ML19308C456
| ML19308C456 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/06/1979 |
| From: | Hebdon F, Michelson C NRC - NRC THREE MILE ISLAND TASK FORCE, TENNESSEE VALLEY AUTHORITY |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001240614 | |
| Download: ML19308C456 (64) | |
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N U CLE A R R E G U L ATO R'I COMMIS SIO N l
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IN THE MATTER OF:
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THREE MILE ISLAND SPECIAL INTERVIEWS INTERVIEW OF CARLYLE MICHELSON i
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200RIORGNAL Place.
Bethesda, Maryland Date -
Thursday, September 6, 1979 Pages 1 - 63 Telephone:
(202) 347-37c0 4
ACE -FEDERAL REPORTERS,INC.
8001.J40 b/f j
444 North Cepitol Street Washington, D.C. 20001 NATIONWIDE COVERAGE DAILY l
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
X 3
In the Matter of:
4 THREE MILE ISLAND SPECIAL INTERVIEWS j
i
X 6
7 INTERVIEW OF CARLYLE MICHELSON 8
Room 405 9
Arlington Building j
6935 Arlington noad l
10 Bethesda, Maryland 11 Thursday, September 6, 1979 10:00 a.m.
12 BEFORE:
FRED HEBDON 14 FRED G. FOLSOM THOMAS COX 15 16 17 18 19 20 21 O
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23 24
% Federcl Reporters, Inc.
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C _O _N T _E N _T _S 2
INTERVIEW OF EXAMINATION 3
Carlyle Michelson 3
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Whereupon, 3
CARLYLE M'.CHELSON l
4 was called as a witness and, having been first duly sworn, was 5
examined and testfied as follows:
6 EXAMINATION 7
BY MR. HEBDON:
8 G
Have you read, do you understand, the letter to you 9
from Mr. Rogovin of the Special Inquiry Group Staff?
10 A
Yes, I have.
11 G
Do you have any questions or comments concerning 12 that?
()
13 A
No questions.
14 0
Would you please state your name?
15 A
My name is Carlyle Michelson.
16 G
What is your current position?
17 A
I am currently a nuclear staff specialist with the 18 Tennessee Valley Authority.
19 G
Could you describe basically what thet an % !1s?
20 A
Let's go off the record for a moment.
21 0
Sure.
()
22 (Discussion off the record.)
23 BY MR. HEBDON:
24 G
Back on the record.
Am Feed Roonen, lm.
I 25 Would you describe your current position?
4 1
A My current position is a nuclear specialist with 2
the Tennessee Valley Authority.
The position is a new one and, 3
therefore, the duties have not yet been fully described.
But O
4 in general, it will involve dissenmination of nuclear safety 5
problems for the nuclear plants being built and operated by 6
TVA.
7 Prior to this position, I was principal nuclear engineer 8
for Nuclear Systems Analysis for TVA.
The job at that time was 9
similar to what I do now, except it involved supervision of a 10 number of engineers.
My present position does not involve any 11 supervision.
12 0
Why was the new position created?
()
13 A
The new position was a part of a reorganization in 14 TVA to establish a nuclear engineering branch.
This position 15 is as a staff specialist in the nuclear engineering branch.
16 Q.
What was your position in late 1977?
17 A
1 was principal nuclear eningeer for Nuclear Systems 1
18 Analysis.
19 G
Would you describe your employment history, including 20 your relationship with the ACRS and positions held with TVA?
l 21 A
How far back would you like to go?
()
22 G
Back as far as college.
23 A
Okay.
24 Q
Just a brief summary is all we need.
We don't need Ace.Federet Reporters, Inc.
25 a lot of details.
1 1
5 f
1 A
I was employed by TVA upon graduation from the 2
Universit fo Kentucky in 1952.
My first position was as a 3
power supply engineer in Chattanooga, Tennessee.
And it started O~
4 very early to be early activities of TVA relative to nuclear 5
power development.
Within the first year of employment, I 6
became involved in nuclear power.
And I have been involved 7
in nuclear power development since.
8 The resume I gave you has all the details, so I don't know 9
that you want to go into that.
10 0
No.
Just a brief summary is all we really need.
11 A
Basically, I spent 10 years at Oak Ridge National 12 Laboratory as a loaned employee from TVA.
In 1966, I went to
()
13 work for TVA Division of Design to start the design of the 14 Browns Ferry nuclear plant.
Since that time, I have been 15 involved in all of their nuclear plant activities.
16 0
What is your educational background?
17 A
I have a bachelors and masters degree in 18 electrical engineering, masters degree in industrial management e 1
19 and a graduate of the Oak Ridge School of Reactor Technology.
20 g
Prior to March 20, 1979, prior to the accident at 21 TMI, what knowledge did you have concerning an incident that
()
22 occurred at Davis-Bessie on September 24, 19777 1
23 A
The Davis-Bessie incident occurred at the time when 24 I was looking at snall breaks.
I have no direct'information Ace Feder'J Reporters, Inc.
25 about it, other than what I could get through Jess Ebersole who
6 1
was a member of ACRS.
He called me on the phone one day to tell i
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2 me that the:7 had an event that looked kind of interesting, but 3
he didn't have a whole lot of information on it at that moment.
4 But he told me roughly what had happened, but pointed out 5
that the core was quite new an', therefore, it was difficult d
6 to say what the significance would have been if it had been a 7
full power operation with an older core.
That's all the 8
inforr.ation he had at that time.
9 Later in time, and I don't recollect for sure where I 10 learned the information, but later in time I became aware that 11 there was some kind of a relay problem that caused a cycling 12 of the valves.
I believe I learned that from Jesse also, but 13 my recollection isn't that strong.
(}
14 0
Why did he find that particular event to be inter-15 esting?
16 A
Mostly because we had been concerned, both Jesse and 17 I had been concerned, about small breaks and the kinds of 18 events that would cause a loss of reactor coolant.
So anytime 19 you find a case of a relief valve being opened or a pipe 20 breaking, something of this sort, then you become interested 21 in it.
22 G
Did you consider this to be a small break?
()
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23 A
Certainly, yes.
And open relief valve is a loss of l
l 24 reactor coolant, but it is not a break as such because it can h Federd Reporters, Inc.
25 be terminated.
7 1
G What additional information did he provide to you 2
about the particular incident?
3 A
That':s all the recollection I have about the 10 k/
4 information on Davis-Bessie at that time.
5 G
He didn't provide you with a copy of the LER or 6
any of the other reports or analyses than were provided or 7
were developed as a result of the incident?
8 A
No, not to my recollection.
9 BY MR. FOLSOM:
10 G
Where do Lens go that reach TVA from other 11 installations?
12 A
Now, are you thinking in terms of that time period I)
13 or today?
(_-
14 G
Then.
15 A
At that time, LERs came in in an unorganized fashion,-
1 l
l 16 I guess you would say..
My principal source of LER material 17 was reading I.tomic Energy Clearinghouse which not routinely, 18 but often, included LER material and included descriptions 19 of events occurring elsewhere.
20 BY MR. HEBDON:
21 G
Excuse me, if I could interrupt, do you know if that
(~)D 22 particular publication included any information on the x
23 Davis-Bessie incident?
l 24 A
I don't recollect seeing it in there.
But the Am-Feer:1 Remners. Inc.
25 Atomic Energy Clearninghouse at that time was not well organized
8 1
in terms of comprehensive reporting of LERs.
Presently,, it is, 2
I believe -- at least they claim to be -- comprehensive and 3
including all LErs.
That is my understanding.
4 BY MR. FOLSOM:
5 O.
Mas there someone that TVA charged with keeping 6
track of LERs?
7 A
At that time, not to my knowledge.
8 BY MR. HEBDON:
9 Q.
Was there any systematic effort to review LERs on 10 plants that were similar design to the plants in the TVA system?
11 A
Not that I was aware of.
I did a little bit on my 12 own.
A couple of the fellows I had working for me attempted to
()
13 do some looking, primarily in terms of those kinds of events 14 that might relate to, say, Browns Ferry nuclear plant.
15 We got the information as best we could.
We had certain 16 kinds of sources that weren't too bad.
We used, from time to 17 time, the Nuclear Safety Information Center reporting which 18 comes out in the form of 5 x 7, I believe, index cards, or a 19 little larger, actually.
But we didn't receive those necessarily 20 in an organized sense and file them, examine them and file them, 21 in an organized sense, no.
It was strictly on an individual
()
22 interest basis, at least to my knowledge.
23 I should clarify I am speaking now of Division of Design 24 Activities.
Our Division of Power Operations is in another Ace-Federst Reporters, Inc.
25 city, in Chattanooga.
I have no knowledge of how they might l
9 1
have handled it.
2 0
But from the organization that you were in, as far 3
as you know, there was no systematic effort to incorporate b;s 4
operating experience at plants outside of the TVA system in the 5
design of new TVA plants?
6 A
At that time, to my knowledge, there was no 7
organized effort.
8 G
Did you prepare a report entitled, " Decay Heat 9
Removal During a Very Small Break LOCA," for a B&W 205 fuel 10 assembly PWR?
11 A
Yes, I did.
12 0
Why did you write that report?
()
13 A
That report actually was a culmination of a long 14 period of thinking about the problems of small breaks on 15 pressurized water reactors dating back to two years or more 16 before the report was written, and with considerable discussion 17 with Jesse Ebersole from time to time.
We were both concerned 18 that if pipe breaks were to be experienced, they would likely 19 be small ones, as opposed to large ones.
And so, therefore, 20 we were quite concerned about the behavior of PWRs for very 21 small breaks.
We were not satisfied that the information O
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22 available to us, at least from the nuclear steam supply vendors, 23 adequately covered the question of small breaks.
24 So we thought about them from time to time and attempted to Ace Fedect Reporters, Inc.
25 postulate what kind of behavior small breaks might have.
And
I 10 1
so finally, when a little more time became available -- and it 2
took that -- I took a look at the problem myself.
At about the 3
tiae of the period of early 1978, I no longer had to supervise O
4 24 people, which I had up until that time.
I had about 12 5
-cople after that.
So I had a lot more time to think about 6
these problems.
7 G
Why was the size of the group that you were 8
supervising reduced?
9 A
Well, I started out with nobody in 1970 and built 10 up a staff of 24 people over the period of years.
The activity 11 at that time included, not along the design and construction 12 safety reviews, but also the preoperational testing of the
()
13 plants.
Each plant, I was responsible for preoperational test 14 program in the Division of Design.
This activity alone was a 15 kind of major consumer of time.
16 So it was decided at approximately 1977 to divide the group 17 into and create a separate preoperational and start-up group.
18 So at that time, about half of my people were spending all 19 theie time on preops.
And they were transferred over to this 20 new group that was formed.
21 BY MR. FOLSOM:
)
22 G
May I just for the record get the date of this 23 report?
24 A
Which report?
Ace Federal Reporters, Inc.
25 0
The handwritten version which I understand is
r 11
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1 May 15, 1977.
I 2
g Well, I think we haven't got around to discussing 3
the handwritten version yet.
The report that was discussed
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was the January, 1978, report.
4 5
Now, let us go back, then, a little bit in history and 6
clarify this point.
When more time became available in which 7
to do these kinds of studies, and I didn't really have anybody 8
else that was adequately, I guess you would say, prepared to do 9
this type of work, I did it myself.
And I first looked at the 10 Combustion Engineering plants and wrote a hand-written 11 description of what I thought the behavior of small breaks 12 might be for a Combusion plant.
And this was written in May 13 of 1977.
{}
14 B
And Mr. Hebdon was inquiring about the January 15 report, then?
16 BY MR HEBDON:
17 0
I was really inquiring about the whole set of 18 reports from the CE report all the way through to the type-19 written draft report.
20 A
Yes.
And I will go ahead and complete the 21 chr.a 1.ogy.
22 MR. FOLSOM:
Off the record for a moment.
(}
23 (Discussion off the record.)
24 BY 19.. HEBD0h.
lee.Feder;I Coporters, Inc.
25 G
Back on the record.
1 I
.1
12 1
A The May,
'77, report was written to describe the 2
behavior, or at least what I thought the behavior of Combustion 3
Engineering plants might be in a small break case.
This report O
4 was completed in a very short time.
It took about a month of 5
part-time work to think about it and write it up.
But in the 6
process of writing it up, I began to think about the B&W case, 7
which is a considerably different geometry, and appeared at that 8
time even to have some kinds of problems that did not exist 9
so clearly for the Combusion case.
10 So at the time I completed the Combusion work, I went right 11 on to start writing a hand-written draft of B&W work.
There 12 was probably about two months of time inbetween, because when
()
13 you sit down and do something like this. then you have got to 14 catch up on other jobs.
And I got back to it, though, as I 15 recollect, sometime in August and prepared a hand-written 16 which essentially tracked the same kinds of things as described 17 for Combusion, except it attempted to point out differences, 18 where problems might exist that were unique to the B&W case.
19 This work was issued as a hand-written draft material in l
l 20 September of 1977.
And historically, I guess there is a couple f
21 of other events that we ought to fit in here.
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22 At the time I completed the Combustion material and I had 23 talked to Jesse Ebersole a little bit about that and gave him 24 a copy of the material that I had turned out for a Combustion i Ace Federal Reporters, Inc.
25 case --
13 1
g Was he still working for TVA at that time?
2 A
No, he was not.
He was ACRS.
3 0
All right 4
A When I completed the September material, I also 5
gave him a copy of that and pointed out to him that I thought 6
that if there was really a good example of problems with small 7
breaks, it was probably clear in the case of B&W and CE.
And 8
therefore, that is the one he probably should look at a lot 9
closer.
10 Also, in that same time frame, the Pebble Springs docket 11 was -- off the record for a noment.
12 (Brief recess.)
()
13 MR. HEBDON:
Back on the record.
14 (The incompleted answer was read by the reporter.)
15 THE WITNESS: -- being reviewed by ACRS, and so 16 Jesse was interested in perhaps finding out a little bit more 17 about small breaks by asking the right kinds of questions on 18 Pebble Springs.
The material then that Jesse had received 19 from me on Combustion and on B&W was available to him at the 20 time he put together some of the Pebble Springs questions.
21 And Question No. 6 in that Pebble Spings set was an attempt to O)
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22 see if certain information could be brought to light in the 23 case of B&W p} ants by asking it on the docket.
24 BY MR. HEBRON:
Am Federal Coporters, Inc.
25 0
Let me see if we can fill in a couple spots here.
y
14 1
First of all, could you describe your professional relationship 2
with Mr. Ebersole?
3 A
Mr. Ebersole was my supervisor during a period of O
4 time when I was at Oak Ridge National Laboratory, although he 5
wasn't an immediate supervisor, but he was an administrative 6
supervisor.
He was my supervisor at the time that we worked 7
together on the experimental gas code reactor project at Oak 8
Ridge.
He was the technical superintendent, and I was the 9
supervisor of the experimental engineering group.
1)
After we went to work at the Division of Design in March 11 of 1966, he was my supervisor as head of the Nuclear Design 12 Staff.
He was my supervisor up until the time that he retired.
()
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13 And I don't recollect the exact date, but I think it was about 14 1974.
15 G
What was his involvement with your becoming a 16 consultant for the AGRS?
17 A
He had a considerable interest, of course, in my 18 participating in ACRS since he thought that I could make a 19 contribution to their effort.
So I first became involved with 20 ACRS during the time when there were some hearings held 21 concerning dissenting technical opinions in ACRS.
()
22 Pardon me, in NRC.
My recollection was that was sometime 23 in the fall of 1976.
24 4
In what areas, what technical areas, were you l
Ace Federal Reporters, Inc.
25 involved with the ACRS at that time?
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15 1
A Well, I became involved as an outside consultant l
t 2
to assist in the examination and review of these dissenting 3
technical opinions.
My area of expertise was generally 4
considered to be nuclear systems analysis.
5 Since that time, I have become involved in a number of other 6
areas, including nuclear plant security, which I first became 7
involved in extensively as a part of a job which I had worked 8
on at the Sandia Laboratories Workshop od Security in the 9
summer of 1975.
10 As a consequence of that workshop, I wrote a report which 11 received some amount of attention because it was a somewhat 12 different approach to the security question that had been
()
13 generally discussed up to that time.
14 0
Mhy were you interested in small breaks?
15 A
I think I already indicated this, but I will go back 16 again.
The interest'in small breaks is a logical one.
The 17 likelihood of large breaks failing is considered by most people 18 in the nuclear engineering business to be much less probably 19 than small pipe breaks.
As a matter of fact, nuclear plants 20 have experienced a number of small pipe breaks, generally pipes 21 of the oter of, say, 1 inch or so.
22 Our own Browns Ferry nuclear plant has experienced instrument 23 line breaks, for instance, in this general size range.
Their 24 behavior on a boiling water reactor is considerably different Cce Federal Reporters, Inc.
25 and much less concern, at least in my opinion.
16 1
The behavior of a similar break, though, on a pressurized 2
water reactor reactor can be much more difficult to contend 3
with.
And it was for that reason that I became interested in O
4 making sure that they understood how they might behave.
5 c.
Would the revie of small breaks be part of your 6
normal function of your job?
7 A
I think that is correct.
The job that I had was to 8
review the safety and licenseab'ility" of all our nuclear plants 9
And any aspect of that plant that might affect safety or 10 licenseability was certainly a legitimate area of review, if 11 I so elected.
12 BY MR. FOLSOM:
("h t/
13 G
What was your logic for considering the small break 14 LOCAs would be different or outside the Browns, if I am using 15 the word correctly, of the large breaks, big pipe, which was 16 considered the worst case situation by the industry?
17 A
Right.
The problem is in the case of a pressurized 18 water reactor, if you experience a very large break, the system 19 undergoes an immediate, rapid depressurization to very low 20 values.
You bring in a large amount of flooding water to cool 21 the core.
There is plenty of hole.
The area of the hole is O
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22 sufficiently large to allow all that flooding water to pour 23 right out of the system so you can flush the core on a large 24 break.
l Ace Federal Reporters, Inc.
25 On a small break, you cannot flush the core.
There is no l
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17 1
place to flush the water to.
So it becomes very important 2
to understand how the core can then be cooled, by what 3
mechanism.
So that is the big difference.
, O 4
The large break allows -- it is very simple.
It is simply 5
a matter of being able to #1ush the core out with plenty of 6
cooling water.
7 0
For a layman such as myself, then, would it be fair 8
to characterize the small break as something that is sneaky 9
and sneaks up on the plant?
10 A
This is a fair characterization.
It doesn't 11 necessarily sneak up,on the plant, generally, the break, and 12 the instrumentation available will tell you that you have
()
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13 experienced some kind of potential loss of reactor coolant.
14 But where it is and how it is behaving and how it can be l
15 addressed is potentially sneaky, that's right.
16 BY MR. HEBDON:
17 G
There had been, I believe, at that time a fair 18 amount of effort spent on analyzing small breaks.
19 A
That is correct.
There was a considerable effort.
20 Recognizing historically they started out with the large break 21 and thought that was all that was necessary to take care of the
()
22 worst problem, historically they found later on that intermediate 23 and smaller breaks also had their own unique behavior.
And 24 they had to be carefully analyzed.
Ace Federal Reporters, Inc.
25 The difficulty that arrived was that the model by which they
18 1
predicted the behavior of small breaks was.not necessarily 2
valid for very small breaks.
The reason being that it did.not 3
account properly for the hydraulic behavior of the system 4
which now became very important because it was a very slow 5
changing situation.
It was not the usual fast depressurization i
6 followed by a massive reflooding of the core.
7 So the small break wss thought to have been considered.
8 And in fact, the NRC analyzed the small break models and 9
has issued an evaluation that Tays it took care of the problem.
10 The pitfall of the analysis, however, was that they used 11 the same model as they adjusted the hole sizes to smaller and 12 smaller values.
And they did not recognize that the model was
()
13 becoming invalid as the hole size became smaller.
14 So by using the model that they thought was valid and by 15 going to smaller hole sizes, they found the core was always 16 kept covered and cool and, therefore, there was no problem 17 below some certain break size.
That was not a correct approach, 18 as I was attempting to point out.
19 G
So that what you were attempting to point out for 20 an even smaller class of breaks than they had analyzed, the 21 model became invalid?
()
22 A
The model did not appropriately consider the small 23 breaks.
Certainly many portions of the model were perfectly 24 valid, but not all portions.
It did not take a new model, Ace Federd Reporters, Inc.
25 but rather an adjustment of the existing models to correctly 1
19 1
what happens at even smaller hole sizes.
And this was the part 2
that I found as best as I could determine to be missing in the 3
reports that I reviewed concerning the B&W small breaks.
I 4
simply couldn't find in there the correct treatment of what.I 5
thought to be the behavior of very small breaks.
That's why 6
I called them very small breaks as opposed to small breaks, 7
which I felt were adequately covered by the model.
8 Q.
Why did you feel that the B&W design was more 9
susceptible to this problem than the CE design?
10 A
One of the principal considerations in the very 11 small break is the fact that a portion of the decay heat must 12 be removed by the steam generators, since the hole itself is
()
13 not large enough to transport all the decay heat.
If the 14 steam generator must remove a portion of the heat, there must 15 be a continuing convective flow from the fluid from the core 16 to the steam generator.
17 This meant that natural circulation in the fluid state was l
18 a very important consideration.
19 If you look at the piping arrangement for B&W, you will find 20 that the pipe passes through a high point prior to entering the end #1 21 steam generator.
This means there is a point at which the j
()
22 elevation or, in other words, the pressure is low and the 23 temperature is stb 1 roughly as high as at the exit of the core.
24 Under such a circumstance, if a system is depressurized Ace Federal Report?rs, Inc.
25 down to satiration consideration, the fluid will first start
20 1
to steam at that high point.
2 This would raise in itself some questions about the 3
viability of continuing natural circulation.
This was the one O
4 unique characteristic that was probably most important as far 5
as small break analysis.
6 Once having broken the natural circulation in the system, 7
then it became a race to get enough fluid out of the system so 8
one could now use the steam generator as a condensor.
Since it 9
can no longer convect to it, you must now pass the steam 10 through piping and condense.
This period of time is very 11 troublesome in the case of the B&W 205 fuel assembly plant.
12 In the case of plants such as the 177 fuel assembly plants,
()
13 it is of less interest, because the auxiliary feedwater is 14 sprayed at the top of the steam generator.
In the 205 plant, 15 it comes in as a flooding system at the bottom of the steam 16 generator.
So there could be delays of the order of 15, 20, 30 17 minutes or more, depending on the break size, before it could 18 becomm a condensor.
19 0
You mentioned that ycu felt that this was an issue 20 that had not been reviewed, these very small breaks, and how 21 they would perform.
O 22 ree.
23 O
Did you give any consideration to reporting this 24 issue that you had identified as being unanalyzed ok unresolved
' Ace Federal Reporters, Inc.
25 to the NP.C?
21 1
A Let me point out now that at that time, and in the 2
hand-written document, even, I put in the NRC's formal evaluation 3
and approval of the small break model by B&W.
So what I was 4
doing now was questioning the judgmnet of NRC in their small 5
break approval.
So clearly, it would be desirable to get 6
information to NRC by some means to point out to them that 7
perhaps they need to go back and look at the small breaks again 8
A I attempted to do this by giving the material to 9
Jesse Ebersole and point out to him that I couldn't tell him to 10 gi';e it to NRC, I didn't think that was quite right, but I also 11 instructed him that I didn't really care what he did with the 12 material.
So he did give the material to NRC.
And he gave it 13 to Sandy Israel.
And he received the material back on the
(}
14 21st of Septenber with a receipt indicating that they had 15 retained copies.
16 So I had thought I.had reasonable basis to believe that the 17 ERC was at least aware of my views on the problem, and that 18 it was certainly an appropriate peer group to review such a 19 problem and reach their own decision as to whether or not it 20 warranted further consideration.
21 G
Uell, I guess this is something that I find a little
( })
22 confusing.
The report was informally handed or sent to 23 Mr. Israel.
It was a hand-written draft report.
{fereyou 24 reasonably confident that a hnad-written draft report informally Ace Federd Reporters, Inc.
25 given to a member of the Staff, a section leader on the Staff,
22 1
which is not particularly a senior position in the NRC, would 2
receive any extensive review or any great deal of review in 3
an area that the Staff had already felt that it had resolved O
4 the issues?
5 A
I felt that it would bc just as effective as an 6
anonymous letter that arrived from Pennsylvania in about 1972 7
dealing with the questions of pipe breaks outside of containment, 8
which is my understanding was also an unsigned document.
It 9
certainly got appropriate attention and consideration by NRC.
10 I had no reason to believe that this wouldn't fare any worse.
11 BY MR. FOLSOM:
12 Q.
Was there any reason why you did not formally submit
()
13 it?
14 A
Now, we are referring to the hand-written naterial 15 in '77?
16 A
Yes.
17 G
Yes, there were.
Let me explain it this way:
18 If a person comes up with a problem and he looks-it over, 19 and it is in obvious disagreement with a rather large and 20 learned group of people, both within the Babcock and Wilcox 21 Company and within the NRC, you have'to treat that as a one-man
()
22 opinion.
23 Clearly, I felt strongly enough about it to make sure that 24 other people at least were aware of my opinion.
But I did not Oce Federd Reporters, Inc.
25 feel so strongly as to believe I had to force it on my own
23 1
organization as well as force it on NRC under the circunstances; 2
the preliminary nature and so forth, in September of '77.
I:f 3
felt it was not in a position then of a type of document that O
4 was ready to be voiced.
5 However, I felt cuite confidently it was a suitable document 6
for review by people who are interested in this sort of area 7
and who might derive some new insight from it if, indeed, it 8
was even valid, keeping in mind that again I felt it represented 9
a number of valid arguments, but clearly I could not claim 10 that they were shared by anybody else.
11 BY 12. HEBDON:
12 C
What caused you to include in that report a position
()
13 or a statement concerning the possibility of the operators 14 being misled by pressurizer level?
15 A
At the time that I looked at the Combustion job, 16 it became apparent that the time history of the level changes 1
17 in the pressurize were an important consideration, particularly l
18 since that was normally what the operator would watch during 19 such a slow-moving event.
I became concerned even in the case 20 of Combustion that the level history is a strange one in that 21 there are periods of time during which level indication
()
22 is clearly not the thing to be followed.
23 However, in looking at Combustion, it became apparent that 24 B&W could have even a worse problem in this regard because of Ace Federot Reporters, Inc.
J 25 the presence of a loop seal on the pressurizer.
In other words, t
24 l
j the piping is shaped more like a manometer.. As a consequence of this loop seal, the indication can be even more deceptive 2
than in the case of the Combustion plant.
3 O
So it was already recognized and already remarked on in the 4
Combustion case.
And it was reremarked and emphasized more in 5
the hand-written version of the B&W case.
And then I pushed 6
it even harder when I prepared a formal type written version 7
in January of '78.
8 9
G You mentioned that you forwarded this report to Mr. Ebersole of the ACRS.
And it is your understanding he 10 11 then forwarded it along to Mr. Israel of NRR.
Did you ever 12 receive any comment from Mr. Israel.
()
A I never received any comments from anyone on this 13 14 document, including Mr. Ebersole, other than he read it and 15 understood it and agreed with it, but no comments in the sense 16 of you ought to look at this a little more or change that or whatever.
17 18 G
Did you receive any sort of a response from NRR 19 directly or through Mr. Ebersole from NRR --
20 A
None.
21 G
-- about these concerns?
()
A Not at all.
22 23 G
Did that bother you at all?
Notparticularly,sinceIwasassurebthattheyhad 24 A
. Ace Federd Reporters, Inc.
25 the report -- since Jesse told me they had the report.
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1 25 certainly didn't necessarily expect them to communicate with 1
2 me directly on it at all.
3 G
Did you have any feeling that possibly this report O
was sitting in somebody's Things I ought to get to someday 4
5 Pile?
6 A
I recognized there was always that chance.
- Yes, I certainly recognized that as a possibility.
7 8
G Did you feel that it was very likely that that was 9
the case?
10 A
I don't recall feeling any strong misgiving about 11 it.
I thought in my own opinion the report was sufficiently 12 clear and sufficiently detaile~ even at that time that anybody
()
13 that read it would certainly understand what I was concerned 14 about.
15 And if, however, such thoughts had already been preexamined, 16 then I would expect the people to lay it aside and say, "Well, 17 we have already considered that, and it is okay."
That was 18 as much as I had thought on it.
19 G
When you didn't receive any sort of feedback from l
20 Mr. Israel or from NRR, did you give any consideration ts l
submitting the report either to ACRS or NRC in any more formal 21
()
27 manner?
i 23 A
Well, now, let me clarify one point.
You se.y I l
24 received no feedback, and maybe I wasn't real. clear.
I l AwFMud Reponen, W.
l 25 indicated that Jesse didn't give me detailed comments on the l
26 1
report.
He did give me one general comment, though, which 2
came back to me as coming from another ACRS member.
And my 3
recollection, and it is a weak one, is that Dr. Okrent was
_s s
4 the one that gave the comment.
5 The comment was to the effect that, gee, these are a lot 6
of interesting statements, but I don't see any numbers to back 7
them up.
It was on the basis of that comment that I went back 8
and had quite a bit of analytical calculational work done, at 9
least a sufficient amount to back up some of the statements 10 with numbers.
And you will find then a considerable difference 11 between the September and January report in this regard.
The 12 January report is much more quantitative.
()
13 So that was the little history that goes with that particular 14 difference.
15 G
As I understand it, you provided the January report 16 to Mr. Ebersole?
17 A
Yes, I did.
18 G
Did you have any indication that he then provided 19 that to anyone in NRC?
20 A
No indication at all, because it was during this 21 period of time that he had personal health problems.
And I
(
22 think that he just -- I do not know what he did with the report.
23 g
Did you feel any need to provide that copy or that 24 draft of the report to NRC?
y Feder@ Reporters, Inc.
25 A
Now, at that time I was, shall we say, determined l
1
27 1
that the issue be brought to a head, because after having gone 2
back and having done some additional quantitative work and 3
having thought about the problem some more in more detail and O
4 having recognized and clear.y tried to indicate that the level 5
indication problem could be troublesome, I felt that it was 6
important then to bring this to the attention of TVA and to the 7
attention of the NSS supplier.
8 We discussed within TVA what to do with the report.
There 9
were two alternatives that were considered.
One was to send 10 it directly to NRC.
Another was to consider sending it to 11 B&W for comment first.
But the intention, our intention, was 12 at the appropriate time to send it to NRC.
()
13 Now, one has to decide what is again the appropriate time.
14 Keeping in mind that this was still one man's opinion, it 15 wasn't shared necessarily, nor there was not necessarily any 16 resistance to the opi-nion, it was simply not understood by 17 other people because they hadn't looked in that depth in the 18 problem, and it is not the sort of problem that you just pick 19 up, not being a little bit knowledgeable in the area, and pass 20 judgment on it.
21 So the decision that was made after considerable commiser-()
22 ation was to send this document to the Babcock & Wilcox 23 Company for their comment.
And then we would see what they l
24 thought and decide accordingly.
This was done on April 27 of I
'Am Fuferal Remners, lnc.
25 1978.
l
28 1
g Why was it decided not to send it to NRC?
2 A
It was decided, as best I can recollect, it was 3
decided not to send it because we felt that, first of all, it 4
was only one man 's opinion.
It was, therefore, something that 5
certainly appeared to be sufficiently of concern to bring it 6
to the attention of our supplier, but not clearly the sort of 7
thing that wodld be brought to the attention of the NRC.
8 You know, again, you have to put this in perspective.
If 9
I were an expert'in the ECCS area, I think one man's opinion
'o is all it would take.
But not being an expert in that area, 11 and I do not pretend to be and have never pretended to be an 12 expert in this area, it is a little more difficult, then, to
()
13 take one man's opinion and go directly to NRC with it.
14 But it was of sufficient importance that it was brought 15 to the attention of the group of experts which we felt could 16 pass judgment on it. -
17 G
I believe Part 21 to the regulations was in effect 18 at that time.
Did you feel any responsibility under Part 21 19 to report what you seemed to feel fairly strongly was a i
20 deficiency in an analysis that had been done?
21 A
The question of whether to report under Part 21, of
()
22 course, was the thing I was discussing just previously in terms i
l 23 of reporting to NRC.
We looked over the Part 21 description 24 of requirements that had to be met to make it reportable under
' Ace Federal Reporters, Inc.
25 Part 21 and could not clearly identify this as a reportable l
t
l 29 1
item under Part 21.
2 G
My own intuitive feeling was that I would much rather 3
report it right away.
However, I also examined Part 21 at that 4
time and had to admit that it did not seem to clearly fit the 5
regulation.
Therefore, I was satisfied to let B&W look at it 6
first, with the understanding on the part of TVA that we would 7
see what B&W would come up with and then decide accordingly.
8 But Part 21 simply does not seem to address what a company 9
should do when one individual comes up with a what-if question 10 which does have significant consequence, but which has not been 11 sufficiently established by expert consideration.
12 G
So then your feeling was that the concern was still
()
13 sufficiently tentative that it did not yet meet the test of 14 requiring reporting to the NRC?
15 A
That appeared to be the case.
As I say, I looked 16 at the regulation myself.
I didn't necessarily just take the 17 view of our licensing people on it.
I discussed it with them.
18 I read the regulation myself and I could not find anything in 19 the regulation that was a sufficiently good fit to force the 20 issue into the regulatory process.
21 G
I would like to ask you a couple of questions about
()
22 your relationship with the ACRS.
As I understand it now, you 23 were at the time consultant to the ACRS.
24 A
At that particular time, I had been a consultant in l
l Ace Federet Reporters, Inc.
25 the area of the differing technical opinion.
And at that time, l
i l
30 1
I was also a consultant in the security area.
2 G
So at that time, you were a security consultant.
3 A
Yes.
O 4
G Were there any prohibitions in your agreement or your 5
contract to be a consultant for the ACRS about consulting in 6
areas of reactor safety, system safety, that type of material?
7 A
No.
Clearly there is no prohibition, since that 8
is the principal subject matter of the ACRS.
There was an 9
agreement.
We have no written contract,cby the way; it is a 10 verbal agreement.
But it was understood by all parties at the 11 time that I would not be allowed to consult on matters that, 12 shall we say, would directly and immediately affect TVA.
But
()
13 I certainly could consult on generic safety issues which might 14 ultimately affect TVA.
15 G
Did you feel that this report fell into the category 16 of the generic safety issue, or into the category of matters 17 that directly related to TVA?
18 A
No.
This was clearly a generic safety issue.
19 Because of its very preliminary nature, it clearly would not 20 affect TVA immediately.
21 4
So then you didn't feel any inhibition against
()
22 bringing this type of an issue before the ACRS?
i 23 A
I felt none at all.
24 0
What, in your opinion, would have happened if the
, Ace Federd Reporters, Inc.
25 report had been formally submitted to NRR?
t
31 1
A Now, you just, of course, want my own speculation?
2 0
Obviously, that would have to be a speculation.
3 A
That one is a question that I have asked myself on O
4 a number of occasions.
It certainly is a very subjective 5
question.
My own opinion is that if this document had been 6
sent to NRR or to, I should say, the NRC, it would have 7
eventually been appropriately reviewed, I'm sure.
And even-8 tually I believe that at least if I had an opportunity to 9
discuss it with them, it would have been, the views would have 10 been, adequately aired, And I think that min _ mal changes 11 might have been made.
12 I think that perhaps the NRC would develop even a better
()
13 understanding of small break behavior, not necessarily because 14 it was adequately discovered or, pardon me, adequately 15 discussed, in my report, but rather it would just get them 16 to thinking about the problem again.
17 I think that the question of level indication, which is a 18 very simple situation, would certainly have caught their eye 19 because it is very easy to understand how it works and how 20 it may not work.
The small break analysis is a much more 21 complicated question.
So probably it would take longer to
()
22 make progress.
23 So I believe, eventually, over a period a two or three years, 24 some changes might have occurred as a result of the report.
And Ace Federti Reporters, Inc.
25 I think that is probably a realistic time frame for these kinds, l
32 1
of Problems, keeping'in mind that it took me a year and a half, 2
more or less, and maybe even as much as two years in thinking 3
about the problem seriously.
O A/
4 Unless you get the attention of somebody with a large amount 5
of resource to work on, it moves slowly.
6 G
Was the report submitted to B&W7 7
A Yes, it was.
8 0
Why?
9 A
Well, as I outlined a little earlier, after the 10 internal process of deciding how to handle thetissue, at that 11 point it was decided to send it to B&W as a report without 12 even questions, but sent mainly in the form of a report for 13 their review and comment.
(}
14 A few points were made in the letter concerning particular 15 issues in the report, one of which was the problem of level 16 indication and proper, operator action.
But basically it was 17 sent as a report for review and comment.
18 g
As I recall the letter forwarded the report to B&W, 19 the concern seems to be raised in the context of the questions l
20 that were raised on the Pebble Springs docket and the possibility 21 of those questions again being raised on the Bellefont docket.
()
22 Why was that particular approach taken?
23 A
That particular approach was taken as a means of 24 encouraging a timely consideration of the problem on the part l
pm Feed Remnon, h e.
l 25 of B&W.
If you want somebody such as your NSS supplier to move t
?
33 1
fairly quickly on a problem, you generally have to give them 2
a good reason to move quickly.
Otherwise, other priorities 3
will come ahead of it.
O 4
So the best excuse, if you will call it that, for getting 5
quick action was the fact that these questions had been raised 6
on Pebble Springs and now we want answers that will fit our 7
Particular docket.
8 G
Then, it was your feeling that you would not get 9
a timely response if you simply forwarded.the report in your 10 capacity as a customer of B&W7 11 A
It would not receive the same kind of attention 12 perhaps as it would if it was pointed out that this is already
()
13 a problem of sorts and, therefore, we want to make sure that 14 our vendor is ready to defend his position.
15 G
Would you describe what happened to the report 16 at B&W7 17 BY MR. FOLSOM:
18 G
May I ask, can we put a date on the report to B&W7 19 A
Yes.
April 27, 1978.
20 G
Okay.
Sorry.
21 A
Now, your question again?
()
22 BY MR. 11EBDON:
23 G
Could you describe what happened to the report 1
24 once it was sent to B&W?
! Ace. Federal Reporters, Inc.
25 A
Of course, I can't describe what they did with it.
l
34 1
I can only describe what we tried to do to get an answer.
2 O
What you "saw from your end.
3 A
That's right.
We sent the report on April 27, 1978, 4
and certainly did not, I did not, expect a reply in less than 5
maybe three or four months, just from experience on these kinds 1
6 of problems.
So it wasn't until mid-summer or so that I started 7
asking our contract man who is the contact with B&W to ask them 8
when they were going to reply.
9 From time to time I would ask them this.
10 We would generally get back an answer like, "Oh, it will 11 be two or three weeks, something of that sort."
On one 12 occasion, I recall that the contract man said the letter
(
13 replying is already on somebody's desk ready for signature, and 14 we should get it in a few days.
That one also fell through.
15 On one occasion, when the contract man was going up to B&W, 16 I asked him to check'on it when he was up there.
And he 17 attempted to do it and again received somewhat evasive answers.
18 We did not know why they weren't replying.
But I had speculated 19 at that time there were two possibilities.
20 One is that they had raised some difficult questions, and 21 it took a while for them to think about it.
22 The other was they simply had too many other things to do 23 and weren't paying much attention to it.
24 That went on through the fall and into the winter.
And
. Ace Federd Reporters, Inc.
25 finally, I had made my own mental decision at least that this
35 1
was going to be cleared up by the end of the year, meaning the 2
end of 1978.
So I started pressing the issue very hard in 3
November.
4 Finally, we got a telephone call arranged on the 4th of 5
December of 1978 in which we sat down and started to talk to 6
them about it.
7 As a result of that telephone call and during that tele-8 phone call, it became apparent to me, and I later found out 9
from looking at other people's notebooks who were in the tele-10 phone call at the time, that it became apparent to the TVA 11 people that they probably hadn't even read the report.
12 From the kinds of questions and kinds of statements they A(_)
13 were making, it was not at all clear that they had read the 14 report.
15 The telephone call lasted about an hour and a half of trying 16 to point out to then the problem and their trying to tell us i
17 all about how the NRC had reviewed and approved, and it was 18 done.
19 At the end of about an hour and a half of this, I gave up 20 in somewhat disgust and told them to send to me a letter 21 outlining NRC correspondence that they had on this issue, the
()
22 NRC letters that said that their report was approved, and so 23
- forth, Because during this period of time, they were undergoing i
24 model changes on the small break model.
Ace.Feded Reporters, Inc.
25 And they claimed that all of this was negotiated with NRC
7 36 I
and that they were'all done and NRC was happy with it.
So why 2
was I raising any question?
So they agreed on the phone to 3
send us a letter indicating the history of this correspondence.
/
4 And I also said, " Indicate your correspondence and send a 5
copy of all of it."
6 That never was received by TVA.
We never received it.
7 In addition, at the time of the telephone conversation, I 8
told them, "I still don't believe you understand what I am 9
trying to say.
I will try to consdense it down to one page 10 so at least you will read that.
And I will send it to you by 11 telecopy."
12 I sent that to B&W by telecopy, as I recall, on the 10th of 13 December.
And I believe a copy of that is in the transcript.
(}
14 That was an attempt to condense down to one page my problem.
15 But the agreement on the phone at the time and which was 16 documented in various, people's notes was that they were to j
17 reply concerning their URC negotiation and approval.
18 As a result of that telephone conversation, they promised 19 by the end of the year to transfer a letter.
20 The answer didn't come.
We bugged ther a couple of times.
21 They finally said it was one somebody's desk again.
And about
(}
22 January 23, 1979, the first reply arrived.
23 G
Now, just clarify a point, they said they would 24 provide you a letter, including their correspondence with the (ce-F w wo a ne n m. uw.
25 NRC?
l l
I i
s 37 1
A Yes.
2 G
Then, that they would provide a response by the 3
first of the year?
O 4
A Yes.
5 G
Is this response to be something separate from the 6
letter describing the correspondence with the NRC?
Were there 1
7 two separate pieces of correspondence?
8 A
No.
It was my anticipation that they would send me 9
a letter describing their correspondence with the NRC, and that 10 it was my intention really to give up on B&W and go back and 11 review the document that they had established with NRC on this 12 subject.
And maybe there was new material that was brought to
()
13 light in the docket or whatever that would lead me to believe, 14 yes, the problem is now cured.
15 Because I had none of this material in front of me.
This 16 was all going on since the material that I had available to end #2 17 revie 18 G
Did yoa understand in addition to that letter, they 19 would also even.tually provide to you an analysis of your report?
l 20 A
The agreement on it at the time of the telephone 21 conversation would be that I would look at their docket with
()
22 the NRC and that that would be enough for them.
That was the 23 agreement.
I was willing to forego worrying about the old 24 letter if I could satisfy myself that they had really covered Ace Federet Coporters, Inc.
25 the problem.
Because their claim was that they had covered all
38 1
my concerns with the NRC.
And I didn't really believe it, but 2
I had tu see it and review it.
That would have put it to bed 3
except it didn't arrive.
4 Instead, the letter that did arrive was one that attempted 5
to go back and address the letter of April 27.
Unfortunately, 6
the telephone conversation was documented in terms of a letter 7
agreement or anything, but we have gone back, and it is in at 8
least three different people's notebooks.
They had written 9
down what they were hearing.
And in all cases,,that was --
10 there was a check.
So that was the history up to that point.
11 The purpose now of sending the December 10 one-pager was to 12 be real sure now they did understand what I was trying to say.
(
13 And I attempted to put it down in a form that maybe they would 14 read.
Because I wasn't convinced they had ever read the report.,
15 So then, I waited to see what kind of reply I would get, 16 recognizing that it cbuld be either what they said they would 17 send us -- namely, their correspondence file and description i
i 18 for the NRC docket -- or perhaps an answer to the original 19 letter.
20 It turned out they attempted to answer the original letter 21 and made no mention whatsoever of any real tangible approval 22 or negotiation with NRC on such points.
So I had a little 23 problem then of trying to decide what to do next.
24 But the first thing that was apparent was I did not under-Ace Federd Reporters, Inc.
25 stand their letter.
And there was a particular technical point
39 1
which I didn't understand concerning a concept of volume balance 2
that B&W uses that other vendors at ler.st don't appear to use.
3 It seemed to be somewhat contrary to physical law, since I 4
generally am only concerned with mass and energy and not volume.
5 So their concept gave me a little difficulty, because it 6
seemed to lead to contradictory conclusions in their letter 7
or contradictory statements at least in their letter.
So I 8
sent a letter back on February 8 asking them to clear this 9
point up.
10 That was not to have been interpreted and was certainly was 11 not intended to be an indication that the only issue left was 12 I didn't understand volume balance.
That was far from the
()
13 case.
It was just simply a matter that we had to clarify the 14 technical grounds before we could get into a dicussion of the 15 variety or acceptability of their approach versus some of my 16 concerns.
17 So the letter of February 8 or 9 -- I don' t recall the l
18 exact date.
19 BY MR. FOLSOM 20 Q.
8.
21 A
February 8, okay.
O)
(_
22 The letter of February 8, then, was to be replied to by 23 March 15.
When March 15 came along, they asked for an extension 24 to April 1st.
Three Mile Island came inbetween, so they
' Ace.Federd Reporters, its.
25 finally replied to my letter on May 23 or thereabouts in which i
- 40 1
letter they included their description of how they considered 2
my concerns for the 177 fuel assembly plant.
This was a part 3
of a document prepared for NRC in response to TMI problems.
4 That description, of course, did not relate to my concerns 5
for small breaks on'205 plants which have distinct physical 6
differences and have to be analyzed separately.
So we sent the 7
letter back.
8 And let's go off the record for a minute now.
9 (Discussion off the record.)
10 THE WITNESS:
We can go back on the record.
I1 One slight correction I should indicate is that the' letter 12 from B&W was May 29, 1979.
This letter did not deal with the 13 205 fuel assembly plant.
And we sent a letter to B&W on 14 July 9, 1979, pointing this out.
15 On July 19, 1979, B&W answered our letter cif July 9, indi-16 cating they thought they were all done with the analytical 17 work.
TVA wrote a letter to B&W August 22, 1979, pointing out 18 that they weren't all done with the work.
19 BY MR. HEBDON:
20 0
So to this date, have you ever received from B&W 21 what you consider to be a satisfactory response to.the concerns l
22 you raised in your report?
23 A.
No, we have not.
And this was so pointed out in j
24 the August 22, 1979, letter.
IAce Federnt Reporters, Inc.
25 0
What do you feel has been the deviciency in the l
41 1
material they submitted to you to date?
2 A
The scope of what they submitted is, in our opinion, i
3 adequate.
It just does not relate to a 205 fuel assembly plant,
4 And it is necessary to look at a 205 plant, because it involves 5
a high steam generator.
And it involves auxiliary feedwater 6
coming in as a flooding function, instead of a spraying function.
7 And these were two principal points brought out in the report 8
which certainly have to be addressed.
9 O
Do you feel that the material they have submitted 10 to you to date satisfactorily responds to your concerns with 11 respect to the 177 plant?
12 A
I had no predetermined concerns on the 177 plant.
O(_e 13 We bought a 205 plant.
It was the only type that I had ever 14 examined in any detail.
15 G
The reason that I am asking, I think is very obvious.
16 TMI, if I am not mist'aken, is a 177 plant.
And so for your 17 plant to have been applicable to the TMI accident, your concerns 18 would have had to be either applicable to the 177s or trans-19 lated to the 177 plant.
20 A
Yes.
Translated, I think, is'probably the correct 21 term, indicating that you have to do a similar type analysis 22 for the 205 plants, using similar techniques, but getting 23 somewhat different answers.
24 G
You mean for the 177 plant?
- Ace-Federst Reporters, Inc.
25 A
For the 205 plant.
It will be different than for
42 1
the 177.
2 G
Now, as I understand it, they did provide you some 3
sort of analysis for the 177 olant.
4 A
That is correct.
5 Q
Did that analysis resolve your concerns for it, or 6
did they resolve your concerns as they would be translated to 7
apply to the 177 plant?
8 A
Yes, I think that the work that was done by B&W 9
and reported in May of '77 indicated that they were starting 10 to think about the small break problem in a correct perspective,
11 but certainly did not indicate they were all done thinking 12 about the problem.
And, of course, we know now there was
()
13 considerably more to the problem than we had first thought.
14 Eut in terms of May of '77 time frame, it appeared that they 15 did a very careful and honest job of trying to examine the I
16 small breaks, keeping in mind the kinds of things that I pointed 17 out in my own report.
18 G
If the analysis that had been provided, if the 19 analysis that was provided to you in May of '79 had been provided 1
20 to you before the accident at TMI, would you still have concerns, 21 would you still have felt that your concerns were applicable
)
22 to the 177 designs?
1 23 A
Uell, it is necessary now to go back and understand l
24 the difference between a 205 and a 177 plant.
One of the Ace Federal Reporters, Inc.
25 principal differences is the auxiliary feedwater which comes
43 1
in at the bottom of the steam generator.
In order for the 2
steam generator to become a condensor, it is necessary to 3
drain the fluid from the tube side of the steam generator down O
4 to the auxiliary feedwater level on the secondary side.
This 5
was pointed out in my report, alor:g with calculations that show it takes anywhere from a few minutes to an hour to do this c 6
7 depending upon the particular break size.
That does not appear to be a major consideration for 177 8
9 plants, since they spray at the top of the steam generatur.-
10 And it doesn't take very long then to drain.
11 I have never really gone into their model to see if they 12 even accounted for the drain downtime, because it would not be
()
13 a major consideration in their case.
It is a major consideration 1,1 for 205.
And it has got t somehow be accounted for in tne 15 model.
16 When they answer our problem and give us the report that 17 shows how they modeled it, I will review it and see that it has 18 been taken care of.
l 19 So there is one example of the difference that you just 20 can't generalize.
But in all due honesty, I feel they under-21 stand the concerns.
And I am confident when they get around (3
(/
22 to addressing the 205 plants, they will appropriately consider 23 it.
24 G
The point I am trying to make is that Three Mile Ace Federst Reporters, Inc.
t 25 Island is a 177 plant.
And the quertion then becomes, if the l
44 1
l 1
feedwater comes in high in the 177 plant, is the report or is the analysis that you performed and the concerns that you 2
3 raised applicable to TMI?
4 A
I think it is important to understand, and I am 5
sure most people understand, the fact that my report deals 6
with problems of small breaks on 205 plants.
The problems 7
of small breaks on 177 plants might be considerably different, 8
and I wouldn't want to claim that the 205 plant description 9
in any way predescribed what happened at TMI.
I don't think 10 anybody has ever made that claim relative to the small break 11 analysis.
12 Now, relative to level indications, yes, the same problem
)
13 as existed on TMI exists on the 205 plant, but not in the area j
1 14 of small break analysis.
15 G
I realize this next question is going to require 16 some speculation, but if B&W had performed a very extensive
]
1 17 analysis, if they had looked at your report and done everything 18 that you reasonably could have expected that they would do, 19 do you think that they would have identi' icd concerns and been 20 able to resolve them in such a way that it would have had any 21 significant impact on the TMI accident?
22 A
As far as small break analysis, no, I don't think 23 it would have.
Their analysis would not have had any major e
24 impact on TMI.
' A>Federst Reporters, Inc.
25 g
Why is that?
45 1
A The reason again is because my analysis ~ dealt with 2
problems of small breaks as they applied to 205 plants.:
It is 3
a different kind of problem on the 1773.
The crux of the TMI 4
problem was not in the analysis necessarily, but rather in the 5
operational mode -- namely, the operator thinking in his own 6
mind that the level indication was an indication of the amount 7
of fluid in the system.
8 This has been brought out repeatedly in other testimony.
9 And it was attempted to be pinpointed in the section 4.6 of 10 my report.
You cannot use a level Indication as an indication 11 of the quantity of fluid in the system.
And if you do, it could 12 leave you with a partially dried out core.
That has nothing
()
13 to do with the small break analysis per se.
It was a spinoff 14 of having done the small break analysis and, namely, it was 15 one of those things that became apparent in the process of 16 trying to understand how small breaks behave.
17 But the small break analysis per se, I would think it had l
18 little or nothing to do, or would have little or nothing to do 19 with the outcome of TMI.
20 g
You prepared a response when you received the 21 letter from B&W, Did you include in that response a request
()
22 for the file material that you had understood they had agreed 23 to provide?
24 A
No.
I did not.
I at that time assumed that they Ace-Federet Reporters, Inc.
25 had gone back to the original problem of answering ny first i,
46 1
letter and that they had given up for some reason on the idea 2
that they were going to try to defend their position by pointing 3
out their negotiations with NRC.
4 I can indicate how I felt at that time.
I felt that even 5
during the telephone conversation December 4 that they were 6
telling me things that might not be quite the way it was.
I 7
am not, and I was not at that time, confident that they indeed 8
negotiated with NRC to the extent that they had tried to 9
indicate.
And I was not confident that the NRC had approved 10 those models.
11 I assumed, then, when nothing more was said about it, 12 that they had given up trying to use that as a possible attack
()
13 on the letter I had written.
14 Are you aware of some concerns that were raised 15 by Mr. Sabin or TVA relating to small break LOCAs, particularly 16 small break LOCAs wit'h tary slow depressurization rate?
17 A
Yes.
Ron Sabin worked for me during the time period 18 in which he raised these questions on Combustion.
Ile was 19 actually assigned to a task force of people that were put 20 together to design, do the preliminary design, of the Yellow 21 Creek plant.
So from time to time I would talk to him about 22 the kinds of problems that we ought to bring up with the vendor 23 and get clarified.
And small break at that time was one of 24 those problems.
- Ace-Feder"J Reporters, Inc.
25 G
What role did his concerns have in the report that
47 I
you prepared, or the reports that you prepared?
2 A
He had done some early discussing with Combustion 3
Engineering about their approach on small breaks.
So when I O
4 wrote the hand-written May '77 draft on Combustion, I had 5
talked to Ron to some extent about what he might have learned.
6 And after I completed the hand-written draft, I asked him 7
to prepare a number of questions about small breaks that we 8
would send to Combustion.
9 My idea at that time was not necessarily to tell Combustion 10 what I thought was happening was small breaks, because I felt 11 that would be perhaps coaching, so to speak.
So instead of 12 coaching them on the problem, I tried to formulate a number of
()
13 questions along with Mr. Sabin in which we tried to bring up 14 some of the salient features of this problem, but without 15 actually telling them what we were about.
16 0
Did you ever send these questions and concerns to 17 Combustion?
18 A
Yes, we did.
Those questions were sent to Combustion 19 Engineering on July 22, 1977.
And the reply was received from 20 Combustion on October 14, 1977.
21 0
Did the reply satisfactorily alleviate your concerns?
()
22 A
The reply satisfactorily answered the questions that 23 I had raised.
I had some discussions with some of the people 24 that worked for me at that time about our approach to small Ace Federd Reporters, Inc.
25 breaks.
The approach in the case of Combustion was to ask a
I I
48 1
number of questions rather than to come right out and tell them l
2 "Here is what we think is happening. What do you think?"
3 So it was apparent from our work with Comoustion that it O
4 was not being too succcessful in trying to really bring out the 5
problem.
So we decided at the time to handle this probler in 6
the future -- namely, with B&W -- by sending a report instead 7
of trying to send questions.
8 g
Did you send the report that you prepared to 9
Combustion Engineering?
10 A
No, we did not.
We did not send that report to 11 them at that time.
It was only very recently sent to them, 12 just to complete the record.
j
.()
13 g
Since the TMI accident?
14 A
That is right.
15 4
Have you ever seen a January 10, 1978, memo from 16 Tom Novak to the Readtor System Branch concerning loop seals 17 and the pressurizer?
18 A
Yes, I have.
19 g
When did you see that first?
20 A
I first got a copy of that memo after testifying 21 on the House Committee hearing of May 21, is my recollection.
(
22 BY MR. FOLSOM:
23 g
Of this year?
24 A
Of 1979, right.
At that time, my testimony was Ace Feder;l Reporters, Inc.
25 followed by the testimony of the NRC commissioners.
One question
49 1
asked of the commissioners was had NRC ever received any of 2
my material.
The answer was about to be given, as near as it appeared to 3
(/
4 be, no, they had not.
But at that point, Dr. Matson' inter-5 rupted and indicated to Commissioner Hendrie that some evidence 6
had come to light of late that indicated that perhaps the NRC 7
had received the material.
8 So between that testimony on Monday and the testimony on 9
Thursday of that same week, the NRC sent to Congressman Udall 10 a number of documents relating to this problem.
Among chose 11 documents was Novak's letter of January 10, 1978.
12 BY MR. HEBDON:
I) 13 g
So you have read Novak's letter?
U 14 A
Yes.
They sent me a copy at that time in case I 15 had not seen it.
And I read it when I received it.
l 16 G
How does Mr. Novak's letter relate to the concerns 17 that you raised in your report?
18 A
It relates only to, of course, the level indication 19 concerns.
And I thought in my reading of it, at least it 20 clearly indicated that the author of that memo understood the 21 possibility of supporting a water column in the pressurizer f
22 even with the hot leg containing steam only.
23 G
So then would it be fair to say that the author of l
24 that memo understood the concerns that you had with respect l ace FederLI Reporters, Inc.
25 to pressurizer level?
l l
50 1
A In my opinion, at least, I believe that the author 2
of that memo certainly understood the possibility of the 3
pressurizer containing water with the reactor coolant system
- 7. s L.)
4 otherwise empty.
5 MR. HEBDON:
Let's take a recess.
6 (Brief recess.)
7 BY MR. HEBDON:
8 G
Back on the record.
9 You mentioned earlier that you were aware of the questions 10 that Mr. Ebersole wrote concerning the Pebble Springs docket.
11 Do you know why he wrote those questions?
12 A
No, I don't really know why he wrote all of the pi q_J 13 questions.
I think I am knowledgeable of why he wrote at 14 least three or four of the questions.
15 g
Three or four?
16 A
Yes, I kno'w why he wrote three or four, because l
l l
17 they were areas we had discussed from time to time.
And this 18 was an opportunity to get them into the licensing arena.
19 G
Did you see the responses that were provided by
)
20 Portland General Electric?
21 A
Yes.
22 G
Did you feel that those responses were responsive 23 to the questions?
24 A
My own opinion was that they were not responsive Ace Feder;t Reporters, Inc.
25 to what I was concerned about, no.
51 1
g In what way were they not responsive?
2 A
I think it can best be characterized, the answer 3
at least can best be characterized, as being a hand-waving 4
operation in which they described two states of the system, 5
one state being natural circulation which I had no real doubt 6
would work, and the second state being a boiling condensing 7
which I had no real doubt would work.
8 My concerns were how you get from one to the other and 9
back again.
That was not a part of the answer.
10 0
Do you feel that that should have been a part of 11 the answer for the questions that were asked?
12 A
That is not real clear.
If the question was very 13 general, the answer was also general.
As I say, if there was
{~}
14 a real concern about the transition period, then perhaps it 15 should have been brought out more strongly in the question.
16 It would take a second round of questions, in other words, to 17 get that point clarified.
18 g
Did you point out to Mr. Ebersole that that parti-19 cular issue had not been addressed in the response?
20 A
My recollection of our conversations on the Pebble 21 Springs answers is pretty fuzzy.
I do recall discussing the
(
22 answer with them, but I don't recall how I might have pointed 23 out to them the difficulties I had with the answer.
24 G
Do you recall that one of the questions was involved Sce-Federal Reporters, Inc.
25 with this issue of the operator interpretation of pressurizer
52 1
level?
2 A
Yes, that was the second part of the Question No. 6.
3 G
Did you feel there was an adequate response to that O
4 question?
5 A
There was no response, as near as I could determine, 6
at least, given to that part of the question.
7 G
Did you point that out to Mr. Ebersole?
8 A
That, I don't recollect.
9 G
Do you recall if he was aware that that particular 10 question had not been answered?
11 A
No, I do not.
12 G
Do you have any speculation as to why that (l
13 question wasn't answered?
14 A
No, I guess I can't even speculate on why it 15 wasn't answered.
It was clearly asked.
I have a recollection 16 of Question No. 12 addressed to somewhat -- was a somewhat 17 similar question.
But it referred one, as I recall, back to 18 Question No. 6, which didn't contain the answer.
19 G
You mentioned in your letter to B&W that you felt 20 that these questions might be raised on the Bellefont docket.
21 Why did you feel that these questions might be raised in the
(
22 case of Bellefont?
23 A
Well, really, I already had, shall we say, prompted 24 the questions for Pebble Springs.
I certainly anticipated Ace Federot Reporters, Inc.
25 that it would be somehow asked again, because it was a very,
53 1
very important question, at least to my mind, for 205 plants.
2 And the next opportunity would pro'.bly be Bellefont.
3 G
But Bellefont was a TVA plant, wasn't it?
4 A
That's right.
5 g
You were not supposed to be, as I understand it, 6
consulting on matters that pertained to TVA plants; is that 7
correct?
8 A
Well, it should be pointed out very clearly here 9
that none of this individual negotiation with Mr. Ebersole 10 was necessarily as a consultant to ACRS.
11 G
Mr. Ebersole was a former TVA employee.
12 A
That's right.
(v) 13 0
Was it your understanding that he would be involved 14 with the review of the Bellefont plant, even though he had 15 been a former TVA employee?
16 A
I don't know if that question even came up at the 17 time.
But I can speculate on the answer.
And the answer was 18 he probably would not be invoired, because generally he 19 attempted to excuse himself from TVA matters, at least for 20 a period of time.
21 G
Well, if he would not be involved and you would not f
22 be involved, who would ask the question on Bellefont since you 23 were, as far as I have been able to identify from the record, 24 the only two people involved with this concern?
Ace Federal Reporters, Inc.
25 A
Well, I believe I explained to you earlier the
54 l
1 reason for pointing out the relationship between Pebble Springs 4
2 and Bellefont was to prompt the B&W company to give us a timely 3
reply.
I am not sure that I thought through how it would be O
4 brought up at the B&W docket time.
5 G
Okay.
Do you recall ever discussing these issues 6
or issues related to this concern about operator interpretation 7
of pressurizer level during a small break with Mr. Kelly or 8
a Mr. Dunn or any other employees of B&W7 9
A To my recollection, I have never discussed this 10 problem with anyone in B&W.
11 Q
Well, you had the --
12 A
Prior to TMI.
And pardon me.
Prior to the time
/
13 that we sent the report to B&W in April of 1978.
14 G
You discussed this matter with B&W.
You had at 15 least the one conference call we have already discussed.
16 A
Yes.
17 G
Do you know if Mr. Kelly and Mr. Dunn were involved 18 with that conference call?
19 A
Do you have the list of people that were in that 20 telephone conversation?
21 G
I don't, really.
(
22 We will find out here in just a minute if he was.
I 23 Why we don't go off the record for a minute.
24 (Discussion off the record.)
Am-FJed Reorwes, lm.
25
55 1
BY MR. HEBDON:
2 G
Let's go back on the record.
3 Could you tell us from the notes that you have who was
('
4 involved in the conference call about your report?
5 A
Yes.
For the B&W Company, Bob Lightle, Jim 6
McFarland --
7 g
What was Mr. Lightle's involvement?
8 A
Mr. Lightle is the equivalent of the project manager 9
type, at least.
end #3 10 g
All right.
Mr. McFarland.
11 A
Jim McFarland is also a project manager type.
12 Dennis Renner, Bob Jones, Lou Cartin --
j 13 g
Excuse me.
With each of these names, could you 14 give us just a brief description of what their involvement 15 was?
16 A
I do not know the background of Dennis Renner 17 Bob Jones, as I understood it, was the fellow who would be 18 assigned to answer my letter.
Lou Cartin, I do not know the 19 background.
And Henry Baily, I do not know the background.
20 Of f the record.
21 (Discussion off the record.)
(/
- s. j 22 BY MR. HEB DON :
23 g
Let me ask you that question again.
24 Due to our equipment problems with our Xerox machine, Q&FMerd Reponm, Inc.
I 25 would it be possible to make a copy of those notes that the
56 1
people took as a result of the conference call and forward 2
them to us at some later date?
3 A
Yes.
We can send a copy of three sets, I believe, 4
of three people that have made notes.
5 The reason I went back and looked these up, of course, was 6
to again refresh my own memory on what I had thought happened, 7
but was getting pretty fuzzy one.
8 MR. LA ROCHE:
Off the record.
9 (Discussion off the record. )
10 BY MR. HEBDON :
11 G
Back on the record.
12 Were you ever aware of the concerns that Mr. Kelly and
(,_)
13 Mr. Dunn had about this issue of pressurizer level indication 14 and operator interpretation?
15 A
I first becane aware of their concern when I read 16 the material that was ' submitted to the President's Commission.
17 G
This was not until after the TMI reaction?
18 A
That is correct.
19 G
Do you know of any other precursor event relevant 20 to the accident at TMI?
21 A
I don't really know of any other good examples of
(
22 situations approaching the TMI situation.
There have been a 23 large number of momentary or short-term relief valve openings.
24 There have been a number of feedwater transients that have
{ce Federal Reporters, Inc.
a 25 occurred that have led to significant shrinkaqs of the primary
57 I
system.
These are.quite well documented in the LER system.
2 I just ' don' t recollect at the moment, though, of any clearly 3
definable event that would say to me that this is a precursor
(_)
4 of TMI other than the Davis-Bessie event.
5 G
Do you have any other additional information that 6
might be relevant to our inquiry into the events surrounding 7
the accident at TMI?
8 A.
Before you go to that question, let me point out 9
one other event which I have only looked at recently and am, 10 therefore, not well familia:7 with yet which in some respects II is indicative of the TMI situation.
And that is the Rancho Secc '
12 event which occurred.
I do not recall even the date at the qQ 13 moment.
I4 But it was the case where the indicator lightbulb was 15 dropped into the socket and caused a loss of a large amount 16 of nonessential instrtimentation which then led to operator 17 doing the best he could, but getting the plant into some degree 18 of difficulty before it finally was able to get out.
19 G
Why do you perceive that to be a precursor of the 20 Three Mile Island?
21 A.
I again preempted my remarks by saying I am still 22 looking.
It wasn't a precursor of what happened in the same 23 way at Three Mile Island, but it is a very good example of the 24 kinds of difficulties that a pressurized water reactor can get W Federst Reporters, Inc.
into if you lose a portion of the instrumentation, including 25
58 1
difficulties associated with how the operator can respond.
2 It fortunately was terminated before the plant got into 3
very serious difficulty.
But it certainly is a case that needs
(,,)
4 to be carefully scrutinized.
And I am trying to do that when 5
I have time.
6 G
All right.
7 BY MR. FOLSOM:
8 G
Your response gives me an opening to ask a question 9
that has been buzzing around in my head.
What affirmative 10 prescription for operator behavior do you have in mind for the 11 small, or did you have in mind for the small break LOCA 12 situation?
M ik )i 13 A
I really had not thought through operator procedure s
14 when I did the small break work.
I did recognize, though, 15 that the understanding was needed of how the breaks behaved 16 before one could reasdnably formulate operating procedures 17 and attempted to point this out in the report and in the letter 18 to B&W.
But I had not made any attempt to think about how to 19 prescribe the procedures, because first of all, it was 20 necessary.to establish whether or not I was even on the right 21 track thinking about the event.
22 If it turned out that I was on the right track, then you 23 had reached the point where you would have to start prescribing j
\\
24 procedures to get out of it.
'Am FMus1 Reponus, tnc.
25 G
Assuming you were on the right track, and maybe that
1 59 1
is a safe assumption now --
2 A
Now, I did speculate quite a bit about the level 3
indication problem.
I did some of the speculation with some 4
of the fellows that worked for me to try to see was there 5
any simple fix of the problem with the loop seal in the case 6
of B&W.
We considered the possibilities of bending the 7
pressurizer to various other high points in the system in order 8
to attempt to equalize pressures so that the pressurizer level 9
would more closely follow the level conditions in the balance 10 of the system.
11 We never really came up with anything that looked like a 12 good fix.
But we didn' t try very hard, either, because dl 13 basically, we were concerned, first of all, with resolving 14 small break behavior and then, depending on the resolution, 15 we would decide what kind of fixes were needed.
16 G
When you are saying you concentrated on the behavior 17 of the plant -- and I am asking, as I think you understood, i
18 my question was about behavior of the operator, people in the 19 control room.
What do they do?
Did you have any fix for them 20 in the prescription?
21 A
I think what you are alluding to 'is what to do about t'3 22 the possible confusion that they may face.
No.
Other than t J 23 to recognize that a confusing picture would exist with them.
24 And as I recall, I pointed this out in the report.
That bFederd Reporters, Inc.
25 is as far as I went on it.
60 1
1 G
Do you have any suggestions in hindsight now?
2 A
I really haven' t sat down to think about it in that
)
3 respect yet, no.
No.
('#,_ )
4 BY MR. HEBDON :
5 g
What was your perception of the degree of reliance 6
by the operator on pressurizer level indication?
7 A
I had some interest in that question.
And for that 8
purpose at the time I was doing the work on the small breaks 9
in the summer of ' 77, I discussed this a little bit with Jesse 10 Ebersole.
And he managed to got for me some operating Il procedures from a plant in the East.
And I think it was Surrey.
12 My interest was particularly in how the operators respond P
13 to possibly trying to isolate these small breaks or closing 14 relief valves or whatever.
15 I did find, of course, in examining the procedure, that 16 one of the standing instructions was to isolate the break, if 17 you could figure out where it was.
This bothered me a little 18 bit.
And in the report I also pointed out now there could be 19 some concern with a standing instruction to isolate a break l
20 whea the break behavior was not well understood.
It could 21 potentially put the plant in an even worse condition that it l'O i
\\J 22 already was in.
So that was about the extent, though, of t
23 trying to examine in detail the operating procedures.
24 I read those particular ones just to get a flavor for how 4ceJederal Reporters, Inc.
25 PWRs typically handle the loss of reactor core accident.
61 1
G Did you get a perception from th "u3 procedures that 2
the operators were placing a heavy reliance on pressurizer 3
level indication?
4 A
I really did not recall pursuing that particolar -
5 point when examining the procedures.
6 G
Do you have any additional information that might 7
be relevant to our inquiry into the events surrounding the 8
accident at TMI?
9 A
I guess I would have to know a -- that is a pretty 10 broad-gauged question.
I don't mind volunteering anything II that I can think of.
But, unfortunately, though, I am not 12 sure -- if you can suggest some areas that you might have in I
13 mind or something, it might be helpful.
14 G
I don't think we really have any particular areas 15 in mind.
16 The next question that follows that is really the same type 17 of question.
Iave we failed to elicit any information that 18 you believe to be important?
Is there anything that you know 19 of that you feel we ought to know about that we haven' t asked 20 you about?
21 A
That is a good question, because it is the first
~
t' )
(_]
22 time it has been asked.
So I certainly would volunteer 23 anything that I thought was relevant.
24 In general, I believe the depositions that I have been hFederal Reporters, Inc.
25 through so far, and this one, have been rather comprehensive.
62 1
And I certainly have attempted to allude to all of the things 2
that I can think of that might be pertinent.
3 MR.
' ROCHE :
You have access to all those, 0
4 the President's Commission depositions and --
5
.-IR. HEBDON:
Yes, we do.
6 MR. LA ROCHE :
You talked earlier with someone else 7
at the NRC.
Who was that?
8 THE WITNESS:
You have, I am sure, the I&E 9
inspection report.
10 BY MR. HEBDON:
11 G
Yes.
12 A
No, I have nothing to hide.
I tried to tell it as 13 I see it.
And I would certainly volunteer any information 14 that I thought might be at all pertinent.
I don't recollect 15 anything at all.
16 g
All right.
17 Do you have any additional questions?
18 MR. COX:
No.
19 MR. HEBDON:
Do you?
20 MR. FOLSOM:
No.
21 MR. LA ROCHE:
Let me ask a question.
You are 4
22 going to provide transcript to us for him to review and make 23 corrections ?
24 MR. HEBDON:
Yes.
Ace Federal Reporters, Inc.
25 MR. LA ROCHE:
Last time, I tried to make it clear l
l
63 i
?
rmg 61 1
in the President's Commission, send me the contract, and I would i
2 get it done.
As it was, they sent it to him, and it took two 3
weeks to where it was.
And there was some delay.
It would
[)
4 be much better if you send it to the Office of the General 5
Counsel at TVA.
6 MR. HEBOON:
If you could give me your full name 7
and mailing address, I will make sure it goes to you directly.
8 MR. LA ROCHE:
Okay.
It should go to Herbert S.
9 Sanger, Jr.,
General Counsel.
10 THE WITNESS:
They like to do things formally.
11 MR. LA ROCHE:
400 Commerce Avenue.
And that is 12 TVA, Knoxville, Tennessee, 37901.
h
~
13 MR. HEB DON :
All right, fine.
14 We will send that to you.
15 MR. LA ROCHE :
And we will get everything to you.
16 That is the easiest way to get through quickly.
17 MR. HEBDON :
All right 18 Do you have anything else you want to say?
19 THE WITNESS:
No, I dun't believe so.
20 MR. HEBDON:
Okay, that completes the interview.
21 Thank you very much.
22 (Whereupon, at 1:07 p.m.,
the interview was 23 completed.)
l 24
$D-FederJ Reporters, Inc.
25