ML19308C555
| ML19308C555 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/05/1979 |
| From: | Rockwell W, Stevens H BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280584 | |
| Download: ML19308C555 (47) | |
Text
, _ _ _
9 95 c i : J =sd. *b 7
-...--x PRESIDENT'S COMMISSION CN THE ACO OENT AT THREE MILE ISLAND
.---..x DEPOSIT:CN of 3A3 COCK & WILCOX by HOWARD HARTMAN STEVENS, held at the offices of Babcock & Wilcox, Old Forest Road, Lynchburg, Virginia 24505, on the 5th day of July, 1979,
[
commencing at 7:20 p.m.,
be fo re Stanley Rudbarg, certified Shorthand Repor er and Notary Public of the State of New York.
l l
s BENJAMIN REPORTING SERVICE CECRED SHOR~ HAND REPORTERS -
FIVE BEEKM.LN STREET NEW YORK.NEW YORK 1C038
[212] 3741138
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4 MCRGAN, *EWIS & SOCK US, ESQS.
Attorneys for Babcock & Wilcox 1800 M Street, N.W.
5 Washington, O.C.
20038 3Y:
GEORGE L.
EDGAR, ESQ.
of Counsel t
-and-8 3YRON NELSON, ESQ.
9 House Counsel 10 11 ggg,ggg ggggggg,:og, l*a WINTHROP A.
ROCKWELL, ESQ.
Associate Chief Counsel 14
..RE.S E NT. :
ALSO P
. RONALD M.
EYTCHISON 16 17 o0o 13 19 20 21
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23 24 25 SENJAMIN R EPCRTING service
i 1
2 3
3 (Resume of Howard Hart =an Stevens was 4
marked Stevens Deposition Exhibit 70 for i de n tifi e r.tio n, this date.)
~
0 HOWARD HA RTMAN S TEV ENS, 6
having been duly sworn by Winthrop A.
- Rockwell, I
Esq., was called as a witness and testified as 8
follows:
9 DIRECT EXAMINATION 10 BY MR. ROCKWELL:
11 Q
Would you state your full name, please?
12 A
Howard Hartman Stevens.
g Q
Mr. Stevens, would you state your current business address?
A 3abcock & Wilcox, P.
C.
Box 1260, Lynchburg, la, Virginia.
16 Q
And your current employer?
17 A
3abcock & Wilcox Company.
18 Q
What is your current position with B&W?
19 A
- am a regional business manager in the suelear 20 Parts 0 Ater at R&W.
31 Q
Mr. Stevens, have you brought with you U-today a resume which we have marked as Stevens Deposition Exhibit No. 707 A
Yes, I have.
24 Q
Did you prepare that?-
25 EENJAMIN REPCRTING SERVICE
f 5
1 2
Stevens 4
3 A
Yes, I did.
4 Q
- s it current and complete and accurate to the best of your knowledge?
O A
Yes.
6 Q
Mr. Stevens, were you involved in the design e
of a cont:c5 room -- I used the word " package" for lack 8
of a better term, and you may want to refine th a t in 9
approximately 19687 10 A
Yes.
11 Q
Can you describe for me what the process 12 was within Babcock & Wilcox which led to this control p3 room design in 19687 A
Yes, I believe I can describe it in general terms.
15 Q
Please do.
16 A
In approximately February 1968 Burns & Roe and 17 Jersey Central met for the first time, at least as 18 far as we here in asw are aware, to discuss the 19 general control room arrangement for Three xile Island :.
20 asW had sold the Three Mile Island 2 plant l
31 essentially as a duplicate of Three Mile *sland 1 in 1
1 1967, and on Three Mile Island 1 3&W had no responsi-bility to furnish control room equipment.
__a As far as cabinets were concerned, as far as 24 consoles were concerned, as far as panels were concerned, 25 SENJAMIN R EPO RTING service,
I 2
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Stevens 5
l 3
our primary responsibility was to furnish equipment 4
that was sounted on equipment to be furnished by Three Mile Island.
We therefore assumed that our o
i scope of supuly would be the same on Three Mile Island P
No.
2.
However, in March of 1968 we received f cm 8
Burns & Roe a drawing which defined the a :angement of the control room for Three Mile Island 2, and in 10 that a :angement was included the definition that a&W t
11 would be responsible for supplying the consoles which 12 they at that time designated as No.
4, which was the
"**1**
- d
- ****i"*1 P""*1' "hi*h th'Y 13 designata. as No. 14, on which control-rod and in-core monitoring information was to be displayed.
t 15 They also indicated that we would be potentially f
16 responsible for furnishing what they identified as i
l l
17 control console No.
3, on which all of the auxilliary 10 systems were to be mounted.
19 Subsequent to the determination of the responsi-I 20 bility in this document, in October of 1968, Burns &
31 Roe transmitted to 3&W the specifications for the equipment to be provided in this control room by 3&W.
i l
In approximately April of 1969 -- excuse me.
May :
l 3
i back up?
04 Q
Sure.
05 E ENJAMIN R EPCRTING 5Envict
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0 Stevens 6
3 MR. IOGAR:
Off the record.
4 (There was discussion off the record.:
A
- n November 1968, s&w transmitted to Burns & son 5
l l
their drawings which represented the arrangement of o
l the simulator which 3&W was planning to build at that 7
time, and which B&W had been working very closely 8
with Bechtel and sacramento Municipal Teilities on 9
the arrangement for.
This simulator design did not 10 exactly match the specification and th e requirements 11 of Burns & Roe in that it contained many pieces of t
12 equipment which one might call miniature or reduced; so that the si=e f the e nsole and the panel board 13 and the total control room arrangement for the simulator was smaller than that envisioned by Burns & Roe for Three Mile Island No.
2.
16 The thing which made it different was primarily 17 the switchings and other equipment mounted on the 10 consoles, which were specified to be different on 19 Three Mile Island, and whose panel board space required 20 a larger arrangement.
31 But we sent the simulator drawing to Burns & Roe, saying that they were primarily for their information, for whatever use they could make in the process of laying out the consoles for which Burns & Roe had 24 responsibility.
25 EENJAMIN REPORTING SERVICE
e 1
0 Stevens 7
sr/ow 3
In December of 1968 B&W went one step further 02 with regard to the simulator layouts and actually 4
recommended to Burns & Roe that they use the simulator
.3 layouts for the Three Mile Island station because 6
there was a very definite advantage to Jersey Central 7
in doing so, that advantage being specifically the 8
ability to train the operators on the simulator in 9
Lynchburg with the same basic control room arrange-l 10 ment and layout that would exist at Three Mile Island.
11 At the same time we also said that using the 13 equipment that had been specified, the console space for the B&W equipment would be 13 feet 7 inches, that g
is Console No.
4, and that the panel board would be l
approximately 4 feet 11 inches.
15 In April of 1969 Surns & Roe submitted to B&W 16 their designs for consoles 3 and 4 and stated that it 17 i
l appeared to them that these two consoles were very 18 closely linked together functionally, and that they 19 would like to entertain the idea of adding Console 3 gg to B&W's scope of supply.
(Continued on following page.)
31 2?
25 S ENJAMIN R EPCRTING m ERvlCE
t 2
Stevens 9
03 3
A (Continuing)
And at this poin 3&W was inv sed r:/ow 4
to bid on console No. 3 as well as the ones which were already designated to be in our scope of supply.
3 They also stated at that time, the drawings which they gave us of Consoles 3 and 4 incorporated 7
the concepts which we submitted to them -- excuse me, 8
but may I strike that last sentence.
9 Q
Iou cannot strike it fr.om the record, but 10 you can indicate what you want to revise.
11 A
I'd like to say that at this point that is all i
12 that they gave us in April of that year.
g
- n May of 1969 B&W provided Burns & Roe with a layout sketch of Consoles 3 and 4 because Burns & Roe had asked us to combing these two together in a single la, functional design.
This was submitted as a sketch, 16 and again was designated in our mind as preliminary 17 primarily for the information of Burns & Roe to aid 18 them in the layout of the console.
19
- n August of 1969 Burns & Roe
- f. hen sent us their 20 preliminary console layout for Panels 3 and 4 and told us that they incorporated at least the concepts which 31 ss we had given them in May of 1969.
Theire were differ-ences between th B&W drawings that hai been submitted the preliminary in May and the final excuse se 24 arrangemen: that 3 urns & Roe gave us in August of tha:
25 S ENJAMIN R EPC RU NG S EnvicE
s 1
2 Stevens 9
3 year.
These were due primarily to the fact that Burns 4
& Roe, who were the final decision making authority a
on control room layout, had elected to make a somewhat 0
different arrangement chan 3&W had given them.
7 However, the changes that they =ade were at a11' times 8
acceptable to 3&W and at no point did 3&W fird any 9
major faults or flaws in the arrangements that Burns 10
& Roe had sent us.
11 We made subsequently some comments which were minor in nature.
We did not make any major com=ents 13 on the layout o r th e concept of that layout, and as a result approximately one year later in August of 1970 14 B&W s ubmitt ed to Burns & Roe the design of Consoles 3 15 and 4 along with drawings and specifications for these 16 panels which were going to be used for manufacture of 17 the panels.
18 It would be safe to say that at this point the 19 b asic concept of the control room layout had reached y the point where it was ready to go to a vendor for bids, and that all final decisions on the arranc,ement 3
at that point in time had been made by Burns & Roe, and thet 3&W concurred that this arrangement was 3
l functionally acceptable, was operable, and could be 04 incorporated into th e cont 1 room in an acceptable 1
25 SENJAMIN REPCRTING S ERVICE
a 1
2 Stevens to 3
fashion.
In 1970, the design of the control room essen-4 tially went into a hiatus and subsequent to 1970 very little was done until 1972 at which point Burns & Roe 6
incorporated some modificatsons into the consoles 7
which basically consisted of equipment that was within 8
their scope of supply which they wanted incorporated 9
into B&W's scope of supply that is, the panels 10 supplied, the consoles supplied by 3&W.
11 MR. ROCKWELL:
Off the record.
(Discussion held off the record.)
~
13 Q
We have now brought the chronology up to 3
1972, Mr. Stevens.
14 Do you stop at that point because then you 15 went on to something else?
16 A
Yes.
In actual fact, the changes that were made in 1972 were made at the time when I had already 18 transferred to BBR in Germany and the details of those 19 changes and the reasons behind those changes are 20 unknown to me at this time.
Q So what you have done, in giving us the 3
s_-
chronology that you have just finished, is to take the matter of the TMI 2 control room from the time you 03 first became aware of it up through your departure 21 from the scene?
25 BENJAMIN R EPCRTING S EMVICE
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Stevens 11 3
A That is correct.
4 Q
could you tell me who the principal actors were at Burns & Roe with whom you had dealings during
.a this period of time in relation to the issues that we 6
have been discussing, namely control room design.
7 MR. EDGAR:
Off the record.
8 (Discussion held off the record.)
9 A
Throughout the time when the lay o'u t of the 10 consoles from a&W's point of view was within my respon-11 sibility we dealt with one man at Burns & Roe whose 13 name for the moment escapes me.
I will get that name
- 7 * **
- h* **"*1"*
- *h * **** ***
13 Q
Do you recall what his position was with Burns & Roe?
l 15 A
He was an instrumentation and control engineer 16 responsible for many facets of the instrumentation and 17 control for the plant, the layout of the conscle was 18 only one of many things which he did at 3 urns & Roe l
l 19 in the way of control room layout.
20 g
Did he have a particular title or was he known as an instrumentation and control engineer?
at A
At this point I do not recall his official title.
Q Where was he based?
Was it in Cradell?
23 A
- was in New Jersey at Burns 24 Q
! believe that Oradell, New Jersey is the 25 S ENJAMIN R EPC R~!NG S ERVICE
s l
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1 1
2 Stevens 12 3
headquarters of Burns & Roe.
Does that sound right to 4
you as to where he would have been?
A' I believe that is correct.
3 MR. EDGAR:
That would be Oradell, New 6
Jersey?
I A
Is that it?
8 g
Yes.
9 7
Yes.
10 g
Did you review,'Mr. stevens, in preparing 11 the chronology, this new sequence of even'ts that we 12 now have, any documents in order to reflect the times and specifies that you have given to us?
g l
A I reviewed some documents, but by no means did I 14 go to the files and search diligently through the files 15 l
for specific documents.
The documents which I 16 reviewed wara chose related to the chronological events 17 which I have given here.
18 MR. ROCKWELL:
Off the record.
19 (Discussion held off the record.)
20 (Documents described below herein marked, i
l respectively, Stevens Deposition Exhibits 71 y
n l
through 85 for identification, this date.)
l Q
Mr. Stevens, you now have before you 23 Stevens Deposition Exhibits 71 to 83.
24 Do understand correctly that in pre;iaring 25 BENJAMIN R EPC R~ LNG S ERVICE
1 2
Stevens 13 3
the chronology which you gave at the beginning of your 4
deposition you had reference to all of these Exhibits and you reviewed them in preparing that chronology?
o A
I referred to all of these documents with the 6
exception of the " Standard Guide Specification,"
7 Exhibit 71, which I did not refer to in the earlier 8
etatements, but which I dif. assemble during the period 9
of time when I was ;eviewing the panel board design 10 issae.
11 Q
Could we go now through each Exhibit, and 12 I will ask you to do this because you are most familiar 7 **
- h* ** iDi*
1
- h***
d """*"**'
- d Fi'"**
13 number and then give the information necessary to identify it specifically, and let us start with Stevens 15 Deposition Exhibit 71.
Would you please identify it.
16 A
Exhibit 71 is the B&W Standard Guide Specification 17 for Control Room Design Criteria.
18 This document was develcped during the course'of 19 our work with sechtel and Sacramento Municipal Utilities 20 cistrict, to develop the simulator and the aancho Seco ni control room design arrangement of consoles, panels and control room.
Q Should we give the date or some of the 23 numbers on this document to distinguish it from other 24 versions of it ths: may exist?
25 E EN.JAMIN R EPCRTING S ERVICE l
a 1
e Stevens 14 3
A This particular document is dated December 20, 4
1968.
It represents the cu1=ination of the work that was done through 1968 in the development of that
-a control roem design.
64 Q
Please proceed to Stevens Deposition i
Exhibit 72.
Would you please identify it.
8 A
This is a drawing submittal form from Sabcock &
9 Wilcox to Burns & Roe, dated' November 7, 1968, and was 10 used to transmit the drawings for asw's simulator with 11 a note that this infc=utdon was developed in connec-12 tion with our simulator and they are furnished for surns & Roe's information only, to be used in the 13 design of the TMI 2 con, trol room.
Q Am I correct that this transmittal which 10 you are referring to as Stevens Deposition Exhibit 72 16 transmits nine drawings?
17 A
Yes, there are nine drawings.
18 Q
Are the nine drawings the drawings that 19 have bee n marked stevens Deposition Exhtbits 73 through 20 817 31 A
Yes.
l C
Q Can you describe generally to me without on going through each of the nine drawings that were transmitted what they deal with.
l 24 l
A Yes, these drawings represent the console and 25 E ENJAMIN R EPCRTING SERVICE
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2
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stevens 15 3
panel arrangements along with the control room arrange-4 ment for the PWR simelator to be built in Lynchburg, Virginia.
3 On each drawing is a numbered arrangement of components on the face of the consoles and panels and 7
a listing of what each of the numbers represents.
8 Q
I take it each drawing deals with a 9
different panel of the control room?
10 A
correct.
Each drawing represents a different 11 segment of the panel, and they are on the plan of the 10 control room arrangement.
g Q
Referring now to Stevens Deposition Exhibit 73, is that drawing No. 136027?
A Yes.
15 Q
What portion of the control panel'does it 16 cover?
j A
It covers the right center of the control console i
18 which handles condensate feedwater and turbine 19 generator operation.
20 Q
Referring you to Stevens Deposition Exhibit 31 74, is that drawing No. 1360257 C.
A Yes.
Q What portion of the control room does it l
U cover?
04 A
It covers the left center of the control console 25 aENJMIN R EFCRTING SEnvict
l 1
2 Stevens 16 3
on which the coolant system is operated.
4 Q
Referring you to Stevens Deposition Exhibit 75, is that drawing No. 136024?
A Yes.
6 i
Q What portion of the control room does it 7
cover?
8 A
That is the right rear panel No. 3 on which the 9
electrical swit=hing equipment is mounted.
10 Q
Referring you now to stevens Deposition 11 Exhibit 76, is that drawing No. 136023?
l 13 A
- Yes, Q
What section of the control room does that g
cover?
14 A
That covers the right rear panel No. 2 on which 15 the plant cooling water equipment is operated.
16 Q
Referring you now to Stevens Deposition 17 Exhibit 77, is that drawing No. 1360227 18 A
Yes.
19 Q
Tell me what portion of the control room 20 that covers?
A This is the right rear panel No. 1 on which the gg turbine generator equipment is mounted.
Q Referring you now to Stevens Deposition 23 Exhibit 78, is that drawing No. 136021?
24 A
Yes.
25 GENJAMIN R EPCRU NG SEMvicE
l 1
2 Stevens 17 3
Q What portion of the control room does that 4
cover?
A That covers the center rear section of the 3
I console on which the reactor and 20S auxilliary is O
mounted.
I Q
Referring you now to Stevens Deposition 8
Exhibit 79, is that drawing No. 1360207 I
9~
A Yes.
10 Q
What portion of the control room does that 11 portray?
12 A That is the left rear panel No. 2 on which the engineered safeguard equipment is located.
g Q
Referring you now to Stevens Deposition Exhibit 80, is that 136019?
15 A
Yes.
16 Q
What portion of the control room does this 17 drawing apply to?
18 A
That is the left rear panel No. 1 on which the 19 plant aux 1111 aries are located.
l
[
20 Q
rinally, referring you to Stevens Deposition Exhibit 81, is that drawing No. 1360267 ny c
A Yes.
Q What portion of the control room does that 23 i
refer to?.
i 24 A
That refers to the central console on which the 25 S ENJAMIN R EPCRTING service
1 2
~
Stevens 18 3
reactor and integrated control system equipment are mounted.
4 Q
Referring you to Stevens Deposition Exhibit 3
82, c.in you identify that Exhibit?
6 A
Yes, that is a letter addressed to Burns & Roe 7
from Babcock & Wilcox, dated December 13, 1968 in which S&W comments on the specifications for the panel 9
boards which were sent to S&W by Burns & Roe on 10 october 30, 1968, and in which B&W identifies that its 11 console No. 4 will be approximately 13 feet 7 inches 13 in width, and its rear panel is 4 feet 11 inches in width, and recommends that the 3&W simulator drawings g
be used as the basis for the TMI control room arrange-ment because of the advantages accruing from simulator 15 training on similar equipment.
16 Q
Referring you now to Stevens Deposition l~'
Exhibit 83, is that drawing No. 30755?
18 A Yes.
19
.Q What does that refer to?
20 A That refers to the auxilliary systems control gy panel No. 3 as 3&W 1 aid it out in 1972.
q, Q
Referring you now to Stevens Deposition Exhibit 84, is that drawing No. 307567 23 A
Yes.
24 2
What does that refer to?
l SENJAMIN R EPORT NG 5ERvicE
1 2
Scerens 13-a 3
A That is the lay:ut of the plant control panel 4
No. 4 as 3&W 1 aid it cut in 1972.
Q And lastly, :sferring you to Stevens
.a Deposition Exhibit 85, could you please identify that Exhibit.
7 A
This is a letter from sabcock & Wilcox to Burns 8
& Roe, dated August 5, 1970 in which comments on the 9
control console layout are transmitted.
10 (continued on following page.)
11 l
12 13 14 15 16 l
17 18 19 20 21 i
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i 23 24 25 l
S ENJAMIN R EPC RTING SE;:tvicE
R: 5 le 1
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2 Stevens 19 3
Q Mr. stevens, can you tell me what if any 4
role was played by Metropolitan Edison in the history I
5 and dealings that you described at she beginning of j
6 this deposition?
A B&W's interface relative to the design of the a
control room and the consoles for which B&W had respon-8 sibility was with Burns & Roe.
Burns & Roe, in turn, 9
interfaced with Jersey Central and/or Metropolitan l
Edison, GPU in general and I therefore have no 1
11 knowledge of the role that either Jersey Central or 12 Metropolitan Edison played in the design of this con-D trol room since they did not take an active part at the interface that we had with Burns & Roe.
14 Q
Did you know who at Metropolitan Edison la.
or Jersey Central was making decisions or contributing 16 in the area of control room design?
17 l
A
.No.
18 Q
Is it a fair statement to say that the 19 final product for the final design in the Tx: 2 con-20 trol room was a product of the input both of surns 21
& Roe and of 3abcock & Wilcox?
3 A
Yes.
The final arrangement of the control room no was the product of inputs from both 3abcock & Wilcox
,,a and 3 urns & Roe, but the final decision-making process in every case rested with Burns & Roe, who had that 25 1
E EN.JAMIN R EPCRTING S ERVICE
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5: evens 2c 3
responsibility.
4 Q
is it your opinion that Burns & Roe was 5
clear about the fact that they were making final 6
decisions?
A Yes, and they so stated in a letter to S&W t
in April of 1969.
8 Q
- s'that one of the letters that we have 9
before us?
10 A
- believe not.
11 Q
Do you have a copy of that letter?
12 A
I do not have it here in this room.
13 Q
Do you have it available to you where you 14 can find it?
Y***
15 MR. ROCKWELL:
May we please have a copy of that.
17 l
MR. EDGAR:
We will produce it.
18 Q
Mr. Stevens, do you recall who wrote the 19 letter and to whom it was addressed?
l 20 A
No.
Normally, letters between auras & Roe and l
21 B&W were addressed from the project manager at Burns on
& Roe to the project manager at B&W.
I assume this 1******
th***f *** $ 11 **d thi" **** #*tt****
3 Q
You were the project manager at B&W7 A
No.
The project manager to which I refer was 25 S EN.JAMIN REPCRTING 5ERVICE
1 0
Stevens 21
~
3 the project =anager for the TM: project totally.
4 Q
You were the project manager for the 5
control room design, is that correcu?
A My : le at M: 2 was the manager of :nstrumentation 6
i and Control Section, responsible for all instrumentation 7
and control systems, which included the design of 8
the control room as one of many responsibilities.
9 Q
Were you involved at all in a decision 10 to change the window in the pressuri=er water level 11 indicator to narrow the window from what it previously 12 had been?
Are you familiar with at at all?
B A
If you can continue with the question, I may he able to answer it in more detail.
14 9
I*
- "Y ""d*"***"di"9 th** ** * ** P i"*
15 the range of level in inches shown on the water pressurizar level indicator in the control room was 17 narrowed to some extent and that that change was 18 then incorporated from that point forward in all 19 B&W designs.
I 20 Are you familiar with that change at all?
21 A
I was responsible for the instrumentation and
.E' control systams throughout the entire period when we 33 were developing the instrumentation for the steam g
genernecr.
We modified the instrumentation on the steam generator several times before the final 25 S ENJAMIN REPORTING SERVICE
l 1
o Stevens 22 3
arrangements were selected.
4 Q
You reali=e : am referring to the 5
pressurizer?
A Ch.
I am sorry.
I am answering the wrong O
question.
t The same thing is true of the pressurizer.
8 The pressuri=er instrumentation was modified on a 9
number of occasions as we were developing the con-10 captual design, which began in approximately 1965 11 or 1964.
I do not, however, recall specifically the C
details of the change to whic'h you are referring, g
which is the narrowing of the window.
In the design of the pressurizar, there are g4 basically two factors which must be considered.
MR. EDGAR:
Off the record.
3 16 (Discussion held off the record.)
17 A
(Continuing.)
Zarlier you had asked for the 18 name of the Burns & Roe representative with whom we 19 dealt on the control room arrangement.
I have since
~
20 obtained the name.
It is charlie Gotilla.
21 Q
Oid the NRC, during the time period that i-we have been discussing, which is approximately 1968 33 l
to 1972, have any standard of criteria which were 23 applicable to control room design?
24 l
A No.
3 SENJAMIN REV mNG SERVICE w- -..,
.v.,.---w.,.
-,,..-..m...,.,
1 n
Stevens 23
~
3 Q
Were there any standards that you were 4
required to meet other than those standards which 5
your respective organi=ations set forth, i.e., surns
& Roe, Babcock & Wilcox, and possibly Metropolitan 6
Edison?
s A
Sefore answer this question, I would like 8
to clarify.the answer to the previous question in 9
the sense, no, with regard to arrangements.
There 10 were many criteria that the NRC applied to control 11 rooms, for example, in the area of ventilation and 12 isolation and the ability of the operator to continue E3 operation in a radiation environment in the plant
- 14. itself.
Q I am talki.ng more about layout.
la.
A No criteria regarding the layout of the control room from the NRC.
17 with that clarification, could you repeat the 18 last question.
19 (Record read.)
20 A
No.
21 Q
Referring to the period, 1968 to 1972, N1/
was there a standard design in the industry for panels ag or control rooms?
3 A
No.
24 Q
Who selects the light color logic in the BENJAMIN t4 EPCRTING SERVICE
1 o
24
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Stevens 3
design that was finally used at TM: 2?
4 A
The architect-engineer, Burns & Roe.
1 5
g oo you understand the basis or rationale f r the light color logic that was selected by them?
6 A
Yes, I.do.
.t Q
Could you explain it.
A The logic behind their arrangement was that 9
all things which were considered either c. or open 10 would be colored reds all things which were off or 11 closed would be colored green.
The operator could 12 therefore determine by looking at the console when L3 he saw it red, it was on or open, and when it was 14 green, it was off or closed.
- P'#*i**1** ****d**d L* *
- f 11 "*d DY 15 all utilities, but it is one standard which is 16 commonly used thronghout the industry and was not in 17 disagreement witt the criteria that was set by B&W 18 for its own simulator in Lynchburg.
19 (Continued on Page 25.)
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on 23 t
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Stevens 25
- , s 6.1 3
Q Just so : get it straight, green is off 4
or closed?
A Yes.
O Q
To some extent, the selection of those colors for those indications might be considered to be centrary to normal human experience in the use of 8
colors red or green for such simple things as traffic 9
lights, for instance?
Do you have any reaction to that?
10 l
A Yes, I have a personal reaction to that.
11 Q
What is it?
12 A
There is no question in my mind but that consis-g tency is a thing which an operator needs to do his job best.
It makes no difference whether that consistency consists of a set of crit (
ea set up, like red and la, green for traffic lights, green meaning go and red 16 meaning stop, or whether red means on and open and l
17 green means off and stop.
The important thing is 18 consistency, so that when the operator is presented 19 with e_
noerational situation he can look at the board 20 and say the consistency that I see here is consistent 21 with my understanding of what red and green mean.
xx Q
How about his consistency of how he inter-33 i
prets red and green at work and how he interprets red and green away from work?
24 A
- find no conflict in that situation at all.
25 SENJAMlN R EPCRTING SEMvicE
1 2
Stevens 26
'6.2 3
The human body adapes to his environment and the situa-tion he finds himself in.
When he spends eight hours 4
each working day working in an environment whers red
,a means one thing and green means another thing in the 6
work environment, this should not be for him a signi-I ficant operating problem.
8 Q
The design of the simulator which you 9
described in your initial narrative, you indicated 10 that that was the product of the collaborative efforts 11 of Babcock & Wilcox, 3echtel and Sacramento Munic' pal Utilities District, which is a utility, is it not?
13 A
Yes.
Q And Bechtel is an architect-engineer?
14 A
Yes.
15 Q
In that design process were any outside 16 experts brought in, in the area of what is known as l~
human engineering or man-machine interface?
18 A
No.
19 Q
was there any consultation during that l
20 design effort with people who had worked or had experi-f ence with the design of control panels in the aircraft
(
q
?
q; industry?
A To the best of my knowledge, no; certainly with 03 3&W the answer is no, and I do not recall that those I
04 on the team of 3echtel and Sacramento Municipal l
n-
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Stevens 27 3
Utilities District were fa=iliar with aircraft industry 4
practices, but it is possible.
Q Was there any consultation with people o
familiar with control panel design or cockpit design in the space industry?
7 A
No, with the same qualifications that I have just 8
given.
9 Q
As one w-has been involved in control 10 room design, do you think that it would be useful to 11 see what lessons might be learned by consultation with 1
12 people having experience in aerospace cockpit cont cl g
panel design?
A I will answer the question as engineers typically answer questions by saying you can always learn some-thing from somebody if there is something you are not 16 j
doing or they are involved in something that you are not 17 involved in, but it is my opinion that it is extremely 18 difficult to adapt aircraft and space technology to 19 the utility industry particularly with regard to 20 layout and size of equipment because the aircraft an1 og space industry are forced to concentrate all the infor-C.
mation in front of a seated operator who never stands, who sits for a finite period of time whereas the operators in a power plant are at their seats eight 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, are free to nove about, and the equipment must 25 SENJAMIN R EPCRTING SERVICE
I n
Stevens 29 3
he maintained periodically and they mus have access 4
and, therefore, the compression of instrumentation and control equipment into a very small space is not a
forced upon the utilities and, therefore, I believe it would be unwise to do so.
The one thing which the industry, the aircraft industry, I think, can contribute 8
to power plant control room design would be the 9
conventions for direction of motion of equipment such 10 increase is up or to the right or forward and as 11 decrease is to the left, backward or down.
This type 12 of convention, I think, can very well be carried in g
the power plant because it lands itself to logical human responses to amargency situations.
Q The views you have just expressed would la, not limit the value of what could be learned with 16 l
respect to information display, would it, and the i
17 technique for information display and presentation?
18 A
The display of information to the operator even 19 in the aircraft industry changes. periodically.
re: a 20 long period of time the aircraft industry dealt with 31 meters which rotated clockwise and counterclockwise.
l There was then a long period of time in which vertical s-r motion meters or thermometar-type instruments became 03 quite popular, and there is todcy a trend away f cm 24 that kind of instrumentation back to the things which 25 EEN LAMIN R EPCRTIN G 3EMVICE
1 2
stevens 29 3
go clockwise and counterclockwise because in many 4
cases they do not get the kind of response from :aa operating crews that the designers intended.
3 Therefore, it is not always possible to draw the
,0 conclusion be'cause the space or the aircraft industry I
does it, that it is always right and correct and, 8
therefore, immediately adaptable to the power industry 9
which 1.
concerned with equipment which must last for 10 many more years than the design of aircraft equipment.
11 Q
- don't think my question suggested that 12 what the aircraft or aerospace industry does is g
always right.
The question is, rather, the concerns N
you expressed about sizing do not limit your ability to examine usefully the --
A No.
16 the types of information display and Q
17 presentation mechanisms employed in the aircraft and 10 s; ace, industries to see what may be useful or applic-19 able in nuclear power plant control rooms, does it?
20 A
No, I think that statement is correct.
It does 31 not limit our ability to look at those concepts.
I believe, however, that experience has shown that those concepts can be applied to power plants only in a very limited way at nost.
24 05 S EN.JAMIN R EPO RTING SERVICE
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o
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stevens 30 3
Q Do you know of anyone or any organization 4
or institution which has taken a comprehensive look 5
at the available technology for control rooms, in 6
terms of human engineering, man-machine interface, 7
and evaluated what if any application or use it may g
have in the nuclear power plant control room setting?
A I have no knowledge of such an organi:ation 9
because I have not been actively involved in instru-i mentation and control room design since 1974.
I 11 believe this question should be addressed to someone 12 else for answers.
U Q
Who?
14 A
Mr. Castanes would be in a better posit.'.on to 15 answer that question than I because he is cur:ently 16 active in the design and specification and procurement of instrumentation and control for B&W today.
1 4 Q
Did the design you came up with, with Bechtel & SMUD for the simulator and for SMUD itself 19 involve a sizing down of the control room panels and 20 switches f:om the conventional size that had generally ns been used before that in power plant control rooms?
~
20 A
Yes, and again I must give a qualified "yes" 23 because there has been a large spectrum of power plant og control room designs from the very large to the very
- 1 h*
d**
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~
5tevens 31 3
smaller than the larger designs, but by no means was it as small as the smalles: designs that have been 3
used in special design applications in the power 6
plant industry in-previous years.
7 Q
Do you have any understanding as to why the choice was made by Burns & Roe to go with a g
1arger-scaled control room at TMI 2 than the scaling 9
of the control room which would have resulted from 10 t
l adoption of your simulator design?
11 A
No personal knowledge.
la
~
Q Do you have any impression as to why U
that choice was made, or any opinion?
l l
14 A
My opinion is that the utility industry is by 15 nature a very conservative industry, particularly 16 where operation of the plant is concerned, because of their obligation to mect the demands of the l,a j
electrical grid and the inability of the utilities 18 to store electricity, and it therefore must be 19 generated when it is demanded.
20 The utilities, therefore, tend through their 91 consetracism to be somewhat slower in response to W.'
22 the state of the art for fear that in adopting the 23 state of the art, they will. create a problem in o4 their ability to respond to the network, and so they tend to move slowly, and control room design is one
,a, SENJAMIN REPORTING service
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Stevens 3I 3
of those areas in which they 'trye traditionally 4
moved slowly, and you will find = ore control room 5
consoles throughout the utility industry which lean 6
e ward the e neept that what was used at Three Mile Island, that is, the large pistol-grip switches to
.i operate pumps and somewhat smaller switches to operate valves, simply because that is the way it was 9
done before, and it worked, and with no motivation 10 to change it and a risk involved in changing, they i
11 tend to stay with it.
12 There is a second factor involved, and that 13 is that the operators themselves tend to keep control
\\ '
14 room designs somewhat they way they are because an 15 operator inherently says to himself, "When I am 16 starting a big piece of equipment, I like to have a big handle in my hand, and I realize the consequences 17 of my act when I do it, and when I have something that is smaller, I like a slightly smaller switch,"
19 and many of the trends and changes in control rooms i
l 3
I to w14at I would call miniaturized equipment have n,
been resisted by the operators because they lose
's on this sense of perspective of big equipment versus i
23 little equipment, and I know from personal experience 24 in Germany that they have gone to ultraminiaturization
'" * "***1
""d h*"* D**^
- d Y
- h*
P*#*****'
25 i
S EN.JAMIN R EPCRTING SERVICE
1 I
o Stevens 33 3
reactions to this ultraminiaturization, which in the 4
worst case involves the starting of very large pieces 5
of equipment with a switch a quarter of an inch in d i. a m e t e r, and the operators rejected this and said, 6
"We must have something larger."
t They also rejected the very small indicators 8
which went with this concept and asked for large 9
indicators so they could see the critical and important 10 measurements without reaching over the panel and 11 squinting, so that there is no magic in reduction 12 in size from the operator's point of view if you D
carry it to the extreme, which is to reduce it down to the point where it is all cramped together and g4
- "1*Y
^ * ** ^9 15 what you have, so the operators have resis'el this 16 for these reasons.
17 The utilities have resisted this because of l
18 their conservatism, and it is my opinion that Burns 19 s Roe were simply reflecting that type of conservative 20 approach in consideration of the operators' opinion 21 from the past.
E-(Continued on Page 34.)
an l
r 24 S EN.JAMIN REPCRTING SERVICE
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Stevens 34
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g Here in this country, do you have any 3.1 4
specific examples which would illustrate the point you made that operators have resisted miniaturication?
.o A
No, I can't cite any specific examples.
I would have to say that there is a general impression wh'ich I
has been derived from a look into the control rooms of 8
many different power plants over the years, and is not 9
based upon any single power plant or any single conver-10 sation with any individual utility, but rather is the 11 summation o f a look into many power plants over many 13 years of experience with the power business.
Q Do you have a personal opinion as to th e,
g I
and I use the term advisedly, the usefulness o r the 14 value or the appropriateness of the SMUD design in contrast with the TMI 2 design?
16 A
Yes.
17 Q
What is it?
l 18 A
This is a personal opinion.
I believe that the 19 design of a control roca which looks more like the 20 Rancho Seco design or the simulator design, as the case 31 may be, is easier for one man'to operate during normal
[s operation of the plant because the one man can scan within the breadth of his arms all of the information 23 that he needs to verify that the plant is operating 24 properly.
When you get into emergency situations, 25 BENJAMIN R EPORTING SERVICE
o 1
o Stevens 35 3.2 3
every utility plans to brtng into the control room 4
supplemental personnel.
They may either be already in i
the general area or quickly available on call, and any 3
control console which does not provide enough roca for these additional personnel to gain access to the i
panels and the information which are necessary to 8
~ assist the operator through this period permit them to 9
of emergency, this reduction in size to that point 10 would be der.rimental to getting the pla.7t through the 11 emergency situation.
10 Conversely, during that same emergency a panel i
g which is spread out over a very large area, and I think it is very difficult to define what the word "large" means, becomes sore difficult during normal operation la, for a single man to scan, and during emergency opera-16 tions requires more people to maintain a safe operating 17 condition.
18 I,
therefore, believe there is an advantage to 19 reduction in size, but that advantage would be very 20 difficult to measure in quantitative terms.
It is a 21 qualitative matter, and if you consider the number of C-power plants in the United States whose control rooms g
are large and whose equipment instrumentation and control equipment is laid out on large consoles and 24 panels and their records of operation, I doubt
.n -a SENJAMIN R EPCRTING SEWICE
1 2
Stevens 36 3
seriously that you would ever be able to find any 4
quantitative measure to verify this very qualitative feeling that I have that it would be somewhat easier a
to operate when it is slightly smaller.
Q I take it in your view that the SMUD design, 7
given the various factors that you have been describing 8
to us, represents an optimum design?
9 A
I could not'say that it is an optimum design.
10 Q
I meant with respect to size?
l 11 A
Dh, size.
It is cotimum to this extent:
It can l
12 be operated by one man during periods of normal opera-13 tion and yet it all ws additional personnel access to both the consoles and the panel during those periods when emergencies can be expected such as startup and la, shutdown without cramping the ability of those addi-16 l
tional people to gain access to the controls that they 17 need to assist the operator during those periods of 18 time.
If it were much smaller it would begin to cramp 19 the additional operators and to that extent I do 20 believe that design is optimum.
1 21 Q
Do you think simic busbars or simic busses Es have value?
on A
My personal belief is, yes, in certain circum-stances, but not in e very case.
24 Q
How about for TMI 2? -
25 EENJAMIN R EPC R* LNG SERVICE
1 2
Stevens 37 3
A There is a mimic panel at TM:
in the makeup 4
and letdown area, and I believe that simic is helpful to the operator in operating that portion of the a
system.
F Q
How about mimics in other areas of the e
system?
8 A
I don'*. like to generalise with respect to this 9
particular subject, but I don't know any other way to 10 answer the question.
11
- is my belief that mimics can be helpful to 12 the operator in certain cases but every operator becomes used to the conditions to which he is exposed 13 in any control room, just as any pilot becomes used.
to his aircraft and any automobile driver becomes used la, to his automobile,' and the existence or the non-existence 16 of a mimic panel in my estimation is not a significant 17 contributing factor in the ability of the operator to 18 do his job better when he is familiar with the control 19 room arrangerent.
It is, however, extremely valuable 20 for new operators who are not familiar with that 21 particular control room who have, perhaps, been C'
trained on a simulator which is a different arrangement 33 and it helps him to realize the relationship between the controls and the system that he is controlling, 24 but once he learns that relationrhip the mimic really 25 S ENJAMIN R EPCRTING SERVICE i
1 3
Stevens 37~"
3
- ontributes no longer to his ability to de the job.
4 t is simply a re=inder.
(Continued on following page.)
5 6
7 8
9 10 11 l
12 13 14 15 16 17 18 19
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on m
24 "5
g ENJAMIN R EPCRTING SERvlCE I
SR 9 le 1
2 Stevens 33 3
Q How do you apply all that o TM: 2?
A I apply it to TMI : only to this extent:
The 4
simic panels which are there are limited to only one
,a area of the console.
6 I do not believe that the addition of that one 7
mimic makes a significant contribution to TM: 2 in 8
the overall.
It could be deleted without seriously 9
hampering the operations of TM: 2.
10 conversely, more mimics could have been added, I
11 for example, in the feedwater area without signifi-cantly improving it.
gg As I said a moment ago, my feeling is that the new operators are the ones who benefit the most 14 from mimics, and I do not know, and I am not aware now, 15 and I never was aware how many operators which enter 16 l
the TM: control room represent new operators versus 17 those people who are experienced with the operation US o'f the TM: 2 reactor.
1 19 Q
co you know whether operators were con-sulted at all in the design of the TM: 2 control room?
3 I
A No, I do not.
Q Am I correct in understanding that on a reactor trip, you may have a number of alarms which 23 come off or which sound simultaneously?
e4
~
A Yes.
25 Q
Those alarms are received and silenced S ENJAMIN R EPCRTING service
I 1
0 Stevens 39 3
all together by the pressing of a single acknowledge button, is that correct?
4 i
A That is =y understanding of the TMI control 3
console.
I believe the acknowledge buttens are on 6
the central console.
I am not aware of any other acknowledge buttons on any other console.
- However, 8
there may be some in the turbine area.
I do not have 9
specific knowledge of that, since we were not respon-10 sible for the design of the turbine area.
11 Q
Is that method of acknowledgement something 10 which B&W would concur in as a matter of design?
g A
I can't speak for 3sw in this matter since I am no longer responsible for this area.
74 15 Q
How about at the time you were responsible?
A At the time when I.was responsible, I believe 16 that we carried out multiple acknowledgement buttons 14 in the plant, yes, in the plant where we were respon-18 sible for the design, so that only a section of the
~
19 simulator was silenced with the acknowledge button, "O
leaving the other sections still active.
t n,
However, we did not at that time have any
[
00 objections to a different philosophy.
We were aware 03 on ;x! : that the alarms were silenced with a single 34 button, and it did not cause us auf concern.,We did not at that time object, and no thoughts of alarm were
,c_
E EN.JAMIN REPC RTING S ERVICE
i i
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1 1
2 Stevens 40 i
3 raised in our mind as a result of the decision on 4
the part of the architect-engineer to use a single 5
acknowledge button.
6 Q
Was any thought given in the design of the control room of TM: 2 to the situation which might arise in a serious emergency where literally dozens of alarms might be sounded in the space of a 9
few minutes, and the capacity of the operators in 10
(
such an emergency to absorb and make sense out of a 11 substantial number of alarms sounding within a very 12 short period of time.
G MR. EDGAR:
Could you read the question i
14
.back.
(##***
"* 9"***i * "**
- d D****'
15 A
.To the best of my knowledge, no specific cttention was directed to this particular phenomenon II
. on the part of B&W.
I cannot state that it was not 18 considered by Burns & Roe in their design of the control 19 room because I have no knowledge of their intent no:
20 their concerns between themselves and Jersey Central 21 or Met Ed. -
gg Q
n light of the TM: 2 accident, do you
- hi"* *h"* *h'* l' " **Di'** "hi*h ***1# "**f*1 7
23 he given some attention?
A res.
25 S ENJAMIN R EPCRTING SERVICE
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Stevens 41 3
Q Do you know whether the B&W design that 4
was submitted and ulcimately recommended to Burns 3
& Roe included indicatien of high-pressure injection 6
flow on the front or the back of the main console?
A It was on the back panel in the same area as i
the engineered safeguard equipment.
8 I should further clarify, however, that this 9
engineered safeguard panel was located immediately 10 behind the equipment for operating the pumps, so 11 j
that the operator could see'that in the same l
12 position as the pump operation.
13 (Continued on Page 42.)
14 l
l 15 16 17 l
18 19 l%)
21 7
03 04 05 s EN4 AMIN R EPC REN G SEnvicE
1 2
Stevens 42 sr/ow 3
Q Can an operator standing at the main 10.1 4
control console read HPI' flow as measured on the back panel?
O A
I do not know the answer to that question because I have no knowledge of the specific location for high I
pressure injection flow on TM 2.
I know only that 8
it is not included on any of the panels which were 9
supplied by 3&W.
10 Q
Are you familiar enough with the TM: 2 11 control room design --
12 (There was discussion off the record.)
g Q
Do you know why the high pressure injection flow gauge was not on the panels supplied by B&W in light of the fact that high pressure injection flow is la, clearly a component within the scope of. supply of 3sW7 16 A
- have no specific knowledge as to why it was 17 not located on these panels, but I do know that this 18 omission was specifically pointed out to Burns & Roe 19 in response to the designs which they sent to us.
20 ER. EDGAR:
Also I would like to raise a al point of clarification.
I don't believe there i.
is any factual basis established to say that 3&W
,o.
r supplied all of the HP: equipment.
There are breakpoints and interfaces in that scope cf 24 supply.
05 S EN.JAMIN R EPORTING S ERVICE
i 1
2 Stevens 43 13.2 3
(There was discussion off the record.)
4 THE WITNESS: Referring back to the issue on one of the previous questions of the location 0
of the indicator for high pressure injection, we 0
noted as Item 5 in Exhibit 85, that the indi-s cators for high pressure injection wer's not 8
t shown by Burns & Roe on their drawings of Panels t
l 9
3, 4 and 14, and we stated, "It is assumed that 10 these will be mounte d on the engineered safety 11 features panel".
12 Q
Do you'know where the controls in the TMI 2 control room are located for the HPI throttle g
valves?
A No.
i 15 Q
Are you familiar enough with the TMI 2 16 control room to tell us whether the auxilliary system l
17 panel was installed as or per the recommendation that 18 3&W made?
l 19 A
I need a clarification of that question before 20 I can answer.
Do you mean th e auxilliary panel which we supplied as panel No. 3 or do you mean another panel, 31 l
C which was supplied by Burns & Ros?
Q As you supplied it.
A Now would you repeat the question?
2%
(Previous question was read back.)
25 SENJAMIN R EPCRTING service
1 2
Stevens 44 3
A I believe that the question is still not clear encugh to be able to answer it in a meaningful way.
4 The recommsndations for the auxilliary panel which a
3&W made are reflected in the drawings which S&W 6
submitted to Burns & Roe.
7 (There was discussion off the re co r,d. )
8 Q
Mr. Stevens, the nine drawings identified 9
as Stevens caposition Exhibits 73 through 81 were, as 10 I understand it, transmitted to surns & Roe initially i
11 for information purposes, and those drawings show the 13 design of the B&W simulator and SMUD design, is that correct?
g A
Yes, that is correct.
14 Q
And that subsequent to their transmission 15 to Burns & Roe for information purposes, B&W took a 16 position that it was recommending adoption of those designs for use in the TMI 2 control room, is that 18 also correct?
19 A That is also correct.
20 Q
And, therefore, if we wish to determine to what extent those designs were incorporated in the gy qs ultimate TMI 2 control room, it would simply be a
~
l matter of comparing the drawings to the control room l
23 l
as it exists today?
24 A
That is correct.
25 SENJAMIN R E;8CRTING service
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Stevens 45 3
Q Mr. Stevens, have you made any statement 4
in connection with your knowledge or understanding of events surrounding or arising out of the TMI 2 acci-O dent, and by " statement" I mean anything that 6
you wrote or anything that you said that was reduced to 7
writing?
8 A
No.
9 MR. ROCKWELL:
We are going to recess your 10 deposition at this time, Mr. stevens.
We are 11 recessing it in order that we may recall you 12 f r further testimony should that be necessary.
We don't anticipate it will be, but we can't be g
sure.
That is why we are ecesssing it.
Thank you for your cooperation.
15 (The deposition adjourned at 9:05 p.m.)
16 17 Howard Hartman Stevens 18 19 subscribed and sworn to 20 before me this,,,,,,,,,
21 day of,,,,,,,,,,,,,,,,_
22 1979 3
34 Notary Public 25 SENJAMIN REM:RTING SEnvtCE
1 e
46 3
2-N-D-E-X 4
Witness Direct 5
soward sartman Stevens 3
6 7
E-x-s-I-a-I-T-S g
9 STEVENS DEPOSITION 10 IgR,jDEHII{IggIjgN g39E 11 70 Resume of soward Hartman Stevens 3
12 71 B&W Jtandard Guide Specifica-12 tion for cont:o1 Room Design Criteria dated December 20, g
.1968 14 72 Drawing submittal form from 12 Babcock & Wilcox to Burns & Roe 16 dated November 7, 1968 16 73 Drawing No. 136027 12 17 74 Drawing No. 136025 12 75 Drawing No. 136024 12 gg 76
" Drawing No. 136023 12 77 Drawing No. 136022 12 20 78 Drawing No. 136021 12 21 79 Drawing No. 136020 12 80 Drawing No. 136019 12
~~
i 1
l 23 81 Drawing No. 136026 12 24 82 Detter dated December 13, 1968 12 to Surns & Roe from sabcock 25
' Wilcox l
EENJAMIN REPORTING S ERVICE
1 n
E-X-H-I-3-I-T-S 46-a (Continued) 3 4
STEVENS DEPOSITION
{gR,jjjjjjjjggjjgg
((gj 5
83 Drawing No. 30755 12 6
84 Drawing No. 30756 12 7
85 Letter dated August 5, 1970 12 from Babcock & Wilcox to 8
Burns & Roe 9
10 11 12 13 14 o0c 15 16 17 18 19 21 s,
23 04 3
E ENJAMIN R EPCRTING SEMvicz
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47 l
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C-E-R-7-I-F-!-C-A-T-E 4
STATE OF NEW YORK
)) ss:
COUNTY OF NEW YORK
)
.o We, ROBERT SERKIN, a Notary Public of the State of New York and STANLEY RUDBARG, a Certified 7
Shorthand Reporter and Notary Public of the State of 8
New York, do hereby certify that the foregoing 9
deposition of HOWARD HARTMAN STZvENS was taken before 10 us on the 5th day of July, 1979.
11 The said witness was duly sworn before the 12 commencement of his testimony; the within testimony was taken stenographically by ourselvas and then 3
transcribed.
The within transe.ript is a true record of the said deposition.
16 We are not related by blood or marriage to 17 any of the said parties, nor interested directly or 18 indirectly in the matter in controversy, nor are we 19. in ebe employ of any of the counsel.
20 IN WITNESS WHEREOF, we have hereunto set t
our hands this 6th day of July, 1979.
l 31 l
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_ p,os_ERT_ _ _ _ _ n _y:+_ _ _
23 R
- ERK:N
_ &_ _ _ W _ _
W _ f_ W n.
STANAEY RUD3ARG, CSR 25 E ENJAMIN REPCRTING SERVICE
o
[
i L
/
WA J
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6 Resu*ie - Howard H. Stevens I a-Newa rd.H. S tevers, a ** '--* * '"-** * "* ager i n tn* W ' * * -
..i..
s-J.
.-.a.---
- a.
! j:inec ia:Co:A e..-.e-...
,e and iiilecx in.943.
- am a g-acaate of Su-cue ' -' v4-sity wi tn a B.S deg te in me:nanical engireer1ng. and nave ::me:ec accittenal stucy in i
reactor c:ntrol Onecry at :ne University of Virginia.
oower Generation W first assipment was as a se*vi:e engiree-in :ne Divisien res:ensibie for start u: an: treu:le snocting cf f:ssil fuel l
firac boile-s for the utility and Orc ess incustries.
I joined the
v "dv rie ia 'c?? M an instrumentation and a
[
control engineer aE: ce:a e sume-visor of :ne nce nuclear instrur.entatice t
grou: in 1956, and ranager of tne instrumentation and ::ntrol unit in 1960, f
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i I transfer-ed.t: Ba::cscr *rewe 5:verd :e!K::r T'SH, a S&W su:sidiary J
in Mannneic' West Ger any in 1972 as ce uty manager of tne *&
Se:: ten anc was rescensi:le for es:aolisnment of tne se::1:n miring and training f personnel and ne a:clication of 5&W te:.nci$cy to ne cesig cf r.an x
nuclear clants. I bees e :nanage-f !!R/E&W inte;-ation in 1974 and continued
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in tha: ;ositica as a !!R manager after re:u n :: the USA in 1975, t
In 1975 I transfernd ba:k :: B&W.5?C and te:t e international g
program r:anager 'er license agreemeat:. In 1978 I transfer-ec to rv present positi:n as a Regicnal Business t*.anager in the Nuclear Parts Center'.
y I was born in Cleveland,0 hic in 1925. ! =resently resice at ISIS Club Orive in Lynenburg, Virginia.
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j Q BABCOCK & WILCOK POWER GENERATION D: VISION NUCLEAR POWER GENERATION DEPARTMENT e
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STANDARD GUIDE SPECIFICATION 5
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ISSUE DATE:
- .c mer 20, uss SPECIFICAilON NO. :::g/ :gs 6
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Tc11oving ;reven power stati== desig: ; 11:s:;ty, cen r:1~ staticas, swit: ss, centr:11ers, irdienters a:4 c 2 er i.fe : :ica dis;1sy as:essar/ te sta-tu;,
l operate, a:d shutdw std1 be ic:sted in the :::d. re:-
Tigure ' sn vs 2e l
re=== ended arra:gese: cf the ::::::1 :::: mai: :::scle a:d ;st.ek oc-*f'A'*f i
ne ecstrol ro== shall be desig=ed so that c:=;ane/ ef *be c:tr:1 re= during 1
absor:21 conditions will te per=issable. Aderaste stieldir.g shall be used ::
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I maintain tclerable radiatic: levels in the ::= r:1 ree: f :.-ard "- :y;ctheti:11 l
l a::ident sc:diticas. Se istegrated dire:S d:se r/= all sour:es of radiati::
to Ocntrol rec: persensel verr. g c: 6. hour stifts durir.g a 9;-d17 perted f=11.-ing a =axt== hy;= te*.1:a1 a::ider, stall :: ex:eed 3 rem (. :hiit; I
ingress a:d egress), vtith is a;ner.':stely the yearl~ rearter.dsse ;e.:1 ted I
in 10 OTR 20.
ne ventilatica systes a:t other :o::e:tices he:veen the : ente:1 re : and areas i
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of potential fire shall be designed te =1:1:1:e t e pessibilities of fire er s=oke fr== rendering the ecetrel roe = "-'--e:itable.
Tae ec::: 1 :::: vesti-j ej latics syste shall be ;r=vided with radiatica dese::::s and a ;-c;ritte alar:s.
l Provisicas shall be =ade to re:ir:ulate ::::: 1 ::c.- air ste: ugh mos:h:c a:d l
char::11 filtars, 4
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Sreathing a;;arst2: and ;-ete:tive :hthing shall be ;-evided to per=it I
1 conti:ved access in the c =tr:1 ree: area curi:g ;erteds of s che and high 4
temperature at: mise during periods of tigh aire:rne ;arti:;1 ate ::::a:izatic:.
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his r.sy be different types cf equi; tent.
l Ersatting ap;aratus and c2er prete:tive erci;:ent f: radiatics ha:ard: stall be provided fer persennel entering er leaving the ::::::1 ro:
,A escape g
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- ards) shouli be ;revided.
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Se 73tectial magnitude of a fire in the control ro= ^=" te limited by the
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fallazing fa::, ors A.
Control rec = =ceztru::1:n shall be of =:::tustnie sterids.
3.
Cont =1 = ables and swit:ht:ard wiring shell te c=structed cf r.aterials that have passed tae fis.e tes as described in bsulated ?cwer Oatie Dgineers Associatic: Pabli:stic: 3-61402 and !!atic a1 T.lectri:a1 Manufacturers Asso:12tien Patil:stics W:$-196L C.
Partiture used in the :::: ci r:c= should be of metal co'est:2:-ica.
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7 Storage for combustible su;;1ies su:t as h gs, ree:rds, precedures, assuals, e :., shall be 11:ited to that retaired for plant c;erstic:.
O ISSUE DATE: :ecenser 20. 1958 PAGE.1 SPECIFICATION NO. 2:13/1255 i
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All ar<.as cf Oe ::::- 1 re= s:all be readily a::essible fer fire ex.1:taisair.g.
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Ade faate fire ex.itraissers shall be pr=videf C.
Equi;:ent to pe=it==ti=ued c:: pss:y of the==te:1 roo= d=ing periods =f emerges:7 shall be provided.
I The necessary fla==able catorials should te distributed se cat a fire voeld I
be limited and " **>e20* to *; read. f erefore, a fire, if started, veuld te
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j of su:t s.all : gritude -ta: 1: ::uld be extiaraissed by the c;srater u:is; a 8
tard fire extincaister. The resulting steke a:d vapers veuli be re cved by I
tse ventilatics s/ste-.
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The cct:rci roo= should te desis=ed to the icilowing P=: tic:a1 criteria:
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"he t=:::1 roc: shall be air-e =ditio ed to aintain -ne - :rliti=s d
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1 of 257 and t=,idity to if 71
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C:: rel ro= lighting shall be provided fr= we ret =ta:. ;:ver so=:es and bat *ery c;erated emerges:y lightieg.
C.
Plast telept::e a:d ; aging systems shal* be ;revided with redunda.- ;wer g
su;;11es t: ;rovide c=tr:1 roc: c;erater 4th constant o:=-mica ics with all areas of the ;1an f
- Cc:::01 roc. sh=uld :::tais all :csticis and isii:sters requirei f:r m
A 10:a1 8
plan: startu; ar4 stutt.:rin pert = =ei reralarly by the operator.
k centrol svitch adda:en: to Oe equipme:: is ::: repaired where ec::::1 equi;=ent is ;-ovided in the to= trol roor. Oc:: ci switches that are used or.ly for :tistenance, infrequent tez-ing, ;- for the ec :::1 cf
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lo:11 sub-systems may te lo:sted near 2e etaiy..ast, in the relay r:c=
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f or 1: "betind panel" space 1: the ec:::ci roc =,
T-Control legi: :abiness, a=;11fiers, ::ansdu:ers : d :th?r auxilia:/
der.:es s::rald be 1 :sted separate fro: c e ec=: 01 coc. :: sole and panel and ou::ide of ths pri=a:/ :==:r:1 area to =i:*=1:e interfere::e i
i beween c;eratic: act =aintemce, T.
Arrange cc trols, '_ '* aters, re:crders sad alsr: indicaters i: f=::i=al j
groups and is a f=::ic:a1 seque :e veerever ;racticable.
g Use u. fc :t types and arrange =ents of ::: trol devices for si=ilar Oc:tions i
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l vherever yrs::icable.
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eee.3er 2:, 1868 PAGE SPECIFICATION NO.
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The icile'.ing Ocler : disc is re::= ended f : 'si':stics lig::t:.
White. (1) nacual (2) sig:a1 sele:: (3) ; ver availatis Red
- (1) open (2) star- (3) in:rease variatie.
Green. (*) 01:se (2) ste; (3) de:rease variatie 4
Yellow: (1) Orip (2) r= tact A ber : (1) Aut==ati:
Blue : (1).*pe':ial N ::10:s f-
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1.
Arra ge instr.::e.ts :
-*-*-4 e the si:e of the cat 01 tearis, bu-k provide space for wo er =:re cperators is c:str:1 area adja:ect ::
costr:1 beards.
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flar= iniicat:rs sw" te 10:sted to te visitie end audible fr= the
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entire cperpics area.
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T Meters and indiesters shall be 10:sted se they ::: be f..
'-ved while standing in ecstrei area : retted at sh*ft cperating desr.
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- . Co.tr:1s shall be 10:sted for eperatis;.*-. a standing ; sitior.
L; rtan-b freque:tly used indi:1.crs and :::trols shal. te 10:2:ed Y.
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near the castral cperating ; sitie: c:.he ec= sele. lefiniticas:
1.
- r e-ta-
- j Centr:1s requiring i=ediate attenti = in -he event ef.syste:
upsets er air.:..:::::s. These =catrels sh:uld be 10:sted so that a si:gle cperat:
st. r.aintain an =rderly 0;sratic: =f l
the est, ire statics at ;wer er =aistai: ;1ast :d perse..nel safet/ cver the period cf ti: e after a casualt; and u=.11 other statics help ::: te. ::: ed.
2.
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Weekly t
l T Icette. infrequently (greater than a veek) used :strels and ::=-vital indicat=rs a..d rescreers either c: au.r. ilia y ::str:1 :::scles er ::
rear of vertical panels.
C.
Auxiliary :::trols and indita.=rs shall be ; evided outside the ::::: 1 room to allow cperator: t: :sistai ;1 ant in the het stu.devn ::=ditica if access to the cos:r:1 r=== is 1:s: due.: fire or ther causes.
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!SSUE DATE: :ecenser 20. l us PAGE.:.
SPECIFICATION NO. 2:11/i:C1 i
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- .e.aer 20.
43 PAGE
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$PECIFICATION NO. 2:ut::u Cais:ocA & V, :co g
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BW 13219 E Pla=t Anilie-ics ?atel (*., R 1) 11%23 E h-ineerei Safe-=rce ?=e1 (L R 2) 136C21 I Res Beneter 6 := P=ci (CR) h 136022 I Wrbi=e-Ge:erater Femel (RK 1) 236'."3 E Fle=t Cc 11:q t' ster Panel (ER 2) 136024 E Ele =trica* Evitchi=g Panel (RR 3) 136025 E Cools t tystc= cer.:=1o (10 136C26 I Rec.cter esa I = Os:scic (00).
136c27 I Conde:scte - Toeiv.ter L 5 :t1:3 Gene stor C :: le(?
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Your letter 2:ri:1 ::. h35 St.ted Cetcher 33 to Mr. J.
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regu::ted e-+-ts c= s."?::e12:eri - ?csic Criteris" c::c:. Ohich vas inclu3:1. S.is tscu=sst h:: hee: revieved to acte-1:3 vhi:t er th=s: re:: aire::.ts 1
are ( ) et=d ri. (t) vi. tin::1. at e:e:n cost, er (:) ne c.vanexe.
- 4e are retr.rtic. c:h c* the C::= cut ::rtci (n). (b) er (e) ty en:h req.irma to==.. sri:e the statu.: c.s indic:tci stove.
- eu itic: va eft:r the 7:11oeir.g j
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- .117 *2tcr 0.. ?:=7 does ::t have facilities to c:e== de.te the t&*:- t;;
j c r:.:21s t; :ified. O.cy 23 ;revide 12:qser ; i:t f.r fi=1 eetts.
s (2) Tr.n cost fer :Tecie.1 colcrs or f r white is oric-s. Norra1*7 pstel: a:1 ccbi::as are ;cisted the tz=a ecler cc teth isterier and e=terict.
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4 (2) ? :.1 tert.::::: d:::: do ::t : r.:1171 :1:d2 vent 1*..tir.; lour ::: tr'esvar, tr.2/ c: he pro.d.:J4 c.
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" res :*.ilo I:1::1 r.:d req:. ire c=tra tr: cia cr is :;i: pr vi:ics.
I Partr-.th is (1) Tae stesitri arrange:tr.t vill is:1'de hiley ? ;=h bt:tt::s phs Sm.
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aI P- -- ---:52-(1) Grou=ii=c bus avail:ble at e=tre :est sni v=uli te 2/S" 11/::" hc1127 co;;.
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(1) '"hsse vculd be sts:dard on 7:.21s s.nl **0.1 cabisats, c::tr cc:t f:r 2!! :stin *r.
h e----h L e Special :::eplates ar ***1e at er.ta cut.
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" alls ?': tar 00. - =7 cc 6ct ;rovii: cloth r2preh:itics.
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rec-in7eut est 1*.lustr?.tinc neeps of su;;17 for enti sts asi ect: ole:.
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l I C:s ecstrol dest re: tics 212" ceross the 13:2 x 163" :::::s the frent :1. *1 r to your iter. No. L of Sh:st 2 except ic ter.
i 1j C:s Esin Oc=:cle Daar ?=e159" vid=, similar to yr::: lte: l'.
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Chould you prefer to t:2 e.irsntr.02 of the centrol icycuts d :liestir-the 2"i Six:later Tacility (dre.vi:-:
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21-is e ee.;2ct t.r-:=.p :nt c.ed fees re stre l
j sub:titutics of =1:10 2: (,si'.cy Ty;e 2 ) pu:n tutt:n svit:1122 f== the gr. M:ile j. types. 2e ;ri.:.ry civ=::
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August 5, 1970 b
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700 T.imderr.a:a:s ?:ad Cradell, %ev Jersey 0?fL7 k
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Jersey Ce: rmi ?:ver 1 *.ight : ;a=y "hree 5:ile Island ':u: lear Static. "si:
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i traving: :f ::: r:1 :::s=le se: i::s *:c. 3 a:t 3. i and verti:a1 ;::e1 To. l'..
'j "hese t svi:gs ;1us -he a: a::si !;e:ift:sti:= ":. 11f2/~55-6/077; f::::ur ;r:-
- ure est ps:kage fer this equi; est.
"he ;ackage is 1: ge:ersi agree:ent with 2;r.s asi ?:e desig criteria, Zur:s a:d 2:e layeu irsvings "o.
I!!! *.22, 22 8
a:d 23, and 2;r s and ?:e ::rres; de::e 1::1u11:4 let ers !? 135 3 and 196-2 a:d a tele; cce discussi:: vith y:ur Mr. :::rris Titter== Jdy 1,17 0.
All iters 1:velved have ::: teen res=lved a:d se e vi'*, re uire ^:rther a: i:.
Several =f these are ;:isted :: 57 the ::::e::s tel:v:
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Certal: equi;:e- : u::ed :: ?ssel 3 requires is:1sti::. !::e :f 1
this equ:; e=t s:culd te restri::ed to the IST ?arel, ;arti: larly l
the IS instr =e::s sad s.". : es f:r i:Je ti:= 'E?!) valves :C.* '.".5-A, e
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It is assu=ed t.ut the ::.st::er's e e tri:a1 syste: insigr. vill all:v the use =f : 17 ::e ;s:e1 svit:: f:r "s:are?" items :0-720-:C3 a:t 10 7.*3-7 3 (th:se a::uated by ::: !?A3 sig als;. :::. Titter of 3 urns att ?ce i:ii:sted sta: a se:: 4 ;asel :vit:0 _.ay be required f:r f
the " Shared
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this :sse a see :t swit:: '.".:3 l
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Se 37;3 :ssual 1:itiate and reset svi ches, and X?* a:d L?! ty; ass switches shev: := the Pa:e1 3 layeu* are i=: ended,o reflee: the svite: require =ssis fer the S7A5 :=re:-17 ;r=;esed : J:7C by 3W.
However, these are still c:siderei to to in the custener's se:pe =f l
su;;17 Tisal resolu-i vill defi:itely te required f:: these svi :hes.
5 Se indicaters for E? i=:ectics :n23-C 113 asi :c3-n 2n, are =st shev = Pacel 3. :., er ik.
- is ass :ei that -hese vill be==u=ted on the IST ;a:el.
6.
So valve ;csitie: icii:sters (ref.JO?P. ::=fere :e =ctes No. k?2, Page 6 iur:s and R e letter, Serial :;o. 1162) have been i=:1:ded.
7.
No 1:str=e:tati = g :: 4 tar has bee: is:1 det since the =eed f:r it is not apparest.
S.
No 10:1:sti== fire dete: crs (ref. JO?C ::=fere::e 3ctes ::o. L53, Page 6, Surns a:d Roe Ls-er.c.1162) have been i=:1uded to:ause the ec= soles ami vertical panel are ;e -e: dei asi thus :s e::1: set.
hese ca: te aided if still required.
9 ne ;hilese;ry e ;1:yet e: the :c; syste: '-* '-. valve status 1:11::::
11stis vouli 1:: ate ::e red (valre ;e:) Ligst 4:vnstrea= cf the valve.
S us the re1stive - sitie: Of such lig:ts relative to the switch is reversed vnere -he fi:v path is reversed i: the =1:1=.
Ois s..ould te reviewed.
10 Se feedvater ;. ;s A e. d 3 speed ::str:11ers a:d t=tice ty; ass valves A a 4 3 ::str:11ers.: ave tee: s :v: : ?nsel k.
- 11. Se s;ecifi:stics has =ct required that all ;asel irsvi:gs te 17* x 22" criginal si:e.
(*Je are, heverer, -equesting a tuctatics f:: t.his ite=.)
- 12. No items f:r 317 ietsy heat, ::re "; ?i:g, s;est fuel and i ter=eiitte cooliss syste=s are==usted := Panel 3, '., er ik.
We are :urre:tly obtaising pri:iss fr:: 3ailey Xeter ::=;ary== the tasis Of these drzvi:gs act s;ecifi:s-i::s.
- cs receipt =f -lis ;rt
- isg, ve vill ;1 ace a ?urezase Order with 3ailey vi.h:ut fe:her :harge to the s;e:ift:sti:.s ami iravi:ss. His
- rici
- 4 vill the te related : the ::;e of ::;;17 vai:: vas is:1 dei ' cur crigica.1 32 ::: act Ice;e asi vill also f:r: the tasis f: Pa ser ::arges if amy.
We request ycur a;;reval :: ::=:ests== this ist:::sti::.
Very truly yours, I. 3. "ar?
Pro *e: Ma.sger W h OO
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Mr. R. L. '41111a=s - General hbli: "tilities Ocr;cratics (w/atta::=e:-)
Mr. G. Gray - ::ev York Sales Offi:e I
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