ML20062H470
Text
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING &' POWER S
COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear S
Generating Station, Unit S
No. 1)
S Material Facts As To Which There Is No Genuine Issue To Be Heard (1)
Following a postulated loss-of-cool accident (LOCA)
Mark III drywell pressure is increased by escaping reactor steam and a steam / air mixture is directed to the Suppression Pool through the horizontal vents which connect the drywell and the containment.
The drywell air forms large bubbles which expand and depressurize causing an upper displacement of water in the Suppression Pool.
When the bubble breaks through the pool water surface a froth is formed.
This entire phenomenon is referred to as " pool swell." (Stancavage Affidavit pp. 2-3)
(2)
As part of its Mark III test program, Ge.neral Electric has engaged in an intensive experimental and analy-tical effort, including more than fifty full-scale and
~
8008190053 15
l sub-scale experiments over a peried of 5 years, to determine the loads on structures and equipment above the Suppression Pool.
(Stancavage Affidavit pp. 3-7).
(3)
The General Electric and other tests have shown that the worst case event which initiates pool swell is the design basis LOCA event; safety relief valve actuation does not cause pool swell.
(Stancavage Affidavit p. 3).
(4)
The pool swell phenomenon occurs in two phases;
" bulk" pool swell, followed by a " froth" pool swell.
Bulk pool swell imparts both an impact load and a drag load on exposed structures and equipment while the froth stage imparts only a drag load.
(Stancavage Affidavit p. 7).
(5)
The Control Rod Drive Hydraulic Control Units (HCUs) will be located on platforms above the maximum lift height of the worst case Suppression Pool swell.
Therefore, these units will not experience a direct " impact" load from the rising water slug.
The HCUs will be conservatively designed to withstand the less severe " drag" loads produced when escaping air bubbles break through the water surface.
(Stancavage Affidavit pp. 8-10; Sullivan and Cheng Affidavit pp. 2-3)
(6)
The transversing in-core probe (TIP) station will be located on a concrete structure cantilevering outward from the drywell wall at an elevation approximately six feet above -
16
the normal Suppression Pool surface.
Because the TIP plat-form design includes a sloped bottom, this structure will not experience a direct impact load.
In any event, the TIP performs no safety function and its postulated loss has no safety significance.
(Stancavage Affidavit pp. 10-11; Sullivan and Cheng Affidavit p.
- 3) $.7
79-1743C DSH COSTS' Doherty Contention No. 5/
PAID BY PLF. DEF.
Suppression Pool Swell 3
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3EFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF:
HOUSTON LIGHTING AND POWER COMPANY, (ALLENS Do ck.e t No. 50-466 CREEK NUCLEAR GENERATING STATION, UNIT 1) s DEPOSITION OF:
JOHN F.
DOHERTY J
I M2/
22 N
d er#
,m ets a
1917 Bank of the Soutnwest Building. Houston, Texas 77002.(713) 652 5911 i
1 consequences listed in B,
C and D of your 2
contention?
Is that where you are right now?
3 A.
Yes.
4 Q.
Thank you.
Let's move on to pool swell.
5 A.
Thank-you for that.
6 Q.
Would you describe for me what you 7
understand to be suppression pool uplift?
8 A.
When the pressure is released through 9
the safety relief valve to the suppression pool, 10 there is a pushing up and outward of the water in 11 that pool.
Some of it is up, uplift is the word 12 I've seen used and I used here, descr'ibing that.
13 Q.
So for purposes of this contention, you 14 are talking about a dynamic effect on the pool Q
4 15 caused by the lifting of safety relief valves?
16 A.
Yes, I think that's right.
17 Q.
How high is this pool uplifting?
18 A.
I've been trying to find that out.
I 19 Q.
I gather from your answer, you don't 20 know how high it goes?
].
4 21 A.
You can only sort of estimate from the
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22 drawings here a little bit.
I'd like to get an m.
23 exact amount.
i 24 Q.
What is your estimation of the height 25 above the top of the pool?
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1 A.
It looks like it would be something o'
f, 2
the order of 20 or 25 feet.
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/
3 Q.
What is the source of your estimate of 4
how high the uplift will go?
1 5
A.
Just looking at these drawings.
j I
6 Q.
And would you tell me what that drawing 7
i s?
tj 8
A.
PSAR Fi 3ure 1.2-8.
9 Q.
Where is it indicated on there the
(
I 10 height of suppression pool uplift?
l' 11 A.
It's not.
I think it should be 12 corrected, there seems to be two numbers.
It's 13 also Figure 2.2-2, Sheet 1.
.t 14 Q.
Is there.anything on that drawing that
,1 15 you have there that indicates the height of G)
-p 16 suppression pool uplift?
17 A.
No, there's nothing there.
18 Q.
Then, how did you estimate the height of 19 suppression pool uplift using that figure?
20 A.
I just took a guess looking at the 21 figure.
22 Q.
You just looked at the figure and then
[
23 guessed as to how high it would go?
24 A.
Yes.
f 25 Q.
So the whole of your contention about 20 INTERNATIONAL COURT REPORTERS, INC.
I t
e.
1 1
influencing certain components is, based on your 2
guess of how high suppression pool uplift will go t
3 by looking at that PSAR figure?
4 A.
In the case of Allens Creek, yes, right t
MI 5
now.
]
6 Q.
What loading will be exerted when the 7
pool reaches its maximum height that you have 7
3-J 8
guessed at?
f 9
A.
By loading, do you mean type of force 10 would be applied?
11 Q.
Yes.
12 A.
- That, I can't tell.
13 Q.
Have you guessed at the load as well as m
S 14 the suppression pool height?
15 A.
No, I haven't even taken a guess.
16 Q.
So you ventured to guess at the height, 17 but you have not guessed at the force?
18 A.
Right.
19 Q.
Then, what is the basis of your 3
Q 20 contention here that these two mechanisms are 3
21 susceptible to damage by suppression pool uplift?
22 A.
Well, it appears that some amount of e
u 23 water would rise to that point.
24 Q.
It appears that some water will rise to 25 that point?
21 INTERNATIONAL COURT REPORTERS, INC.
Llo 1
A.
Yes, estimating.
2 Q.
What makes you imply that water will 3
reach that height?
I thought we established it 4
was based on a guess.
4 5
A.
Tha t's right, we did.
6 Q.
So you have guessed as to the height.
y 7
You have no guess as to the load and that leads l
J 8
you to the third guess that there will be some i
9 damage to these components?
1 10 A.
A moment ago, you asked me for the I
11 loading which implied some type of force answer.
12 I have only a rough estimate, not in numbers, but i'
d 13 just in terms of experience that it looks as if 33 i
14 the large amount of water will rise upward and j
15 strike the parts mentioned in the contention.
16 Q.
Well, let's make sure we're very clear i
7[l 9
e 17 about our terms here, Mr. Doherty.
Do you have M
23 18 an estimate or do you have a guess as to a load
-4 19 being exerted on these components from pool swell?
h3 20 A.
What is an estimate to you, sir?
21 Q.
An estimate is some figure that has a 22 rational basis.
A guess is a hunch or a figure 23 that has no rational basis.
Now, which of those 24 is pertinent to your contention here?
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25 A.
What is a figure to you?
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1 Q.
A number.
l 2
A.
No, then it has to be B,
guess, I have 3
no number, 4
Q.
So this whole contention is then a guess?
j i
5 A.
You may label it as you like.
i 6
Q.
You have no knowledge as to the height
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s 7
of the suppression pool uplift?
l 8
A.
At this point, I do not, that's right.
1 9
Q.
You have no knowledge as to the load c
10 that will'be exerted by the suppression pool 11 uplift?
i 12 A.
That's right.
1 13 Q.
You-have no knowledge as to the ability F
2 14 of these components to withstand that load?
f 1
i 15 A.
That's right.
+
16 Q.
You have no knowledge as to the ability 11 17 of the floors within the containment to withstand 18 enat load?
there is a 3
19 A.
There are documents l
J 20 document NUREG 0474 which indicates that the
,+
! 4 21 things that I have expressed may occur.
22 Q.
Would you show me those passages in 04747 23 A.
I don't have 0474 with me.
However in 1
4 24 my response to your interrogatories, I believe
+
25 there is something.
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INTERNATIONAL COURT REPORTidd, INC.
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1 Q.
What is that something that's in your ji 2
response?
3 A.
All right.
In answer to your question, 4
B-2.
O 5
Q.
What about the answer?
- Well, is enis 6
contention based on information contained in 7
8 A.
Some of it is.
9 Q.
What portion is not?
T 10 A.
I had to take some information from the q
11 plans for Allens Creek in order to locate what 12 items in the reactor building might be subject to 13 the loading of suppression pool uplift.
14 Q.
What information did you take from the 15 plans of Allens Creek to use in conjunction with 16 NUREG 04747 17 A.
The location of those items.
[
f 18 Q.
The location of the control rod drive 1
19 mechanism, hydraulic unit and of the tranversing i
20 end core probe?
21 A.
Yes.
2?
Q.
That's the only information you.took 23 that is Allens Creek specific for this contention?
24 A.
Yes.
t 25 Q.
Does NUREG 0474 indicate the height of M
l INTERNATIONAL COURT REPORTERS, INC.
HOUSTON. TEXAS (713) 652-5911
1o1 IS 4-1 pool swell?
2 A.
Not for this unit, to my knowledge, not 3
for Gessar 238.
4 Q.
Does it indicate what force or load 5
might be exerted by the pool swell?
T
~
4 6
A.
No, it doesn't right at the moment that 4
7 to my knowledge.
8 Q.
Then, if the only information you have
'1 4
9 is the location of these two named components and 10 NUREG 0474 says nothing as to the height or load 11 of suppression pool uplift, what is the basis for 12 your contention that suppression pool uplift may gg 13 in fact affect these components?
=a 14 A.
The previous GE units have had this 15 cited as one of their problems.
16 Q.
Which units?
17 A.
Mark I and Mark II units have.
18 Q.
Is it your understanding that Mark I and 19 Mark II units are identical for these purposes
]
20 for the Mark III design for Allens Creek?
c' 21 A.
No.
T 22 Q.
Are they in any way similar?
i 23 A.
Tha t I'm not certain.
T 24 Q.
You do not understand the differences S
25 between a Mark I,
a Mark II and a Mark III 25 5
INTERNA"IONAL COURT REPORTERS, INC.
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suppression pool?
y a
2 A.
As related to this very detailed point, 1
3 no.
4 Q.
Then, how can you base a contention on a 5
Mark III suppression pool uplift to other j
e 6
different systems that you have no knowledge of?
i i
7 A.
Part of it's in the contenti)n answer i
al 8
that no full scale tests have been done to guard e
i 9
against the possibility.
10 Q.
What part of the answer is in that 11 s ta temen t?
]
12 A.
What part of the answer?
It's in the 13 contention --
}
14 Q.
Now, you said that the answer to my 15 question about how you could base this contention 16 on two completely different systems that you have 1
17 no knowledge of and you said, part of the answer 18 was the statement in the contention that no full 19 scale "ests have been performed and I asked you
.j 20 what part of that answer was in that statement?
21 A.
Well, evidently, I was moving ahead 22 instead of replying to your question.
What I am 23 saying is that Mark I and Mark II plans have had 24 these problems and as an intervenor, I see no 25 proof that Mark III will escape these problems.
26 95 INTERNATIONAL COURT REPORTERS, INC.
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Q.'
As an intervenor, do you see any a
2 information at all which will indicate that the y
3 problems, whatever they were at Mark I and Mark
+
ii 4
II, will also occur in a Mark III plant?
a 5
A.
App,arently they were, I'm not certain 7
.i
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6 they have been corrected.
9 7
Q.
Apparently what was?
8 A.
Th.t t the danger of pool swell uplift was j
3 a problem.
10 Q.
Fo r the Mark III?
11 A.
Yes.
12 Q.
What gave you that indication?
13 A.
I'm trying to locate the exact site now.
i l
14 Q.
What are you.looking at to locate that 15 exact site?
16 A.
A book called "The Silent Bomb".
17 Q.
"The Silent Bomb"?
i 18 A.
Yes.
19 Q.
B-0-M-B7 l
20 A.
Yes.
1 21 Q.
Did you find what you were looking for?
22 A.
Not exactly, I was looking for a 23 quotation by a man named Dragoonm, as who was 1
24 employed by Potomac Electric Power.
o P
25 Q.
Well, maybe I can expedite things, Mr.
1 INTERNATIONAL COURT REPORTERS, INC.
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Doherty.
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2 A.
- Yes, I'm sorry to take so long.
3 Q.
Am I correct in assuming that the only 4
basis for your contention is NUREG 0474, whatever l
5 facts are contained in there pertinent to this f
6 contention and this book, "The Silent Bomb"?
7 A..
No, I think there's testimony by the 8
General Electric engineers named Minor, b
9 Bridenbaugh and Hubbard in 1976 as well.
10 Q.
What did they say in their testimony?
11 A.
That suppression pool swell was a 12 p r o b.l e m for the Mark III system.
13 Q.
What did they base that conclusion on?
}
14 A.
At the moment, I don't know.
15 MR. NEWMAN:
You said they 16 identified the problem.
What was the nature of 17 the problem they identified.
18 A.
That in the event of blow-down, the 19 water in a Mark III containment system would rise 20 and load on safety components in the reactor i
21 building.
7 22 MR. NEWMAN:
Did they specify tip 1
23 system, T-I-P?
24 A.
No, I don't believe they did, but I'm 25 not certain.
I just don't believe so.
}
28 3
INTERNATIONAL COURT REPORTERS, INC.
It o u s T O N. TEXAS (713) 652-5911
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1 Q.
(BY MR. BIDDLE): Then, am I correct, Mr.
2 Doherty in assuming that the only basis for your 3
contention is whatever facts that are relevant 4
are contained in NUREG 0474, the book "The Silent a
1 5
Bomb" and the testimony by the GE engineers?
6 A.
Yes, for the time being, yes.
1 3.
7 Q.
That is the basis of your contention now?
o 8
A.
Seems to me that's where I located i
9 almost all the material that went into this.
i e
10 Q.
You have no other facts to support this 11 contention; is that true?
j 12 A.
I need to refresh my memory a minute.
13 Also, do you want to go back on or -- in addition, g
e u>
14 there is a memorandum which I have received from r
15 the Union of Concern Scientist that is q
16 essentially a part of at least the document from f
9J-i 17 Dr. Stephen Hanour, then of the AEC, dated I
n 18 September 20th, 1972 which does mention a f
19 tendency of. overcrowding and limitation of access 20 to reactor and primary system components for 21 surveillance and in-service testing.
22 Q.
What has that got to do with suppression 23 pool uplift?
e L
24 A.
The fact that the reactor containment p
25 building has been reduced in size because of the d
29 INTERNATIONAL COURT REPORTERS, INC.
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,73,s ago.coit
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use of the pressure suppression system.
2 C.
What has that got to do with the 3
loadings exerted by suppression pool uplift?
4 A.
This says that at the moment, the type 5
of system has the problem of overcrowding and 6
limitation of access and 7
Q.
That reference there is to the Mark III 8
system?
9 A.
I believe it is, yes.
10 0.-
Does this have anything to do with 11 loadings exerted by suppression pool uplift?
12 A.
Yes, it does.
a 13 Q.
What?
14 A.
Because it says that since these devices 1
15 have to be placed somewhere, they have been 16 crowded near the top of the pressure suppression 17 pool 19 Q.
Where does it say they have been crowded 19 near the top of the suppression pool?
x 20 A.
All right, it doesn't say that, but it n
E 21 does say --
22 Q.
You just told me that it did say that.
O 23 A.
That's right.
All right.
I say that.
24 Q.
Is there anything in that document that
- P 25 you're reading from there now make any reference 30 w
1 INTERNATIONAL COURT REPORTERS, INC.
1 to suppression pool uplift loadings?
Did you 2
understand my last question?
3 A.
Yes, sir.
4 Q.
Could you answer then this question, Mr.
5 Doherty.
Are the words suppression pool uplift 6
ever used in that document you were just reading?
7 A.
I didn't see them in looking through it 3
just now, Mr. Biddle.
9 Q.
Would you tell me what the tranversing 10 end core probe system is?
3 11 A.
Oh, I think it's an information system, L
12 sort of like a mobile, sort of like a mobile LOCA 13 power range monitor.
It can be moved-around.
14 Q.
So this system is used to measure 15 neutran flux when the reactor is operating and is 16 capable of moving about the core; is that your 17 understanding.
18 Q.
That's my understanding of it, yeah.
19 Q.
Could you describe it physically?
20 A.
No.
21 Q.
Do you know where it's located?
22 A.
Part of it.
Part of it is located in 23 the containment. building near the concrete, 24 apparently that's concrete support for the 25 reactor vessel.
'~
31 1
INTERNATIONAL COURT REPuRTERS, INC.
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1 Q.
Can you tell me what elevation that is?
o 2
A.
145 feet, 145 feet and three inches I 3
guess is the way that could be read.
4 Q.
Is this the component you're concerned w
5 about in your contention as experiencing a load t
m 6
from suppression pool uplift?
7 A.
Yes, that's one of them.
m B
Q.
That is the tranversing end core probe 9
e 9
that you reference in your contention located at 10 elevation 145 feet, roughly?
11 A.
Yeah, that's the one.
The drive units w
I 12 are located somewhere between 142 and a half feet 1
=
13 and 145 feet three inches.
At the appear to be 2
14 142, well, let's say 143 feet.
15 Q.
So I understand you to say that you're 16 concerned about the impact on these two 17 components, both of which are above elevation wa 18 approximately 143 feet.
19 A.
The bottom of one appears to be 143 feet 20 from sea level.
a 21 Q.
So the answer to my question is yes?
22 A.
Yes.
y 23 Q.
Can you tell me the role of the 5
1 24 tranversing end core probe system in preventing 25 accidents?
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INTERNATIONAL COURT REPORTERS, -INC.
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1 A.
It would provide away of getting h.
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2 information about the reactor core.
e t
3 Q.
During normal operation?
g 4
A.
During normal or accident operation.
{ R s e l
5 Q.
Can you describe for me the role of the 6
tranversing end core probe system in mitigating
.v :
7 accidents?
I t '.
3 A.
It's not an accident mitigator by itself, l J 9
Q.
It is used only in preventing accidents?
.(d 10 A.
No, it could be used for any of a number
'f ;'
f,il 11 of other reasons.
l IC -
a.;.
12 Q.
What are the other reasons it's used?
{r' 3; r 13 A.
I'm not aware of all the reasons anyone
!{l 14 might use a traversing end core probe.
((
Ylk fj j 15 Q.
Why are you concerned about the
[' :
16 traversing end core probe being damaged?
- j i et nk,;
17 A.
Well, I don't think it's there for fun.
ih.e 18 It must have some use.
U p
- h 19 Q.
Do you know what use it is?
20 A.
It does give information as I described y.
21 earlier and that must be of some importance or it 22 wouldn't be there.
[',
ji 23 Q.
Does it have any importance to you or
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24 are you just rel'ying on the fact that it is f
25 installed?
y
- t-33
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INTERNATIONAL COURT REPORTERS, INC.
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1 A.
I think when people decide safety.
2 equipment like tnis is needed, that I'm concerned.
3 Q.
So you have no direct knowledge of its
]
4 importance; you're relying only on the fact that
]
5 it is, in fact, installed?
6 A.
I think I indicated earlier that it was
]
7 used to give information about LOCA concitions in i
3 8
the core and that is some information I have.
9 Q.
And that is the basis of your concern
}$
10 that it might be damaged is that you will lose 7
.:3 11 this information in the core?
=
12 A.
Yes.
13 Q.
Can you describe for me the function of
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14 the control rod drive mechanism, hydraulic units?
15 A.
Only that it appears to be an important
=jg 16 part of the entire control rod mechanism.
'5e SM 17 Q.
Why does it appear to you to be an gjg 13 important part?
control rod drive l
19 A.
It appears to be
."g 20 unit, the control rods are essential for
]l 21 controlling the reactor.
22 Q.
Well, that might be an answer to another i
23 question, but mine was:
What is the importance
((j 24 or the function of the control rod drive w
25 mechanism, hydraulic unit?
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A.
I don't know the exact function of it, 2
but it appears to be significant to the movement i
3 of control rods.
4 Q.
What gives that appearance?
t S
5 A.
Drive.
E 6
Q.
What gives tnat appearance?
7 A.
Drive,,the word drive.
5 8
Q.
Oh, the word drive in the name drive?
a a
9 A.
Yes.
10 Q.
So the important to you of this d
11 contention as to these components is the ract f
12 that the word drive is included in the name, 13 control rod drive mechanism, hydraulic unit?
e 14 A.
That's part of it.
Control rod is t
15 important, the whole term is important.
s, 16 Q.
So you derive all of the importance of 17 these components in this contention from the 18 label?
19 A.
That's an odd question.
I just wouldn't 20 say all, but that's important.
I think I need to 21 know a little bit more about what the control rod 22 drive mechanism does in order to discuss the 23 contentions sensibly at the hearing.
3 4
24 Q.
My question to you was exactly that.
25 would you tell me what you understand to be the 35 t
192 1
ft etion of the control rod drive mechanism i
1 2
hydraulic unit?
i 3
A.
At the moment, I don't understand its l
t 4
function.
5 Q.
And therefore, the only importance you 6
attach to it is that derived from the words used I
7 in the label, control rod drive mechanism, 8
hydraulic unit; is that correct?
I 9
A.
All right, that's correct.
10 Q.
I'd like to recap briefly, is it my 11 understanding that you do not know what load will 12 be exerted by suppression pool uplift on the t
13 floor which supports either the tranversing end j
3 14 core probe or the control rod drive mechanism, 15 hydraulic units?
o 4
16 A.
Yes, I think that was my answer to o
17 question B-2 in your interrogatories.
18 Q.
Do you know what the design loading for 19 those floors are?
v 20 A.
Not at the moment, v
a 21 Q.
Do you contend that these floors cannot 22 absorb the impact of suppression pool swell up-23 lift, whatever that might be?
o 24 A.
Yes, at the moment.
25 Q.
What is the basis. for that contention?
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193 m
.9 1
A.
That under previous books that I've y
a3 2
indicated to you, that there was a problem along
]
3 chis line and if the floor was sufficient, there 4
wouldn't have been a problem.
5 Q.
Did you identify any problems other than
[
6 those experienced, supposedly experienced in the 7
Mark I and the Mark II?
8 A.
Say again?
9 Q.
Did you identify any problems other than 10 those supposedly experienced by the Mark I and 11 Mark II systems?
12 A.
I haven't been abl.e to reference some of I
13 the problems about Mark III which were mentioned I
14 in this book.
15 Q.
Which book is that?
16 A.
Yes, let me look at the title.
- Silent 17 Bomb".
(
18 Q.
Would you give me the author and the
=
19 date of that book?
j 20 A.
I'll do my best.
All right.
The date 21 is 1977.
I am trying to remember the author's 22 name.
23 Q.
It's not indicated on that flap edge?
24 A.
This is just xeroxing some of the 25 chapters, so it doesn't seem to be right handy.
av 1