ML19308C405

Deposition of Jh Taylor (B&W) on 791005 in Lynchburg,Va. Pp 1-90

ML19308C405
Person / Time
Site:	Crane
Issue date:	10/05/1979
From:	Taylor J BABCOCK & WILCOX CO., NRC - NRC THREE MILE ISLAND TASK FORCE
To:
References
TASK-TF, TASK-TMR NUDOCS 8001230380
Download: ML19308C405 (90)

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{{#Wiki_filter:_ kN, fin? O NUCLE AR REGUL ATORY COMMISSION C O =. IN THE MATTER OF: THREE MILE ISLAND SPECIAL DEPOSITION DEPOSITION OF: JAMES H. TAYLOR BTOR~0RIGINAL Place - Lynchburg, Virginia Pages 1 _ go Date - 5 October 1979 T.i. phon.: (202)347-3700 ACE - FEDERAL REPORTERS,INC. OfficialReporters 444 North Capitol Street Washington, D.C. 00001 8 0 0123 osso s' NATIONWIDE COVERAGE. DAILY

1 MADELON UNITED STATES OF AMERICA mpb 2 NUCLEAR REGULATORY COMMISSION (7 h 3 ___________+ r~s 4 () In the matter of: 5 THREE MILE ISLAND SPECIAL DEPOSITION 6 ___________+ DEPOSITION OF: JAMES H. TAYLOR 8 Conference Room A 9 Babcock and Wilcox 3515 Old Forest Road 10 Lynchburg, Virginia 11 5 October 1979 8:20 a.m. 12 BEFORE: 13 FRED FOLSOM, ESQ. ja FRED HEBDON, ESQ. 15 GEORGE EDGAR, ESQ. LISTA CANNON, ESO. 16 JOHN MULLIN, ESO. 17 l 1 18 l i 19 20 21 22 ,s .~ 23 i l 24 ( ~\\ A

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g mpb E O_ N T E N T,S h. Witness. Examination 3 James H. Taylor 3 4 5 9 6 Insert number one follows page 4 7 8 9 10 11 12 13 6 14 15 16 17 IF b 19 20 21 22

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3 MADELON P,R_ O,C_ E_ E D,I,N,G_ S_ mpbl 2 7 (_) MR. HEBDON: We'll go on the record. 3 Will you raise your right hand, please? (/ i 4 x_ Whereupon, JAMES H. TAYLOR e 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: 10 0 Would you state your full name for the record? 11 i A James Harry Taylor. 12 O Okay. (~') MR. HEBDON: For the record, this is a copy of a RJ 1etter to Mr. Taylor, dated October 1st, 1979, from Mitchell l 15 Rogovin, director of the NRC TMI Special Inquiry Group. j e 16 BY MR. HEBDON: 17 Q Have you read this document in full? 18 (Handing document to the witness.) i o I i 19 l A Yes. I i 20 Doyouunderstandtheinformationsetforthinthisf Q 21 letter, including the general nature of the NRC TMI Special 22 i (~) Inquiry, your right to have an attorney present here today as j i t-23 l your representative, and the fact that the information you 24 provide here may eventually become public? ,A 1eral Reporters, Inc. 25 A Yes. l l

G mpb2 Q Are you represented by counsel today? 2 l + Q) A Yes. 3 MR. HEBDON: Would you state your name, please? {'\\ 4 K_/ MR. EDGAR: George Edgar. 5 BY MR. HEBDON: f 6 0 You should be aware that the tesimony you give has 7 the same force and effect as if you were testifying in a court 8 of law. My questions and your responses are being taken down, 9 they will be later transcribed. You ull be given the opportun-10 ity to look at that transcript and make changes that you deem 11 necessary. 12 However to the extent that you subsequent changes (~') are significant, these changes may be viewed as affecting your x_/ credibility, so please be as complete and accurate as you can 15 in responding to my questions. l l 16 If you at any point during the deposition do not 17 l understand a question, please feel free to stop and we'll try l 18 1 l to clarify it for you. 19 MR. FOLSOM: At this point we'll insert the letter ! I 20 from Mr. Rogovin to the witness as Insert number one in the 21 record. 22 (~^; (The document referred to follows:) l i xs 23 a I 24 A eral Reponers. lm. l g 25 i

r$ Luw / 1 October 1,1979 In Reply Refer to: NTFTH 791001-09 !!r. J. H. Taylor b c/o George Edgar, Esquire ?! organ, Lewis 6 Bockius Attorneys for Babcock and Wilcox Co. 1800 !! Street N.W. Washington, D.C. 20036

Dear Mr. Taylor:

I am vriting to confirm that your deposition under oath in connection with the accident at Three Mile Island is scheduled for October 2-5, 1979 at Babcock and Vilcox facilitv, Lynchbt.cg, Virginia. This will also confirm ny requent for you to have yo'ur resume and any documents in your possession or control regarding T!!I-2, the accident or precursor events which you have reason to believe may not be in official NRC files, including any diary or personal vorhing file. The deposition vill be conducted by members of the NRC's Special Inquiry Group on Three !!ile Island. This Group is being directed independently of the URC by the law firm of Rogovin, Stern and Huge. It includes both UnC personnel who have been detailed to the Special Inquiry Staff, and outside staff and attorneys. Through a delegation of authority from the NRC under ) Section 161(c) of the Atomic Energy Act of 1954, as amended, the Special 1 " Inquiry Group has a broad mandate to inquire into the causes of the accident at Threc !!ile Island, to identify major problem areas and to make reca::menda-tions for change. At the conclusion of its investigation, the Group will issue a detailed public report setting forth its findings c.nd reco=nendations. Unless you have been served with a subpoena, 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. HovcVer, the Special Inquiry has been given the power to subpoena witncases 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 acconpany him at the deposition as his representative. You should reali::e that while we vill 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 cay eventually beconc public, inasmuch as the entire record of the Special Inquiry Group's investigation vill be made availabic to the HRC for whatever uses it may deem appropriate. In time, this information may be made available to the public voluntarily, or become available to the public through the Freedon of Information Act. Morcover, other departncnts and agencies of government may request access to this infornation pursuant to the Privacy Act of 1974. The infornation cay also be made available in whole or in part to co nittees or subco nittecs of the U.S. Congress. OFFICE k. SURNAME. I I .l. oATE NDC FORM 318 (9 76) NRC'.' 0240 D U.S. GOV E RNMENT PRINTING OFFICE: 1979-289 369

O 2 - l'r. J.11. Taylor Octuber 1,1979 ( ) If you have testified previously with respect to the Threc :'lle Island accident, it would be uncful if you could revicu any transcripts of your previous state:1 cut (s) prior to the deposition. ) Thank you for your cooperation. Sincerely, Mitchell Rogovin, Director NRC/t!I Special Inquiry Group DISTRIBUTION TERA FFolsom FHebdon WParler (g) PNorry RDeYoung GFrampton MRogovin EKCornell /mL) NRC/TMI / V g % orry e 19/1/79 i v orF Cc k'. . NRC/.TM.I., ..NRC/TMI. NRC,gjd,I NRC/,TJ41 NRC/}! f4RJ,/TMI 3.Erf3['ofil. .GFraStohf>d ogov.i.n. suRNautk..FFolsom:kr:mc. WParler. .RD 6 ng. DATE kj..h[... [.79. 9[..((,h. ,h[ h9.. ,.9(( [.7.9 . J A[.(. { /.79 { )B.9., NP.C FORM 316 (9 ?6) NRCM 0240 D U.S. GOVERNMENT PRINTING OFFICE: 1979 289 369

5 BY MR. HEEDON+ ()pbl l 2 0 What is your current position? j () A I am manager of Licensing for the Nuclear Power 4 Generation Division. 5 Q What was your position in late 19777 6 A Manager of Licensing. i 7 Q The same position? 9 8 A Yes. 9 O For whom did you work? 10 A At that timc? 5 11 0 Yes. 12 A Mr. Deddens. 13 Q And for whom do you work now? 14 A Dr. Roy. 15 Q Approximately what time frame did that change take 16 place? 17 A Let's see, it was within the past 12 months. It l 18 must have been right around the first of the year. 19 Q All right. 20 What is your educational background? 21 A I have a Bachelor's degree in mechanical engineering /~3 'I 22 from the University of Pittsburgh, and a number of other short 23 I also participated in reactor operators training courses. %.p e n,n,l,,ine, programs and' received a senior reactor operator's license for the nuclear ship SAVANNAH, which was a program lasting about 4 e

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6 (]',pb2 eight months. 2 Q All right. ( Would you describe your employment history, 4 including positions held at B&W? 5 A I started with B&W in 1954 as a student engineer, 6 participated in a B&W training program for about one year, 7 went to work in the Atomic Energy Division in the summer of 1955. My initial assignments were in connection with the 9 nuclear submarine program and that then led into work on the 10 nuclear ship SAVANNAH project. And for the period of time 11 from 1956 until 1963 I performed various functions on the 12 SAVANNAH project involving auxiliary system design, safety gx %.] 13 analysis to some small extent. 14 I participated in and supervised portions of the 15 test program, start-up program, and served in an advisory 16 capacity on a number of trans-Atlantic cruises on the SAVANNAH. 17 Then in 1964 I did some work on the B&W steam 38 cooled breeder reactor project, and other miscellaneous jobs 19 up until 1966, at which time we began with the current 20 generation of nuclear power projects. I did auxiliary systems 21 design work and supervisory work in connection with the r-kg 0 22 Oconee projects and other projects that the B&W company had 23 obtained during that period of time. g '/ 24 In 1969 I was promoted to Production Services %.pe n.,on.,,, inc, 25 manager at our Mt. Vernon, Indiana, reactor vessel factory.

7 I pb3 That job involved production control responsibilities, tool e 2 engineering, industrial engineering, maintenance. It was a i 3 broad spectrum of activities. That lasted for about two years. 4 Then, in 1971, I returned to Lynchburg and was 5 responsible for-the next five, five and a half years for the 6 engineering support in connection with our German subsidiaries 7 activities, Babcock-Brown-Bavarie. 8 And then in 1976, I was on a special assignment 9 for one year involving straightening out some problems we had 10 with reactor coolant pumps on our current projects. And then in 1977, in March of 1977, I became Licensing manager. 12 Q Okay. 13 I'd like to ask you some questions concerning an 14 incident that occurred at Davis-Besse in September of 1977, and 15 I'm particularly interested in trying to get at your knowledge 16 and understanding of that incident prior to the accident at TMI. 18 Specifically, prior to March 28,_1979, what 19 knowledge did you have concerning an incident that occurred at 0 Davis-Besse on September 24, 1977? 9 21 A My knowledge of that incident was really rather 22 peripheral. I was familiar with the fact that the incident had occurred. I read some.of the meeting minutes and trip reports C 24 Gat had come back 6m daC hcMed. I was aware d de 4..p.o.r:j n. pori.r., ine. 25 general concern over the incident and the severity of the I

8 '/'Mb4 cool-down that occurred. V 2 I was also familiar with one of the initiators 3 r') being the pilot operated relief valve. I knew that the pilot ( 4 operated relief valve that was used at the Davis-Besse plant 5 was of a different type than had been used at some of the 6 other plants. 7 I don't think I -- I'm sure I did not -- I never 9 visited the site with regard to the Davis-Besse transient, and j 8 9 I was not involved to my recollection in any detailed discussion 10 of the transient until after TMI-2, ) 11 Q What was your organizational responsibility with 12 respect to Davis-Besse? us g3 A The Davis-Besse plant at that time, of course, had 14 their operating license, and after the B&W plants received their 15 operating license the Licensing section then goes into a 16 supporting role with regard to support of the power plants 17 that are in operation. And our key responsibility after they 18 become operational is in connection with preparation of re-19 load reports. And then, of course, if there are -- our organ-20 ization would deal with problems that might come up in connec-tion with analytical difficulties that could be established in \\ \\~' 22 a follow-on contract which might have some implications for an 23 earlier contract, and in that sense we are the ones who are _(m k-24 responsible for managing the safety concern procedure that we ' AwFWwd Ramnws, lm. 25 have~in PG&E. l l

9 (pb5 Q Why were you informed -- or why would you be provid-a V 2 ed the information that you were given concerning that incident? A I really can't say why I was provided that informa-() 4 tion. I tried to stay abreast of what's happening on the 5 operating plants, and I probably learned more about that 6 ' transient.by asking questions than I really did anything else. 7 Q So was it more just a function of your own 8 personal curiosity that you required that information? 9 A Yes, as I recall. 10 The way the Licensing section is organized, I have 11 three units in the section, and c.ne of the units is designated 12 as the Operating Plant Licensing Unit. And the man who is the D ~/ 13 supervisor of that unit, Mr. Kane, tries also to stay abreast 14 of the activities of the operating plants. And when something 15 like this happens he tries to inquire. And we were aware of-16 the evaluations that were going on from just a general stand-17 point, but we didn't have any reporting responsibilities or la anything of that nature. 19 Q Did you have any review responsibility? 20 A No. e 21 Q All right. C-) 22 BY MR. FOLSOM: O Why, then, was this incident of particular interest N 24 to you? Ace Federd Reporters, Inc. 25 A Well, it was just a severe transient, that's all. I

10 '1 (~/'ob6 I try. to be interested in any one of our plants that goes 2 through a severe transient. 3 (_') Q Is this a frequent matter for your concern? 4 A Not a transient of this significance, no. When a 5 plant -- there have been, oh, I would say since 1974 a half a 6 dozen transients that stick out in my mind as being significant, t 7 A couple at Oconee, one at Daeis-Besse, one at Rancho Seco. 8 But, no, I wouldn't classify it as frequent. 9 BY MR. HEBDON: 10 Q I'd like to ask you some questions concerning 11 your understanding of the scenario that developed at that 12 particular incident. And as a point of reference I have on the O' -13 ~ wall over here a graf what was prepared by Mr. Leon Engle of 14 ,,lua N RC S ta f f. And it's based on some reactimeter data that 15 he got at the site.following the Davis-Besse incident. 16 And on the graf he has plotted pressurizer level 17 and reactor coolant temperature and pressure and saturation 18 pressure. And he also has marked across the top some of the 19 milestones during the event. 20 You might want to take a moment just to glance at 21 that and familiarize yourself with it a little. (Witness reviewing chart.) 23 "g MR. EDGAR: Off the record. (LJ 24 (Discussion off the record.)

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25 MR.'HEBDON: Okay, let's go back on the record. I-I

11 1 BY MR. HEBDON: {}pb7 2 O At the time of the incident when you were looking c 3 () ,at the information, did you realize that steam formed in the l 4 reactor coolant system during the transient? 5 A No. I don't think -- I think it was considerably 6 af ter that that I personally was aware of that. 7 Q When did you personally become aware that steam had 8 formed in the reactor coolant system? 9 A I really don't recall. 10 0 Was it before or after Three Mile Island? 11 A Oh, no, it was before Three Mile Island, yes. 12 Q Okay. g-) (/ 13 Initially did you realize that the steam formation 14 in the reactor coolant system caused the pressurizer level to 15 increase while the leak continued? 16 A No. 17 Q Did you become aware of that at any point in the 18 future? 19 A I think the point where that -- it'was probably in 20 connection with some of the discussions that took place, or 21 probably in the reading, I believe, of Bert Dunn's memo, or a s-22 brief conversation that took place after that memo was written. 23 Q So you didn't recognize that particular fact g-) k/ 24 nitially?

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\\ 25 l A As contributing to the pressurizer level, I mean -- i i

12 llgpb8 the voids in the system contributing to the rise in pressurizer 2 level? /~ 3 (j% Q Yes. 4 A No, I don't believe so. 5 Q Okay. 6 What significance would you have assigned to that 7 fact if you had noted it? o 8 A At that time? 9 ~ Q Yes, prior to Three Mile Island. 10 A I really don't know. Of course voids in the primary, 11 system are undesirable under any circumstances. I don't know. 12 It's really hard to separate as a result of all of the conversa-gS \\_) 13 tions that have taken place in the last six months about this, 14 it's hard to separate and say how I would have thought about it 15 at that time. 16 Q Okay. 17 A I don't know. 18 Q Did you realize at any time that the operator 19 secured high pressure injection before they had isolated the 20 leak? s 21 A Yes. p 22 O Okay. 23 (-} At what point in time did you become aware of that? \\' 24 A I believe it was during some -- no, I take that

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25 back.- 'I believe I did. I certainly realized it after I I

13 I q pb9 received the Bert Dunn memo. But thinking back to 1977, I 2 think I did, but I'm not sure. 3 ) Q Okay. 4 There's been a little bit of confusion with respect 5 to Mr. Dunn's memo and some concerns that people in Mr. Karrash's, 6 group had because of the fact that the operator secured high 7 pressure injection twice during the incident. He secured it 4 8 once at about four and a half minutes into the transient while 9 the system pressure was approaching saturation pressure. He 10 then turned it on again out at about somewhere around 35 or 11 40 minutes into the transient, and then turned it off again at about 60 minutes. 13 Were you aware that they had secured it twice? A No. No, at no time, really, until after TMI was I 15 - really aware that they had done it twice, and so I can say 16 definitely no. I7 Q Are you reasonably certain that the securing that 18 you recall being aware of was the first securing while the 19 leak was still progressing, or was it the second one which was 20 after the plant was in a fairly stable condition? C A I'm not reasonably certain, no. I think that it V 22 was the first one, but I wouldn't say 100% for sure. 23 Q Okay. 24 Ace-Federd Reporters, Inc. 25 give any consideration to what might havelhappened if the plant I

14 (ggpbl0 had been at a higher power level? 2 A Well, I'd like to just clarify. When you say in 3 (s) the course of reviewing this incident, I really didn't review s 4 ,the incident. S Q Okay. 6 A And I think it would be doing my involvement in 7 that incident an injustice to call it a review. 8 Q Okay. 9 How about we'll just say: 10 During the course of your involvement with that 11 incident did you give any thought to what might have happened 12 if the plant had been at a higher power level? f-13 A No, I don't think so, until I recieved Bert's memo. 14 Q Okay. IS I'd like to go on and discuss some memoranda that 16 we've talked about briefly here already, what's come to be 17 known as the Kelly-Dunn sequence or memoranda. 18 As I understand it, the whole sequence in writing 19 became a memo prepared by Mr. Kelly in which he discussed 20 some concerns that he had with respect to the operation of j 21 the high pressure injection system. Did you receive a copy rx 22 of that memo? 23 A No. .f N \\' 24 Q Were you ser aware of that memo prior to the acci-AeFMed Reportus. lm. 2S dent at Three Mile Island? I

15 I A No. ggpbl1 2 O What was your first involvement with that particular l i 3 issue? l () 4 A When I received the -- well, would you clarify 5 what was my first involvement with that issue? I'm not sure 6 I understand that question. 7 Q Well, I believe you received the Dunn memo -- 8 A Yes, I did. 9 0 -- which, as I understand it, was addressed to you. 10 A My point of uncertainty here only deals with having 11 knowledge of the Davis-Besse transient. Of course that was 12 very early. And if you're talking about what was my first gs (m.- 13 involvement with the issue of whether or not the operators 14 could use some additional instruction, then the answer to that 15 question is when I received the Bert Dunn memo. 16 Q Okay. 17 What I was particularly trying to get at was whether 18 you had any particular discussions with anyone -- 19 A No. 20 Q -- talked to anyone or anything else about that 21 specific issue that's in the Dunn memo? g\\ kJ 22 A No. 23 Q All right. -) x_ ' 24 Now you received Mr. Dunn's memo. Could you Am-FMerd Reorters, im. 25 describe what transpired? I

16 [ pbl2 A Well, as I recall, I talked to Mr. Kane, who is 2 my unit manager in charge of the Operating Plant Licensing () Unit. And I told him that I felt this was a matter which 4 required involvement of the Nuclear Service Section much more 5 than it did.the Licensing Section. And I suggested that he '6 talk to somebody in the Nuclear Service Section. And the conversation really didn't contain a lot more than that. 8 And then about a-week later there was another 9 memo from Bert to me. I did not talk to Bert, to my recollec-10 tion, about that memo at that time. And the follow-up-memoran-dum indicated that things were going in the channel which I 12 believed was appropriate for them to-go, which would lead to O/ 13 some clarifying operating instructions. That was the February 14 16th letter. l 15 Q Was that the end of your involvement with the issue? j i 16 i A Until after TMI, yes. I 17 Q So, then, basically you just received the first memo, referred it to Mr. Kane, and then received a second i 19 memo and felt that the issue was on.its way to being resolved? l 20 A Right. 21 Q Who would have been responsible for following up 22 on the second memo that Mr. Dunn wrote to see that the actions were in fact carried out? .O 24 A Well, in retrospect, I should have assumed that Am.Feder:$ Reporters, Inc. 25 . responsibility, I think. i I

17 Q Why is that? (7bl3 2 I A Well, because the memo was directed to me, really. I) +Ut. EDGAR: What about at the time? -v 4 THE WITNESS: At the time I felt that no follow-up 5 was necessary because it appeared to me as though the ECCS 6 Analysis people and the Nuclear Service people had reached an 7 agreement on a procedural clarification and operating instruc-8 tion and I didn't feel any further involvement was necessary 9 ~ on my part. 10 BY MR. FOLSOM: l l 11 Q Do you normally issue clarifications of operating instructions? 13 A Does Licensing? 14 Q Yes. 15 A No, that's not c ar job. And that's why I asked my 16 unit manager to put it into the channel where those kinds of 17 instructions normally originate, which is the Nuclear 18 Service Department. And I felt that the thing which was 19 required was just simply either a clarification or a reinforce-20 ment of an operating instruction. And I've told other people 21 who have asked me this question, 'Why did you think along those O 22 lines', and I looked at the' issue as not being one that implied any basic design inadequacy or hardware inadequacy + s-24 l Ae..F.d.,ei neporters; ine, in the plant, but rather one which involved operating instruc-25 And so that was the reasoning I used in suggesting that tions. t I

18 {]pbl4 it go to Nuclear Service. 2 Q If a plant changes its operating instructions, ( are you alerted to that fact? 4 A No. 5 Q Dc you become aware of it? 6 A. Not at all. 7 Q Were you aware that Davis-Besse did alter their 8 operating instructions -- 9 A No. 10 0 -- before TMI? 11 A No, I was not aware of that until after TMI. 1 12 1 BY MR. HEBDON: O 13 O I get the impression from what you said just a 14 moment ago that you had a feeling at least that a faulty or a 15 less than adequate operating procedure was not as significant 16 as a faulty design. Is that a fair representation of your thoughts at the time? 4 A I don't think I made any comparison in my mind as 4 19 to which of these things is most significant. I certainly ) 20 would never agree that one is more important than the other. 21 Misoperation of the plant can do every bit as much damage and n' \\- 22 be every bit as much a safety hazard as improper equipment 23 performance. O(x 24 But the perception, the thought process that I Ace Federd Reporters, Inc. 25 l went through, I think the way safety concerns have been viewed

19 l gggpbl5 or had been viewed up until that time -- and I'm using safety 2 concern in a broad sense, not the way we defined the preliminary () safety concern in our procedure -- the things that were logical 4 and. proper for people to direct to the Licensing Section for 5 action because of the way the regulations have been developed 6 were those having to do with design, construction, hardware 7 and analysis. And the operating procedure issues, the 8 licensing process itself has just not had a strong emphasis 9 on operators and operating procedures. 10 And my primary involvement is in those activities 11 which are directly related to the licensing process. And so 12 it's no more complicated than that in my mind. g~s \\ ') t 13 O Okay. 14 A But I would want to make sure that I don't leave 15 the impression that I think operating procedure matters are 16 unimportant. They are very, very important. 17 Q Did you have any feeling for why the memo was sent l 18 to you? 19 A No, at the time I didn't. Bert Jones has told me 20 subsequent to TMI-2 why he sent the memo to me. 21 Q Excuse me, I think you mean Bert Dunn. 73 t k' 22 A I mean Bert Dunn, yes, here in the same ECCS family 23 And it was that he felt this was an issue that he g3 >\\ s's 24 Was trying to get some action on, and he felt that I could help Am FWwd Rmorms, Inc. 25 precipitate that action. I

20 i Q Why did he feel that you could help precipitate llgpbl6 2 that action? I i /~N 3 (,) A I don't know. Maybe I have a reputation for tryingl f 4 to make things happen, I don't know. 5 Q Did you give any thought at all to the possibility 6 that he considered this to be a safety concern or almost a 7 safety concern within the definition of your preliminary safety 8 concern system? 9 A No, no, I did not. 10 BY MR. FOLSOM: ~ 11 l Q Let me ask -- 12 A And I'll say again that the issue of whether this rS(.) 13 was a safety concern in the sense that we use the word safety 14 concern in our procedure just did not enter my mind at that 15 time. Q Did you relate the two Dunn memos to Davis-Besse in any regard? Did you see that as the origination of it? 18 A Well, I think the memos said that. 19 MR. EDGAR: We have them here, if you'd like to 20 look at them. 21 MR. FOLSOM: I just wanted to know if the witness fs () 22 was aware of that. 23 THE WITNESS: I've seen a lot of those memos since (~) ~ '~' 24 then, but I believe the memos said Dav' -Besse in them, if I'm Aa-FMwat Rmorms, W. 25 not mistake:

21 ('7bl7 (Document handed to the witness.) %s! 2 THE WITNESS: Yes, the direct concern here rose () out of the Toledo incident. 4 BY MR. FOLSOM: 5 Q The concern was what you recognized as a very 6 significant transient. 7 A Yes. I have to say that my original concern about 8 the Davis-Besse transient was more related -- well, I would 9 have to say almost exclusively related to what had happened 10 to the plant, and not the operating procedure aspects of it. 11 ~ And I think it's also fair to say that until Davis -- or until TMI there was a strong tendency to look at these incidents -- 7-) (_/ 13 and I believe this is true of not only ourselves but of the 14 NRC Staff and others -- in terms of what had happened to the 15 equipment, was the equipment damaged in any way, was it ready 16 to go or able to go back in service again. 17 And I think that was the main thrust of my concern, 18 whether there were any safety implications in terms of the I 19 possible effects on the equipment that had gone through this 20 transient. .i 21 Q In short, you didn' t feel o~f ethe~ operator himself as a piece of equipment that could have a decided influence on S the plant? 23 %] 24 A That was not -- I don't think that was the primary , Ace-Fsdord Repo,ters, inc. 25 reason for my involvement at that time, no. I

22 k 1 BY MR. HEBDON: gggpb18 2 Q I'd like to get back to the safety concern question ,m 3 ( ) just a little bit. ~ 4 We've talked about the fact that you felt that the 5 Davis-Besse incident was one of the more significant incidents 6 that had occurred, and also in Mr. Dunn's memo he reaches a 7 conclusion that core damage was quite possible,and perhaps O 8 probable are the terms he used, if this incident occurred at 9 full power. 10 Why was it decided with this type of rather strong 11 language this was not a safety concern? 12 A Whether or not this was a safety concern in the (,) vs 13 sense that we use the word in our internal procedure and 14 policy was not a conscious decision. That particular question 15 just did not enter my mind at the time I received that memo, 16 and it didn't enter my mind until after TM1-2 until somebody 17 started asking me questions about it. 18 And I can only surmise why it did not enter my 19 mind, and that was the historical background on how this 20 procedure had come into being, and the procedure that we have 21 is one which grew out of 10 CFR 50.55 (e) which is applicable k3 22 to plants with construction permits, and it emphasized the 23 design and construction problems, and the same with 10 CFR 21, ,s (_) 24 which evolved out of 10 CFR 50.55 (e) to cover more clearly

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25 those things which were outside the construction permit arena. 1 l

23 1 ('-)bl9 And so operating procedural inadequacies or s 2 operating instruction inadequacies, I think it was while they () can create safety problems, I think we viewed -- at least I i 1 4 viewed that process to be more applicable to things that 1 5 implied design and analysis inadequacies or errors. 6 Q So then would it be fair to say that you didn't 7 feel at the time that inadequacies in operating procedures j i 8 ' met the or fell under the purview of Part 21? c 9' A At the time, I think so, yes. 10 Q Okay. 11 A Now I obviously think about it different today, and 12 we have taken steps in our own house to modify the procedure O 13 that we have to call out very specifically to the people in the 14 Engineering organization and the people in the field that l 15 operating procedure errors, inadequacies or training inade-16 quacies definitely are candidates for processing according to 17 this system. 18 Q But at this time the operating procedures were not 19 perceived as being included in the coverage of the preliminary 20 ,. safety concern system, for example? 21 fs A Uh-huh. (J 22 Q Okay. 23 ~ MR. EDGAR: Can we go off the record? (' T 24 (Discussion off the record.) ' Ace-Federal Reporters, Inc. 25 l 482 MR. HEBDON: Let's go back on the record.

24 ) i (lgpb20 BY MR. HEBDON: 2 Q Okay. 3 (O) It's my understanding, then, that when you received 4 the February 16th memo you felt that the issue was essentially S resolved, is that correct? 6 A I felt that it was on the way to being resolved in 7 an acceptable and proper way, yes. 8 Q Okay. 9 Did you feel that the procedural change that was 10 proposed by Mr. Dunn in his memo was an acceptable way of 11 solving the problem? 12 A Well, I'm not sure really how I thought about it at g-(.' 13 the time. I have no recollection that I thought it was un-14 acceptable. And it seems to me that the people who really 15 were most able to make a judgment about, or most able to 16 contribute to a proper solution had talked among themselves 17 and had reached agreement. And I can only say that I had.no 18 negative reaction to the prescription. 19 Q Okay. 20 Okay, I'd like to go on and talk about a report 21 that's come to be known as the Michelson Report; and, again, g ( 22 we're trying to get at your involvement with that prior to 23 the Three Mile Island accident. {~}- x. 24 Prior to March 28, 1979, what knowledge did you Am Feded Reporters, Inc. 25 have of the Michelson Report? I

25 A Well, I knew the report had come in. I had received {lgpb21 2 a copy of it. r^N 3 qJ I was trying to think whether I had a copy of the 4 letter and the report, but I had received a copy of the report. 5 I knew that it was being handled between the project manager 6 for the Belafonte project and the ECCS unit, and I of course 7 knew that it dealt with a small break issue. O 3 And I have a fellow in my organization who works 9 in a different unit than the one that I mentioned earlier. He 10 works at what we call the Generic Licensing Unit, a man by the 11 name of Henry Bailey, who is reasonably f amiliar with the ECCS and small break issues. And so I knew the report was in-house 13 and I also knew that there were some other issues re3ntad to 14 small breaks going on in the house at that time, particularly 15 with regard to the operating plants. 16 What more do you want me to say? 17 Q Did you give the report to Mr. Bailey? 18 A I believe yes, I recall passing a copy either of 19 the report or a copy of the letter to him. 20 Q Do you know if he performed any review of that 21 report? q 22 A Yes, I believe he did. 23 <~} Q Did he give you any indication of what his observa-J 24 tions or Comments were as..a result of that review? Ace Feder:1 Reporters, Inc. 25 A I believe he gave some feedback to me through his I

26 l gggpb22 unit manager at the time, Mr. Levendowski I believe was the z 2 manager at that time, o ,o 3 (_) Q What did he say? 4 A It was a brief rundown of the Michelson concerns, 5 and I believe he indicated that this was something that was 6 being looked at by the ECCS unit, and that they intended to get back to TVA as soon as they completed their evaluation. ] 7 8 Q Did he give you any indication of his perception 9 of the significance or validity of the concerns that were 10 raised by Mr. Michelson? A Yes, I believe that the feedback he'gave to Mr. 12 Levendowski, as I recall, it was not something that really 13 hit me as a real critical issue to deserve attention right 14 then at that moment. 15 Q Do you recall focusing at all on the question of 16 operator interpretation of pressurizer level? 17 A No. 18 Q You don't recall any reference to that at all 19 in the course of your discussion? 20 A Well, no. I recall -- I think that was mentioned O 21 in the notes that he gave back to Levendowski, but I didn't g-]g 22 attach any real significance to it at the time. 23 Q You mentioned that he provided some notes. (~l S 24 A Yes. Ace-Federd Reporters, Inc. 25 0 Are those notes available? i i

27 q pb23 MR. EDGAR: They've already been made available. 2 MR. HEBDON: Let's go off the record for a moment. ( }. (Discussion off the record.) 4 MR. HEBDON: Let's go back on the record. 5 BY MR. HEBDON: 6 Q So thea was it your feeling then that the issue 7 was going to be handled between the Project Management group 8 and the ECCS group? 9 ~ A Yes. 10 Q Okay. 11 A It was -- I have to say that my impression at the 12 time was that it was primarily a 205 fuel assembly plant issue 73 (_) 13 that had been raised by the TVA project, and that due to higher 14 priority work we had some problems that we were trying to resolve on the operating plants with regard to small breaks 16 at that same time, that it was going to be taken care of in 17 due time. 18 Q Okay. 19 Now there's also an issue that's somewhat related 20 to the Michelson Repcrt associated with some questions that 21 Mr. Ebersole of the ACRS asked as part of the ACRS review of 7s 22 the Pebble Springs application. 23 Prior to March 28, 1979, what knowledge did you 7-24 have concerning the questions raised by Mr. Ebersole of the l Ace Federal Floporters, Inc. 25 l ACRS concerning Pebble Springs? i

28 A Well, I attended some of those meetings. I can't {lgpb24 2 recall exactly which ones I attended. But I remember the c ,r m 3 (_) questions that he prepared, and I'm not sure exactly which 4 meeting it was that he first raised these questions. But there 5 were a whole list of questions that we got through the Portland 6 General Electric project. They came from -- as I recall it c 7 went from the ACRS to the Staff and then from the Staff to C 8 the Applicant and then came to us, and we supplied information 9 for a number of those questions. And that was in the fall of 10 1977 -- the fall of '77 or the first part of '78. 11 Q Were you involved with the preparation of the 12 (3 responses to those questions? (_/ 13 A Well, involved as -- yes, I was responsible for 14 the part that went out from B&W in the context that I'm the 15 manager of the Licensing section. I did not personally review 16 them, but they were reviewed by one of my people and by his 17 supervisor prior to them being transmitted back to Portland. 18 Q One of the questions in that group that's been of 19 particular interest is question number six, which is related 20 to this issue of small break LOCAs. C 21 Part of that question -- there are several questions ,r 3 22 included number that nedber. There's a question related to 23 (^} how the operator will interpret pressurizer level. L' 24 Do you recall focusing on that particular question Ace Fedent Rarvsrters, Inc. 25 at all? t i

29 I A No, not at that time. I've been asked about that gpb25 2 a number of times since the TMI incident. by Prof. Carbon ~ 3 (x >) and Dr. Okrent from the ACRS, and in digging into that i 4 question a little bit we just did not focus on pressurizer 5 level. 6 c2 As a matter of fact, our answcr did not address 7 that part of the question, and it wasn't until afterwards that 8 I really understood the background behind the question. And 9 as I now understand it--and as we sometimes do, we try to 10 answer the question as we interpret the question. So there I was not a focus on pressurizer level on that part of the 12 question at all. ,,s ( ) 13 Q Do you recall that during the review of the 14 response by the people within your organization, did anyone 15 raise the issue of 'part of this question isn't answered'? 16 A I don't recall any discussion on that, no. I7 Q Okay. 18 Do you recall making any connection between the 19 questions that were asked at Pebble Springs and the Michelson 20 Report, which was received later on? 21 A No. It was not until after that. I did attend the 22 l ACRS meeting at which these questions were discussed in a broad 23 sense. There were a total of 26 of them, and I don't know how ,2s r 1 \\I 24 many of them we participated in or provided input to. But I

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25 do recall very clearly that the information that had been

30 (ggpb26 provided to Portland and from them to us seemed to have hit the 2 target. 3 (',) In other words, that particular question which we had interpreted, because we thought we understood what the 5 concern was, drew no further comment to my knowledge. As a 6 matter of fact, I can recall both the Staff and the ACRS were 7 complimentary of the responses, and to my recollection there 8 were no open items in the safety evaluation report that was 9 issued by the Staff on the Pebble Springs project with regard 10 to that particular issue. 11 O Well, as I recall, having read the transcript of 12 7w that January, 1978, meeting when the issue was brought up, (j 13 Dr. Ebersole does raise the issue that related to question 14 number six about how the operator will interpret pressurizer 15 level. 16 Do you recall a discussion with him on that subject 17 during that meeting? 18 A Yes, but I don't recall his being -- it was not 19 something that stuck out in my mind. I recall the question 20 coming up, but I didn't really attach significance to it. And I guess I have to say that in thinking about the thing, fy'") t 22 pressurizer level par se didn't come out as a real central 23 issue, but rather it was inventory in the reactor coolant 7x 24 system and being able to remove heat from the system under AwFMusi Reporwn, W. 25 this two-phase natural circulation mode. I

31 (~';b27 Q Do you recall a discussion about the fact that the V 2 operators would be expected to be trained concerning this \\ 3 ,j particular problem on the simulator and then a counter-4 argument by Mr. Ebersole that the simulator would not simulate 5 this particular response with respect to pressurizer level? 6 A Vagucly, yeah. 7 Q Not in the course of your discussions with the ACRS 8 on an issue such as this, do you recall what came of this issue 9 with respect to how the simulator would simulate this particular ~ 10 event? 11 A No. 12 Q Do you recall if, when you returned, there was any discussion with the simulator people as to whether or not the 14 simulator would accurately simulate, and if not, whether it 15 needed to be changed? 16 A I didn't have any discussions with them on that 17 subject, and I don't know whether anybody else did or not. 18 Q Now, in the course of your general business of 19 working with the ACRS, for example, if an issue such as this 20 came up where somebody raises an issue that possibly the 21 simulator doesn't accurately! simulate a particular type of 22 transient, is there any systemmatic way in which this sort of 23 information would be sent back to the simulator people? -{ N-24 A Normally what would happen is that there would Ace Federd Reporters, lac. 25 be some action items coming out of the meeting. Usually when I i

1 32 I llgpb28 an ACRS meeting ends or when a meeting with the Staff ends a 2 there are certain commitments or action items that come out of /~s 3 l i ) it, and where those are clearly defined, then I would say therei sw 4 is a systemmatic way of following up on them. Unless those 5 discussions lead to a specific action item, then I would have 6 to say there is not a systemmatic way of making it happen. O 7 Q Okay. 9 8 Now who defines the action items? 9 A Well, in the normal course of events, the ACRS 10 infrequently will ask the applicant or somebody else at the s 11 meeting to provide them some information or to do something. 12 But the normal way of doing business is for the ACRS to require ("$ (/ 13 some action by the Staff and then the Staff in turn requires l 14 action by the applicant. The applicant in turn requires 15 action of whomever it's appropriate to get action from, whether 16 it's the architect-engineer, the NFS vendor or somebody else. 17 Q So then basically what you're saying is that the 18 action items are defined by the ACRS. 19 A Well -- 4 20 0 They develop the list and then the list is appor-21 tioned out to the proper people. J w 22 A The ACRS in their writing of their letters on any 23 ('n, given project, it can happen either one of several ways. But \\I 24 the two most common ways are for issues or open items to be Ace Feder2 Reporters, Inc. 25 identified in the ACRS letter which addresses a particular

33 {ggpb29 project or the ACRS can verbally in a meeting ask the Staff, 2 whoever it may be, Denny Ross or the project manager or who-t'% 3 () ever it might be, to do something. And they will take the 4 action to write it down and to document it. So in terms that when you say the action items 6: are written down by the ACRS, that's not always the case, but 7 their letters -- their letters identify those items which I a 8 think are characteristically interpreted to be the most 9 important to them. 10 Q The point I'm getting at is that it would appear 11 that the people involved in the ACRS meetings defer to the 12 ACRS to establish what the action items are;by whatever r^g k_/ 13 mechanism they transmit those, it's basically if the ACRS 14 doesn' t highlight it as an action item or doesn' t ask somebody 1S to look into it, it doesn't get looked into? 16 A No, I would not agree with that at all. There 17 are many, many items that we do come home and look at, that 18 we do do additional investigations on without being asked to 19 do anything by the ACRS. 20 Q How are those items identified? Does somebody go 21 (-) back through the transcript and say ' Gee, that's a good ques-22 tion, we ought to look into that or see what needs to be done 23 with it'? Or is it a matter of somebody, in the course of (-'} 24 the Conversation, making a note that 'here is something we Am Federd Reporters, Inc. 2S ought to look into'? How is it done? I

34 /~'pb30 A It could be any one of those ways. It can be c V 2 in the form of a trip report or meeting minutes from the () people that went to the meeting, it could be in the form of v 4 just somebody coming back and deciding that.something needs 5 to be looked at further. It could involve going through the 6 transcript. 7 Many times there is a process that is followed 8 which involves the subcommittee meetings and the full committee 9 meetings, and in trying to be prepared to answer questions 10 at the full committee meetings it's customary to go through 1 11 the transcript from the subcommittee meetings, if transcripts S are kept, and identify those items which need to be investi-13 gated further and prepared for further. 14 Q Okay. 15 But the full committee meeting is basically the 16 last stop, right? 17 A Well, the full committee meeting always leads to 18 a letter from the ACRS as to how they view those, and the 19 full committee meetings of course are held for both the 20 operating license and the construction permit stage of c 21 licensing. And so that represents the last stop, so to speak, O' 22 if it's a construction permit, until they write their letter. 23 Q All right. 24 ~' Do you have any feeling for why this question of AeFederal Reporters, Inc. 25 how the operators would interpret pressurizer level and whether I i

35 I I' pb31 or not the simulator 'ccurately simulates that particular 2 transient wasn't picked up as an action item -- ~ 3 () A No, I don't. I 't : 4 0 -- in your own review of it, because I agree it S wasn't highlighted by the ACRS? 0 A No, I don't. 7 Q Do you feel that such an issue should have been 8 highlighted? 9 A You mean in retrospect? 10 0 Well, no. More on your perception of how the system was functioning at the time. Was that the sort of 12 thing that should have been picked up, was it just an over- ) 13 sight? Or was it something that normally wouldn't have been 9.145 picked up anyway in the course of reviewing these issue.? 15 A I really don' t know how to answer that que stion. 16 Again, I have to say that throughout 8.3 entire licent.ing 17 process the focus has been on the design analysis and engineer-18 ing aspects of it. And while they are important and se view 19 them now as even more important than they were viewed before, items related to the operator and to the procedures he used 21 did not get the same - :v' of attention particularly as a ,i t'> 22 result of an ACRS meeting as the problems related to the design 23 and analysis. ,s I ) k' 24 And I think it was just a mind-set, really, on Ace Federj Reportert Inc. 25 the part of a lot of people.

37 (';b33 e room, is it not? 2 A Oh, yes. 3 () (_ Q And somebody has to understand the gauges in the 4 control room. 5 A Yes, sir. 6 Q Would either Mr. Michelson's concerns or the 7 question six in the Pebble Springs packet that went to the 8 ACRS, or that was considered by ACRS have made any difference 9 in what B&W viewed as proper operator response? 10 A I'm still not sure I understand the question. 11 IF B&W is concerned about an issue then we 12 certainly would try to have it make a difference. I think the question that Mr. Ebersole asked -- and 14 I'd just like to try to characterize Mr. Ebersole. I have a 15 great deal of respect for him. He's a good engineer. And I 16 think he raises good questions. 17 At the same time I have been in many ACRS meetings 18 with Mr. Ebersole, and I personally find his questions very 19 difficult to understand at times because they are long ques-20 tions which sometimes involve a number of questions all wrapped 21 .(s up into one. And also they involve not infrequently some 22 admonishments. 23 But I have the utmost respect for him. But many l4e,.re non.,,, inc. times we have to interpret what we think hin questicns mean, 25 and I think the question that was asked there, that number six t

36 llgpb32 O Okay. 2 Then would it be fair to say that you don't find ~ 3 (,) it particularly surprising, based on the way things were done 4 at the time, that an issue associated with how the simulator 5 functions or what the operators would see was not picked up as 6' an action item as a result of that ACRS meeting? 7 A No, I don't find that surprising. 8 MR. HEBDON: Can we go ahead and take a break? 9 MR. FOLSOM: Before we break: 10 BY MR. FOLSOM: 11 Q Was there a ready answer to the question already 12 r-in existence in the bosom of B&W7 (_S) 13 A A ready answer to what question? 14 Q To the operator interpretation of pressurizer 15 level? 16 A No, not to my knowledge. At that time, no, not to 17 my knowledge. 18 MR. EDGAR: Let's define " ready answer". 19 BY MR. FOLSOM: 20 0 Well, had the problem been considered peripherally a 21 ,r^') or directly in connection with -- (/ 22 A Interpretation of pressurizer level? ( 23 G Q Yes. f 24 A I don't think so. Ace-Feder) Reporters, Inc. 25 Q Well, pressurizer level is reflected in the control I 1

38 (ggpb34 question seemed to our people, from talking to them after-the-2 fact, to be focused on heat transfer removal primarily on the ~ 3 I'~j secondary side of the steam generator. But I think that the 4 attitude that existed, at least up until the time the Kelly 5 memos and the Bert Dunn memos started coming out, the attitude 6 that I believe existed was that pressurizer level was an 7 indication of adequate inventory in the reactor coolant 8 system. 9 0 So that there was a possibility of the operator 10 misinterpreting it? 11 A Well, as we look back on it, yes, certainly. 12 Q Exactly. 73 \\ 13 Now what I'm driving at is had you had a fine ear 14 for what question six in hindsight is considered to mean, 15 would it have made any difference? 16 A Well, if we had done small break calculations to 17 the extent that we have done them now, and with particular 18 reference to small breaks at the top of the pressurizer, we 19 would have probably viewed that in a different way. But small 20 breaks to my recollection were not pin-pointed as to their 21 location in the system except in terms of things like looking r3 22 at them in the pump discharge, the pump suction and so on. 23 But this idea of pressurizer level not serving rT i s/ 24 3s an accurate indication of reactor coolant system inventory AwFMwd Rmomn, W 25 had not come out of any of our small break work until much

39 l gggpb35 later. 2 MR. FOLSOM: Okay. l-7 '! 3l Shall we take a break, then? (_, 4 MR. HEBDON: Yes. s 5 (Recess.) 6l MR. HEBDON: Okay, are we ready to resume? Let's I go ahead and go back on the record. 8 Let's go off the record for a minute. 9 (Discussion off the record.) 10 MR. HEBDON: Okay, let's go. We'll try this again. 11 BY MR. HEBDON: 12 Q I'd like to ask you some questions concerning what's -) K_/ 13 come to be known as the Cresswell investigation. 14 Do you recall having any contact with a Mr. James 15 Cresswell of I&E Region III? 16 A Pardon me. I wonder if we could go back? I want 17 to just clarify something on the previous answer. I didn't 18 know if we were going to continue the earlier conversation or 19 not. 20 Q No. 21 f^3 A In terms of the -- I didn't want to leave the i\\) 22 wrong impression about the question of interpretation or 23 operator interpretation of pressurizer level. I don't kncw ^) 24 exactly how I said it, but I don't want to leave the impression Ace Federal Reporters. inc. 25 that there was a popular attitude or popular feeling or i

40 llpb36 prevailing feeling that it was:the indication of inventory c 2 i in the primary system or the most important parameter that the i I o G 3 i i) operator should pay attention to. 4 And as I said before we actually started the 5 conversation this morning, that we certainly consider pressure 1 6 to be a very, very important parameter and should not -- I 7 don't want to leave the impression that we feel that the C 8 operator should pay attention only to level and not to pressure 9 in terms of trying to decide whether or not there's a leak in 10 the system or anything like that. 11 Q Okay. 12 This is an issue I was going to bring up a little r~) (/ 13 bit later on, but since we've started into it now I guess we 14 can go ahead with it. 15 Here what I have is two pages from Amendment 11 ] 16 dated April, 1978, to the Pebble Springs PSAR and it's from l 17 Chapter 15, and specifically pages 15.13-27 and -28. And j basically as I understand it what was done in this particular 19 amendment was an attempt in Chapter 15 of the SAR to include 20 some discussion of operator action during some of these e 21 ~ various incidents and various accidents that could occur. g] 22 This particular one relates to very t.all LOCAs where the 23 t; pressurizer level is regained. And in one particular section Lj 34 there's a discussion of inventory control. And it would seem Ace-Federal Reporters, Inc. 25 from this discussion at least that there was a perception that i

41 ) (~ Jb37 there would be a very heavy reliance on pressurizer level. 2 In fact, the opening statement is: () "The operator must control pressurizer 4 levels to prevent filling the pressurizer and 5 thus increase the reactor coolant pressure, 6 and this is accomplished by controlling high pressure injection. flow." 8 (IIanding document to the witness. ) 9 Now I recognize that statement is out of context, 10 so if you want to take a moment and read that particular section, and if you'd like to comment on that I would appreciate it. (The witness reviewing document. ) 13 A Okay. 14 I'm not really too sure what preceded this, but I 15 remember that the overall question that was raised about 16 operator action after these events; this has to do, though, 17 with -- I think some of the significant words here are "very 18 small LOCAs". 19 Q Isn't a PORV failure a very small LOCA? 20 A Well, I don't know. But certainly -- I would say 21 no, my judgment is it's a small LOCA, you know, it's a quali-O 22 tative thing. But this deals with -- 24 "The operator must control pressurizer u,,% %,,, g levels to prevent filling the pressurizer al.d l l l t

42 thus increase the reactor coolant pressure..." (ggpb38 2 Now if he's able to maintain the reactor coolant 3 (",) then he should have a concern about pressurizer leveli

pressure, 4

That's the way I think it was intended. And when we talk 5 about the operator: 6 ".... slowly decreasing HPI flow until a 7 stable pressurizer level is maintained..." 8 and: i 9 ".... initiating in as near normal cool-10 down as possible..." 11 in the transient situation, with the pressure down at 1200 12 or 3000 psi, as it was in TMI, I don't think thers should 73 \\_/ 13 have been any concern for pressurizer level in terms of over-14 pressurizing the system, and that's what I think was intended 15 here. 16 The words: 17 ... filling the pressurizer and thus 18 increasing reactor coolant system pressure..." 19 I don't think we can ignore the concern about pressure. 20 Q Well, isn't this basically the concern that's 21 been discussed from time to time about going solid? r3 22 A Yeah, it's undesirable to have a system filled 23 solid with water at near the design pressure. (~) (/ 24 O Well, how would this particular action as discussed Am FWed Reponers, W. 25 in that section be inconsistent with, for example, the action i

43 i l {ggpb39 that the operators took at Davis-Besse? 2 They saw a pressurizer level increasing and in I 3 ('N_) fact at the point in time when they shut off the high pressure 4 injection, the pressurizer level was up past the normal value 5 for it. 6 A Yeah, but the pressure was way down. 7 Q But it doesn't say anything in here about pressure. 8 It just says ' prevent pressurizer level from going up'. 9 A Yeah, but the concern over pressurizer level, my 10 ) belief is that it should only be a concern when the pressure q 11 l j is high. 12 Q Well, I would agree. But that's not what that (~3 \\-) 13 says. 14 A Yes, it does: 15 "The operator must control pressurizer 16 level a to prevent filling the pressurizer and 17 thus increase the reactor coolant pressure..." 18 Q But the "and thus" is the result of filling the 19 pressurizer, not an initial condition that must be met before 20 you shut off the high pressure injection. O 21 (The witness reading.) 7x I i' 22 It seems that the concern is that you'll force the 23 (^q pressure too high and that there's no consideration of whether '/ 24 or not the pressure is already high enough before you shut Ace Federd Reporters, Inc. 25 off the high pressure injection. I

44 A I think forcing the pressure is a very legitimate (]pb40 2 concern, forcing the pressure too high is a very legitimate () concern, but not when the pressure is at 1000 psi, which it ~ 4 was at TMI, and which it was down quite low in the Davis-Besse 5 transient as well. 6 In my mind there just should not be a concern on 7 the operator's part about going solid if the pressure is only 8 half its normal value. 9 Q Well, I would agree with that conclusion. But I 10 question whether that conclusion follows from the discussion 11 or is even consistent with the discussion in that section. 12 If the pressure is at 1000 pounds -- let's say the U(S 13 pressure is low, it's at 1000 pounds, and I fill the pressurizer solid. Assuming that I'm not thinking about this idea of 15 saturation and the fact that there may be steam voids in the 16 system, but if I were to assume that the system were full of 17 water and the pressurizer level was headed toward solid, how 18 long would it take after the pressurizer was full for pressure 19 to go from, say, 1000 pounds to 2200 pounds? 20 A Well, while going solid may be undesirable, in my 21 opinion it's not really a safety issue because the safety 22 valves can accomodate the flow, the volume flow from the high 23 (~ pressure injection pumps. But I think there is -- these are \\ -) 24 ~ -not -- I think these could be viewed as broadly descriptive

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25 operator actions to be refined at some time in the future.

45 . (]')b41 But I don't think it's right to take pressurizer level or 2 pressure out of context and say 'well, those are the only () parameters that the operator has to deal with'. He's got 4 temperature, he's got levels, he's got a lot of things. S Q Well, I would agree that the operator needs to 6 deal with all of these, and I would also agree that he couldn't i operate.the plant by that description. That's obviously not 8 enough to make a procedure. 9 A Right. 10 Q But it does seem to give an indication of where 11 the emphasis was, that in a discussion of inventory control the only parameter discussed as a controlling parameter on es 13 inventory control is pressurizer level. 14 A I don't read it that way. 15 Q Okay. 16 A I read it to say that he should be concerned about 17 -- and I agree, it's not absolutely clear -- but I read it to 18 say that the operator controls pressurizer level to prevent 19 filling the pressurizer and thereby increasing reactor coolant 20 pressure. And the words that are not here but which are in m'1 mind 'to abnormally high levels'. f - s, l 22 Q But it would appear that Lne comment with respect 23 r-) to pressure is a concern about having pressure too high and 'J 24 doesn't have any discussion about the possibility that pressure A 5m n., n.,,, ine, 25 is too low.

46 4 I A But the operator does have a concept of temperature- {Jb42 2 pressure relationships, or at least he should. () Q Yes. A And the temperatures in both the Davis-Besse and 5 the TMI incident were way out of line with the pressure. 6' O Could you explain that? I don't quite follow 7 what you meant by that. 8 A Well, the pressure here, the reactor coolant 9 system temperature on the Davis-Besse plant was down to 500-10 and-some degrees. Q The temperature? 12 A The temperature. 13 Q It's about 540 to 550, 540 to 550. 14 A And the pressure is down to half its normal value. 15 0 Are you saying that that indicates that the 16 operator had an understanding of the relationship between 17 pressure and temperature? 18 A Well, I think they certainly should have, because 19 they know that every time they go through no-low conditions 20 with zero power, the average temperature -- the pressure on 21 the secondary side of the reactor coolant system is about I -O' 22 where it is right there, and that's saturated conditions. l j 23 They certainly don't have the steam tables memorized, but 24 !4.p.e.r3 n ,,,,,, inc, there are some numbers I think which should be firmly ~ implanted 25 6 in their minds, and that's one, where the secondary side e

47 {];b43 no-load pressure on the generator is 1000 psi or thereabouts. 2 Q Okay. Let's go on. () Getting back to this issue of Mr. Creaswell and 4 his concerns relative to Davis-Besse, do you recall any 5 discussions that you were involved with concerning these 6 concerns? 7 A Some very brief discussions, only in preparation 8 for a meeting which was held I believe in February of this 9 year -- yes, February of this year. 10 Well, to answer the question you asked earlier, I d 11 have not had any conversations personally with Mr. Cresswell. ) 12 1 Q All right. O 13 A I was not involved in the meeting here in February. 14 But one or two of my people were. I believe I was out of town 15 that day. That was the meeting where -- I know about the pre-16 paration for the meeting. I knew about the scope of it. I 17 recall reading the letter that had come in from I believe la Mr. Foster from I&E, identifying the-questions that they 19 wanted to review and what they had asked our operating plant 20 customers to be prepared to discuss. e 21 And the thrust of that. concern and the purpose of fs 22 that meeting was to talk about transients which had led to 23 low pressurizer level, offscale on the low side. / O Did you have any feeling for why they were concerned

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25 about that particular issue?

48 A As I recall, it was a general concern about the (]pb44 o 2 operator being blind with regard to pressurizer level for a () period of time when the pressurizer was offscale low, and I 4 believe they had a concern -- let's see. I believe their 5 concern was based on a safety issue. They were concerned 6 about it from a safety standpoint, what the safety implica-7 tions of low pressurizer level would be. 8 I don't recall it being related to -- I don't 9 recall it being related to voids in the system, but the ~ 10 pressurizer level being unavailable to the operator. 11 Q Do you recall any discussion about the possibility 12 of actually draining the pressurizer? 13 A It's hard really to keep in mind or to keep 14 straight some of the things that I've been involved in or 15 talked about since TMI from those things which happened before 16 TMI. 17 I have a vague recollection that draining the 18 pressurizer was a concern, but I'm not sure that that was 19 something that was in my mind before TMI or not. 20 Q Okay. 21 Why were. you involved in this particular issue? ~ 22 A I believe it was because it was an issue that had 23 l been raised by the regulatory people, and as I recall the l \\' 24 l Aco Feder:2 Reporters, Inc. inqu ry had gone from I&E to Toledo, and Toledo had come back I -2S to us -- the Davis-Besse people had come back to us and said i

49 i i r~ 1 ( )b45 'it would seem we need your help here to help prepare for this 2 meeting'. And I believe they asked us to try to coordinate l i e (~/') 3 the activities of the other operating utilities. And so it j w_ 4 was a licensing matter as it appeared to them, and that was it. 5 0 So this would be involved with a licensing issue l i 6 rather than, as I understand it, the project management group I 7 which is normally involved with operating reactors? 8 A Well, project management, we have several project 9 management organizations here, and let me clarify that. 10 We have a project management organization that 11 deals with the individual utilities from the time the contract 12 (~ becomes a contract until it becomes commercial. That's one \\_}/ 13 organization. And that's the organization that was dealing 14 on the Michelson issue. That's our Nuclear Steam Supply System 15 contract and project management organization. 16 And then when a project becomes commercial it 17 obtains its operating license. It shifts over to the Nuclear 18 Service Department and the Nuclear Service manager takes over 19 the project management function. And his responsibility is to 20 maintain that single point contact between B&W and the operat-(~i ing plants, so that the customers have a single point to come (_/ 22 to. And then it's his responsibility to decide who within the 23 rest of the organization here at the Nuclear Power Generation (J \\ 24 Division should be involved in any given request from a Am-FMwat Rgeners, Inc 25 customer. It may be an equipment problem, in which I would not i

50 2 directly with the control room, and so the inforr.a 'an we were () recej' ring was displaced in time by -- well, we didn't know, 4 but we knew it was delayed. 5 So it was hard for us to assess what was going on i 6 at any given time because of the way the communication was 7 flowing from the control 1)om to our offsite representative 8 and back down to here. 9 I can recall several attempts and hearing people 10 talk about several attempts. I remember being in Jim Deddens's office at one point when they were trying to get in touch with 12 (~ people up there and they finally were able to reach GPU -- not x' 13 Met Ed -- and tried to pass messages back to them. 14 Q Excuse me. 15 Approximately when did that occur? 16 A As 1 said, I know there were several telephone 17 call attempts like this. The one that I can recall was probably 18 sometime like one o' clock or two o' clock in the afternoon, the 19 one that I was able to hear, one or two o' clock in the afternoon 20 between Jim Deddens and I believe Bob Arnold, if I'm not mis-C 21 taken. { ') '~ 22 Q Okay. 23 (^T, And this was approximately at what time? () 24 A I think it was in the one o' clock or two o' clock Aa-FMwd Rgenus, Mc, 25 time frame in the afternoon. I

72 i ((jb68 <~ 1 a Q Do you recall what was said during that conversa-tion? (~N 3 (/ A I think the main thrust of that communication was a can something be done to put us in direct control or direct 5 contact with the control room. We're just not able to get 6 good information. .j r 7 That's the thing that sticks out in my mind from 8 the conversation. I don't think I was there during the whole .g 9 communication. 1 10 I remember it starting -- I think that was the b 11 main thrust of the part that I recall. 12 Q Do you recall any discussion about attempts to { 13 repressurize the plant during that call? i 14 A No. 15 12 During any other calls? j 16 A I believe so, and I believe it was prior to the 17 time when we were trying to see if they could get the reactor 18 coolant pumps back in operation. But it's not a very clear 19 recollection. 20 0 APproximately what time would that have been? 21 A Three or four o' clock-ish, I think. Q With whom was that discussion? f 22 23 A That, again, was -- there were two conversations (} 24 l A<m-Federd Reporters, Inc. that I'm kind of mixing up. I think we tried to pass messages 25 back to Lee Rogers through.Greg Schedell with regard to getting

73 (v)b69 high pressure injection flow, making sure there was high 2 pressure injection flow. And I believe this conversation I f',bx_ / started some time after lunch. 3 4 And then I believe it was sometime around three-5 thirty or four o' clock that we were finally able to get in 6 touch with the control room with Lee Rogers, and I've forgotten 7 whether he called us or we were able to get to him. I think ? 8 he called us. And that message was passed through that channel. I think the thrust of that was get high pressure injection i 9 10 flowing. There was some, at least 4-or 500 gpm. And then there were a series of things that took 12 place with regard to trying to start the reactor coolant {}> 13 pumps, get the reactor coolant pumps back on. And I believe 14 the questions came through to us 'okay, the reactor coolant j 15 pumps had been off, high pressure injection had been off; what 16 do we really need to do to get the pumps back on to make sure 17 we don't make a worse problem'. And so there was some considera-f 18 tion give- _y the people here who are our pump experts and they 19 came up with a list of things that said 'do this, this, this and this,.and then we can see'whether or not it's okay to 21 r"N start the pumps'. ~ 22 And some of those things had to do with trying to 23 determine the condition of the reactor coolant pump seal. /^^) (~ 24 Q Now you mentioned that there was a conversation to AwFWeal Repomrs. Inc. 25 the effect that the high pressure injection system had been off.. i

i 74 ( )b70 Do you recall when you first became aware that the 2 high pressure injection system had been off? ('/ h 3 (_ A No, I don't. 4 Q Do you recall how you became aware of that? 5 A No. We had received some information through one 6 of the TMI-2 operators who was here in training, Floyd, and 7 it might have come through that channel, I'm not sure. 8 So in answer to your question I really don't 9 recall how that came to us. 10 Q Okay. 11 Do you know if B&W knew during that day that the 12 (-} strategy of the plant was to try to depressurize the system A-13 and blow it down in order to ensure that the core was covered 14 by dumping the core flood tanks? 15 A No, I don't. 16 Q You don't recall any discussion of that sort of i 1 17 a strategy or the advisability of it -- l 18 A No. 19 Q -- the fact that it was being done? 20 A No. I remember soma conversations involving long 21 \\ term cooling the.next night, whether to stay on the secondary ~} 22 side heat removal or go to decay heat removal. But I don't 23 (~) remember anything the first day on that score. \\_/ 24 Q Okay. Am Federd Reporters, Inc. 25 Now as I understand it, you recall getting some 1

75 I (^')b71 information about hot leg temperatures at some time in the Ase I 2 afternoon, that they were high. I A Yes. 4 Q Was there any attempt to request the hot leg 5 temperature earlier in the day? 6 A I don't remember. O Okay. 8 Do you recall being requested at some point during 9 the day by the plant to calculate how much high pressure 10 l injection flow should be maintained? I 11 ~ A No. Q Were you requested by the plant at some point {-) VV 13 during the day to calculate how much high pressure injection 14 flow was needed? 15 A I don't recall that, no. 16 Q Do you recall ever making that type of calculation 17 or do you recall anyone making that type of calculation? 18 A I was not aware of that calculation having been 19 made. I do recall that the message had gone back through a 20 couple of different channels 'try to get at least 4-or 500 21 (']' gpm going into the reactor coolant system from the high 22 pressure injection system'. Now whether that was based on a 23 /~'s calculation, I'm not aware. \\' 'J 24 Q okay. Aa Federd Reporters, Inc, 25 Now in the context of this recommendation about high l

76 ()b72 pressure injection, was it your perception that people were 2 aware that the high pressure injection was off and were 3 (^{) recommending that it be turned back on, or was it more in (, 4 the sense of 'we don't know what it's doing, but make sure 5 c4 it's at least 400 gallons a minute'? 6 A Would you repeat that, please? 7 0 Well, we've talked with some cther people that o 8 were involved with the issue that day and at least I seem to 9 get the perception that in some people's mind the recommenda-10 tion about high pressure injection was more in the context of 11 'we don't know what it is, but make sure it's at least as much' 12 rather than a perception that 'we know it's off, and turn it v' 13 back on'. 14 A Well, okay. I understand your question now. 15 I think the perception ucs'to ensure adequate 16 decay heat removal, let's make sure it's at least this much. 17 Q Okay. 18 A That's the impressicn I have, yes. 19 Q So'regardless of what you're doing with it, what 20 has been done with it, make sure you've got at leAst this much 21 on'. 22 A Yes, putting it in that context, yes. 23 Q Okay. p) x-24 BY MR. FOLSOM: Ace-Federet Reporters, Inc. 25 Q Were there any messages indicating what in fact

I 77 I N they had been doing with HPI? bb73 2 As I recall, our information about high pressure A 3 ("N, injection flow was very sketchy, and that the information had g a come back that it had been turned off, but we didn't know when 5 and for how long and that sort of thing. That was just un-6 available information. 7 Q Okay. O O MR. HEBDON: Okay. O 9 BY MR. HEBDON: 10 Q Now were you involved in the phone call to Bob Arnold that was made around four or four-thirty in the after-12 i noon? I 13 A I think that was the phone call I mentioned earlier, and I remember being in the office for part of that telephone 15 conversation, if it's the one I'm thinking of. I thought it was a little bit earlier than that. But that may be the right 17 time frame. 18 Q Could there have been two calls? 19 A There could have been, yes. 20 Q Okay. 21 A I can only recall one, but there could very well 22 have been two. Q Okay. t s / 24 But your original conception was that that one Ace-Fedad Reporters, Inc. l } 25 call was more like around one-thirty, right? I

78 ^ 1 ~ A No, no, I think it was -- yes. (~_s?b74 i 0 I'm sorry, yes what? n (\\ 3 (_) A It was earlier. My perception was a little bit 4 earlier in the afternoon. 5 Q Than four o' clock? 6 A Yes. 7 Q Okay. 8 So then you recall a phone call to Bob Arnold 9 earlier in the afternoon than four o' clock? 10 A Yes. 11 Now my recollection of time is -- I don't have 12 a great deal of faith in it for that day. g 13 Q Although it's possible that the four o' clock call 14 was a second call that you were not involved in? 15 i A Yes. 16 0 Okay. 17 In the phone call that you were involved with, did hesaythathehadalreadyinstructedtheplanttorepressurizel? 18 19 A I don't recall that in:the telephone call I over-J 20 heard. I do remember after the fact those kinds of messagc-e 21 being noted by people, or those kinds of conversations being 22 noted by people, and I'm trying to keep separate what I learned (~} after that first day from what I recall on that first day. x_/ 24 And so, no, in response to your question, I don't Au-FMwd Rmonm, lm. 25 remember that being a part of the conversation I overheard.

79 I (~ ;b 7 5 0 Who do you recall making notes of phone conversa-( v 2 tions? (\\ 3 (_) A Ken Wandley. 4 Q Anyone else? 5 A No. In the morning he was designated as the guy 6 to try to keep track of things, and I'm sure there were a lot 7 of other people making scratches and making isolated notes, but l 8 he was the only one who was doing it in any systemmatic way. 9 Q In the phone conversation with Mr. Arnold that you 10 were involved with, do you remember there being any recommenda-11 tion about high pressure injection flow or amount of flow to 12 maintain? g 13 A No. As I said, the part of the conversation that 14 I' overheard was a brief one, and it was one more of desparation, 15 'we've got to find a way to get accurate information between 16 ourselves and the site and can you do something to help open 17 up some communication channels'. 18 Q Who was involved in that communication or in that 19 phone call from the B&W end? 20 A Jim Deddens was involved for sure. He placed the (') call. And I believe Don Roy was in the office at that time. \\ i '/ 77 And there were three or four other people. (^} Q Just as an aside, did anyone give any thought to \\_/ 24 seeing if the telephone operator could break in on any of the Am FMed Rmorms, W. 25 phone conversations that were going on? As I understand it, I

80 I j'^7b 76 you kept getting busy signals. Did anyone consider trying to y 2 have the operator break in on any of the calls? e ~ 3 (v) A I don't remember. To my knowledge that was not 4 tried. Q Okay. 6 At any point during about say the first 24 hours 7 following the TMI incident, do you recall anyone making any 8 parallel between the TMI accident and the Davis-Besse incident? 9 A No. And I think the TMI-2 during the first 24 hours, 10 until some time around late in the afternoon on the 28th was II when we really began to get some fairly decent information. But it wasn't until the next day that we had a decent under-13 standing of what had happened, so that I don't think there Id would have been any way that we could have drawn a conclusion 15 or made a comparison between those two transients. There was just too little information. I7 Q Okay. 18 When did you learn that the PORV was stuck open or 19 had been stuck open? 20 A I believe it was the next day. 21 ,S Q So you don't recall any discussion about that on e i 22 Wednesday, the day of the incident? 23 ,m A No. 4 \\_/ 74 Q Okay. Ace Federal Reporters, Inc. BY MR. FOLSOM: t

81 /'N 1 (vjb77 Q Do you recall the content of the message or l information that informed you that the PORV was stuck open as l 2 /'_N 3 (' to time or duration? i 4 A No. Again, it's hard to separate what we learned 5 afterwards from what we learned early. No, I don't recall when we first heard about the PORV being opened; whether that 7 was at the time at which we learned how long it was before 8 they closed the blocked valve, I don't recall. 9 N MR. HEBDON: Okay. BY MR. HEBDON: .\\ 11 O I'd like to ask you some questions that are some-12 ggg what more general in nature. 13 l In your opinion what is meant by the term an 14 "unreviewed safety question"? 15 A It's a condition or a combination of circumstances 16 which have not been looked at within the safety analysis for a 17 given site. 18 MR. EDGAR: I'd like to go off the record for a 19 moment. 20 I (Discussion off the record.) (Recess.) 22 MR. HEBDON: Okay, we're ready to resume. Let's 23 ) go back on the record. ('J y BY MR. HEBDON: Ace Feder;j Reporters, Inc. 25 Q In your opinion, what issues or problems should be

i 82 l j pb78 submitted to the NRC for review? o 2 A You're asking for this opinion as I think today? 3 (_)' Q No, I think more in the feelings that existed 4 prior to TMI. 5 A Well, it's very clear by law as to what we have to 6 do with regard to, for example, the discovery of an error in our ECCS calculations. In that particular regard we are i 8 obligated, if we were to discover an error that l_d to a J 1 9 variation in heat clad temperature of more than 20 degrees, to 10 tell the NRC about it. 11 Q How about in other areas not directly related to ggg the ECCS analysis? 13 A We have reasonably clear direction as to what our 14 obligations are under either 10 CFR 21 or 10 CFR 50.55 (e). 15 If we were to discover outside the ECCS analysis an error in 16 another accident analysis, Appendix K covers ECCS calculation 17 requirements pretty specifically. The things, the accidents, 18 the transients which are non-ECCS related I feel we're obligat-19 ed to tell them about anything that we would find either in a 20 hardware or analysis area that would take us outside the boundaries of the safety analysis report and the assumptions 22 that had been made in that analysis. 23 () If we had determined that there were some assump-24 tions that were no longer valid -- control rod drop time or . Am FWwd Hmonm, lm, 25 what have you, or the -- well, those are some examples. L

83 j pb79 So primarily I think the obligations that we have 2 clearly under those regulations that I mentioned and things (3j that would invalidate the safety analysis that served as the 2 3 4 basis for the plant's license. 5 O In the reviewes that are performed that you're 6 involved with, does anyone assess what would happen if the 7 operator took incorrect action during a transient? 8 A I don't think so. I think correct operator d 9 actions outside the single failure criteria -- I mean outside 10 those operator actions that might be covered by the single 11 failure criteria, the normal assumption is that the operator 12 does what was assumed in that analysis. If he's supposed to 13 open the suction valve from the voided water storage tank or 14 switch over from the sump to the voided water -- borated water storage tank or vice versa, it's assumed that he does that. 16 Q Is there any thought given to -- 17 A Pardon me a minute. 18 One of the big points of discussion that has 19 occurred over the years is not whether he does the correct thing or the incorrect thing, but there has been a lot of 21 ,/~) discussion about how valid the assumption of his timing is. EN 22 Q Okay. 23 /^) There's been e lot of debate on the question of ( / 24 the operator doing something he's supposed to do or not doing Am FWed Rgomrs, W. 25 something that hu's supposed to do. But has there ever been

84 hpb80 any discussion in your mind about the operator doing something a 2 that he is not supposed to do? l A I can't recall any conversations like that. We 4 are getting into that now with a more sophicticated approach S to the development of operating procedures by the use of fault 6 trees. 7 We have a program now which is designated as our 8 Abnormal Transient Operating Guideline Program which is a very 9 extensive program, and that will addrest, combinations of 10 things that the operator does or does not do as well as 11 l multiple equipment failures. But in the past, I don't think 12 so. 13 Q Do you have any feeling for why that type of a 14 consideration isn't included in the design of plants? 15 A I can only speculate. 16 Q Okay. 17 A You want me to speculate? lb Q Please. 19 A It would only be that, again, there has been a very heavy emphasis on the machine as far as the licensing a i 21 t process is concerned, and not on the man, e 22 Q Okay. 23 [~N, Do you know of any other precursor events that in 24 your opinion are relevant to the accident at TMI, and let me AwFWed Reorwrs, lm. 25 define " precursor events" in the context that we've been using I

85 b81 it. 2 It's basically any event or really any issue that might have indicated that an accident such as TMI might happen 4 at some point in the future. The Davis-Besse transient is a 5 good example. The Kelly and Dunn memos are also good examples. 6 Do you know of any others that you feel might be 7 relevant to the accident at TMI? O 8 A Not specifically. In the broad sense that we now 9 look back on TMI-2 there is an extremely large number of 10 operator-error-caused events. I mean, that's the thing that 11 really sticks out as far as the things that are the basis for (} licensee event reports, and in the sense that TMI-2 did involve 13 operator errors, I suppose in the real broad sense you could 14 say there have been many, many precursors. But specifically 15 relates to issues like misinterpretation of pressurizer level, 16 no. 17 Q Okay. 18 Do you have any additional information that you feel 19 might be relevant to our inquiry into the events surrounding 20 the cident at TMI? b 21 e A I don't know exactly how broadly to interpret that 22 question. I can't think of any information in the form of [) memoranda or precursor information. 24 O Well, let me try to restate the question a little . A w.r e w s n co m n. w. l 25 bit. i u

86 ~ 1 ( ^'pb82 Have we failed to elicit any information that you m g %J 2 believe to be important? Basically, is there anything else that (J you feel is important or relevant that we haven't touched on s 3 s 4 in the course of our discussions? 5 MR. EDGAR: Within the context of his questions. 6 MR. HEBDON: Right. O 7 MR. EDGAR: I mean, there may be the universe. 9 0 BY MR. HEBDON: y 9 Q Within the context of precursor events to TMI or 10 the TMI accident? 11 i A No, I can't think of anything. 12 Q Okay. Ah 13 Is there anything else you want to say? 14 A Well, I can talk all day about the things I think 15 we ought to be doing for the future. But specifically with 16 regard to the line of questioning that we've had here, no. I7 0 Okay. 18 MR. HEBDON: Mr. Folsom, do you have anything else? 19 MR. FOLSOM: A couple of questions. 20 BY MR. FOLSOM: 2I Q I'm an expert on bureaucracy. I've been in one for 22 many years. e, es I nccice -- and this may be unfair to put the ~ ( 24 question to you, but: Are there any management personnel to 25 your knowledge.that have business administration decrees at B&W? I

87 pb83 A If you're asking me the question with regard to my 2 direct line of supervision -- (9 3 (y Q All right, that will do for now. 4 A -- I don't think that my direct managers have Sl I business administration degrees per se. I do want to say, 6' though, that my direct managers over the past two or three 7 years, Mr. McMullen, Dr. Roy, Mr. Deddens, have had many, many O 8 special courses for management personnel, and I'm talking about 9 courses lasting six to eight weeks of full-time intense train-10 ing given by business consultants. 11 There have been many in-house training programs 12 ,r$ dealing with business type activities, non-technical courses. G' 33 If you go outside my direct line of supervision, there are 14 many people in tnis building who have masters degrees in 15 business administration, and there are many people who have 16 been to short courses given by our retained business consultants 17 from the University of Virginia Graduate Business School. I've 18 been to some of those courses myself. 19 So the answer to your question is a certificate 20 called an MBA or Bachelor's Degree in Business Administration, 21 there are many in the building who have them. But there are 22 equivalent things in my opinion that have been obtained by 23 r"] my direct supervision also. ( / 24 Q Now my next question derives from my ignorance. , Ace Federal Reporters, Inc. 25 Is there any reason why -- well, is there any i

88 1 1 ( }pb84 prospect that HPI termination could become an automated matter 2 rather than be an operator choice matter? ',). f 3 (; A Certainly that's a possibility. 4 Q Has any consideration been given to that? 5 A Not in the direct sense. We have an open mind, 6 however, about what is likely to come out of this more ) 7 sophisticated review of transient behavior of the plant. The I 8 program I referred to as the Abnormal Transient Operating 9 Guideline Program rcad the purpose of that program is primarily ^ to tighten the loop between the designer, the analyst, the 11 operator, the trainer, et cetera. And if in the course of 12 going through these fault trees in a very systemmatic way we r-L_g-13 determine that the real time operator requirements are un-14 reasonable for some things that appear to have a high probabil-15 ity of occurrence, then that would be given consideration for 16 automation. 17 One of the things that has been done -- and I ~ 18 didn't realize this until af ter the fact -- one of the things 19 that has been done on our German plant, the German version of 20 our second generation power plant, is that the isolation valve ) f. 21 for the PORV is automatically closed after a certain period fq k-22 of time. I think it has a two minute time delay or something 23 of that nature built into it. '} 24 So that kind of thing would take away the depend-a..p e,, n,,,,,,,,, 25 ence on the operator to recognize that, although in my opinion I

89 lpb85 he had many reasons for closing that block valve. 2 BY MR. HEBDON: Im 3 ( j, Q Do I understand you correctly that if the PORV is i 4 open for more than two minutes the block valve is shut? 5 A I believe the way it is set up is if the pressure l goes to a point which should lift the PORV, within two minutes i 7 after that pressure has been reached -- and maybe it's that the; 8 pressure has to go down below the set point again, I don't 9 know the details, but there is a circuit in there that would 10 close the block valve automatically. 11 Q Do you have any feel for why that design wasn't 12 considered in the U.F. version? A No. I didn't even know it existed in this one 14 until after TMI-2. 15 Q That particular design, though, existed prior to 16 TMI-27 17 A I believe so. 18 Q That's interesting. 19 MR. FOLSOM: Well, I have no further questions. 20 MR. HEBDON: I have no additional questions. 21 BY MR. HEBDON: / 22 Q Do you have anything else to add? 23 [~j A No, sir. L./ 24 MR. HEBDON: Well, then, thank you very much. Am4MuJ Reporters, lm. 25 That concludes the interview. i

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90 \\ 1 gb86 (Whereupon, at 11:40 a m., the deposition 2 in the above-entitled matter was concluded.) O, 4 5 6 7 o 8 9 k 10 1 I 11 12 ! 13 14 15 16 17 18 19, 20 21 22 23 (s 24 , Ace Fedetti Reporters. 8% 25 .}}