ML19322C221

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Transcript of 791105 NRC Interview of WR Cobean & as Dam of Burns & Roe in Paramus,Nj.Pp 77-108
ML19322C221
Person / Time
Site: Crane 
Issue date: 11/05/1979
From: Cobean W, Dam A
BURNS & ROE CO.
To:
References
TASK-TF, TASK-TMR NUDOCS 8001160642
Download: ML19322C221 (32)


Text

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2

3

--X 4

In the Matter of:

5 THREE MILE ISLAND SPECIAL INQUIRY DEPOSITIONS 6

-_______________x 7

0

~

SI5'R9IEN~OF':'

WARREN R'. "C'O' BEAN,~JR'.~

~~

~~

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and ALLAN SCOTT DAM l

i 9

Offices of Burns & Roe 10 650 Winters Avenue Paramus, New Jersey I

3j i

Monday, November 5, 1979, I

9:30 a.m.

13 BEFORE:

Id For *.he Nuclear Regulatory Co:nmission:

IS HANS SCHIERLING, TMI/NRC Special Inquiry Group BARRY HORVICK, TMI/NRC Special Inquiry Group p

16 For Burns & Roe:

17 4

i TOM A. HENDRICKSON, Assistant to the President IE KEVIN MURPHY, Senior Counsel l-RICHARD B.

DiFEDELE, Staff Attorney 9

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MR. MURPHY It's not a deposition at a;1.

l 2

MR. HORVICK:

It is a continuation of the I

3 interview conducted previously.with Mr. Cobean.

We'.11 be 4

questioning Scott Dam.

5 Whereupon, i

6 ALLAN SCOTT DAM

'l 7

was called as a witness, was examined, and testified as 8

f olloWs3 I

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9 EXAMINATION 10 BY MR. HORVICK:

11 O

Let's see.

Mr. Dam, have you read the. witness 12 notification -

13 A

Yes.

14 Q

-- form, and you understand it?

15 A

Yes.

16 0

Okay.

Mr. Dam, could you tell us.what prior 17 testimony you've given regarding Three Mile Island 2 18 A

I've given no testimony on the record.

19 O

Okay.

And I would also like to get this on the 20 record.

21 Mr. Hendrickson, you have given testimony.

22 MR. HENDRICKSON:

Yes, I have.

I 23 MR. HORVICK:

In front of the President's 24 Co mmi ss io n.

And just to get it on the record, that 25 testimony does in part cover this issue of the AEs' role 2 i

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MR. HENDRICKSON. It covers it extensively.

2 MR. HORVICE:

And the utility's operating license 3

and decision to go into commercial operation.

Ukay.

4 To get into the --

i i

5 MR. HENDRICKSON:

This might be helpful.

The i

i 6

testimony was, as I remember, on Wednesday and Thursday, I

7 August ist and 2nd of this year.

8 BY MR. HORVICK:

9 0

Okay.

Now, Mr. Dam,.were you at the TMI site for

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10 the full calendar year, 1978?

11 A

Was I at the TMI site?

12 0

Yes.

13 A

No.

14 0

Well,.were you involved in any of the pre-op or 15 start-up tests at the site?

I 16 A

No.

17 0

Okay.

What.was your involvement with TMI, then, 18 during 1978?

19 A

I became the Project Manager for Burns & Roe in 20 March, 1978.

Burns & Roe at that time was still involved 21 with the construction, design and construction contract for 22 the Three Mile Island Unit-2.

23 0

Could you tell us more specifically what your 24 duties were as Project Manager?

25 A

The Project Manager is responsible for the overall t

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operations in the company, as Burns &. Roe, for the project, 2

for the project being for the design 'of the Three Mile 3

Island Unit-2.

Burns & Roe was responsible for the balance 4

of plant design.

5 0

Let's see.

Was there any significant change in 6

the character of your duties after TMI 2 gained its 7

operating license of February 8, 19782 1

8 A

Again, I say that I became Project Manager in l

9 March, after they had the operating license.

10 MR. HORVICK:

Okay.

If we could go off the record i

4 11 one second.

12 (Discussion off the record. )

13 MR. HORVICK:

If we could go back on the record,.

14 then.

At this point, for the record, I would just like to 1

15 identify the authors of these questions as Larry Vandenberg, 16 V-A-N-D-E-N-B-E-R-G, and David Evans.

17 MR. MURPHY:

Employees of whom?

18 MR. HORVICK:

They are both with the Task Oroup of 19 the Nuclear Regulatory Commission dealing with precursors to i

20 the TMI-2 accident.

21 MR. MURPHY:

From where?

From the government?

22 From the NRC offices or --

23

.MR. HORVICK:

Yes.

They are with the NRC.

24 Right.

They are.

25 MR. MURPHY:

Okay.

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BY MR. HORVICK 2

0 If we could just back up a second, Mr. Dam, some 3

of the questions I've asked up to this point, you have 4

responded to them as an individual.

If we could look at

~

some of these questions in a larger context, if you were not o

6 personally responsible for certain pre-op and start-up tests 7

during 1978, are you aware of any other B&R people under you I

8 or any other divisions of B&R that were involved with these 9

tests?

l 10 A

Burns & Roe prov.ided an engineering liaison 11 service during the start-up test program.

In that regard, 12 we had an engineer assigned to the Tect Working Group.

His 13 name was Rich Brownewell.

14 0

If we could just discuss your attendance at any 15 monthly meetings conducted by 'the GPU Project Manager, were 16 there any such meetings that you know of, and did you, 17 indeed, attend them?

18 A

During the design and construction of TMI Unit-2, 19 there were monthly Project Managers' meetings of which the 20 GPU Project Manager, the Burns & Roe Project Manager, as 21 well as the constructor -- and I believe B&W is the reactor 22 manufacturer -- attended.

They were typically held at the 23 TMI site.

I believe shortly af ter the operating license was 24 obtained, those meetings were stopped as far as the design 25 project goes.

There were subsequent meetings called the i

i 1

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monthly Project Managers' meetings held on the site, but 2

they dealt with first refueling project items.

3 0

In the course of any of these meetings that you've 4

Just mentioned, was there talk of some kind of a target date 5

for going into commercial operation?

/

6 A

Yes.

7 Q

Could you tell us.what the import of those 8

discussions was?

9 A

I don't understand your cuestion.

10 0

Okay.

Was the issue a question of time or GPU 11 people saying, "We need to get into operation, commercial 12 operation,"

within a certain period of time?

13 A

I don't remember,the discussions phrased in that 14 manner.

The date of commercial operation really was not 15 something that either the Project Managers or specifically 16 Burns & Roe were particularly concerned with.

I_t_as more of 17 a financial consideration or whatever.

We had target dates

~ _ _ _ _

18 for various things that we were doing, and certainly the 19 commercial operation date was mentioned.

But more 20 importantly, we_wer_e_ talking. about_ a target system operation 21 date of when the_ plant _wou_id be at full power.

22 MR. HENDRICKSON:

I think if I might elaborate on j

23 that, the commercial operation date is not technically 2a oriented.

Obviously, the plant must be completed and tested 4/'

25 and accepted before that.

But the date is a utility matter, i

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not something -- commercial operation is a utility matter, 2

not something the architect engineer is involved with 3

directly.

4 BY MR. HORVICK:

5 0

Right.

We're just trying to pick up as much 6

information as we can in this. area.

I think if something 7

was passed on to you, you could perhaps tell us about it.

8 In fact, can you specifically recall what the discussion 9

concerning commercial operation did have to do with?

10 Apparently, you weren't pushed in terms of time, but 11 whatever discussion you did have along those lines, can you 12 remember what the thrust of such discussions were?

13 A

There were a variety of dates, again, to target 14 system operation, 100 percent power, which we were working 15 for and various completions of tasks.

By the time of 16 initial criticality, there were not too many Burns & Roe 17 related tasks that were required to be done to support IDO 18 percent power.

And during the spring and summer, various 19 dates were mentioned as far as target dates for LOO percent 578.

I think that answers 20 power, starting like in June of 21 what you're looking for.

22 0

Yes.

I think that does.

Let's go on then.

Which 23 OpU Service Corporation and Met Ed people did you regularly 24 work with or discuss plant problems with when you became 25 Project Manager?

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A I believe --- and this is a recollection --- that 2

when I became Project Manager, Dick Heward, H-E-N-A-R-D, was 3

the GPU Project Manager for the design and construction.

4 Shortly thereaf ter, I believe that John Barton became i

5 Pr ject Manager, and I don't remember the dates on any of o

6 these changes.

After Barton, Clay Montgomery became.our 7

contact as the GPUSC Project Manager.

8 With regard to Met Ed, we had a number of contacts in the i

j 9

Gary Miller site organization as well as with Met Ed, 10

  • Reading, and that group is headed by Dick Klingaman, and 11 there were many individuals involved in all of the 12 organizations.

13 0

Let me ask you, specifically with regards to 14-commercial operation, did you ever have any discussions with 15 any of the people that you've just mentioned regarding 16 commercial operation?

Even more specifically, a need to get 17 the plant into commercial operation by a specific date?

18 A

Again, this was over a year ago, and I don't l

19 remember the discussions at all regarding commercial 20 operation.

It was a date that was being mentioned at 21 various times.

But as far as a Burns & Roe target date, it i

22 really didn't play a factor in our work.

It was more of a 23 general interest.

24 0

Let me ask you, had you ever heard anything about 25 a May 31, 1978, target date for TMI-2 going into commercial i

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service?

2 A

I believe I said first of June, but.May 31 could 3

have been the date as well.

4 0

All right.

5 A

That was the date, I believe, that was chosen very 6

soon af ter initial criticality.

7 0

Do you have any insight as to why that date was 8

specifically picked?

9 A

No.

10 MR. HORVICK:

If we could go off the record for 11 one second.

12 (Discussion off the record. )

13 MR. HENDRICKSON:

Back on the record.

I'd like to 14 amplify Mr. Dam's responses to these questions by saying 15 that architect engineers do operate in accordance with 16 schedules for all projects.

And there is also a schedule or 17 pressure on us by all clients to get the power plants 18 finished and on the line and generating electricity.

19 In the case of the Three Mile Is1,and project and GPU, we 20 have had schedules throughout and operated and did our. work 21 in accordance with schedules.

And there was schedule 22 pressure by GPU, as there is from all clients, but there was

.I 23 no undue pressure.

We did the job completely and u'

24 thoroughly, and all requirements that we were aware of in f

25 the course of the design and testing program for the plant.

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'I might also add that our contract with Gcneral Public 2

Utilities is a standard architect / engineers contract.

It is 3

unrelated to meeting particular schedules or goals.

We were 4

paid for our work with a multiplier to meet our costs and a 5

modest fee.

l 6

MR. HORVICK:

Off the record again, please.

7 (Discussion off the record.)

06 ~

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MR. HORVICK:

Back on the record.

2 Mr. Hendrickson, in view of what you have just said, we 3

have looked in Mr. Cobean's deposition taken by the President's l

4 Commission.

At page 154 of that deposition, Mr. Cobean 5

testified that, "The client was always concerned about meeting 6

a commercial operation date.

That was his principal goal in 7

life, to make that ccmmercial operation date in some way."

i

'8 Could you speak a little about Mr. Cobean's statement?

Does 9

it in any way refute what you just said?

10 MR. HENDRICKSON:

No, I don' t believe it does.

If l

11 you read the entire section of Mr. Cobean's testinony, you l

i 12 will see that the gist of his remarks are roughly the same as 13 mine.

And that the particular quote is taken out of context.

14 Mr. Cobean was indicating that all clients are properly 7

15 concerned with the timely completion of their plants and

{

16 placing their utilities in commercial operation.

But, there 1,

17 is no one who has concern, to our knowledge, on the part of I

18 General Public Utilities and in'no way were short-cuts taken

/

1 19 to our knowledge, in the completion of the Three Mile Island 20 Unit No. 2.

4 21 BY MR. HORVICK:

22 G

Okay.

Going on, Mr. Dam, you stated that you weren' t: --

23 that commercial operation dates were not a majcr concern of j

24 yours.

But, to the extent that you did know about the target

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.25 dates for commercial operation, did you report them to your l

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superiors?

Was thnre any discussion about these dates?

Was it 2

an important issue with your superiors to know about such a

3 dates?

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l 4

A The commercial operation date that was discussed j

5 previously was certainly mentioned to my superiors, Mr. Cobean, 6

again, for general interest.

I don't remember any lengthy 7

discussions with him or anyone else in particular regarding i

8 ccmmercial operation.

9 MR. MURPHY:

Ask another question.

10 BY MR. HORVICK:

l 11 g

Okay.

We are moving into a new set of questions l

t 12 here relating to the April 23, 1978, transient.

Were you i

13 on the site when the main steam safety relief valves failed i

14 to recede?

1 15 A

No.

i 16 4

Could you tell us where you were?

I 17 A

No, because I don't remember there I was.

I 18 remember I was not in the office.

19 MR. MURPHY:

Do you have a date when that happened?.

20 BY. MR. RORVICK:

21 g

April 23.

f 22 A

I would have to check a calendar back then of where i

23 I might have been.

24 MR. SCHIERLING:

Do you recall that particular w %n.n. w.

25 transient?

b_.. __...

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3 I

THE WITNESS:

Yes.

2 MR. HENDRICKSON:

According to my calendar, Scott, 3

April 23, 1978 was a Sunday.

Would that help?

j i

4 THE WITNESS:

I think Ron Toole called me at home I,-

v' 5

that Sunday, as a matter of fact, asking me some technical 6

questions regarding the safety valves.

And I remember taking I

7 some data on a netepad that was hanging up on the wall in the 8

basement.

9 BY MR. SCHIERLING:

l 10 0

Did he identify to you the reason for that call?

11 A

That's the call I i.m thinking of, he was asking for 12 some information regarding the safety valves.

It may not,

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i 13 in fact, be that same call.

l 14 4

I just wonder, Mr. Dam, assuming that April 23 was, j

15 indeed, a Sunday, you mentioned that you did become aware of j

16 the main steam safety valve not receding.

Were you involved?

17 Was Burns & Roe involved in any follow-up action on that 18 transient?

19 A

Yes.

}

20 G

And if so, what were the activities?

t 21 A

Our main. activity w;as -- first started out with an 22 evaluation in detail of the main steam safety valves that were 23 provided by Lonergan Company, how they were supposed to perform, 24 and how in fact they were performing, along with various reviews

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25 to determine what corrective action or additional testing h/

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chod1d be undertaken with regard to the Lonergan valves.

2 Subsequent to that time, after numerous meetings, discussions, 3

tests, et cetera, it was concluded to replace Lonergan safety 4

valves with a different designed valve.

And Burns & Roe l

5 provided the design for those modifications.

i i

6 G

Was that activity requested of you by the GPU l

i 7

organization?

j 8

A Yes.

I

'9 MR. SCHIERLING:

Why don't you go off the record?

10 (Discussion off the record.)

11 BY FUt. HORVICK:

12 G

Back on the record.

I 13 Do you remember any discussion about the May 31, 1978, 14 commercial operation date in regard to this transient?

l 15 A

Only that late in May, the date was changed.

But 16 I don't even remember what the date that..they changed it to 17

was, i

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18 G

Do you have any knowledge of what kind of factors l

19 went into that change of date?

i 20 A

Only that the plant was not going to be operate 21 at 100 percent power because the safety valves were being 22 replaced.

23 G

But you personally weren't involved in any of those 24 discussions?

N Reconen, Inc.

25 A

As we have talked, commercial operation was something I

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the utility was involved with, not Burns & Roe.

I 2

BY MR. SCHIERLING:

l 3

O These safety valves that we are talking about, are l

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they within the scope of supply of Burns & Roe or of the 5

NSSS vendor?

6 A.

Burns & Roe specified the valves based on the B&W i

I 7

design requirements.

And purchasing was done by GPU, as was 8

all procurement activities for the balance of plant equipment.

+

9 BY MR. HORVICK:

10 0

Okay.

Mr. Dam, we have another question here based:

11 on Mr. Cobean'sdepositiontakenbythePresident'sCommission.l 12 At.page 157 of that deposition, Mr. Cobean testified that it t

13 was important to GPU for accounting reasons, if for no other

,I

.14 reason, to try to get the plant on-line commercially before 15 the end of 1978.

j 16 We are aware from your testimony up to this point, that you !

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17 had very little import or discussion regarding target commercial i

18 operation dates.

But do you know anything at all about this 19 kind of reasoning in regards to a commercial operation date?

20 A.

Time out.

21 MR. HENDRICKSON:

Off the record.

22 (Discussion off the record.)

23 BY MR. HORVICK:

24 g

Mr. Dam, based on our questions and answers up to NW Reconers, Inc.

25 this point, it is obvious that you know very little about the i

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various target' dates for co=mercial operation that GPU and l

2 Met Ed arrived at in 1978.

Could you just summarize your 3

role surrounding this whole issue?

l l

4 A

Again, the commercial operation dates were mentioned 3

at various times, at various meetings.

However, there was no 6

direct on Burns & Roe with those dates.

l l

The one side issue with regard to commercial operation date 7

i g

was the date that work started for the Metropolitan Edison 9

Company under our continui services agreement for updating 10 drawings under their cont t, versus updating them under the 11 GPU contract.

That was one of the principal -- one of the t

principal reasons to know the commercial operation date.

12 The work we were doing was task-type work resolvirg 13 14 reopen items.

A number of those continued af ter the commercial operation date, which were GPU's responsibility.

Some were 15 16 turned over and became Met Ed responsibility, and we worked 17 on those for Met Ed.

18 4

Is that all you have on that?

19 A

Unless there is something else you want me to say 20 specifically, i

21 0

That sounds fine.

Why don't we just put the lid on

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i 22 that issue.

1 Hans, why don' t you take over with some of these questions 23 (pCeconenune.

24 regarding the valve itself?

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BY MR. SCHIERLING:

2 4

Okay.

Mr. Dam, we talked about before, the April 23 3

failure of the main steam safety valve, relief valve.

And l

you indicated already that you were directed by GPU to prepare I 4

5 design changes in case that i.41ve would have to be replaced.

6 Is that correct?

7 A

Yes.

l I

t 8

4 When were f.~ edvisedorrequestedbyGPUtoinitiatef 9

that effort?

10 A

I don't recollect.

It would be in the timeframe 11 of.May, 1978.

But I don't remember what exact date.

12 4

Specifically, what did you do, look at other valve 13 designs, evaluated those with regard to their applicability, I

la or what was involved?

f 15 A

I think, as I said before, we first started out 16 looking at the Lonergan valve to see what should be done to i

17 make the Lonergan valve work.

In addition, a test valve was 18 taken-by Lonergan and modified by them to attempt to make the 19 valve recede with the specified limits.

20 As a back-up to Lonergan not performing, Burns & Roe did i

21 a number of studies looking at valves of size and types which 22 could be installed in place of the Lonergan valves.

i 23 A decision was reached scmetime in May, I believe, that GPU '

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24 wished to proceed with the detailed design of a replacement

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And that was done.

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.O It la my understanding that th;ro wns a manting on i

2 May 23rd at the TMI site on that particular issue between l

l 3

Burns & Roe, Lonergan and GPU.

Did you attend that meeting?

4 A

I attended numerous meetings.

I could have, very i

i I

i 5

easily, attended that one.

6 g

If you did not personally attend it, is it correct 7

to assume that you probably had someone else attend that a

meeting?

9 A

Yes.

I i

10 g

Okay.

Were you aware that there were other valves 11 intended to be used for the Forked River project at about j

12 the same size as the Lonergan valves, but made by a different i

13 manuf acturer, and that hey would be available in November of I

14 1978?

15 A

Yes, although that date was in question.

At various 16 tines, Crane Company would not give us a firm date.

In fact, 17 I don't believe their valves had even started f abrication in 18 May.

19 So, any date that Crane would have given, would have been 20 a questionable date.

21 MR. SCHIERLING:

Off the record.

1 22 (Discussion of f the record. )

23 BY MR. SCHIERLING:

24 g

Back on the record.

c.,w m. corm s,inc.

25 Mr. Dam, could you please address the whole issue of these 1

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cafoty relensa valvc2 with respcct to the cvailability of the i

2 Crane design that were not into manuf acturing yet for the 3

Forker River project, the Dresser valves, and the Lonergan I

4 valve?

Which one was finally opted to be installed at the 5

TMI-2 unit?

6 While we were off the record, we mentioned three valves; 7

is that correct?

Dresser, Lonergan, and Crane?

8 A

Okay.

9 G

Which is the one that was finally selected?

l 10 A

The Dresser valve was selected.

11 4

And that Dresser valve was obtained from where, 12 from another nuclear power plant or was it specially ordered I

I 13 for GPU before TMI-2?

i 14 A

The valves were in the Dresser shop.

They had been l

i 15 ordered by Commonwealth for one of their projects.

And I 16 don't remember which project.. But they had not yet been 17 shipped.

18 4

And these are the valves that were then ultimately 19 installed at TMI-2?

20 A

That's correct.

21 O

How much time did you have to complete that task?

22 A

It was not so much as how much time we had, it is 23 how much time it took to do it.

Nowhere do I remember being 24 given:

you have to have it done by a certain date.

It was Di R9Dorters, IOC.

25 how fast can you do it.

Look at various opulons so that the i

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endproduct can.be done in a reasonable -- as quickly as l

2 possible.

But I don't remember ever being given a date that i

3 it had to be done by.

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G What effort, was it considered a rush job, then, 5

for Burns & Roe?

6 A

It was considered --

7 G

To the extent that other work had -- other scheduled i 8

work had to be dropped in order to accomplish this task?

1 9

A It was considered our highest priority task.

And 10 as many of the staff that were needed worked on that in deference 11 to other work items which had lower priority, particularly the items that weren' t due until the first refueling outage, 12 13 which was the predcminat workload of our group at that time.

14 G

The original valves that were in the TMI-2 safety 15 relief valves, they were Lonergan valves?

16 A

That's correct.

7 4

They were designed according to Burns & Roe 18 specifications?

1 19 A

Burns & Roe provided what is called a performance 20 specification.

That is, we provide the set pressure, the 21 blowdown percentage, other characteristics that the valve 22 has to be made to.

However, we do not tell a valve manufacturer 23 how to do his valve design in our specifications.

24 g

Why was this design selected, rather than a more

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25 common design used in the nuclear industry?

Let me ask you:

Y 96 rag 11 1

Is, indeed, the Lonergan design one of the lesser used valves I

2 i

in the nuclear industry?

I i

6 3

A I can' t speak for the whole nuclear industry.

I 4

O To the best of your knowledge.

l l

5 A

It is not -- I don't believe at that time it was I

6 the prevalent design in the power industry.

However, there t

7 was good precedent, I believe, for that valve that was chosen.

i 8

MR. HENDRICKSON:

Let me give also a partial caswer j

9 to that.

This is from so long ago that I may not have it all 10 exactly right.

11 But the Dresser valve was an outgrowth of the relief valve

^

12 failure that had occurred.

13 THE WITNESS:

You mean the Lonergan valve?

i 14 MR. HENDRICKSON:

In one of these Virginia plants, f

15 THE WITNESS:

Which valve do you mean, the Lonergan 16 valve or the Dresser valve?

17 MR. HENDRICKSON:

The Lonergan valve.

The original 18 Three Mile Island design was an outgrowth of one of the 19 failures that had occurred a number a years ago at one of the i

20 nuclear plants, one of the relief valves.

It was a VEPCO i

I l

21 plant, that's right.

l 22 And the feature that Lonergan had provided in this valve l

i 23 was a double discharge, which balanced or tended to equalize 24 unbalanced loads that were prevalent with the other designs.

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as considered at the time a new and desirable I,

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facturo.

i 2

However, relief valves are very difficult.

And there are i

3 not very many suitable facilities fog testing valves.

4 Unfortunately, this was-the first chance for a full test of fy' t

5 this design.

And it did not perform well.

l 6

We therefore had t; alter the Three Mile Island plant and j

i 7

install valves similar to earlier designs that did have, i

8 as I recall, unbalanced loads.

Am I correct, Scott?

9 THE WITNESS:

That's correct.

10 MR. HENDRICKSON:

And design the supports and piping 11 to accommodate the unbalanced loads.

t 12 THE WITNESS:

The Lonergan valve was a much simpler V-13 valve for installation and had much reduced loads on the i

14 piping system.

And therefore was a high_1y_ desirable valve.

15 There were 12 Lonergan valves that had to be replaced by 16 20 Dresser valves.

17 So, the valves -- the Lonergan valves, while they were 18 larger, had much less forces on to the valve stem and their 19 attachment to the piping.

20 MR. HENDRICK3ON:

If the valve had performed properly, i

i 21 it would have been a very desirable valve.

}

22 THE WITNESS:

In fact, the Forked River valves you t

i i

i 23 mentioned before designed by Crane, were essentially the same l

1 24 jMR as the Lonergan valves.

That is, they were double discharge i

A eno,ters. Inc.

25 T size orifice valves.

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Right.

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MR. HENDRICKSON:

Right.

2 BY MR. SCHIERLINGJ 3

0 You mentioneo that the 12 Lonergan valves, the 4

original Lonergan valves at TMI-2 were replaced by 20 5

dresser valves.

1 6

MR. MURPHYJ

.He mentioned it.

7 BY MR. SCHIERLING2 8

0 You men tioned tha t, Mr. Dam.

In that selection of v

the Longergan valves, the f act that they were quite a f ew 10 le ss, cid cost play any role in the selection of these

.11 valves, to tne oest of your recollection?

12 A

Yes, the Lonergan valves were less expensive than 13 either Crane or Dresser at that time.

And a technical 14 evaluation as well as a cost evaluation was done on the 15 bids.

And as I remember from looking at the history -- I 16 was not on tnr project at the time -- a thorough evaluation 17 was done, prior to placing the order with Lonergan.

18 0

There's one final question that probably will IV require you to go back into your memory, your recollection.

1 20 Please try to do so, if you can.

21 You participated in various meetings, I'm sure, on the i

i 22 schedule, although commercial operation is. not of interest t'

23 to you, to Burns & Roe.

But meeti gs where, indeed, 24 schedule was discussed.

And based on your prior testimony,

}

25 the information tha t you have given us. you probably did not i

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j6 08 02 100 kap /PL 1

have any -- you appeared to have not had any input into 2

these oiscussionst however, do you recall that ever issues 3

were discusseo relating to what aspects of the TMI-2 plant t

4 could be safely deleted or postponed in order to get the 5

TMI-2 uni t on-line by the end of 19787 6

A No.

7 0

You do not recall that any tasks that still were 8

not completed at that time could be postponed to beyond v

commercial operation?

10 A

I don't believe that's what you asked the first

.11 time.

12 0

That's what I mearit to ask the f.irst time.

13 A

Now, I'm conf used about your question.

14 0

I'm asking if there were any TMI-2 related tasks, 15 safety-related, that were deleted to beyond the commercial 16 operation cate of December 19797 17 A

I don't remember any commercial operation date, 18 s af e ty-rela te d.

IV O

'78, I'm sorry.

I 20 A

'78.

Any saf ety-related items that were not 21 completed before commercial operation where there was a t

22 reason or need to have them completed.

There were, as you i

23 know, licensing commitments made in the operating license 24 for saf ety-related items, which would be done at the first l

25 ref ueling outage, which was per the agraement of i

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Metropolitan Edison and the NRC.

Those were the only items 2

that I know of that were scheduled out af ter commercial 3

o pera tion.

4 MR. SCHIERLING:

Did you want to add some thing to 5

that?

6 MR. MURPHY:

I think you meant to say def erred, 7

rather than deleted.

8 MR. SCHIERLINGs Deferred.

Y MR. MURPHY:

Deferred beyond the commercial 10 o pera tion.

.11 THE WITNESS:

I know of no items that were 12 deleteo.-

13 MR. SCHIERLING:

Def erred or postponed, that was 14 my intent.

l 15 MR. MURPHY:

Right.

l 16 BY MR. SCHIERLING2 17 0

Is there anything else that you would like to add 16 on this line of questioning regarding the need -- the rush IV to go into commercial operation by the end of 1978?

20 A

From Burns & Roe's standpoint, I can't remember 21 any particular rush as it affected Burns & Roe.

There were 22 numerous discussions I'm aware of within the GPU system on 23 work breakdown between Me t Ed and GPU, and wno was going to 24 do what anc ce re sponsible to what, relative to commercial 25 opera tion.

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But as it aff ected Burns & Roe, I don't really know of 2

anything that would show a rush.

3 MR. HENDRICKSON Sco tt, there was a 4

contract-relatec issue before commercial operation date.

I t

5 believe our work f ell under the original new construction i

6 contract.

And there was a continuing services contract

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l 7

between Burns & Roe and Metropolitan Edison and obviously at 6

some po in t, tasgs that still naeded to be done, whether it's the parking lot or the glass or whatever it is, might be v

10 carriec on on the continuing services contract, rather than

.11 new construction contract.

12 THE WITNESS:

In fact, I did mention the 13 c rawings.

The responsibilities were pre tty well-defined in 1

14 Novemoer and December, which items were going to be GPU 15 response and which items were going to be Met Ed response.

16 And in fact, we had alreacy started working with Met Ed on 17 some tasks, when Met Ed wanted to make some plann ed 16 improvements on the neutralizing system, f or example, and 19 f or make-up water in the secondary plant, things of this 20 nature, which Met Ed said it was their responsibility, 21 because they were not part of the original designer and I

22 construction.

23 GPU aio carry over past the first of the year, various 24 items which were of a peripheral nature.

25 MR. HENDRICKSON:

I believe, isn't it true, that I

t 2

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g60805 103 kep/PL 1

both contracts are still open today and work is still being 2

done by Burns & Roe under both contracts, both the initial 3

construction and the continuing seryicas contract?

r 4

THE WITNESS:

That's right.

5 MR. SCHIERLINO:

I think that completes this line 6

of questioning.

Do you have anything else to add Barry?

7 MR. HORVICK:

No.

I think we've covered all the 8

i ssues and that's it.

Thank you very much.

9 MR. MURPHY:

I have a request before we go of f the 10 record, and that is that the page s of Mr. Cobean,

.11 Mr. Cobean's interview, be identified from the beginning of 12 his testimony until it enoed.

Those pages within 13 Mr. Cobean's interview tha t reflec t Mr. Dam's f ew answers 14 and questions -- answers to questions be identified, and 15 then pages of Mr. Dam's interview be identified f rom 16 beginning to end af ter Mr. Cobean finished.

And those few 17 pages wnere Mr. Hendrickson answered.

Otherwise, we're 16 going to go crazy trying to get this thing pro perly 19 reviewec, since it's not going to be broken down.

It's all 20 going to be in one package.

21 MR. SCHIERLINO:

Back on the record.

22 W here u pon,

23 WARREN R. COBEAN 24 was recalleo as a witness and, having first been duly sworn, i

25 was examined and testified further as fo11ows2 l

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BY MR. SCHIERLINGJ

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2 0

At the suggestion of Mr. Murphy f rom Burns & Roe, 3

we woula like to ask you, Mr. Cobean, two questions on some

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i 4

prior testimony you had given.

We are referring to the 5

testimony that you gave f or the President's Commission.

And o

we are referring to a statement on page 154 where you 7

testified, and I quote:

"The client was always concerned 8

aoout meeting a commercial operation date.

Tha t wa s hi s 9

principal goal in lif e, to make that commercial opera tion 10 date in some way."

.11 Now, this is a statement, indsed, out of context.

But 12 you --

13 A

Also, i t doe sn' t reflect the change that I made to 14 this thing.

Did you realize that?

15 0

No.

I didn't realize that.

l 16 MR. MORPHY:

Is there an errata?

17 THE WITNESS:

You bet there is.

This doesn't read le English.

The client was concerned about ge tting through.

19 There are certain tnings you have to do in designing and 20 building and testing a power plant that let you get 21 t nrough.

He was never trying to skip any of the steps of 22 getting through.

But he wanted to get through.

23 Why dic he want to.get through?

He wanted to get t hroug h 24 for a lot of reasons, principally, because they needed the m.

25 power, and second of all, that by being through they could

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go --- they could declare that the plant was in commercial 2

o pe ra tion s.

That means having completely designed the 3

plant, having completely constructed the plant and having 4

completely tested the plant.

Then, they could declare g

5 commercial operations.

6 Now, f rom an economic point of view, that had two 7

benefits to him.

One is that he started generating electric 8

power f or the thing, and two, he could get, hopef ully, the 9

. cost of tha t plant in the r. ate base for his area and stop 10 incurring additional -- and start paying off the debts that 11 he had -incurred in designing and constructing and testing 12 the plant.

13 So, that's wha t I mean t by --

14 SY MR. SCHIERLINGJ 15 0

Could you explain to me what you mean by saying 16 "getting through"?

17 A

Well, I put it that way because I thought it was la the simplest way of saying it.

19 0

Ge tting through what?

20 A

Getting through the job of designing, 21 constructing, ana testing the pl an t.

There is, as you know.

22 a design to complete of a plant.

That plan t has to be 23 construc.ted to that design.

That plant then gets tested on 24 a piecemeal basis, continuing to add parts until at the end, 25 you have the whole plant being tested simultaneously as an i

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integra ted plant.

2 Now, upon completion of all the pre-planned and 3

pre-oraained tests, mee ting all the criteria for t.t' *ast 4

data, test data recorded during 1 hose tasts, then the pl ant 5

has succe ssfully been tes.ted.

After having been 6

successf ully designed and completed -- constructed --

7 that's what I mean by finishing, ge tting through.

5 O

Mr. Cobean, the second statement on page 157, 9

attricutec to you, have you looked over that particular 10 statement?

.11 A

Yes.

12 Q

Let me repeat it here.

"I t was importan t to GPU 13 for accounting reasons, if for no other reason, to try to 14 get the plant on-line commercially before the end of 1978."

15 I think in your previous statement you gave us your 16 interpretation of t ha t, of this statement here, what it 17 means to get to on-line commercially.

IS Did Mr. Scott Dam provide you wi th any in put to make that 19 s ta tement ?

20 A

If he cid, he did i t in a 'very o.ffhand way.

I 21 don't remember anything.

As I said in the following 22 question and answer, I have been and am still in almost 23 constant contact with a number of pecole within GPU.

And I 24 am certain tnat that's the princi pal source of inf ormation.

25 However, Dam could have contributed to it.

I don't i

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recall.

a,'

2 O

Mr. Cobean, you mentioned earlier that the first 3

statement had been correc ted by you;. is that correct?

4 A

I*m almost positive it has, because the last 5

sentence does not read good English.

And one of the things 6

that I tried to do when I was correcting my testimony, as 7

you see, was to try.to pick up that kind of --

8 MR. MURPHY:

Le t's take a look. and sse if we have Y

the errata in the back.

10 THE WITNESS:

No, we don't nave the errata.

We've hCk'.{

11 got part of the errata.

I 12 MR. HORVICK:

My copy does have it.

0V

\\,, p,r' 13 THE WITNESS:

It is not corrected.

I missed that 14 one, sorry.

It coesn't read good English, though.

5 '. cggi 15 MR. SCHIERLING:

I think that we'll, first of all, 16 straighten out the record with regard.to the errata shee t.

17 And secondly, it amplifie s the sta tement that Mr. Cobean 16 made in the earlier testimony, 19 dould you, Mr. Murphy -- do you have any additional I

20 comments on this particular issue now?

I do not see any 21 need to nave Mr. Dam address the same questions again.

I 22 think as f ar as we are concerned, the inf ormation provided l

23 by Mr. Cobean suf fices, 24 MR. MURPHY:

I'm very sati.sfied that the issue has j

l 25 been fully covered.

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MR. SCRIERLINO:

Okay, with that statement, I 2

think we have obtained tne information tha.t we wanted to 3

obtain today.

4 Again, Mr. Cobean, I want to thank you for your 5

participation and all the information.

That's it.

6 Mr. Cobean, one final comment I would like to make is, in 7

case there should be any need to obtain further information, 8

either from you or someone else in the Burns & Roe y

organization, we will let you know about it and arrange for 10 any adcitional inter. views or de positions, if they shculd be

.11 required.

' 12 Tna t's i t.

13 (Whereupon, a t 3 : 30 p.m., the interviews were concluded.)

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