ML19308C403
| ML19308C403 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 10/04/1979 |
| From: | Folsom F, Hallman D, Hebdon F BABCOCK & WILCOX CO., NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001230377 | |
| Download: ML19308C403 (69) | |
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NUCLE AR REGUL ATORY COMMISSION
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IN THE MATTER OF:
THREE MILE ISLAND SPECIAL DEPOSITION i
DEPOSITION OF D.
F.
HALLMAN
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?00lFOR8N/I Place - Lynchburg, Virginia 2!
Pages 1 - 68 Date - 4 October 1979 1
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f.]*O (202)347 3700 ACE - FEDERAL REPORTERS,INC.
b OfficialReporters 444 Nor+h Capitol Street 8 0 01 ~9 3 0M7
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Washington, D.C. 20001 NATIONWIDE COVERAGE - DAILY t
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NUCLEAR REGULATORY COMMISSION I
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l In the matter of:
I 5
THREE MILE ISLAND AL DEPOSITION 6
---________+
1 7
DEPOSITION OF:
D.
F.
HALLMAN 8
Conference Room A 9
Babcock and Wilcox 3515 Old Forest Road I
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Lynchburg, Virginia 11 4 October 1979 9:00 a.m.
12 BEFORE:
33 FRED FOLSOM, ESQ.
34 FRED HEBDON, ESQ.
GEORGE EDGAR, ESQ.
15 i
LISTA CANNON, ESQ.
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4/79 C O N { E,N,I @,
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Witness Examination l
D.
F.
Hallman 3
4 5
6 Exhibits 8
(None) 9 10 i
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14 15 16 17 18 19 20 21 22 23 O
24 Ace-Fsderal Reporters, Inc.
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l MADELON j
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2 MR. FOLSOM:
Would you raise your right hand, I
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please?
4 Whereupon, 5
D. F.
HALLMAN 6
was called as a witness, and, having been first duly sworn, 7
was examined and testified as follows:
8 EXAMINATION 9
BY MR. HEBDON:
i 10 Q
Would you state your full name for the record, 11 please?
12 A
Donald F. Hallman.
13 MR. HEBDON:
For the record, I have a document 14 dated October 1, 1979, from Mr. Rogovin, who is the director 15 of the NRC TMI Special Inquiry Group.
16 BY MR. HEBDON:
17 a
Q Have you had an opportunity to read this document 18 in full?
19 A
Yes.
20 Q
Do you understand the information set forth in this 21 letter, including the general nature of the NRC TMI Special O
22 Inquiry, your right to have an attorney present here today as 23 your representative, and the fact that the information you (g
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24 Provide here may eventually become public?
Ace-Federal Reporters, Inc.
A Yes.
1 1
4 I
1 b2 MR. FOLSOM:
At t =,is point we '11 ptit this document 2
in the record as Insert Number One.
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(The document referred to follows:)
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AU 0;;ctier 1,
,m-9 In neoly Refer to:
HTFri 791001-00 g( ')
Mr. D. F. Hallman c/o George Edgar Esquire Morgan, Lewis & Bockius
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l Attorneys for Babcock and Wilcox Co.
1 1800 !! Street l'.U.
< Ul 5 5HL Wachington, D.C.
20036
Dear Mr. Hallman:
I am 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 Uilcox facility, Lynchburg, Virginia.
This vill also confir= cy request for you to have your resume and any documents in your possession or control regarding THI-2, the accident or precursor events which you have reason to believe may not be in official URC files, including any diary or personal working file.
The deposition vill be conducted by members of the !2C's Special Inquiry Group on Three Mile Island.
This Group is being directed independently of the ICC by the lau firm of Eo3cvin, S crn and Huac.
It includes both !aC p
personnel who have been detailed to the Special Inquiry Staff, and outside V
staff and attorneys. Through a delegation of authority from the !EC under Section -161(c) of the Atomic Energy Act of 1954, as a= ended, the Special Inquiry Group has a broad candate to inquire into the causes of the accident at Three Mile Island, to identify major prob 1cm areas and to make recom=cnda-tions for change.
At the conclusion of its invectigation, the Group will issue a detailed public report setting forth its findings and reconmendations.
Unicss yote have been served with a sub oena, your participation in the depos-ition is voluntary and there vill be no effect on you if you decline to answer some or all of the questions asked you.
However, the Special Inquiry has been given the power to subpoena witnesses to appear and testify under 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 acco: pany him at the deposition as his representative.
You should reali::e 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 information they provide may eventually beco=c public, inasmuch as the entire record of the Special Inquiry Group's n
investigation vill be made available to the l2C for whatever uses it may deen V
appropriate.
In time, this information may be made available to the public voluntarily, or beco=e availabic to the public through the Freedom of Information Act.
Moreover, other departncnts and agencies of government may request access to this information pursuant to the Privacy Act of 1974.
The f) information may also be made available in whole or in part to comnittees or v
subcommittees of the U.S. Congress.
orruce >I
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Mr. b. F. Haiiman 2
Octeter i, 1979
'O N.i' If you have testified previously with respect to the Three Mile Island accident, it would be useful if you could recu any transcripts of your p,
previous statement (s) prior to the deposition.
V Thank you for your cooperation.
Sincerely,
&/
Mitchell P.ogovin, Director NRC/TMI Special Inquiry Group DISTRIBUTION TERA FFolsom p)
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l MR. HEBDON:
Off the record for just a second.
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(Discussion off the record.)
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MR. HEBDON:
Let's go back on the record.
f 4
BY MR. HEBDON.
5 Q
Are you represented by counsel here today?
A Yes.
7 MR. HEBDON:
Would you state your name, please?
8 MR. EDGAR:
George Edgar.
9 BY MR. HEBDON:
10 Q
You should be aware that the testimony you give 11 has the same force and effect as if you were testifying in a 12 court of law.
My questions and your responses are being taken
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13 down and will be later transcribed.
You will be given the 14 opportunity to look at that transcript and make changes that 15 you deem necessary.
16 However, to the extent that your subsequent changes 17 are significant, those changes may be viewed as affecting your la credibility.
So please be as complete and accurate as you can l 19 in responding to my questions.
20 If you at any point during the deposition do not understand the question, please feel free to stop and we'll
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try to clarify the question for you.
I i
What is your current occupation?
l 23
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24 A
Nuclear engineer.
Lee Fedec Reponm, Inc.
I 25 O
What is your current position?
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Manager of plant performance and services.
U 2
Q Would you give us a brief explanation of what that 3
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position entails?
4 A
Yes.
5 It entails formulating and providing advice and 6
consultation for the test programs for both initial reactor 7
l startup and restart after refueling.
8 Q
Okay.
9 What was your position in late 1977?
10 A
The same as now.
I II Q
For whom did you work?
I 12 A
G. M. Olds, manager of Nuclear Services.
13 Q
For whom do you work now?
Id A
The same.
I0 Q
The same?
16 A
Yes, sir.
I7 Q
What is your educational background?
I8 A
I have a B.S.
in chemical engineering and a Ph.D.
l in nuclear engineering.
20 i
0 When did you receive those degrees?
21 A
1960 for the B.S.,
1968 for the Ph.D., with an 22 Air Force certificate in meteorology in 1961.
23 Q
Do you have a copy of your resume with you?
24 A
No, I don't.
w Federd 7,eporters, Inc.
I 25 Q
okay.
1 7
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'(')pb3 Well, we can just go through it on the record, then!.
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Would you describe your employment history,
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including positions held at B&W?
is 4
A Do you want the complete history or the B&W history?
5 Q
Not in detail; if you'll just give us a brief 6
description of the positions that you've held, the various 7
companies you've worked for, that sort of thing.
8' A
U.S. Air Force, 1960 to '63, meteorologist; 9
Savannah River Laboratories, engineer, 1967 to '69; radiation 10 technology, Canada Limited, 1969 to '71, Radiation Technology, 11 Incorporated, with the U.S.,
'71 through '72.
12 B&W in the research center, '72 through '75; 13 B&W nuclear service since.
14 Q
Since '75?
15 A
Yes.
16 0
Okay.
17 I'd like to ask you some questions concerning an la incident that occurred at Davis-Besse on September 24, 1977, 19 and I'm particularly interested in trying to get at what you knew or understood about that incident prior to the accident 21 that happened at TMI.
22 A
Yes.
l 23 l
Q Specifically, prior to March 28, 1979, what
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v) 24 knowledge did you have concerning an incident that occurred Ace Fwer) Reponen, Inc.
25 at Davis-Besse on September 24, 1977?
8 A
I had a knowledge that the incident had occurred llgmpb4 2
and that the plant had come off line.
I had attended a generalj
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i gj h briefing on a wrap-up of the incident, in which the PORV had 4
opened and had been taken care of.
5 The pressure had gotten low and the system had 6
essentially recovered.
Also in that meeting was something 7
about an electrical or mechanical problem with that PORV which 8
caused it to do that, and on which corrective action has since 9
been taken.
10 0
Approximately when was that briefing held?
11 A
It was approximately three to five weeks after the 12 incident.
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13 Q
Who'gave the briefing?
14 A
It was given principally by Joe Kelly.
There may 15 have been others with minor roles.
16 Q
Why did you attend that briefing?
17 A
It was -affecting a plant in start-up for which I was responsible.
19 Q
Do you recall studying the incident or the transien,t 20 in any detail?
21 A
No.
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22 Q
Was there any detailed discussion at that meeting 23 concerning the transient, exactly what happened, the sequence fy l
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24 of OVents, that sort of thing?
Ace Federet Reporten, Inc.
i 25 A
Yes, in general it concentrated on the precursor
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(/1mpb5 to the event, the thing which kicked it all off, and I don't i
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recall the details of what that was.
It was something, from e~'
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my memory, in the feedwater system.
1 Was there any extensive discussion of what happene 4
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say, af ter the reactor tripped during the period of time that I
6 the PORV was open?
7 There was discussion that we had lost inventory A
8 and that there was a possibility of pumping a bubble through 9
the core.
10 Q
You mean a possibility of bubble formation in the 11 primary?
12 (S
A Yes.
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13 Q
Okay.
14 A
It did not come across as void formation of the 15 primary, to my memory, it came across as the liquid inventory
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16 got so low that some steam came out of the pressurizer.
17 Q
I see.
18 So it was not the idea of void formation in the 19 primary, but a problem of the bubble being drawn down out of 1
20 the pressurizer through the surge line.
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Correct.
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22 Q
All right.
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What significance did you attribute to this inci-1 23 r3
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A At that point in time I attributed the significancei
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/~'mpb6 mainly to the feedwater problem as something that should be
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solved before we could have the plant operational.
I did not
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at that point in time attribute a particular significance to 4
drawing the bubble out of the pressurizer.
It was something 5
that we didn't want to have happen.
It was not within, as I 6
understood them, our design bases.
7 But the action had been taken and it had been 8
And I didn't follow up in my own mind very much recovered.
9 more.
10 Q
What did you do as a result of the information that 11 you received concerning this incident?
12 A
The information received at that briefing?
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g3 The information received about the incident itself Q
14 at any time.
15 A
Sure, okay.
16 After that briefing the problem was being handled 17 by others within B&W, and within the customer's organization 18 per my understanding.
We were to correct the initiator of the 19 problem and that was outside of my scope.
i 20 Later I received a memo from Joe Kelly, who had l
21 presented the original briefing.
And that memo talked about (m
22 the premature termination of high pressure injection.
It was 23 addressed to myself, Ron Finnen, who worked for me, and others.
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24 I sent a copy of it to Frank Walters, who also works for me, Aa.pe,e n,o,,,, ine.
25 asking him what did he think, did he think this was a significan9 i
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2 0
Okay.
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I'd like to ask you some specific questions --
4 MR. EDGAR:
Off the record.
5 (Discussion off the record.)
6 MR. HEBDON:
Back on the record.
7 BY MR. HEBDON:
8 When we were talking a minute ago you said that it 0
9 was three or four weeks after the incident.
Now Mr. Kelly 10 wrote his memo on November 1st.
Could you try to put the i
11 meeting and the incident and Mr. Kelly's memo in the proper 12 f-sequence for us?
(._
33 A
Yes.
14 The meeting, the briefing occurred before receiving 15 Mr. Kelly's memo.
16 Q
Okay.
17 So -it was -some time before the first of November?
18 A
Yes.
19 Q
All right.
20 I'd like to ask you a couple of questions about 21 the actual scenario and your understanding of what actually 22 happened after the plant had the initial trip.
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23 You mentioned that you were aware that there was
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. AsF.e r:,: n. porters, inc, some steam, the potential existed that there was some steam in j
E 2S the reactor coolant system.
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Yes.
2 Q
As I understand it, your perception was that that l
3 f1 steam came from the pressurizer, not from voiding in the core, x_-
is that correct?
4 5
A That's correct.
6 Q
Did you have any fral at all that there was void 7
formation in the reactor coolant system?
8 A
No.
9 0
If you had bern aware of that, what significance 10 would you have given te it?
11 A
Generally it would have been that it's not supposed 12 to happen.
We have a solid water system outside the pressurizer, g-(J 13 and that essentially a malfunction would have made it happen, I#
and to see what corrective action we should take on that mal-15 function.
16 Q
Would you have considered void formation in the I7 reactor coolant system to be a significant safety problem?
I3 A
Yes, I would have at that time.
10 O
Okay.
20 As a point of reference, I have on the wall over 21
,,s here a graf that was prepared by Mr. Leon Engle from the NRC
( l Staff shortly after the incident at Davis-Besse, using the 23 reactimeter data that was available.
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24-A Yes.
Ace-Federal Reporters, Inc.
25 0
As you can see, it's basically a plot of pressurizer t
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I^hpb9 level and the reactor coolant system temperature and pressure.
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It also has a plot on there or saturation pressure consistent 3
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with the reactor coolant system pressure graf.
4 There is also across the top some description of 5
some of the various events that happened during the incident.
6 And I thought we could use this for reference as we're talking 7
about some of these things.
8 If you'll notice, the plot of pressurizer level 9
goes up very sharply initially and then comes down very sharply.
10 At about two and a half minutes it turns and starts to go back 11 up, which I think you would expect because of the impact of the 12 high pressure injection system.
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13
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A Yes.
14 Q
Then at about four and a half minutes the operator 15 secured high pressure injection, and you see pressurizer level 16 turns and starts to go back down again, unti) about six minutes'I 17 where it starts going up again very sharply.
And it goes up 18 until the pressurizer is full at about eight minutes.
19 At the time you reviewed this particular -- or -that 20 you were involved in the meeting that reviewed this particular 21 rx incident, do you recall any discussion of the fact that the
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l-22 reactor coolant system boiling caused the pressurizer level to
>23 go up sharply there at about six minutes?
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No, I don't recall that.
Ace Federat Reporters, lnc.
25 Q
- Okay, l
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14 would it have concerned you if you had realized I
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that at the time?
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A Yes, it would have concerned me in that I would v
4 have been interested in what the mechanism was for making it S
happen.
6 Q
Do you think you would have concluded that boiling 7
in the reactor coolant system is what caused it to go up like 8
that?
9 A
I don't know.
This would have been outside my 10 field and I would have had to talk with people who knew more 11 about it to find out exactly why this happened.
12 Q
Who would you have talked to?
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13 A
I would have talked with -- started with plant 14 integration, who was our primary contact in design, and that 15 would have led me somewhere.
16 Q
Now plant integration, as I understand it, would 17 have been Mr. Kelly and some of the people in that organization?
18 A
Yes.
19 0
Okay.
20 Now you mentioned some discussion of the fact that the operator secured the high pressure injection system.
In g3
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'3 injection system twice.
He secured it once at about four and
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-J 24 es, ad den seCWed h again at abod sMy mindes, Ace Federd Reporters. inc.
25 after the pressurizer level drops back down.
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Do you recall which one of those two securings of
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2 the high pressure injection system you were aware of at the
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time?
4 A
Yes, it was the second one.
5 0
The second one?
6 A
Yes.
7 Q
Were you aware at the time that they had secured 8
the high pressure injection system the first time?
9 A
No, I wasn't aware of it then.
10 0
Okay.
11 In the course of looking at this particular inci-12 dent did you give any consideration to what might have happened O
13 if the reactor had b en at a higher power level?
e A
No, I don't recall giving that any consideration.
15 BY MR. FOLSOM:
16 Q
You talked of corrective action being taken.
What 17 corrective action did you mean?
A I'm speaking from second-hand knowledge, but the 19 corrective action was a mechanical or electrical thing to fix 20 whatever was wrong with the-diesel equipment, and I don't know the details of that action.
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22 O
Was that action taken as a result of advice from 23 i
B&W?
- 24 A_
From second-hand knowledge, yes.
It was my 4.p.e.ro n.pon.n, inc.
impression --
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What's the source of your second-hand knowledge?
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A It was discussions with I believe Bill Spangler,
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who was herd of the start-up at that time, and that the problem 4
with the core had been fixed, it was a mechanical and/or 5
electrical problem, and that therefore we wouldn't expect it 6
to sit and shatter, as it did before.
O Do you know what the fix was?
8 A
No, I don't.
9 BY MR. HEBDON:
10 Q
I'd like to go on and discuss a series of memoranda 11 that related to some extent to this incident.
I believe they have_come to be known as the Kelly and Dunn memoranda.
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13 First of all, did you receive a memorandum dated 14 November 1st, 1977, in which Mr. Kelly raised concerns about 15 the customer guidance on high pressure injection operations?
16 A
I received that memo; I'm not sure of the date.
l 0
Okay.
i 18
.A
.I'm not sure it's right.
l 19 I
MR. HEBDON:
For the record, I have a memo from 20 Mr. Kelly to distribution list that includes Mr. Hallman, dated November 1st, 1977.
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22 (Document handed to the witness. )
23 BY MR. HEBDON:
24 O
Is that the memo that you received?
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Yes.
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17 0
What was your understanding of Mr. Kelly's concern?
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A At that point in ti.ne?
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Q At that point in time.
l 4
A My understanding was that we weren't pumping the 5
system back up high enough and that he felt it should be 6
pumped up higher pressure before we terminate.
7 Q
What was your assessment of his concerns?
8 A
My assessment was that this was a potential problem 9
that we should look at.
I did not assess it at that time as a '
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10 vital problem, so to say.
11 I,
in my way of doing business, transferred it to 12 one of the people who would technically know more than I did.
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j3 Q
Okay.
14 To whom did you refer the issue?
15 A
I referred it to Frank Walters, to request his 16 opinion.
O Okay.
18 What did Mr. Walters do as a result of receiving 19 the memo?
20 A
At that time, before March 28th, I was not aware 21 that he had done anything.
Later, since March 28th, I've
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22 learned that he did write a return memo to Mr. Kelly.
23 Q
Did you find it at all unusual that he wrote a g-i 24 N'
return memo and did not provide a copy of it to you?
Ace-Federal Reporters, Inc.
A Not unusual.
The way that we worked it was that if'
18
bl4 a problem is important enough that it's going to change some-v thing, a previously established position within the section,
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that I would be involved.
If it was a problem that did not 4
. reach fruition yet that was still being worked or that did not 5
involve change in previously established positions, then it 6
was within his prerogative to go ahead without my advice.
7 Q
Now you mentioned that you were not aware that 8
Mr. Walters had written this response.
Did you, in your way 9
~
of doing business within your group, have any sort of a follow 10 up system to keep track of whether anything was done as a 11 result of this memo?
12 A
Of this memo, no.
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Q So, then, would it be an accurate statement to say 14 that you just passed along to Mr. Walters without intending to 15 follow up on whether anything was ever done about it?
16 A
Maybe those words aren't exactly it.
The follow up 17 would occur in the way that I would intend it to occur if 18 Mr. Walters evaluated it as something that we should change 19 our previous position on, then we.would follow up and pass it 20 to Mr. Kelly and then to follow up particulatly on what did he
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do about it.
That was not my intent, to ask him later 'Did t
22 you follow up on that memo'.
My assumption was it would be followed up'.
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9 Ace FederJ Reporters, Inc.
25 Now Mr. Walters prepared a response and sent it
19 back to Mr. Kelly, and this is a memo dated November 10, 1977,
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2 from Mr. Walters to Mr. Kelly.
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As I understand what you said, you did not see 4
this memo until after the TMI accident.
5 A
That's correct.
6 Q
Having reviewed this now, recognizing that this 7
was af ter TMI, what is your assessment of the observations 8
that Mr. Walters makes in that memo?
9 (The witness reviewing document.)
10 A
My assessment is that it's hard to change one thing 11 4
in a nuclear plant, and that Mr. Walters was stating 'We have 12 a cause and effect here' and that we should 7:c-aed slowly O-'
13 and evaluate.
If we change this thing which may correct one problem, we may create other problems elsetthere.
15 0
Okay.
16 One of the things we've tried to get at is trying 17 to place Mr. Walters' concerns about going solid in perspective 18 l
with Mr. Kelly's concerns about the opera *:or securing the i
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high pressure injection.
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20 How serious a problem would lou consider this l
i 21 problem of going solid to be?
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22 A
I consider that to be a nuisance.
You would blow 23 some water out of the system and you would then have a mess to ys k-]
24 clean up, and that if there is a better way of keeping the 4.pm n,,,,, %
25 system safe than by doing that, we should take it.
I would
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.mpbl6 not consider -- I don't think he or I, neither one thought that U
2 there was an absolute prescription against going solid.
It
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was just something we would prefer not to do.
4 Q
Now to go to the other side of the problem, 5
Mr. Kelly, in writing his memo, as I understand it from our 6
discussions with him earlier, was concerned about the first 7
securing of high pressure injection that we talked about, and 8
when the high pressure injection was secured the first time 9
the system was at saturation pressure and pressurizer level 10 was increasing at least in part due to boiling in the reactor 11 coolant system.
12 A
Okay.
13 Q
If you had been aware of that, if you had recogniz-14 ed that first securing of high pressure injection, would you 15 have been more concerned that something needed to be done to 16 ensure that the operators wouldn't do that again?
17 A
Yes, I would have had I realized the exact sequence 18 of events that he was referring to.
19 Q
Would you have considered the concerns that Mr. Kelly 20 raised about securing high pressure injection while void forma-21 (g
tion was occurring in the reactor coolant system to have been
\\~#
22 more important than any potential problems associated with the
'3 plant going solid?
(
24 A
.Yes.
l Ac.F der;i n porters, Inc.
l 25 O
Okay.
I c
i
21 1
llgmpbl7 Now later in the sequence of events, as I under-2 stand it, Mr. Dunn wrote two memos to Mr. Taylor, and I have l
3 r~ l both of these memos here.
One is dated February 9, 1978, and 4
one is dated February 16, 1978.
5l (Handing documents to the witness.)
i 6'!
Were you aware of either of these two memos prior 7
to the TMI-2 accident?
8 A
Yes.
9 Q
How did you come to become aware of them'r 10 A
They were brought to me by someone within Services 11 l
who said
'I think this is in your area', and I agreed.
I don't 12 1 recall the name of the exact guy who brought it,to me.
r-)
't./
13 Q
Now his comment, as I understand it, is that this 14 was within your area?
15 A
Yes.
16 Q
Did you agree that this was within your area?
17 A
Yes.
18 Q
If it was in your area, why weren't the memos sent 19 to you in the first place?
20 A
I'm not sure.
,o, Q
- Okay, w/
22 i
What did you do when you received these memos?
23 A
I asked Mr. Walters to go ahead and take the action;
(^
I
\\'J 24 that we should take, essentiallyforhimtotakethetechnicall Am FMeal Reporms inc.
!I 25 lead on formulating the action.
i i
t
22 1
Q What do you mean by " formulating the action"?
I
{}mpb18 2
A By deciding what do we do, is this a valid concern,.
3 f'.)T is it a not valid concern, exactly how should we solve this problem that's been raised in here.
5 0
What did you understand to be the problem?
6 A
The problem was that the HPI was being cut off 7
too quickly, but the phrase that struck'me was in the Bert 8
Duna memo which said:
9 "I believe this is a very serious matter 10 and deserves our prompt attention and correction."
11 I did not at that point in time personally look 12 into the technical aspects in detail of what Bert was referring 0) b 13 to.
14 Q
Based on your relationship with Mr. Dunn, did you 15 feel that if he made a statement such as that that this was a concern that ought to be looked at quickly?
a 17 A
Yes, it was a concern for him on his part of the I
plant.
I felt that we should look, though, at what the effects 1
would be on the other parts of-the plant and how to best 20 integrate this thing into the total operation of the plant.
21 Q
Okay.
)
73 22 i
Now as I understand it, you referred this matter to-i 3
Mr. Walters?
?
24
~ Ace-FeWJ Reporters, Inc.
l 25 Q
What then happened?
i k
i
23 A
Then later Frank and I discussed it -- and it was
(])mpbl9 2
somewhat later than this -- and we prepared a memo.
He discuss-()
ed the technical concerns about 'Here are the things that 4
have been recommended, here are some possible consequences of 5
i that, and how do we best decide which is the best way to go'.
6 And we decided we needed more input on other areas, so we 7
prepared a memorandum to integration asking for information.
8 Q
Okay.
9 What additional information did you feel was 10 necessary?
11 A
We wanted to know if you followed this through and 12 you take the plant solid, what are the consequences of that.
Q Okay.
14 I have here a memo from you to Mr. Carrish, dated
-15 August 3rd, 1978.
16 (Handing document to the witness.)
17 l
Did you write that particular memo?
18 A
No, I did.not.
Mr. Walters wrote it for me.
I 19 may have made some word changes, but it was essentially his 20 memorandum.
21 Q
All right.
22 Did you have any other concerns other than the i
23 plant going solid?
gx 24 F
A We had concerns of -- I can't really delve into h..pe,,n.,,,x, 4
25 my memory to say what exactly was going through my mind at that r.
L.m
24 6
(])mpb20 time, but it was a concern that we are going to make a change l
and what other effects of this change are we going to see, if i
2 I
()
any.
O What did you feel should be done with this memo?
5 j
A The August 3rd memo?
6l 0
Yes.
7 1 felt that we should have the questions answered A
8 by the proper design people, which I assumed to be the plant 9
integration people.
10 Q
And you sent this memo off, then, into plant 11 integration?
12 A
Correct.
O What happened next?
14 A
Next Mr. Walters asked me had we received any input 15 back from this memo, and I attempted to contact the party that 16 l
I had written the memo to, Mr. Carrish, achieved two or three i
17 verbal contacts -- I'm not sure from my memory -- and received 18 no response, no written response to it.
1 Q
By "no response" you mean you were unable to I
20 contact Mr. Carrish, or ou were unable to get a response to 21 your memo?
22 A
I was able to contact Mr. Carrish, but not immediates J
23 ly.
I got no written response back to the memo, which is what
^)
I mean by "no response".
1 Am.r.o.,.i n.,o,
,. ine.
25 0
All right.
25 o
BY MR. FOLSOM:
{lgmpb21 i
2 I
Q Did you get a verbal response?
3
,x()
A I got a verbal response, yes.
Q What was that?
5 A
The verbal response was a conversation which says
}
'I think we're okay' or
'I don't think there's a problem'; I I
6 7
don't recall the exact words.
And, as I've stated before, 8
after walking away from that I tried to decide what does "no 9
problem" mean.
Does it mean there is no problem with follow-10 ing to the letter of the law the recommendations that were I
11 originally banded to me, or does it mean there's no problem in I not following them, they were already covered by what we have
,r3 13 s_-
out there.
14 Q
What did you do about that question in your own 15 mind?
16 A
I tried to contact Mr. Carrish again.
17 Q
Were you able to?
18 A
No, I don't believe I was able to after that before 19 March 28.
20 0
Then what happened?
,ew A
After March 28th?
(
22 Q
No.
23 A
Oh, excuse me.
I f~s t
)
k' 24 I was not able to establish contact with Mr. Carrish.'
3, p g,,,,,,,,,,,, ge i
25 Q
Did anything happen between that last attempt, j
i e
26 i
f I
( 'pb22 unsuccessful attempt to contact Mr. Carrish and March 28th, ss i
2 l
1979?
l
(~,
3
(_,1 A
No, not to my knowledge.
4 i
BY MR. HEBDON:
i l
5 Q
Now in the course of your conversations with l'
6f Mr. Carrish, did you discuss with him in any detail what you 7
felt should be done with this memo?
8 I don't recall having a technical discussion with A
9 him.
I discussed that I felt this memo should be answered j
1 1
10 where we could establish a position and then go from there 11 with whatever changes need to be made.
But I do not recall 12 !
,e w.
j saying that we should go one way or the other.
)
t'
13 Q
Well, apparently there was some confusion because 14 of the fact that in the memo there'c really two things asked 15 for.
One is an answer to two very specific questions on what 16 would happen if the plant goes solid, a nd unen the closing 17 lines in the memo request that integration resolve the issue 18 of how the high pressure injection system should be used.
19 Now do you recall in your discussions with Mr.
20 1 Carrish pointing out to him that there were in fact two parts i
21 to your request, one was a request for the very specific O(~
22 answers to the questions and the other was the resolution of how to operate high pressure injection?
e, 24 A
I don't recall pointing that out specifically, no.
Ace-Federal Reporters, inc.
l 25 Q
Do you recall any perception in your mind that l
27
()b23 possibly Mr. Carrish didn't understand er didn't recognize 2
that part of what you were asking for in this memo was a
. ()
request that he resolve how the high pressure injection system 4
should be operated?
5 A
You're asking if I thought that he did not under-6 stand that part of the question?
The answer is no, I didn't 7
receive any input back that would make me believe that.
8 Q
Okay.
9 So you didn't have any feeling that he didn't 10 understand what you were asking?
11 A
No, I didn't have any feeling.
12 Q
Okay.
13 Now he did provide you, as I understand it, with 14 a verbal answer to the two specific questions.
15 A.
The Verbal answer was, in my mind at that time, 16 not addressed to the two specific questions.
It was addressed 17 to the overall memo; and the verbal answer, again, as I recall la it, was
'I don't think we have a problem', which could be 19 interpreted several ways -- at least two ways by me -- and it 20 was a question I. asked myself after the verbal conversation 21
(~N-and when I tried to get back with him:
One, does he mean 22 that we now have adequate instructions out there to cover this
-23 circumstance and that no additional instructions are needed;
^T I
s-24 or, two, does he mean that he. agrees with Mr. Dunn in that Ace-Federd Coporters, Inc.
25 we should make a positive change and transmit same to our i
28 l
ll$324 operators, that here is something new and we believe you 2
l should go this way now.
l
"'T 3
So that was why I tried to contact him later, i
i i
~-
1 4
still expecting a response to the memo such that we could l
i 5
j have a basis to start operating.
But I developed that 6!
l question, what does
'I think we're all right' mean.
i 7
l 0
okay.
8 Now at the time he gave you that answer, is it just a matter of your reaction times weren't fast enough to 10 ask him the question when he gave you the answer that there 11 was no problem, or was there some reason that you had to then 12
/'~,
contact him later?
13 A
I don't think I understand that question.
14 Q
He gave you the answer cf
'I don't think we have 15 a problem'.
Why didn't you simply ask him right then and 16 there 'Well, what do you mean by 'We don't have a problem?
17 Why was it a matter that had to be brought up later on in an 18 attempt to communicate with him later?
19 A
As I recall, he was on the way to a meeting which 20 he was late for, and we didn't.take the time at that particular 21
(~',
point to resolve why there wasn't a problem.
And, truthfully,
'~'
22 I don't think I correlated it about no problem, which way does 23 r~)
it go, until I had walked away also, and then I had to try to 24 get back to see what was in his mind.
Ac..ree.r : n porters, inc.
Q Now in the course of this conversation, which I
I I
29 e
(~-b25 apparently was fairly brief, which you had with Mr. Carrish -- :
%i l'
2 A
Yes.
( )
Q
-- did he discuss with you at all the fact that 4
i this question of the water surge through the relief valves i
5 l
and the pressurizer going solid had been considered as part 1
of the ATWS review?
6 1
A Not in that conversation, from my memory.
8 Q
Do you recall that issue coming up in any conversa-9 tion?
10 A
No, I don't.
Il l I
Q Were you aware prior to TMI that the question of a 12 water surge through the relief valves had been addressed as
-s x-13 part of the ATWS evaluation?
14 A
No, I wasn't.
15 Q
So you weren't aware at all, then, that that j
16 issue had been considered and apparently resolved?
17 A
No.
18 Q
All right.
19 -
I guess we discussed the f act that you had this 20 conversation with Mr. Carrish.
Approximately when did that take place?
,y 22 A
It was approximately late February, early March of 23 this year, from my memory.
/s)
'x_/
24 i
Q Soitwaswithinamonthorsopriortotheaccidenp Ace-Federal Reporters, Inc.
i 25 at TMI?
30 i
l I
A Correct.
.{}b26 Q
When you attempted to contact him again you were l
2
()
unable to contact him, is that correct?
4 A
Yes.
5 Q
Do you normally, in the course of the work that you 6
find it this jthpeopleinsomeoftheothergroupshere, do 7
difficult to establish communications with another person 8
within the B&W organization?
9 A
That depends, and it depends I think principally j
on what the other person is working on at the time.
My percep-11 tion was that Mr. Carrish was very busy and he was not in his 12 office very much.
- 04. calling he would not be there quite 7-s
\\-)
13 frequently.
So, no, I don't think it's normal, but it will 14 happen more than once.
4 15 Q
Just to make sure we're clear on another somewhat 16 related issue:
17 If you had understood that the securing of high 13 pressure injection by the operators at Davis-Besse had resulted 19 because of a boiling in the reactor coolant system, what actions 20 would you have taken then?
21 A
I would have escalated it, in my own mind, had I
<~
22 understood that we had -- other than sucking the bubble out --
'23 we had actually put enough heat into the water to boil it, my I
24 actions would have been either to escalate it to my boss, say
.,m %n,,, %,
25
'Here's a problem that I haven't been able to resolve and I c
31
.(])b27 need your help in getting the attention on it' or to go back 2
and sit at Mr. Carrish's desk, since I preceded him at that I
th 3
(,)
time as the man who held the key to this action, go back and 4
sit at his desk until he got there and made sure that we 5
addressed it.
6 l
Q Do you feel that if you had taken that action that 7
the precautions that were discussed in Mr. Dunn's memos to be 8
sent to the operators would in fact have been sent?
A I don't feel they would have been sent as Mr. Dunn 10 had worded them, no.
I think something would have been sent, 11 but not his exact actions.
12 Q
How do you feel it would have been changed?
x 13 A
I do not feel that we would have.left the injection 14 water on for 20 minutes as part of the action.
I think we 15 would have arrived at other criteria for termination.
16 Q
And I realize this is just speculation, but what 17 sort of criteria do you feel would have been established?
18 A
I feel we would have established the criteria that i
19 we have now, which' is to make sure that you have adequate sub-
.l 20 cooling before this is terminated.
21
'{#3 0
Go then you feel that the precautions which would 22 have been set out might have been somewhat similar to the ones 23 that are in effect now because of the accident at TMI?
('s N-24 A
Yes.
hee-Fedora Reporters. Inc.
25 l
Q
- Okay, l
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L_
I
..u
32 l
l 1
(~'/pb28 BY MR. FOLSOM:
j
\\_
2 Q
Going back to the corrective action that we were
(])
discussing earlier, this corrective action with respect to 4
operator performance wasn't taken, is that correct?
5 A
This corrective action of sending --
6 O
The corrective action regarding the operator 7
prematurely securing the HPI.
8 MR. EDGAR:
Well, what was the prior corrective 9
action?
10 MR. FOLSOM:
Well, I'm trying to figure out what 11 he's talking about.
He said that B&W -- or that he had learned 12 I
that corrective action had been taken.
13 THE WITNESS:
Oh, you're talking about the TECo 14 incident.
15 MR. EDGAR:
The PORV.
16 BY MR. FOLSOM:
17 Q
What corrective action did you take with respect to 18 the PORV?
19 A
Did I take?
20 Q
Or did B&W tLke?
l 21 A
I'm not sure, sir.
I took none because that 22 involved a particular piece of hardware that was outside my 23 scope.
spe: n.,or,,, inc, Q
Well, do you understand that what went wrong with 25 the PORV, there was a missing relay?
i
- m f
33 llhmpb29 A
That sounds correct.
I 2
Q And the corrective action is put the relay in there;.
(~;
3 f
(,,/
A That sounds right, correct, 4
Q So B&W didn't do anything with respect to that?
j l
5 A
Whoa.
I'm not sure.
I think they did, but that's i 6
outside my scope.
7 MR. EDGAR:
Do you know the specific corrective 8
action taken at TECo on the valve?
9 THE WITNESS:
No.
10 MR. EDGAR:
It may have been a simple matter of a l
11 relay, but it may have been more, is that right?
12 :
(~3 l
THE WITNESS:
Yes.
\\_)
13 MR. FOLSOM:
All right.
.14 BY MR. FOLSOM:
15 Q
So the relay problem wasn't one of which you're 16 familiar?
17 A
That's correct.
18 Q
And an operator performance problem is one that we 19 now know wasn't corrected before TMI, that is the premature 20 securing of HPI was not taken care of by any action by B&W 21
(~'
before March 29 of this year -- March 28 of this year?
22 A
The question -- Well, I suppose the question l
I 23 really is was any corrective action needed based on what was l
73
\\J 24 already out there, is that right, sir?
l Ace-Federd Reporms, Inc.
25 Q~
What's your answer to that one?
i l
t i
34 I
I A
I don't believe there was, really.
gggmpb30 2
Q This didn't call for corrective action?
i c'
3
()
(Indicating chart on the wall.)
j 1
4 A
Could I phrase it another way?
'5 There were instructions out there to stay within 6 I I
a certain pressure-temperature envelope, and if that had been l
7' i
done, if the operators take the actions to make the plant stay 8
within this envelope, the plant operates safely, in my opinion.
9 So there's a question of do we take a discrete action with new 10 technical information or do we reinforce the previous action 11 which we have set out.
Now we did not take an action with discrete new f3(-)
13 technical information, to my knowledge, whether it was needed 14 as a result of this incident, new technical action wasn't 15 necessarily needed, new action to inform the operator this 16 can happen to you and be sure that you understand and watch 17 out for it, that's a question of judgment.
We have taken 18 action since then.
We said the incident happened, there is a 19 reason for it, and we should do something about it.
20 MR. HEBDON:
Now if I can interrupt just a minute before you go on --
{~]
'~'
22 THE WITNESS:
Sure.
23 BY MR. HEBDON:
y
\\J 24 0
You mentioned that there are precautions or there j
AceJederst Reponers, Inc.
i 25 are instructions that say to keep the plant within certain l
i l
35 I
(}mpb31 pressure and temperature limitations.
2 A
Yes.
3
(_s)
Q Do you know of any precaution that talks to the 4
operator at all about the issue of saturation pressure and S
maintaining the plant in a subcooled condition?
6 A
I know of nothing that calls for that specifically, 7
but if you maintain within these envelopes this will happen 8
automatically.
9 Q
Where is the envelope defined, how is this envelope 10 defined that would keep the operator in a subcooled condition?
11 A
They're in the technical specifications as 12 pressure-temperature curves, and there's a band of pressure-km/
13 temperature at which you keep the plant.
14 Q
And these are in the standard technical specifica-15 tions?
16 A
You used the word " standard".
They're in the l
17 technical specifications.
18 Q
They're in the tech specs?
19 A
I'm sure they're in the standards also, i
20 l
Q The technical specification that discusses pressura-21 temperature relationships.
rs
(~)
22 Now I would be willing to accept the fact that 23 there's a limit on high pressure for a given temperature c) f X/
24 I
because of the brittle fracture mechanics problem.
But do 4..pe,, n,,,,,, %,
25 you know for a fact that there was also a lower limit on
{
Il
36 I
{~}mpb32 pressure and temperature?
2 A
Yes.
Now I don't know for a fact that that is in i
3 the technical specifications, but it is supplied in informa-w 4
tion that B&W supplies.
5 Q
Explicitly there is a graf somewhere that shows 6
pressure and temperature and there is a low limit on that 7
envelope?
8 A
Yes, there are probably several grafs covering 9
different pieces of the action, and all of the pressure-10 temperature is covered, such as you have a band defined and 11 you keep the plant within this.
12 Q
Would it be possible to obtain a copy of that 13 instruction?
14 A
Yes.
15 Are you interested in any specific one, any 16 specific plant?
l 17 0
Well, specifically Davis-Besse and TMI, since 18 they're the ones we're related to.
But specifically I'm 19 interested in any sort of a precaution or even more strongly, 20 a limitation that tells the operator that he must keep the 21 plant within a certain envelope and specifically defines that O'
22 envelope, particularly on the low side with low pressures for 23 a given temperature.
}AJ.
eS 24 A
Yes, I think that can be procured.
Am-FWwW Roonm, W.
25 Q
Okay.
k
37 I
' (])mpb33 If you could provide that, I would appreciate it.
2 l
A Okay.
()
MR. FOLSOM:
Let me continue with this just a 4
moment.
I won't beat it to death.
5 BY MR. FOLSOM:
6 Q
Something prompted Messers. Dunn and Kelly to 7
recommend a change in operator instructions.
8 A
Correct.
Q And that came over to your shop and was handed to 1'
10 Mr. Carrish -- was handed to Mr. Walters --
11 A
Who works for me, yes.
i i
12 f
g~
Q
-- who referred it back to Mr. Carrish.
l 13 A
Yes, correct.
14 1
Q And it died.
15 A
Died is a strong term.
It was not acted on within l
16 the time span between August the 3rd and March the 28th.
And 17 i
when I say " acted on", it was not brought to a final resolution.
I 18 There were efforts made to get a response and then 19 to go ahead to a final resolution.
So I don't think " died" is 6
exactly the right term.
BY MR. HEBDON:
gg 1
Q But in a seven month period it hadn't been resolved.
t b
23
- 3. g-A That's correct.
k %s' 24 Q
Did you have any expectation that it was going to j Am Fewst Roomn, W.
25 be resolved?
i.
i
38 A
Yes, I expected an answer to this such that we
{ mpb34 2
could then have a basis for going ahead.
Q But you had not received an answer in seven months.
().
4 A
That's correct.
5 Q
Just in the normal time frames of the way things 6
are done, was there any expectation or any perception in your 7
mind that if you hadn't gotten an answer in seven months you 8
were never going to get an answer?
9 A
There was not that expectation in my mind because 10 of the contacts, and my memory of the contacts is, yes, we're 11 going to get something to you.
So I did not consider it a dead 12 '
issue by any means.
7-)s
's_
13 In retrospect, it had gone much longer than I 14 would like for anything to go without arriving at a resolution.
15 BY MR. FOLSOM:
16 Q
Your last contact with Mr. Carrish was no problem?
17 A
Yes.
18 Q
And that would seem to me to indicate you had no 19 basis for expecting any further response.
20 A
It could be #.nterpreted like that.
I still expected 21 a response in writing r,o that I could have a basis for taking O'
22 action, since it wr.s -- I am not a design person and I fit my I
23 instructions.to where they're consistent with the design.
I l
did address it to a design organization and I expected somethinlg 24 i
4,.,,,3,,,,,,
25 solid that would say 'Yes, we do now understand what to do and T.
i
39 1
{}pb35 we're going to go ahead and do it'.
2 The conversation that I had with Mr. Carrish where !I
()
he said it's all right, as I said, raised questions and I 4
wanted to clarify that before we went ahead and arrived at 5
the final resolution and sent it through.
6 So in my mind, anyway, I was expecting a written 7
response that we could refer to and then from that proceed 8
with further action.
9 BY MR. HEBDON:
10 0
I'd like to go on and ask you some questions that 11 are a little bit more general that relate to plant procedures 12 and technical specifications and how B&W goes about doing some O.
13 of the things that you do.
And I realize that these answers 14 will be based on your understanding of the organization and 15 are obviously not the official company policy or anything else, 16 but just your understanding of the system.
17 Who in B&W is responsible for preparing plant 18 operating procedures?
A Plant operating procedures, as we call them, no one.
I 20 l
We prepare plant operating specifications which laid out the 21 s technical basis for an operating precedure, and my perception rS
\\~/
22 is that the utility, the licensee takes these and then prepares; i
l.
.23 the detailed operating procedures.
g-
\\_-
24 But the rreparation of plant operating specificatio'ns Ace-Federd Reporters, Inc.
25 concerning the overall plant is my responsibility.
i
40 0
Okay.
(}b36 2
Now these plant specifications, are they related toj 3
("')
what I believe are referred to as draft procedures, DPs?
4 A
Yes, that's the old term.
The specification is 5
the new term, essentially.
6 0
I've seen a few of these DPs and they appear to me 1
7 to be whac the name implies, draft procedures that are sent to 8
the utility.
J 9
Is it your perception that they're not draft 10 procedures?
11 c2 A
Since I have become active in this position my 12 perception is that they are the technical requirements for how gS
\\_/
j3 to operate the plant, and that they're not a document that the 14 operator will take as is and go out and operate it.
They will 15 be flushed out in specific plant language, identifying some-16 times instrumentation, dial numbers, et cetera, that 'here are 17 the actions you take and here is where you go to take the 18 actions'.
19 0
But the general description of how the plant should 20 be operated?
21 es A
That will be included in either the draft procedure 22 or the spec, operating specifications.
23 Q
Okay.
3 N-24 So in that area, the preparation of the draft hoe-Federd Reporters, Inc.
25 procedures, the DPs, that would have been in your group's area l-t i
0
41 I
1
{ 7b37 of responsibility?
2 A
Correct, for the overall plant operation.
There
()
are some dealing with specific equipment or specific systems 4
that are not within our scope.
5 Q
How does your group factor operational information 6
and operational experience into the preparation of these guide-7 lines?
8 A
We look at how well they have been operating in the 9
field, especially on our test procedures; we prepare summary 10 test reports from the tests that are performed, evaluate how 11 the tests go and see if we need to make modifications to make 12 it go better or to get better data.
k-13 Q
Now this is for the test procedures.
How about the 14 operating and emergency procedures?
15 A
The operating and emergency procedures.
When we 16 are preparing a new document for a new plant we refer back to 17 what has happened and should we change this to make it operate 18 better.
19 If we were to spct something big, something that 20 we felt was a vital issue, then we would inform our other 21 customers, tae previous customers, of 'Here is something we s
(N /
s 22 have uncovered and we think you should consider this in your 23 procedures'.
/'JA 24 There was a mechanism by which, when we get problems a.,
no, %
l 25 in from the field, then we consider those in preparing l
l i
42 l
I instructions.
()b38 x_
2 How do you get this information from the field?
l O
A We have -- well, it's in a couple of phases.
l
()
\\
4 On a normal startup there is a crew of B&W people 5
there and internal documents prepared on problems are sent 6
back to this office for information, resolution, whatever is 7
required.
That's one source of information.
Once the plant has passed the unit acceptance 9
criteria, we get it back in by personal contacts with the plant, I
I f
by them calling up to ask us to help them with a problem or 11 whatever.
There was at that point in time no mechanism other 12 then depending on the utility itself to provide us with it.
13
- 2 Q
How does the site problem report get into this?
14 A
That is the. mechanism by which the information is 15 transmitted back when a problem is identified on the plants 16 that are in operation prior to having resident engineers on the 17 site; they are simply prepared somewhere within B&W by personal 18 contacts with the operating plants where they said 'We had 19 this problem'.
The site problem report is then drafted up to l
l 20 lock it in and make sure it's retrievable.
t t
i 21 Now when the Davis-Besse incident occurred in '77, l
Q 22 was it still in the startup phase?
23 A.
-Yes, it was.
So we had a site problem report on g
\\_)
24 that particular event.
w.p.a.ru c n.,,,inc, 25 Q
To what extent was the Davis-Besse transient factored
- I i
43 1
(b39 back into the draft procedures that you prepared?
\\_/
i 2
A I believe it probably wasn't in that my personal l
()
view of that transient was that it had gone properly.
I was 4
not aware at that time personally of this fine structure carly in the transient.
I was aware that later on the 6
operator had refilled the system and had pumped the pressure 3
7 back up and th9n he terminated HPI.
And my general impression 8
was, yeah, that went okay.
9 This, frankly, I wasn't aware of.
10 Q
Does anyone,in your group conduct a systemmatic 11 review of these various transients to identify problems such 12 as the earlier securing of high pressure injection?
73
(_)
13 A
That depends on how deeply we are involved.
The 14 organization as it existed then was such that I was not 15 responsible for that particular plant.
I was responsible for 16 a piece of the action.
17 The resolution of this SPR did not pass through la my hands.
I attended the meeting at which it was discussed, 19 but neither I nor my people were intimately involved.
It was 20 carried on by another organization to resolve the problem and 21 see what should be done about it.
And the SPRs are distributed
~
f' 22 to us from those areas of which we are cognizant and have l
23 responsibility, and they are factored by the people who are l
(_s[
24 I
writing procedures into the new procedures.
Ace-FedwW Reconm, Inc.
25 I'm not sure that I totally answered your question 9
\\
44 1
1
'o40 there.
2 O
Well, the problem I have is it's just a fairly
(}
simple thing, and I'm trying to ask it without asking it in an 4
accusing sense.
The question simply is:
6 If your group is the group that works on preparing 7
these draft procedures --
8 A
Yes.
9 Q
-- why didn't anyone in your group look at the 10 Davis-Besse incident in sufficient detail to realize that the 11 operators had secured high pressure injection while void forma-12 tion was occurring in the reactor coolant system?
13 A
What I think, happened there is my group was not 14 involved in the details of going through that particular 15 transient.
We saw some information, I believe, that said 16
'Okay, whenever they terminated the HPI they were back within 17 this envelope of operations', and that therefore we believed 18' the operators acted in a normal fashion.
They kept the action 19 going until they got back right.
And then at their choice 20 they terminated the accident and they were in the right spot.
21 Now why we didn't see this in detail I'm really 22 not sure.
23 Q
Do you have any feeling for who it was that told dp ) ' n.,o,.., ine, 24 you that they were back in their proper envelope when they 25 secured the high pressure injection?
The reason I ask that is I
~
45 1
l i
gggmpb41 Mr. Kelly, who's the une that apparently gave the briefing and 8
2 was the one that was the most intimately involved with rt /iewing I
3
(')
this incident, did realize that they had secured the high 4
pressure injection the first time; in fact, that'swhyhewrotel his memo.
6 Mr. Dunn also realized that, and that's why he 7
wrote his memo.
8 So even with this issue having been highlighted a
~
twice, once by Mr. Kelly and once by Mr. Dunn, there still l
10 doesn't seem to have been a suf ficiently in-depth look at this l 11 transient to realize that the operators had secured the high 12 pressure injection system twice.
,e
(/
13 A
In retrospect, I agree that I myself had 'ot looked 14 at it in-depth enough to realize what I now understand is the 15 problem that Mr. Kelly and Mr. Dunn were addressing, and the 16 mechanism for looking at same, there exists a formal procedure 17 which defines the information you look at when you're going to la draft a draft operating procedure, in your terminology, and 19 as a result of that this should have been examined.
t 20 I just personally did not examine it in that much detail.
,eq
\\
22 Q
Okay.
i 23 MR. FOLSOM:
May I ask a question.
'J 24 BY MR. FOLSOM:
Am-FMwal Reporurs, Inc.
When Mr. Kelly returned from the Davis-Besse plant l; 25 Q
1
46 i
I after the September 24, '77 incident --
gggspb42 2
l A
Yes.
s 3
(v) 2
-- and gave a briefing, is this a frequent occurrence 1 t
4 A
If you'll define " frequent".
5l 0
Have you ever attended another briefing cf a i
6!
l similar nature?
1 7l A
Yes.
8 Q
How often do those occur?
9 A
Once or twice a year.
10 Q
As a result of transients at B&W plants around the i 11 country?
12 A
Uh-huh.
,3
('-]
13 Q
What's the purpose of those briefings?
14 A
The purpose is to present 'Here is what happened, 15 now what do we do about it', and to pull together the various 16 technical disciplines that are needed to resolve the problem 17 in one place such that you shorten the communications chain.
18 Q
That briefing didn't -- or did it -- prompt action 19 by your branch?
20 A
That briefing did not prompt action by my branch.
O To your knowledge, then, do you know that it
,-m,
'j 22 prompted action by any other branch?
23 A
' lou asked from my knowledge?
7-i
(~)
24 0
Yes.
Ace-Federst Reporters, Inc.
A I have no direct knowledge.
f 25
47
- ( ',mpb43 0
Well, it was a little unfair, the prior question, l
1
%_/
2 but I want to know, do you know?
f')
A I recall a report being prepared and being trans-v 4
mitted to Davis-Besse -- this is second-hand information -- but-5 I've not read that report in detail and do not recall being on 6
distribution for it.
2nd that's about the extent of my know-7 ledge of it.
8 My perception was that B&W was taking action and 9
had gone back to design people for them to essentially solve 10 the problem in coordination with the nuclear service department,.
11 I was just not involved in it in that phase.
12 I attended the meeting just to get some information 1
(e 13 since the total plant startup and testing was my responsibility, 14 and I wanted to have some background on what was going on.
15 Q
Well, was sloppy plant management during startup 16 a concern of your branch?
17 A
Sloppy. plant management by --
la Q
Somebody picking up a relay off a PORV and taking 19 it to some other spot in the plant?
20 A
That particular one would not have been my concern 21 because I would have dealt more with hardware than how you
,, g
, (-)
22 operate the overall plant.
So that would have been handled by 23 others.
' ()
24 O
Would operator action be a concern?
j Am-FWeel Rgemn, loc.
25 A
Operator action would be a concern, operator action f
48
{])mpb44 as defined in the concept of 'here's how we're going to handle 2
the plant'.
[)
Q But in this briefing you Missed the first operator i 4
action that was crucial to a particular Davis-Besse transient 5
of September 24,
'77.
6 A
Yes, based on what I know now.
I was not aware of i
i this at that time.
I was aware of the second time at which 8
they terminated HPI.
9 BY MR. HEBDON:
10 Q
Do you recall when you became aware of the first' 11 time they secured HPI?
A It was after March 28 of this year some time, a s
\\--
13 month or two after that.
14 Q
All right.
15 Who in B&W is responsible for preparing technical 16 specifications?
j7 A
Licensing is responsible for that.
18 0
Do you know if this group takes operational informa-19 tion into account in preparing technical specifications?
I 20 A
I don't know.
21 Q
Okay.
-}
22 Who is responsible for seeing that the technical 23 specifications'and the' draft operating procedures are consistent?
g.
x/
24 A
We'are responsible for seeing that, and also I Ace-Federet Reporters, Inc.
25 believe licensing has some responsibility.
But I think we have-i
49
(~'mpb45 the prime responsibility.
s_/
2 O
In the event of a conflict, which takes precedence?i e-3
(,g A
The operating procedure or the technical specifica-j 4
tions?
5 Q
Yes.
6 A
There should be no conflicts.
But if there are 7
conflicts I would believe the technical specifications would 8
take precedence.
9 Q
Who in B&W reviews the actual procedures developed 10 by the licensee to see that they are consistent with the draft 11 procedures proposed by B&W?
12 A
To my knowledge, no one reviews each procedure 13 that is prepared by the utility.
Those procedures which are 14 related to documents which plant performance services would 15 have prepared should be sent back to plant performance services, 16 those which are related to a specific component sent back to 17 the originator, where the procedure originated from.
18 Q
Then do I understand you that the procedures, for 19 example, that were developed at Davis-Besse based on the draft 20 procedures that your group prepared are sent back to you for
-21 review to ensure they are consistent and appropriate?
22 A
They are not always sent back to us, and that I believe is at the utility's discretion.
Those that are sent w
N-24 back are usually the test procedures which are to be performed, j
4c..r.o.r.: n.oort.,3, inc.
25 and when they are sent back we review them.
We also have plant j
50 gggmpb46 integration, and that is a separate entity, and then comments are sent back for resolution.
r5 3
i
)
On the operating procedures themselves, that is l
4 spotty.
Sometimes we see them, sometimes we don't.
5 Q
So then it's your understanding that there is no I,
6 systemmatic method for reviewing the actual procedures by which' 7
the plant is operated to ensure that they are consistent with 8
the draft procedures that you have prepared or with the 9
technical specifications?
10 A
That is my impression, yes, sir.
11 2.180 Q
Are you aware that the Davis-Besse small break procedure was revised to include a precaution designed to
\\_ /
13 prevent premature securing of high pressure injection and to 14 alert the operator to possible failures in the PORV?
15 A
I was not aware of it before March 28th.
I've 16 heard about it since then.
17 Q
Would you normally have been kept aware of such 18 changes?
19 A
There exists no formal system that requires -- I 20 guess the straight answer is no, there is no formal system that 21 I am aware of that requires utilities to send back those changes r~3 22 to us for review.
I don't think it happens.
23 Q
Would you care to comment on the advisabi.'.ity of
, ~s 24 n t having those changes in those procedures reviewed by B&W?
Ace-Federal Reporters, Inc.
25 I don't think I'd care to comment now because that's A
l
51 I
l
\\
i 1
llgmpb47 something we are really rethinking ourselves and we haven't 2
i arrived at a conclusion as to whether all procedures should be,
<~s 3
)
sent in to B&W or the vendor to be reviewed before they are v
4 applied at any plant.
I 5
Q The reason it strikes me as rather odd -- and you I
may or may not want to comment on this -- is that Mr. Kelly I
7 and Mr. Dunn proposed a change to a procedure that you had a 8
concern with, and people within B&W debated that change over 9
a period of about a year, and as a result never made a change, i
never proposed the change, when in fact the change was already ;
10 11 l
made by the utility in a completely separate operation.
12 !
i Does that strike you as a rather strange way to 73 13 develop procedures for a plant to be operated under?
14 A
Are you asking for my personal opinion and not 15 from the utility's point of view?
I 16 MR. EDGAR:
I don't understand the question.
I'm trying to grapple with the notion.
18 The utility, though, has the responsibility to 19 operate that plant and knowledge of how to operate that plant.
20 THE WITNESS:
That's true.
21 MR. EDGAR:
And doesn't the utility have knowledge
,r-)
22 as to when they need technical advice also?
I 23 I
MR. HEBDON: Well, it's hard to say that a utility
<w i
t It's kind of a catch-22l.
\\.J 24 knows when they need technical advice.
Aa-Feetal Rmorurs, lm.
25 If they knew they needed technical advice, that would be fine.
i I
i
52 1
1
('7b48 But how do you handle a situation where they think they don't
\\_/
i 2
i need technical advice and in fact they do, because it would 3
eS appear to be somewhat of a dichotomy here.
Therutility went l _j 4
ahead and made a change that B&W was sitting here agonizing S
over whether or not should be made, and yet B&W never knew 6l that the utility had made the change, and the utility never i
7 knew that B&W was sitting here agonizing over whether or not a change they had already made was advisable.
9 BY MR. HEBDON:
10 Q
Now does that seem to be az. insulation of the two 11 groups from each other that is detrimental to the overall safe operation of_the plant?
13 MR. FOLSOM:
Or other similar plants?
14 MR. HEBDON:
Well, that's another part of the 15 question --
4 16 MR. EDGAR:
That's a separate question.
17 MR. HEBDON:
-- because to complicate the problem 18 ever more, Mr. Cresswell in I&E Region III was going through 19 exactly the same problem that Mr. Kelly and Mr. Dunn and you
'O people here at B&W were going through.
21 BY MR. HEBDON:
+g 22 Q
And I was it.terested if you would care to comment on the fact that that seemed like a~ rather odd way to erasure f
23 f3 I
(_)
24 the safe operation of a plant.
You had three different AwFWe9 Rgomn, tm.
25 9
organizations working on the same problem and none of them know; i
1
--.s s--
53 I
b49
-that the other one is working on it.
2 A
You asked for comments, is that an odd way.
In 3
retrospect it would have been better if there had been more 4
close integration between the three parties, as you were, to 5
this.
6 A question that has been raised in my mind since 7
Three Mile Island 2 is where do the responsibilities lie, and 8
my personal perception was as follows:
9 During the initial startup of the plant until'the 10 plant has. achieved the -- satisfied the licensing process that 11 the test program has proven that it can be safely operated and 12 also has satisfied the commercial aspects that it will develop O"
I3 what we say it would deliver, we work very closely with the Id utility.
15 Once that point has gone in the past, in my mind 16 it is now the utility's responsibility with B&W having the I7 technical responsibility, probably not the contractual respon-18 sibility, but on a professional engineered technical responsibil-ity of advising those plants even though they are no longer 20 maybe even in touch with us, those instances in which we 21 discover that could pertain to their operation.
And there has
()
been a separation in the past in that once the plant is 22 23 delivered and has passed the criteria then it is the utility's 24 and they assume responsibility for the total operation of the Aco Fede,d Repo,ters, Inc.
25 plant.
i
54 1
(~1b50 0
Well, we'll again address this issue of insulation
. (/
I 2
l of organizations.
l f
()
Assuming that Mr. Kelly and Mr. Dunn had never 4
raised their concern at all, would there have teen something 5
to be gained by B&W reviewing the change that was made at 6
Davis-Besse --
7 A
Yes.
0
-- to see if there was any generic implications of 0
9 that change?
10 A
Yes, I think tl., would have been.
I have not yet 11 seen the change that they made.
I've heard that they've made 12 a change in their procedure, but I have not read the actual 13 procedure to identify the changes.
14 Based on what I've heard here and elsewhere, I 15 believe it would have been beneficial for us to have been 16 involved in that.
i 17 MR. HEBDON:
Let's go off the record for just a 18 minute.
19 (Discussion off the record.)
20 MR. HEBDON:
Back on the record.
F BY MR. HEBDON:
,i 22 Q
You mentioned that you haven't seen this procedure.
23 Just for your own information and whatever observations you
(
l 24 may want to make, this is EP 1202.06.3 from Davis-Besse, and w.p e u n.po m,,,ine, 25 you'll notice that the procedure is marked as " obsolete".
i
55 i
l llgoS1 That's because there have been subsequenc changes to it after l
j 2
Three Mile Island.
3{
ex (j
~
But it's my understanding that this was a procedure; I
4 that'was in effect at Davis-Besse at the time of the Three Milei Island accident, and has subsequently been changed.
j 61 (H'. ding document to the witness.)
7 The circled in red note was the note that I 8
believe was added as a result of the Davis-Besse incident and 9
the concerns that Mr. Cresswell had raised.
10 (The witness reviewing document. )
11 A
This is the actual Davis-Besse plant procedure?
I 12 0
I believe it is.
73 13 This is the one that the operators would have to A
14 refer to during --
15 Q
I believe that is correct.
Now we have not 16 actually gone and deposed the Toledo Edison people yet, but
'7 this is a copy that has been provided to me from some Toledo 18 Edison people with the condition that that is the procedure l
19 that was in effect.
20 A
Yes.
21 Q
And we don't have them under oath or anything, but f-^)
22 I believe that is correct.
l 23 A
That would have attracted my interest, and the em, j
(
'i i
i
(
24 exact wording that is written in I probably would have said, km.Federa Ceporters, Inc.
25
'Okay, how do we tell the operator here's what you look for to l I
l 1
i i
56 l
I 1
(')b52 see if you can do have a leak at the top of the pressurizer. '
l x-2 I think your basic question was if I had seen this,'
.()-
if it had been brought to my attention prior to -- while the 4
other wheels were rolling here in the building, would it have 5
prompted me to do anything more.
6 It would have prompted my attention and curiosity 7
to find out why this was put in there, and I'm not sure what 8
would-have resulted.
9 Q
Well, I can see two ways that it might have been of 10 interest to you.
One is whether or not that precaution is a 11 good idea on its own merits.
12 A
Right.
O And the other approach is the question of whether, 14 if it is a' good idea, should it have been sent to the other 15 B&W utilities.
16 A
Once I had understood the base reason why this was 17 put in here, more than just reading these words in a hurry, it 18 would have attracted my attention, and then things may or may 19 not'have happened.
That's speculation, and I can't say for 20 sure.
But I would have certainly taken a closer look than I 21 did at 'why do you feel it necessary to put this type of g-
\\-
22 statement in your procedure'.
23 O
All right.
j
( )-
I 24 I'd like to 4sk you a few questions about the hce-Federal Reporters, inc.
25
. post-TMI period, particularly about the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after l
l
57 1
( ;lb53 the TMI accident.
l y
2 First, would describe your involvement with the i
r~
3
(,h)
TMI task force that was formed on March 28, 1979?
I 4
A I attended the initial meeting.
5 0
Approximately when was that?
6 A
That was 8:30 or nine in the morning.
t 7
Let me back up further than that.
8 Q
All right.
A Somewhere around a quarter of eight I was asked to I
10 go into Bill Spangler's office, who was in charge of startup l
11 plants, to receive a phone call from Three Mile.
The guy on the other end of the line was Lee Rogers, who was our site f3 13 operations manager, and he described that the plant was down 14 and that the reactor coolant pumps were off sticks in my mind, 15 and then the next involvement was that -- oh, the radiation 16 alarm.
17 The radiation alarm I guess was of a lot of 18
.Interest.
19 Q
Which radiation alarm?
20 A
I'm not sure.
He mentioned that there was a 21 radiation alarm and high activity inside contaiament.
So I
,r 3 V-)
gy don't know the specific alarm.
Q But it was inside the containment?
f3 i\\-
24 A
Right, inside the containment.
l AmFearst Reconers, lrx.
25 c
Q All right.
j l
t
58 (vQ pbS4 A
So then we proceeded to get together the technical j I
people that we felt should be working on the problem to see i
2 i
3 I
{}
what do tre do about this, and Bill Spangler took the lead on this.
The meeting was held approximately eight-thirty or nine -
5 g clock that morning, I can't remember which, in which we 6
reviewed the data that we had and reached a decision about 7
eOkay, based on this data we need more information; we'll do O
two things:
recontact the site with a list of questions' 9
and I don't recall the specific questions.
Also deploy three 10 people up to the island to provide support at that end if it is II needed.
12 One of the guys that went up works for me.
(J 13 Q
Who is that?
I#
A Bcb Twilley.
It was a three-man team.
15 Q
At'that eight-thirty meeting what was perceived to 16 be the problem?
37 A
I'll have to go back in my memory for a moment.
18 The problem ' ras perceived to be that the plant is to in an unusual condit. ion and we have a potential for fuel 20 damage because of the radiation alarm, and that we should get 21 it back stable as quickly as possible.
And we should -- the 22 l
main thrust was to get more information such that we could I
23 define the exact position of the plant at this point in time i (s l
24 and then be able to go ahead with detailed recommendations j Ace Feder9 Reporters, Inc.
25 L
about what should be done next.
l
59 i
l I
mpb55 Q
At that early meeting was the perception that the 2
plant was in a reasonably safe condition and we need to start i
i i
(")
working on the recovery effort, orwastheperceptionthatthe[
v--
plant is not in a safe condition and we need to find a way to 5
get it into a safe condition?
i 6
A My perception was that the plant is in a reasonablyj safe condition and that we need to get it to a stable condition!
7 8
and start working on the recovery of it.
9 Q
All right.
10 At that initial meeting do you recall any discussioh 11 of high hot leg temperatures?
A No, I don't.
V)
+
13 Q
Do you recall any request in that first set of 14 questions related to the hot leg temperatures?
15 A
I don't recall that being specifically called out.
16 But we asked for data around the system, and I believe that 1
was included in the data.
I' 18 O
Okay.
l l
10 i
Now would you go on and describe what else you j
i 20 recall of that day?
21 A
Of that day.
I then, since we had the task force
(,,)
22 working on it, went back and got involved in another project that I was on until some time shortly before lunch, and my 23
(,)
l
\\~/
24 perception was that there was maybe one contact with the site.
j Ace Federal Reporters, Inc.
25 I do know that right after the meeting Bill Spangler and I went
60
/~S back to his office and tried to call the site to get some more
\\_/ pb56 m
2 information.
We were unable to get through because the tele-
. ()
phone lines were busy.
i 4
Then later on there was another meeting in Spangler's 5
office in which some more data was presented -- and I'm not 6
sure of the origin of the data -- which said that the plant 7
was in an unusual condition.
Therefore we sat down to try to 8
figure out how do you get it out of this condition into a 9
stable condition.
10 It was not at that point in time a perception that 11 the plant was unsafe, it was it's not where we want it to be 12 and we have to get it to a stable condition.
And the main thing I recall, there was never enough data.
The data that 14 you had was spotty and it raised questions about what are the 15 other parameters doing, where we can build a complete picture 16 of what the hell is going on at that plant.
17 Q
Do you recall at this later meeting -- the one that 18 I believe took place around eleven-thirty --
19 A
That sounds about right.
20 Q
-- was there any discussion at that meeting about 21 4
the hot leg temperatures?
'-]
22 A
'I really don't recall.
23 Q
Do you recall _any discussion of a strategy at the x-)
24
[
Ac.-F der.i-n. cort.rs, ire.
plant to try to depr,n,.;urize the system, blow it down, in 25 order to ensure the core was covered by dumping the core flood i
61 1
1 l
mpb57 tanks into the core?
2 A
No, I don't recall that.
r ~s 3
(,)
Q Do you recall any discussion of the strategy that 4
the utility was using to get the plant from its present condi-5 I
tion to some other condition?
Do you have any understanding I'
of where they were trying to go or what they were trying to do {
6 i
i up there?
8 A
My perception is that overall they were aiming --
9 this is second-hand knowledge, not primary -- they were aiming 10 for cold shutdown, which is a stable condition and the 11 preferred mode for the plant to be in.
12 Q
Second-hand in what respect?
<~
k--)x 13 A
Second-hand in that I was talking to'the people 14 who may have talked to the site personally, who may have talked 15 to someone else who talked to the site.
16 Q
Do you recall who it was that you talked to?
17 A
No.
18 Q
Okay.
19 Now there was this meeting at eleven-thirty.
Did 20 you have any other involvement that day?
A Yes.
Some time after lunch, before two o' clock, s
f
)
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22 we reconvened to a larger meeting room and started trying to l
23 initiate contact with the site, and we essentially stayed in
- l
,r 3
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24 that meeting room from whenever we went in there until about Ace Federal Reporters, Inc.
25 seven-thirty that night, seven-thirty, eight o' clock.
62 i
i 1
What was the method of communication?
llmpb58 Q
2 A
Telephone.
I r'
3 i
Q Directly to the site or through an intermediary or l i
l what?
5 A
We were trying directly to the site.
There was a 6
method of communication established where we were contacting i
i 7
Greg Shedell, a B&W employee, at his home and he was presumably 8
receiving information from the site and passing it on to us, 9
and we were passing back along to him questions that we had 10 to try to build that picture of where we are.
11 Q
How long did that communication through Mr. Shedell 12 last?
-(y) i3 A
Per memory, until about six or six-thirty that 14 afternoon.
15 0
And then what happened after that?
16 A
We were able to contact Lee Rogers at the site 17 directly, or maybe he contacted us, I'm not -- we established l
18 Whether we called him and he answered, or they called.
contact.
19 us, I don't remember.
20 So this was somewhere around six o' clock, then?
0 A
Yes, somewhere in that time frame.
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I 22 At what point in the day did you realize that the Q
l 23 plant was in a -- basically the plant was in trouble?
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24 l I Ace-Federal Reporters, Inc.
l I 25 because I did one thing:
We were not able to establish contact j
- 1 I l lI
63 i
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hpb59 with the site.
We were at that point in time trying to get 2
the information to them to keep a number -- 400 or 450 gallons!
i 3
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per minute of cooling water going through that core from your 4
injection.
5 We weren't able to get through to them.
We weren' t 6
sure whether they were doing this or not.
It was just some-l 7
thing that if you aren't, you should.
8 Mr. Jim Floyd, who was down here on training -- I 9
knew him from previous to Three Mile -- I contacted him to see 10 if he had a magic telephone line that could get us into the 11 site.
He tried and he was able to establish contact with the 12 Unit 1 control room but not with the Unit 2 control room.
And g3 13 we passed the message on:
Get this minimum amount of flow 14 through the core.
15 Q
About what time did you pass that information on?
16 A
You mean to Mr. Floyd?
17 Q
To Mr. Floyd, yes.
18 A
Gosh, it was some time between two and two-thirty, 19 I think.
20 Q
Do you recall approximately when he was able to
()
get that information to the Unit 1 control room?
22 i
A Well, it was somewhere in that two to three-thirtyj i
I 23 I
r~s time frame, and I recall him trying maybe five or six numbers L'
24 before he was able to get through.
So it was caybe 15 minutes ;
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25 after I had called down and got him.
I
64 jpb60 Q
And so you were there when he made the call?
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A Yes.
3 x("N)
Q Do you recall at any time a request from the plant 4
that the people here at B&W calculate how much high pressure 5
injection flow should be maintained?
A No, I don't recall that.
7 Q
Do you recall ever making that type of a calcula-8 tion?
9 A
I didn't make it.
The number was provided to us 10 by our ECCS people, 11 Q
So then, as I understand it, that number was 12 provided more on.their initiative than as a result of a request?
.13 A
That's my understanding.
14 Q
Okay.
15 A
They were involved, I believe, in the early meet-16 ing, at least someone from that organization was involved, 17 and then this came about later in the day.
18 Q
Do you recall any realization during that day that 19 the high hot leg temperatures meant that super-heat steam was 20 in the reactor coolant system and that voiding was occurring?
21 A
Yes, but I don't recall what point in time that was.
(^'/
3 x-22 0
Do you recall who raised that issue?
-23 A
We got some data in -- I believe this was through 24 the Greg Shedell route -- where the hot leg temperatures were Ace Federal Reporters, Inc.
25 high, and then it just followed.
They were too high for the f
l i
65 f-A 1
J;b61 pressure that you have there.
2 Q
But you don't recall when that information came in?l
-( f A
It was some time in the afternoon, I don't recall 4
the exact time.
5 Q
Do you recall any recommendation about increasing 5
i 6
the pressure?
7 A
Mo, I don't recall any recommendation on that.
8 Q
Do you recall any -- Do you recall a phone call to 9
Mr. Arnold of the Met Ed staff which had been at somewhere around '
10 four or four-thirty in the afternoon?
11 A
No, it must not have gone through the line that we 12 were using in that conference room.
13 Q
So you don' t believe that call was made from the 14 conference room?
15 A
I don't believe so, no.
16 Q
Did you ever learn at any time on Wednesday, on the 17 day of the accident, that the high pressure injection system 18 least throttled throughout most of had been turned off or at 19 the day?
20 A
No, that was something we weren't sure of.
r' Q
So even by the end of the day you still weren't 22 sure what the status of the high pressure injection was?
23 A
No, I wasn't -- well, possibly when Lee Rogers got f-
'k-)/
24 hold of us that point came up because we'd been trying all day
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to push this, 'make sure that you keep that injection water
66 l
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'did you do it', and the answer was 'Okay, we've got it' type 3
~~
(
)
of thing.
But I don't recall saying that it's been on all day.
l s-4 or we just cut it on or whatever.
S Q
Okay.
6 Do you remember anybody at any time during that j
day making any connection between the incident that occurred 8
at Davis-Besse and the incident that was occurring at TMI?
9 A
No, I don't recall that.
I 10 Q
No reference to the fact that ' Gee, this looks like 11 the incident up at Davis-Besse' or anything to that ef fect?
12 A
No, I don't recall it.
13 0
Okay.
14 Do you know of any other precursor events that 15 you feel are relevant to the accident at TMI?
And let me 16 l
define a " precursor event" as we're using the term.
It's 5
17 basically any incident or issue that might have indicated l
t i
18 that an accident such as the accident at TMI would occur at j
i 19 i
some point in the future.
20 Do you recall any such precursor events that you r'3 feel might be relevant to the accident at TMI that we haven't t
22 discussed already?
23 A
None before March 28th that we haven' t discussed.
s e
24 I've recently seen a copy of a Bezinoff report that, when I 4,.pe,a n.pomr., w.
i glanced through it, they had an open core thing depressurized.'
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67 I
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2 It seemed to be a similar type of incident.
I seem to recall l
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)
it occurred in the mid ' 1s.
l Q
Okay.
i 5
Do you have any additional information that you I
i 6
feel might be relevant to our inquiry into the events j
surrounding the accident at TMI?
8 A
It's a broad question.
O It's basically to give you an opportunity to 10 provide any information that we might not have asked for yet.
11 A
No, I can't recall any that you haven'ttasked for 12 that are relevant to Three Mile Island.
gS
'N~'1 13 Q
Have we failed to elicit any information in areas 14 that you believe to be important?
15 A
I'll make a statement, then:
16 In view of the fact that Three Mile happened, there 17 was a reason, and we're still not sure what this reason was, 18 why that particular sequence of events was allowed to carry 19 out like that.
But it says that we should review what we have l
done in the past -- "we" being all the parties involved --
I 21
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and identify and take whatever steps are necessary to, oh, I
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y sharpen up the procedure or to keep better track cf field i
1 23 information, b2 better aware of what our personal and corporate;
-,j3; 24 responsibilities are in here.
W.Federd Reporters, Inc, 25 I believe as part of it we've got to shake out L
68 7~ dmpb64~
'where the responsibility is.
Is everyone responsible for La 1
1 2
Leverything,'or are there lines we can draw which will say
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Party A.is responsible up to this point and then Party B takes
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4 over, because right now it seems that everyone is responsible S
for everything.
And I think those are positions that we'll shake 7
out as we go down the road.
8 Q
Okay.
9 Is there anythiny else that you want to say?
10 A
No.
11 MR. HEBDON:
Do you have any additional questions?
12 MR. FOLSOM:
No, I don't.
I 13 MR. HEBDON:
That's all the questions we have for 14 you.
Thank'you'very much.
15 THE WITNESS:
Okay.
16 (Whereupon,.at 10:30 a.m.,
the deposition 17 was concluded.)
l 18 t
19 20 t
5 21 22 23 24 Ace-Federd Reporters, tric.
25 L
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