not require and never 19 have required, and it would be very foolish of us to try to 20 require that every piece of equipment, every component in the 21 plant always absolutely functioned correctly without fail.
We
/^)
(,/
22 have to recognize that there will be failures, and this is a 1
23 case where we will recognize, yes, this valve may fail in the 24 open position, however there are at least two other actions l
Ace FMerJ Ressners, lrm.
l 25 that can be taken to prevent that particular event from becoming l
73
=le-20 1
a real problem.
2 One is to recognize that the valve is open, which 3
the operators were not capable to do at Three Mile Island for P
4 whatever reason.
5 Q
Were at DaviseBesse?
6 A
They did recognize it at Davis-B:ise albeit some 20 7
minutes late, but that was soon enough.
8 BY MR. HEBDON:
9 Q
If I could interrupt, that was soon enough due to a 10 large extent to the fact that they were at such a low power 11 rate.
12 A
So be it.
I don't know what the exact timing would k
13 be, how long you've got.
I 14 Q
Well, they left it open for about 20 minutes, and 15 they had one effect of full power a day at the plant.
16 A
As I understand the situation at Three Mile Island, 17 if they had closed that valve within 20 minutes they probably 18 would not have had the trouble, either.
But I am not sure of I9 that.
20 At any rate there was that possibility to close the I
21 valve.
The second possibility, of course, was to allow the 22 high pressure injection system to continue to operate.
And 23 again, some other signals suggested to the operators that we 1
24 are putting too much water in, we ought to stop it.
That was Ace. Federal Reporters, Inc.
I 25 an erroneous assumption.
i
74 alo-21 1
So, the point that I make is, yes, individual 2
components are going to fail and we try to decide to have 3
something that is going to take care of the situation in the
,,gs l
I 4
event that failure does occur.
And indeed, these things did 5
exist.
They were misinterpreted where other circumstances 6
were misinterpreted, so they did not get used like they should 7
have been, but they were there.
8 MR FOLSOM:
Thank you.
9 BY MR. HEBDON:
10 Q
Do you have any additional things to add?
11 A
No, sir.
12 MR. HEBDON:
Do you have any additional questions?
dl 13 MR. FOLSOM:
I can't think of any at the moment.
14 MR. HEBDON:
I have no other questions.
Thank you 15 very much.
snd t-6 16 (The proceedings were adjourntd at 11:45 a.m.)
17 18 19 20 l
21
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22 23 1
24 i
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