ML19308C574
| ML19308C574 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/29/1979 |
| From: | Helfman S, Washburn B Office of Nuclear Reactor Regulation, PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280604 | |
| Download: ML19308C574 (79) | |
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UNITED STATES OF AMERICA g
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P2ESIDENT'S COMMISSION OF THE ACCIDENT AT 0
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0 if It DEPOSITION OF:
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CERTIFICATE 4
I certify that I.have read this transcript and corrected any errors in the transcription that I have been able to identify, except for unimportant punctuation errors.
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Date:
Bever1/W.Washburn e
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UNITED STATES OF AMERICA 2
PRESIDEN"'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND 3
4 5
6 7
DEPOSITION'OF:
MR. BEVERLY W. WASHBURN 8
9 Rocm 714 10 2100 M Street, N.W.
Washington, D.C.
11 Wednesday, August 29, 1979 12 1:00 p.m.
13
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14 10 APPEARANCES:
16 On Behalf of the Commission 1;
STAN HELEMAN, ISCUIRE Associate Chief Counsel is 2100 M Street, N.W.
Washington, D.C.
19 On Behalf of the Deponent 20 RONALD K. OLSON, ESQUIRE Office of General Counsel
.n U.S. Department of Energy 12th & Pennsylvania Avenue, N.W.
gg Washington, D.C.
23 24 i
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DEPONENT DIRECT CROSS 3
BEVERLY W. WASHBURN 3
3901 Mesa Verde, N.E.
4 Albuquerque, New Mexico 87110 1
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9 10 11 12 13 5 E E 1 5
,I., T S 14 Exh. No.
Description Received 15 1
Resume of Mr. Beverly W. Washburn 3
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Question and response regarding 68 17 (To be operator action and procedures (identified) provided) re safety features termination 18 19 20 21 23 24 25 Acme Reporting Company
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WHEREUPON, 3
MR. SEVERLY W. WASH 3 URN 4
the Deponent, was duly sworn and was examined and testified 5
as follows:
6 MR. HELFMAN:
Would you please state for the record 7
your full name?
3 MR. WASHBURN:
Beverly W. Washburn.
9 MR. ELFMAN:
I see you brought a resume with you, 10 Mr. Washburn.
Would you hand it to me?
11 Is this resume an accurate summary of your employment 12 and educational experience?
13 MR. WASH 3 URN:
Yes, Sir.
14 M51. HELFMLN:
I'd like this marked as the first 15 exhibit to the deposition.
16 (WHEREUPON, the document referred 17 to was marked for identification 18 and received as Exhibit 1 to the 19 Deposition.)
00 MR. HELFMAN:
Have you ever had your deposition 21 taken before?
22 MR. WASH 3 URN:
Once.
23 MR. ELFMAN:
Was that in connection with your work?
24 MR. WASH 3 URN:
A patent case.
25 MR. HELFMAN:
Let me describe to you very briefly Acme Reporting Company i
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some of the characteristics of the deposition that we are going 2
to take today.
3 Since your testimony is sworn, it will have the same 4
force and effcet as though you were giving it in a Court of 5
Law, even though the deposition is. being taken in the relative 6
informality of an office here at the President's Commission.
7 For the benefit of the Court Reporter it is necessary for you 8
to wait until I've completed a question before you commence an 9
answer even if you know where the question is going because it to is difficult for the reporter to pick up two people speaking at 11 once, and for the same reason it is necessary that you give 12 verbal answers rather than gestures so that she can pick this 13 up and make it part of the record.
14 It is also necessary for you to try to be as accurate 15 as possible today with your responses.
Although you will have 16 an opportunity once the deposition is reduced to transcript 17 form to make any corrections that you deem necessary, if those 18 corrections are substantial, they could adversely reflect on 19 your credibility.
So, therefore, accuracy today is very 3) important.
21 It is our custom at the conclusion of the deposition 22 to recess it rather than adjourn it.
In the event we have 23 any further questions to ask of you, we simply reconvene the 21 deposition and continue.
It hasn't happened yet, and we do not 25 anticipate doing it, but you should be aware that we maintain A,c m e Reporting Company l
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that option.
2 Do you have any questions about any of the foregoing?
3 MR. WASHBURN:
No.
4 DIRECT EXAMINATION 5
BY MR. HELFMAN:
6 Q
Who was your employer in 1974?
7 A
Los Alamos Scientific Laboratory.
s Q
Where is that located?
9 A
Los Alamos, New Mexico.
10 Q
What were your duties there?
11 A
I'm a staff member.
12 Q
Are you presently employed at Los Alamos?
13 A
I am presently employed at Los Alamos.
14 0
W' hat type of duties did you perform when you were at 15 Los Alamos?
16 A
I have worked in a variety of technical fields at 17 Los Alamos--the nuclear rocket program, the gas laser program, 18
'the reactor saf ety program.
19 Q
Who were you employed with in 1975?
go A
Los Alamos Scientific Laboratory.
21 Q
Same employer?
22 A
Same employer.
23 Q
At some time during 1975 were you assigned to the 24 NRC?
25 A
I was assigned ro AEC Regulatory in 1973 which in Acme Reporting Compony
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the Energy Reorganization Act, I believe, became NRC at the 2
beginning of 1975.
So my assignment was with both agencies.
3 Q
When you were assigned to AEC, was this a somewhat 4
unusual event?
5 A
AEC Regulatory in 1973 had sought outside temporary 6
help to handle the licensing of a number of applications that 7
they had and they expected to receive at that time.
I was one 8
of a number of persons loaned by the laboratories to the 9
Regulatory Division of the AEC.
10 Q
Were there a large number of people who were loaned 11 to AEC at that time, do you know?
12 A
My recollection is that the number was between 65 13 and 1CJ.
14 Q
Did they all come from Los Alamos?
m A
Approximately 20 people, I believe, came frem 16 Los Alamos; the remainder from other laboratcries.
1; Q
When you were assigned to the AEC, did you come to 18 Washington?
Did you physically change the location of your 19 work?
20 A
That is correct.
Work was in Bethesda.
21 u
What particular branch with the AEC were you 22 assigned to?
O 23 A
It was the Regulatory Division, as I recall, and 24 under that I was in the Licensing Division.
25
'Q What role did you perform for the AEC within the Acme Reporting Company
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Licensing Division?
2 A
I was licensing project manager for Three Mile 3
Island Unit II during the time I was assigned here.
4 Q
Was that the only plant for which you were responsible?
5 A
That was the only plant.
6 Q
And that responsibility commenced in 1973?
7 A
1973.
8 Q
When did that end?
9 A
June 1975.
10 Q
And the agency at that time was the NRC?
11 A
That is correct.
12 Q
What was the branch or division at the time it was 13 NRC?
14 A
I believe it was LWR 2-2 in reactor projects.
15 Q
Is that somehow connected with the department of 16 project management or the division of project management?
17 A
That would be, yes.
18 Q
And who was your immediate superior at the time that 19 you were working for NRC?
20 A
Karl Kniel was the branch chief, and Voss Mcore was 21 the AD.
22 Q
Assistant Director?
23 A
That's correct.
24 Q
What training, if any, were you provided, prior to l
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manager?
2 A
At the time I came here I had the experience with
-3 the Rover nuclear rocket program as a bac}. ground, and in 1973 4
after being assigned to NRC I attended
-- back up.
- Instead, 5
it was AEC at that time.
I attended a two-week given by 6
Westinghouse, a short course version of the training program 7
that they give to operators.
This program was conducted for 8
people from Regulatory, mainly people from I&E but a few 9
people from Licensing attended.
10 Q
Was this basir:11y voluntary on your part, or were 11 you assigned to attend this course?
12 A
I was asked, I believe, if I would like to attend 13 and I took advantage of the opportunity.
14 Q
Was this designed to train you in what a project 15 manager does?
16 A
No.
This course was directed at the Westinghouse 17 light water reactor system.
18 Q
What prior experience or training did you have for 19 the role of project manager?
N A
This was my first experience with a light water 21 reactor.
My previous experience, as I indicated, was with a
the Roter nuclear rocket program in 1960 to 1970, approximately 23 Q
Did you serve as a project manager on that project?
1 L
44 A
I was responsible for a number of things in the 25 facilities and the operations in that procram, and I was Acme Reporting Company
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a participant in other areas.
2 Q
Was there a project manager for the rocket program?
3 A
We had a test director and a test group leader and 4
then people with particular responsibilites or job assignments 5
under that.
There were some section leaders, which I was one 6
for a while when I was in E wada where the f acilities are.
7 Q
You have some coordinating experience as a result 8
of that, I assume?
9 A
Considerable.
10 Q
With respect to being project manager at TMI-II, 11 would it be accurate to say that you learned the function on 12 the job?
13 A
The specific concept of the designs of light water 14 reactor plahts was new to me and this was another situation of 15 learning.
16 Q
While you were doing it?
17 A
While working.
18 Q
The TMI-II facility is not a Westinghouse plant, is 19 it not?
20 A
That is correct.
21 Q
Were you given any training on the 3&W system prior 22 to the time you assumed these responsibilities or was it n
confined to this brief training course on Westinghouse light 24 water reactor?
I s
A The formal work was strictly with the Westinghouse f
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plant.
2 Q
And your familiarity with the B&W design, did that 3
come about as a result of your actually working on the TMI-II 4
project?
5 A
That is correct.
6 Q
Could you describe briefly what the responsibilities 7
of a project manager are?
8 A
The project annager at Licensing was responsible for 9
the overall managraent including technical and administrative to coordination of :he review and evaluation of the applications.
11 Q
It was basically a coordinating function?
Would that 12 be accurate?
13 A
Much of it was coordinating, but there were areas 14 where infor'mation needed to be e.schanged and differences 15 resolved between the applicants and the technical review staff 16 and it was necessary, then, to get these people together and 1;
have some agreeable conclusion arrived at in these areas.
18 Q
As project manager,'ere you responsible for 19 resolving disputes between the applicant and the regulatory m
agency?
21 A
I regarded it as part of the work to try to get zr these matters successfully resolved without having the
.23 application go to hearings with open items or having appeals,
24 this sort of thing, to higher management.
25 Q
' Were you ~ successful in that regard in every case?
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I can't answer that precisely because the review was 2
not over at the time I. lef t and there may have been some 3
isstes, and I believe there were, that had not been satis-4 factorily resolved, and there may have been other issues that 5
came out of things that were not resolved or still open at 6
the ti.me I was there.
But there were a number that, I believe, 7
did ge: resolved to the satisfaction of the staff.
8 Q
At what stage was the T!!I-II license application 9
when you were assigned to TMI-II?
Was it at the construction to permit application stage?
11 A
That is correct.
They had the construction permit.
12 Construction was underway.
13 Q
They already had their permit?
14 A
They had their permit at t:1e time I was assigned on 15 this project.
16 Q
Was there a predecessor project manager?
17 A
Yes.
13 Q
Do you happen to recall the name of the person?
19 A
I can't be sure but I would mention Hans Scherling; 00 he may have had it briefly before I had it.
21 Q
How would he spell his name--S-h-e-r-1-1-n-g?
22 Does that sound --
23 A
You'll have to resort to the telephone book.
I believe it is S-c-h-e-r-1-i-n-g.
24 25 Q
When you took over the p. oject, what coordination Acme Reporting Company
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effort did you make with him so as to become aware of what had i
2 gone on prior to your involvement?
3 A
As I recall, he gave me a few papers and copies of l
4 letters between the applicant and Regulatory, but mainly I got 5
up to speed in this area by reviewing the docket file from the 6
time the application came in through the construction permit 7
review and ACRS letters and open items and the SER at the CP 8
stage.
I do no believe the previous licensing project manager 9
had the project very long prior to my getting it.
10 Q
Is it your feeling that there was a project manager 11 involved prior to Mr. Scherling's involvement?
12 A
There were several.
13 Q
Seriatim?
14 A
S'everal.
15 Q
Do you happen to know the names of any of those 16 persons?
17 A
Robert Tedesco, I believe, was one; and Brian Grimes 18 comes to =dnd as another possible project manager.
19 0
Is it unusualy from your understanding for a project 20 to have so many project managers?
21 A
My understanding is that some projects have more Z!
than others.
23 Q
Is it uncommon for a project to have a single project 24 manager that folicws it from beginning to end?
25 A
I believe chere are cases where there has been maybe Acme Reporting Company
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one project manager or not more than two throughout the 2
licensing phase.
Q In your opinion does it create any difficulty in 4
managing a project if there are numerous project managers who 5
are with a project for a short period of time and then turn it 6
over to another project manager who then turns it over to another project manager, and so on?
8 A
In principle, that could be a real problem.
May I 9
say what I did when I turned it over?
to Q
Yes.
11 A
All my notes and records were turned over to my te successor, and --
13 0
Who was he, by the way?
Let me interrupt for a 14 moment.
15 A
Harley Silver.
In addition, I recall having written 16 a status of all the open items and items that needed further t-review and so, in my opinion, so that he would not have to search for these items.
18 19 Q
The way you had done?
A The way I had to to start with 3
21 Q
So this was basically a procedure that you developed 3.
yourself to facilitate the transfer?
A I thought it was appropriate to pass this information 3
on.
3 i
Q Did Mr. Silver have any direct contact with you at 05 l
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the time the transfer took place?
2 A
Well, our offices were next to each other and we ate 3
lunch together frequently, so we had a lot of contact.
4 Q
Can you recall if you discussed the transfer of TMI 5
and the status of TMI at the time it was transferred to 6
Mr. Silver?
7 A
Well, other than explaining to him my filing system--
8 I maintained a subject file and a chronological file--and where 9
these things were, records of my discussions with the appli-10 cants, and so forth, I believe that was about it; nothing 11 formal except giving him my lists of the status of the open 12 items, items that maybe had been addressed and resolved at 13 that point.
14 Q
iou mentioned earlier that you reviewed the records 15 of some ACRS hearings.
Were any ACRS henrings conducted while 16 you were project manager?
17 A
No, Sir.
Is Q
Were any public hearings conducted?
19 A
The last action, next to the last action on my part 20 here was to attend a pre-hearing conference the 22nd of May, 21 1975 in Harrisburg.
That was the status of the review and 22 hearings.
23 Q
And this pre-hearing conference was attended by 24 whom, besides yourself?
u A
Harly Silver was in attendance.
The attorney from l
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OGC whose name I can't recall; he was assigned to this 2
application.
3 Q
Were any intervenors present?
4 A
I believe they were.
5 Q
And I assume that you lef t NRC prior to the actual 6
holding of these public hearings.
Would that be accurate?
7 A
That is correct, yes.
8 Q
Were you present at the time the intervenors pre-9 sented their complaints or their issues?
10 A
May I ask:
presented to the board?
11 Q
They were filed with NRC?
12 A
Yes, they were filed during that time that I was 13 project manager.
14 Q
Did you have any responsibility with respect to the 15 issues raised by the intervenors?
Is A
Yes.
17 Q
try recollection is that the intervenors raised is thirteen (13) separate points regarding the TMI license is application, one of them involving inadequate radiation 20 monitoring devices.
Does that ring a bell?
21 A
I don't recall specific details, m
Q Do you recall specifically-any of the complaints 23 that were raised by the intervenors?
es A
I.think in the initial meeting that I had with them l
3 they raised the question of pressure vessel rupture, for i
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example.
2 Q
Yes, I recall that being cne of them as well.
3 And the ef fect this might have en ECCS?
4 A
I don't recall that detail.
5 Q
Do you recall a complaint raised by intervenors 6
regarding lack of emergency preparedness, evacuation plans, 7
the holding of drills, and so forth?
8 A
I believe there was a point raised in that area.
9 Q
What responsibility did you have with respect to the 10 intervenors' complaints?
11 A
When they submitted, following their submittal of 12 these points, or whatever they are rightfully called at that 13 time, to Licensing, I had a meeting in Bethesda with the branch 14 chief and 'Chauncey Kepford and a lady that was a member 15
.of the group--Elizabeth, I believe, something; I don't recall 16 her name.
17 Q
One of the intervonors?
IS A
Yes.
Kepford and this lady represented the inter-19 vening group.
20 Q
And the branch chief at that time would have been 21 Mr. Kniel?
22 A
Karl Kniel.
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2 Q
And what was discussed at the meeting?
24 A
We discussed these issues raised by the intervenors, M
and sought to give them the sranus and the Licensing cpinien Acme Reporting Company na,.a......
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about these issues.
We provided them, then, with documentatico,
2 background, from what had been done in these areas, what was 3
being done.
4 Q
Did you have any responsibility for these background 5
materials or the background steps that had been taken?
6 A
Not the details.
My responsibility was to see at 7
that point that the intervenors were informed as to what had 8
been done and what was being done on these issues.
9 Q
And what had been done and what was being done were to things that had been done and were being done by persons other 11 than yourself, is that correct?
12 A
That is correct, yes.
13 Q
Was there an atte=pt at this meeting to come to some 14 sort of a resolution on the intervenors' claims?
15 A
That would be ideal, of course; but as I recall 16 several of these issues tnat they originally raised, either at 17 that meeting or subsequently, they were satisfied perhaps by 18 what was being done.
This did not clear up all the issues.
19 Q
Did these. issues remain open at the time you left 00 NRC?
21 A
Yes.
They remained open for the hearing process, Z!
as I understand it.
23 Q
And the hearings were actually held af ter your 24 departure?
l 25 A
That is correct.
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Q Did you attend those hearings?
2 A
only the prehearing conference in May of '75.
3 Q
Normally, what would be the role of the project 4
manager at the public hearing?
5 A
The public hearing for l'icensing, as I understand 6
it, having not been through it, is conducted by the attorney 7
on the staff of Licensing.
The project manager there is to 8
provide information or testimony as necessary on these issues.
9 Q
Did you crief Mr. Silver prior to any testimony he 10 may have given at these hearings?
11 A
I can't say that specifically that the information 12 that I turned over to him as background and status fully 13 covered the details of the intervention on the application; but 14 prior to may departure he had had a meeting with the inter-15 venors on my behalf because I had other commitments and could 16 not attend.
So he started out with the intervenors at that 17 point, also prior, I recall, to this prehearing conference.
18 Q
I see.
Had you met with the intervenors without 19 Mr. Silver being present prior to the prehearing conference?
20 A
When the issues were originally filed, as I 21 indicated, yes.
Mr. Silver was not known to be my replacement i
22 at that time.
23 Q
You mentioned a mcment ago that when you assumed the 24 position of project manager for TMI, you reviewed the records 25l of the ACRS hearings.
Do you recall what, if any, open issues, Acme Reporting Company na,.......
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safety issues were raised by the ACRS and had not been resolved 2
by the time you assumed your responsibilities?
3 A
Pump fly wheels, hydrogen generation.
4 Q
Hydrogen generation?
5 A
In the containment, as I recall.
6 Q
Was there concern about hydrogen generation in the 7
pressure vessel?
8 A
I don't recall that ever being addressed.
9 Q
Do you recall whether any concern was addressed to regarding operator reliance on pressurizer level as an indica-11 tion of core level?
12 A
I don't recall any discussions in that area.
13 0
Were any questions raised bi the ACRS concerning 14 the inability to vent gas trapped in the steam generator side 15 and its possible effect on natural convection in the B&W 16 design?
17 A
I have no recollection of that.
18 Q
Do you recall whether there were any issues raised 19 regarding PORV, the function that it serves and its reliability 3) in the B&W design?
21 A
Again, I have no recollection of this being addressed.
l r
Q-How about containment isolation by single parameter; l
23 was that raised?
24 A
Containment isolation was a problem with this 3
. application in general.
The specific event or condition that Acme Reporting Company
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in'itiated it, I have no recollection of the depth of which that 2
was considered or reviewed.
But the isolation itself, indeed, 3
was a problem.
4 Q
Was this raised in the context of the ACRS hearings?
5 A
You mean the isolation feature?
6 Q
Yes.
7 A
Well, would you like me to explain that to you or 8
just say no?
9 Q
Well, say no, and then feel free to explain.
10 A
My recollection here was that when the TMI-II design 11 was originally submitted for the construction permit, it was 12 a plant that they had intended to locate at oyster Creek, and 13 during the review on the construction phase the utility, the 14 applicants " elected to move that design to TMI where TMI-I was 15 in some planning and licensing phase.
So my recollectivn here 16 is that the special feature had been proposed at the con-17 struction phase of TMI-II wherein not only were the double 18 isolation valves to be provided in the lines that required 19 isolation, but there was also to be a fluid blocking arrange-20 ment here to provide additional insurance that there would 21 not be leakage when the containment was isolated.
1 r
When the applicants came in for the operating 23 license, they had omitted or deleted that from the designs.
24,
Q Had that particular design been approved previous 5
to their deletion?
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A It had been an understanding at the construction 2
stage that this feature would be incorporated in the TMI-II 3
design.
This wz reviewed, as I recall, and specifically 4
commented on by the ACRS and by the Board at the CP stage.
So 5
w/ problem aww was, gee, there's a long history here and the 6
construction permit, in part, involved some consideration and 7
delici. ration on the containment isolation.
8 As I recall, the reasoning behind this was concern 9
for the population density around that particular site.
10 People were addressing this and said can we improve the isola-11 tion of the containment and it is believed it should be done.
12 Q
So as to avoid radioactive emissions into the 13 community?.
14 A
Ih the event of an accident.
So the applicant had 15 deleted that.
So I spent some time urging and finding out 16 there was no way they could delete that without going to the r
hearing and getting a determination finally, and then it is 18 kind of late in the game, because in licensing we believed that is feature should have been retained.
And it turned out as a s) result a different cesign was submitted but the evaluation at 21 the time I lef t indicated that the applicant's proposal was 22 acceptable and did provide an additional degree of assurance 23 of isolating the containment at TMI-II.
24 Q
Who reviewed this change in the design plan and I
3 approved it?
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A As I recall, Brian Grimes, in the accident analysis 2
branch, was the principal reviewer.
3 Q
Were you involved in the review and approval of this 4
modification?
- 5 A
Only to the extent of trying to get an acceptable 6
solution worked out.
We had several meetings and lots of 7
correspcadence on this particular issue.
8 Q.
You indicated that you urged the retention of the 9
original design.
How was this dispute between you and the 10 applicant resolved?
11 A
well, I would maybe not characterize it as a dispute.
12 It was a difference of opinion, as you can see when they 13 deleted the feature from the design af ter receiving a pe rmit 14 to construc't the plant with that and other features involved.
15 So it was a matter of convincing them that that was the 16 appropriate thing to do under the circumstances, to continue 17 that feature in the design.
18 Q
In your opinion, is this mcde of effective contain-19 ment isolation a safety related feature?
20 A
It is definitely safety related.
21 Q
Do you recall what the applicant's interests were 22 or what their arguments were in deleting this feature from 23 the design?
24 A
I cannot really delineate these.
As I recall, 25 Unit-I had a similar feature, of course.
And I don't knew the f
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detail of the design, but it was a complicated, complex, 2
-involved approach to providing for this assurance against 3
leakage when isolated.
4 Q
Do you recall whether cost was a factor in the 5
applicant's reluctance to incorporate this feature in the 6
second. plant?
7 A
It is likely that that's mentioned.
It comes up 8
frequently.
9 Q
Do you recall whether the number of modes of con-10 tainment isolation actuation was an issue at the time?
11 A
May I ask what you mean by modes?
12 Q
My understanding as a nontechnical person is that 13 containment isolation at TMI-II was actuated by pressure in 14 the containment building, and there are other multiple choices.
15 A
You mean how do you initiate the isolation?
16 Q
Yes.
1; A
I was thinking that you knew something about how to 18 design the isolation, per se, so it would be an improvement.
19 Well, there are a number of modes, as fou say or as I say, 20 parameters on which one would isolate the containment and they 21 vary f cm plant to plant, although there are other plants, I m
believe, that use this containment pressure as an initiating 23 signal.
24 Q
It's my understanding that a number of plants use 25 multiple parameters for initiation of containment isolation--
Acme -Reporting Company u
24 1-radiation level in the containment, pressure in the contain-2 ment, 'or actuation of ECCS--and using maybe two of those three 3
alternatives as opposed to just one; whereas at TMI-II con-4 tainment isolation was actuated solely by pressure in the 5
containment.
Is that an accurate summary, do you think?
6 A
To my understanding of TMI-II, only pressure was 7
used whereas these other logical possibilities exist.
8 Q
Did the question of the number of parameters for 9
initiation of cantainment isolation come up at the time that to you were project manager for TMI-II?
11 A
That I don't recall, but I seem to vaguely recall i
12 some discussion or consideration of what parameter should he i
13 used or what the level should be.
14 Q
The level of pressure.
15 A
That's correct; what level of whatever was chosen, 16 and it apparently was pressure.
1; Q
Was there no discussion, then, of the number of 18 parameters that would be used for containment isolation?
_19 A
That I couldn't say positively because I don't 20 recall that much of the detail.
i 21 Q
Do you know if there were plants that were licensed 22 at the time TMI-II was going through irs licensing phase in 23 which containment isolation was actuated by more than a single 24 parameter?
3 A
-I don't have any knowledge of that.
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1 s
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Q Are you f amiliar with a plant known as the Sequoia 2
Plant?
1 3
A I've heard of it.
4 Q
Are you aware of the fact that it received its con-5 struction permit six to nine months after TMI received its I
6 construction permit?
7 A
No, that doesn't mean anything to me.
8 Q
Are you aware that the Sequoia Plant had diverse 9
actuation in two-phase containment isolation?
10 A
I have no knowledge of that.
11 Q
To the best of your recollection was diverse actua-12 tion of containment isolation required by the NRC at the time 13 TMI-II was. going through its licensing?
14 A
I don' t recall anything specific as to criteria that 15 is applied to that.
i l
16 Q
Is it your recollection, then, that there were no 17 such requirements?
18 A
I couldn' t say that definitely there were none.
19 Q
If there were, you were unaware of them?
j 3)
A Or I don't remember them now.
21 Q
Okay.
Are you familiar with the SRP, the Standard 22 Review Plan?
23 A
I am now.
t 24 Q
Do you know when the standard review plan went into 25 effect?
i Acme Reporting Company i
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26 1
A I believe that this was developed by sections or 2
chapters over a period of time and that some of these were 3
published at least in draft form prior to my leaving NRC.
4 Q
Are you aware that the standard review plan requires-5 diverse containment isolation actuation?
6 A
I have not studied the standard review plans except 7
as specific questions have arisen since I lef t there.
8 Q
You didn' t refer to the standard review plan in the 9
course of licensing of TMI-II?
10 A
I don't believe that that was referred during the 11 time when I was there.
We had something at that time that was 12 a forerunner, perhaps, of standard review plans and a thing 13 that was incorporated in many of these.
This was known as the 14 branch position.
15 Q
Did the branch position deal with the question of 16 containment isolation?
17 A
That I cannot say here.
18 Q
You don't recall?
19 A
I don't recall that.
20 Q
Are you aware of whether the standard review plan 21 was backfitted to plants that were in the licensing process r
and had not yet received their operating license at the time 23 the standard review plan went into effect?
24 A
I believe this gets into an area that was the problem 25 in the case of TMI-II and other plants, the question of Acme Reporting Company an'a'*aa
27 1
changing regulations and changing regulatory requirements, 2
changines in the reg guides which are not requirements but 3
which are acceptable means of acccmplishing certain things.
4 These evolved while TMI was under construction but not yet in 5
for licensing.
So there were a lot of these issues involved.
6 During the time that I was there I don't think the standard review plan had'haq been, of course, completely 7
8 developed and the sections that were there, to my knowledge, 9
were not really applied to TMI-II except branch positions that 10 had evolved that were applied in these areas.
So it's a 11 matter of degree in terminology in part here, maybe.
12 Q
Did the standard review plan go beyond the branch 13 positions in requiring safety components in the design?
14 A
W' ell, I guess the standard review plan, again, like 15 reg guides, you used the word requirements, and those are 16 regarded as not requirements but a presentation of designs 17 or approaches, whatever you wish to call it, that are 18 acceptable to licensing in these various areas.
19 Q
Would it be an accurate summary to say that with 20 the reg guides and the standard review plan that the licensee 21 would be obligated to follow the standard review plan or the a
reg guide unless they could demonstrate to the NRC that some 23 alternative approach would produce the same result?
24 A
I believe that's correct.
They have an opportunity
's to take a different approach to the problem or solution Acme Reporting Company nou........
28 1
provided they can demonstrate that it is equivalent to or 2
better than.
3 Q
Do you know any reason why the standa.rd review plan 4
was not applied to TMI-II?
5 A
During my involvement, as I indicated, the standard 6
review plans were just under development; there were only a few sections out.
So I would regard that as reason why it a
wasn't applied during the time I was involved.
And then, of 9
course, in all specific plans and reg guides and regulations to one encounters the time frame in which these documents are
-11 applied to a given plant, usually based on when they got their 12 construction permit.
So there are degrees in which this gets 13 applied.
It's not uniform.
14 Q
rn other words, talking from your present knowledge, 15 you are saying that you are aware that the standard review is plan was not applied to TMI even after your departure as 17 project manager?
18 A
That I could not say.
19 Q
You don't know whether it was or wasn' t?
m A
I do not know.
21 Q
Was the decision to apply the standard review plan r
to plants that had not yet received their construction permit n
made at the time that you were with the NRC?
24 A
Would you repeat that?
I was thinking.
25 I Q
Was the decision that the standard review plan is Acme Reporting Company
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29 1
not to apply to plants that had already received their con-2 struction permit made at the time you were with the NRC7 3
A I don't recall any decision like that, no.
4 Q
Do you know from your present knowledge whether such 5
a decision has been made by the NRC?
6 A
I do not.
7 Q
Do you recall whether either, in your review of the N
8 ACR hearing records or your preparation for une public hearings 9
whether the question of the design of the OTSG came up as com-l i
10 pared to the recirculation steam generator design of the 11 Westinghouse or the CE plants?
I'm referring specifically to 12 the rapid boil-on time.
13 A
I gathered you were getting to something and my 14 response is I regard nothing that was pointed at the OTSG 15 per se.
16 Q
Do you recall whether that issue occurred to you, 17 whether or not in the context of hearings, or review of hearing i
t4 18 records?
19 A
No, it did not.
20 Q
You indicated at the outset that you were unfamiliar 21 with the B&W design when you took on this task.
In the course 51 of your being the project manager for TMI-II, did you become Il aware of the characteristics of the OTSG or once-through steam 24 generator?
3 A
Not the OTSG, per se.
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Q What do you mean by that?
2 A
That's just one piece of the system.
3 Q
Did you gain an impression of the B&W design as a 4
whole?
5 A
Through the comments of others; not because of any 6
analysis done by myself.
Q What sorts of comments are you referring to?
~
8 A
I can't quote these, but you asked me for impressions 9
so I'm free to take license with that.
10 0
Well, to relate them as accurately as you can.
11 A
Several times I believe I heard people whose business 12 it was to review that plant and system that they didn' t know 13 as much about it as they felt they should know or they would 14 like to know and they had difficulty getting information.
They 15 were not satisfied with the responses and they tried to think 16 of questions to ask that would shed more insight in this.
17 Q
Are you referring to the reviewers with DSS?
IS A
May I ask who is DSS 7 19 Q
That's the Division of System Safety.
My under-20 standing is, at least presently, they review the design aspects 21 of the C2 and OL application.
2 A
Yes.
Well, I wanted to get this back in the right 23 time frame.
These were people in Reactor Systems as part of 24 the technical review division at that time.
So DSS is a new 25 term.
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Q Do you recall the names of any of those people?
2 A
I can't.
They were people who were involved with 3
the T>1l review in the Reactor Systems Branch, as I recall.
4 Q
Do you recall the name of Denwood Ross?
5 A
Yes, but hu was not one.
6 Q
Roger Mattson?
7 A
Yes.
-8 Q
Was he one?
9 A
No, he was not one.
10 Q
Thomas Novak?
11 A
He was the branch chief, but I don't recall these 12 conversations wich him.
This was at the reviewer level and 13 people that I was working with on this application.
14 Q
James Watt?
15 A
That's the name I could not recall; one of them, I 16 believe.
17 Q
Do you now recall that that is one of the names?
18 A
That's right; that's one of the people.
19 Q
Jerry Ma:etis?
20 A
I don't recall him associated with this particular 21 plant.
z!
Q Do you recall whether it was James Watt who expressed 23 some of these impressions about the flow of informatier. con-24 carning the B&W design?
25 A
I think he may have been one, and something borhers Acme Reporting Company
.am eas.4een j
32 (ts/ARedW nt/##1Rs) 1 me--there is someone e se that also tended to confirm this 2
intuition I was getting from these inputs.
3 Q
Sandy Israel?
4 A
That name is not familiar.
5 Q
When you refer to insufficient responses, are you 6
referring to questions directed at the utility or the vendor 7
by the NRC?
8 A
Yes, in this area I guess perhaps two thing go on 9
in the review.
The specific applications which involve a 10 specific nuclear steam supply system and vendor have questions 11 directed at that plant and at the reactor, the reactor system 12 by the technical review people.
Responses then come back from 13 the applicants.
I believe that other reviews of the reactor 14 designs were conducted and information exchanged directly 15 between people like the reactor systems branch at that time 16 and the vendors.
17 So those people received information in two ways 1
18 about the designs, is my understanding.
So they directed 19 questions in both directions here and looked at the response.
20 The utility's response, I would add, I believe really 21 comes from the reactor vendor and the utility and perhaps 22 varying degree reviews the inlor=ation supplied by the reactor 23 vendor in response to the licensing question.
So it's a chain i
24 there.
I don't know what is added or draleted.
1 25 Q
But essentially the answers to the questions come Acme Reporting Company a n,
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from B&W with respect to the TMI-II project?
2 A
This is my understanding, quite a few of them.
The 3
applicants here did not readily reveal the source of answers 4
to these questions when you asked.
They did not regard that 5
as a proper question.
6 0
What was the role of the project manager in this 7
exchange of questions and answers between the utility and the 3
vendor and the NRC?
9 A
Well, the questions would be generated, of course, 10 by the technical people reviewing a given area or aspect of 11 the design.
Then their branch chief would review the ques-12 tions.
Then the Assistant Director in that area would in 13 turn review the questions.
The questions, then, come to the 14 licensing p'roject manager.
15 Q
You, for example?
hef 16 A
When I was there, to me.
% were probably on 17 paper directed at the AD level, like Voss Moore, but these are 18 formalities in the paper routing.
Then I would review these 19 questions and summaries and talk with the reviewer to find out, M
gee =, why are you asking this question?
How does
.t relare?
21 and so forth, and get some background, you know, where does 22 this fit in the picture?
23 Then I would prepare a letter and forward this 24 through the branch chi 1f or the assistant director and the 25 letter would go to the applicant with the questions.
1 Acme Reporting Company
34 1
Q And then the questions would come back through your 2
hands?
3 A
They were distributed.
The responses are usually 4
directed, I believe, nowadays to the branch chief.
At one 5
time they were directed to, like the director of reactor Anfe Gmbusso 6
projects or whatever the proper term is-- M M (phonetic) 7 so it varied as to where the letter was really addressed.
The copies went to'thg,all 8
But then these were distributed.
9 the review branches and I received a copy of the response, 10 checked to see what the responses were and the status of the 11 responses, and then I would write an internal note to the 12 reviewers for two or three reasons, but that note showed 13 (1) what had been received, (2) whether I questioned that-i 14 it was even close to being responsive or not, and comments 15 like this then to the reviewer.
Then I would send that out to and this would alert the reviewer that he should find the 1;
response and do something.
18 Q
In the event a response was inadequate, was it your 19 responsibility as a project manager to obtain an adequate 3) response from the vendor or the u-ility, or was that the 21.
responsibility of someone else witt in the NRC7 m
A Again, it was the responsibility of the process, I 23 guess I would say, that there would be things, for example, i
i 24 that I would question and the reviewer would come back and l
3 say, no, rhat's all right, you don't understand, or something.
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Then there would be things conversely that I didn' t really 2
raise any significant questions and the reviewer would come 3
back with more.
So we would have this exchange among ourselves i
ofewed 4
Then these would be fo.
ed up either with a 5
second round; if that was the first question that had gone 6
out, for example, then there would be a second round of ques-7 tions or positions.
We might take a position then on an issue 8
in order to clear it up.
Say, your response is inadequate; it 9
is our position that you -- Okay, and then this leads to 10 either resolution or a firm difference of opinion.
It keeps 11 it moving.
12 Q
So your --
13 A
So these went out the same way again, okay, revfewed 14 by the technical review management staff over to licensing 15 and then out to the applicants then maybe phone calls and
+
16 whatever else goes on to make sure -- Well, we'd also conduct 17 meetings with the applicants during this question process after is we formulated the questions to make sure that they had an 19 opportunity to discuss with us what we meant by the question 20 and why we were addressing this or any other thing.
21 Q
Did the vendor normally attend those meetings?
22 A
In some cases.
This was at the discretion of the 23 applicants.
24 Q
Do you recall any questions that you may have raised 25 about a question that went out to the utility at che time you i
l Acme Reporting Company l
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36 I
were project manager?
2 A
Yes, I recall one; not too much detail.
3 Q
Could you please elaborate?
4 A
It was a question that we didn't understand and we 5
went back and asked why it was being asked and what did they 6
really mean, and after this discussion we said, gee, that 7
isn't what you asked in the question.
We want to change it.
8 Oh, you can't change it.
It has been approved by the AD.
9 So I think we did make a minor change.
There are 10 these jurisdictional disputes between the author and the 11 editor, of course.
We did make a minor change that we kind of 12 agreed to, but nobody was satisfied with that question, and I 13 don't know how to respond.
This was right about the time I 14 was leaving", I think, in the second round question.
But I 15 reflect on that as it is not easy to get things righted once 16 they are wronged.
17 Q
Were you project manager at the time any responses la came back from the utility or the vendor?
19 A
Ch, most of the questions and responses, I believe, 20 came back during the time I was there.
21 Q
Did you find that the responses frem the utility or 22 the vendor were adequate?
23 A
Not in all cases.
That's why I wrote the status 24 report each cime an amendment came in as a result of my review 25 to let the reviewers know how I reacted to the responses, and Acme Reporting Company
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37 1
then get their iudgment.
2 Q
Were your comments and concerns directed primarily 3
towards Mr. Watt?
4 A
You mean the comments and concerns regarding 5
applicants responses?
6 Q
Yes.
7 A
No.
It was directed to everybody involved.
a Q
Which would mean to the utility?
9 A
No, in Licensing, to all the reviewers, to Q
The technical reviewers?
11 A
Yes.
Because Watt was one of 20 or something, if 12 I recall the number approximately right.
13 Q
As a result of concerns raised by you and addressed
~
14 towards the appropriate reviewers, were any questions 13 reformulated or any demands made to the utility for better 16 responses that you are aware of?
17 A
Yes..If you review, say, the second or third round 13 questions, you will see lots of comments:
Your response to 19 question so-and-so was incomplete er was not adequate or words to that ef fect.
20 21 Q
Uere there any inadequate responses to the second round questions, as you recall?
3 A
I can't identify any offhand, but I think that's 3
likely.
Let me think.
(Pause)
Oh, steam line breaks or l
24 l
3 high energy line breaks or something in that area, okay, Acme Reporting Company oes p co
38 CM7hrInmd'n 1
involved with the e systems.
That was a big con-2 cern, so that is probably an exanple of what you just asked 3
here where second round questior was inadequately responded to.
4 Q
Is the inevitable next step the taking of a position 5
by the NRC or is there some further effort to get an adequate 6
response from the utility?
7 A
I believe that the approach at this time, when I was 3
there, that if you reached the point where responses were 9
inadequate or unacceptable or something at the second round to question stage, what might have been called at one time third 11 round questions became positions in order to clear up these 12 items before the hearings.
That was the object, so that you 13 could write a clean SER and not have a lot of open items, the bd.
14 issues to be resolved.
g 15 Q
Had TMI-II embarked upon the third round of questions 16 while you were project manager?
17 A
Well, may I explain something here?
18 Q
Yes.
19 A
I believe the third round questions mostly came 20 after when I was there.
The review --
21 Q
After you left?
r A
After I left, yes.
The review at TMI-II, because 3
of the licensee's scheduling of responses to the questions, 24 wasn't done in a nice, neat package from a scheduling stand-25
- int whereby you could say today we send cut round one Acme Reporting Company w u,-...
39 I
questions; 60 days we have your responses; and 30 days later 2
we send yea round two.
Well, we went through that kind of a 3
schedule, if you will, except that we had different dates for 4
their responses to certain sections and certain portions of 5
the questions and sections in the FSAR.
6 So, as a result, rather than hold up everything 7
until the last response to round one was in and say, okay, now 8
we'll start round two, I scheduled everything piecemeal to 9
accommodate their staggered response schedule.
So there may to have been some third round questions in a few areas go out 11 before all the second round ones had even been asked.
12 So it is not clean enough to answer your question 13 directly.
14 Q
I see.
You mentioned that the effort was to produce 15 a clean SER.
What do you mean by a clean SER?
16 A
No open items I dre ned in there.
17 Q
All right.
18 A
You've got everything understood and resolved before 19 you get to the hearings.
M Q
What role does the ACRS play in the licensing process?
21 A
Well, after the safety review in Licensing and I 22 believe the issuance of the SER, or at least the SER in draft i
j 3
stage, there is an ACRS meeting of the full ccmmittee and they 24 review the licensing review and comment on it and give their 25 opinion as to whether the plant can be operated saf elv and Lay Acme Reporting Company
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40 1
list items where they wish to be kept informed that need to v
2 be addressed.
3 Also, during this review, there is an ACRS sub-4 committee that is assigned to the plant or the plant is 5
assigned to them, however you look at it.
They go along and 6
address the concerns that have been addressed, I guess, or 7
raised by the full committee and other members of the ACRS, 8
snd interact with the review this way.
And they have, I 9
believe, site visits richeduled there and go and look at the 10 plant, and so forth.
And this is kind of in their review and 11 background preparing for t..a full committee review.
f 12 Q
Does the ACRS normally get involved in the license 13 review process af ter the staff's review is virtually completed?
14 In other words, does the ACRS get involved at the time the SER 15 is completed?
16 A
Well, this subcommittee of the ACRS that I mentioned 17 is going along.
They start at scme point during the licensing is review, so they are going along in parallel.
During the time 19 that I had TMI-II was, of course, prior to the SER, prior to 20 the ACRS.
But I did have several discussions at points with 21 one of the ACRS staff members that was assigned to that, I r
guess.
23 Q
How was the ACRS kept abreast of disputes that may 24 have arisen between the NRC staff and the applicant over 25 questions in the first or second round and inadequate responses, Acme Reporting Company
41 I
and so forth?
2 A
To my knowledge, there is no direct formal communica-3 tion here other than that they receive copies of the questions 4
and the responses.
5 Q,
Were you responsible for directing copies to the 6
ACRS?
7 A
That was taken care of in the distribution process.
8 Q
But you recall that that was done?
9 A
To my knowledge, it was.
They received 16 copies to of everything, if I recall the number correctly, or they used 11 to.
12 Q
They received copies of the questions and the answers 13 and the FSAR and the SER?
14 A
Y"es.
(Pause)
May I add one thing here?
15 Q
Certainly.
16 A
I never made any attempt to check or verify that 1;
they got their copies of everything, okay.
I addressed the 18 reviewers to Nake sure they had their information.
19 Q
Did you see distribution lists on which the ACRS y) was listed as recipients or intended recipients of these et documents?
22 A
Ch, yes.
Oh, yes.
23 Q
And this was while the process was on-going?
2 A
That's correct.
25 0
!>o you recall whether at any time that you were Acme Reporting Company
42 I
project manager at TMI-II whether the question of normal 2
operation computer readouts came up and the fact that the 3
computer would not provide information during abnormal operat-4 ing conditions?
5 A
I don't recall that specific concern being addressed.
6 Q
Were you aware at the time that this was the case?
7 A
No.
The last thing I recall there was the question 8
directed at them about display of information to the operator.
9 Q
What was the nature of that question?
10 A
I can't say.
I vaguely recall something in the dis-
~
11 cussion of it though that got into the seismic qualification Nab
- Adn 12 of that recorder and h became more important K having a 13 recorder that would work.
14 Q
I$ the recorder a safety related item?
15 A
I don't really know, but I doubt it.
16 Q
As project manager, were you concerned primarily with 17 safety related items if not exclusively with safety related 18 items?
19 A
(Pause)
I guess I would judge that the majority of T
the ef fort was directed at engineered safety features, items 21 called safety related, important to safety, this category.
But it was not 100 percent.
23 Q
Are these terms of art?
24 A
I believed at the time when I was there that 25 Acme Reporting Company
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43 I
terminology " safety related" and " safety grade" were not under-2 stood universally as to what was really required, what was cadere ev-3 meant, what the significance, and so forth, of things Deze to 4
which these terms were applied.
5 Q
Who was responsible in the first instance for 6
determining which items were safety related and which items I
were not?
8 A
I don't believe you could name a single individual 9
or a single branch that had such a responsibility.
10 Q
Did NRC have a list of safety related items which 11 would be presented to the utility or did the utility present 12 a list of safety related items to the NRC?
13 A
I think if you are thinking of a nice clean table 14 somewhere l?isting all the items of a specific plant or a 15 specific generic design where you would find lists of safety 16 related or important to safety,or whatever the terminology is, 17 items, I don't recall any such lists.
It is, in my opinion, 18 woven into the review and the FSAR that you will see, maybe, 19 in the questions, like the regulatory staff position or some-l 20 thing.
They will say we regard that as such-and-such system 21 as safety related based on our review of your FSAR and there-5 fore we require this meet seismic one criteria, IEEE-279, and 23 Appendi:4 B, and whatever is applied.
24 But, again, that's not uniform, so you would have l
25 to really look at each application, each detail to see how it Acme Reporting Company
l 44 I
was treated in its entirety.
)
2 Q
Is it your impression that this was idiosyncratic 3
with each plant?
4 A
It was handled in such a way that it could have been.
e 2-A 5
Q Do you recall whether during the tine you were 6
project manager that any disputes arose between NRC staff and 7
the applicant as to whether a particular component or system 8
should or should not be deemed safety related?
9 A
Well, you know, dispute, in my judgment, is subject 10 to interpretation.
But --
11 Q
A difference of opinion?
12 A
Yes.
I would point out that the auxiliary feedwater Gnct 13 system which was a thing that I had some time'aq,i.
.vement 14 in communications with the applicant, et cetera, in trying to 15 get it upgraded, improved in TMI-II.
I believe they responded 16 to one of the questions in such a way that I disagreed with it.
17 But that was kind of immaterial because we took a position on 18 it, so we weren't asking for understanding.
But in that case 19 we had asked a question or maybe made the statement that we 20 regarded it as safety related and therefore we, you knew, 21 required certain things and that we wanted an analysis of the dd 5
system's behavior, Thq folicwing loss of off-site pcwer 5Wg any 23 one of the following things.
And the applicant said, gee, you 24 know, you're out of bounds with the general design criteria 25 dated 1969, or something, and you knew, indicated thar they Acme Reporting Company na,........
45 1
disagreed with the question, or the way we were beginning to 2
handle or change the feedwater system, if you will.
3 Q
How was that disagreement with the applicant 4
resolved?
5 A
I believe they changed the feedwater system.
1 6
Q And you believe it was upgraded to a safety related i
I 7
component, system?
wken 8
A I'm not sure w h the final design occurred, 9
okay, in the aux feedwater system, but it was well along 10 except for a cor.ple of areas that we may have been waiting 11 for final details at the time I lef t.
12 Now, I'll just digress here.
I believe the question 1
13 that I referred to here is where they sort of took a difference i
14 in opinion about that system, was one of those questions 15 directed at the T.MI application where we were really trying to 16 find out how that reactor would behave.
This is my recollec-17 tion.
It was a good question, but it was part of this business 18 of being concerned how the B&W plant would behave.
19
~ Q Did you get some type of response eventually to that 1
3) question?
21 A
Ch, they responded, yes.
Z:
Q What was that?
23 A
They said well this was probably something like this 24 is a highly unlikely and unimaginable event.
However, we 25 present the following results.
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Q What type of results did they present?
1 2
A I don't recall the details.
3 Q
Did they explain how the B&W design would function 4
in the event of the loss of all feedwater?
5 A
I don't think the loss of all feedwater was 6
addressed, all right?
But I would point out one thing that 7
was done there.
In presenting the results of some of these 3
analyses, they produced plots or graphs, if yc7 will, of 9
pressurizer level, hot leg temperature, system pressure, and to so forth.
I found they only took those transients out to about 11 20 seconds, where in some cases I believe there are really 12 inflection points in those curves and the more exciting parts i
13 are yet to come.
My review showed that.
The implication of
~
14 the response is that everything is all right after that time.
15 Q
Did you address your concerns to the technical 16 reviewer or were these held privately by you?
17 A
This point I mention here didn't concern -- I didn't 18 understand the significance potentially of it at that time,
.M 19 okay.
As I say, af terwards I looked.
And this is part, in 3) my judgment, why people were trying to keep asking some of 21 these questions and learn about the plant.
ZZ Q
But the deficiency that you mentioned in the response 23 when they carried the cransient out to 20 seconds and nothing 24 beyond, was this a concern which you formally raised and pre-3 sented to the technical reviewer?
l l
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A No, because my feeling or impression, understanding 2
or whatever, at that time, was that everything was all' right 3
after that point, okay.
The words that were used, discussions 4
and so forth, left you feeling that, gee, you went through 5
that event just with no difficulty at all.
6 Q
Do you recall whether in that context the snort 7
boil-out time of the once-through steam generator came up?
8 A
I don't recall that specifically during this review.
9 Q
Do you recall what the major saving apparatus was 10 that was referred to by B&W in the event of the loss of all 11 feedwater that enabled the transient to be successfully con-12 cluded within 20 seconds?
U A
I believe you mentioned loss of all feedwater.
That 14 was loss o5 main feedwater in which aux feedwater functions, 15 for example, okay.
I was not aware of the questioning and 16 thrust of the staff's concerns about feedwater until af ter the 17 event at TMI-II at which time I looked into these things.
18 Q
These concerns were not raised and addressed at the 19 tine you were project manager?
Zi A
I can't say for sure, but the questions, of course,
21 may indicate this, because there the questions addressed at the feedwater, as I indicated, one, to try to get more informa-23 tion and understand the behavior of the B&W system, and two, was the position of ' hag, Licensing at that time that that 24 3
auxiliary water was indeed safety related, important to safety, Acme Reporting Company
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48 l
1 and should be made seismic category I in classification and 2
treatment and the instrumentation controls should be made to 3
meet the requirements of IEEE-279 for diversity of power sources 4
and the feedwater system should have diversity of drive for 5
the feedwater pumps, and so forth.
Also then that the system 6
should be able to take a single line break and still perform 7
its. intended function.
So the single failure criteria, and S
everything, that is applied to safety related systems was 9
applied in the design of TMI-II.
10 Q
Is it your impression, based on comments you received 11 frcm James Watt and other who were in the technical evaluation 12 involved in technical evaluation, that give you the impression 13 that perhaps the NRC was in the process of licensing a plant 14 which it didn't fully understand?
15 A
I didn't view it that way.
I viewed it that they is wanted more information that apparently they didn't have.
17 Q
And were having some trouble obtaining?
18 A
And the question -- they were having trouble obtain-19 ing it.
The route of asking questions of the applicants 95%
20 who wanted to license the B&W plant was an avenue, that 21 was a route, that was a way, see.
And they were asking the 22 questions.
I can't answer what the concerns were, okay, except' 2
that they felt they were missing information.
They either 2b wanted to confirm something or that may have been the case, 2
okay, or they may have just had nothing to confirm and they Acme Reporting. Company
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wanted something to question.
2 Q
You indicated a moment ago that a question was posed 3
concerning how the plant would behave in the event there was 4
a loss of cain feedwater, and you also indicated - that some of 5
the technical people indicated to you that they didn't fully 6
understand that particular B&W plant design.
Would it be 7
accurate to state that during the course of the licensing 8
process the NRC was proceeding to license a plant which it 9
didn't fully understand, and I'm talking only in terms of the 10 time that you were involved and not what may have occurred 11 subsequently.
12 A
Let me say one thing.
You used the term, I believe, 13 that they were seeking answers for things they didn' t under-14 stand.
Thef may have well understood them; they were looking 15 for the necessary confirmation so they could do something 16 about it.
I have that impression, too, from my recollection of 17 these discussions, okay.
So it was back and forth process.
18 I can' t ccmment on what understanding the people 19 that were reviewing tha reactor system and its behavior, say, T
under these transient conditions, what really went on in their 21 minds.
I can't.
S Q
Was the B&W design a fairly new design at that time 23 compared to the GE or Westinghouse designs?
24 A
I guess that's a proper statement.
25 Q
And that the NRC was learning about the design throuch Acme Reporting Company fi2 128 4880
50 I
the process of licensing plants with that design.
Would that 2
also be an accurate statement?
3 A
That was part of the learning process, as I said 4
before, that they also directed q"estions directly to the 63 5
vendors about the designs.
So there were two paths which the g
6 technical people received information about the plant.
7 Q
Do you recall whether there was a position indicator 8
on the PORV at TMI-II?
9 A
Not from the licensing experience.
10 Q
Why would PORV indication not have come to your 11 attention at that time?
12 A
I don't recall it being specifically addressed.
13 Q
Was the PORV considered a safety related item at the 14 time?
~
15 A
I don't recall that, either.
16 Q
Is it your impression that it was not?
17 A
Well, my understanding was that it was not ASME Code 18 Three as applied to the reactor coolant pressure boundary and 19 therefore there has to be a code Class 3 valve downstream of the 20 PORV.
21 Q
Which would have been the cede --
be 22 A
Which would have been a block valve, to % :he 23 pressure boundary in accordance with the requirements of the 24 code.
j 05 Q
Would the block valve have been safety relared?
Was l
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the block valve safety related?
1 2
A May I back up the answer to the last question?
I 3
believe I said downstream.
It should be upstream.
I think 4
the PORV noncode has to be downstream of the block valve.
5 Q
So the block valve would be between the PORV and the i
6 code safeties?
7 A
My recollection is that in the top of the pressurizer 8
there are two manifold arrangements.
The code safeties are in 9
a separate piping arrangement from the block valve and the FORV.
10 Q
Is it your impression that the block valve was a 11 safety related device?
12 A
Only from the understanding of the code that I 13 believe it would have to meet, and that is why I said in my 14 opinion it would have to be upstream of the PORV and I 15 inadvertently said downstream.
16 Q
Would it surprise you if neither the PORV nor the 17 block valve were safety related with respect to TMI-II?
18 A
(Pause)
I have trouble with the tern safety related 19 and the way it is used sometimes.
I would say it would sur-20 prise me if that was not an ASME Section 3 code componant, 21 okay.
L 22 Q
Apparently you are working with several definitions 23 of safety related.
Perhaps you could state several of these 24 for the record and distinguish between them.
l 25 A
Well, I mentioned before that I had scme doubts that i
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the true significance'5q, real meaning of these terms is 2
universally understood and I have explored that a little bit 3
and find, I believe, I just got confirmation through what was 4
my understanding from the years 1973 to 1975, that the 4
regulations in Appendix A address componeng systems and struc-5 6
tures important to safety.
7 Q
Is this 10 CFR you are referring to?
8 A
Title 10 CFR 50.
Appendix B addresses the quality 9
assurance program that will be applied to systems components to and structures that are safety related.
And --
11 Q
So, so far we have important to safety and safety 12 related.
13 A
That is correct.
14 Q
A're there any others --
15 A
These two terns appear in the regulations which is, 16 I believe, the basis for all things that follow.
17 Q
Are there any other definitions or uses of the tern 18 safety related besides those two that you are aware of?
19 A
If you review the licensing, the docket file and 20 the questions that are asked you find that some people use the MS 21 term, and we mentioned before the question that directed at 3
22 TM.I where they said based on our review of the information in 23 your FSAR we find the auxiliary feedwater system to be safety
[
24 relared.
5 Q ~
That would be a reference to Appendix 3, I assume.
1 Acme Reporting Company L
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Is that correct?
2 A
Yes, that, in some cases, is a reference to Appendix B
3 B, but I think *fou will find exceptions that Appendix is not A
4 automatically applied.
5 0
Are items which are deemed important to safety 6
treated differently than items which are deemed safety related?
7 A
I believe that's a correct statement, and I would 3
add that items deemed important to safety per Appendix A are 9
not all treated uniformly.
to Q
With respect to the loss of feedwater, was it your 11 attempt to have the auxiliary feed system classed as a safety 12 related item as opposed to an item important to safety, or 13 was it an attempt to have it classified as an item important 14 to safety?
15 A
The classification, per se, wasn't as important to 16 me as how the system design turned out.
17 Q
Would there have been a difference in the way the 18 design turned out based on whether it was deemed important to.
19 safety under Appendix A or safety related under Appendix B?
20 A
It could have been, but when you examine how things 21 are actually treated when the Appendix A is applied, or Z:
Appendix a does not automatically follow, you can't predict the Z3 outcome of this.
24 Q
Getting back to the PORV axi the block valve, would 25 you be surprised to lea;.
that neither the PORV nor the Acme Reporting Company
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54 1
block valve were considered safety related as used in 2
Appendix B?
3 A
I would be surprised to learn that, yes.
I have not 4
looked at that and didn't consider it.
I would say Appendix B 5
is the application of the quality assurance prcgram to those 6
items that have been declared safety related, okay.
So I
Appendix B itself does not delineate or describe or categorize 8
anything as being safety related.
Once I put that handle on 9
something and say that Appendix B applies, then --
10 Q
In other words, Appendix B does not contain a list 11 of items?
12 A
That is correct.
13 Q
Would it surprise you that with respect to the PORV 14 and the block valve, the PORV was not considered safety 15 related because it had a block valve in series with it and the 16 block valve was not considered safety related because it had 17 a PORV in series with it?
You have a lock of surprise on 18 your face.
19 A
The logic defies me offhand.
20 Q
I'll represent to you that that is the testimony of 21 Roger Mattson at the public hearings and also in his deposi-22 tion, the head of DSS one of whcae branches is RSB, the 23 technical reviewers who review the plant designs during the 24 licensing process.
3 If the PORV was not considered safety related, would Acme Reporting Company
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it follow naturally that indication for PORV position-would 1
2 not be considered safety related?
3 A
That is likely, in my opinion, because of the way 4
these things are handled in the review, that once there is an 1
agreement that an item is safety related then the other o
6 branches who worry about the electrical wiring to it or the 7
instrumentation or the power or the quality grouping, and 8
so forth, they would then look at these areas.
So one sort of 9
follows from the other in the process.
10 Q
So would it be correct then that if an initial 11 determination were made that a particular item was not safety 12 related that when that item then went to the electrical 13 engineering people they would not treat it as a safety relate.d 14 item and then would it also be correct that when I&E enforced 15 regulations on the plant during the licensing stage and 16 thereafter they would also not deem it safety related?
Is it 17 a decision that kind of nails it down in cement and then 18 follows for the rest of the life of the plant as either being 19 safety or not safety related?
20 A
Well, I don't have enough experience with some of 21 these things and I can only give my impressions or concerns.
22 But you say do these things follow through from the review 23 and clear :n to the I&E inspections and the applicant's treat-24 ment in the field.
I believe there are subtle things that go 25 on here.
For example, like where an applicant addresses Acme Reporting Company
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56 1
certain features of the plant or certain responses to licensing 2
concerns may be indicative of the treatment that is going to 3
afford that system if not directed specifically otherwise 4
as far as his maintenance priorities, inspection, quality, and 5
so forth.
And my belief is that with regard to some of these 6
items the applicant puts some items in the plant on his Q list 7
which gets reviewed in licensing and certain quality assurance 3
program of applicant is applied to those items.
Then other items that are not on that list may be included in the appli-9 cant's detail plan of the site but not in the FSAR, not reviewed to 11 by Licensing.
12 Now, when the I&E inspectors look at the applicant's 13 activities at the site, I believe that they review what is done to a glven component or system in accordance with the 14 15 applicant's listing of equipment that's included in these 16 stages of the program.
17 Q
In the FSAR?
A It would include the things in the FSAR and depending 13 maybe on the applicant, things in addition to those items in 19 the FSAR.
But there is the possibility here for a lack of gg continuity between the licensing review and the significance 21 attached to these itams from a safety standpoint and how they 3
23 eventually get treated and monitored by I&E.
That's what I'm 24 trying to say.
i 25 -
Q Uhere do you see this breakdcwn in continuity?
Is it l
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57 1
that the I&E people rely on the FSAR and documents generated 2
by the utility whereas Licensing has stated its position in 3
the SER?
Is that basically what you're driving at?
4 A
I'm not sure the use that all of these documents 5
receive by all the people involved in that chain.
As I see it, 6
the Licensing people are quite f amiliar with the plant and the 7
detail design from their review and from their questions and a
they have indicated that the applicant, their position that 9
something is safety related when the applicant either fidn't to even mention it or he has it in a place in the FSAR where you 11 would not expect it to be addressed.
As I pointed out, that 12 carries some possible indication of the applicant's thinking 13 about the system when you find these things in the FSAR where 14 you find them.
15 The people then in I&E in the field don't have al 16 this background information from the review of the FSAR.
- Sure, 17 they have an FSAR; you know, they are kept informed, to my is knowledge, by the system and the process.
But they tr.ke over 19 then and must review and audit the operations in the field 20 without all of this appreciation for the system and cme of 21 the detail.
22 Q
Do you see a lack of coordination between the z3 Licensing people and the I&E7 In other words, are there meet-24 ings and discussions?
Is there a paper flow back and forth in 05 an attempt to give this background to I&E7 j
Acme Reporting Company
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1 A
I can't address that in an operating stage, but 2
during the construction I maintained close liaison with the 3
inspector.
4 Q
The I&E inspector?
5 A
The I&E inspector on the plant.
I made site visits 6
and inspections with him.
7 Q
Is it your understanding that that was a normal 8
procedure or is this something that you adopted as seeming l
9 reasonable?
10 A
It may have been done in other cases but it was not 11 a requirement or a routine thing.
12 Q
Did you arrange for the I&E inspector to come to the 13 site and tour the plant with you?
~
14 A
I coordinated it with him and arranged to meet him.
15 Sometimes I'd meet him there; sometimes I would ride out with 16 him from Philadelphia.
17 Q
To what extent was experience at other B&W plants 18 which were already operating incorporated into your coordina-l 19 tion of efforts at TMI-II?
Was there any method by which 20 such experience could be brought to bear or was brought to bear?
21 A
As I recall, I think it was a unit at Oconee that r
had started into operation at the time I was working on TMI, 23 and there was, as I recall, no formal channels where I saw 1
24 things like what we call the LERs now or event reports or 25 abnormal occurrence reports, maybe they were in those days.
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But I tried to talk to people in operating reactors who were 2
following the daily operations of that plant with the startup 3
testings and things like that, the fellow who was the project 4
manager there, and find out what was going on.
5 Q
Was tnere any formalized or systematic way by which 6
you were kept abreast of operating experience at other B&W 7
reactors?
8 A
No, the only contact I had was through a friend who 9
had the Oconee plant as an operating unit, and he kept up, 10 of course, daily with the occurrences.
11 Q
At his own plant?
12 A
At his own plant, yes.
13 Q
Do you recall what his name was?
LeoMcDon3{.pk ou 14 A
15 Q
Were you aware of a transient that occurred at the 16 Oconee plant Unit 3 on June 13, 1975?
17 A
A transient.
Could you say something about the
[
18 transient?
That much doesn't mean anything.
j l
19 Q
Were you project manager at TMI-II on June 13, 1975?
l
'N Were you still there?
21 A
That was about the end, approaching the end.
I was 22 still there, to my knowledge, on that date, yes.
23 Q
Were you there until the end of the month?
24 A
Near the end of the month.
n Q
Okay.
Let me read to you a summary which is contained Acme Reporting Company
60 1
in -a document which bears the number AO-287/75-7 from the
-2 DukeEPower Company, Oconee Unit 3.
There's a paragraph on 3
the first page entitled, "Deteription of Occurrence."
It 4
reads as follows:
5
" Description of 0.currence:
On June 13, 1975, a 6
routine shutdown for maintenance was in progress on Oconee 7
Unit 3. - When reactor power had decreased to approximately 8
15 percent a minor system transient occurred which resulted in 9
the opening of the power actuated pressurizer relief valve, 10 3RC-66.
Valve 3RC-66 remained open and a reactor r lant 11 system depressurization continued until isolation
've 12 3RC-4 was shut.
The reactor coolant system temperature and 13 pressure were 480 degrees Fahrenheit and 720 psi, respectively, 14 when the depressurization was terminated."
15 Then in a subsequent paragraph entitled " Designation 16 of Apparent Cause of Occurrence" it reads:
17 "The apparent cause of this occurrence was operator is error in that the operator did not consider the initial RC 19 temperature drop which occurred during repressurization when 20 establishing the subsequent ecoldown rate.
The reason 3RC-55 21 remained open was due to boric acid cryscal buildup on the
.22 connecting pin of the lever arm of the pilot valve.
In addi-23 tion, a cellonoid operated plunger was stuck in che open 24 position."
l i
-l 25 This appears to be a description of a failed ocen l
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PORV followed by a partial blowdown of the plant.
Were you 2
aware of this occurrence at the time you were project manager 3
of TMI' 4
A I was not.
I recall, I think, a pump seal failure 5
that bothered me, I believe, in the Oconee plant there.
6 Q
A pump seal?
Which pump?
7 A
a reactor coolant pump.
8 Q
Did similar problems develop during the licensing 9
process at TMI?
10 A
I checked and found that it was a pump of different 11 design and manuf acture, so that didn ' t --
It doesn't say it 12 won' t happen, but it wasn't the same problem.
13 Q
Once you discovered that the pump was a different 14 design, you took no further action in that regard, is that 15 correct?
16 A
I believe that's right.
Just to determine what the 17 differences were, or were they the same; and they were la different.
(Pause)
With regard to the abnormal occurrence is that you mentioned at Oconee, the boric acid crystals on the 20 PORV, I recall that occurring some place, but it may not be 21 this event.
22 Q
Do you now know of a transient which occurred at 23 Davis-Sesse in 1977 which resulted in a stuck open --
24 A
(Whispered) September.
3 C
(Laughter)
September -- Apparently you are aware Acme Reporting Company
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\\
I of that one, which involved a stuck open_ PORV in part because 2
of crystalization formation?
Are you aware of that transient 3
now?
4 A
Yes.
I was aware of it before TMI.
5
,Q 3efore the TMI accident?
6 A
Yes.
7 Q
Af ter the time that you were project manager, 3
necessarily?
9 A
That's true, necessarily.
10 Q
Is that the transient, perhaps, that you were referr-11 ing to which involved the crystaline formation on the PORV stem?
12 A
Well, I don't remember that detail of that one, but 13 I think the point is that this may be a thing that has happened 14 many times 'before and it is to be watched here in trying to 15 create a reliable position indicator.
16 Q
How did you become aware of the Davis-Besse transient 17 prior to the TMI accident of this year?
18 A
In my recent work I've been trying to address safety 19 improvement in light water reactors, and of course I fish 2
around and try to get ideas and think of what people ought to 21 work on and things like this.
S Q
This is your work at Los Alamos you are referring to?
23 A
~In the vaactor safety program, right.
And I sort of 24 go from one task to the other or pick things up and move to 3
something and come back and so forth.
But I had developed Acme Reporting Company ac a,.. 4...
63 i
somewhere along the line the idea that safety systems should 2
never be challenged in a light water reactor plant.
You should 3
run for 40 years and the only time they are ever operated is 4
when you test them routinely.
5 Q
What is the reason for that?
6 A
Well, they are a line of defense against serious 7
accident.
8 Q
Would it be fair to --
9 A
So if you just let all the safeguards down and say, 10 gee, I've got these features that will keep me out of trouble, 11 I think that's not good clear thinking.
So my thinking and 12 approach has always been that, as I said in Nevada, we are 13 here to run reactors, not to scram them.
And that means that 14 you are in control of the situation; you don' t have to rely 15 on your emergency and safety features.
l 16 Q
How does the Davis-Besse transient fit into that 17 scenario?
18 A
Well, with that basic premise that I mentier.ed, the 19 philosophy, I had g0nt through the LERs looking for all situa-20 tions I could identify where the safety features had been 21 challenged or used in any way during the course of routine r-operations and anticipated transients, and that includes all 23 events prior to TMI-II.
24 I had flagged these things in the process of sorting l
I 25 and collating and =arked the abstracts where I found this as Acme Reporting Company
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an early phase of my analysis to see what was going on, and 2
of course, TMI-II occurred and I was distracted and after some 3
time I went back and reviewed these things.
I was going to 4
pick this idea up again.
Of course, the details of that 5
scenario did
't occur to me at the time of TMI-II, okay.
When 6
I went back and I read it, I was in a state of shock and I 7
wrote a memo and said call this to people's attention and I os' 8
said I am puzzled as to why in Bulletin 79, the PNO's I guess 9
that came out of I&E, that they referred to some other event to at Davis-Besse a couple of months later because the similarity
$bi$
of the September event at Davis-Besse was yg.'Asf.
11 3
12 And the conclusion I drew from this was, okay, 13 safety is my concern, okay.
I flagged that event because of 14 my criteria that I would like to prevent all situations where e
15 safety features are ever called upon to operate, operatsonaa-n is routinely, and so forth.
,c d I said, well, I didn't forecast 17 TMI.
I would have gotten there eventually through this is criteria I was applying.
What can we do to stop these things?
po 2-3 19 That's how I got to Davis-Besse.
20-Q At the time you were 1 coking through the Leas on 21 Davis-Besse, were you aware that the operator at' Davis-Besse 22 had terminated HPI during the course of the September 1977 23 transient in reliance on rising and high pressuri er level at 24 the time he was losing coolant through the PORV which had l
3 stuck open?
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A I. assume that information is in this abstract that 2
I have, but that didn' t catch =y eye and load to any forecasts 3
either.
4 Q
Did you obtain these abstracts from the NRC?
5 A
From the OakRidge, NSLIC, is that correct?
I don't 6
know, but they are published periodically and compiled at 7
Oak Ridge.
S Q
Were you aware prior to the TMI-II accident of this 9
year that a number of persons within the NRC staff had 10 essentially predicted the TMI-II transient based on such 11 events as the September 1977 Davis-Besse transient?
I will 12 just throw out some names:
Cresswell, Israel, Ebersall, 13 Michelson.
14 A
May I ask the first part of the question again?
15 Q
Were you aware that any of these people prior to 16 the TMI-II accident had essentially predicted the TMI-II 17 accident based on such prior transients as the Davis-Besse 18 September 1977 transient?
19 A
I was not awarc of this and only after TMI-II, 20 awareness of only the concerns of a couple of these people 21 you mentioned.
Pebble Beach was --
22 Q
Pebble Springs?
23 A
Pebble Springs, excuse me -- I keep moving that plant--
24 was called to my attentien by someone in NRC shortly after 25 TMI-II.
I came downtown to the Public Occket acom and got a Acme Reporting Company i m, u.a...
66 I
copy of that question and the response.
2 Q
Are you referring to Jessie Ebersall's question 3
number six to B&W which was unanswered?
4 A
26?
5 Q
Well, there were several.
My recollec; ion is there 6
were 6, 12, and 26, and that B&W failed to respond to Jessie 7
Ebersall's concerns on that score.
8 A
You have comments cleaned up.
9 Q
But this is something you discovered after the 10 TMI-II accident?
11 A
After.
That was pointed out to me.
I was referred 12 to that as background af ter TMI-II.
So that had gone on, 13 h7 wever, prior to TMI-II.
14 Q
D'uring the course of the licensing process, was 15 there any systematic or formalized incorporation of operating la procedures or experiences with operator procedures in the 17 licensing process or the review of the PSAR or FSAR?
18 A
Was there any review of the operator actions and 19 procedures during the licensing review?
20 Q
Yes.
21 A
Yes, there was.
22 Q
To what extent?
23 A
In several ways.
There was a question tnat in light 24 of the event at TMI-II now, this question was addressed to 25 the applicants regarding the termination of safety features
% SeC#W /?tth.c r/r.53w.re 4 / / / h ddm nok
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actions by the operators --
2 Q
Such as ECCS?
3 A
I interpret it as any safety feature.
The question 4
was addressed because the applicant's maybe ambiguous or 5
a statement in the FSAR--I don' t know the detail of that--
6 but the staff did address --
7 Q
This question was addressed at the time that you 8
were project manager for TMI-II?
9 A
I believc that is correct, yes.
10 Q
co you recall what the substance of the c estion 11 was?
12 A
I think they were looking for a commitment out of 13 the applicant that the operator would not terminate any safety f.
featuresactionsthatwereautomaticallyinig'iated-period.
14 15 Q
Do you recall what, if any, response was received?
16 A
I don't recall the specific response or whether it 17 was acceptable.
18 Q
Would there be any vay for you to obtain and provide 19 to us the question to which you have referred and the
'M response, if any, that was provided in response to this 21 question?
22 A
The question and the response should both be in the 23 application, in the FSAR, or supplement to it.
So I should be 24 able to provide that to you.
05 1
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MR. EELFMAN:
Okay.
Perhaps we can have a stipulation 2
that Mr. Washburn will provide that to us and upon receipt of 3
it, it will be deemed Exhibit No. 2 to the exhibit.
Is that 4
agrceable?
5 MR. OLSON:
Yes.
6 (WHEREUPON, the information 7
referred to will be marked for 8
identification when received as 9
Exhibit 2 to the Deposition.)
10 BY MR. HELFMAN:
11 Q
Is that the extent to which operator procedures were 12 taken into account during the course of the licensing review, 13 as best as you can recollect?
14 A
I don't recall any others, but there may have been.
15 I would add, because the question is kind of general, that in 16 the review of the accident analyses, if you will, in antici-17 pated transients, operator actions ray be required at some 18 time to reset things or turn things off or start pumps or 19 do something, okay, during the course of that accident or 3) transient in order to get an acceptable outcome.
And these 21 are generally questioned as to the time at which'the operator 22 must take this action.
My recollection here is that they 23 allow no credit, as they state, for operator actions prior to 24 ten minutes after an initiauire event.
25 Q
Was there any review of the procedures themselves to Acme Reporting Company
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determine their content or whether they were the appropriate 2
action to take or whether it was possible for the operator to 3
perform them?
A There is really no review to my knowledge in 4
5 Licensing of the operating procedures.
The operator licensing 6
branch, I believe it is called, receives a copy of the appli-7 cant's emergency procedures, operating procedures, which they use in examination of the operators.
But my understanding g
here is that those procedures are accepted as written and they 9
are treated as proprietary, perhaps is the answer, but they 10 are submitted in some confidence and the are not distributed 11 to project managers or other reviewers.
They are strictly gg used by the operator licensing branch to conduct the operator 13 exam for a given plant.
g4 Q
Would it then be accurate to say that an operator 15 procedure, whether correct or incorrect, would be incorporated 16 l
in the examination of operator applicants by OLB?
17 i
A It's my opinion that that would occur.
18 Q
Was there any systematic or formal review of control ig room design or layout during the licensing process?
3 A
Not to my knowledge.
3 Q
Do you know what the Response Review 3 ranch is?
A N,
I don't.
23 Q
From your perspective as a project =anager, what 3
was the role played in licensing by the ' commissioners, if any?
3
}
Acme Reporting Company
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- O 1
A Well, I can' t think of any examples that would show 2
that there was a role or how it would relate.
3 Q
Are you aware of the design differences, 3&W design 4
compared to the Westinghouse design and the CE design?
I 5
am speaking generally now of the steam generator side.
6 A
I would say I guess I'm aware of some differences.
7 Q
Are you aware of the comparative boil out times?
8 A
In a talitative sort of way, I guess I tried a 9
couple of times to find out about quantities of water avail-10 able in t.he B&W stemn generator and all I got was answers in 11 inches from some place and that doesn' t help me at all.
12 Q
Have you become aware of the amount of time it takes 13 for the B&W steam generator side to boil dry in full power 14 or after a scram as opposed to the Westinghouse and CE plants?
15 A
In a qualitative sort of way, yes.
16 Q
What is your impression in that regard?
17 A
The steam generators in some of these transients 18 go dry very quickly, and --
19 Q
Is that true of all three designs?
20 A
In the B&W; my response applies to the B&W.
The 21 others, no, are the order of minutes, if I recali, before you a
dry out the steam generator.
And I would put the 3&W plant 23 down in the seconds category in this qualitative answer.
24 Q
Is there a correlation between sp ad at which the 05 3&W OTSG boils dry and the amount of time an operator has to l
l Acme Reporting Company
71 1
an emergency or a transient?
1 2
A There may be.
I think there is another aspect if 3
your concern is how fast the ope'rator must respond, another 4
aspect.
5 Q
Is there yet another aspect that you were thinking of?
6 A
The behavior of the primary system, not unrelated to the steam generator, of course, okay, but it involves 8
pressurizer, the volume of the pressurizer, the loop seal to 9
the pressurizer, the location of the pressurizer, the dynamics 10 of the system.
11 Q
Would you agree with the characterization that the 12 Westinghouse and CE designs are far more sluggish and forgiv-13 ing than the B&W design?
14 A
That's my understanding, but never having operated 15 one of those plants, I wouldn't know.
Is Q
What advantages can you see in a design which is 17 very quick to react and relatively unforgiving in the course is of a transient?
19 A
That places a lot of demands en everything else--
20 all the other hardware, the operator, and so forth.
That I 21 can relate to because our nuclear rocket program, we change rt power in short periods and high rates, so we can have--no pun n
intended--a fast accident.
So that's even more of a problem 24 than, say, like a B&W relative to other designs.
25 Q
Can you think of any advantage to the 3&W design, Acme Reporting Company
72 1
recognizing these characteristics, from perhaps the point of 2
view of the utility or the vendor or the NRC?
3 A
well, I suppose there are differences and pluses and 4
minuses, but I have no opinion on that.
5 Q
You indicated that you lef t the NRC in 1975.
Did 6
you return to Los Alamos?
7 A
Yes, Sir.
8 Q
And have you been with Los Alamos ever since?
9 A
That's correct.
10 Q
You indicated initially that you were assigned by 11 Lea Alamos to the NRC for this brief period between 1973 and 12 1975.
Have you, since you lef t the NRC, been assigned by 13 Los Alamos to any other projects or departments?
14 A
I have been en assignment to Department of Energy 15 here in Germantown since last Fall, last October, as part of 16 our light water reactor safety improvement effort.
17 Q
Does that temporary assignment continue to the 18 present?
19 A
The understanding was it would terminate at the end N
of this fiscal year.
21 Q
Have you in turn been temporarily assigned by 00E to 22 any projects or departments?
23 A
No.
I get my direction from Los Alamos Scientific 24 Laboratory, and I merely exchange information with DOE and l
l 25 others and do not take direction frcm the Department of Inergy.
1 Acme Reporting Company J
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Q I see.
Has Los Alamos assigned you to any other 2
departments or projects since you were assigned to DOE?
3 A
I was asked to provide what assistance I could to 4
the President's Commission on the Accident at Three :lile 5
Island.
6 Q
Would it be accurate to describe you as bascially 7
in a consultant capacity?
8 A
That's possibly correct.
I don't look upon myself 9
as a consultant.
10 Q
As opposed to employee?
11 A
That's true in that sense; that's true.
12 Q
Or as opposed to staff member?
13 A
That's true.
14 Q
When did this latest assignment begin?
J 15 A
Ayproximately two-and-a-half weeks ago.
16 Q
Would it be accurate to state that you are concerned 17 with technical matters in your present position with the 18 President's Commission?
19 A
That's the kind of questions that have been addressed 2
to me.
21 Q
I have one final question which goes back to the 22 intervenors which we mentioned at the outset.
Was it your 23 impression that the intervenors had sufficient technial 24 knowledge and funding to adequately represent the concerns of 25 the community?
Acme Reporting Company
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A I don' t know anything about the funding that was 1
2 available to them or the people really involved.
As far as 3
the technical side, I believe that Chauncey Kepford had scme 4
technical background and that he was a knowledgeable person 5
and he could ask good questicas.
6 Q
He had the technical competence to match NRC technical people in an exchange during the licensing process?
~
8 A
I can't make that judgment, but he was an informed 9
person that, as I say, asked good questions and ind Gated some 10 knowledge.
11 Q
Would you put his inquiries en a par with those that 12 were addressed by the NRC staff reviewers?
13 A
This, I guess, involves a matter of the detail of 14 one's questions versus the importance of the generalities or 15 the areas being addressed by the other, and I think we were 16 looking at apples and oranges there.
17 MR. HELFMAN:
I have no further questions.
.v.r.
- Olson, 18 do you have any questions?
19 MR. OLSON:
Yes.
It night be well just to ask a 20 couple of questions to clear the record.
21 CROSS EXAMINATION 22 3Y MR. OLSON:
23 Q
Mr. Washburn, you stated early on and then later en 24 in the deposition that you are employed by Los Alamos 25 Scientific Laboratory.
Is that correct?
l Acme Reporting Company
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A Yes, Sir.
2 Q
What is Los Alamos Scientific Laboratory?
Could 3
you briefly state?
4 A
The Los Alamos Scientific Laboratory is owned by 5
the Department of Energy and operated for the Department of 6
Energy under contract by the University of California.
7 Q
That's correct.
And you work for the contractor, 8
is that correct?
9 A
I work for the contractor.
10 Q
And not the Department of Energy?
11 A
That is correct.
12 Q
And therefore any assignments that are made for you 13 are made by your employer, the University of California, and 14 not the Department of Energy?
15 A
That is correct.
16 MR. OLSON:
Thank you.
I have no further questions.
17 MR. HELFMAN:
Okay.
On that note, wa will conclude is the deposition.
Thank you very much for your time.
19 (WHEREUPON, at 3:30 p.m.
the Deposition was m
recessed.)
CA/vis 21 22 23 24 25 Acme Reporting Company
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j 2
3 REPORTER'S CERTIFICATE 4
5 DOCKET NUMBER:
6 CASE TITLE:
Deposition of Beverly W. Washburn 7
HEARING DATE: August 29, 1979 8
LOCATION:
Washington, D.C.
9-I hereby certify that the proceedings and evidence herein 10 1
are contained fully and. accurately in the notes taken by me 11 at the hearing ir. the above case before the 12 President's Ccmmission of the Accident at Three Mile Island 13 and. that this is a true and correct transcript cf the same.
14 15 Date:
August 30, 1979 16
( Wh&A )
18 Official Reporter 19 20 Acme Reporting Company 21 1411 I Street, N.W.
Washington, D.C.
22 23 24 25 Acme Reporting Company ge.m.<m J
i O*
3EVERLY W. WASH 3UP.N iduca-ion:
University of New Mexico, 3.S. II, 1949 Stanford University, M.S. EE, 1951 Exterience:
Thirty years in diverse technical fields --
1949-1950 General Electric company, Test Program 1951-1952 Pacific Gas & Electric, Office Engineer 1952-1958 Sandia corporation, Staff Member-Section Leader, Field Test 1958-1959 Space Technology Imb~ oratories, Assistant Department Manager, Data Analysis Department 1959-present Los Alamos Scientific Laboratory, Staff Member --
Nuclear Rocket Program 1960-1970 ram 1971-1973 Gas Laser Prog /NRc AEc Regulatory 1973-1975 Reactor Safety Research 1975-present a, _ _ __
-- 3 n--
_.r 2
_3EVERLY W. WASHBURN DEPOSIT *CN 1
m
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