ML20024C442
| ML20024C442 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/02/1982 |
| From: | Keaten R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-03, TASK-06, TASK-3, TASK-6, TASK-GB B&W-4035, NUDOCS 8307120630 | |
| Download: ML20024C442 (7) | |
Text
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92 pk UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
.x GENERAL PUBLIC UTILITIZS CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, g
METROPOLITAN EDISON COMPANY and PENNSYLVANIA (LECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
a Defendants.
.....................x Continued deposition of General Public Utilities Corporation by ROBERT W.
KEATEN, taken
=
by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Tuesday, January 5, 1982 at 9:45 o'c'.oc in the forenoon, before Joseph R.
Danyo, a Shortnand Reporter and Notary Public within and for the State of New York.
8307120630 820105 PDR ADOCK 05000289 T
HOL DOYLE REPORTING. INC CERTIFIED sTENCTYPE REPCRTER:
399 LaxtMeTom AvsMus WALTER SHAPIRC. C.S.R.
New Yomst. N.Y.
loo 17 CHARLES SHAPIRC. C.S.R.
Tsi.uMome 212 - se7 422o
ll
~
1 Keaten 171 2
Items."
Do I take it that TTF referred to your task force?
3 4
A I believe tiaat is correct.
5 Q
Would you look at the first item that you 6
have got noted there.
"1.
Transient Review.
A, We l
l 7
are having problems with feedwater control prior to 8
trip - high pressurizer level, popped pressurizar I
g relief, et cetera - level dropped significantly - wh. ore 10 did the water go.
Apparently out of normal SS 11 operation - see temperature Av."
12 I have attempted to fill out what I believe 13 to be abbreviations on your part.
You are not bound 14 by my reading.
If I have mischaracterized anything 15 that you wrote there, please let me know.
16 A
I believe I agree with your characterization 17 of the abbreviations.
18 Q
Your comment indicates that you,had learned 19 that the plant was having problems prior to the April i
20 23 incident, as you note here.
Isn't that correct?
21 MR. GLASSMAN:
Are you asking whether the 22 comment indicates that or whether he now 23 recollects that?
24 MR. WISE:
Whether he now recollects it.
25 A
I recollect that there were some problems 1
I 1
Keaten 172 i
l 2
in feedwater control prior to the trip.
3 Q
were th se problems in fact resulting in 4
high pressure level and relief through the 5
pressurizer relief valve?
3 6
A I frankly don't remember that.
i n
7 Q
Do you recall with whom you had l
8 conversations concerning this topic?
9 MR. G LASSMAN :
Objection.
Lack of 4
10 l
foundation.
He didn't say he had any 11 conversation.
12 Q
.You didn't make this up out of thin air, 13 did you?
14 MR. GLASSMAN:
He didn't say he recalled.
15 A
To answer your question, I do not believe 16 I made it up out of thin air, i
17 Q
I only asked that because your counsel was l
18 uncertain as to whether or not we needed a foundation 19 or I should say your counsel believed we needed a 20 foundation for whether or not you learned this from 21 someone else.
l 22 MR. GLASSMAN:
It still hasn't been 23 established whether Mr. Keaten recollected any I
24 conversations related to this.
25 MR. WISE:
That is what I asked.
I presume i
e l
l.
- - -.~---
s, 1
Keaten 173 s
2 he had conversation with someone.
Who he learned l
3 this information from.
4 A
I do not remember who I learned it from.
a 8
5 Q
Would you look briefly at the following 6
page, 3820, and see item 1 listed as gas bubble.
About l
I 7
midway down the page, there is item 1,
gas bubble, 1
4 8
and immediately below that, it says " Pressurizer relief 9
had blown about 50 times in last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to 10 sluggish" and I an afraid I can't read the next word.
11 A
I believe the next word is " heater."
12 Q
" heater control - operators had t
13 improved things somewhat (blowing once per hour)."
i 14 Do you recall to what that comment had li reference?
15 IG
~I A
I believe that it referred to problems that 17 the operators were having with the controller for the 18 pressurizer heaters.
19 Q
Had that resulted in challenges to the 1
20 l
pressurizer relief valve about 50 times in the previous 21 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
22 MR. GLASSMAN:
You are asking for Mr.
9 I
23 Keaten's recollection?
24 MR. WISE:
Yes, all of my questions are 25 directed to Mr. Keaten's recollection.
L
~
l I
Keaten 174 l
2 A
I do not recall any specific numbers such 3
as the ones that you used, but I also should comment 4
that the concept of this type of an operation being a
(
5 challenge to the pressurizer relief valve is 3
l
'6 something that postdates this event, and my recollection [
l 7
is that the attitude at this time was that this was a 8
normal function of the pressurizer relief valve or j
9 PORV.
s 10 Q
Just so it is clear, the numbers that I used 11 in my question had come from your notebook.
12 A.
Yes, that appears to be correct.
13 Q
Did the task force give any consideration 14 to this particular item and the consequences it might have for the reliability of the pressurizer relief 15
{
l valve?
16 i
17 A
The only thing which I recollect associated 18 with this item was a general opinion on the part of i
19 the task force that the heeter controls should be made 20 to function correctly.
21 Q
Did anyone consider the possibility that i
22 repeated lifting of the pressuriser relief valve as 1
23 4
many times as indicated in your notebook may have had 24 i
an adverse effect on the reliability of that valve?
25 A
I don't recall one way or another.
l' I
- ~ ~ - -
' ' ~ ' ' " ' - ' ' ' ' ' ' ' '
' ^ ~ " ~ " ~ ' ' ~ ~ ' ' ' ~ " -
t e
1 Keaten 175 d[
2 Q
Did anyone look into the number of openings and closings and the conditions under which that 3
a I
valve 4
was designed to operate?
(
5 MR. GLASSMAN You are talking about during 3
6 the course of this task force work?
7 MR. WISE:
Yes.
8 A
Again, I don't specifically recall one way 9
or another.
As part of the activities that were going 10 on in evaluating the transient and the consequences 11 of the transient, there were discussions between GPU/
12 Met Ed personnel and B&W personnel about some a spects 13 of this transient.
Whether the question of the PORV 14 was raised, I don't know.
15 Q
Let me go back to page 3819, the preceding i
16 page.
We've discussed item A under your action it ems 1-(
for May 4, 1978.
Before we leave that, let me ask i
'I 18 1
one or two other questions.
I i
19 j The notation at the end of that first If 1
20 i
comment reads, "Apparently out of normal SS operations -
21 see T av."
What was meant by that comment?
22 A
I frankly don't remember what it meant.
SS f
is not'an abbreviation as.far as 23 I can recall that I
24 l normally use.
25 Q
Rave you used SS to stand for steady state?
1
,I w
a-.
's, i
e e
1 Keaten 176 i
i l
2 A
That is possible.
3 Q
You are not able to recall now whether 4
that is what you meant here or not?
3 5
A I ***llY d' not-6 Q
Do you recall any significance of T-av i
7 with respect to this comment?
1 I
3 Perhaps I can clarify my question.
You j
g have noted "See T-av" following your comment.
Would 10 looking at the T-av tell you something about the items i
11 that you have mentioned in this comment, namely, high 12 pressurizer level, popping of pressure relief valve, 13 a significant drop in the level, and out of normal 14 operations?
15 MR. GLASSMAN:
You are asking for Mr.
16 Keaten's interpretation of this particular item i
17 now rather than his recollection of whether it 18 meant anything to him?
19 MR. WISE:
No, I as trying to refresh his 20 recollection and test his recollection about this 21 item.
I am" not asking him to interpret it today,
(
22 except insofar as he is interpreting it, he is l
l 23 l
recalling what he meant then.
l l
24 i
A I don't recall what I meant then.
25 Q
Let me now move on to the next item in your I
4
..-