ML19308C518
| ML19308C518 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/04/1979 |
| From: | Goldfrank J, Klingaman R METROPOLITAN EDISON CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280517 | |
| Download: ML19308C518 (56) | |
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PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
_______________________________________________x CONTINUED DEPOSITION of METROPOLITAN EDISON COMPANY by RICHARD M.
KLINGAMAN, held at the Three Mile Island Nuclear Generating Station, Harrisburg, Pennsylvania, on the 4th day of August 1979, commencing at 2:00 P.M.,
before Stanley Rudbarg, Certified Shorthand Reporter and Notary Public of the State of New York.
BENJAMIN REPORTING SERVICE CERTIFIED SHORTHAND REPORTERS FIVE BEEKMAN STIN NEw YonK.NEW YORK 10038
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3 METROPOLITAN-----------------_ON EDISI ---_OMPANY:
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SHAW, PITTMAN, POTTS & TROWBRIDGE, ESQS.
(
Attorneys for Metropolitan Edison Company a
1800 M Street, NW Washington, D.C.
6 BY:
ALAN R.
YUSPEH, ESQ.
7 of Counsel 8
9 PRESIDENT'S COMMISSION ON THREE MILE ISLANI:
10 JOAN GOLDFRANK, ESQ.
Associate Chief Counsel 11 WINTHROP ROCKWELL, ESQ.
12 Associate Chief Counsel 13 Algo _PRgggNT; 14 LOUIS F.
COOPFR 15 o0o 16 MS. GOLDRANK:
We are continuing the 17 deposition of Mr. Klingaman.
18 R I C H.A R D M
KLINGAMAN having 19 been previously duly sworn, was examined 20 and continued to testify as follows:
21 BY MS. GOLDFRANK:
C 22 Q
Can you tell me what information on a 23 routine basis you received from the NRC7 24 A
Cn a routine basis by standard distribution 25 that is made on incoming correspondence that comes 9
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Klingaman 143 2
to Met Ed to the vice president of Generation, I 3
received a copy of all incoming NRC correspondence.
4 Q
And what would that include?
\\
5 A
That included notices or notifications from 6
the Commission.
It would include such things as I
7 I&E bulletins, the normal items that are sent 8
from the Commission to all licensees, as well as 9
specific items that are directed to Met Ed as 10 holders of the two licenses for TMI.
11 Q
Do you receive copies of computer 12 printouts of all LERs from the NRC7 B
A I do not'believe I have seen those, no.
14 Q
Do you receive a copy of what are called 15 NRC Current Events?
16 A
I don't recollect seeing that specifically.
17 I know that as part of the I&E bulletinsJthere is 18 always a list attached with each one of the bulletins 19 indicating previous bulletins sent, but the one 20 you refer to I don't recollect seeing.
21 Q
Did you receive any kind of newsletter 22 from the NRC7 23 A
That also by title doesn't, maybe I just i
24 don't relate to the specific document, but as a 25 newsletter I don't recollect receiving that r -
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Klingaman 144 2
automatically, no.
]
3 Q
Do you remember receiving any kind of 4
document from the NRC that would be a standard 5
communication from the NRC, but contain information 6
on other events in other. nuclear plants?
7 A
The IsE bulletin does that.
8 Q
Other than I&E bulletins.
9 A
I don't recollect seeing other ones, other 10 than the I&E bulletins which I have seen.
11 Q
And the information that comes to the 12 vice president of Generation, that would be i
B Mr. Herbein, and he directs copies of that informa-14 tion to you. Is that every copy or does he select?
)
l 15 A
I am one of thecones:that is on a list for l
16 automatic distribution of each one.
17 There is a standard distribution list which 18 indicates distribution made of each placer.of NRC 19 incoming correspondence.
20 I don't remember the exact date, but I don 21 know that initially in my present position I was C
22 not on automatic distribution for incoming 23 correspondence from the NRC.
Sometime since 24 November of '74 I have been placed on automatic 25 distribution.
It has been for quite some time, but BENJAMIN REPORTING service
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Klingaman 145 I don't remember the exact date.
g 3
Q w uld y u take a look at what we have 4
previously marked as Porter Deposition Exhibit 2, and tell me if y u had received that type of 5
d cument fr m Mr. Herbein?
6 A
I have not seen a document with this type of 7
g cover page which reads, " Current Events," I don't i
believe I have seen one document with this kind of 9
- "*" "h****
10 77 Q
And you have not seen this specific one?
A If I have not seen one, it is obvious I have 12 not seen this one.
g 74 Q
Would you also look at one which has 15 been marked as Brown Deposition Exhibit 78 and tell me iffy u have received that kind of document 16 77 entitled, " Power Reactor Events"?
ig A
No, I have.not.seen any.
I might have seen 19 similar information, but this document headed, 20
" Power Reactor Events," I have:'not received any 31 copies or been shown copies of that or a similar C
33 document.
23 Q
And the information that is sent to you 34 from Mr. Herbein it comes from the NRC, what do 25 yud with that inf rmati n r th se documents?
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Klingama.:
146 2
A Those are handled in various ways.
The 3
copy which I receive is merely intended to be an 4
information copy and an advance copy in some cases.
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Action to be taken on incoming correspondence 6
from the NRC is initiated either directly by me, 7
Mr. Herbein or by our Licensing Department on the 8
corporate staff in Reading.
9 It is assumed by me that the responsibility 10 for the response to the documents and the preparation 11 of the input for response to those documents is 12 by the Licensing Department for Mr. Herbein's 13 signature.
14 I receive copies because in many cases there 15 is a support effort required by other groups, 16 particularly engineering, for licensing personnel to 17.
prepare the responses.
In order to provide the 18 capability for timely response, I receive them as' 19 advance copies.
Thezefore, in many cases I take no 20 action because it is obvious to me that the licensing
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21 personnel have the capability to directly prepare 22 the answer.
23 In some cases it is obvious to me that they i
24 will need support.
Therefore, in those cases I 25 will utilize those documents for advance information BENJAMIN R EPORTING SERVICE
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Klingaman 147 2
to assign to the-appropriate cogni: ant engineer 3
in my department to support the licensing personnel, 4
yet maintaining the corporate posture that the 5
responsibility for preparation and timely prepara-6 tion for preparing that resulting response 7
correspondence is in the Licensing Department.
8 Q
Do you wait for the Licensing Department i
l 1
9 tor. contact you with respect to preparing a response?
10 A
With respect to preparing a response, that 11 is their responsibility. However, if I recognize 12 a support effort may be required, I will assign it 13 to one of my engineers to begin work on the 14 documentation, the research, and in some cases 15 there may be a field investigation required.
16 But in some cases we may need to utilize 17 other engineering agencies for analytical work.
18 So T utilize that advance copy for assignments 19 to an engineer in order to begin the effort to 20 prepare the information that the Licensing Department
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"I will need for the response.
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22 My point is that the engineering staff is 23 not charged with the responsibility of the response, 24 and in our system the Licensing Department would 25 initiate a service request on the Engineering Department SENJAMIN REPORTING SERVICE w
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Klingaman 148 2
to support them.
3 In many cases the response times are 4
extremely short, and the mechanism for initiating that 7
5 servi =e request in itself would incur in some cases 6
one or two days' delay.
7 By having an advance copy, I am merely getting 8
started on the support work and the paper work, 9
to make me respond to provide that support, which 10 may follow it by one or two days.
11 Q
Has.there ever been an instance where 12 you have in response to receiving this information 13 copy, initiated your engineers on developing or 14 doing research on a certain issue, and the Licensing 15 Department has not subsequently asked for your 16 assistance?
17 A
Yes, and it da accepted that in those cases 18
- we have functioned in parallel or7 pay.not..have 19 wasted some effort, but in essence in those cases 20 we have them compared the results of what we have 1
21 obtained to come up with a mutual understanding of
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22 what the proper response is.
23 In most cases I would say though that working 24 in this fashion has providedius with the capability 25 to begin work prior to processing the paper work for BENJAMIN REPORTING SERVICE e
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Klingaman 149 2
requesting assistance in-house and in both cases 3
the problem of two departments working separately 4
on the.same problem has not existed because the 5
way in fact it has functioned is my engineer on 6
receipt of the task to support the licensing for 7
- a particular letter almost always has immediately 8
resulted in a phone call from the engineer to 9
Licensing to determine just exactly how much 10 infermation they have and the details of what 11 support they will require.
12 My point is the two departments do not function.
13 autonomously and separately;of each other.
This 14 advance copy is utilized to be inward, but in 15 so doing there is almost always an immediate 16 Phone contact that determines that there is or 17 isn't support required.
18 In cases where Licensing has had the capability 19 and the information and didn't need support, even 20 though I may have assigned it, that has resulted I
21 in an engineer then responding to me that Licensing
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C 22 has the information and they are going to pursue it 23 and they are going to initiate whatever action is 24 required to respond to that correspondence, and 25 there is no effort required from Engineering.
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Klingaman 150 2
Then we cancel the task.
3 g
You indicated that initially you were 4
not on the automatic distribution list of this f-5 information from the NRC.
6 A
That is correct.
7 Q
And was it at your request that you were 8
put on that distribution list?
9 A
I believe that occurred when Mr. Arnold was 10 still vice president of Generation to Met Ed, and 11 I believe it occurred because there were one or two 1
12 cases where the Licensing did not have adequate D
information in a timely fashion, so that we had to 14 respond to the Commission that we needed additional 15 time to answer.
16 That being the case, and looking into where t
17 the delays occurred, led us to the conclusion that 18 it would provide us the capability to be more timely 19 if I automatically got copies, only because, as 20 I mentioned earlier, of the delays incurred in 21 the mschanism of initiating in-service requests, 22 filling out a form, putting it into the-system, 23 so that the computer could follow it, and then 24 sending it in the mail or even hand-carrying it 25 from one department to another, and in the same I
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Klingaman 151 2
building, does incur one or two days delay.
3 so it was probably tws or three cases that 4
we had been less timely on than we would have 5
desired to have been in recommending on responses 6
which than led us to the' conclusion that we could 7
function more quickly if I were in addition to screen 8
all incoming requests for information,:.make my 9
judgment, and if my judgment was that Licensing 10 could handle it, I didn't do anything with them.
11 If that was correct, they functioned.
12 If that was incorrect, I got a request D
for information, and then I might be a day or two 14 late.
If I made the.other decision that it required 15 assistance from my engineers and Licensing, again 16 I might be correct or I might'be incorrect..rIf I 17 was correct, I would be done a day or two early.
18 If I was incorrect, in almost all cases those 19 were caught because my engineer, when he got the 20 task, would immediately contact Licensing.
21 So the logic behind putting me on automatic C
22 distribution was only to make the system function 23 more rapidly and begin earlier in order to provide 24 the information so that the'two departments were 25 working together to provide a good technical response 4
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1 Klingaman 152 2
to those letters from the Commission.
3 Q
What kind of standard information 4
do you receive from B&W7 7
5 A
I am on automatic distributions proposals 6
that were received from B&W for B&W efforts in 7
accordance with anticipated tasks to be accomplished.
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8 Under the B&W master services contract.
9 We have a contract with B&W for continuing 10 services and, in fact, most of those tasks are 11 initiated, based on input for station personnel 12 at the site.
D In a few cases they may be initiated based 14 on the nedd from my staff or need to support 15 licensing personnel, but in most cases they're 16 initiated at the site.
1 l
17 This is another case where, because of the i
l 18 fact that action may be required to fund and l
19 initiate the work on those tasks from several
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20 locations, the originals of those letters are l
1 21 written to our Materials Management Department,
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22 but copies are provided in several locations 23 because the initiating request for the task 24 either came from the station staff or from the 25 engineering staff in Reading or Licensing.
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1 Klingaman 153 2
That being the case, these people are copies 3
on all proposals to the t
'ter services contract.
4 Since again it was assumed itewas more logical to C
5 provide them to all the groups who might be 6
requesting them, we were all advised in that way of 7
what type work B&W was doing for us, and again it 8
avoided the confusion and delay that might occur 9
in merely sending the correspondence to the Materials 10 Management people, and then their needing to find 11 out which agency had originally requested it, in 12 order to provide the authorization to initiate an B
authorization for B&W to work under the master 14 services contract.
15 so those I received, even though, as I said 16 earlier, most of those'are authorized based on 17 needs at the site.
18 There are other specific items of correspondence 19 from B&WTwhich : receive, but those are in areas 20 where they are in continuing response or an 21 ongoing effort associated with given tasks, given C
22 projects, or cases where the staff in Reading, the 23 engineering staff, may have specifically 24 communicated with B&W for response to questions 25 we had.
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Klingaman 154 2
Q Do you receive any kind of standard 3
newsletter from B&w?
4 A
I know B&w has a standard periodical.
y L
5 I don't know the title of the plant newsletter 6
which Met Ed receives.
7 I have seen several of them, but I do not 8
automatically receive distribution from B&w or 9
organs in-house.
B&W has an in-house newsletter, 10 a printed newsletter.
Again, I don't remember 11 the exact title of it, which I believe is issued 12 approximately monthly, and I do not know the source.
)
D But I get a copy of it and I believe a copy of 14 each issue.
15 The reason I say I don't know thersource is 16 in many cases I receive correspondence or I receive 17 items of news with my initials or
='y name on the 18 top of the piece of paper.
Therafore, I can't 19 tell whether the originator sent it to me or 20 someone in-house distributed it, but I do get what 21 I believe is an approximate monthly periodical 22 in-house printed newsletter that comes from B&w.
23 Q
what kind of information is contained 24 in this in-house monthly newsletter?
25 A
It frankly appears to be to a great extent B ENJAMIN REPORTING S ERVICE t
1 Klingaman 155 2
commercial type information, the type of information 3
that is normally disseminated within the manufactur-4 ing company to individual employees of new products, r
5 new efforts, research efforts that are being 6
expanded, news that the company has disseminated 7
by way of articles or publications or journals or 8
presentations at technical sessions.
9 It always has a brief set of remarks by 10 Mr. MacMillan.
It is fairly technical on content, 11 although there are some I guess who would characterize 12 it as B&W news, employees' news-type information.
13 g
now does the plant newsletter differ?
14 A
My recollection from the ones I have seen, 15 the plant newsletter provides more specific 16 information to whomever reads it to the various 17 B&W plants.
It provides information with regard 18 to significant events at the plants.
It provides 19 ir. formation on outages. - It.provides *ncormation 20 on whe.n refueling outages occur at the various 21 plants.
It provides information on plant generation b
22 oraplant availability, those types of things.
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23 Ms. GOLDFRANK I would like to request l
1 24 we he provided with copies of both the plant
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25 newsletter, and Mr.
l Klingaman didn't remember g
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l Klingaman 156 i
the name of the other B&W monthly, but we "i11 #*U ***
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3 (Discussion off the record.)
4 Q
Other than throught.the informatinn that is sent to you from B&W, what other contact do you have with respect to other B&W plants?
7 A
In the purest sense of my understanding of the g
word " contact," I almost have to say none, which 9
doesn't well mean that I don't see other pieces of g
information which would advise me.of the occurrences at other B&W plants, such as the Atomic Energy-Clearing House and the contents therein, which g
covers many, many kinds of things for nuclear plants, "1Y 8'" P1*"** h"*
th*" Pl*"***
15 Those types of things I do see, and they g
77 times contain information en other B&W plants.
at At times that has been the source of information gg yg with regard to status problems, resolution problems, occurrences at other B&W plants.
g 3
Q With respect to the Atomic Energy Clearing House information, do you receivs that directly?
,33 A
It is not mailed to me directly, It comes to 3
3 Ed under a subscription, and I frankly can't Met
,3 9
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1 Klingaman 157
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tell you whose name.
It is hanuled and distributed 3
with the standard routing slip, which has a 4
standard routing from one individual to the other 5
through the mail in Met Ed, and I receive in 6
accordance with that routing slip. It is not 7
mailed to me.
8 Q
And do you assign that to someonc under 9
you to review or does that just come to you?
10 A
Not specifically for review.
In many cases 11 one or the other of the managers may have seen 12 items that are of specific interest to other 13 personnel.
14 The routing slip may be marked, "See article 15 Page 34," or something like that.
I have done 16 the same thing in some cases to assure that 17 specific engineers make noterof items at specific 18 locations in the report.
19 Frankly the report is quite lengthy and 20 voluminous, and I would be naive to believe that 21 each person on the distribution read that entire 22 report cover to cover.
23 It probably is scanned.
I scan it.
I think 24 other scan it.
But in many cases there are 25 highlighted items, and I guess I should say not BENJAMIN R EPORTING SERVICE
1 Klingaman 158 2
necessarily assigned tasks.
l 3
That does seem logical from my viewpoint and 4
that in many cases items in the clearing House i
5 are not timely news.
They are received after the 6
fact.
7 since we handle them and circulate them 8
with a circulation list to go from person to person 9
to cover thatecirculation list, in many cases it 10 is very old information by the time it is read.
11 So it is not utilized as a method for 12 determining information or as a method for 13 determining work that should be assigned.
That 14 may occur, but I think it is the exception rather 15 than the rule.
16 Q
what kind of lag time are you talking 17 about?
18 A
That is a variable.
There have been times 19 when I have seen it very shortly after it was 20 received.
r 6
21 There are times when in circulation I have C
22 received a copy as much as two to three months 23 after they have been received and began being 24 circulated within the company.
25 That situation, that delay situation, O
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1 Klingaman 159 2
has been improved some for quite some time.
That 3
circulation list has the managers first on the 4
list, so that we do receive it before it-begins
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5 its formal circulat. ion at lower level with the 6
supervisors.
7 sut I do know that during the earlier 8
period of time when I was in a position, that in 9
some cases that information was two or three 10 months old by the time it was provided to me.
11 Q
Do you have any involvement with the 12 B&W owners Group?
D A
Personal involvement as a member, no, I do 14 not.
However, there are seve.ral member representatives 15 for various portions of effort for the asw owners 16 Group, wherein the representatives are either 17 engineers on the corporate staff, in the Licensing 18 Group or engineers in my own group.
19 so some of the specific items that the 20 operators' Groups are following do have representa-(
21 tives which are engineers from my group at Reading.
C 22 Q
And which groups would the engineers 23 under you be represented on?
24 A
At the moment there is an Owners Group which 25 is looking at all the ramifications of responses BENJAMIN REPORTING S ERVICE
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1 Klingaman 160 2
required from the owners for the series-of IE 3
bulletins under 7905, and one of my engineers 4
has been a representative and at most but not all, 5
but most of those owners Group's meetings.
I 6
can't think of a specific, other than the one 7
my engineer is on right now.
But I know there 8
are one or two other ones that are represented 9
by the Licensing people.
10 Q
who appoints people to attend the 11 Bsw owners Group meetings?
12 A
I can't give an answer to that question.
I 13 have not ever seen a Met Ed listing of appointments 14 to these Owners. Groups.
I know thatlin some cases, 15 as with the effort to restock TMI 1, one of-my 16 engineers is a key member of the group performing 17 the effort in Met Ed and GPU, and when it became 18 known that various representatives of the owners 19 were meeting as a group to interact with asw, 20 on the basis of a check with the vice president of e
1 21 Generation, it has been agreed who would represent C.
22 Met Ed.
23 I do not know of a case where we have 24 specifically appointed in writing a member of the 25 asw owners Group for specific tasks that asw was BENJAMIN R EPO RTING SERVICE e
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1 Klingaman 161 2
doing.
3 We have accomplished it with various people, 4
but I have not seen a letter designating someone 5
as a member.
6 Q
With respect to the ti=es that you had 7
engineers under you attend these B&W owners Group 8
meetings, how did those particular engineers become 9
assigned to that?
10 A
That occurred usually by those meetings being 11 requested by B&W at the onset of a particular area 12 of effort, and requesting that. representatives 13 of the owners attend meetings.
14 Whent.those items would occur, and if they 15 were items which we had already begun work on, 16 there would usually have been a verbal conversation 17 either between myself and Mr. Arnold, when he was 18 vice president of Generation, or between myself 19 and Mr. Herbein, at which time it would be decided 20 in some cases that the engineer in Generation
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21 Engineering would be the representative and attend b
22 those type meetings in order to be sure that the j
23 Met Ed input was received and that the actions 1
1 24 recommended by the various owners were not 25 inconsistent with our desires.
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In some' cases on the basis of those conversa-3 tions it was decided that it was more appropriate 4
that a Licensing of a plant staff member become 5
the one to interact with asw in that particular 6
task, and then my effort would merely be in support 7
of whomever was the Met Ed representative.
8 In some cases it was decided that, because of 9
the content of particular owners meetings, that 10 we might have both the Technical as well as 11 Engineering member attend, as well as a Licensing 12 member attend.
D In the purest sense, they probably were not i
14 both members, but they were representatives of 15 Met Ed, and indicated to the owners Group and c:-
16 Bsw their best understanding of what the Met Ed 17 position or posture might be.
18 In some cases the items which came up 19 at the owners Group meetings were such that the 20 representatives weren't compelled to respond
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21 particularly in cases where those authorizations 22 considered commitments for a considerable amount 23 of funds.
24 In those cases two methods were available 25 to the members that were at the owners Group meetings, BENJAMIN R EPO RTING SERVICE
I Klingaman 163 2
either by phone conversati'on or by delay of response.
3 Now, they were ab$e to determine what action 4
was being recommended, what the owners Group as a 5
group may have decided that asw do, and references 6
to the meeting, discussed them further to determine 7
whether we did agree in fact with action.
8 In many cases the type of actions that 9
were recommended at asw owners Group meetings 10 were far reaching and had considerable economic 11 impact in the commitments made.
12 There were conversations associated with 13 ongcing investigations and ongoing analysis, 14 and the owners did not always agree that each and 15 every phase of what asW was recommending was really 16 required.
17 so zn some cases recommendations were made i
18 from B&W in particular long-range areas, in terms 19 of phases of work, and not all the owners agreed l
20 unanimously to have asW accomplish all this.
21 Q
With respect to the Bsw owners Group, 22 would you explain the structure of it?
l 23 A
I don't think I can.
I never have understood 24 what "the 3sw owners Group" is.
I have never 25 seen a charter for it.
I hava never seen it written 4
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I Klingaman 164 2
up.
I really can't explain it to you.
3 Q
Do you know if there is one group with 4
subcommittees under it?
5 A
My own perception is the term "asw owners aroup,"
6 it is a funny term that is used very loosely, i
7 that is not defined.
8 There is not a charter for it that I have
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l 9
seen.
There is not a set of membership nor a 10 set of " owners," nor a list of subcommittees for 11 it, nor any of the kinds of questions that you may 12 like me to respond to on it.
D I really can't because you hr.ve asked me 14 all of these same questions, and I functioned with 15 it and I provided input to groups that met, and I 16 frankly believe the term, "Bsw owners Group" is 17 a very loosely used term.
18 Q
Do you know if is is just a series of 19 ad hoc meetings?
20 A
The way it has functioned from my viewpoint f
21 is under that title a particular arca is of interest, C
22 whatever that area might be of interest, and has 23 mutual concern among the owners, and since it is 24 a gencric common item to Bsw, either from the owners 25 or from asw, with that viewpoint it is brought up BENJAMIN R EPORTING S ERVICE
1 Klingaman 165 i
3 and correspondence goes to the various owners.
3 That begins the interaction between them, 4
and those things are done under the guisc of k
5 something called "Bsw owners Group."
6 g
Do y u know if at these meetings 7
that it is just in response to B&w making g
recommendations on certain issues?
9 A
No.
I do not believe that is always the 10 case.
I believe some of these typesthings have 11 been initiated because of owner concerns.
I don't 12 know if it is classed under "Bsw Owners Group,"
l 13 but periodically, approximately yearly, there have 14 been meetings at which representatives of the owners 15 meet with Bsw, and B&w to the greatest extent made 16 presentations on what i s' going on among the owners, 17 status, significant items of interest for specific 18 plants, predominantly slanted for operating personnel.
19 I believe they have been pretty regularly.
20 I have personally only attended one, and from the
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21 interaction I have at that. meeting, my understanding 22 is that it is intended to be approximately an 23 annual meeting with operating and management 24 representatives of the various owners.
25 It quite frankly appears from my viewpoint to BENJAMIN REPORTING Sir.RVICE
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Klingaman 166 2
be somewhat sales oriented, but predominantly the 3
mechanism to pass information from one to the 4
other of the owners with regard to new events,
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5 operating problems, items which may be of mutual 6
concern to tne utility.
7 My recollection is one such meeting which 8
I attended in this area and as part of it a tour 9
of TMI for the other owners, which I did not 10 participate in, but in the meeting sessions 11 had presentations made by B&W and also by some 12 representatives of the individual utilities.
13 My recollection is they were operating 14 aspects of the various plants presented by 15 superintendent-level people.
16 There were items of common interest with II regard to feedwater and steam chemisty and its 18 association with turbine problems, the type of 19 things that would be of general interest to the 20 various owners and in particular if there were r'
21 problems that had occurred, the intents to (3
22 communicate with the other operating personnel 23 the type of problems that had been encountered, l
24 so they could be avoided by other operators.
25 g
nid you receive an agenda in advance r
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m-r v --
1 Klingaman 167 2
of the meeting that you attended?
3 A
Yes.
I believe there was a brief agenda.
4 Q
And were there handouts at that meeting?
(
5 A
There were not handouts for each of the 6
presentations, but I do believe there was printed 7
material available for the technical presentations, 8
and my recollection is thatasometime after the 9
meeting, in printed form the technical presentations 10 were sent to the attendees.
11 MS. GOLDFRANK: I would like to request 12 that we be provided with a copy of the printed G
material.
14 (Discussion off the record.)
15 THE WITNzss:
The one I went to was here 16 in Hershey, approximately two and a half years e
17 ago, but I don't really recollect the exact 18 date.
19 Q
You indicated that at various times 20 entineers under you have attended or worked on tasks 21 with respect to the B&w Cwners Groupg.
2 22 A
Correct.
23 g
And did they prepare memos for you 24 concerning their involvement in that group?
25 A
when one of our engineers is authoriasd to B ENJAMIN R EPORTING SERVICE
Klingaman 168 g
attend an off-site meeting, there should always e prepared a tr p report, covering in the broadest 3
i sense what had occurred at that meeting, and that 4
(
8h uld have been presented to me subsequent to 5
ineivieua1 eri,s, incany cas..h.n eh.y hav..-
7 attended a meeting or made a trip out of town or j
had off-site attendance.
i So to the extentethat they were present at j
9
- *f * ""
ff-*it' ****i"
- h'** 'h*"1#
10 i
exist a trip report covering each of those.
gy 12 There may be several associated with the same 13
- Dd***'
D"* *h*** 'h "1d D* 1"
"" #11**
- 74 separate report for any case where an engineer has attended one of these type meetings.
15 MS. GOLDFRANK:
I would like to request 16 1-that we be provided with copies of trip gg reports to Mr. Klingaman front-his engineers 19 concerning participation in the Bsw owners 20 Gr up.
r-31 Q
What contact do you have with the E'
33 B&W personnel on-site?
23 A
since I have left the site in January of 34 1974, my contacts with the site B&W personnel have I
25 been minimal, and the only contacts that existed l
9 BENJAMIN R EPO RTING SERVICE
I Klingaman 169 2
have been in cases where there might be a need 3
for support or technical information from us.
4 Tasks that the site personnel might be performing 5
for the Met Ed site personnel.
6 That being the case, most of the contacts 7
really have been with the Met Ed site personnel.
8 So quite frankly, contacts with the site-assigned 9
ssw personnel from my own viewpoint have been 10 extremely rare.
11 Q
What had you thought is the function 12 of the Bsw site personnel?
B A
From my own viewpoint I feel that the B&W 14 site personnel are here to.. provide technical 15 support when needed or when requested in specific 16 areas where the Met Ed site personnel may need 17 support associated with the primary system for 18 each of the two units, and also to provide Met Ed 19 site personnel with a single point of contact for 20 the entire B&W organization, so that inn a.reas onably
(
21 organized fashion, if the site Met Ed superintendent kl 22 needs help, needs support, needs technical 23 information, needs work done, whatever it may be, 24 he is relieved of any problem with attempting to 25 determine who in asw can provide that-information, BENJAMIN R EPORTING SERVICE l
i l
1 Klingaman 170 2
but mereir goes to one single source.
3 In addition, the asw site personnel have 4
supported us and supported Met Ed site personnel 5
with regard to efforts associated with refueling 6
and have been able to interact to provide whatever 7
support the site personnel needed for the various 8
evolutions associated with refueling, and have 9
provided the site with recommendations with regard 10 to plans operations when they, the B&w site personnel, 11 were knowledgeable fo a need for changes in operations 12 or operating procedures, and they did provide 13 that notification to site personnel.
14 Q
Are the people, the B&W employees on the 15 site, are they - en gin e ers ?
16 A
I can't specifica1'ly address the background 17 and education and qualification of the assigned 18 people at the site, frankly.
I only know one 19 of them and that knowledge only exists because 20 he had been assigned at the site when I was a l
(
21 the site.
k; 22 Therefore, I can't address the background and 23 education-and qualifications of the people who are 24 here because I don't know them.
25 Q
would you view the asw personnel that BENJAMIN R EPORTING S ERVICE
-.--._e.
w
l l
1 Klingaman 171 2
were on-site prior to March 28th as merely a 3
contact point for the TMI site engineers?
4 A
I don't think I'm qualified to answer that.
5 g
Were you aware of a september 24, 1977 6
incident at Davis-sesse 17 7
A When?
8 Q
On March 28th?
9 A
No.
10 Q
Did you learn of it subsequent to 11 March 28th?
12 A
Yes.
1 l
13 g
Were you aware of an incident prior to 14 March 28th at another B&W plant that. involved a 15 failed open PORV and the pressurizer level 16 indication high?
17 A
I do not think see 18 (A brief recess was taken.)
19 Q
could you look at what we have already 20 marked as Womack Deposition Exhibit 23 and read it
.e 2) to yourself, please.
Have you ever seen this memo k2 22 before?
23 A
No.
24 Q
Have you ever seen other memos?that 25 raised the same concerns as articulated in this memo S ENJAMIN R EPO RTING SERVICE
1 Klingaman 172 2
prior to March 28th?
3 A
No.
4 Q
Prior to March 28th had you eve r been
('
5 aware of a report written by a Mr. Michelson?
6 A
No.
7 Q
Were you aware of a history of a 8
failed open PORV at B&W plants prior to March 28th?
9 A
I don't know that I would characterize it 10 as being a history of that type of occurrence, 11 but'I was aware that there had been instances 12 of electromatic relief valves failing to completely 13 close.
14 I don'tPknow that'Ivean relate it to the 15 context of how many occurred or the proportion of 16 number of failures to close in comparison to 17 numbers of operations.
I don't even"believe 18 that data exists right now.
19 Therefore,31: is difficult to put it in 20 the context of the pattern of occurrences, but
(-
21 I did know it had occurred, yes.
(:,
22 Q
How were you aware of that?
23 A
It had occurred, that is at least the failure 24 of electromatic relief valves to fully reseat.
25 had previously occurred on TMI 1.
I believe I had BENJAMIN REPORTING SER VICE
1 Klingaman 173 2
either heard or read about it, failure of 3
electromat relief valve to fully close, but 4
I don't recollect the association at this point 5
with a specific plant or a specific time.
6 The point is I did not believe that the 7
only occurrence was at Three Mile Island Unit 1.
8 Q
But you don't remember how you became 9
aware of that fact?
10 A
Not specifically, no.
11 Q
Do you know if that information came 12 from B&W7 13 A
If I don't know how I got it, I can't tell 14 you if I remember where it came from.
I just 15 don't know. It might have been in conversation.
16 I really do not know.
17 Q
You don't?know;if this information i
18 came to you orally or in writing?
19 A
I can't associate that. I rec 11y don't know.
20 Q
what type of analysis was undertaken 21 when there was a failed open PORV at TMI?
a 22 A
I frankly can't answer that question with 23 any specificity.
I think to answer one would 24 need to go back to the correspondence in the file 25 associated with that period of time to determine BENJAMIN R EPORTING SERVICE
1 Klingaman 174 2
what was done.
I honestly don't know.
3 o
was that analysis performed by your 4
department or an engineer under you?
i
{?'
5 A
I can't tell you whether there was one done 6
or not.
I don't know.
7 MS. GOLDFRANK:
would like to request 8
that the files be searched to determine 9
what the correspondence was relating to an 10 analysis of the failed open PORV at Three Mile 11 Island.
12 (Discussion off the record.)
D Q
If such an analysis was performed at 14 Met Ed, whose responsibility would that have been?
15 A
That would depend on the magnitude of the 16 analysis itself.
The pEoblem began with the 17 occurrence at the site. If the problem occurs at 18 the site, if the capability exists, and if e
19 information is readily available, the site technical 20 personnel would investigate that incident.
21 If there were any notification requiredhby 22 law or by specification, they would initiate the 23 actica for it.
24 Depending on the magnitude, they may or may 25 not need assistance and request assistance from the BENJAMIN R EPORTING S ERVICE
I Klingaman 175 2
appropriate staff.
3 It is not automatically requested of the 4
corporate staffs only in those cases where, by
('
5 way of expertise they are available.
6 If time and other constraints operate so 7
that they can't perform what they perceive to be 8
a required analysis, they will ask for assistance.
9 so it would depend on the magnitude of the 10 analys4s that were made.
If the site personnel 11 would assess a situr. tion such that very brief 12 simple analyses were made, they would naturally 13 go ahead and do it themselves with the technical 14 personnel available.
15 If they perceived the situation to be such 16 that it was very detailed and very involved and 17 requi =dne., considerable amount of expertise and a
18 requ;. red support, they would then request that 19 suppcet of the staff.
20 Q
Do you receive copies of LIRs for 21 Lnit 1 and Unit 27 22 A
Yes.
23 Q
And do you also receive copies of 24 analyses of incidents thau have occurred at Unit 1 25 and Unit 27 e
B ENJAMIN R EPORTING S ERVICE
1 Klingaman 176 2
A I can't guarantee that I receive all analyses 3
of any occurrence or any incident here at 4
Three Mile Island at either of the two points.
(
5 If they were prepared as part of the supporting 6
documentation for an LER, I probably would have I
received them.
8 Q
And the LERs that you received from 9
Unit 1<.and Unit 2, is there a review of those 10 LERs in your department?
11 A
which unit?
12 Q
Both units.
D A
Unit 2 has a review required, my recollection 14 is, by tech specs under the GRC that is done under 15 the cac.
The requirementeis not the same for Unit 1, requirement for Generation 16 and there is not a 17 Engineering staff to. review all LERs,to th's best 18 of my knowledge, associated with Unit 1.
19 I do receive, I believe, all LERs for Unit 1.
20 Q
In reviewing LERs for Unit 2, would 21 your staff review those to determine whether.-or 22 not certain changes should be instituted or.4 analysis 23 should be made as a result of that LER7 24 A
I think the logic of the review is not 25 specifically to ask the questions you have asked.
i B ENJAMIN R EPC RTING SERVICE
1 Klingaman 177 2
I think the logic of the reviet of an LER is to I
3 review the occurrence and the response that has 1
4 been prepared by another engineer and the logic 5
of that response and the completeness of that 6
response, and whether or not that investigation 7
and that response has satisfactorily addressed 8
the root cause for whatever the occurrence may be.
9 This may very well lead to asking the 10 specific questions which you have asked -- is 11 the' analysis adequate or is the analysis complete 12 or is more analysis required.
13 My point is that I believe that the technical 14 review really goes further than the question you 15 have asked, but includes the adequacy and the 16 completeness and if additional analysis might 17 be required.
18 Q
Your department would review an LER 19 to determine whether or not the technical analysis 20 was correct for purposes of forwarding that document 21 to the NRC7 22 A
Yes.
23 Q
Does it go beyond that?
24 A
In some cases we may have reviewed on Unit 1, 25 we may have reviewed the content of that LER after l
B ENJAMIN R EPORTING SERVICE 1
1 Klingaman 178 2
the facts that is, after it has been submitted to 3
the Commission.
4 Q
But on Unit 2 --
V 5
A on Unit 2 my recollection is they have to be 6
reviewed by GRC per the tech specs and are reviewed 7
prior to submission.
8 Q
Does it have to be reviewed by your --
9 A
It has to be reviewed by GRC.
10 Q
Does it have to be reviewed by the 11 manager of Generation Engineering?
12 A
No.
B Q
Because you are on GRC, you are a 14 member of GRC, correct?
15 A
I think what I tried to characterize when 16 we previously talked about GRC must make me say to 17 you that all the things that are reviewed under 18 GRC are not, each and every item is not specifically 19 reviewed in detail by each and every member.
It is 20 done under subcommittees and those subcommittees 21 report to GRC.
22 So frankly to address my specific review of 23 LERs specifically in detail-- I really can ' t do that 24 since,as a member of GRC, my involvement -- is the f
25 assurance that we have performed the reviews, and 9
BENJAMIN REFORTING SERVICE me.-me M4
i I
1 3
Klingaman 179 i
2 in many cases the superficial review and a report 3
is presented to GRC indicating the review 4
made by subcommittee, at which time J'ere may or may 5
not be interaction, questions, responsos to 6
questions, to be sure that the review was made 7
adequately.
8 So the function from my own viewpoin t in 9
GRC has been an overview, a questioning and assurance 10 that whoever made the review did it adequately, 11 but not to the point of any specific detailed 12 review of the LER.
13 Q
Are you aware that in the spring of 1978 14 there was a failed PORV incident in Unit 27 15 A
I have difficulty with the word " failed."
16 To set what we're talking about straight, we are 17 not talking about failed in the sense of an 18 engineer that I think of a failure. We are talking 19 about failure to fully ressat.
Was I aware during 20 the spring of 19797
/~
21 Q
1978.
b 22 A
1978 -- that we had the failure of an 23 electromatic relief valve to fully reseat, that 24 should have been during the period of time that 25 we were in startup and tests prior to going critical?
BENJAMIN R EPORTING SERVICE l
1 Klingaman 180 2
I may have, but I don't recollect the specific 3
ccurrence that I can recall at this time to 4
indicate that I was at that time.
5 Q
were you aware of any changes that 6
were made in the indication of the PORV position 7
in the control room in Unit 27 g
A Sometime during the startup and test program 9
we had the occurrence which I presume you tried to 10 establish -- and I don't know the time -- but i
11 associated with the occurrence it is my recollection 12 that it was decided to add indication in the control 13 room on TMI 2 for electromatic relief valve position, 14 based on problems with the valve.
15 That indication was added subsequent to the 16 initial design, and base'd on problems thatnhad 17 occurred during the startup and test programs.
18 Q
Do you know the analysis that went 19 into making that change?
20 A
To the best of my knowledge, I have not-seen f-21 one.
k;,
22 Q
was your office involved in the decision 23 to make that change?
24 A
I indicated that to the best of my knowledge 25 that was during the startup and test program, and SENJAMIN R EPO RTING SERVICE
1 511ngaman 181 g
2 during the startup and test program the responsibility 1
3 for modifications for the plant were under GPUsc, j
4 and they were not the responsibility of the technical 5
support staff, since we were not functioning under 6
the operating license.
We were in the tail and 7
of a construction phase.
8 Q
So the responsibility for that rested with 9
the startup group from GPU7 10 A
Yes.
i 11 Q
And you don't know who was involved 12 with an analysis that was undertaken with respect 13 to those changes?
14 A
Not specifically.
15 Q
Do you know if at that time it was 16 considered to have a direct valve p'esition indicator 17 in the control room with respect to the PORV7 18 A
Not having seen an analysis nor being i,
19 involved in the determination, anything I would say 20 would be pure speculation.
I do not know.
21 Q
Did the GPU Startup Group have their
~
kL 22 own engineers?
23 A
In the organization of the startup Group, 24 they had shift test engineers, and they have 25 available to them technical support from other e
BENJAMIN REPORTING S ERVICE l
1
l l
1 l
l 1
Klingaman 182 2
GPU engineers on the basis of the startup personnel 3
requesting assistance from GPU.
4 Q
And who would be the lead engineer?
5 A
I don't know who the lead engineer would 6
have been in that organiration at that period of 7
time.
My recollection is that Ron Toole was the 8
startup and test superintendent at that time.
9 Q
what is your perception of the concept 10 of going solid?
11 MR. YUSPEH:
What does that mean?
12 MS. GOLFRANK:
What.is his understanding?
13 A
My perception of going solid is taking any 14 system that might exist anywhere in the world to the 15 point where it is completely filled with liquid.
j 16 I don't know what bearing it has on what we're 17 talking about, but that is my perception of what 18
" going solid" means.
1 19 Q
And what is your perception with respect 20 to a nuclear power plant?
21 A
That is again a very broad kind of a m
22 thing because there are systems that are operated 1
23
" solid."
Naval systems are operated solid.
24 There are nuclear systems that are operated in a 25 lot of different ways.
B ENJAMIN R EPORTING S ERVICE
1 Klingaman 183 2
Q With respect to Three F',le Island.
3 A
What my perception of " solid" at Three Mile 4
Island is?
My perception is that for normal 5
circumstances, under normal operating conditions, 6
this system isn't intended to be continuously 7
operated solid.
8 Q
And what about in an emergency situation?
I 9
A I don't know that there are any emergency 10 procedures that were in existance prior to March 28th i
11 which instructed operators to operate the system 12 solid under even emergency operating conditions.
13 2
Do you know if there are situations in 14 an emergency situation where you would rather have 15 the system operate solid than something else happen?
16 A
I think today it is pretty obvious that there 17 can be a more desirable situation to have the 18 plant in that condition.
I 19 Q
What was your perception of that prior 20 to March 28th7 i
i l
21 A
My own opinion -- and it is only my opinion --
g b
22 prior to March 28th on a review of the 3sw system, l
23 I believe it can be safely operated solid.
24 Q
What is that perception based on?
25 A
On the fact that I believe the system can be SENJAMIN R EPO RTING SERVICE
.r
_g-.-
1 Klingaman 184 2
adequately controlled even if there is not a 3
bubble on top of the pressurizer.
4 Q
And do you remember specifically C,
5 where you received any information that you 6
based that on?
7 A
I didn't say I received information based 8
on that.
I said it is my opinion and I make my 9
opinion as an engineer based on my judgment of 10 what I assess as I look at the configuration of the 1
11 system and how it can and can't be operated.
1 12 I did not say I received any information G
that indicated that that was an acceptable situation l
14 for operating a plant.
15 Q.
Did you receive any specific information 16 that you used to base that perception on?
17 A
Yes, a description of the plant.
Specifically 18 there is a description of the plant.
1 19 Q
From asw?
20 A
There is a description of the plant in the.
r-21 S a f e t'y Analysis Report which was submitted to the 22 Commission.
23 Q
And on what are you basing your opinion?
24 A
I am basing my opinion on the fact that I am an 25 engineer and I read a description of the system and e
BENJAMIN R EPO RTING SERVICE
,I
1 Klingaman 185 2
I read a description of the controls of the system 3
and my personal judgment.
1 4
That is all I have said, my personal 5
judgment, based on what I have read as a description 6
of the system and the controls for the system lead 7
me to believe, me, personally, to believe that 8
the system could be safely operated solid.
9 I really cannot give you a document, a set 10 of notes, something that was.sent to me.
I have 11 said and all I can say is it is my opinion as an 12 engineer.
That is all it is.
13 Q
And the description of the system that 14 you are basing your opinion on, was that contained 15 in the safety Analysis Report?
16 A
If you will looki$.there is a system described 17 in the safety Analysis Report for these two units.
18
'f e s, there is a system described.
That is what 19 the safety Analysis Report is.
20 Q
And is that description the one you are 21 basing your opinion on?
r.
22 A
Yes.
l 23 Q
what specifically in the description 24 of the system in the Safety Analysis Report?
25 A
All of it.
An e,ineer needs to look at the SENJAMIN R EPORTING SERVICE e
e -
-,vw
., - -~
,w
,,,,,+w-w-.s g
qi
I Klingaman 186 2
entire system to assess what you can and can't 3
do with it.
4 You can't ignore one part cf the system and
<5 5
say, "nased on this little part, make this judgment."
6 No engineer can do that.
7 Q
What is your analysis, your opinion of 8
what the control room operators responded to on 9
March 28th7 10 A
I was not here.
I cannot judge what tho'e s
11 men did in that control room.
From what was 12 reported to mesover':the phone three miles away, 13 I am not capable of doing that.
14 Q
Based on what you have been informed 15 since then, what is your opinion?
16 A
I have been informed of a considerable 17 amount of information by the news, which is 18 absolutely useless, and I have a good number of 19 bits and pieces of information by way of conversation.
20 I have not been a parody to nor have I made a
- g..
f-21 detailed analyais nor have I questioned the same i
22 people you have to determine what they did that 23 night.
24 So I frankly am not capable of judging what 25 was done.
BENJAMIN R EPO RTING SERVICE l
- ~ -
1 Klingaman 187 2
Q What havc been your responsibilites re[overyunit 3
with respect to the since March 28th?
4 A
That is part of this investigation?
5 (Discussion off the record.)
6 A
(continuing) since the accident, my 7
responsibilities with zagard to the technical g
support staff have not altered, other than they 9
have expanded in the fossil area, since Mr. Herbein 10 has spent virtually all of his time associated 11 with ThreekMile Island.
12 Therefore, 'many'of his responsibilities 13 with regard to the fossil plants I have been responding 14 to for him.
15 In addition, more specifically, I.
have 16 been involved with and several of my engineers are 17 part of the organization which is pursuing the 18 efforts associated with modification.s for restart 19 of Three Mile Unit 1, and specifically individually 20 I have been one of four management level personnel 21 who have been functioning at the site on the back 22 shift as a management representative for those 23 periods of time when Mr. Herbein is not available i
24 at the site.
25 g
And with respect to your on-site activities BENJAMIN R EPO RTING SERVICE
r 1
Klingaman 188 2
watch when Mr. Herbein is not on-site, what 3
types of things are you responsible for?
4 A
We are responsible for interacting with the b
5 Jperations personnsi, the shift supervisor and/or 6
shift foreman on-site for both Unit 1 and Unit 2, 7
to provide assistance in resolving any problems 8
that may exist or that may come up with regard 9
to QA requirements for parts and/or materials 10 for functions being performed through the day, 11 interfacing with construction activities which 12 may be occurring, even though they are of a lengthy 13 nature during nighttime, assuring that operationally 14 we are functioning in accordance with the now 15 existing procedures for operating TMI 2 in its 16 present condition, assuring that the operating 17 personnel foAlow existing procedures and more 18 specifically assuring that all liquid movements 19 are adequately controlled, and any of the other.
20 management-type functions which either I feel I i
i g
21 can act upon or,c.if not. I would then be responsible 22 to contact Mr. Herbein for advice, counsel or 23 direction, in those cases where I didn't feel I 24 had the capability or authority to act for him.
25 Q
This is a watch that will either occur BENJAMIN R EPORTING S ERVICE
= - -
l 9
1 Klingaman 189 2
8 at night to 2 o' clock in the morning or 3
2 in the morning until the next morning?
4 A
That is correct.
C-5 (A brief recess was taken.)
6 Q
Prior to March 28th, what was your 7
perception of what the operators were taught with 8
respect to taking a unit to solid?
9 A
I did not participate in the Training Program.
10 Therefore, I can't specifica11 3 address items of 7
11 content or items of instruction over and above the 12 procedures that existed that the operators were 13 functioning under.
14 However, my general feeling or my perception 15 was that they had been instructed to operate the 16 system in accordance with the operating procedures, 17 which did require operating with a bubble in the 18 pressbriser.
19 Q
Do you know which operating procedures
~
20 specifically?
21 A
From memory, no.
Without going back into 7
(>
22 the operating procedures to determine which 23 specific operating procedures covered it, I can't 24 do that by recollection, no.
25 Q
Do you know generally what the BENJAMIN R EPORTING SERVICE e
e-
-m.
--m-
I r.lingaman 190 3
operating procedure says that indicated that the 3
perator should not take the plant solid?
A In that context, no.
4 5
g Y u indicated that y ur perception 6
was that the parators were instructed pursuant 7
to operating procedures not to take the plant to g
solid, correct?
9 A
I do not know that the procedures say, 10 "D
nt take the plant solid."
guite frankly, 11 I cannot recite to you the content of the plant operating procedures.
I really can't.
But if 13 y u ask my perception, I tried to give you.my 14 perception, not the co nt e r.t of the procedure.
15 As I said, my perception is they were taught to 16 perate the plant with the bubble in the pressurizar.
17 g
You indicated that you cannot point 13 to specific operating procedures by number, but 19 do you know generally what was said in those 20 procedures that you would base your perception on?
21 A
Let me try once more.
23 I didn't go through the procedures >of the 23 Trainigg Program, so tc lead you to specific areas 24 in procedure that led me to my judgment is impossible.
25 However, I do know how the plant is operated.
BENJAMlN REPORTING S ERVICE
I Klingaman 191 2
I do know what controls exist.
I am familiar 3
with the design.
I was involved with many of 4
the system descriptions and many of the system V
5 descriptions lead one:.to understand the plant 6
fundamentally and in the broadest sense and in 7
some cases very specifically how the equipment 8
needs to be operated.
9 It is based on that knowledge that I make 10 the judgments and provide you my perception of 11 how we operated, and from plant information that 12 is available that can be reviewed at one or the 13 other time, whatever those times may be, and the 14 plant information that provided in writing or 15 plant information available officially, from 16 having been in the control room -- so my point is 17 I did know how the plant was being operatsd.
18 It was logical from my viewpoint with 19 regard to operating with the bubble in the l
20 pressurizer, but I have not gone through the 21 specific Training Program and training procedures, 22 and I can't respond specifically to specific items 23 that are in the procedures in this area.
i 24 The general concept of the design and how 25 the plant was operated are the kinds of things that
=
BENJAMIN R EPORTING SERVICE i
1 Klingaman 192 2
lead me to my perception of how it operated.
3 Q
You indicated before that it was 4
your opinion that in certain instances you could P
5 take a plant solid, as opposed to having something 6
else happen, correct?
7 A
I also indicated that the Navy systems 8
are operated solid, yes.
9 Q
And is there something specific that 10 you are basing thatvopinion on?
11 A
No.
12 Q
Is it just a general reaction?
3 A
No, it is not a will-o'-the-wisp whim.
14 It is an engineering judgment.
I don't know how 15 else to try again to explain how I make a judgment 16 on the basis of knowledge of the system, on the 17 basis of knowledge of how the system is designed, 18 and on the basis of the description of the system, 19 plus the fact that it has been demonstrated that 20 the system can be operated solid now, since the 21 accident, under different conditions, but it can be.
l
(_-
22.
Q But prior to March 28th was that i
23 your perception?
24 MR. YUSPEH:
Do you understand' the 25 question?
I am not sure I do.
Could you BENJAMIN R EPO RTING SERVICE
1 Klingaman 193 2
state the whole question again? Prior to 3
March was it your perception that the plant 4
could be operated safely with the uressurizer h
5 solid, or is it a different question?
6 MS. GOLDFRANK:
No.
7 A
Prior to March 28th there were no instructions 8
to operate the plant solid to the best of my
~
9 knowledge.
I was asked for my perception with 10 regard to operating solic before.
In fact, I 11 believe I was asked were there instructions to 12 operate the plant solid and there were not.
13 But in my own opinion was it possible to 14 operate the plant solid -- in my own opinion I 15 responded, I think, that I felt the system in 16 its design was such that it was possible to operate 17 the system solid.
18 I can't lead you to any specific item that 19 addresses that.
It was my opinion, my perception, i
20 based on the system design and the equipment that 21 is available..
~'
22 Q
If you were a consultant engineer 23 and you were asked what your perception was of the 24 ability to take the plant to solid, how would you l
25 respond?
BENJAMIN R EPO RTING S ERVICE
-'7
1 Klingaman 194 2
A By indicating the fee required as a consultant 3
engineer to make a detailed analysis to provide 4
the justification for it.
That is exactly what
(
5 I would do.
I wouldn't provide what: you,have asked 6
me to do, a perception of something as a consultant.
7 I wouldn't do that.
8 I would indicate to a client that if he 9
wants a substantiated documented position, he 10 would have to provide me with funds for me to 11 provide the services to make the detailed analysis 12 that I would need to make to assure myself that 13 the system design was capable, that the system t
14 was capable of functioning that way, that it 15 could meet all of the legal requirements and all
~
16 the requirements of the safety analysis and that 17 there was adequate instruuentation there.
18 I would want to do all those before I 19 indicated that there was an acceptable method, 20 mechanism, way in which to normally or udder 21 these specific defined conditions operate that (1
22 condition.
23 My point is there are two different questions 24 in my mind with regard to -- is there an acceptable 25 way to operate -- and making a determination based BENJAMIN R EPORTING SERVICE
1 Klingaman 195 2
' on it and what is my perception.
I relate 3
these as two different questions entirely.
4 Q
And did you perform that kind of 5
analysis?
6 A
I was never asked.
7 Q
Did you, yourself, perform that kind 8
of analysis?
9 A
No.
10 Q
so your basis for;your perception is 11 just a general feeling?
12 A
It is a general judgment just based on overall 13 knowledge of the system, without having made any 14 kind of detailed analysis.
15 The comment I made to you was not meant to be 16 a posture or a position or a defensible or even 17 a statement of this as an acceptable way to 18 operate.
I was asked for my opinion, and that 19 was my opinion.
But it is not substantiated by 20 any facts of any detailed investigation.
\\
21 Q
Since March 28th you have been interviewed J
22 by various groups concerning the incident on I'
i 23 March 28th, correct?
24 A
Yes.
25 Q
You were interviewed on May 31, 1979
~
B ENJAMIN R EPO RTING S ERVICE
O I
Klingaman 196 3
by Robert Marsh of the Nuclear Regulatory 3
C maission, were you interviewed by the NRC 4
any other time?
5 A
I believe that was the only interview with 6
the NRC since March 28th.
7 Q
Other than the President's Commission, g
have you been interviewed by anybody else, aside 9
from NRC, on May 31st?
10 A
The nly other interviews I have had have i
11 been with personnel representing the President's 12 Commission.
13 Q
Have you been told by any other group 14 that you will be interviewed or deposed by them?
15 A
Not as of today.
16 MS. GOLDFRANK:
At this time I would 17 like to recess this deposition.
We have 1
18 no further questions, but it is possible 19 that at some future date we will call you 20 back for further questioning.
21 (The deposition was adjourned at 4:15 P.M.)
22 23 RICHARD M.
KLINGAMAN 24 Subscribed and sworn to before me this________ day of 25 l
___________ 1979.
BENJAMIN REPORTING SERVICE
I 197 2
STATE OF NEW YORK )
- ss 3
, COUNTY OF NEW YORK) 4 I, STANLEY RUDBARG, Certified Shorthand
(
5 Reporter and Notary Public of the State of 6
New York, do hereby certify that the 7
foregoing deposition of METROPOLITAN EDISON 8
COMPANY by RICHARD M. KLINGAMAN was taken 9
before me on the 4th day of August 1979.
10 The said witness was previously duly i
11 sworn before the commencement of his testimony.
12 The said testimony was taken stenographically D
by myself and then transcribed.
The within 14 transcript is a true record of the within 15 deposition.
16 I am not related by blood or marriage to 17 any of the said parties nor interested directly 18 or indirectly in the matter in controversy; 19 nor am I in the employ of any of thee. counsel.
20 IN WITNESS WHEREOF, I have hereunto 21 set my hand this__
~ day of. 1)htif ___1979.
(?'
23 STANLEY RUDBARG, CS 24 25
,e t
5 j
l BENJAMIN REPORTING SEFh4CE l
l j
t.,.
{
PRESIDENT'S CO:SiISSICU ON THE
_ ACCIDENT AT THREE MILE ISLAND Corrections to August 3, 1979, Denesition of Richard M. Klingaman Pace Line Change To Read h
25 Kutztown, I think.
Kutztown.
7 15 engineer production engineer in production supervisor supervision 7
19 cool-fired coal-fired 12 18 Unit 2 Unit 1 14 9
General play General plant 19 2
paid in this paid in that 21 1h located that rotationally rotated the 29 20 that time by that time to 45 5
full diagram flow diagras 59 4
superintendent and responsibility in a 59 5
superintendent responsi-superintendent's responsi-bilities bilities 59 19 at the prior at their 66 11 to all them to allow then 65 16 Rudy Leffler Rudy Lefin 69 20 GPU 103 GP 1003 76 22 including approving 79 3
approval above approval of both 65 12 tower type station.
tower at the statien.
S9 25 Andy Lawyer Sandy Lawyer 93 3
May of "any of 95 16 changing items, checking items, 96 lh nine cases sc=e cases 10h 6
but do dollar but dollar 108 9
changes occur on a changes, on a 109 16 electrical administrative 113 2
physics-Itse physics-fuel 118 3
fuse problem fuel problem 125 12 and many and made 125 13 drad ngs in order drawings.
In order AlA/ / a y/-
ft
)L sA r hs
- t M. Kl;1frgnnan /
g Subscribed and sworn to before me this 16th day of August
, 1979
% }l/ r a-Notary Pu'elic EITA M. POWERS
- F/.*J:?c. WYer@r; Tag., Berks Ca.
)
Y UMl33:081 f!>ral det PC er 23, /# fs'
/
< i
PRESIDENT'S CCTCSSION ON THE ACCIDE7f AT THREE MILE ISLA*ID Corrections to August h,1979, Deposition of Richard M. Klin.nman Page Line Change To Read 1k9 2
in both cases in most cases 149 lh to be invard to be prepared 153 2
are copies receive copies 160 15 restock restart 162 k
Licensing of Licensing or 162 20 weren't compelled weren't able 186 12 three miles fifty miles 186 20 parody party 188 12 lengthy lesser
/v
/
A
' Richard M. Kling/ man
/
J Subscribed and sworn to before me this 16th day of August
, 1979
-; fly., 211
-wJ Notary Public RITA M. POWERS P
tiers./ uti.c, Sta:Cet*Mrg Tag, Berks CO, f.h C:,mmiss.oa Ex::r s Se;*.emter 30, / ? f.2, a
e
+
5
i
- _~
'8
,, 1 Klingaman 138 3
1 2
natural draft cooling towers for unit 1,
we did
.I b
3 not bid the two natural draft cooling towers for 1
l 4
Unit 2, we negotiated the purchace of those towers.
r." {r..
.._t 2.
5 so we didn't go out for bids.
There was an g.
7{
6 additional savings, if you will, in the effort that
((j' i
7 one goes through, and the justification in our mind J't k.
8 was we knew where we stood economically from one W
~j e
9 vendor to another by having gone through the bidding 10 process and we felt comfortable in just negotiating 11 an addition to the contract to add two more towers, so 12 that was not a conpelling circumstance, but it did 13 add to the l
logic of Met zd procuring those towers.
j 14 Q
!s that why you did not go to Burns & Roe T
15 to design those cooling towers, but went to Gilbert 3
16 Associates?
1 II A
I think for both those reasons.
1 18 Q
- dhy don't we recess.
4 19
[ Deposition was adjourned at 4:50 p.m.]
n
- .l
_L. d.n.P_d._N7h,' % _ u m -_-
/#
)
- *{
21
/1.
/
/
/ RICHARD M.
KLI^!G AM AN
- d.
(C 22
- is Subscribed and sworn to before me t*#'i
~3 El, t h i s _ _.s _ _d6t_h _ _ _ d a y g f _ _ _A_u_g u_s _t _ _ _ _ _ _ _19 7 9.
ry.
N C A d ~ % <___________
25 notary Public RITA 'A. PCWERS
" cry Nu;c. WMe.aberg Tao, Berks CA..
- p C:.t.auun E ;wes up smber 3% gENJAMIN R EPORTING SERVICE t
i.
2 1
Klingaman 196.
!j 2
by Robert Marsh of the Nuclear Regulatory 1j 3
Commission.
Were you interviewed by the NRC 4
any other time?
i i
5 A
I believe that was the only interview with
't-b 6
the NRC since March 28th.
-I.' :
3r (d
7 Q
other than the President's Co= mission, Y{
g have you be'en interviewed by anybody else, aside 1
1 9
fron NRC, on May 31st?
-1 1
10 A
The only other interviews I have had have 4
f 11 been with personnel representing the President's 4
12 Commission.
r 13 g
aave you been told by any other group i
14 that you will be interviewed or ~ deposed by them?
4
)
15 A
Not as of today.
16 Ms. coLDFRAsK:
At this time I would
?
17 like to recess this deposition.
We have 4
e Q
18 no further questions, but it is possible i
1
.]
19 that at some future date we will call you iq 3
back for further questioning.
M y..i 21 (The deposition was adjourned at 4:15 P.M.)
ur 22 l
--7$, l8/ p p
_'.;,_/.'_bd2'_. 2 '_' !_d.e.c#w.w.
p
{f.,i
[RICHARDM. KLiNGAMAN l t'
03 i
/'
^
M 24 Subscribed and sworn to 4
1
' defore me this___1gs.h___ day o f 25
_ _A_u.gus t_ _
1979.
i i
B ENJAMIN REPCRTING SERVICE M.C'.:-- N h.< w
/
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mrA..t. pewsas x:~ vtne. nc:e.su; ao, ou,, u.
- E*?"*53*P [tT*/ fir ePar?S s 4 81