ML19308C517

Deposition of Eg Ward (B&W) on 791017 in Lynchburg,Va.Pp 1-38

ML19308C517
Person / Time
Site:	Crane
Issue date:	10/17/1979
From:	Dienelt J, Ward E BABCOCK & WILCOX CO., NRC - NRC THREE MILE ISLAND TASK FORCE
To:
References
TASK-TF, TASK-TMR NUDOCS 8001280516
Download: ML19308C517 (39)

Text

{{#Wiki_filter:. _ _ o 1-Q c,, O ] N U CLE A R R E G U L ATO R'( COMMISSION I IN THE MATTER OF: NRC/TMI SPECIAL INQUIRY GROUP DEPOSITION OF EDWIN GRANT WARD Place - Lynchburg, Virginia Date - Wednesday,17 October 1979 Pages 1 - 38 l Telephone: (202)347-3700 ACE -FEDERAL REPORTERS,INC. 8 0 01280 o j& ~av"~ c J< l ,@)j l 444 Nonh Capitol Street d,dk l$)UUh5 j* f~ Washington, D.C. 20001 NATIONWIDE COVERAGE. DAILY 1. b-( 4 e' d 4

1 "/ f ?C# i dspl I UNITED STATES OF AMERICA ( )1 2 NUCLEAR REGULATORY COMMISSION 3 .x () 4 In the Matter of: 5 NRC/TMI SPECIAL INQUIRY GROUP 6 ___________________x 7 8 Offices of Babcock & Wilcox 3515 Old Forest Road 9 Lynchburg, Virginia 17 October 1979 to 8:45 a.m. 11 12 DEPOSITION OF EDWIN GRANT WARD Id BEFORE: 15 JOHN DIENELT, Esq. HAROLD ORNSTEIN 16 PRESENT: 17 GEORGE EDGAR, Esq., on behalf of the Deponent 18 ALSO PRESENT: 19 CARLA D'ARISTA, NRC Staff 20 21 22 23 c. .i Reporters, i. 25 l M% g -

l i i ( 2 I i i i I dsp2 C,O_ N T_.E_ N_ T_ S_ [ 2 Exhibit: Identified 3119 5 l 4 I .i 5 i 1 6 7 l t l 8 f 9 l 10 3 I i 11 12 i i 13 l 14 ? i 15 i P 16 17 l. 18 19 } l 20 i l 21 i-I. 23 1 9si neponm. inc. 24 hee.F 25 y n s i,, 5 f 7 '

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3 l dep3 i 1 PROCEEDINGS i I l (]) 2 Whereupon, 3 EDWIN GRANT WARD () 4 was called as a witness, and having been first duly sworn, 5 was examined and testified as follows: 6 EXAMINATION 7 BY MR. DIENELT: 8 Q Would you state your name and business address? 9 A My name is Edwin Grant Ward; business address is 10 P. O. Box 1260, Lynchburg, Virginia. II Q Have you had an opportunity to review Exhibit 310l? 12 A Yes, I have. 13 Q Do you understand it? 14 A I believe so. 15 Q The testimony you give today has the same effect s 16 as if you were in a court. You will have an opportunity to 17 review the transcript of your deposition. If you make any 18 vhanges in the transcript which are of a substantial nature, 19 as opposed to changes of typographical error or corrections, 20 of misunderstanding in what your testimony had been; those 21 changes could be viewed as affecting'your credibility. 22 So, it is important for you to understand the Os 23 question and give as full and complete an answer, today, as (~ 24 Ac.4 s)a n. con.<s, Inc.you can. 25 If you don't understand a'. question, please let me 1 1 ..~

l 4 dsp4 1 know and I will rephrase it or try to clarify. 2 Also, if you will allow me to finish a question, ) 3 even though you know what the thrust of the question is, before 4 you give your answer; that will allow the court reporter in (]} 5 getting a full transcript. 6 You have testified previously in a deposition before 7 the President's Commission. Is that correct? 8 A That is correct. 9 Q Have you had an opportunity to review the transcript 10 of that deposition? 11 A I have. 12 Q Did you prepare an arrata sheet or make any changes 13 in the transcript? 14 A Yes, I did prepare an errata sheet. 15 MR. DIENELT: I would like to request a copy of that. 16 MR. EDGAR: We'll provide that. 17 BY MR. DIENELT: 18 Q Did you make any changes in the transcript, which 19 in your view, affect the substance or meaning of what you 20 said? 21 A None. 22 Q Have you given any other sworn testimony in connection 23 with the Three Mile Island incident? 24 A No, sir. Ace-F i Reporters, Inc. 25 Q Am.I correct that you have not been interviewed by 5

5 .\\ l I dsp5 the Office of Inspection and Enforcement of the NRC in connection i O 2 with the incidene2 3 A I have not. 4 Q Have you been interviewed by any other person with 5 respect to the incident when the interview was taped or 6 transcribed? 7 A No, sir. 8 Q You have furnished me with a copy of your resume 9 and that has been marked as Exhibit 3119. I would just like 10 you to identify that exhibit for the record as your resume. A Yes, it is. 12 (Ward Deposition Exhibit 3119 13 was marked for identification. ) 14 Q Is the resume accurate and up to date? A Yes, it is. 16 Q For the record, will you state your current position 17 and briefly summarize the responsibilities that you have? 18 A My current position is senior project manager, and 19 as such, I have the responsibility for the project management 0 activities related to two projects, at present. 21 One. of. them being the Washington Public Power 22 Service System, Units WNP-1 and 2; and the Portland General 23 Electric Pebble Springs Nuclear Project. 24 I still have some residual ~ duties remaining on the el Eeporters. Inc. Ace-25 Three Mile Island 2 project. I i s

6 dsp6 1 Q On March 28, were you the senior project manager () 2 for Three Mile Island Unit 27 i 1 3 A That is correct. 4 Q Since March 28, has there been another senior 5 project manager for Unit 2 designated? 6 A Not a senior project manager; however, a special 7 recovery project was organized under Mr. George Kulynych as 8 leader. 9 Q On March 28, were you the senior project manager for 10 Three Mile Island Unit l? II A No, sir. After a unit has been declared commercial 12 and accepted, it is our practice, here, to transfer responsibilitie@ {~} from the project management department to the nuclear service 13 14 department. 15 The project manager no longer has the responsibility, 16 but a service manager does. 17 Q Who was the service manager for Unit l? 18 A The service manager for Unit 1 is Tom Fairburn. 19 Q Were you the senior project manager for Unit 1, when 20 there was a senior project manager? 21 A Yes. Prior -- prior to it's being turned over to (~T 22 the nuclear services. LJ 23 0 When was it turned over? 9 erd Rmorars, lm. 24 A In the spring of -- I believe, in the spring of 1975. AwF 25 Q During the period beginning on March 28, did you

7 dsp7 I maintain a log or a diary of your activities? O 2 ^ r1eese ser ehe-esein. 3 Q During the period beginning on March 28, 1979,.did 4 you personally maintain a log or a diary or other running O 5 account of your activities? 6 A Yes, I did maintain a very rough log of telephone 7 calls and other activities for the period of about two weeks 8 following March 28. 9 Q Did you retain that log? 10 A Yes, I do have that. MR. DIENELT: I would like to ask for a copy of that. I2 MR EDGAR: All right, we'11 provide that. 13 BY MR. DIENELT: I4 Q Subsequent to March 28, did you prepsre any memorandun 15 or other document summarizing the activities in which you 16 engaged, other than the log that you just testified about? I7 A The only thing would be that from that log, I did 18 prepare a listing of the telephone calls; a very brief listing I9 of the telephone calls and subject matter taken from the log. 20 MR. DIENELT: I would also like to request that. 2I MR. EDGAR: Yes. That's a phone call list? 22 THE WITNESS: Yes. 23 BY MR. DIENELT: 24 q Q Does either the log or the phone call list or both, ,Acedvd Roporters, Inc. 25 reflect the persons to whom you spoke? I

8 I A The telphone call list does. I should add, however, O 2 this is not my personal log. This is a 1 g that -- there were 3 actually four of us at one time or another that carried on O 4 converseesons ehee ere recorded in this 1oe, four geoe1e-5 MR. EDGAR: Could you explain that in the context of 6 the recovery shift operation; give them some sense of that? 7 THE WITNESS: Yes. Starting on the 29th, one of 8 the activities which we participated in was a project management 9 activity wherein myself; Mr. W. A. Cobb; Mr. L. R. Pletke; 10 and in one instance, Mr. R. R. Steinke; participated in II covering communications which are included in this log and 12

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te i 13 MR. ECGAR: The log was filled out by the man who 14 was on shift at the time? 15 THE WITNESS: That is correct. 10 BY MR. DIENELT: 17 Q Was the telephone list -- strike that -- does the 18 telephone call list list calls made by all four of you, or only 19 by you? 20 A All four. 21 Q Do you know whether other logs were maintained by 22 counterpart organizations within the recovery organization at 23 B&W7 f) 24 A I don't understand that. wa n n.,,.,ne. 25 Q Let me show you Exhibit 3115, which is an organization m

9 dop9 1 chart reflecting, as I understand it, the recovery organization i l () 2 as it existed at one point in time. 3 Are you familiar with this chart, or with charts () 4 similar with this? 5 A I am. 6 Q This chart indicates you, Mr. Cobb, and Mr. Steinke 7 in a box labelled project manager. 8 A Right. 9 Q And you've testifiec that the the three of you, plus 10 one other person, maintained a record of your telephone 11 communications. 12 My question is whether you know whether similar logs 13 were kept by licensing, engineering, operations manager, and/or 14 service manager during the period of the recovery? 15 A I believe there were logs maintained in the 16 project control center of the communications, between the Three 17 Mile Island site and that control center. 18 Whether or nor each of these other groups, as you 19 indicate; licensing, or the service manager had separate logs, 20 I do not know. 21 MR. DIENELT: Let me just request that if there are 22 separate logs similar to ths one that Mr. Ward has described ) 23 that we would like to have access to them as well. (~} 24 I am well aware of the large general communications Ace 4uW Reporters, Inc. 25 record. Of" course, I already have that. ~ g-e .I y

10 dsp10 1 MR. EDGAR: We'll endeavor to see what, if any, logs O 2 were eexe - ore ene recora for e =ome=t-3 (Discussion off the record.) O 4 er MR. DIENEtr= 5 Q Directing your attention to Exhibit 3104, are you 6 familiar with that document? 7 A Yes, I am. 8 Q Have you reviewed that document? 9 A Very briefly. 10 0 During your review, did you not any inaccuracies in II the document, particularly as it may relate to your activities? 12 A I did not. 13 Q Directing your attention to Exhibits 3105 - 3110, O Id which are volumes of the general communications record, are l 15 you familiar with those documents? j I0 (Witness reviewing document.) 17 A I recognize the general communications records were 18 being made during the recovery period. I have never reviewed I' any of these records, nor seen thein before. 20 Q Did you have any responsibility with respect to the 21 maintenance of those records? 22 A Not of these records. l 23 Q Were you involved in the determination to maintain i 24 %,O a record? el Rowcors, Inc. v 25 A Not personally. j l a

11 depil j (Pause.) 2 Q How did you learn about the TMI incident? 3 A From a telephone call from Mr. W. H. Spangler sometime O prior to 8:00 a.m. on March 28th. 5 0 At that time, what did you understand to be the 6 nature of the problem? 7 A That the unit had suffered a severe transient. The 8 reactor had tripped; the turbine had tripped. 9 The major concern expressed was that in addition 10 to what, otherwise night have been a normal transient, there II was indication of radioactivity in the containment. 12 Q After your phone call with Mr. Spangler, what did O rou ao2 A I alerted Mr. J. C. Deddens, my supervisor. And -- 15 Q What -- excuse me -- go ahead. 16 A Also advised him that a meeting had been scheduled 17 for approximately 9:00 a.m. and that to consider this report in 18 further detail. I' Q Did you describe what you understood to be the 20 nature of the problem to Mr. Spangler during your notification 21 to him? Excuse me, Mr. Deddens? O '2 A Yes, I explained to Mr. Deddens the.few facts that 23 had been passed along concerning the occurrence. Q 24 Q Specifically, did you advise him'of the radioactivity Am4,, M Reporters, Inc. 5 in the containment?

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12 dsp12 1 A I did. 2 Q Did you attend the 9:00 meeting? () 3 A I did. 4 Q Did you do anything else between the 8:00 phone () 5 call or roughly 8:00 phone call with Mr. Spangler and the 9:00 6 meeting related to the TMI incident? 7 (Pause.) 8 A I don't recall that I did anything other than, perhaps, 9 have conversations with other people that I have no record of. 10 0 Do you recall approximately how many people were 11 at the 9:00 meeting? 12 A I'm not sure whether Wandling's memo describes how 13 many were at that meeting or not. If I were estimating, I O 14 would say, 15 or 20. 15 Q During prior depositions, a number of different 16 individuals have been identified as having been present at the 17 meeting. I am going to ask you if you are aware of any others 18 who are present, and also, as I go over this list, if there 19 are any on the list whom you are certain were not present, I l f 20 would appreciate your telling me. 21 Mr. Roy; Mr. Spangler; Mr. Karrasch; Mr. La Belle; 22 Mr. Deddens; Mr. Winks; Mr. Womack; Mr. Kelly; Mr. Elliott; O( / 23 Mr. Dunn; Mr. Olds; Mr. Hallman; Mr. Walters, and possibly 24 Mr. Telenko. Do you recall any other persons who were present? Ac. 4ei n porters. Inc. 25 A Myself, and Mr. L. R. Pletke.

13 dspl3 I Q Are there any other persons on that list whom you 2 () 2 are certain were not present? 3 A Not that I'm certain of, no. () 4 MR. EDGAR: Of1' the record. 5 (Discussion off the record.) i 0 BY MR. DIENELT: 7 Q During the day of the 28th, what specific 8 responsibilities, if any, were you given in connection with l response to the TMI incident? 10 A I participated in setting up the project control 11 center; arranging for communication lines to be established in 12 that center. (} I initiated contact with the GPU office in Parsippany I# Other than that, my responsibilities were mainly, to participate in the discussions'and general activity that took place in the 16 project control center. I7 Q What did you do in assisting to establish the project 18 control center as the base of operations? 19 A Primarily recommending that be the place to establish 20 the control center _and secondly, to arrange for extra telephone 21 services to be installed. 22 (]} Q What was the telephone service which was in the 23 project control center at the time that you first moved into ~ Am+I )W Reorwrs. lm. it? 25 .There was one telephone. We wanted more telephones A. 2 . _. ~ _ m I L -g 3 4

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14 dspl4 1 and -- and arrangements for telecopy machines. () 2 Q Do you recall how many more telephones ~were installed? 3 A At least one additional phone. () 4 0 Was that installation during the day of the 28th? 5 A I don't believe it was completed that day, no. 6 Q At the time that you moved to the project control 7 center, was there more than one telephone line going out of the 8 project control center? 9 A Not at that early part of the -- not on the 28th, as 10 I recall. Il Q So that we understand each other, there were no 12 buttons on the phone indicating different extensions that could 13 be used. If you recall? 14 A The telephone in that room is not like that phone 15 you are pointing to. It is a special device that has speaker j 16 phone attachments and it does have extensions, but there just i 17 was -- just one conversation could take place at the beginning 18 of the day. 19 Q -But as you understood it, you could have somebody on 20 home and be conducting another conversation? 21 A Those kinds of things could be done, right. (g 22 Q When did you initiate contact with GPU in %/ 23 Parsippany? f~) 24 A Just after the 9:00 meeting. I called Mr. R. C. Cutler Am-LJ:1 Reporters, Inc. 25 with Mr. L. R. Pletke; that is the two of us called Mr. Cutler x-

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15 dsp15 I to advise him of our report from Three Mile Island and to O find out if he had any additional information on the occurrence. 3 As it turned out, he was not aware of the occurrence 4 at that time. C 5 0 Who is Mr. Cutler? 6 A Mr. Cutler is, I believe, an assistant project 7 manager in the GPU service corporation, who is our normal 8 contact. 9 Q What did Mr. Cutler say in response to the information 10 you gave him regarding the incident? II A That he intended to confirm the report we had and 12 find out if he could obtain any additional information regarding 13 the occurrence. O Id Q Did you have subsequent conversations on the 28th '15 with Mr. Cutler or with anybody else from GPU? 16 A Yes. Approximately 11:00, Mr. Cutler called back I7 to advise that he did indeed confirm the transient, generally, 18 as we had reported. I9 GPU planned to direct a few of their engineers to 20 the site to be of assistance. 21 Q Did you discuss your calls with Mr. Cutler with 22 anyone else at B & W in Lynchburg? 23 A Not that I recall. 24 Q Was Mr. Pletke involved in the second call with Ace ((7 ,Jd Reporters, Inc. 25 Mr. Cutler? l ( 5-

16 I A I believe he was. G 2 Q Did any of the information that you received from 3 Mr. Cutler during the second call change your view as to the O a nature or the seriousness of the transient? 5 A No, it did not. 6 Q After the 11:00 call, did you have other conversations 7 during the day with Mr. Cutler or others from GPU? O A No, sir. 9 Q During the day, did you have any telephone conversations 10 with anyone at or near the site? 11 A During the day, we were having conve.rsations from the 12 project control center to representatives at the site, which many people aprticipated in; and I did participate to a minor 14 extent in those conversations. 15 Q Do you recall any such conversations with anyone 16 other than Mr. Schaedel, or Mr. Rogers? A There were conversations with others. I didn't 18 participate in any of the other conversations other than 19 Mr. Rogers or Schaedel. 20 Q Apart from the call in the project control center 2I with Mr. Rogers and Mr. Schaedel, do I understand that you were 22 not involved in any telephone conversations with anyone at or 23 near the site on the 28th? 24 A That is correct. Am-F d Reporters, Inc. 25 0 Were you involved in any conversations on the 28th kM h

17 l dspl7 1 with anyone from NRC? I 2 A No, sir. ) 3 0 Were you involved in any conversations on the 28th (]) 4 with any official from the Commonwealth of Pennsylvania? 5 A No, sir. 6 0 were you involved in efforts to obtain a direct 7 line from the TMI control room to the project control center? 8 A I was aware of these efforts. I didn't personally 9 participate in those. 10 Q Did you have communications during the day of the 11 28th with the telephone company? 12 A No. With Miss Natalie Lampman, who is our person, 13 here, at Old Forest Road who does maintain contact with the O 14 telephone company. 15 0 What request or instructions dfd you give her? 16 A We required additional telephone communication and 17 telecopy service in the control center; and essentially, these 18 were the instructions. 19 Q Was it your understanding that she was -- or that 20 someone was making requests to the telephone company to assist 21 in obtaining a direct line or a dedicated line? 22 A I'm not aware of them. O 23 Q Do you recall any discussion in the project control 24 room during the day of the 28th, regarding the possibility or (c 4u neponen, sne. 25 the probability that the core was uncovered? (

18 dspl8 1 A I don't recall that discussion. A (_j 2 Q Do you recall any discussions of the possibility or 3 the probability or the fact of super heat in the core? ,-~ \\ 4 A Yes. We were aware, shortly -- excuse me, maybe I 5 should refer to Mr. Wandling's memo; however, shortly after 6 lunch, I recall having -- our having been advised of the 7 temperatures in the hot legs and they appeared to be super 8 heated. 9 Q Do you recall any discussion during the 28th, relating 10 to whether the strategy being followed at the site of attempting Il to depressurize the system was a correct strategy? 12 A As I recall, it was out belief that they should 13 not depressurize, but rather, add high pressure injection to 14 overcome this superheating condition which was evident. 15 Q Your.' understanding is that the high pressure 16 injection would be inconsistent with the strategy of l l 17 depressurization? l 18 A Yes. 19 Q And the viow that the HPI should be employed rather l 20 than an effort to depressurize was a view with respect to 21 which there was consensus, here, at B & W? 22 A I believe so. {} 23 Q Do you recall how early in the day of the 28th, the 24 view that high pressure injection should be initiated or Ace F al Reporters, Inc. 25 increased as a means of dealing with the transient was reached? ~ ~ ' q., -l,. Y'

19 dspl9 I I don't recall the exact time. I imagine this could A b 2 l be gleaned from Mr. Wandling's report, however. v 3 Were you involved in any efforts to communicate the 0 1 4 review regarding HPI to the site? O 5 A Other than being a participant in these group 6 conversations with Mr. Schaedel, no. 7 Q When, if at all, did you go home on the 28th? O (Pause.) 9 A Shortly after the 1-A reactor coolant pump was I started and running, I went home. This would have been 11 approximately 8:00 -- 8:00 p.m. 12 O Did you spend the bulk of that day between the time O y u went t the project control center and 8:00 -- did you 14 say p.m.? A (Nods in the affirmative.) 16 Q 8:00 p.m. in the project control center? A That is correct. l 18 Q Were you called back during the late evening of the 19 28th, or the very early morning of the 29th? 0 A I was not. 21 When did you come back, if you did, on the 29th? Q l 22 t] A At my normal coming to work time; which is 23 approximately 7:30. Ael Reporters, Inc. 24 Q Can you summarize the nature of your activities and ' Ace-25 responsibilities beginning on the 29th? j l e-

20 dsp20 1 (Pause.) () 2 A My responsibilities were generally to participate 3 and be of whatever assistance I could be, in further conduct () 4 of our support of the TMI 2 site. 5 No specific activity comes to mind. 6 Q Returning to Exhibit 3115, can you tell me when you 7 and others began to -- began to rotate shifts as project 8 manager? 9 A The shift rotation really started on the 29th, and l 10 my stay during the 29th was a 12 hour shift. I was relieved by II Mr. Pletke that first day, who stood another 12 hour shift. 12 This activity went on for a couple of days, then gg we added Mr. Cobb, such that we could have three shift coverage. 13 L) 14 So, really, shift coverage really started from the morning of 15 the 29th, although we didn't realize that at that time. 16 Q Can you explain the differences or the different 17 responsibilities that the project manager had as compared to 18 the engineering operations manager? 19 A The main line of communications were between the 20 operating managers and the engineering managers; and the site. 21 The project manager communications were primatily with the GPU 22 center in Parsippany and the Burns & Roe Center at their 23 offices in Oradell. f-} 24 Q Can you describe the general nature of the dealings Ace 4m JJ Moporters, Inc. 25 or communications that you, as project manager, had with GPU ~ ~ g 4

21 dsp21 1 beginning on the 29th? () 2 A We did not have very much communication on the 3 29th, as I recall, because they did not really have a center () 4 established as we did here. 5 However, later on, they did establish a center and 6 had it organized on around the clock coverage. Their center, 7 like our center and the center that Burns & Roe maintained, 8 Were all, as I View it, satellite supporting organizations to 9 the site where the primary activity was, of course, centered. 10 0 What kind of support? 11 A As people at the site would request information, the 12 assignments would be nade to one or the other of these 13 organizations. 14 In the course of carrying out an assignment, GPU 15 may need input from us; that is, they may want some information. 16 They would call us, and we would gather the information for 17 them; oh, an a raft of alternatives and data regarding 18 equipment; many facets of miscellaneous information, which 19 altogether was required to put togetLO

.eir support to the 20 site.

i 21 Q When a request form information was made, how was it 22 normally communicated to the project manager? 23 A By telephone, as a rule. 24 Q From what person or what position i. the organization? {^} , Am4J Reporters, Inc. l 25 A The people that managerd the GPU center were people l V O

22 dsp22 1 from their project management group; various members of the () 2 GPU service organization project management operation. 3 0 As project manager, you normally received requests 4 for information from or through GPU, as opposed to from or S through the engineering operations manager, here in Lynchburg? 6 A Yes. I would say we were an outside contact, as 7 opposed to an internal contact. If we would receive a request 8 for an activity that would require more than, you know, their 9 routine information; that is, if we required some actual 10 engineering activity, we would introduce that request into the 11 organization through the engineering operation manager. 12 In other words, we did not try to operate a separate 13 support activity. Rather, we worked through him to get the {} 14 work done. However, we were a communication link with the 15 GPU center, as well as the Burns & Roe Center. 16 Q Do you know whether requests for information or 17 guidance were made from the site to the engineering operations 18 managers? l 19 A Yes, theyewere. t 20 Q Do I understand that if a request was made directly 21 from the site, it would be -- it would have been made to the 22 engineering operations manager; whereas, if a request was made [ t' 23 from GPU in Parsippany, it would have been made to the project I (~ 24 manager? l Acada)d floporters, Inc. 25 A I would say that that is generally the case. There I +-

,4 7 3

23 dsp23 I were, undoubtedly, exceptions to this curing this period, but O 2 in general, we were maintaining the communication link between s_/ 3 Burns & Roe, and GPU in Parsippany. () 4 These people were maintaining communication with the 5 site. 6 Q Did yo.' receive requests for information from 7 Burns & Roe? 8 A A minor amount of requests from Burns & Roe. Most 9 of the time it was the other way around, with Burns & Roe. We 10 wanted information from them. II Q Who was the person or who were tna persons with 12 whom you, as project manager, primarily dealt at GPU? 13 A Mr. Clay Montgomery; Mr. R. C. Cutler; occasionally Id Mr. R. W. Heward, and others. 15 0 Who was the person or who were the persons with 16 whom you primarily dealt at Burns & Roe? 17 A In the beginning Mr. Cobean. Later on, with others 18 who were on a shift work established at Burns & Roe. One name 19 I recall was Scott Dam. There are others. I don't recall 20 the names right now. 21 Q Did you hav: any communications with the site on 22 the 29th or thereafter? 23 A I did have conversations through' the project () 24 control center, which maintained an open line. So there were Ace 4 W Reporters, Inc. I 25 conversations going on, you know, almost constantly.

24 dsp24 1 Q Were you a principal participant at any point in () 2 these conversations? 3 A Not a principal participant, I wouldn't say. ( 4 Q Were you-involved in dealing with the issue of 5 hydrogen bubble? 6 A Well, I was certainly aware of the concern of the 7 hydrogen bubble and had discussions concerning it with GPU in 8 Parsippany; and with our engineers, here, who were evaluating 9 that problem. 10 Q Can you describe the substance of the conversations 11 that you had with GPU regarding the hydrogen bubble? 12 (Pause.) 13 A The substance of the conversations were primarily, 14 what the best scheme was to reduce the size of the bubble; how 15 large the bubble was; comparing calculations; and calculating 16 procedures. Those kinds of concerns. 17 Q Was it your understanding that GPU in Parsippany was 18 making calculations regarding the size or the means of 19 dispersing the hydrogen bubble? 20 A They.were certainly concerned in all aspects of -- 21 of the problems identified at the site; and this certainly was 22 one of them. [} 23 Q Do you know specifically whether anyone at GPU in f') 24 Parsippany was making calculations? Ace 4.-.:d Reponen, Inc. 25 A I believe they were, but-I cannot give you anybody's c

25 dsp25 I name. O 2 Q Did you send eny ce1cu1eeiens which were done et 3 B & W to GPU in Parsippany? O 4 A I would have to refer to my log, but it does -- I 5 do recall that at one time we exchanged calculating procedures. 6 Q Were you aware that Mr. Nitti was doing calculations 7 regarding the bubble? 8 A Yes, I was. 9 Q Do you know when the earliest time he prepared any 10 calculations was? II A Not exactly. 12 Q Do you know whether your log would reflect that 13 information? Id A My log would reflect the first note thr.c I made 15 regarding the hydrogen bubble. Whether or not this would be 16 the first time Nitti prepared a calculation, I could not be I7 sure. 18 0 Who were the people at GPU with whom you discussed I9 the hydrogen bubble? 20 (Pausa.) 21 A I believe Mr. Montgomery. Off the record. 22 MR. DIENELT: Sure. 23 (Discussion off the record.) l Am&JJ Reporters,Inc. p 24 BY MR. DIENELT: 25 Q You talked to Mr. Montgomery and -- D

26 dsp26 1 A Courtney Smythe. 2 Q Was Mr. Smythe a person you had other conversations 3 with beginning on the 29th? O A Yes, he was. 5 Q Do you recall conveying a recommendation on behalf 6 of B & W regarding the hydrogen bubble to GPU? 7 (Pause.) 8 A We had conversations. I am not aware of any 9 particular recommendation. 10 Q During the time you were~ project manager.under the II recovery organization, did you have any communications with 12 anyone from NRC? 13 A It seems to me at one time GPU was requested by NRC I# to discuss with them the advisability of adding sodium -- 15 ' sodium sulfite to the reactor coolant system to reduce the 16 oxygen content. They requested that we contact certain I7 individuals in the NRC who had this concern. 18 We arranged such a conversation and as far as I l 19 know, that was the only conversation with -- with NRC. 20 Q Did anyone from NRC with whom you spoke, indicate 21 any displeasure with B & W's role or activities? j p 22 A No, none. 1 W 23 Q Have you ever become aware of any indications of 24 displeasure with B & W's role in response to the incident that AcesaWJ Reporters, Inc. 0 were made by the NRC? . L ', 4. '

27 dsp27 1 A I have not. () 2 MR. DIENELT: This would be a good time to take a 3 break. () 4 (Brief recess.) ) 1 5 BY MR. DIENELT: 6C Q Do you attend owners group meetings? 7 A No, sir. j 8 Q Have you ever attended one? 9 A No, sir. 10 (Pause.) 11 Q As senrio project manager for TMI 2, did you have 12 any role in reccmmending operating procedures? 13 A In recommending? ) 14 Q Yes, sir. 15 A I did not personally have any role in recommending 16 operating procedures. 17 Q Did anyone from B & W recommend operating procedures? 18 A Perhaps it would be desirable to explain how 19 operating procedures were prepared. 20 Q All right. How are operating procedures prepared? j 21 ER. EDGAR: For TMI 2? 22 MR. DIENELT: Yes. [ 23 THE WITNESS: First of all, the n'ormal sequence is (~) 24 that B & W supplies draft procedures which are almost like a ' Ace +u:::s toporwes, Inc. 25 very brief outline of a procedure. From this draft, a detailed. j 'd. 9 .g 4 L' 'c

28 dsp28 procedure is prepared by the utility or with the assistance of 1 O 2 other - 3 In this case, on TMI 2, the customer elected to () 4 prepare the detailed procedures for Unit 2 from the detailed 5 Procedures of Unit 1; rather than from drafts. 6 Mr. Lee Rogers, our site representative and his 7 field engineers working at the site, as well as certain 8 individuals in the nuclear service department, here in 9 Lynchburg, participated in the preparation of the detailed 10 operating procedures for Unit 2 under the master services 11 contract. 12 In that sense, we did participate by having, originally, 13 supply the draft procedures used on Unit 1; from which eventually 14 Unit 2 procedures became develcped, and by the fact that 15 individuals working under the master services contract did 16 assist Met Ed in preparation of many of the procedures used 17 on Unit 2. 18 Q Can you identify the persons in Lynchburg who 19 participated in the praparation of the operating porcedures 20 for Unit 2? 21 A I can not. 22 0 What department would they have come from? 23 A The nuclear service department. l (~} 24 Q You were not involved? Ace 4w4J Reporters, Inc. 25 A Not directly. '.~ 'O 'N

29 dep29 1 Q Did B & W approved the operating procedures in any () 2 formal sense? 3 A No, sir. When Mr. Rogers would complete a procedure () 4 that he was assigned to work on under the master services 5 agreement, he would submit it to the plant operating review 6 committe called the PORC. 7 We were not members of that PORC. It was that 8 group which made the final approval of the operating porcedures. 9 A Was there any formal concurrence or signing off of 10 procedures which B & W did? 11 A Not formal signing off, no. 12 Q Was there a mechanism for B & W's indicating 13 disagreement with a procedure? 14 A Yes. We had a plant start up team at the site.who, 15 in most cases, had prepared the operating procedure, or at least 16 had an opportunity to review it. If there were any inconsistencies 17 in the operating procedures used at the site, they would hava 18 brought this to the attention of the plant management of TMI. 19 Q Was there a means of resolving any disagreement 20 which was expressed to the management of TMI? 21 MR. EDGAR: Is this in a formal sense? 22 MR. DIENELT: Yes. O 23 MR. EDGAR: Formal procedure, sort of. f-} 24 MR. DIENELT: Yes. AceLJd Reporters, Inc. I 25 THE WITNESS: I'm not aware of any formal procedure. "l ~,

30 l_ f dsp30 I BY MR. DIENELT: 2 Q Do I understand correctly that if there were a 3 disagreement with respect to an operating procedure, B & W, (s"T / 4 as you understood it, did not have a kind of veto power or an 5 ability to acquire Met Ed or GPU to follow the procedure, or 6 change the procedure in a way to take into account the 7 objection or disagreement which was expressed? 8 A There was no formal procedure for doing this. 9 However, in the contact of our project activities, when there 10 were disagreements, the matter would be resolved through 11 escallation to higher management. 12 By this, I mean, we would not have just rested with 13 a condition which we were confortable with, or which we thought 14 was in the best interest, without taking it to a higher level 15 of management. 16 Q Are you aware of any instances in connection with 17 TMI, in which a disagreement percolated up to higher management? 18 A Not regarding operating porcedures. 19 Q I should have restricted to operating procedures. 20 Is there or has there been a mechanism at any plant with 4 21 respect to whir you had responsibilities as project service {} manager for a formal approval or signing off by B & W, with 22 23 respoect to an operating procedure? (} 24 (Pause.) Ace +_m Reponen, Inc. 25 A Not that I recall. The only other plant that I l

31 dsp31 1 would have been involved in would have been TMI 1; and I'm not (_N j 2 clear whether the test working group approved those draft 3 procedures or not. ( The test working group which is another group at the 4 5 site do apporve test procedures. That is -- B & W is a member 6 of that group. 7 Q Are you aware of any plants, with respect to which 8 B & W had or presently has a formal approval or concurrence 9 responsibility with regard to proposed operating procedures? 10 A No. 11 Q Was the role, if it had one at all, of B & W with 12 respect to emergency procedures at TMI 2 different from the 13 role that you have desctibed, that it had with respect to plant ) 14 operating procedures? IS A Please review that question again. 16 Q What I want to know is whether B & W's role in 17 connection with emergency precedurte a.t TMI 2 was different from i 18 the role that you have just described for me, with respect to 19 plant operating procedures? 20 A No. The role with operating procedures and emergency 21 procedures would be the same. I did indicate that the role was 22 slightly different for test procedures, and the rolc with [} 23 regard to operating procedures on TMI 1 may have been different l I') 24 early on -- TMI 1, that is. l Ace. W Reporters, Inc. l 25 Q What would the difference have been? l -s-

7 32 I A The role of the test working group as opposed to 2 the plant operating review committee having final approval. 3 0 Was the role with respect to maintenance procedures O 4 different fromt he role with respect to plant operating and 5 emergency procedures? 6 A No. I don't believe there was a difference. MR. EDGAR: Are they the same? O THE WITNESS: I believe so, but I'm not -- I'm not clear on that. BY MR. DIENELT: 11 Q Who would know? 12 A The starion personnel responsible for the preparation 13 and approval of these procedures would know. Within B & W, it 14 would be in our nuclear service departr.ent. 15 Q Did B & W have a role with respect to the -- strike 16 that -- did B & W make any recommendations regarding the 17 control room design for TMI 27 18 A Very early in the design of the control room, we 19 made recommendations. 20 Q Did B & W have any formal approval or sign off 21 responsibility with respect to the control room design? 22 Q A We had no -formal approval or sign off responsiblity 23 with the overall arrangement of the control room. We did supply-two sections of the main console which we had design g 25 responsibility for. VNdi_ ~ m.

33 dsp33 I We had design responsibility within the context. I () 2 should say; however, that Burns Roe also had to approve our ~ 3 design. (, 4 Q Did you have the authority or responsibility to 5 approve the design of Burns & Roe, or anybody else with respect 6 to the parts of the control room console which you were not 7 primarily involved? 8 A No. 9 Q Did B & W prescribe or recommend any safety limits? 10 A Ye-we have a document called " Limits and Il Precautions" which is a draft procedure which, essentially, has 12 a -- could be construed as a listing of safety limits. (^g 13 Q And you furnish that to TMI 2? U Id A That is correct. 15 Q That was in the form of a draft? 16 A Operating procedure. 17 0 Your responsibilities with respect to that would 18 be the same as with respect to any other operating procedures? I9 A Except that we just supplied very few draft operating 20 procedures for TMI 2. As I indicated earlier, most of the 21 procedures were prepared from Unit 1 detailed procedures. l {} In the case of the " Limits and Precautions" document, 22 23 and also the set points document, these were' prepared for TMI Asi Reporters, Inc. 24 2 by B & W, and supplied under the NSS contract. Ace-25 Q Did B & W prepare the final document? j 4

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34 dsp34 ) A No, sir; just the draft. O Did B & W have any formal approval or sign off 3 responsibility with respect to the final document? b) 4 s/ A No, sir. 5 Q Did B & W furnish to TMI 2, any safety analyses? 6 A In conjunction with the safety analysis reports, 7 we did supply safety sanalysis. 8 Q Were these draft documents, or final documents? A these would be draft documents, which would then 10 he documented in the PSAR and FSAR by GPU. 11 Q Did you have any approval or concurrence or sign off 12 responsibility of a formal nature with respect to those? (} A No sign off as such. 14 Q No approval? 15 A No. Let me explain why we did not have formal 16 approval rights. There is no reason to believe that they did 17 not change our analysis or -- in other words, it wasn't a case 18 that we would supply an analysis and they would change it and 19 we wouldn't have anything to do with it. 20 There wasnt' any problems like that. There wac 21 concurrence, I believe, in all of the sections that were () finally submitted to the NRC. Q Do I understand that the nature o'f the concurrence n 24 w uld be a form of informal concurrence or consensus, as opposed fc.4u n pon.n. ine. 25 to some formal documer._ which B & W would have to sign or check

35 dsp35 ) ggg7 () 2 A That is correct. They would -- different participants 3 in the safety analysis report would prepare their drafts. We () 4 would have review meetings. 5 During these review meetings, comments would be 6 resolved and a final draft prepared, then, which represented 7 a consensus of all of the parties. 8 Of course, everyone in connection with the project v receives copies of FSARs so that you had proof that what was 10 finally submitted was, indeed, what had been agreed to. 11 Q Was the role, with respect to safety analyses, that 12 was played by B & W with respect to TMI 2, different from r-13 the role which was played by B & W with respect ta any plant of b] 14 which you are aware? 15 A No, it's not different. 16 (Pause.) 17 Q What is the relationship,if there was one, between 18 the warranty obligations under the contract to supply the NSS 19 and TMI's - 'and B & W's role in connection with operating 20 procedures or safety limits? 21 MR. EDGAR: Are you asking him for a legal opinion, q 22 or -- b 23 MR. DIENELT: Just if he has any understanding. 24 MR. EDGAR: His working understanding, if he has one. f') Aos-Ost Reporters, Inc. 25 THE WITNESS: Well, the warranty is limited or

l l 36 dsp36 I conditioned by the utility operating in accordance with O 2 instrucetone. In the course of the contrece, we suge1r 3 instruction manuals, and these " Limits and Precautions". O 4 Therefore, it is a equirement on their part to 5 operate within these -- these 1.imits to t.aintain their warranty 6 in good standing. 7 Q As you understand it, if B & W were dissatisfied 8 with an operating porcedure, and the matter could not be 9

r. solved at the opper management level, would B & W be -- would 10 B & W issue an instruction to operate or to change a procedure in accordance with certain requirements that B & W wanted to I2 impose?

13 A I'd have to answer this in a hypothetical case; but I# that is correct. 15 Q The reason you would a'nswer it as a hypothetical 16 is that you are aware of no such occurrence? 17 A That is correct. 18 (Pause.) I9 Q Do you have any basis on which to compare any aspect 20 of the TMI 2 operation with TMI 1, or any of the other plants, 21 with : respect to which you are the senior project manager, or 22 have been the senior project manager? 23 A I don't believe so. I -- by that'I mean that I don't 24 O have any reason to compare the operation of TMI 2 as being Ams w.,#J Reporters, Inc. 25 different that TMI 1. V

37 dsp37 1 In fact, we were always of the opinion that TMI 1 O G \\l was a/seprebl well operated plant, and fully expected TMI 2 l k 3 performance to be the same. () 4 Q You mentioned two other plants to which you are now rm 5 theseniorporjec,h)hanager. / 0 A Yes. The WPPS project and the PG & E project, l 7 neither of which are even approaching the operating phase, yet. 8 0 You have not been senior project manager for any 9 plant which did reach the operating stage, other than the TMI 10 plants? 11 A One additional one would be the Crystal River plant 12 at Forida Power Corporation. I don't have any real basis to () compare the operation at TMI with Crystal River. 14 0 You have never considered that or formed an opinion? 15 A Never formed any real opinion with respect to that. 16 (Pause.) 17 Q Were you involved in any discussions on March 28, 18 29, or 30 relating to the venting of the makeup tank at TMI? 19 A Only after the fact. I was aware that the venting 20 of the makeup tank contributed to a release of radioactivity. 21 Q You were not aware of or involved in any discussions 22 () prior to the nin)ofthemakeuptankbetweenthesiteand B & W in Lynchburg? l Ami] set Reponers, Inc. 24 A No, sir. 25 l MR. DIENELT: I have nothing further. Thank you

i-38 j i dsp38 i I very much. i

O 2

ras w1russs: whamx you. 3 (Whereupon, at 10:13 a.m., the deposition was adjourned.)

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