ML19308C394
| ML19308C394 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/03/1979 |
| From: | Lightle R BABCOCK & WILCOX CO., NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001230364 | |
| Download: ML19308C394 (46) | |
Text
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O N U CLE AR REG UL ATO R't COMMISS!ON O
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i TMI SPECIAL INQUIRY f
DEPOSITION 4
I DEPOSITION OF ROBERT E.
LIGHTLE I
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i Place - Lynchburg, Virginia Wednesday, October 3, 1979 Pages 1 - 46 j
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UNITED STATES OF AMERICA
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2 NUCLEAR REGULATORY COMMISSION 3
- - - - - - - - - -x 0
4 DE,P6SITION OF:
5 ROBERT E.
LIGHTLE 6
- - - - - - - - - - - -x 7
8 Conference Room A Babcock & Wilcox 9
Old Forest Road i
Lynchburg, Virginia 10 Wednesday, October 3, 1979 11 {
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12 '
NRC/TMI SPECIAL INOUIRY GROUP
(
14 i
The interview of Mr. Robert E.
Lightle commenced i
i 15 't at 9:10 a.m.
i i
16 h Present for the NRC:
Fred Hebdon and Fred Folsom.
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Uh Present for Babcock & Wilcox:
George Edgar, John l
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i 13 Mullin, and Lista Cannon.
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.A we Reporters, inc.
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_C.O N
_T_ E N_ T_.S-2 Witness:
Examination by:
Page:
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4 ROBERT E.
LIGHTLE Mr. Hebdon & Mr. Folsom 3
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2 Whereupon, ROBERT E. LIGHTLE 3
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was called as a witness and, having been first duly sworn,
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4 was examined and testified as follows:
5 EXAMINATION 6
4 -
BY MR. HEBDON:
7 8
Q Would you please state your full name for the 9
record.
10 A
Robert E.
Lightle.
Il i Q
For the record, this is a letter to Mr. Lightle l
12 l dated October 1st, 1979, from Mitchell Rogovin, Director 13 of the NRC/TMI Special Inquiry Group.
O 14 j Mr. Lightle, have you had an opportunity to read i
15 this document in full?
Il 16 h A
I have.
n j
4 7 ;;l Q
Do you understand the information set forth in this j
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- 3 ;I letter, including the general nature of the NRC/TMI Special i
Inquiry, your right to have an attorney present here today I
7:
as your representative, and the fact that the information you s
2:
provide may eventually become public?
22 A
I do.
(
I 23 [
MR. EDGAR:
For the record, let's note that there 2n is a typo in the spelling of Mr. Lightle's name in the Aa('ni neponen, ix.]
letter
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The correct spelling is L-i-g-h-t-1-e.
25
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MR.HEBDON:
That's correct.
2 MR. FOLSOM:
Yes, that was something we realized,
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3 but didn't get corrected at the time.
Our apologies.
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4 BY MR. HEBDON:
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Q Mr. Lightle, is counsel representing you here today?
6 A
Yes, he is.
7 MR. iiEBDON:
Would you please state your name?
8 MR. EDGAR:
My name is George Edgar.
9 BY MR. HEBDON:
l 10 0
Mr. Lightle, you should be aware that the testimony l d
i 11 l you give has the same force and effect as if you were testifying l
12 l in a court of law.
My questions and your responses are being l
i f-13 l; taken down, and they will later be transcribed.
)
f us 14 You will be given an opportunity to look at the i
15 ji transcript to make the changes that you deem necessary.
- However, i
s 16 j to the extent that your subsequent changes are significant, iln
?[ these changes may be viewed as af fecting your credibility.
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- I,
So please be as complete and accurate as you can in responding ;
to my questions.
If at any point during the deposition you don' t i
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2i understand a question, please feel free to stop and indicate, l
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22 lj and we'll try to clarify the question for you.
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23 I A
I understand.
i 24 ;,
Q What is your current position?
frat Re mrters, ine.
Aw 25 [-
A Associate project manager.
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- j
5 Q
What was your position in' late 1977?
o-j A
Associate project manager.
2 Q
Would you explain briefly what your duties are?
3 A
I receivei the contract correspondence coming from
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4 the customer.
I take action upon it by sending it to various 5
groups and individuals throughout the company.
6 I receive answers and return answers to the 7
customer.
8 Q
For whom do you work?
9 10 A
My supervisor is James McFarland.
1)
Q And what is his position?
t' A
He is senior project manager.
12 l 13 Q
Is he the person for whom you worked in late 1977?
O 14 A
That's correct, f,
15 Q
What is your educational background?
I 16,
A It is in the resume that I have here.
l' 1
- 7 I have a Bachelor of Arts Degree, Mathematics, h
- 3 from the University of California in Los Angeles, awarded in I
1950.
l 2: l I have a Master's of Aerospace Operations Management' li l
3 from the University of Southern California in 196 9.
-22 O
Okay.
I understand you have a copy of your resume.
Os e
MR. HEBDON:
This will be included in the record, 23 ll 24 then.
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[The document follows:]
25 I
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+u ink. f I October 1, 1979
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In Reply Re.fer to:
NTITH 791001-0~
Mr. R. Lightile
(
)
c/o George Edgar, Esquire Morgan, Lcuis & Bockius Attorneys for Babcock and Wilcox Co.
1800 M Street N.U.
Washington, D.C.
20036
- ~
Dear 15. Lightile:
I a= writing to confir that your deposition under oath in connection with the accident at Three Mile Island is scheduled for October 2-5, 1979 at Babcock and Wilcox facilit.y, Lynchburg, Virginia. This vill also confirm my request for you to have your resume and any docu=ents in your possession or control regarding TM1-2, the accident or precursor events which you have reason to believe may not be in official NRC files, including any diary or personal working file.
The deposition vill be conducted by ce=bers of the NRC's Special Inquiry Group on Three Mile Island.
This Group is being directed independently of the NRC by the lau firm of Rogovin, Stern and Huge.
It includes both NRC personnel who have been detailed to the Special Inquiry Staff, and outside staff and attorneys. Through a delegation of authority from the NRC under
,__( )
See:1on 151(c) of the Ato=ic Energy Act of 1954, as a= ended, the Special Inquiry Group has a broad mandate to inquire into the causes of the accident at Three Mile Island, to identify cajor proble= areas and to =ake reco==enda-tions for change. At the conclusion of its investigation, the Group will issue a detailed public report setting forth its findings and reco==cndations.
Unicss you have been served with a subpoena, your participation in the depos-ition is voluntary and there will be no effect on you if you decline to answer some or all of the questions asked you.
However, the Special Ingniry has been given the power to subpoena witnesses to appear and testify un6 c oath, or to appear and produce documents, or both, at any designated place.
Any person deposed may have an attorney present or any other person he wishes acec=pany him at the deposition as his representative.
You should realize that while we will try to respect any requests for con-fidentiality in connection with the publication of our report, we can make no guarantees.
Names of witnesses and the infor=ation they provide may eventually become public, inasmuch as the entire record of the Special Inquiry Group's investigation will bc made availabic to the NRC for whatever uses it may dee=
appropriate.
In thee, this information cay be cade available to the public z_(s) voluntarily, or become available to the public through the Freedom of Information Act.
Moreover, other departments and agencies of govern =ent =ay request access to this information pursuant to the privacy Act of 1974.
The inf er=ation =sy also be made available in chole or in part to co==1ttecs or subec==ittees of the U.S. Congress.
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N AC Fo AM 2]E (9 761 N ACM ONO D U.S. GovERNMCNT PPINTING orra:E; 3 9 7 9-2 8 M69
Mr. R. Lightilo October 1,1979 If you have testified previously with respect to the Three Mile Island accident, it would be useful if you could review any transcripts of your
,m(j previous statement (s) prior to the deposition.
Thanh you for your cooperation.
(
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Sincerely, v
A Mitchell Rogovin, Director URC/TMI Special Inquiry Group DISTRIBUTION TERA FFoisom FHebdon WParler O
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g PREPARED FOR THE PRESIDENTIAL C01SIISSION INVESTIGATING TM1-2 EVENTS
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RESUME June 1979 Age 55 ORobertE.Lightle:
Born Long Beach, California Married 31 Years - 3 Sons Present Duties:
Title, Associate Proj ect Manager The Babcock & Wilcox Company, NPGD, Lynchburg, Virginia.
Responsible for directing the specification, procurement and delivery of a large share of the NSS system equipment for the TVA Bellefonte project.
Review all incoming contract letters and take appropriate action upon those that are within my sphere of responsibility. Write and maintain the associated contract documentation. Responsible for directing the licensing activities through the B&W licensing section for the Bellefonte Preliminary and Final SAR.
Obtain quotations and make proposals for equipment changes, upgrades and analycic work.
Formal Education / Training Degree: Masters Aerospace Operations Management, University of Southern p
California - 1969
(_/ D2 gree: Bachelor of Arts (Mathematics), University of California at Los Angeles -
1950 Credential:
Secondary Teaching (California) 1951.
Engineering Courses:
University of New Mexico - 1952-1955.
Work Training Sessions:
Contract Administration, Communications, Management, Law, Reliability, and Fault Tree Analysis.
Work History The Babcock & Wilcox Co., Lynchburg, Va.1971 - present
Title:
Associate Project Manager Supervis ors:
J. McFarland, D. W. Berger, G. R. Skillman, W. S. Delicate Share the responsibility for directing the design, analycis, equipment specification, procurement, and delivery of a nuclear steam supply system.
Maintain direct liaison with the customer and provide proper documentation of all agreements and discussions.
Sell additional equipment and services.
Aerojet Nuclear Svstems Company, Sacramento, Calif.
1969 - 1971
Title:
Program Supervisor
-]
Supervisors:
R. V. Evleth, G. F. Mader, N. A. Norman (Managers, Program s_-
Controls Department)
Interpreted customer directions and prepared internal directives for the control and guidance of the NERVA program.
Performed liaison work between all
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proj ects and prepared reports as required.
Robert E. Lightle
. Resume, Pg. #2 June 1979 Aerojet General Corporation, Las Vegas, Nevada 1965 - 1969
Title:
Supervisor and Nuclear Engineer s_
Supervisors:
C. K. Soppet, W. D. Wayne, R. G. Staker (Department Managers)
Prepared facility operations procedures and was responsible for proper documentation of facility modifications.
Aerojet General Nucleonics, San Ramon, California and' Idaho Falls, Idaho. 1959 - 1965
Title:
Nuclear Engineer and Section Head Supervisors: - G. B. Carlton, R. H. Chesworth, W. D. Wayne (Operations Manager)
Responsible for reactor technical test program.
Prepared and commented upon test procedures, interpreted and reported test results.
The Babcock & Wilcox Co., Lynchburg, Va.
1955 - 1959
Title:
Reactor Physicist Supervisors:
M. C. Edlund, D. B. Wehmeyer (Department Managers)
Performed reactor analytical calculations for the design of reactor cores and fuel elements. Used digital computers extensively.
Los Alamos Scientific Lab., Los Alamos, New Mexico 1951 - 1955 i
Title:
Staff Member Supervisors:
A. R. Sayer, E. R. Salmi (Group Managers)
Performed weapons calculations, ran parametric studies and assisted with interpretations of results, used digital computers and learned machine pro-gramming.
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6 1
BY MR. HEBDON:
2 O
We have this in the record, but just for background, 3
could you give us a very brief description of your employment 4
history, including positions that you held at B&W?
5 A
I have worked twice for B&W.
The second time I joined them in 1971, and I have had the same position since 6
7 joining them.
I have always been on the, what we call the 8
TVA project as associate project manager.
9 Q
Okay.
And prior to that, what was your experience?
10 A
I was with Aerojet General for 12 years, working II i with them on the NERVA Program in Sacramento and Las Vegas, 12 I was working on gas-cooled reactors, in Idaho Falls, Idaho, 13 and out of San Ramon, California.
14 j Q
Okay, I'd like to ask you some questions concerning b
15 an incident that happened at Davis-Besse on September 24th, 16 1977, and particularly interested in your knowledge and 27l perceptions prior to the accident at TMI.
1 Md Specifically prior to March 28th,1979, what i
I' knowledge did you have concerning the incident that occurred j
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at Davis-Besse on September 24th, 19777 a
21 A
None.
O 22 Q
So you have not been exposed to that at all?
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23 ll A
go, 2a p
Q Would it have been a normal function of your job Ad jsrot Reporters, Inc, j
s 25 j
to be exposed to that information at all?
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A No.
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2 0
So there was no effort that you are aware of
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to circulate _.._ormation about incidents such as that to people i
9 p
a in positions such as yours?
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5 MR. HEBDON:
Let's go off the record.
l
[ Discussion off the record.]
6 z -
y 7
MR. HEBDON:
Let's go back on the record.
THE WITNESS:
It is normal for us to have reports 8
of incidents from other plants circulated.
I do read them, 9
I I evaluate them, in terms of my own project.
10 j If I deem them suf ficient -- or I mean deem them 11 '
12 :
relevant, then I would take note of them specifically'.
If 13 they don't seem to have any effect on me, then they probably
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_Y 14 i, were just passed over, and that's why in the previous one at Davis-Besse, it didn't seem to have an effect, and if I did 15 g 16['
read about it, it had nothing to do with me.
r BY MR. HEBDON:
h is,
O chay.
So you may have read about it, but you don't have any recollection?
A Right.
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O All right.
Prior to March 2 8th again, do you i,
Il 22 h have any recollection of some concerns about the operation
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n, of high pressure injection system that vere raised by Mr.
l Kelly and Mr. Dunn of B&W?
Aahrs Reporters, Inc.
25 i
A No.
I d
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1 0
Prior to March 2 8th,1979, what knowledge did you 2
have concerning the report that has come to be known as
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3 the Michaelson report?
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4 I have a copy available of that report if you 5
want to take a look at it to refresh your memory at all.
t 6
MR. EDGAR:
Off the record, o
[ Discussion off the record.]
7 8
MR. HEBDON:
Let's go back on the record.
Go ahead.
9 10 THE WITNESS:
The Michaelson report that we are 11 discussing is titled a draft report, is it not?
A draft 12 report?
13 BY MR. HEBDON:
O l
0 Yes.
14 j
15 "
A All right.
Officially that was received by B&W 1
through a TVA letter, and as is normal practice, it fell hd within my sphere of responsibility to assume the : racking of 7
I l
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the letter through the company.
i-I sent it immediately to the ECCS group who handles and discusses that type of information, and then I had further 3;
discussions with Bob Jones about this.
I 21 p 22 0
Is Mr. Jones in the ECCS group?
23 l A
Yes.
24 Q
And who would have been the supervisor within l
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- f at Rescriers. inc.
l 25 the ECCS group that you sent it to?
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?
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Bert Dunn.
l 2
O Did you send it through Mr'. Dunn or did you send x-3 it directly to Mr. Jones?
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4 A
I don't remember for sure.
Probably both.
Normally 5
I ccnd it to both.
l 6
Q So you sent a copy to each of them?
7 A
This being such a large report that I doubt that I 8
sent it to both.
I probably just talked to both of them and i
I 9!
showed them what it was.
i 10 i 0
Did you review the report at all yourself?
1 II A
No more than to page through it to see what the I2 centent was and to be sure I was getting it to the right
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13, g roup to handle it.
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0 14 Q
What significance did you attribute to the report?
i 15['
A No more significance than a comment on operations j
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16 lI and the calculations for which we are responsible, and it just seemed like another comment to me, somewhat langthy.
l I
I i3 BY MR. FOLSOM:
I, O
May I ask, was TVA one of the projects for which T
you were responsible?
II A
Yes, sir, I work only on the TVA project.
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O I see.
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23 h A
I work only on the Bellefonte project.
That's the 1
24 way.t's identified.
Adlhwa menon,s. ine. h 23 e c
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10 1
BY MR. HEBDON:
2 O
Did you notice in your review of the report a concern 3
about the operators being misled possibly by pressurizer 4
level indication?
5 A
Not at that time, I did not read it in that detail.
6 Q
At what time did you become aware of that?
p --
i 7
A Probably later in the summertime, discussing the 8
paper with Bob Jones.
9 Q
But you did at some point prior to the accident at 10 TMI, you did become aware of this concern about the possibillty II of the operators being misled by pressurizer level?
II '
A Yes, I probably -- I say probably, yes.
13 0
What significance did you assign to that concern?
I4 A
No more than just an ordinary concern that it il 15 should be picked up by the service people to handle it.
16 Q
Would that particular concern have been the U
responsibility of the ECCS people or the service people?
II.
A I believe I would say that the answer would be shared I
between them.
22 Q
Did you refer the report to anyone in the service 2i group?
22 lI A
No, I did not.
Q V
23 h O
Just for background, could you identi;y the service i
241 group to which you are referring?
I n
At erst Reporters, Inc.
3 25 A
That is the group that writes our procedures and l
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1 is concerned with our start-up operation.
2 O
Who is the head of that group?
3i A
At the present the person is Jim Hansell we are l
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working with.
5 Q
Who was the head of the group at that time?
I 6l A
I believe it was Tom Scott at that time.
7 Q
All right.
But you didn't refer the report to that group when you became aware of it?
8 i i
9' A
No, I did not.
10 0
Is there any particular reacon why you didn' t refer II I it to them?
l 12 A
Yes.
The reason is that our procedures and start-l 13 up operations are still in preparation, so that it would be my i
x_/
14 ll assumption that this was a normal piece of business that G
i 15 l wouldn't be picked up as we wrote our procedures.
h 16!l Q
Did you consider that any of the concerns, and M
i d
? jl particularly the concern about operator information, might 4
R, have any generic implications?
i A
Could we have it read back, please?
^:
0 The question, did you consider that the concerns 21 that were raised in this report, and particularly the j
3 li 22 I! concern about the operators possibly being misled, did you I,
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ns 23 !, consider the possibility that any of those concerns might l
i 24 have any generic implications to plants other than Bellefonte? :
i, Ac ft:A Reporters. IN.
25 i A
They could have had generic implications.
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MR. EDGAR:
Did you consider at the time?
2 THE WITNESS:
No.
No, I would not consider at the La 3j time that that would have any concern.
( )
4 BY MR. HEBDON:
5 0
was it a normal practice of yours in doing the work 6i that you did to consider the generic implications of concerns
>~
7 that might be raised on a particular docket?
A No, no. If they -- well --
8 9,
O Is there anyone within the B&W organization who would lo have -- whose responsibility it would have been to review or 11 j report such as this to see if it had any generic implications?
12 A
Yes.
I leave that strictly to the Engineering l
l Department.
l 13 4
(
i la q Q
Now by the Engineering Department --
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15 A
And that would be following through Bob Jones,
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i 16 ll Bert Dunn.
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- 7 [I Q
So then you would have expected Mr. Jones and Mr.
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Dunn to look at this material and to make any decisions l
about whether it had any generic implications?
n A
Absolutely.
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21 Q
So you felt it was their responsibility to look y
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l 22ll at the generic implications, not yours?
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23 f A
Right.
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o okay.
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13 1
BY MR. FOLSOM:
2 0
Let me ask a couple of questions.
Did you get a lot 3
of correspondence from TVA about Bellefonte?
4 A
We have something like 8 or 10,000 letters that 5
I've gone through in the last three years.
6 0
From this one source?
They 7
A We're close to 6000 now in this series.
Pertain to all matters to the project.
8 9
0 So this was just a letter among many?
10 A
Right.
11 0
And it was handled in accordance with established 12 l routine?
l 13 A
I believe.so, yes.
14 BY MR. HEBDON:
0 15 0
Of this 6000-some letters that have come in, I 16 assume what you're saying is that you have about 6 000 letters 7
that have come from TVA concerning that docket?
- l; A
From this one particular source.
We havecothers i;
from TVA -- I mean other parts of the TVA organization.
r 0
Okay, but what you're saying then is that the 6000 i
letters that you've reviewed that related to Bellefonte, 21 p 22 I those are 6000 letters that came isom TVA' I
23 h; A
Yes.
l-24 3 0
Okay.
Now --
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[AcOval Reporters, Inc.
U MR. EDGAR:
And further, one organization within i
25 i
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1 TVA; right?
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2 THE WITNESS:
Yes.
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3 BY MR. HEBDON:
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4 Q
And there are other letters from TVA that you don't S
see beyond the 6 000 that would come to B&W; is that true?
I 6
A No, I don't mean that.
I mean that I would review 7
those also.
8 0
I'm still a little bit confused.
9 A
Let me try to put it in perspective.
10 The 6000 I'm referring to come frota the engineer l
11 f in Knoxville.
We also have a source of letters from the i
12 contracting officer of Chattanooga.
13 7- )
We have a source of letters from the materials j
'v' 14 J engineer in Knoxville.
i j
15 l 0
So those are three sources within TVA that write l
16 d' letters to B&W?
n I
a l
!7 ll A
Yes.
h
'l Js Q
Now approximately -- and I realize this is going j
to have to be a rough estimate -- approximately how many i
2T letters are we talking about from these three groups, all total?
i i
21 A
Probably a little under 10,000.
j l
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22 Q
Over what time period are we talking about?
l 23 h I
A Since the beginning of the contract, which was 24 June of 1970.
I A
ed Revanen. Inc 25 I
O So from 1970 to the present, you have received and i:
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15
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l handled basically something on the order of 10,000 letters 2 ! from TVA?
il 1
3j A
Correct.
N r '
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0 Okay.
Now of those 10,000 letters, approximately 5j what percentage would you estimate are letters in which TVA 6i raises an issue that they want B&W to look at, or to consider,
)
7 or to analyze?
8 A
Probably three-fourths of them.
9I Q
So then it's your perception, then, that TVA has 10 l sent something in the order of 7000 to 8000 letters to B&W 11 !
over the last nine years describing concerns that they feel l
12 i should be addressed or reviewed to some extent by B&W?
I 13 A
When they raise the concern, I mean it is a comment g ~.
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14.i on maybe a specification or a drawing or something of that L
l 15 ;
nature.
It is not strictly a safety concern of this nature l
l 16 l that wa should -- should handle as a safety concern, only a i
t P ll question from them.
'i II Q
Okay.
Now did you perceive the letter that con-
)
i tained the Michaelson report to be a letter raising a safety i
concern?
i I
- i A
Yes, yes.
k i'
U 22 li Q
Now again an estimate, approximately what percentage, r1 i
)
s 23 p of this 10,000 letters raised safety concerns?
l 2'
A That would be a very rough estimate.
I find it Ac $a nwonm. inc. !;,
25 'i dif ficult to come up with a number.
Couple thousand.
16 3
O Okay.
So then this letter raising a safety concern r~\\
2 was one of maybe.a couple of thousand letters, similar letters U
3 that you received over a period of nine years?
9(v, 4
A Yes.
5 Q
All right.
Now as I understand it, you sent chis 6
letter to Mr. Jones.
Would you go on then and describe what 7
happened following that?
8 A
During the summer, I talked to Mr. Jones informally 9j numerous times, whenever I would see him, and ask him when he 10 was going to get an answer for me, which again is a normal i
11 course of business, the way we handle our business, and received 12 l assurance that it would be answered as soon as they could get 13 to it.
('T
%-)
i 14 l
I remember one telephone call that we had from TVA t
15 about June asking for a response'to the letter or asking at i
16 least for a discussion on the letter.
The ECCS group was I
7 busy with other concerns at the time.
That's why we deferred 4
i it, and I still deferred an answer.
l a n l
TVA is in daily and many times hourly contact with
}
- ..i us, and we work on the letters and concerns that they are l
21 j really pushing us for.
I had only the one call that I had I
1 22 l recorded, remembered about.
It wasn't until about November
^
)
l l
23 { that they began questioning, wanting a response to the letter.
24 Q
So then from the time that you received the report Ac['~'pg Reporters, Inc.
j 25 ! until the timeframe of about November, you only recall a single '
i
17 time in which anyone from TVA raised the question of when they 3
wer g ing to get a response to this particular letter?
2 A
Correct.
3 Q
Is it a normal practice in the way that you handle
(}
4 these letters to take a period of, oh, something in the order 5
of eight or nine months to respond to a letter such as this?
6 Is that a normal timeframe?
7 A
I believe the answer would be yes.
The normal 8
answering periods depends upon the letter and the subject, 9
the difficulty of answering, and that sort of thing.
Some 10 11 questions are outstanding for years before we really get them resolved.
12 13 We attempt to answer them much faster.
Ov 14 Q
When you receive these letters, did you set any sort i,
of a deadline on them?
15 16 A
Informally, yes, in-house, between myself and the 1
7 engineers, yes.
3 Q
Is that deadline documented in any way?
Is there some sort of a routing document, for example, that you use to l
i send these around that has a desired completion date established on it?
21 A
Sometimes, yes.
Not always.
22 O(_/
l:
23 ll Q
Do you recall if you had a desired completion date I
24 0 for this particular report?
A=I'\\st Reprters, lrx.
\\~'
25 j
A No, we did not.
l i
i
18
~
l Q
Is that a normal practice to not put a desired 2
completion date on a report such as this?
(,;
I 3i A
Yes.
l 1
()
4 0
What sort of reports would you have put a completion 5
date on?
6 A
The answer would be to -- depending on the category 7
of the letters and the desire from TVA.
The importance is 8
the completion of the project and to keep the questions and 9
comments moving.
If we are needing the answers immediately, 10 l l
say it pertains to shipment of a piece of material or something 11 lllike that, that they need immediately, it gets something done 12 immediately.
13 If it is an item that is needed for, say, licensing, 7!
tvs l the SAR, while extremely important, they may not need it or 14 15 want it for two years.
Then it takes a lower priority.
I 16 j MR. EDGAR:
Is that because of the NRC -- what i
- '! you're talking about is the schedule for the SAR?
l!
o 13 ;;
THE WITNESS:
Depending on the schedule, that's j
correct.
f l
M BY MR. HEBDON:
i 21,
O So then it sounds like the schedule for the work on 22 li these various issues is driven to a large extent by when it's i
l em
)
23 ll needed in the licensing process and in the construction process?
24 '
A Correct.
s1 Reporters. Inc. y A
25!!
O When would the response to the Michaelson report L
t
19 I
have been needed?
[v}
2 A
The response to it would not have been put directly 3
into any documentation I can recall at the moment.
The l
(,)
4 information would have been presented in the SAR, and that 5
is still not ready for review.
6l.
So then your perception is that the first time O
>~
7 that the response to that report would have been needed would 8
have been for the SAR?
9 A
That's when it would have been needed by the project.
I, 1
10 I believe it should be recognized that if TVA had pushed very 1
11 l strongly and demanded an answer sooner, we probably would i
12 i have worked on it sooner.
13 Q
But just based on tying it to some point in the
(-)
ll L
(_
I4 !! overall schedule for this particular contract, the milestone l
15 q that you would tie it to would have been the preparation of l
1 16 the SAR?
i li l
17 h A
Correct.
li d
Q Okay, now, at the time that the report was received in the timeframe of spring to summer of
'78, when was t
E it anticipated that the SER would be completed?
1 i
2I j A
At that time we were planning to file the SAR --
'i l
l
/~1 22 not the SER --
L>
f l
l 23 Q
I'm sorry, if I said the SER, I meant the SAR.
24 i;
.A The SAR was to be filed, I believe it was the first Ac rd Reporters, Inc.
25 ! of 1979, N
f s
20
?*
1 0
So when you received the Michaelson report, you j
felt that a response then wasn't really required until some l
2 3I time early in 1979?
o()
4 A
Right.
5 O
Now you said it was to be filed in early '79.
l 6!
Backing up from that a little bit, when would it have needed 7
to be completed to be ready to be filed?
I would assume 8
there's some internal review in just the mechanics of having 9
the thing reproduced in sufficient quantity.
l A
I believe I stated earlier that the answer would l
10 II !
not have gone directly into the SAR.
It would have been only i
12 the material, the meaning of the answer that would have gone p
into the answer to the SAR.
So the recponse to the letter l
13
%.J Id I
could have been made in conjunction with or independent of, i
15 i even, the SAR.
l 16 ll 0
But as far as actually needing the results of the
,,"p analysis, that was requested, and any response -- excuse me, I
" response" is a bad word -- any application of that analysis,
f
'3 that wasn't going to be needed until some time around the E
end of 1978 or early 1979; is that correct?
l q
g A
Yes, that's correct.
Our work for the SAR had a
22 h already been written in a preliminary f ashion, our preliminary l
(]
l K.s i
23 I, work had already been done.
The report answer was merely 24 L
an amplification of our work so that we saw -- I saw this as Ac ed Remnm, Inc.
h 25 f chancing nothing that we already had prepared for the SAR.
I L
21 1
Q So then if I understand you, your perception was
(}
2 that although the potential existed for having to revise 3
part of the SAR as a result of the concerns raised in the
()
4 report, you didn't anticipate that any changes would actually 5
need to be made?
6 A
That is correct.
0 -
l 7
Q Now could you go on with your discussion of what 8
happened with the report?
I think we were up to some time 9
around November.
10 A
Yes, then we had a few telephone calls which would 11 be normal -- which was normal practice, setting up a telephone 12 call with TVA personnel and B&W personnel for a discussion of 13 the paper.
14,
O Do you recall who was involved with that phone i!
15 conversation?
16 A
Some of the people that were involved, as follows, l
17 for B&W:
It was myself, Jim McFarland, Bob Jones, Lou l
l i3 h Cartin --
i; O
Excuse me, who is --
2:
A Lou Cartin, C-a-r-t-i-n.
21 i Q
What is his position' g
22 A
He it in the Integration Section.
23 O
All right.
{;
24 A
Dennis Renner was involved from the Licensing i Aw eral Reporters, Inc, 25 l Section.
I I
t l
l l
l I
i
22 I
From TVA, there was primarily my contact there,
(]')
2 which was Rick Simmons, Carl Michaelson, I believe Stuart~
3 Thickman who was one of the TVA licensing group, Lee Hank,
()
4 one of their engineers in this area.
5 Q
Okay.
6 A
And I'm not sure of the rest of them.
a -
7 Q
What do you recall was the content of the phone 8
call?
9 A
It was a complete discussion of -- it was a discus-10 sion of the complete paper.
II O
The technical content of it, or the schedule?
12 A
No, no, no.
The technical content.
13 0
Do you recall what sort of observations the various f-,h 14 people made, what sort of conclusions were reached?
il 15 A
The conclusion was that the concerns seemed to 16 have been answered.
The result of the call was a request I7 for B&W to document the answers in a letter.
Because of
- 3 h the extensive nature of the paper to begin with, and our
'2 long telephone call, I requested Rick to give me a letter or a l
E piece of paper stating their specific questions they wanted 1
21 o answered, so that I would be able to respond in a timely manner.'
I i
22,
Q Now who is Rick?
~
('_)s 23 A
He was my counterpoint at TVA.
24 f-Q Now in what form had the concerns raised in the A( 3*g Reporters lN, 25 report already been addressed?
l I
L i
i 23
>~
l A
They had been discussed in the telephone call.
2 O
So then the phone call, you felt adequately addressed
(
- l l
u/
3I the concerns and the comments that were in the report; is that j
()
4 c orrect?
5 A
Absolutely.
6 Q
Now you asked TVA then to provide a letter with a -
l 7
additional questions that they wanted answered or just to 8
document the questions that you had felt were already answered 9
in the phone call?
l 10 A
A list of questions to which we could respond 11 l which would complete the letter and the telephone call.
l 12 l Q
Now, these questions, did you perceive these to be l
13 in addition to the issues that had already been discussed?
,cy 4
w/
f I4 A
No.
F 15 Q
So this was just then to document the issues l
U l
16 i that had been discussed in the phone call?
I i A
Yes.
Ul MR. EDGAR:
Was it to narrow the issues or make them more specific?
2P-THE WITNESS :
Correct.
I l
II BY MR. FOLSOM:
lI I
i 22 d Q
Were any new issues raised in the phone call that 7y 1
L) l 23 " had not been raised in Mr. Michaelson's --
24 A
Not to my recall, i
af no enerws. tnc.
25 i
O What was the need for further documentation?
i b
24 1
A That is our normal way of doing business.
2 O
You mean you get your client to write a letter,
{}
3 and then you make him write another letter on the same subject? l
()
4 A
[ Witness nodding affirmatively.]
5 Q
Really?
6 A
He wrote the letter, bis 36-page report.
7 MR. EDGAR:
Let's go of f the record just a minute.
8
[ Discussion off the record.]
9 MR. HEBDON:
Could we go back on the record, please.
10 BY MR. HEBDON:
11 Q
Now could you go ahead and summarize the discussion 12 that I think we just had off the record concerning why this 13 particular letter or why this particular document was requested 0_
14 from TVA?
il 15 A
I requested a number or a few questions specifically 16 from TVA to let us answer which would complete the matter.
i
- 7 The telephone call discussed all items of the report, and 13 [! the request for additional questions or summarizing questions I;
was merely to simplify the response to the report.
i M
Q So then what you were trying to do then was to j
q I
21 j ask TVA to narrow the scope of the questions or the concerns 22 that were in the report?
(-s')
i 23 l A
Correct.
l 24 0
So that you could focus on the issues that were l Ad
\\pp Regerters, ine, l l
l
(_/
i i
25 i really of concern to them?
I l
I i
i
25
~
1 A
Yes.
( )
2 Q
Do you recall in the course of the phone conversatio t/
3I whether or not the issue of the operator's interpretation 1
(v) 4 of pressurizer level, whether that particular issue came up?
5 A
I don't recall for sure.
i 6
Q So you don't recall that particular issue being 7
discussed?
8 A
No.
9 Q
Now you asked TVA then to provide you with this 10 i material.
Was it to be in a letter or in subsequent phone l
11 call, or how was this narrowing these questions that you had 12 asked, how were they to be sent?
13 A
As per our normal practice, they sent a telecopy i
.\\_/
I 14 i which was less than one page in length, with primarily three U
i 15 l questions to respond to.
I 16 O
Do you recall what those three questions were?
Il A
No, I guess not.
17 h N
I i3 1 Q
Okay.
Let's go off the record.
i
[ Discussion off the record.]
l 2:
MR. HEBDON:
Let's go back on the record, i
l 21,.
BY MR. HEBDON:
22 I Q
For the record, I believe this is a copy of the
,x
(
i 23 telecopy that you were referring to.
Unfortunately the quality!
24 of the reproduction isn't very good, but try to take a look L
AqlgFr:t Reprtm. loc.
l 25 ;. at that and refresh your memory a little.
,i 1:
.il I
26 l
[ Handing document to witness.)
()
Okay, you mentioned there were three issues 2
3 raised in this telecopy.
What was your understanding then
()
4 of the three issues that TVA had raised?
5 A
One issue is the removal af heat from the system.
6 Another issue is the use >f the steam generator as 7
a condensing medium or a heat mediun, depending on the state 8
that we're in during the transient.
9 And the third would be the concern of the postulated 10 break to remove or not remove enough of the decay heat to keep II the system in equilibrium as we have postulated.
I2 Q
Okay, now, was the issue of operator interpretation 13 of pressurizer level included in the list of more detailed Id questions that you received?
h 15 A
No, I don't see it.
16 Q
So as you understood it, then, that issue was not U l, carried over into the more detailed list of concerns that i
..o
"!! you received from Mr. Michaelson?
A That is correct.
27 d Q
Now could you go on and discuss the sequence of 4i el 4 events that occurred.
i 22,
A I don't recall the exact date that we received 23 these letters, this particular page, but it was toward the i
,W j-end of December, and that's when the letter -- the page was Aw( 3ya Remnm. ine.
25 given to Bob Jones and he prepared the answer to it about the I
l l
I l
27 j j end of January.
I 7'-
2 l Q
Do you recall any discussions that you had with
(-
f Mr. Jones during the period?
3, A
I had none from a technical nature; only from the
(~;
schedule.
I remember talking to him a number of times, trying 5,
I I
6}
to hurry the answer along.
So then the answer was prepared and sent off to TVA?
Q 7
A Correct.
8 Q
Did you review the answer at all?
9 A
- Yes, 10 l 11 Q
Did you review the technical content of it?
12 i A
No.
i 13 !
O Did you review the answer to see if it adequately r,
il
(
4 n
ja j addressed the concerns that had been raised by TVA?
t A
Yes.
15 16 Q
What was your conclusion?
l A
That it did.
l 3 ;I I
- 3,
O Did the answer address the concern of operator l
interpretation, pressurizer level?
i A
May I ask to see what is in the letter?
3 2;
O Certainly.
Let's go off the record for a' minute.
i 22 {0 l
[ Discussion off the record.}
/_
(
bu2 23 ';
MR. HEBDON:
Back an the record.
li 74 BY MR. HEBDON:
i Act9 ot Reporters. Inc. j 25 Q
Would you go ahead and identify the letter that you ll i
h
I 28 l
I referred to?
e i.
2 A
We answered the Michaelson report and the telephone l
x_.-
3
,l call with our letter No. D-3132, dated January 23rd, f
i i
(" ';
4 subject, "Small Break LOCA Analysis," and in that letter v
we did agree with the Michaelson report that the pressurizer 5
6l level alone was not adeguate to give the state of the RCS 7
system.
t that the pressurizer!
8 Q
In agreeing with that statement, level was not alone an adequate indication of the state of 9;
10 l the system, did you -- did that raise any concerns in your 11 l mind?
I 12 l A
No.
No.
i i
13 0
Then you felt that this was -- this was just l
(')
i 14 [ agreeing with an obvious point?
P t
15 lI l
l A
Yes.
l I
1 16 Q
Did you feel that any action needed to be taken l
i
'7 d as a result of the agreement by B&W that pressurizer level was i
,3, not an adequate -- that pressurizer level alone was not an
'l adequate indication of the state of the system?
i n
A No.
I had had no action to take.
l r
t BY MR. FOLSOM:
i 22 Q
Did you have a further comment about pressurizer f
x/
~
- 3 '!
level?
j 2 4,,
A Yes.
The letter identifies the use of system l
19 Reportm, inc. lj
. Aa 25 temperature and pressure to indicate the state of the system.
L D
b
29 i
0 Very good.
2 BY MR. HEBDON:
3 0
Do you recall if anyone else that was involved with this letter, Mr. Jones or Mr. Dunn, indicated that they had any
]
4 concern because of this observation about pressurizer level?
5 I
6l A
No.
7 0
Did they indicate to you that any additional action might be required?
8 9
A No specific reference that I can recall.
10 0
Now this letter was then sent off to TVA.
Wotild 11 you continue in the chronology of events?
12 A
Shortly after they received the letter, they came 13 back with their second le.tter stating that most of their O
14 concerns were answered, but they would like clarification of a 15 ' couple of points.
16 0
Now was it your perception that this letter was
- 7 including all of the additional concerns about your response, 13 or was this just part of a continuing discussion that they l
n i;
expected to have to carry on to resolve all of their concerns? l
\\'
A I interpreted it to be complete acceptance of our i.
,, h..
discussion and our letter, except for these two items, a l
22,
couple of items that they'd asked for clarification.
O 23 j 0
What was your understanding of the items that they 24 'i requested clarification?
A ce nenonen, inc.
25 A
My understanding at the time was it was f airly
30 I
obvious to me what the answer should be, but that I certainly
()
could not respond to it without getting a technical evaluation 2
3 from the ECCS group.
()
4 Q
What did you understand to be the concerns that TVA 5
still had?
6 A
The concerns that they still had had to do with 7
a clarification of how he was using the term volume balance --
8 MR. FOLSOM:
Let the record show that the witness 9
is looking at a copy of the TVA response dated February 8, 10 1979, to Mr. McFarland from the -- Mr. Peterson, Chief II Technical Engineering Branch at TVA.
I2 MR. EDGAR:
That's Patterson.
13 T
MR. FOLSOM:
Patterson. I'm sorry.
1 Id THE WITNESS:
The second part of the letter asks 15 for clarification of two statements which the letter believes 16 are not compatible.
17 BY MR. HEBDON:
IE h Q
Okay.
You mentioned that the answer to the 4
^
t concerns was fairly obvious.
What did you perceive to be the i
,.4 answer to the concerns?
2 I
A To me it seemed obvious, but again I do not take l
22 the responsibility for making those responses.
I 3l Q
I understand that.
I was just trying to get a j
E I
} 's fs feel for what you felt the answer was, recognizing that that's i Ac' rM Reporters. Inc.
just your perception and wouldn't necessarily have been the f
25 i
31
>~
l official TVA technical position.
)
2 l
A The comment on the volume balance, I thought, was a (J
L 3l mere play on words that could be clarified easily by Mr. Jones.
rw i
(,)
4' The incompatibility of the two statements, af ter I read the 5,
letters, seemed -- I didn't see the compatability that they i
6 were trying to point out.
So that's why it didn't seem like D -
7 it was much of a concern.
8 0
Why did you feel that the comment about volume 9
balance was just a play on words?
Could you explain that a 10 little bit more?
i 11 A
The explanation would be from the way it was 12 l written and the way the question came back, it just didn' t seem 13 to me that there was a valid concern.
,c
()
4 14 0
What did you feel the term volume balance meant?
h A
The balance between steam and water in the system.
15 [
16 0
I believe Mr. Michaelson's concern was associated 17 h with the idea of a mass balance and an energy balance, rather l
d,t than a volume balance.
Did you find those approaches to be l
10 inconsistent?
i i
2:
A I don't believe I stopped to evaluate it in that f
)
21 fashion.
p I
7s 22 l, Q
Did you feel that the term volume balance and mass i
i h
(/
i i
23 fi balance were similar?
24 A
Yes.
Just in the way they were used.
Arj h-cl Rmonns, snc.j 25 l 0
So then did you feel that the two terms were n
H
!i n
32 i
basically the same thing?
)-
()
2 i
A The terms themselves were not the same.
The way LJ l
3' they were being used may have been similar.
i 1
l
)
4 0
Could you go on then with the chronology of what
(~j 5
happened?
6 A
The letter asked for an immediate response, telephone w -
l calls with Rick Simmons again, I believe it was.
We 7
8 identified a problem,were answering it immediately, but that 95 we'd get it answered in a month or month and a half.
]
10 0
What was the problem with answering it immediately?
11 A
Press of other business.
12 0
Did you feel that the response was tied to any 13 particular milestone in the progress of this particular c
contract?
14 15 A
No.
16 0
So then the response or the schedule of the response; i
?
was being driven primarily by the amount of pressure that I
- 3p you received from TVA to respond?
i '-
A Correct.
l 2;
Q Did you talk with Mr. Michaelson at all about the 4
4 7;
concerns that he raised in this letter?
I S
22 A
No.
j 7-s L) 23 0
Do you know if anyone else from B&W talked with him?!
A I do not kno.w of anybody and I presume none.
It's 24 p Aho seconen. inc. q 25 not normal practice.
t l
!4
33
>~
l Q
Now Mr. Jones then, I assume, received this letter.
()
Did he give you any indication of whether he felt these concerns 2
3 were serious or significant, or whether it was just a matter of
()
4 a misunderstanding?
5 A
That was my impression, it was just a misunderstanding, 6
one that could be answered quite easily.
n -
7 Q
Would you then go on with what happened?
8 A
Before the answer to the letter was written, the 9
TMI incident occurred, and schedules slipped considerably.
10 Q
Was a response ever prepared?
II A
Yes.
12 O
When?
13 A
I don't recall the date of the letter.
It was 14 during the summer.
I 15 Q
During the summer of --
16 A
This year.
17 O
This past summer.
So then a response was prepared?
id :l A
Correct.
1, Q
Do you recall the content of that response?
i M'
A The content of the response was a prepared document l
21,
by Bert Dunn and Bob Jones as part of a presentation to the 22 NRC on small break analysis.
l
(-
(
i 23 ll Q
Now this presentation was associated with the p
i A,
Michaelson report, associated with the Three Mile Island fs At nre nem nen.ine.
\\m/-
l 9g l
accident, or some combination of the two?
s l
l 34 1
A It was primarily for the TMI.
~
(
'3 2
O Now just to go off on a somewhat separate subject, i
%s' l
3I as I understand it, the Michaelson report was associated with I
em
()
4 the 205 B&W plant?
{
5; A
Correct.
I 6
Q Is that correct.
7 TMI, and the analyses that were done for TMI, was 8
177 plant?
9 A
Correct.
10 Q
Did you perceive any inconsistencies between 11 the Michaelson report and the design of the 177 plant?
12 A
No inconsistencies.
There are dif ferences, yes.
13 Q
Did you have any perception, either before or after
,-~)
14 the TMI accident, that the Michaelson report might not be I
i applicable to the 177 plant?
I 15 I
16 A
I had no perception of it.
l l
4 P ll Q
Did anyone indicate to you that they had any percep !
l 13 [ tion of that?
l A
No.
M Q
Has anyone after TMI indicated that they didn't feel; l
21 the Michaelson report applied directly to the 177 design?
22 A
No.
p o
ss 23 l';
l 0
The response that was prepared and sent back to TVA l 24 after the Three Mile Island accident, was it consistent with Ad herd Reporters, lnc.
25 your initial perception that the concerns raised in the l
35 February TVA letter were just a matter of interpretation and 3
i l
not a matter of any real substance?
(3 S
\\
i a
T.2 ).
A Well, the answer was in a very general response,
(-
x a complete discussion of the Michaelson report; whether
)
4 v
5 they mentioned specifically the words volume balance or 6l mass energy balance, I don't recall.
a -
7 Q
Was there any action then af ter this letter was sent back to TVA?
What happened next?
8 A
They have written back saying that they still l
9 10 have outstanding concerns and have asked us to respond.
I 11 O
Do you recul2 what those concerns were that they 12 -
still are outstanding?
/-
13 A
I do not know what those concerns are, no.
3
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MR. HEBDON:
Let's go off the record for a minute.
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[ Discussion off the record.]
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16 l MR. HEBDON:
Okay, let's go back on the record.
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BY MR. HEBDON:
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- 3 Q
For the record, could you identify the document that we've been talking about for the last 10 minutes or so?
n A
The document that was sent to TVA was Appendix 5 1
g from the -- as part of a letter from B&W to Dr. Roger Mattson, j 22 l dated May 7th.
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23 p MR. EDGAR:
Will you describe the title of Appendix l 24 5?
Ahrsenerters.anc.j 25 i
THE WITNESS:
The title of Appendix is "B&W i
36 Assessment of Decay Heat Removal During a Very Small Break 3
2 LOCA for a B&W 205 Fuel Assembly PWR, January 197 8, C.
V('N 3
Michaelson."
BY MR. HEBDON:
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4 5
O Okay, so this. document that was initially sent to the NRC was also sent to TVA?
6 3
A Correct.
7 BR. FOLSOM: Hold it just a second.
I have a hunch 8
9 you didn't get all that.
10 (Discussion off the record.]
11 BY MR. HEBDON:
12 Q
Now that report 'that was sent to the NRC assessing 13 the Michaelson report is basically a review that was done of O
14 the entire report; is that correct?
15 A
Yes.
Yes, the entire Michaelson report, you me an.
16 Q
Yes.
- 7 A
Yes.
Q Now was there any effort to specifically address
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l 2 ;,, to B&W responding to your January letter to them?
9
- l A
Not specifically, I don't believe.
21 q t
22 0
Do you know if that particular report specifically
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addresses their concern about volume balance as opposed to 23 '
24 mass and energy balance?
f l Ay pp Reporters, inc.
25 A
I don't believe it does.
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Q Do you know if'B&W has ever responded to TVA about 2
their concern with the issue of volume balance versus mass 3
energy balance?
O 4
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Sveoifica11, mo.
1 5[
Q You don't recall or --
6 A
No, we have not done it.
3 _.
7 O
So it's your understanding that the issues that were 8
raised in the letter that was sent back to B&W in Februsry 9
have never been responded to?
10 A
They have been responded to in a general manner II with this report.
12 Q
But they have never been specifically responded to?
13 A
That's correct.
O I4 O
The specific questions that were raised in that 15 letter?
16 A
Yes.
I7 Q
All right.
I3 Now we're up through about the summer of this year.
What's being done with the Michaelson report now?
- '{
A There is no further activity on the Michaelson 2If report in-house at the moment.
22 Q
So then it's your perception that the Michaelson 23 report is settled.
Is that true?
I 2
A In my mind it is settled.
I believe we are still Acr,m7a! Aeporters, Inc.
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. waiting for TVA to say that it is settled.
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'O Have you gotten any indication from them one 2
way or the other whether they agree that it's settled?
3 A
The response to this letter, to the letter 4
transmitting this report, states that they are -- they still 5
have outstanding concerns.
6 0
Okay.
So you perceive it as being settled, but 7
it would appear that TVA does not?
8 A
That's correct.
9 0
Are you then waiting on additional concerns from 10 them?
II A
Correct.
12 O
And it's your understanding then that they are 13 working on some sort of additional set of concerns that they Id are going to forward to you at some later date?
15 A-I would assume so.
16 O
So then until you receive that set of additional I7 concerns from TVA, do you feel that there's any activity or
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'# i! anything that needs to be done by B&W?
u A
No.
2?
Q So until you receive that set of questions, you 21 L. feel the issue is settled?
22 A
Correct.
23 0
.Okay.
I'd like to go on and ask you some more, i
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h general questions that don't specifically relate to the I
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25 Michaelson report itself, but are more general in nature.
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Who in B&W, based on your understanding of the
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2 organization, was responsible for preparing plant operating q.;
3 procedures?
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4 A
It's done in the service department.
5 Q
Are you involved with that activity at all?
6 A
Superficially.
7 Q
In what way?
8 A
The procedures are prepared and some of them I 9
transmit to TVA as a procedure.
10 0
How do you incorporate operational information II involvement that you have with the procedures?
12 A
I don't -- I don't have any connection with 13 incorporating them.
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So then your function is primarily just one of I
15 h passing them along rather than any review?
l 16 A
That's right.
j 1
4 Uj Q
Based on your understanding of the organization, I
j i3 ' who in B&W is responsible for preparing standard technical i
specifications?
2I A
The licensing group handles the -- handles the i
Il]specificationsanditismyunderstanding, of course, that j
,,3 they get their input from the other technical groups.
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23 Q
Are you involved with that activity at all?
"5 A
I am involved with the technical specifications d Rumortm, Inc. l A
25 after they are prepared, sending them to TVA, any comments l
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40 I
from TVA, and keeping up our schedules in-house, handling it
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v 3
Q So again your function is primarily administrative?
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4 A
Correct.
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Who is responsible for seeing that the technical 6
specifications and the operating procedures are consistent?
7 A
Again the service department.
8' O
Is your involvement with that also administrative?
9 A
Yes.
i 10 Q
Who in B&W reviews the actual procedures developed 11 by the licensee to see dnat they are consistent with the 12 p roce'dures that are proposed by B&W?
I l
13 A
The procedures that we have received are given to 7- )
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t 15 i O
Do you receive all the procedures that are eventually l
adopted by the licensee?
l 16,
I7 A
I don't believe so.
l Il 13 h Q
What is the basis for the procedures that you do l
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receive?
Ic there any specific list, or is it just the ones j
T-d that they decide to send to you?
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The la~cter.
I 22 l 0
So then if they send one to you for comment, j
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A That's correct.
l 24 Acq ci Reprters, lnc.
25 ll 0
Is that your statement?
So then based on your 1
l
41 1
perception, does anyone in B&W look at the procedures that
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2 are eventually adopted by the plant to see if they are consis-(
1 l
3 tent with the procedures and the technical specifications that
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5 A
The service department again has a responsibility 1
6; for going,for the procedures and the start-up operation.
j 7
We may or we may not get them through my office.
They may 8
review them separately, I don't know whether they do or not.
2 9
Q So it's possible that the procedures are sent to them 10 directly rather than being funneled through you?
II A
They are not sent to them directly.
The start-up 12 operation works directly with TVA when they get -- when they l'
13 start working, and it's possible that they will work together O
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Q I see.
I 16 I'd like to go on and ask you some specific
'7 questions about the events that occurred immediately after t.
13 ;i t he accident at TMI, and I'm particularly interested in about t
G the first 24 to 36.ours after the accident.
l 20 Would you describe your involvement with the TMI l
t i
l 21 -
taf.; force that was formed on March 28th, 1979?
22 A
I had no involvement.
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23 Q
So you were not involved with that particular group 24 at all?
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l 25 A
No.
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Q Is there any particular reason why you were not r'j 2 l involved?
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3 A
Yes.
That's not my project.
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4 Q
So it was just siaply a matter of you were involved u-5 with other --
6 A
I was elsewhere, right.
7 Q
Do you know of any other events that might be 8
described as a precursor event that you feel are relevant to 9l the accident at TMI?
10 Before you answer that, let me define precursor for I
you.
The way we are using the term, it's a little more general,!
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I think, than the dictionary definition.
But i ;'s basically i
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l anything that might have indicated that an acciddnt such as I'
L 14 d' TMI might happen at some point in the future.
15 The Michaelson report is an example of a precursor i
i 16 l1Pl event.
l
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' ll Are you aware of any others that you feel are i
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I3 relevant to the accident at TMI that we haven' t discussed?
F A
I certainly had no knowledge of any at that time.
I',.
Since TMI I've heard discussions and read reports about valve l
1 2I.
malfunctions at other plants, but I certainly had nothing at i
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22 !.j that time.
i 23 !I Q
Any others besides valve malfunctions?
24 A
I can recall none.
A erb Reporters. Inc.
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25 Q
Do you have any additional information that you feel b
43 I
might be relevant to our inquiry into the events surrounding
- O 2
the accident at TMI?
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3 A
None whatsoever.
I (o) 4 Q
Have we failed to elicit any information in areas v
5 that you believe to be important?
6 A
None.
7 Q
Do you have anything else to add?
8 A
No.
9 MR. HEBDON:
Mr. Folsom, do you have anything else?
10 BY MR. FOLSOM:
11 Q
As associate project ut
.r, you're kind of a 12 B&W contact man for projects that you're involved in.
13 7_s A
Correct.
i l
(J 14 ll' R
0 I get a sense from some of the history of the l
15 Michaelson report that there is more information being submitted i
16 to you by TVA, more questions, than you all have the capacity l
57 to make prompt response to.
Do I perceive that correctly?
d A
Yes, I believe that's correct.
MR. EDGAR:
What do we mean by prompt?
I 2: "
THE WITNESS:
Promptness to me means answering within 1
i 2I. the time that the customer wants his answer.
I i.
22 MR. EDGAR:
Under the circumstances do you feel f3 i
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24 THE WITNESS:
Oh, yes.
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25 l MR. EDGAR:
All right.
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l THE WITNESS:
Yes.
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BY MR. HEBDON:
/y) 3 Q
Is it customary for a customer who submits a
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4 request for a review to give you a specific indication of 5
when they want the response back?
6 A
This happens sometimes, but not always.
7 MR. EDGAR:
Does the customer have a management 8
system for establishing priorities?
I 9
THE WITNESS:
If they do have a system, I'm not 10 aware of it.
Il MR. EDGAR:
Do they have anything like a critical 12 items list?
13 THE WITNESS:
Yes.
Let me go on and say that they
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15 ' call the TVA Outstanding Items List, the acronym of TOIL.
f 16 It is submitted every two or three months, depending on 17 their ability to get it updated.
It lists the items and I30 letters that they think are critical and wish to have a response, or at least to have it on the list that they want a j
i response.
E 2i !
BY MR. HEBDON:
i 22 Q
Again just as a point of trying to put it in l
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23 l: perspective, of the some 10,000 letters that you have received '
24 i from TVA, approximately what percentage of those letters are Ajlfrra amorters. ine.j i
25 included in this list?
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45
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l A
Probably two or three hundred.
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2 Q
So then these are-the two or three hundred out of uf 3
10,000 issues that they feel are sufficiently significant
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4 to highlight and put on a list of outstanding items?
5 A
Yes.
To' explain it just a little further, I think 6
would help.
This listing did not begin until about three or 3 __
7 four years ago.
We are presently on item 280 or something-8 like that, with a large number of those 280 being resolved.
9 So we are down to really working on maybe 30 of them at the 10 moment.
II As a further explanation, the letters pertaining 12 to the Michaelson report did not appear on that list.
13 Q
All right.
So then this is two or three hundred 7-
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14l items out of maybe two or three thousand?
il 15 A
Yes.
16 O
So something on the order of magnitude of 10 percent?
17 A
Yes.
Certainly no more than that.
15 l}
Q Is it your perception then that the way that this l
l I?
list is defined, that this is the most important 10 percent?
20 j' Is that the kind of criteria that you understand to be used d
2I to put things on this list?
l 22 A
I'm not sure that I would use the word "most 23 h important. "
I don' t know the criteria that TVA uses in l
24 +]
putting things on this list.
Some of the things thdt end up f,
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I 25 on there are maybe quite small items which get old, which i
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they do not have closed out, and they show up on the list, in l
2 order to not let them get lost in all the correspondence.
j 3
Q In your usage of this list, you consider these to be
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the hi.ghest priority items that you are working on, on the t
5 TVA contract?
6 A
No.
They are highest priority in terms of timing,
5 -
7 but sometimes the lists have gone as high as six or eight 8
months without being revised, so it becomes extremely out of 9
date.
So we will obtain a very -- much higher priority item 10 that is not shown on the list, we may get an answer before it Il ever gets on the list.
12 Q
I see.
13 But there is some perception that these are among 3
Ix-)
14 l the highest priority jobs from TVA?
15 l
A Oh, yes.
Right, right.
16 MR. HEBDON:
Do you have anything else?
'7 MR. FOLSOM:
I have no further questions.
j d
I50 MR. HEBDON:
Do you have anything else to add?
THE WITNESS:
No, I don' t believe so.
M MR. HEBDON:
Okay, thank you very much.
That l
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21 a completes the interview.
I 22 l
[Whereupon, at 10:35 a.m.,
the interview wac rs VI
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23 [
adjourned.]
24 }
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