ML20024C674
| ML20024C674 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/30/1982 |
| From: | Tracy Scott BABCOCK & WILCOX CO. |
| To: | |
| Shared Package | |
| ML20024C673 | List: |
| References | |
| TASK-06, TASK-6, TASK-GB GPU-2181, NUDOCS 8307120947 | |
| Download: ML20024C674 (17) | |
Text
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(( 01:FER OV UNITED STATES DISTRICT COURT MOOF)
SOUTHERN DISTRICT OF NEW YORK GENERAL PUBLIC UTILITIES CORPORATION, a
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, s
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-8 THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
a Defendants.
.....................x Deposition of THE BABCOCK & WILCOX COMPANY, by THOMAS F.
SCOTT, JR.,
taken by Plaintiffs, pursuant to Notice, at the offices of Kaye, Scholar, Fierman, Eays & Bandler, I
Esqs., 425 Park Avenue, New York, New York, i
on Friday, April 30, 1982, at 9:45 o' clock in.
the forenoon, before Robert E.
Levy, s.
Certified Shorthand Reporter and Notary Public
~
wi' thin and for the State of New York.
b307120947 771017 PDR ADOCK 05000289 V
hot.
l DCYLE REPORTING. INC.
CERTIFIED sTENOTYPE REPORTERS 369 LazlNeToM AvtMWE WAI.TER SHA!'IRC. c.S.R.
Msw Yama. N.Y.
10017 E
SH.ARW SHOPTF, N TELarwows 2f 2 - as7 a22o
i
?
85 Scott 1
[w j
2 pressuriser?
i I can remember no such training at asw.
A 3
L_
4 Q
During our lunch break, I take it you did x
go over portions of GPU 513 with counsel?
('
5 MR. BENEDICT:
You can answer that.
6 7
A Yes, sir.-
The Bellefonte plant is a plant containing
[7 8
Q a B&W nuclear steam supply system, right?
g 10 A
Yes, sir.
The Bellefonte plant was designed as a 11 Q
12 pressurized water reactor, right?
13 A
Yes, sir.
14 Q
.Has Bellefonte ever gone into operation?
15 A
No, sir.
16 Q
As a PWR, what approximately are its t
17 normal operating temperature and pressure for the 18 reactor coolant system?
l ID MR. BENEDICT:
Are you &sking him what ha 20
. recalls about those parameters for this plant?
MR. SELTZER:
Yes.
21 I don't recall the specific values.
22 A
t That is why I said just approximately.
23 Q
24 A
Approximately 600 degrees average RC a
fM and approximately 2200 pounds per square I
25 temperature, 1
a r
i l
86 scott 1
2 inch pressure.
3 g
At 600 degrees Fahrenheit?
4 A
Yes, sir.
('
5 g
The temperature in the pressurizer would be designed to be higher under normal pperating, conditions s
7 than the reactor coolant system, average tempirature, 8
right?
g Yes, sir.
10 Q
The pressuriser has water in it that is at the reactor coolant system, right?
1 j
11 the same pressure as
?
12 A
Disregarding pressure line losses.
There j
'e 13 are pressure jobs associated with each of the lines.
14 Q
Except for that relatively small amount of 15 pressure loss, the pressure in the pressurizer is the same as the pressure in the rest of the reactor coolant 16 t
17 system, right?
18 A
No, sir, the pressure in the reactor coolant s
i 19 system varies from loc. tion to location.
r 20 g
By approximately how much did you understand the pressure in the pressurizer would differ from the J
21 6
k.
l 22 pressure in the hot legs?
4 I
23 MR. BENEDICT:
Do we have a time frame for I
24 nis understanding?
Do you want his knowledge 1
25 today?
1f 1 - - -
j, y
~
87 Scott g
MR.' SELTZER:
Yes.
2 A
on the order of perhaps 20 pounds or so.
3 4
Q The water in the pressurizer is maintained at the point of saturation, right?
(
5 A
During normal operation, yes.
6 l
7 Q
So pressurizer temperature is generally 8
above reactor coolant system temperature by the amount equal to the subcooling margin of the reactor coolant g
10 system, right?
MR. BENEDICT:
Could I hear that back?
11 (Record read.)
l 12 A
Given that there are different pressures 13 and different temperatures for different parts of the 14 15 reactor coolant system, there is not one value that 16 you could say this is the subcool margin reactor coolant 17 system pressurizer.
There are probably -- not probably, there are a family of numbers.
18 l
19 Q
The pressurizer water is going to be hotter than the water in the reactor coolant system, right?
20 g
A Yes.
A 21 22 Q
You said that the average temperature in the reactor coolant system outside the pressurizer is about 23 24 600 degrees Fahrenheit.
About how much hotter did you 25 undestand the temperature in the pressurizer of
- l-
.s.
scott 88 I
'2 Bellefonte plant would be?
A I do not recall the exact number.
You are 3
4 asking approximately?
(
5 Q;
Yes.
6 A
Approximately 50 degrees.
7 Q
so that your understanding is that 8
Bellefonte plant would be designed to have pressurizar temperature under normal conditions in a range around g
10 650 degrees Fahrenheit, is that right?
11 A
Yes, sir.
n Q'
In 1978, you prepared GPU 513, right?
i t
13 A
The preparation was complete in 1978, yes, 14 sir.
15 Q
And you were the one who worked on its J
i 16 preparation, right?
I 17 A
Yes, sir.
18 Q
You knew that there were relief valves at 19 the top of the press'urizer, right?
20 A
Yes.
a 21 MR. BENEDICT:
Pressure at Bellefonte I take
(
22 it we are talking about?
23 MR. SELTZER:
I don't think it makes a 8
(
whole lot of difference but we are talking about 24 l
25 the Bellefonte reactor.
I
i,*
's 89 Scott g
Q It had both a pilot operated relief valve 2
and two code safety valves on th'a top of the
{M, 3
ap,
,r.ssur1..r. right?
A I believe that is correct.
(
5 Q
Those were all three relief valves, right?
6
...'I A
Yes.
7 Q
At the top of the pressurizer under normal 8
peratirig c nditions, there is a* steam space, right?
9 A
Yes.
10 Q
The steam is at the same temperature as the
[
gg water in the pressurizer, right?
12 A
Under steady state conditions.
13 l
Q The answer is yes, under steady state g4 conditions?
15 A
Yes, under steady state conditions, j
16 t
Q In other words, both the steam and the g7 water would be at saturation temperature for the 18 Pressure existing inside the pressurize =,
right?
19 l
A Y
- i**
20 Q
Was it y ur understanding in or about the timo 21
(,
that you were preparing GPU 513 that if a relief valve 22 pened on the top of the pressurizer, the, steam that was l
23 l
inside the Pressurizer would exit into the discharge 24 line on the other side of the relief valve?
25
4
/
's 1
Scott 90 1
)
2 A
Yes, I understood that.
]
3 Q
You knew that there were thermocouples in 4
those discharge lines?
A I knew there were temperature indications.
['
5
~
6 I don't know if there were thermocouples or RTDs or 7
what the devices were.
~
8 Q
You knew that there was someting for measuring the temperature in the discharge lines?
9 10 A
At the Bellefonte plant, yes, sir.
11 Q
Was it your understanding at the time 12 you were preparing GPU 513 that if the pilot-operated relief valve operating on the Bellefonte plant opened, 13 that the temperature detector in the pilot operated 14 15 relief valve discharge line would see steam that was 16 over 600 degrees Fahrenheit? By "sse" I mean 17 experience.
18 A
I don't recall whether I would have l
19 expected that or not.
Mk I
Q What, if anything, was your understanding 20 of what the temperature of the steam would be in the 21 k
discharge line if the pilot operated relief valve 22
- h" s
23 opened?
WWS; I cannot recall thinking about that, making q&{ (g pg 24 A
25 that determination.
W b
.. s.
I
.93 Scott 1
Q Take a look at page 6 of GPU 513.
2 MR. BENEDICT:
off.the record.
3 (Discussion off the record.)
4 Q
..g..,,o.... p.g..?
cg A
I am on page 6 6
This is ons of the pages that you prepared Q
7 as part of GPU 5137 8
A It appears to be.
g 10 Q
Do you see the third item down from the line left is pressurizer relief valve discharge 11 temperature?
12 fA M A
Yes, sir.
13
~
Q What does RC-12 refer to?
14 That.is the Babcock a Wilcox company's A
15 instruments string designation.
i 16 I
7 g
What instrument is being designated by l
18 that?
The nomenclature for this is to the left.
A 19 So that is the pressurizer relief valve
.Q 20 disaharge line?
i 21 A
Temperature indication.
22 What does T335-T337 refer to?
23 Q
on page 4, note 2 states, " computer ID point A
24 numbers are listed under the service where applicable."
25
Il '
1 9
92 scott 1
from that it would indicate that T335 ES 2
through T337 are three computer points associated with 3
this instrument string.
4 Is there an indication of a temperature 5
9
('
[(p at which a computer alarm would enunciate fo'r..high 6
temperature in the pressuriser relief valve discharge 7
8 line?
A Yes, sir.
9 what is the temperature at which the 10 Q
s computer alarm would sound or enunciate?
11
)(h%>4 12 A
600 degrees Fahrenheit.
Did that mean that when the pressurizer k Lu
%#g 13 Q
relief valve discharge line experienced a temperature 14 of 600 degrees Fahrenheit or greater, an indication 15 would sound or light up or be given from a computer 16 alarm in the control room?
17 The exact method of that alarm I do 18 A
Yes.
19 not know. _
(
the alarm signal would go to the control 20 Q
But room only when the discharge line temperature was at 21 is that right?
or greater than 600 degrees Fahrenheit; 22 I am not sure that is correct because I 23 A
tell from this document where all that string 24 can't would go, where all it might be indicated or enunciated.
25
---.-,-r.r
-.,-<-------,-..,,,.-e,e--
--,m--
y.
-m-v-..,---,,.,-,,-..3-
,--c.-w-
-, +. - - -, - - - - - -
4 Scott 9.3 1
so you don't know where the alarm would g
2 enunciate?
3 It could be A
There may be other indicators.
4
(
mounted in a panel.
It could be any number of places 5
6
- that I would not be able from this document to dete'rmine.
But wherever it is placed, it will only g
7 indicate when the tamperature reaches or exceeds 600 3
degrees Fahrenheit, right?
g A
No, sir.
That is what I an disagreeing 10 with because this document does not say that nor imply gg that.
12 This document states that something will 9
13
~
happen at 600 degrees, right?
14 A
Yes.
15 What was your undersatading of why there.
9 16 would be an indication at 600 degrees?
gy I am not sure I understand MR. BENEDICT:
18 the question but if you do, you can answer it.
19 What was my understanding at the time I l
A f
20 i
prepared this document?
21
(
g Right.
22 Why that number was there?
I A
23 What is your understanding of why there 9
24 would be a computer high temperature alarm reading 25
}
l.
,/
i 94 Scott t
temperatures in the pressurizer relief valve discharge 2
line?
3 MR. BENEDICT:
You mean,,what was the 4
(
ptfrpose of this calculation or this figuring?
5 MR. SELT2ER:
Not calculation.
Just putting in a figure --
7 I
^
g Q
Let's put aside the figure.
What was your understanding when you were preparing this as to why g
1 there would be any temperature figure that would trigger 10 a computer alarm for high temperature in the pressurizer 11 12 relief valve discharge line?
MR. BENEDICT:
Objection to the form of the 13 s 4.M g4 question.
I honestly don't understand it, but if
( [S l
QJ the witness understands it --
I k, gg 16 A
Il I understand your question, and I l
believe I do, the purpose of that indication would be 17 18 to detect leakage by one of the reliefs or that the o,1ve had opened.
va a t og V
20 Q
And what valve are you referring to?
A There are three valves.
Either the code 21 safeties or the power operated relief valve.
22 23 Q
By power operated relief valv'e, do you mean l
24 the same thing as pilot operated relief valve?
A Yes, sir.
I l
Eh /\\
y p,-
1
s.'.
.s Scott 95 g
l \\
h j v
-~.,
The number that you have inserted here for 2
the computer high temperature alarm is 600 degrees 3
Fahrenheit.
Is that because it was your understanding 4
("
in 1978 that a leaking or' stuck open relief valve at the top of the pressurizer would' heat up the. discharge 6
~ :..
line to 600 degrees or higher?
A I don t agree with that statement because 8
r I do not now know why any of these numbers got in 9
10
]g Q
Where did you get those numbers when you prepared GPU 5'137 7
l 12 A
In general we referred to engineering l
33 1
documents.
g k
Q Bsw documents?
g A
or documents from vendors or calcul.ation 16 4
data sheets.
A number of sources.
j g7 e
You said it was the intention in having a j
18 P
high level alarm that*it would show when a code safety 19 h
or pilot operated relief valve was opened, right?
8 tt h
[9 I don't know of any other une that would be 21 b,g~'t made of such an indication.
22 s
Q Doesn't it follow from that that if 600 I
g i
degrees is the point at which the high level alarm 24 k
would enunciate, that it must have been your g
/
3
\\
96 Scott 18 g
/ b understanding that 600 degrees w2s the temperature that 2
would be experienced in the discharge line if there were an opened PORY or code safety?
4 A
That is not,necessarily true.
f 5
Bow could 600 degrees get into the discharge g
6 line other than through an open code safety or PORV7 l
7 A
Your questions appear to assume that I 8
generated these numbers.
I generated none of the 9
numbers.
10 Q
No, my question only assumed that you 11 understood some of what you had put into 513.
You have 12 already said that you understood that the purpose of a 13 high temperatu-s alarm was to show when there was g4 discharge into the line from a code safety valve or PORV.
15 I am now showing you that 600 degrees was the 16 that temperature that was inserted into the document 17 I
you prepared and I an asking you wass't it your 18 understanding when you prepared this document that 600 gg i
degrees as the high level alarm set point must mean that I
20 e
in the discharge that,is tihe temperature that would exist 21
(.
li"* if * **11*f **1'* **** *P**?
22 MR. BENEDICT:
The question is what do you 23 recall of your understanding at the time you 24 parepared the material as to this.
25
To n.'
Scott 97
~
I j ' A A
I do not recall reviewing that number for 2
h i
its accurateness or applicabil ty.
l
$N^
Q Whom would you go to if you-wanted to find 4
t day what the basis was for petting 600 degrees in out b
5 as the high temperature alarm set point?
6 I would go to the test planning task engineer A
7 for the Bellefonte contract.
8 Q
Who was that?
g A
I do not know who that is today.
10 Q
Test planning?
11 A
Yes, sir.
12 4 s-Do you know today that if a relief valve Q
/
13 at the top of the pressurizer were open, that the l
g4 temperature in the discharge line would be a lot. lass 15 than 600 degrees?
16 A
No, sir, I do not.
37 18 Q
Would your expectation today be that the i
temperature in the discharge line would be something gg close to the temperature that existed inside the 20 pressurizer?
21
('
I'm sorry, could I hear that MR. BENEDICT:
22 8981"?
23 that the Q
Would your expectation today be y
temperature in the discharge line would be approximately 25 i
____.,---,-,,,~,._e,,_..
,n--,--,,yn,ag,,,, -
,,,.7...,,e,
, - -,7,,,--,,-n,v_n,,--nn
i
's Scott 98 g
the same as the temperature in the pressurizer if there 2
were n open relt.f valve; 3
MR. BENEDICT:
Are we talking about any 4
(' '
given discharge line?
What configuration --
5 MR. SELTZER:
The discharge line 6
immediately downstream from the relief valve.
7 MR. BENEDICT:
On Bellefonte?
8 MR. SELTZER:
Yes.
g MR. BENEDICT:
To the extent you know 10 about the details of that configuration.
11 A
I don't know.
12 what facts would you need to know?
Q 13 A
Well, I suppose I would need to know --
14 MR. BENEDICT:
Objection to this' question.
15 You can answer it.
16 I think this is improper but go ahead.
17 I hope to finish soon.
Go ahead.
18 A
If I kriew the physical arrangement, pipe 19 2 would have to know the normal temperature diaseters, f
20 in the pressurizer also.
I am not sure I personally 1
21 k.
could figure that out, but I might be able to.
22 why would pipe diameter affect the result?
1 Q
23 MR. BENEDICT:
Mr. Seltzer, I think you 24 have gone as far as you can go on this point.
25
Soctt 33 1
Mr. Scott is not here to testify.on the issue 2
of thermodynamics and I hope that we are going 3
to wind this up shortly.
4
(
MR. SELTEER:
We absolutely.are.
I promise.
5 MR. BENEDICT:
You know, to the extent that 1
6 you can explain why.you think it would be useful 7
for you to know the diameter of the discharge 8
line or any other orifices, diameters or other g
size, and you can explain it to Mr. seltzer, go j<
10 ahead.
Please be brief.
11 12 A
It might be pertinent concerning the expansion of the steam.
13
.Q Before you issued GPU 513, did you reivew )
g4 it?
15 A
Yes, sir.
16
~~7 17 g
When you got numbers from other sources and other people, did you review them to see if you 18 19 thought they were accurate to the best of your knowledge and information?
20 21 '
A It is very difficult for ce to say exact 1r what I checked numbers for.
22 23 g
You wouldn't have put a number in here tha t you knew was wrong, would you?
24 A
No, sir.
25 b
~%.
Scott 100 1
1 2
Q So it is safe to say that when you put 600 h}
degrees in bare as the temperature alarm for the 3
discharge line, you didn't know that that was the wrong 4
[
"""D**?
5 A
I don't know whether I did that or not.,.
6 I know'that I would not knowingly put falso information 7
in a document I prepared.
8 MR. SELTZER:
I don't have any further 9
10 questions.
MR. BENEDICT:
I don't have any 11 l
12 questions on this subject.
But quite frankly, I I
didn't know this subject was going to happen until I
13 it started to happen.
So in the very unlikely g4 event I have a few questions on cross-examination 15 t
i somewhere down the road, you and I can arrange e
16 that.
I think that is unlikely.
17 MR. SELTZER:
Okay.
18 (Time noted:
3:34 p.m.)
19 20 gg THOMAS F.
SCOTT, JR.
,(
22 Subscribed and sworn to before me 23 this day of 1982.
24 25 i
/
= = - --
_