ML20072H730
| ML20072H730 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/24/1981 |
| From: | Faust C METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-04, TASK-07, TASK-08, TASK-09, TASK-1, TASK-2, TASK-3, TASK-4, TASK-7, TASK-8, TASK-9, TASK-GB NUDOCS 8306290703 | |
| Download: ML20072H730 (143) | |
Text
_ _ - - -
~
569 UNITED STATES DISTRICT COURT b(,)os SOUTHERN DISTRICT OF NEW YORK
- -x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
I
-. - - -x Continued deposition of METROPOLITAN EDISON CO MP ANY by CRAIG C. FAU3T, taken by De fendant s,
pursuant to adjournuent, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Thursday, the 24th day of Septembe r 1981, at 10:11 o' clock in the forenoon, be fo re Charles Shapiro, ce rtifie d Shorthand Reporte r and a Notary Public within and for the State of New York.
y O
DOYLE REPORTING. INC CERTIFIED STENOTYPE REPORTER 1 369 LaxtNSTON AVENUR WALTER SHAP!RC, C.S.R.
Nrw Yomst. N.Y.
10Q17 CHARLES SHAPIRO, C.S.R.
TaLEPMons 212 - 867 8220
1 570 o)
(_
2 Appe aran ce s :
3 KAYE, SCHOLER, FIE RM AN, HAYS & EANDLER, ESQS.
4 Attorneys for Plaintiffs 9
425 Park Avenue 5
By:
ANDREW MacDONALD, ESQ.
-and-7 RICHARD C.
SELTZER, ESQ.,
)
o f Co un se l 8
1 9
LeEOEUF LAME LEIRY & MacRAE, ESQS.
10 Attorneys for the Witness 1333 New Hampshire Avenue, N.W.
11 Washington, D.
C.
20036 12 By:
KEVIN M.
WALSH, ESQ.,
of Counsel s
g) 13 14 DAVIS POLK & WARDWELL, ESQS.
15 Attorneys for Defendants One Chase Manhattan Plaza 16 New York, New York 17 By:
ROBERT R.
FISKE, ESQ.
WILLIAM E.
WURTZ, ESQ.
18
-and-RODMAN W.
BENEDICT, ESQ.,
19 of counsel 20 (gg 21 Also Present:
22 JOEN QUINN 23 (y
u e e e V
25
1 571
(~)
2 CRAIG C.
- FAUST, having been 3
previously duly sworn, resumed and testified
{
4 furthe r as follows:
j (O
w 5
E XAMINATION CCONTINUED) 6 BY MR. FISKE:
7 Q
Mr. Faust, you realize you are still under 8
oath?
9 A
Yes, I guess I am.
10 Q
You understand that, right?
11 A
- yes, 12 Q
Did you, in between the time we adj ourne d
(
13 in August and today make available to your counsel 14 I
certain documents that you had in your possession?
15 A
- Yes, 16 Q
Can you tell us what the nature of those 17 documents were?
IO A
They we re assorted training mate rial that I just 19 colle cte d ove r the years, being at the plant.
A lot 20 of it was recent training material that I had gotten g
21 since the accident.
22 Q
where did you have this material?
23 A
some of it I had at home and others I had at the
[V')
24 plant, and some of it I turned over to my attorneys.
[
f 25 Q
Which attorneys?
1
l 1
Fauct 572
(~)%.
(_
2 A
Well, LeBoe uf Lamb, Kevin Walsh representing 3
t he m.
4 Q
I guess what I would like to find out, Mr.
(
5 Faust, is what you had done since we left the last 6
session of this deposition in August to collect docu-7 ments for production to your counsel.
8 A
I j us t gathere d --
9 MR. MacDONALD:
I think you wante d the 10 documents from his home the last time.
11 A
(Continued)
That's all I did, was just collect 12 I
the documents which I had sitting at home, which was
()
13 training material that I had known of that I had 14 received after the accident.
I just had it at homa for l
15 study purposes.
16 Q
Well, did you ge t mate rial that you turned 17 over to the Kaye,.Scholer firm from anyplace othe r than 18 your home?
19 A
Some of it was at th e plant.
I have a locker at 20 the plant.
I just pulled it out.
I put it all in 21 boxes and sent it or brough t it in.
22 Q
That is what I am trying to find out.
23 From wha t ddfferent place s did you collect x
24 mate rial that you gave to Kaye, Scholer?
25 A
Personally?
1 Faust 573
(^'N
\\-
2 g
Yes.
3 A
Two place s.
The locker at the plant that was 4
additional stuff I had that you were asking about, and 5
at my home.
That is whe re I pulled the material that 6
you wanted.
That is the way I unde rstand -- that is 7
what I understood you wanted me to bring or make 8
available to you.
9 MR. FISKE:
I think the record should 10 reflect that certain mate rial was delive re d to 11 us en the late afternoon o f Sep tembe r 2 2, that 12 is, the day before yeste rday from Kaye, Scholer.
13 0
What I would like to do, Mr. Faust, is mark li come of that as exhibits, and then go through it with 15 you.
16 MR. FISKE:
Could we mark as Exhibit 276 a 17 colle ction of mate rial, of Xeroxed mate rial which 18 bears the numbe rs 10 34 conse cutively through 1524.
19 This is preceded by a page that has the number 20 2698-5-1 on it.
21 (Zeroxed pages, that are comprised of a
[
22 page numbered 2698-5-1 plus pages numbered 23 consecutively 1034 through 1524, was marked
(^.)
24 B&W Exhibit 276 for identi fication, as of this
\\_/
25 date.)
1 Faust 5 74
~'
(
i
\\ '/
2 (Documents hande d to the wi tne s s. )
3 g
Do you Eave that material in front of you, 4
Mr. Faust?
O 5
x
- yes,
.6 g
Do you recognize that as copies of material 7
that you delivered to your counsel for production to us?
O A
It looks like the stuff I de live red.
Part of it, 9
anyway.
I am looking at it right now.
Just thumbing 10 th rough it, it looks like my reactor theory on this 11 fi rst one.
12 I MR. NacDONALD:
I think you have answe re d
(_/
13 the question.
14 There is a question pending?
i 15 MR. FISKE:
Yes.
16 ME. M a c D O !' A L D :
He answered it.
His answer 17 was yes.
18 Do you have another question for him?
19 MR. FISKE:
I believe Mr. Faust is still 20 looking through the mate rial.
gg 21 MR. MacDONALD:
The question is, do you 22 recognize'it?
23 THE WITNESS:
I want to make sure.
It's a t
('j 24 long time.
It looks like it, yes, that mate rial.
V l
25 Q
I woul d like you to look at the mate rial that l
l
1 Faust 575
[\\_/
2 starts at Page 1259.
3 A
This one Cindicating} ?
f 4
Q Do you see a page marked 3 259, the page that 5
says Chapter 6, operating Characteristics?
6 A
oh, right in front.
Excuse me.
I am looking at 7
that.
I am sorry.
8 Q
Was this mate rial, which you produced to 9
your counsel in some sort of a loose-leaf binder?
10 A
Yes.
~
11 Q
Let me direct your attention to Page 1386.
12 A
Yes.
()
53 Q
- Does that say nuclear power preparatogt Z4 training core performance, 4,
number 4, a course for
\\
15 Metropolitan Edison by vide ot ape by NUS Co rp o ratio n,
16 Rockville, Maryland?
17 A
That is what it says.
18 g
Is there a name at the top of that page?
19 A
My name, Faust.
l 20 Q
Is that in your handwriting?
1 21 A
It looks like my printing, yes.
g 22 Q
Is it material that begins on Page 1259 23 entitled "Chapte r 6, operating Ch aracte ristics," part
(~}
24 of the booklet which is the nuclear power preparatory
'wJ 25 training book?
l 1
Faust 576 f's i
i
\\/
2 MR. MacDONALD:
Are you asking whether the 3
ma te rial 1259 to 1385 is part of what is from 4
1386 to 15247 5
MR. FISKE:
Correct.
6 MR. Mac DON ALD :
Excuse me.
I just didn't 7
hear you.
8 MR. FISKE:
Yes.
9 A
Yes, it is a continuation of it.
I believe it is 10 a dif fe rent I believe it is f rom a diffe rent handout I
11 that I di d.
12 Q
tre li, let's just start at Page 1286,
()
13 Nuclear Pcwer Preparatory Training.
Do you see that?
l 14 l A Yes.
15 Q
Was that a booklet of some form that was 16 given to you in the course of your training at Met Ed?
17 A
Yes.
18 MR. MacDONALD:
At some point in time?
19 MR. FISKE:
Yes.
20 A
I believe it was, yes.
If I remember right.
21 Q
Is the mate rial that appears beginning at 9
22 Page 1259 part of that booklet?
23 A'
That is what I am not sure of. It has an outline
~
24 in the front of it there that doesn't really have this 25 section in it.
I think this was something else.
l l
1 Faust 577
(^N
\\-
2 Q
So your answer is no?
3 A
I d.r't believe it is.
I started putting 4
material that I had gotten together in a book.
hk 5
Q I don' t understand that answer.
6 A
And I might have had this and stuck this in the
.7 book, the same book with the (indicating).
That is all.
8 Q
You mean you may have stuck the material 9 l beginning at Page 1259 in the same loose-leaf notebook 10 thac pertained to nuclear power --
11 MR. MacDONALD:
He is asking you if yon
~
12 can recall.
(%
=
(_)
13 A
Well, what I am saying is I just stuck mate rial 14 to ge the r, that I had.
It might not have been in any 15 specific order.
16 Q
Looking again at the booklet that is 17 entitle d " Nuclear Power ' Preparatory Training," you did 18 receive that, did you not, in the course of your 19 training at Met Ed?
20 MR. MacDONALD:
At what point in time?
21 MR. FISKE:
Will you read the question 22 back, please.
23 CQuestion read.)
24 A
Le t me get this right.
You are asking me if I
(']
v 25 just received this in training from Met Ed?
1 Faust 578 2
Q Yes.
3 A
I remember receiving material in training, yes, 4
when I was at Met Ed.
i e
5 Q
O.K.
6 A
And this is probably -- I would have received it 7
at Me t Ed, yes.
I am just trying to say I received it 8
at Met Ed.
9 Q
Yes?
10 A
Tha is what you asked?
)
11 g
- yes, 12 x
o,g,
(
)
13 Q
As pa rt of what training program at Met Ed x_,
14 did you receive this booklet?
15 A
Just a second.
Let ze thumb through here a little 16 bit.
17 Q
Sure.
18 A
This might come back to me.
19 I can' t actually answe r what -- which part 20 of.the training program I received it in.
I know I 21 received it, but I am having a hard time distinguishing g
22 which one I received it out of.
23 Q
Who was the individual at Met Ed who f~}
24 provided this to you?
<s 25 A
I don' t remembe r that.
That was probably handed
l 1
Faust 579 (j
a
\\m 2
out in a class we had.
3 Q
Ge ne rally, Mr. Faust, without going beyond 4
this particular document we are talking about now, but 5
covering this training material that you produced to 6
your counsel in the last week or so, is it correct 7
that that was mate rial that was provided to you during 8
the course of your training at Met Ed, all of it?
9 A
You are not looking for a time period?
10 0
No.
11 MR. 15adDON ALD t You told him it was pre 12 and post the accident.
()
13 j
THE WITNESS :
Yes.
I'A 14 It was presented to me.
15 Q
Going back to this pa rticul ar do cume nt,
16 beginning at Page 1386, the nuclear power preparatory 17 training book, did you use this book in the course of 18 any classroom discussions at Met Ed?
19 A
I would have, yes.
20 Q
Did you unde rstand when you received it 21 that you were supposed to read it and become familiar qgg 22 with it?
23 MR. MacDONALD:
You mean with every word g-~%
24 that is written there?
Is what sense familiar?
(_)
25 Q
Did you understand you were supposed to
1 Faust 580 j
l'
(' %
4
/
2 read this booklet when you receive it in the training 3
program?
4 A
You are speaking about the one with my name on 5
it the re (indicating)?
6 Q
Yes.
7 A
O.K.
I believe this was a book that we used 8
in a training program like it says in conjunction with 9
videotapes that they had.
10 Q
By "they," you mean Met Ed?
11 A
Me t E d.
12 Q
What was th.e nature of the videotape?
C:)
i 13 MR. MacDONALD:
You mean what was the j
i 14 contents of it?
15 MR. FISKE:
Yes.
16 A
It covered what yo u' ye got in front of you, 17 that's all.
Actually, it was almost in the nature 18 of being -- you would read a section, and that's why 19 I' m wonde ring.
If this was the one for sure.
You 20 would watch the said videotape and you would also 21 reproduce it from this.
[
22 Q
Just so I unde rstand you, did the videotape 23 reproduce verbatim what is in the booklet itself?
f) 24 A
No, not in this format.
v 25 Q
Without asking obviously to recall the i
i
1 Faust 581 O
\\
2 pre ci se detail of the videotape, do I un de r s t 1n d 3
corre ctly that the videotape cove re d the same 1
4 in fo rma tion, the same subj ect matter but presented 5
the information in a different form than what is in l
6 the booklet?
7 MR. MacDONALD:
On this particular 8
matter?
9 MR. FISKE:
Yes, the one that is called --
I 10 MR. MacDONALD:
Nuclear power preparatory 11 training.
.12 MR. FISKE:
- Yes, e
13 A
1 don' t recall it being in thiu fernata no, the,
(
14 videotapo.
15 Q
In other words, the video format was
.16 A
I am not -- I could be wrong on saying this was 17 the exact one, the video tapes we were thinking about.
18 Q
Does the fact that it says on the cove r o f 19 this booklet, "A course for Met.ropolitan Edison 20 company via videotape," help refresh your recollection?
21 A
I know I studied with videotapes, and I have gone
{
22 to a handout we had, but the ones I am thinking about 23 that I did the program under that was reactor theory.
(~N, 24
.It was listed reactor theory.
That is why this V
25 doesn't really look like the format of that one that
1 Faust 582
(~%
\\-
2 we used.
3 Q
I guess all I am asking you now is 4
whe the r, to the best of your recollection as you sit 5
here today, you can tell us whether you recall seeing 6
a videotape for the subj ect matter of the booklet,
7
" Nuclear Power Preparatory Training, Core performance."
8 A
That would fit this.
I don't recall -- I 9
can' t recall that spc cific videotape, no.
The one I
- l 10.
an recalling is "Re actor Theory. "
This night have i
(;
11 i include d something like " Core performance."
but I i
12 don't just remenbe r specifically this (indicating).
(~)h p'
vhet is the last time you saw that s.,
13 14 vide ot ape ?
15 MR. SELTZER:
Which one?
16 Q
The one that you just referred to.
17 A
Back in
'77, I believe.
18 Q
When is the last time you read this book 19 that we have just been talking about, " Core 20 Pe rf o rman ce "?
l 21 MR. MacDONALD:
From cover to cover or g
22 when he might have read a page in it, or what?
23 MR. FISKE:
Any part o f it.
(')
24 A
I don' t think I can answer that.
I picked up
\\_J 25 material and I have written my name on it, and that is
/
1 Faust 583
/"N N..]
2 what 1E am trying to dis ce rn he re, de ciphe r.
If I just 3
picked it up on ny own this might have been one that I 4
did.
I have done that.
That is why this is part of my 4 16 5
pe rsonal training mate rial where I was just -- I might i
l 6
have come across it and picked it up.
This might be 1
7 what this is. That is why I am having a hard time 8
re co gnizing it.
9 This part here, I probably had it.in training.
1 10 I can't really recall.
11 Q
This is mate rial th at you had be fore the 12 sceident, is it not?
MR. MacDONALD:
Just what you recall, Mr.
13 i
i 14 Faust.
15 A
I had this book be fore the a c ci de nt, if you want 16 that (indicating).
17 Q
Could you turn to Page 1456, I guess that is 18 the page that is 2-42.
I would simply ask you whethe r 19 you see your handwriting on that page.
20 A
It looks like my printing, yes.
21 Q
Page 1457, which is Page 2-43, is that your gg 22 handwriting on that page?
23 A
Yes, that looks like my printing.
()
24 Q
Page 1458, is that your handwriting or 25 p rinting, that is Page 2-447
I Faust 584 l
\\ '#
2 A
1458?
3 Q
Yes.
4 A
Yes.
It looks like it.
5 Q
Page 1459, Page 2-45, is that your writing?
6 A
Oh.
Yes.
7 Q
Page 1460, the re is some writing on Page g
2-46, there is some writing near the top of the page g
right above the words "1,000 PSI."
10 Do you see that?
11 A
Y88-
.12 Q
Is that your handwriting?
J3 A
'Ye n.
My printing.
14 Q
Your printing.
15 What does that say?
16 A
I think it says " Saturation tempe rature. "
17 Q
Turn to Page 149 3 which is 3-27, 18 Is that your handwriting 19 A
Ye s.
20 Q
that page?
A That is my handwriting, my printing on there, yes.
21 22 g
The next page, 3-30.
23 3-28, is that your printing on that page ?
A Yes.
24 25 You don't find any dates on this, do you?
Fcuot 5 85
(
2 Q
The dates a re what?
The date, I be lieve, is 3
1969, copyrigh t 1969.
That is on Page 1387.
4 A
O.K.
5 Q
Page 1494, Mr. Faust.
6 A
O. K. Cindicating).
7 Q
Is that part of Chapte r 3 in the book?
8 A
It looks like it, yes.
9 Q
And then the tables that follow beginning 10 at Page 1496, 1497.
(
MR, MacDONALD:
Will you repeat the 11 12 question, please.
O 13 Q
Are the tables that appear beginning at a
14 Page 1496, are they part 'o f Chapte r 37 15 A
I don' t know.
16 Q
Going through Page 17 A
It doesn' t have an'ything that mark s it on it, 18 does it?
19 Q
You can' t tell by looking at that?
20 A
No.
21 Can you?
g 22 Q
well, it's your book.
23 A
I know it is, but that is not saying I know the 24 book by heart.
(3 25 Q
I guess the question is:
Can you tell?
1 Faust 5 86 V(3
[
2 A
To say it's on the back here.
l 3
Q The back or'what?
4 A
This section here that is Chapter 3 and then it 5
goes into a blank page and I have steam tables there.
6 I might have pulled the steam tables,out and stuck them 7
in the re for convenience.
8 Q
Let me direct your attention, back to Page 9
1272, which appears in the book as produced before 10 Page 1386.
11
.Do you see Page 4-1 which is numbe re d 12727 s
12 A
Yes.
n
(]
13 Q
'Do you l
see at the top where it says, "For 14
_ heat transfer and heat ge n e rati o n" at the top of that 15 page?
16 x,
Yes.
~1 17 Q
Does the mate rial that appears beginning 18 at No. 1272, is that Chapte r 4 of the book that's been 19 already identified as " Nucle ar Power Preparatory 20 Training, Core Performance"?
g 21 A
It is sort of out of orde r, b ut --
22 Q.
Thak; is why I am asking you the question.
23 '
If;you want to look at the table of (3
24 contents.
C) t 25 A
Oh, there you go.,
s
1 Faust 587 O
2 Is that it there?
3 MR. MacDONALD:
Are you asking him what 4
his recollection is?
He is not the author of h
the book.
5 6
MR. FISKE:
I am asking him, and he has 7
produced the book, and I am just asking him 8
whether the material that begins at Page 1272 is g
Chapter 4 of the book.
10 A
It's in here (indicating).
I collected these 11 things.
It's there.
12 Q
I am just trying to ve rify that what 13 appears.beginning at. Page 1272 is part of the book, 14
" Nuclear Power Preparatory Training, Core Performance."
15 MR. MacDONALD:
Again, he didn' t write the 16 book.
You mean, to the best of his knowledge.
17 MR. FISKE:
Yes, I unde rstand that.
18 A
I am saying it's all in that package I h ave the re,
19 yes.
20 Q
I unde rstand all the mate rial that we have 21 been talking about this morning was produced as part gg 22 of one package.
I am simply trying to go through that l
l 23 package and ask you whether this particular material,
()
24 beginning with Page 1272, entitled, " Heat Transfer and 25 seat Generations," in fact, Ch apte r 4,
" Heat Transfer l
1
1 Faust 588 N/
2 and Heat Ge ne ration, " as it is described in the 0
contents of the core performance book.
i 4
If you want to take a minute and compare 5
the page s and the heading with the contents 6
A No, it looks like it is.
7 Q
Then continuing on with Page 1296, which 8
has got the numbe r 5-1 at the bottom and the number 9
5, core the rmal pe rformance at the top, is that 10 material chapter 5 of the co re performance nuclear 11 powe r preparatory training book,7 12 A
It looks like it is, yes.
13 Q
Directing your attention to th'e page that 14 has been marke d or numbe re d 1313, is that your hand-15 writing?
16 A
Yes.
17 Q
That appears, does it not, between Pages 18 5-17, 5-187 19 A
Yes.
20 Q
your attention to Page 525, 21 which has been marked or numbered 1321, do you see your
[
22 writing on that page?
23 A
Yes, it looks like it.
~x, 24 Q
On the page that has been numbered 1324, which (d
25 follows Page 5-27, do you see your writing on that page?
g Faust 5 89 (m
2 A
It looks like I was copying somebody's notes.
3 Yes.
4 Q
Mr. Faust, you said earlier you might have 5
picked up this booklet called " Nucle ar Powe r Training 6
Co re Performance " before?
7 A
Yes. I don't remember totally how I received it.
8 I think it was part of a training program.
l 9
Q By "part o f a training program," you me an it 10 was part of the material that wa s h an de d o ut to you in i
i 11 effect that was course material for one of your training 12 programs at Met Ed?
13 A
Yes.
14 Q
As I understand your testimony, this was a 15 book that you did review and discuss in class?
16 MR. MacDONALD:
Hasn't he already testified 17 to that, or are you asking a question?
l 18 MR. FISKE:
I am trying to find out 19 whethe r that is corre ct.
l 20 MR. MacDONALD:
Framed"in the course,"if I
[gg 21 understand your testimony.
22 MR. FISKE:
Yes.
i 23 Q
Yes, that is my understanding of what you l
(~)
24 said be fore, that that was a book that was used in l
i
\\_)
l 25 class.
l l
l N
1 Faust 590 p
2 A
Yes.
3 Q
As pa rt of the procedure, Mr. Faust, in the 4
training programs at Met Ed when you had books or 5
course material such as the material we have just been 6
talking about, was it the practice at Met Ed for you 7
to be given assignments to read the mate rial so that 8
when you came back to discuss it in class, everybody 9
would have become familiar with it?
10 MR. MacDONALD:
Are you asking whether it 11 was handed out before class to read for class 12 preparation?
()
13 MR. FISKE:
Yes.
14 Q
In othe r words, when you discussed it in 15 class --
16 A
It was more going ove r it in class.
17 Q
were you also given assignments to read 18 the material so that you would be prepared to discuss 19 it at a later class?
20 MR. MacDONALD:
You are talking about 21 gg if the re was a gene ral practice?
22 MR. FISKE:
Yes.
23 A
we weren't given assignments to go home with.
24 Is that what you mean?
25 Q
You mean you were ne ve r given any homework?
l
Faust 591
\\~
2 A
we weren't given assignments to go home with.
We're union.
If they did that, the company would have 3
4 to pay us at home.
If we took it at home, a lot of us
~5 did like myself, but we would be given time there at 6
the plant to go over it.
7 Q
In other words, you would be given time 8
during normal working hours to go over the material in 9
the book, so that you would be familiar with it and 10 able to discuss it in class?
11 MR. MacDONALD:
Are you talking about any 12 specific book now or just in general?
('
13 MR. FISKE:
My questions are related to 14 the hook we have been talking about.
15 MR. MacDONALD:
Your questions were -- I 16 think if it was related to the book, relate it to 17 the book.
18 A
I believe it was more, we would go ove r it 19 together with the instructor in class.
20 Q
when you went over it, did you go ove r it 21 chapter by chapte r?
[g 22 A
well, see, this instructor might have been a tape.
23 I don' t remembe r which way we did this one.
[G
\\
24 Q
well, either way, whether it was with a --
l 25 A
And we would talk to somebody afterward.
l l
I 1
Faust 592 s
2 Q
Whichever way it was, did you go through 3
the book chapter by chapter?
4 MR. MacDONALD:
In that o rde r, Chapter 1,
5 chapter 2, chapter 37 6
A I don't recall the order that we went through it.
7 Q
But did you cover all the chapte rs in the 8
book?
9 MR. MacDONALD:
This book now (indicating) ?
10 MR. FISKE:
Yes.
11 MR. MacDONALD:
What his recollection is 12 of that book.
(~)h
\\-
13 A
I honestly couldn't answer if we cove red eve ry 14 chapter like you are sayin; like you are asking.
15 Q
Did you have any reason to believe as you 16 sit here now that you didn' t cove r all o f the chapters 17 in this book?
18 MR. MacDONALD:
You aske d for his 19 recollection.
He told you.
20 MR. FISKE:
I am asking the question.
ggg 21 A
My recollection of it would be that we had gone 22 into specific areas, I don't know if it was 23 specifically this one, but we have had programs that
()
24 we would just go into sections that we were dealing 25 with at that time, and we might not go into the rest
1 Faust 593 O
2 of that book, that particular area.
That is what I 3
am having -- I don' t think I can cort that one out as 4
to which, if you put a book in front of me like this 5
for my training program, if I remember going over the 6
whole thing in that class period.
The one I am 7
thinking about is my reactor theory where we went 8
through it chapter by chapte r.
I have been in other 9
training sessions where we might be just re fe re ncing 10 to a specific area, and that is the one we would study 11 from.
12 Q
And can you tell us as you sit here now 13 with respect to this particular book that you did not 14 go through that book chapter by chapte r?
15 A
I don't really know.
16 MR. MacDONALD:
He just told you the answer 17 twi ce now.
18 MR. FISKE:
Mr. Ma cDon al d, we would like 19 to have produced the videotape for this program.
20 MR. FISKE:
I would like to mark as 21 De fe ndant s ' Exhibit 277 a series of pages that 22 have been numbered 1101 through 1276, which were 23 produced to us in a folde r entitled "2699-1-1."
24 (Page s numbe re d.1101 through 1276, 25 produced from a folder numbe red 2699-1-1, were
1 Faust 594 2
together marked B&W Exhibit 277 for 3
identification, as of this date.)
4 (Documents hande d to the witness. )
5 MR. FISKE:
There is another numbe r that 6
appears on all o f these, 1401.
7 BY MR. FISKE:
8 Q
The question, Mr. Faust, is whether you 9
recognize this exhibit as a collection of documents 10 you produced to your counsel for production to us.
11 A
Yes, I believe it is.
~
12 Q
Eas this material in a separate loose-leaf s
\\
13 notebook?
14 MR. MacDON ALD:
You are talking about 15 from this material (indicating) ?
16 MR. FISKE:
Yes, from the material that has 17 been previously numbe re d 2 76.
18 A
I have -- what I did was put them in large 19 black books -- loose-leaf notebooks, a lot of the 20 material I had just for storage.
It may have been in 21 with something else.
9-(
I 22 Q
What I am trying to find out, the documents 23 that we already markd as Exh'ibit 276, which you said l
(~N 24 came from a loose-lea f notebook, was Exhibit 276 the
%-]
25 entire contents of one loose-leaf notebook?
Faust 595 g
(D
\\-)
2 MR. MacDONALD:
This is 276 (indicating).
Is that what you want to knows 3
4 MR. FISKE:
Yes.
5 A
It looks thick enough that I wouldn' t have put 6
anything else in.
7 MR. MacDONALD:
He asked you what you 8
recall.
9 MR. FISKE:
We will take that answer.
10 Q
Is the material that I have just shown you 11 marke d as Exhibit 2 77, is that the entire contents of 12 a separate notebook?
13 A
I don' t really know.
It looks like a complete 14 section.
15 Q
Directing your attention, Mr. Faust, to the 16 page that has been numbered 1182, do you see that page?
17 A
Yes, I see that page.
18 Q
Can you tell us where you obtained the 19 material that begins on Page No. 218 and continues on 20 in the collection of pages that have just been marked?
21 A
I might have received them --
qg 22 MR. MacDONALD:
If you recall, Mr. Faust.
23 will you please repeat the question?
(~N 24 (Question read.)
25 Q
218 is number 1162.
i
1 Faust 596
( --')
2 MR. MacDONALD:
You are talking about 3
what physical location?
Just to the question 4
where?
lh 5
MR. FISKEt Le t ' s clarify that, Mr.
6 Faust.
7 Q
The first question I am asking is, when 8
you first received that collection of page s, who did 9
you get it from?
10 A
I believe I --
1}
- MR. MacDONALD:
If you recall, Mr. Faust.
12 A
(Con tinuing)
I don' t remembe r where I got it (3
(_)
13 from.
I me an -- it's two place s.
14 Q
Pardon me?
15 A
There are two places I would have gotten it 16 from.
I don' t know if that answers your question.
17 Q
What are the two pla ce s ?
18 A
It was either at the simulator or at He t Ed.
19 Q
You mean either down at Babcock & Wilcox 20 or at Met Ed?
21 A
Yes.
22 Q
Did you understand that the material that 23 begins at Page 2-18 had been prepared by Babcock &
24 WilCOX?
25 A
That's what it's got on the page.
1 Faust 597 C)h
(_
2 Q
The re are a series of pages, are there not, 3
going tl. rough to Page numbe re d 1271 that all contain 4
the name Babcock & Wilcox on them on the lowe r corner h
5 of the page.
6 MR. MacDONALD:
Do you want him to look 7
at all the pages for that?
That is basically 8
what you are asking.
9 A
1270, was it?
10 Q
Yes.
11 MR. MacDONALD:
He wants to know if all 12 these pages contain B&W.
()
13 A
Do'.you want me to go through and look at each of 14 them?
15 Q
Well, did you, Mr. Faust, re ceive a booklet 16 from either Met Ed or B&W which you understood had 17 been prepared by B&W which contained a collection 18 of separate chapters?
19 MR. MacDONALD:
Specifically you are not 20 referring to this one, you are talking about 21 any book that he recalls.
G 22 MR. FISKE:
Let's go back to the first 23 question.
,f g 24 Q
As you look at this mate rial now, Mr.
U 25 Faust, do you recognize that as material that you
i 1
Faust 598 C)
V 2
received either f rom Met Ed or from B&W which you l
3 understand had been prepared by B &W?
4 A
I received the booklet as you said.
That's the 5
h a s.t I can recall on it.
6 Q
Can you tell us now whether you received 7
that at Metropolitan Edison or whether you received it 8
at Lynchhurg?
9 A
I don' t remembe r.
I received material at 10 Lynchburg and Metropolitan Edison after the accident, 11 and I received a f air amount of it.
I j us t -- I still 12 di.dn' t bothe r to k.eep t rack of where I received the O
13 stuff from.
14 Q
Isn't it a fact that you received this 15 mate rial be fore the accide nt, the material containing 16 Page 2-3-87 17 A
I don't remember when I received it.
18 Q
Let's do this, Mr. Fa us t, and maybe we can 19 expedite this.
20 MR. FISKE:
Let's mark as Exhibit 278 a g
21 document called "B&W Videotape Training Manual,"
22 which is copyrighted 1977.
It's in a hard 23 cover consisting of a number of separate sections
/')s
(
24 in a loose-leaf binder.
And I will ask you 25 whether it is not a fact that the page that we
1 Faust 599 l\\/
2 have j ust been referring to in Exhibit 277 are 3
Jerox copies of pages from that book.
4 Cpocument handed to the witness.)
I 5
MR. MacDONALD:
Exactly the same.
6 Do you want him to go through them and look 7
at them?
8 MR. SELTZER:
Off the record.
9 Cpiscussion off the record.)
10 A
It looks like it's the same material, I guess.
11 Q
Looking at Exhibit 278, that will be 12 marked in its original form, that is the, loose-leaf 13
' notebook that says "B&W Vide otape Training Manual,".
14 do you recognize that as mate rial that you receited 15 prior to the acci de nt?
16 MR. MacDONALD:
You are talking about 17 the book itself in the form that it is here?
18 MR. FISKE:
Yes.
19 A
I received books, blue and beige with Babcock 4
l 20 s wilcox on them, yes; and I trained from manuals that 21 we re in that general layout.
22 Q
My question is:
Isn' t it a fact that you 23 received that book before the accident in 19797
(~'N 24 MR. MacDONALD:
Are you asking whether
(_)
25 he recalls receiving this in the form and
1 Faust 600 2
information contained therein prior to the 3
accident?
4 MR. FISKE:
That's right.
5 A
If I reme mb e r, I was just -- I don't recall the 6
actual -- I receive d training from B&W on the items 7
that are liste d in here, if you want to look at it 8
that way.
9 As far as me recognizing the exact formats 10 of the training material, I don' t think I can do that.
11 Q
Well, is it your testimony that you 12 received training f rom B &W on the mate rial that is
(
13 contained in Exhibit 277 before the accident?
14 MR. MacDONALD:
E ach and e ve ry p art of it?
15 I don't think that is what he te stified to.
16 A
I can't recall the format.
You are asking me 17 to re co gnize the mate rial, the layout of it on these 18 m an uals.
I just -- I already got it wrong the first 19 time there.
At first I thought it was after the 20 accident.
It is starting to look like it was before 21 the accident.
22 Q
Referring to the mate rial we have j ust j
23 been t~alking about, right?
~
24 A
Right.
(N w) 25 Q
Is it your be st re collection as you sit
1 Faust 601 G
2 here now that you received the material which is 3
in Exhibit 278, copyright 1977, before the accident?
Just because it was 5
copyrighted before the accident doesn't mean 6
he received it before the accident.
7 MR. FISKE:
I think it is ce rtainly a 8
relevant consideration.
9 MR.*MacDONALD:
I don't think it has any i
10 bearing on it at all, but I think he has already 11 given you his te stimony he doesn't recall.
12 MR. FISKE:
I am entitled to an answer t
i 13 to the question.
14 MR. MacDONALD:
He gave it to you once.
15 He can give it to you again.
16 A
I am not sure.
I know I received information l
17 like this.
You are asking me this program right here.
18 MR. MacDONALD:
Answe r his que stion.
19 A
(continuing)
I am not sure when I re ceive d it,
i 20 that's all.
21 Q
Do you have any basis as you sit here now ggg 22 for telling us that you received that material that 23 we have just been talking about afte r the accident?
(~)
24 A
I just don't raccl..
At first looking through
~-
\\
25 it I thought it was afte r the ac ci de nt, because the
1 Faust 602 t%
\\_
2 material I kept at the house, I thought I had all l
I 3
pro-or after-the-accide nt mate rial, be cause I was 1
4 turning the re st of it in.
I though t I did.
5 Apparently I didn' t on this one.
6 Q
Do I understand from your testimony, 7
the n, that as you read through this material it 8
looks to you like information that you had be fore the 9
accident?
10 MR. MacDON ALD:
Objection.
I think he 11 just told you he didn't recall what he had.
12 A
The best I can answer it; I answered it the best
(~N
(-)
13 I can remembe r on it.
14 Q
Ehich is what?
15 A
I am not sure when I received the training on 16 it here.
17 MR. MacDONALD:
That is the third time he 18 has given you.that answe r.
19 (B&W Videotape Training Manual was marked 20 B&W Exhibit 278 for identification, as of this ggg 21 date.1 22 (Re ce ss taken.)
23 MR. MacDONALD:
Before we begin, I think he O
24 has something he wants to clarify.
J 25 THE WITNESS:
The only thing I wanted to
1 Faust 603 sq 2
say is, I am having a hard time with locating 3
when I received it or not.
4 Q
Locating when you received it?
5 A
or the time period that I had gotten it, either 6
p re or post the accident.
I just don' t really recall, 7
honestly recall when I received a lot of material.
8 Q
And by that you are refe rring to Exhibit 9
2787 10 A
277, 278, I guess it is.
11 Q
CIn dic atin g. )
12 A
That's all.
O k-13 MR. MacDONALD:
2 76.
14 MR. FISKE:
Why don' t we let the witness 15 answe r?
16 A
(Continuing) 276 and 277.
The manual that you 17 refe rred to there.
Just putting it on when I received 18 it --
1 19 Q
Let's just get this straight.
20 We earlier this morning were asking you 21 about two di ffe re nt manuals.
g 22 A
Right.
23 Q
one was marked Exhibit 276 and portions n
I 24 of the other were marked 277.
I think you testified
\\/
25 earlier this morning that you received the material
1 Faust 604
<s
(
)
'~'
2 in Exhibit 276 before the ac ci de nt.
3 Are you changing that testimony?
4 A
Well, what I am saying is, I don't remembe r when fg 5
I re ceive d this stuf f.
That's all I am saying.
I am 6
not sure.
7 Q
So you are changing the testimony that you 8
ga ve earlie r this morning that you received the mate ri al 9
in Exhibit 276 before the accident?
10 MR. MacDON ALD:
He is clarifying it.
11 A
I don't remembe r for sure whe n I received it.
12 That is the same thing?
C'T 13 Q
Do you have any basis as you sit here now 14 for telling us that you received the material in 276 15 after the accident?
That is the 1969 publication.
16 Do you have any basis for saying now that 17 you received that a f,te r the accide nt?
18 A
My basis is, I re ceived so much training mate rial 19 I am not sure when I received it.
That's been 20 about -- I am as honest as I can be with it.
q 21 Q
So that is the only basis for changing 22 the testimony that you gave earlier?
23 A
That is what I am looking at.
(
24 9
Mr. Faust, going back to the day of the 25 accident, March 28th, 1979, talking about the period
1 Faust 605 2
of time between the time that the transient began and 3
the ilme that the second set of reactor coolant pumps 4
were turned off, that is the time period that I am 5
going to be asking you about.
6 Do you understand that?
Do you have that 7
time period in mind?
8 A
O.
K.
9 Q
It is a fact, is it not, that sometime 10 during that time period, approximately an hour and 40 11 minutes, sometime during that hour and 40 minutes
~
12 you learned that there had been a sharp drop in the e
\\-
13 pressure in your primary system; is that correct?
14 MR. MacDONALD:
Will you state what you 15 mean by " sharp drop"?
16 MR. FISKE:
Didn't we define 17 MR. MacDONALD:
I don't think it is 18 necessarily so.
It may mean one thing to you 19 and another thing to the witness.
20 Q
Can you answer the question, Mr. Faust?
21 A
I was aware that pressure was low.
22 Q
Right.
And you learned during that period l
23 of time that the pressure had gone down below the
[)
24 point at which high pressure injection was l
%)
25 automatically actuated; isn't that correct?
1 Faust 606 iV 2
A I was aware that we had high pressure injected --
3 Q
O.
K.
sometime in that -- sometime in that interval.
4 A
5 Q
And you knew from that fact that the 6
pressure had gone down to the level at which HPI came 7
ons isn't that correct?
8 MR. MacDONALD:
Are you asking whether g
he knew it automatically came on or manually?
10 MR. FISKE:
The question was " automatic."
11 MR. MacDONALD:
I don't think it was.
Now 12 it is.
(h L,/
13 A
What I recognized was that we had -- we had had 14 an initiation of high pressure injection.
15 Q
Well, isn't it a fact that sometime during 16 that period of an hour and 40 minutes you had learned 17 that pressure had gone down below 1640 pounds per 18 square inch?
19 A
The way I remember it, we had actuated high 20 pressure injection.
21 Q
Right.
22 A
We had gotten to 1640.
I just know that's the 23 set point.
l (J
)
24 Q
O.
K.
And I take it, you also knew by l
l the time that the second reactor coolant pumps were 25
1 Faust 607 2
turned off that at some point after HPI had been 1
3 initiated, it had been turned off?
4 MR. MacDONALD:
Completely?
9 5
MR. FISKE:
Throttled back.
6 A
You are asking my factorial recollection of it?
7 MR. MacDONALD:
That's right.
8 Q
Yes.
By the time the second set of pumps 9
were turned off, which was approximately 100. minutes 10 after the accident started, you knew that HPI had 11 come on and had been throttled back?
12 A
I knew it came on and I assumed it was throttled OL) 13 back.
14 Q
O.
K.
15 You knew, did you not, Mr. Faust, on the 16 day of the accident that the actuation of HPI was 17 itself a symptom of a loss of coolant accident?
18 A
Leaving out everything else?
19 Q
Well, yes.
You knew that actuation of HPI l
20 was a symptom of a LOCA?
gg 21 A
I knew a couple of things.
I knew it was a 22 symptom of an over cooling reaction, too, action --
u Q
O.
K.
1 24 A
-- and we were having those.
()
25 Q
You knew that the actuation of HPI could
1 Faust 608 2
either be because of a LOCA or because of an over 3
cooling; 16a't that correct?
4 MR. MacDONALD:
Only those two things?
5 MR. FISKE:
That is my question.
6 A
A major break.
7 Q
Yes, which would be a loss of coolant 8
accident, would it not?
9 A
In a major break.
10 Q
O.
K.
Am I correct, then, that you knew on 11 the day of the accident that initiation of HPI itself 12 was a symptom of a loss of coolant accident?
13 MR. M'acDONALD:
Just as a point of 14 clarification, are you asking him whether he 15 discussed this with anybody?
16 MR. FISKE:
Off the record.
17 (Discussion off the record.)
i 18 MR. MacDONALD:
Will you please repeat 19 the question.
20 MR. FISKE:
I will withdraw the last 21 question.
gg 22 BY MR. FISKE:
23 Q
On the day of the accident, what did you
()
24 understand could happen if there in fact was a loss of 25 coolant accident?
I 1
Faust 609
\\
\\J 2
A Just generally.
3 MR. MacDONALD:
Are you asking whether he 4
spoke to somebody or he had training on this 5
before the day of the accident?
6 MR. FISKE:
Please, Mr. MacDonald, the 7
question is very simple.
8 Q
What did you understand on the day of the 9
accident could happen to the plant if there was a 10 loss of coolant accident?
11 MR. MacDONALD:
Objection.
I think there 12 is a difference between what he may have been 13 doing on the day of the accident and what his 14 understanding was.
That is what I am trying to 15 clarify.
16 MR. FISKE:
The question was, what was 17 his understanding.
18 MR. MacDONALD:
During the time that 19 the accident was taking place?
20 MR. FISKE:
On the day of the accident, 21 Mr. MacDonald.
22 Q
At four a.m.
on March 29th, as of that 23 period of time, did you have any understanding in your
)
24 mind as to what possible consequences could result to J
25 the plant and to the safety of the public if there was
1 Faust 610
(~h
(_)
2 a loss of coolant accident?
A How far are you carrying this out?
I didn't 3
4 think anything would happen to the public.
tg 5
Q I just wanted to know what was in your mind.
6 MR. MacDONALD:
At the precise time of four 7
o' clock in the morning?
8 MR. FISKE:
Please, Mr. MacDonald.
9 MR. MacDONALD:
You just said that.
That 10 is what you are talking about?
11 Q
On the day of the accident, as the accident 12 began, what understanding did you have as,to what f^\\-
(_)
13 consequences could happen to the plant and to the 14 safety of the public if there was a loss of coolant 15 accident?
16 MR. MacDONALD:
I object.
It is 17 ambiguous.
18 MR. FISKE:
No matter how many times 19 Mr. MacDonald is going to divert that question, 20 it will be asked and answered.
tj h 21 MR. MacDONALD:
I am just saying it is 22 ambiguous.
23 MR. FISKE:
It couldn't be much more g-24 straightforward.
LJ 25 MR. MacDONALD:
Because you are trying to
1 Faust 611 1
(m
\\m 2
imply he may have thought about certain things 3
on the day of the accident which he may not have 4
thought about or did not discuss with anybody.
5 MR. FISKE:
You are making a speech and 6
trying to tell him what to say.
It is getting 7
ridiculous, it's been going on for five days.
8 MR. MacDONALD:
I will make my objection.
9 MR. FISKE:
We are just about to stop 10 this deposition right now and take the 11 transcript of those prior depositions be' fore a 12 magistrate and we are going to get some rulings
()
13,
on this kind of conduct.
14 MR. MacDONALD:
Go right ahead.
15 MR. FISKE:
Let's break.
16 MR. MacDONALD:
Go ahead.
17 MR. FISKE:
Let's go.
18 MR. MacDONALD:
My objection stands.
19 MR. FISKE:
We are breaking until this 20 is resolved.
(gg 21 Why don't we just adjourn.
22 MR. SELTZER:
We would like to have time 23 to toll the references from depositions that i
(V~}
24 you were defending, Mr. Fiske, and your partner 25 Mr. Wise was defending, that your associate Rod
1 Faust 612
/~N 2
Benedict was defending, where objections of 3
this very nature were interposed and it was 4
very stoutly defended by you in eloquent terms 5
as being a proper way to defend a deposition.
6 MR. FISKE:
Please, Mr. Seltzer, nothing 7
has gone on like what has gone on in this 8
deposition since the beginning.
Every time we 9
get to an area that is sensitive where Mr.
10 MacDonald senses that Mr. Faust is getting 11 himself in trouble, getting into a dangerous 12 area that may jeopardize your case, we get a
('))
(_
13 string of " objections" which are designed to 14 do nothing but either educate Mr. Faust to what 15 Mr. MacDonald thinks he ought to answer or 16 else just to block the inquiry completely.
All 17 you have to do is go back and read the 18 transcript of the last four days where time and 19 time again Mr. MacDonald would object on the 20 grounds that a question had been asked and 21 answered and you can go back and read the l
22 question and you will see it was never answered 23 even though I put it four times and Mr. MacDonald 1
24 said repeatedly he answered it.
You can go back 25 and look in the record and you will see it was
1-Faust 613 2
never answered.
3 MR. MacDONALD:
You can go back and sue 4
the witness answered the same thing four or 5
five times.
He thought he answered the 6
questions.
7 MR. FIS KE :
There has been a repeated 8
pattern.
9 MR. MacDONALD:
We are trying to. clarify 10 the time period we are talking about.
11 MR. FISKE:
It could not have been much 12 clearer.
I am asking Mr. Faust as of the day 13 of the accident did he have any understanding 14 in his mind'as to what the consequences to the 15 Plant could be and to the safety of the public 16 could be if there was a loss of coolant 17 accident.
18 MR. MacDONALD:
My objection stands.
19 MR. FISKE:
All right, can he 20 answer?
21 MR. MacDONALD:
I never directed him not (gg 22 to answer.
23 BY MR. FISKE:
()
24 Q
Can you please answer for us.
25 A
I would break it up a little bit.
I would break
1 s
\\
s, 1
T
Faust 614 l
~
\\_/
2 it into -- what.- about -
,I would think of it 3
where youLare talking loss of coolant, I am thinking 4
of a leak wit'hin the size of the capacity of the 5
makeup pump.
From that paint of view, I would not 6
think anything would happen because we would be 4
7 keeping up with it.
\\
8 Q
If HPI was on, right?
N 9
A Yes.
We would be able to keep up with it.
l-l l
10 Q
"O, K.
11 And suppose there was a leak --
12 A
Do you want me to finisht 13 Q
Fine, f'inish.
I 14 A
My other answer would be, on a major break where 15 the makeup pumps could not keep up with it, we would 16 depressurize and still inject water \\into the system 17 until we get 'on low pressure injection.
18 I never thought about a danger being to the 19 public because of a large or small break.
Now, that is 20 loss of coolant accident.
4 21 So far as the third one that was in our system 22 at the time, was the combination of, with a loss of 23 a vital bus' or. a makeup pump, and that was just another
\\
('N 24 response, but I never thought it would lead to core L-]
s 25 damage, if that's what you mean to mean it would be 4
l k
4 g
s.
1 Faust 615 l
2 endangering the public.
3 Q
Did you understand that core damage could 4
cause injury to the public?
5 A
I understand we had several barriers to prevent 6
core damage or preventing possible core damage from 7
reaching -- preventing release of the radioactive 8
material from reaching the public.
9 Q
But you understood if core damage 10 occurred, it would increase the possibility of 11 damage to the public; isn't that correct?
12 A
I guess I never dwelled on it, is what I am
(~%
\\-
13' saying.
I understood that the way I theorized, we 14 would never get to that point.
15 Q
Nobody ever told you at any time up to the 16 day of the' accident that if there was core damage that 17 that could lead to the release of radiation into the 18 atmosphere?
19 A
I'm not saying that.
20 MR. MacDONALD:
Assuming that's damage 21 to the public, any release of radiation.
g 22 MR. FISKE:
Please.
23 MR. MacDONALD:
No, please, not please.
24 A*
My understanding loss of coolant accident 25 leading to hazard to the public.
I didn't think a
1 Faust 616
\\
2 loss of coolant accident would lead to a hazard to 3
the public because I thought we were covered by it.
4 Q
Let us take the question of core damage.
5 Did you understand on the day of the 6
accident if there was core damage that could cause 7
the release of radioactivity into the atmosphere?
1 I knew that.
8 A
Yes, I was 9
Q And did you understand that if a loss of
]
l 10 coolant accident were not properly diagnosed and 11 corrected that could lead to core damage?
12 A
I never thought we wouldn't diagnose it properly.
(-)
s) 13 g
why did you understand it was important to 14 diagnose it correctly?
15 A
A loss of coolant accident?
16 Q
Yes.
17 A
so you are in you procedure.
18 Q
What did you understand was the reason for 19 a procedure that re' quired you to diagnose a loss of 20 coolant accident correctly?
21 A
To pick out the right procedure and follow it.
ggg 22 Q
No, what did you understand was the 23 reason for diagnosing a loss of coolant accident O
24 correctly?
V 25 A
In other words, if I walked out of the place and
l l
l 1
Faust 617
[/
\\
2 just left it run by itself, you mean?
Because I 3
didn't think along those terms.
That's what I think 4
you are getting at.
5 Q
why did you understand it was important 6
to be able to diagnose a loss of coolant accident 7
and correct it?
8 A
So I knew where to go.
9 Q
What did you understand would happen if 10 you did not diagnose it correctly and correct it?
11 A
I guess I never thought I would not diagnose 12 it correctly.
13 Q
Are you telling me, Mr. Faust, that at no 14 time before four o' clock on the morning of March 29th 15 did anybody ever tell you what could happen if a 16 loss of coolant accident occurred and was not properly 17 diagnosed and corrected?
18 A
That's not what I said.
19 Q
That is my question.
20 A
I was under the impression that if you had core gg 21 damage, we didn't discuss how we could get to the 22 core damage, necessarily.
23 Q
Didn't you know on the day of the accident (T
24 that if a loss of coolant accident occurred which
\\_)
25 was not diagnosed and corrected that could lead to
1 Faust 618 (a~1 2
core damage?
3 A
Do I know what I knew?
4 Q
Answer that question.
5 A
I knew that our procedures were designed to 6
prevent core damage and we never stretched it out 7
to where we would say "We are going to turn it 8
off and keep going just to see what happe'ns."
That's 9
what I knew.
10 Q
I understand, Mr. Faust, that you had 11 procedures that were designed to enable you to 12 correctly diagnose a loss of coolant accident t'
\\'
13 correctly.
All I am asking you is, didn't.you know 14 or didn't you believe, didn't you understand at the 15 time on March 28, 1979 that if a loss of coolant 16 accident occurred that was not properly diagnosed and 17 corrected that could lead to core damage?
18 MR. MacDONALD:
He just gave you the 19 answer.
20 A
I did.
The answer I am going to give I gave 21 because I think I have answered your question the way g
22 I understood it.
23 Q
Your answer was you had procedures h) 24 designed to allow you to correct it.
I am asking s_/
25 you did the thought ever occur to you at any time
l l
1 Faust 619 0
L-2 before four o' clock on March 28, 1979 what could happen if the procedures were not followed and you did not
.4 4
correctly diagnose and correct the loss of coolant 9
5 accident?
6 A
state it again.
7 MR. FISKE:
I will withdraw the question 8
and ask another one.
9 A
The first one was pretty simple; I thought I 10 answered it.
11 Q
I would like a yes or no answer.
12 A
You can't get a yes or no answer to a question g-
\\J 13 like that.
14 Q
Mr. Faust, you haven't even heard the 15 question yet.
16 A
The one you just stated.
17 Q
I am about to give the question, and I 18 know you have been prompted to say you can't answer 19 it yes or no, but at least wait until you hear the 20 question before you tell me that.
llh 21 A
That's my own.
22 Q
The question, Mr. Faust, is, yes or no, 23 on the day of the accident did you understand that if O
\\,_/
24 a loss of coolant accident occurred that was not 25 properly diagnosed and corrected, that that could lead
1 Faust 620 rg
_Y 2
to core damage?
3 MR. MacDONALD:
I object to that.
4 A
My answer is I didn't train that way.
I don't 5
remember being trained to say if we did not diagnose 6
a loss of coolant accident right that it would go 7
on and lead to core damage.
We trained in procedures 8
that we would follow for a loss of coolant accident.
9 Q
Are you suggesting, Mr. Faust, that nobody 10 at Met ever, ever once told you in any part of your
-11 training that there was a risk that if a loss of 12 coolant accident occurred that was not properly 13' diagnosed and corrected that that could lead to core 14 damage?
15 A
I don't think anybody at B&W said it that way 16 either.
17 Q
What is the answer to my last question?
18 A
The same one I have been giving.
19 Q
Nobody at Met Ed ever told you that?
20 A
I am saying it wasn't put the way you are saying 21 it.
22 Q
I am asking you whether anybody at Met 23 Ed -- withdrawn.
()
24 I am asking you whether it is your testimony 25 that at no time in your training at Met Ed did anybody
1 Faust 621
(~s
(_)
2 ever tell you that if there was a loss of coolant 3
accident that was not correctly diagnosed and
)
1 4
corrected that that could lead to core damage?
S A
I don't recall that question being stated that 6
way.
That's all.
That's what I have been trying 7
to tell you.
Not that we couldn't have core damage.
8 Q
So, do I understand your testimony that on 9
the day of the accident there was no connection in 10 your mind between a loss of coolant accident that 11 went unc'orrected and possible core damage?
12
.A I didn't recognize in the early part of the
[\\
13 accident that we had a loss of coolant accident.
%)
14 Q
That is not my question, Mr. Faust.
15 MR. FISKE:
Read the question back, 16 please, Mr. Reporter.
17 (The reporter read back the last 18 question.)
19 Q
I think it is pretty simple.
20 MR. MacDONALD:
My objection still stands.
ggg 21 I think you are talking about what I stated 22 before, what his thought process was on the day 23 of the accident.
I think it'is ambiguous.
r-24 MR. FIS KE :
Let's get a couple of things a
25 straight.
Are you seriously suggesting that I
1 Faust 622
/
~
.2 Mr. Faust's thought process during the time 1
3 that this accident was going on is not a proper 4
subject of questioning?
5 MR. MacDONALD:
That is not my objection.
6 My objection is I think you are trying to 7
imply by your question that he thought of these 8
things on the day of the accident.
I think 9
what your question is aimed at is whether prior 10 to the time that this accident began at four 11 o' clock, did he have an understanding of that.
12 MR. FISKE:
Let's Qo
\\_/
13 MR. MacDONALD:
I don't want that confused 14 with what he did on the day of the accident.
15 That is the basis of my objection and has been 16 the basis of my objection before.
I think it is I
17 ambiguous to the itness.
18 MR. SELTZER:
It is a good objection.
19 I sustain the objection.
l l
20 MR. FISKE:
Could you read the question 21 back, please, Charlie.
g 22 (The reporter read back the pending 23 question.)
f~d')
24 MR. SELTZER:
I think you have either of s
25 two good questions there.
You can ask him did
J 1
Faust 623
/7
, U 2
he think about this on the day of the accident 3
or did his training prior to the day of the 4
accident include this subject.
O 5
MR. FISKE:
I appreciate the offer of 6
assistance and at some point we may ask either 7
one of those questions.
For the time being, I 8
would like an answer to the one I just asked.
9 MR. MacDONALD:
The objection stands.
10 A
I don't recall thinking about the kind of 11 question you just posed in that sense.
I should have 12 had you there.
13 I t,hink what your --
14 MR. SELTZER:
Don't 15 MR. MacDONALD:
Just answer the question.
16 A
You are phrasing this for the first two hours 17 now.
You are saying did I think this.
18 Q
I am just saying, I am simply asking you, 19 during that period of time on the morning of March 28, 20 1979, did you have any understanding in your mind gg 21 as to any possible relationship between a loss of 22 coolant accident that went uncorrected and possible 23.
core damage?
()
24 MR. MacDONALD:
The same objection.
25 MR. SELTZER:
Are you asking did he think
l l
1 Faust 624 1
(~h
\\-)
l 2
that on the day of the accident, Mr. Fiske?
3 Is that what the question is?
4 THE WITNESS:
It is more specifically 5
two hours.
G Q
I am asking you, Mr. Faust, simply as to 7
the state of your knowledge and understanding as of 8
the time that the accident started.
9 A
Are you just asking for my previous training 10 if I had -- that's what I am saying.
If I understand 11 where you are coming from on this or how you -- what 12 you are asking, you are asking on the day of the
(~%
\\-
13 accident if I thought if we didn't analyze the loss 14 of coolant accident, would it lead to core damage; 15 is that right?
16 Q
Yes.
17 A
I am just saying I didn't think of it that way.
18 I never thought that we wouldn't analyze a loss of 19 coolant accident that would lead to core damage.
20 Q
In all of the training that you had had ggg 21 in which you had been taught procedures which were 22 designed to diagnose a loss of coolant accident and 23 correcting it, during all of that period of time
()
24 that you were going through that training, did the 25 thought ever cross your mind once, "What happens if
1 Faust 625 (V~)
2 we don't correct a loss of coolant accident"?
3 A
I never thought about the pressurizer level 4
with pressure decreasing --
4 5
Q Please, Mr. Faust, can you answer that 6
question.
7 A
I am.
I am saying there are things that happen 8
we didn't go over in training and you are asking if we 9
thought about that the same way.
10 MR. FISKE:
I move to strike that answer 11 as totally unresponsive and I would like to 12 have the question read back, and please, 13 Mr.' Faust, listen to the question and then 14 answer it, O.
K.?
15 A
I just answered it.
16 Q
No, you did not.
17 MR. FISKE:
Please read it again, Mr.
18 Reporter.
19 (The reporter read back the question 20 as requested.)
21 MR. MacDONALD:
I will object for the lll 22 reason he has just given the answer, and 23 furthermore
()
24 MR. FISKE:
What is your next one?
25 MR. MacDONALD:
That's just the first one.
i i
1 Faust 626 rw I
)
%d 2
MR. FISKE:
What is it?
3 MR. MacDONALD:
It is that in prior 4
testimony that you have defended deposition 5
testimony, you have instructed your witnesses 6
not to answer what their thought processes were 7
if they never spoke or communicated it or did 8
something to tell or inform someone else.
You 9
are not asking here what he was taught by 10 someone, you are asking him if the thought ever 11 crossed his mind, and you have instructed your 12 witnesses not to answer on that.
I don't think
(~
\\_)/
13 that was proper.
14 MR. FIS KE :
No.
1, that instruction when 15 it was given was limited to post-accident 16 situations; secondly, that is not what I am 17 asking Mr. Faust.
18 MR. MacDONALD:
It's not?
19 MR. SELTZER:
Withdraw the question and 20 reframe it, if that is not what you are asking.
ll) 21 MR. FISKE:
Look, this is really getting 22 ridiculous.
I am trying to find out what i
23 Mr. Faust's thought processes were as this I
(^N
(,)
24 accident developed.
i 25 MR. MacDONALD:
That's fine.
l
1 Faust 627
(
1
\\#
2 MR. FISKE:
And how he reacted to it and 3
what he did, and if you are seriously suggesting 4
that I can't examine on these questions, there is 5
really no point in going further.
We may as well 6
stop and go get a ruling on it.
7 MR. MacDONALD:
That is not what I am 8
suggesting.
You have instructed your witnesses g
when we have asked questions regarding pre-10 accident thoughts that they should not answer.
11 MR. FISKE:
Either Mr. Faust will answer 12 the question I just asked him or we will go get 13 a ruling.
14 MR. MacDONALD:
If you give us time to 15 go back and' pull out exactly what you instructed 16 your witnesses to do back then --
17 MR. FISKE:
If you persist in preventing 18 your witness from answering this question, we 19 will get a magistrate and you can get whatever 20 you want.
I will not go further with this 21 deposition if we can't ask questions like this, gg 22 Particularly in light of the series of answers 23 that we have just been getting.
()
24 MR. MacDONALD:
I am not objecting to the
\\..)
25 day of the accident questions.
l
1 Faust 628
-)
' X.J 2
MR. FISKE:
Either he answers it or we go 3
get a ruling.
Which is it?
4 MR. MacDONALD:
Let me check the 9
5 deposition testimony in which I think you gave 6
your instruction.
7 MR. FISKE:
What do we do with the pending 8
question?
9 MR. MacDONALD:
Until I look at that, I 10 will instruct him not to answer.
11 MR. FISKE:
Then we might as well break.
12 MR. MacDONALD:
I will take a look at it O
13 and take it bnder adyisement.
14 MR. FISKE:
I will not go further with this.
15 I have a whole lot of questions about what 16 happened on the morning of the accident.
17 MR. MacDONALD:
You can ask whatever 18 questions you want about the day of the accident.
19 That question had nothing to do with the day of 20 the accident.
lll 21 MR. FISKE:
It is developing what his 22 understanding was on the day of the accident 23 based on the training that he received at Met (3
(,)
24 Ed.
If I can't --
25 MR. MacDONALD:
You are not asking what
1 Faust 629
[\\
'/
\\
2 training he received on the subject.
1 3
MR. FISKE:
That is precisely my last 4
question.
5 Please read it back, Charlie, if you 6
can find it.
7 MR. SELTZER:
Off the record.
8 (Discussion off the record.)
9 (At this time, 12:15 p.m.,
a luncheon 10 recess was taken.)
11
~
12 13 14 15 16 17 18 19 20 (IP 2'
22 23
([';
24 25
1 630 m
2 AFTERNOON SESSION 3
1:58 p.m.
f 4
CRAI G C.
FAUS T,
resumed.
5 EXAMINATION (continued) 6 BY MR. FISKE:
7 Q
Good afternoon.
8 A
Good afternoon.
9 MR. MacDONALD:
Will you please repeat that 10 question, Mr. Reporter.
11 (The reporter read back the question as 12 follows:
"In all of the training that you had r~~)
(
N/
13 had in which you had been taught procedures 1
14 which were designed to diagnose a loss of I
15 coolant accident and correct it, during all of 16 that period of time that you were going through 17 that training, did the thought ever cross your 18 mind once, 'What happens if we don't correct a 19 loss of coolant accident'?")
20 MR. MacDONALD:
I am going to object to 21 that question.
I will let the witness answer, q
22 basically, although in prior deposit. ns 23 Mr. Fiske has defended, there have been
()
24 instructions not to answer, base'd on thought 25 processes, not limited to pre-or post-accident,
1 Faust 631 ID V
2 just on the basis of thought processes, no differentiation made whether it was pre-or 3
4 post-accident, in Mr. Womack's deposition.
th 5
In the interest of moving the examination 6
along and getting this thing finished, we are 7
just going to object and preserve the 8
objection.
9 MR. FISKE:
Will you please repeat the 10 question again for Mr. Faust.
11 (The reporter again read back the 12 question, as requested.)
13 THE WITNESS:
Can I hear the answer?
14 (The reporter read back the answer 15 as requested.)
16 THE WITNESS:
I would like to hear my 17 answer.
18 (The reporter again read back the answer.)
19 MR. FISKE:
Do you want to hear the 20 pending question?
21 MR. MacDONALD:
Would you read it.
]h 22 MR. FISKE:
Maybe you should listen to 23 it again so that there isn't any interruption yj 24 in between.
25 (The reporter read back the question as
1 Paust 632 O
%)
2 follows:
"In all of the training that you 3
had had in which you had been taught procedures 4
which were designed to diagnose a loss of 5
coolant accident and correct it, during all of 6
that period of time that you were going through 7
that training, did the thought ever cross your 8
mind once, 'What happens if we don't correct a 9
loss of coolant accident'?")
10 THE WITNESS:
Will you please repeat the 11 preceding answer and question.
12 (The reporter read from the record 13 as requested.)
14 A
I don't think the thought crossed my mind when 15 we were going through training for a loss of coolant 16 accident that if we didn't find it, in other words, 17 if we didn't find it.
When we were trai'ning on a 18 loss of coolant accident, it was always the specific 19 set of things.
I don't think we talked about whether 20 we didn't find it or not.
(gg 21 Q
Did anybody tell you in the course of your 22 training, Mr. Faust, why it was important to diagnose 23 and correct a loss of coolant accident?
()
24 A
I don't believe somebody told me in those terms 25 that's why it was important.
In our training, we
1 Faust 633 CT U
2 trained that -- let's see if I can ge.t this in the 3
right place--in our training we would talk about 4
core damage, all right?
When there was analysis done O
5 by engineers, it was eve'ntually related to us that, 6
you are talking about core damage in the sense that 7
they -- they ran their tests, I believe, to figure 8
out what the different levels of fuel damage that g
could occur for various accidents.
10 Q
Let me just ask the question as simply 11 as I can.
12 Did you have an understanding at any time O
13 up to the,date of the Three Mile Island accident 14 that if there was a loss of coolant accident that 15 was not diagnosed and corrected, that t l. a t could cause 16 core damage?
17 A
I guess the way I thought of it was that --
18 Q
First, Mr. Faust, can you answer that 19 question yes or no?
20 A
I am having problems with your question the 21 way it is phrased.
I am trying to remember what I ll 22 think I thought the day of the accident.
23 Q
No, any time up to the day of the accident.
h) 24 A
This would be any time up to the day of the wJ 25 accident?
1 Faust 634 O
V 2
Q During your entire career up to that 3
time, did you ever have an understanding that if there 4
was a loss of coolant accident that was undiagnosed th 5
and uncorrected, that could cause core damage?
can 6
you answer that question yes or no?
7 A
I understood that if we didn't have coolant or 8
if the we lost the capabilities of coolant in 9
the primary system, you would have core damage, yes.
10 If that's what you are asking.
11 Q
O.
K.
12 A
I had no problems with that.
O
\\/
13 (continued on page 635.)
14 15 16 17 18 19 20 4Ep 21 22 23 O) 24
'\\_
25
635 k 1 1
Faust O
2 Q
And you knew that one way you could lose the capability of coolant was through a loss of coolant 3
f 4
accident, isn't that correct?
9 A
I knew you would lose coolant in a loss of 5
6 coolant accident.
7 Q
You said earlier, Mr. Faust, you knew that 8
one of the things that could cause HPI to come on was a1 ss of coolant accident, correct?
9 A
In relation to other things, yes.
10 11 Q
And you knew that, as you testified earlier, 12 that HPI had in fact come on on the morning of March 13 28th, 1979, that's correct also?
- A I think I also said why I thought it came on at 14 that time.
15 16 Q
That was going"to be my next question.
What did you do on the morning of March 28th 17 18 to determine that the cause of HPI coming on was not a loss of coolant accident?
19 A
I associated the -- you are talking about when I 20 first came across the panel, all right, and I was trying h
21 22 to put a makeup pump on and I proceeded to go over to the feedwater system?
During that time period when I 23 g t over to the feedwater system, I guess it was when 24 25 I was g ing past that, I was thinking that we were
2 1
Faust 636
(~(v) 2 cooling down, overcooling at that point.
I thought 3
because it wasn't abnormal, it was something that had 4
happened before when we had trips.
We initiated O
5 high pressure injection.
6 Q
Now, in this period of time that you have 7
just described in your answer was a period of time 8
before you found out that the 12's were closed, is 9
that correct?
10 A
It would have been before the 12's, I found out 11 the 12's were closed, yes.
That's what I am saying, I 12 was I didn't stop and rationalize out and put in O\\'"/
13 tkme frames.
What I am saying, I was thinking.
That 14 was what became difficult through the day.
15 Q
But the answer that you just gave a minute 16 ago was directed at the time period before you 17 discovered that the 12's were open?
18 A
Yes.
19 Q
or closed?
20 A
You have to realize something also in that answer, gg 21 the fact that that day.I wasn't thinking clearly in 22 time frames that we are putting it now that it looks 23 so clear on things.
p()
24 Q
I am just trying to get as simple an 25 answer as I can to simple questions.
ik 1 1
Faust 637
.O V
2 A
They are not simple.
3 g
You knew HPI had come on and you said 4
that you knew that one cause of HPI coming on was O
5 a loss of coolant accident.
I asked you what can 6
you do to determine that the cause of HPI coming on 7
was not a loss of coolant accident and you gave me 8
the answer that you concluded that it was an 9
overcooling.
10 MacDONALD:
Are you asking him about 11 questions now, ones that he already testified 12 to a few minutes ago?
You do not have to g-(.J 13 build on it.
He represents what his answers 14 were.
He has given you three answers to those 15 three questions before.
Now you are phrasing 16 them in your own terminology.
Objection.
17 g
You testified a moment ago about what 18 you were doing when you were in front of the panels, 1
19 right?
20 A
I am testifying, trying to answer your question lll 21 what I believe where I thought I was coming from at 22 that time, why I thought at that time that day high 23 Pressure injection initiated.
All right?
Now my O)
(_
24 problem is trying to keep it in specific points 25 through the day.What happened to me became obvious
2 i
Faust 638
(~T 2
afterwards that I was taking things inside at one i
time interval and another one and I was making 3
4 conclusions from that.
5 Q
I am not trying to get into that, Mr. Faust.
6 That is exactly what I am trying to avcid.
I am 7
trying to take this step by step.
8 A
That is what happened to me though.
9 Q
As I understand your prior answer, and 10 correct me if I am wrong, you said that as you were 11 moving from one panel to the other, you reached 12 the conclusion that HPI had come on because at that O)
~
time you thought there was an overcooling.
(_
13 14 A
That's another problem.
15 Q
Isn't that what you said?
16 A
I am trying to make I know it doesn't sound 17 good, but I am trying to make it as clear as I can 18 what I was thinking about.
When I was making that pass, 19 for some reason I thought we were overcooling.
20 Q
O.K.
All I am trying to do, Mr. Faust, is identify --
l 21 A
But there is another problem with the answer, 22 The thing I am not sure is when I connected high 23
(~)
24 Pressure injection coming on in that, connected high
%.J 25 Pressure injection coming on with cooling, overcooling.
1 Faust 639 OU That is what I am saying.
2 Q
All right.
3 At the time you made this pass, as you 4
described it, I think you testified that at that 5
6 time you thought there was an overcooling?
That 7
was your state of mind at that time?
8 MR. MacDONALD:
I don't think hc just said that but --
9 10 A
I am trying to answer your question.
Q I know.
31 _
12 A-When high pressure injection comes on,and I think this is the best way I can answer it, when I realized 13 14 high pressure injection came on I associated it with the 15 vercooling in the core.
16 Q
O.K.
A If you try to pin that to a specific time 37 18 that I was thinking of that through the day, that is w).at I can't recall.
19 Q
I think you testified a few minutes ago 20 and earlier in this deposition that there had been g
21 ther situations before March 28th, 1979 on which 22 y u learned that HPI had come on auto'natically,
23 i
A
- Yes, p
g v
25 Q
I think you testified that one of those
1 Faust 640 0
2 was the incident on April 23, 1978 when the steam relief valve had opened?
3 4
A Right.
5 Q
And correct ne if I am wrong.
I think 6
you testified that there were either one or two other situations in which it had come on where there was 7
8 an overfeeding of the steam generator?
A That's right.
9 10 Q
If I understand your testimony before, 11 there were two such situations, one when you were 12 at full power and one when you were not; is that 13 correct?
14 MR. MacDONALD:
You are asking him for 15 his recollection of his previous testimony, or 16 are you asking those questions to lead up to 17 something?
18 MR. FISKE:
I am basically trying to 19 make sure that we are all operating from the 20 same basic understanding.
MR. MacDONALD:
I would prefer his l
21 22 previous answers be what they are.
23 A
Yes.
I have been exposed to this steam relief r
i valve nt setting which was an overcooling accident, 24 and I had another one where feed water had been 25
5 1
Faust 641 2
in manual and wasn't run back that was an overcooling accident that initiated high pressure injection.
I 3
4 was in that.
5 Q
So I guess what I am trying to be sure 6
we understand is how many overcooling incidents 7
were you aware of where HPI had come on?
8 MR. MacDONALD:
You are talking about ones at Three Mile Island?
9 10 MR. FISKE:
Yes.
11 A
Just at Three Mile Island?
12 Q
Yes.
C,s'S l
A I d'on't know.
I am just quoting the ones I 13 e
14 remember.
'I may have been exposed to others.
15 Q
Well, to the best of your recollection 16 as you are testifying now, there was the April 23rd, 1978 transient that we went over in some detail a few 17 18 days ago?
19 A
Right.
20 Q
And then there was a transient in which there wa's overfeeding of the steam generators correct?.
21 A
Right.
22 23 Q
Was there a second transient where there fN 24 was verfeeding in the steam generator?
or put it i
%-]
25 an ther way, was there more than one transient when l
\\
(
G 1
Faust 642 O
2 there was overfeed ng in the steam generator which 3
caused HFI to ome on?
4 A
At TMI?
~
5 g
Yes.
6 A
That 's what.I don ' t r emember.
7 Q
As you sit heres now, do you remember 8
more than one transient at i-MI where HPI came on g
because of overfeeding of the steam generator?
10 A
I don't r e ue mb e r'.
11 Q
You testified earlier, Mr. Faust, and 12 I can get to the page if you would like to see it,
^N 13 that in the ipril 23, 1978 trhnsient where the 14 steam relief valves stuck open, that both pressure 15 and temperature dropped on the secondary side.
16 MR. hacDONALD:
Is that a question to 17 have him reaffirm testimony or'just
'f you i
18 are just laying a predicate and ask'the next 19 question --
20 Q
Is that correct?
21 A
That we had an overfeeding and pressure and 4
l temperature both dropped? '
22 23 g
In the April-23,. 1978 transient, pressure
(~~
24 and temperature both dropped in the steam generator?
Lj)
N, 25 A
I know pressure dropped.
I wasn't watching s
D
Faust 643 7
1 2
temperature but from -- just from reason, it would have dropped.
3 4
Q And you received a report, did you not 5
A Right.
after that transient which has already 6
Q been marked as an exhibit which described the 7
8 transient and attached photographs which showed what 9
happened to the pressure and temperature?
10 A
Yes.
11 Q
There is no question, is there, that the 12 photograph, with respect to that accident, shows 13, that there was a sharp drop in temperature from 14 the beginning of the transient on?
15 A
I believe so.
16 Q
And isn't it a fact, Mr. Faust, that 17 what caused the pressure drop on the primary side 18 in the April 23, '78 transient was a drop in temperature 19 on the secondary side?
MR. MacDONALD:
He already answered that.
20 I thought we spent two hours going over this
<g 21 le a s t,' in prior testimony.
at gy MR. FISKE:
Fine.
23 O,
MR. MacDONALD:
I hope we won't go for J
24 two more heure en that.
ag
644 1
Faust C)\\
1,'~
MR. FISKE:
One simple question and 2
ne simple answer and we can move on.
3 A
The temperature did drop, yes.
This was when 4
I reviewed the document.
5 6
Q Right.
And it is the drop in temperature which in turn produced the drop in pressure in the 7
8 primary side; isn't that correct?
A That is correct.
9 10 Q
And in the situation that you described earlier there was a cooldown as a result of overfeeing 33 12 in the steam generator that also involved a drop in 13 temperature in the steam gen'erator; did it not[?
A Yes, it did.
34 15 0
And again, it was that drop in temperature in the steam generator which caused the drop in pressure 16 17 on the primary side, correct?
18 A
You are correct.
gg Q
Mr. Faust, did you know on March 28th, 1979 that you did not have an overcooling transient?
20 A
Right at the beginning of the accident, in fact, 21 through the accident, what I was thinking and developing 22 pini ns through that day.
At one time I thought I had 23 O
an overcooling accident.
I thought that is what y
'V initiated high pressure injection myself because at some 25
1 Fouct 645 O
(/
2 point during the day I saw temperature dropping.
In fact, temperatwr= was dropping initially when I 3
4 made my first pass because the generator, if you lll want to go back and look at it from hindsight, right 5
6 now the generator was blowing down, boiling down.
7 Q
Isn't it a fact that before you opened the 12's, 8
temperature was much higher than you had exppeted it to be?
A I would have to look at the graphs for that.
9 10 I know temperature had increased and I had learned 13 when we started putting it together, I had learned 12 that the period of time it was right around when I
()
13 was watchin.g the generators after they found out 14 later they boiled dry,that temperature was incteasing because I said so.
15 16 Q
Yes.
17 A
But when I made my first pass, I believe 18 temperature was decreasing slightly or I don't even 19 know, I don't know what the temperature drop was.
20 Q
Didn't you know that at one point before y u had closed the 12's that the temperature was as 21 22 high as 590 degrees?
A Yes, but that is what I am saying.
I don't 23 know at what point we had already initiated high 24 V
pressure injection at that point.
I am saying that 25
0 1
Faust 646 2
one time when I looked at the gauge, I had seen 3
temperature dropping and at another time it was 4
higher than I needed.
5 Q
Did you understand that at the time you 6
knew the temperature was above 550 degrees and at one 7
point as high as 590 degrees, that during that period 8
of time you did not have an overcooling transient 9
going on?
10 A
At that period of time?
11 Q
Yes.
12 A
I didn't think of an overcooling transient,
~
13 because I was trying to figure out why the generators 14 were boiling dry.
What I am saying, my frame of 15 mind that day, when I was assorting information 16 together to try to figure out what was going on, I 17 had perceived a drop in temperature and that I 18 associated with high pressure injection.
I am saying 19 I probably got it out of sequence.
20 Q
It is a fact, is it not, Mr. Faust, that 21 temperatures in the steam generator, based on your 22 training and experience of 550 to 590 degrees, are 23 inconsistent with an overcooling transient?
(~N 24 A
I didn't deny that.
b]
25 Q
O.K.
Fouct 647 g
A What I was saying is you are trying to piece --
I said to myself, " Hey, we overcooled and got a high 3
pressure injection."
And all I am saying is when I g
was thinking that day one of the things I remember coming up with, we had a high pressure injection came on with a --due to a cooldown and I may have believed.
In fact, I would have to look at it again.
Q Did you ever see a decrease in temperature in the cold leg at any time?
A Yes.
11 Well, let me clarify that.
I saw the Tave decrease.
Q Decrease from what to what?
A You have to be kidding me.
I wouldn't remember that.
I am having a hard time remembering numbers as it is that happened that day.
Q You knew, didn't you, that A
What I am saying, what I have been saying is I had a hard time putting things together.
I learned 20 that after periods of time that I had probably, I 21 e
am saying probably fit back and when I was sitting i
22 there and had a moment to think about it, that I said, 23 "Well, this probably happened,because of that."
Qs 24 Q
You knew, didn't you, Mr. Faust, based on 25
Faust 648 1
OV 2
your training and experience on March 28th, 1979, that if HPI came vn at time when the temperature 3
4 was above 547 degrees, that that would be inconsistent 5
with an overcooling transient?
6 MR. MacDONALD:
Are you asking whether S
7 he thought of it that day?
8 MR. FISKE:
Did he know that at that time.
9 A
At that time I would have known it, yes.
But 10 you are missing something here.
I don't know what 11 you are trying to get out.
. 12 Q
I will
- t. ell you what I want.
I would n
13 like to ask the questions one at a time and if we get s
14 through --
15 A
You are missing something.
16 Q
Let's go through it and we will see.
You 17 had in front of you, did you not 18 MR. MacDONALD:
Let him finish.
19 Q
You had a strip chart that showed 20 temperatures from the beginning of the transient forward?
21 22 A
What?
23 Q
You had available to you, did you not, f~}
n Panels in the control room a strip chart which 24 N_/
25 showed temperatures from the beginning of the transient
1 Faust 649 2
forward for a period of time?
3 A
No.
I had a true gauge I was looking at and 4
I had a downcomer temperature that is not a strip 5
chart that I was looking at.
6 Q
Was there a chart available to you in 7
the first ten minutes of the transient which would 8
show you what the temperatures had been, the true 9
temperatures from the beginning of the transient 10 through the first ten minutes?
11 A
No.
12 Q
Was there any way on the morning of the O
\\_/
13 accident that you could have found out what th e-14 temperature, the true temperature, had been from the 15 beginning of the accident through the first ten 16 minutes?
17 A
I imagine if I went over to the not from 18 where I was looking at it, I didn't have it.
I enaed 19 up stationed at the foedwater station.
20 Q
If you wanted to find out what the ggg 21 temperatures had been from the beginning of the 22 transient through the first, let's say, 15 minutes, 23 could you have obtained that information?
[~)
24 (Continued on following page.)
v 25
1 Faust 650
\\
2 MR. MacDONALD:
I will object to that.
3 The objection is based on anything is possible.
4 MR. FISKE:
I don't know whether it is 5
Possible or not.
That is what I am trying to 6
find out.
7 MR. MacDONALD: I'think you have 8
established in prior testimony what his g
recollection was about what instrumentation 10 is available in the control room, what he 11 understood and recalled about what the computer 12 Printed out, his understanding of all that prior 13 to the day of the accident.
We spent many, g4 many hours over that and it seems to me you 15 are going over it.
16 Q
My question, Mr. Faust, so you understand I
17 lt, is not limited to what may have been directly in 18 front of where you were standing.
My question is 19 was there information available to you during the l
first 100 minutes of the accident by which you could 20 i
21 find out what the temperatures had been from the Tave temperatures from the time the accident started 22 23 through the first 15 minutes.
(~N 24 MR. MacDONALD:
My objection still stands.
A Just a. minute.
I know I am having a memory blank 25
I Faust 651
)
Ov 2
in my panel right now.
3 Do you have a picture of the panel, the 4
instrumentation that is on it?
O 5
Q Sure (banding document to the witness) 6 What is the answer to the question?
7 A
It is a rather basic one.
I can't remember a 8
meter, what type it was.
9 Q
Well, just give us your best recollection.
10 A
Yes, but that wasn't -- I think we -- I think 11 it is the Tave strip chart that is over to the left 12 of the RC flow.
.)
13 MR. MacDONALD:
It is what your recollection 14 is, Mr. Faust?
15 THE 5 FITNESS :
Yes.
16 I am having a hard time remembering if 17 that meter is a strip chart or not.
18 I can't believe that.
19 Q
At any time up to the time that the 20 second set of reactor coolant pumps were turned over, i
g 21 did you ever attempt to determine what the temperature 22 had been at the time pressure reached 16407 23 l
A During that day?
No, I didn't.
24 Q
Did it occur to you during that period 25 of time that that would be an important fact to know l
l l
6 1
Faust 652
%)
2 in deciding whether or not HPI activation had been 3
the result of an overcooling?
4 A
I told you what I already thought it was at the 5
time.
I didn't have a reason to go back at that time 6
to doubt what I was thinking.
I thought it initially 7
occurred due to an overcooling accident.
8 Q
But 9
A That.is what I associated it with.
10 (continued on next page) 11 12 O
15 v
14 15 16 17 18 19 20 21 g
22 23 24
(
2s
653 Faust
/^T U
2 Q
You testified previously that you didn't 3
know at what point HPI had come on.
4 A
No, when I sit back and start thinking about it, 5
I don' t know what point it came on.
6 Q
All right.
7 So that without knowing at what point HPI 8
actually starte d, you wouldn' t know whether or not HPI 9
had been due to an overcooling; isn't that corre ct ?
10 A
I already told you what I thought about it.
I 11 j ust keep on saying, my frame of mind that day and what 12 I was thinking, I had reason to doubt that the initial 13 problem was due to an overcool'ing accident.
That is 14 not saying that I am going -- it is going to make my 15 me mo ry bette r now -- and say I sat back and say I 16 really skrewed up here in my analysis.
17 Q
I am simply trying to find out, yes or 18 no' whe ther at anytime during the first 100 minutes of 19 this accident it occurred to you it would be important 20 to know what the temperature was at the time HPI had ggg 21 come on?
22 A
Why would I do that?
23 Q
Because it might tell you whethe r or not r
( )h 24 HPI actuation had been due to an overcooling if it 25 showed that the temperature was above 550 when HPI
654 1
Faust V(~%
2 came on?
3 I already thought that.
A 4
I will stop in the middle that I figured.
5 Q
How could you have reached that conclusion 6
if you didn' t know what time HPI came on?
7 A
Because I have already also stated I wasn't sure 8
when I put all this together in my mind.
I was coming 9
up with reasons for things during that pe riod that I 10 was thinking I remember seeing that tempe rature doing 11 that at that point.
.12 Q
So your testimony is that you reached the conclusion that HPI came on,due to an overcooling 13 14 without ever knowing at what point in time HPI had 15 come on?
16 A
I told you I remember seeing temperature drop.
17 I remember thinking about temperature dropping, and 18 thinking I am causing their problem ove r the re.
19 Q
But you didn' t know, and you didn't take 20 any steps to find out whether HPI had come on during ll 21 the time the tempe rature was dropping, as you say, or 22 whether it had come on when temperature was rising as 23 high as 590 de gree s ?
t 24 A
Too bad you weren' t there.
25 Q
I am simply asking the question.
I l
l
655 1
Faust O
2 A
I know what you are simply asking, and I have 3
given you a simple answer that I can make it as simple 4
as I can in my frame of mind that I remembe r that day.
5 It wasn't that simple to me.
I thought I was 6
reasoning it out properly.
7 Q
O.K.
8 Mr. Faust, let me show you again what has 9
been marl.c d as B &W Exhibit 267.
10 (Document hande d to the witne ss.)
11 This is a chart prepared by GPU and 1
12 submitted to the Nuclear Regulato ry Commission, O.
13 re fle ctin g tempe rature in the ste am gene rators in the l
14 first 30 minutes.
15 Now, I believe you testified earlier, Mr.
16 Faust, that tempe rature in the cold leg of the reactor 17 coolant system is equivalent to tempe rature in the 18 steam gene rator.
19 MR. MacDONALD:
I will object to that.
20 I don't think he testified that it was gg 21 exactly equivalent.
22 Q
within a few degree s, I believe you said.
23 MR. MacDONALD:
You are trying to
(~h
(_)
24 Paraphrase an answer.
25 Q
That is co rre ct, Mr. Faust, that within a
656 1
Faust O
2 few degrees temperature in the cold leg and the 3
reactor coolant system is comparable to the steam 4
gene rato r tempe rature ?
O 5
MR. MacDONALD:
Yo u me an at all times?
6 Q
(Contin uin g)
During normal ope rations.
7 A
Yes, it is about it is close.
8 Q
Doesn't Chart 267 refle ct that when the 9
trip occurre d, tempe rature in the cold leg increased 10 to almost 550 de gre e s -- I ' m s o rry, almost 570, up 11 to above 570 degrees?
12 MR. MacDONALD:
Are you asking him that
(~T V'
13 is what the chart shows?
14 MR. FISKE:
Yes, that is fair enough.
15 A
That is what the chart shows, yes.
16 Q
Do you have any reason to believe that 17 this chart submitted by GPU to the Nuclear Regulatory 18 Commission does n' t accurately reflect what the 19 conditions were on the morning of the accident?
20 MR. MacDONALD:
Are you asking whether ggg 21 the --
22 A
This wasn't in front of me on the day of the i
23 a cci de nt.
[~)
24 Q
That is not my question.
V 25 A
Well, that is my answer.
1 Faust 657
/'N b
2 Q
For the moment, Mr. Faust, let me ask the 3
questions and you answer them; if somebody else wants 4
to ask you some othe r questions late r on, they can do 9
5 that.
We have to proceed in an orderly f ashion s and 6
the orderly fashion is for you to answer my questions 7
fi rs t.
8 MR. MacDONALD:
That is'what he is doing.
9 MR. FISKE:
Read the question and the 10 answer, please.
11 (Re co r d re a d. )
12 MR. FISKE:
I move to strike the answer, 13 and ask Mr. Faust to answer the. question.
14 MR. MacDONALD:
I think he answered the 15 question.
16 Will you please read the' question?
17
- (Record read) 18 19 MR. MacDONALD:
I object to the extent 20 that I think we have gone into this chart ggg 21 be fo re along the same line.
Basically the 22 witness testified he didn ' t recall seeing it 23 be fo re, sp e ci fically, and has really no A(_,)
24 foundation based on any of his testimony here.
25 He didn' t prepare it.
6S8 1
PAust
('1
\\_/
2 MR. FISKE:
O.K.
3 MR. MacDONALD:
He can tell you what his 4
re collection was on the day of the ac ci de nt,
5 which is what he is trying to do.
6 BY MR. FISKE:
7 Q
Would you answe r the question, please, 8
Mr. Faust?
9 A
I personally don't see why it wo ul dn ' t re fle ct 10 it.
11 Q
O.K.
12 A
If it was provide d by those people.
/
(_)N 13 Q
Isn't it a fact, Mr. Faust, that on the 14 mo rning of the accident you did not see a drop in 15 temperature in the steam generator?
16 A
No, that is not a fact.
bact that you did not see a 17 Q
Isn't it a 18 drop in tempe rature in the cold leg?
19 MR. MacDONALD:
I object.
20 A
I didn't see the TC.
I saw the downcomer 21 te mperature on the gene rators and at one point during 9
22 that day I had seen a drop in tempe rature on it.
23 MR. FISKE:
Let's mark as the next exhibit, 24 Exhibit 279, a one-page d'ocument produced by GPU 25 in this litigation, bearing numbe r 9 72 7, bearing
1 Faust 659 O
2 the designation, " Memory Trip Re vi ew. "
3 (On e-p age document produced by GPU 4
be aring numbe r 9 72 7, with the designation O
5
" Memory Trip Review," was ma rke d B &W Exhibit 279 6
for identification, as of this date.
7 (Document handed to the witness.)
8 BY MR. FISKE:
9 Q
The GPU chronology, which has been marked 10 as an exhibit p reviously, which was filed with the 11 Nuclear Re gulatory Commission, indicates that a 12 memory trip review was requested by the operators at 13 approximately 4:30.
j t
14 I would like to show you what has been i
15 marked as Exhibit 279, and ask you whethe r you have 16 ever seen that before.
17 A
I don' t believe I have.
If I di d, I don't
}
18 remembe r it.
19 Q
Were you aware that at any time during I
20 the first 100 minutes of the accident that information qg 21 had been obtained from the computer which showed that 22 at the time pressure went below 1700 pounds per square 23 inch in the reactor coolant system, the ste am gene rator
()
24 temperatures were 576 de gre e s ?
25 A
No, I wasn't.
L
Faust 660 y
%d 2
Q Mr. Faust, there was anothe r situation 3
be fo re March 28th, 1979 in which you knew that HPI 4
had been automatically activated by a drop in primary 5
pre s s u re other than overcooling in the steam 6
generators isn't that corre ct?
7 A
Which one do you mean?
8 MR. FISKE:
I will withdraw the question 9
and phrase it again.
10 Q
We have been discussing here in the last 11 few minutes incidents be fore March 28, 1979 in which 12 HPI had come on automatically because o f a drop in 13 pressure in the primary system caused by an 14 ove rcooling in the steam generator; correct?
15 MR. MacDONALD:
Evente at TMI?
16 MR. FISKE:
Yes.
17 A
Right.
18 Q
Now, you knew that on March 28th, 1979 19 that the re had been anothe r case in which HPI had 20 come on automatically because of a drop in primary 21 pressure which was not caused by an overcooling in g
22 the steam generator s isn't that right ?
23 A
Yes, I know or One.
()
24 Q
What caused the drop in pressure on that i
25 tran sient?
l j
l i
1 Faust 661 v
2 A
There was a loss of powe r.
3 Q
Resulting in what?
4 A
A lost indication on the electromatic relief 9
5 believe was open.
They didn't realize it be cause it 6
was open.
{
l 7
Q You learned that the open electromatic l
0 relief valve had caused the drop in pressure, which 9
activated HPI; isn't that correct?
10 A
It didn' t have any increase in level at the 11 pressurizer that I know of.
. 12 MR. FISKE:
I move to s t rik e that answer.
O 13 THE WITNESS:
Why?
14 MR. FISKE:
Be cause it is not responsive.
15 THE WITNESS:
What are you talking about, 16 it's not responsive?
17 MR. MacDONALD:
You answer the questions.
18 Somebody will move on his motion to strike.
19 MR. FISKE:
Just answer them one at a time.
20 MR. MacDONALD:
He is answering the g
21 questions.
You j ust ask the questions.
22 MR. FISKE:
That is what I am doing.
23 Q
You knew, did you not, that what had
()
24 caused the drop in pressure in that particular 25 transient was' an open pilot-ope rate d relie f valve ?
1 Paust 662
()
2 A
The way I have stated it, yes.
3 Q
Did the thought ever cross your mind in 4
the first 100 minutes of the accident as a possibility 5
that the drop in pressure on the reactor coolant 6
system might be because of an open pilot-operated 7
relief valve?
8 A
I already told you what I thought.
9 Q
I haven't asked you that q ue s tion.,
10 A
Yes, you have.
I gave my answer, what I thought 11 the pressure drop was from.
12 Q
Did it ever cross your mind as a
(}
13 Possibility that there was an open pilot-operate d 14 relief valve that caused the drop in pressure?
15 A
I imagine if I sat back and thought about it, I 16 would have come up with that.
17 Q
Did you come up with that?
\\
18 A
That day, no, I didn' t think about it that day.
19 Not at that point.
20 Q
At anytime in the firs t 100 minutes of
/}
21 the accident is what I am talking about.
a Did that 22 thought ever even cross your mind?
23 A
I already answered what my reason was.
what I 24 thought about pressure.
I don't remembe r e ve rything O
25 I was thinking about that day, either.
That is
1 Faust 663 O
2 obvio us, too.
3 MR. FISKE:
Can I hear the last answer, 4
please?
5 CRe co rd re ad. )
6 MR. FISKE:
Off the re cord.
7 (Discussion off the re co rd. )
8 (Recess take n. )
9 (Continued on Page 664.)
10 11 12 13 14 15 16 17 18 19 20 dIl 22 23 3
24 J
25
- 1 Fount 664 1
{k-s 2
BY MR. FISKE:
0 Q
Mr. Faust, you testified before a 4
committee of the United States Senate?
5 A
Yes, I believe I did.
6 Q
The chairman of which was Senator Hart; 7
is that correct?
8 A
Yes.
9 Q
Let me show you.a transcript of that 10 testimony, page 71, and if you want to read over 11 into page 72, that is perfectly all right and ask 12 you whether that refreshes your recollection that 13 on'the morning of March 28th, 1979 you had considered 14 the possibility of an open PORV (handing transcript 15 to the witness).
16 A
If you read the whole thing, it will answer 17 your question.
18 Q
My question, Mr. Faust, is whether or not 19 reading what is on page 71 and page 72 refreshes 20 your recollection that on the morning of March 28th, 21 1979 you did consider the possibility that there was 22 an open PORV which was causing the drop in pressure.
23 I don't think you said that.
I don't think the
~}
24 testimony says that.
25 A
I will read it right from the words that are
g Faust 665 O(
on this thing.
2 Q
The question is whet;. r it refreshes 3
4 your recollection or not.
A I said in this thing that you are referencing 5
6 to that whole paragraph, if you read it, I also said I am talking for somebody 21se right now that should 7
8 be noted.
MR. SELTZER:
Just answer his question.
9 10 MR..FISKE:
I am trying to find out with Mr. Faust whether this refreshes your 11 12 recollection.
o A
Of what I was thinking about that day?
13 14 Q
After you read this question and answer that I just put l'n front of you, does that help 15 16 you remember whether on the day of the morning of the accident you considered the possibility that 17 18 there was an open pilot-operated relief valve that was causing the drop in pressure on the primary 39
'id*7 20 A
My answer is the same.
21 MR. MacDONALD:
"You" being Mr. Faust?
22 MR. FISKE:
Yes.
23 A
My answer, what I thought is the same.
This 24 was given later on and I stated in there I was talking 25
bt 1
Faust 666 O
kl 2
for what somebody else had said later on in 3
interviews and when we were together after the 4
accident had taken place..
5 Q
Did you discuss with any other operator 6
during the first 100 minutes of the accident the 7
possibility that the pilot-operated relief valve might 8
be open?
9 A
I, myself, no.
10 Q
Did you hear anyone else discussing that?
11 A
I can' t put it in a time frame now but I recall 12 discussions on the electromatic.
I wouldn't even call
(_)
13 them discussions.
I was from what I recall and 14 remember hearing during that period of time on the 15 day of the accident were fragmented.
It's in relation 16 to a full discussion like I was part of it or just 17 standing listening to that, no.
18 I don't remember that totally.
I just 19 remember parts.
20 Q
You testified earlier in this deposition 21 that as part of the training at Babcock & Wilcox gg 22 you had been taught to diagnose an open pilot-operated 23 relief valve by looking for a drop in pressure in the
('s. -
24 reactor coolant system.by looking at the temperatures N.
25 on the tailpipe from the PORV and by looking at pressures I
2 1
Faust 667
/~T C
2 in the reactor coolant drain tank.
3 A
Maybe that's the problem.
4 MR. MacDONALD:
Are you asking him to k
g affirm that?
6 MR. FISKE:
That is just a preliminary 7
question.
g Q
Do you remember giving that testimony?
9 MR. MacDONALD:
Specifically as you stated 10 it?
remember giving testimony "to you about the 11 A
I
- 12 way you look for an open pilot-operated relief valve.
s\\-).
13 Q
Right.
14 And one thing you were taught to look for, 15 you were taught to look for a drop in pressure, to 16 look at the temperatures on the tailpipe, and to 17 look at the pressures in the reactor coolant drain 18 tank, isn't that correct?
19 MR. HacDONALD:
Just those three things?
20 Q
This is what you testified you were 21 trained to do at LsW, is that correct?
g 22 A
At B&W, for the situation they have, yes.
23 Q
O.K.
I
[)
24 At any time during the first 100 minutes xs 25 f the accident, that is, up to the time the reactor,
3 1
Faust 668 l
l)\\
(-
2 second set of reactor coolant pumps were turned off, did y u try t find ut what the temp-ratures 3
were on the tailpipe?
4 (gp A
I was assigned to wher I was hy my Supervisor.
3 6
I was busy working with the problems that I had seen or that I was working with on the secondary side.
7 8
Q So what is the answer to my question?
g Yes or no.
A Just that 10 11 MR. MacDONALD:
I think he gave the answer.
12 A
I was busy working the secondary side of the panel.
~
33 14 Q
I simply asked you whether you tried to find out what'the temperatures were on the tailpipe.
15 I think you can answer that yes or no.
16 A
I d n't like yes or no.
17 18 9
W*ll ~~
A I like the answer I am giving you.
I am telling 39 y u what I was doing, what I was assigned to do then.
20 Q
S does that answer mean you did not try 21 to find out what the temperatures were at the tailpipe?
22 23 A
My answer is I was working the secondary side of
)
24 the plant.
\\/
25 Q
I think y u said that three or four times.
i 4
1 Faust 669 2
A I understand I did and that's going to stay my 3
answer.
4 Q
I would like to find out, yes or no, i
5 did you try to find out 6
A I answered you.
l 7
Q Why don't you tell me what the answer is?
8 Is it yes or no?
e A
I don't like yes or no answers, Mr. Fiske, in this 10 thing.
11 Q
I think this is a perfectly straightforward I
12 question.
Either you tried to find out or you didn ts o\\/
13 th'at's all I am asking you.
You can give any 14 exp1'anation you want.
I am not preventing that.
15 I just want to know whether you did or whether you 16 didn't.
17 A
No, because I was working in the secondary side 18 of the plant.
19 Q
Did you try to find out at any time 20 in the first 100 minutes of the accident what the 21 p'ressures were in the reactor coolant drain tank?
22 A
once again, I was working the secondary side 23 of the plant, so I wouldn't have been looking at the
(
24 drain tank at that point.
25
'Q so you didn't try to find out any of the
1
\\
t 5
1 Faust t
(~)/
\\_
2 conditions in tne drain tank'during that first 100 3
min uie s ?
4 A
At the time i was having a problem with the steam 5
gene rato r'.
Q so the answer is'no, right?
6 7
A
'Yes.
8 Q
'b.K.
9
'Did it come to your attention at any time 10 before the second set of reactor coolant pumps were 11 turned off that the rupture disc had broken on the 12 reactor coolanc drain tank?
h)
'~#
13 A
'How would I know*that?
14 Q
I am simply asking you whether anybody 15 told you that fact.
16 A
No, I don't believe they did.
17 Q
It is correct, is it not, that as of the 18 date c'
%se accident, you would not have expected 19 t *, e ;?
'r coolant drain tank r.upture disc to blow 20 based on this simple, ordinary opening and closing 21 of the pilot-operated relief valve after a reactor 22 trip?
23 MR. MacDONALD:
Are you asking him whether O) 24 he ever saw the opening or closing that blew the t
l w
25 rupture disc on the drain tank?
(
s
~
~
L2, '
l s
l
'}.
6 1
Faust 671 A
2 MR. FISKE:
I will stick with my question.
3 THE WITNESS:
Read his questlo...
4 A
Unless you want to restate it.
Say it again, 5
please.
6 Q
It is a fact, is it not, that on the 7
day of the accident, you wouldn't have expected to 8
see a rupture disc, the rupture disc blow on the g
reactor coolant drain tank simply from an opening 10 and closing of a pilot-operated relief valve following 11 an ordinary reactor trip?.
12 A
one opening and closing?
13 Q
Yes.
I wouldn't have expected that, no.
14 15 Q
I think you testified be fore, Mr. Faust, 16 that after the and that is before in this 17 deposition -- that after the March '78 incident in 18 which a pilot-operated relief valve failed open, 19 that there had been discussions of that transient at 20 Met Ed in which you participated?
21 MR. MacDONALD:
Are you asking him to g
22 recall the subject now, not the specifics?
23 I don't want to get into recharacterizing his
.fm()
24 prior testimony.
25 MR. FISKE:
That's a preliminary question.
7 1
Faust 672 2
A I recall that the electromatic failed to close 3
because of a loss of power, yes.
4 Q
And you were taught, were you not, that 5
if the pilot-operated relief. valve had stuck or 6
failed open that you should close the block valve?
7 A
That's if you determine it's failed open.
8 Q
That's right.
If you knew it was open 9
or thought it was open, you should close the block 10 valve?
11 MR. MacDONALD:
That's not what he said.
12 Q
Didn't you learn that if you thought that
()
the pilot-operated rebief valve. failed open 13 or stack 14
- open, that you should close the block valve?
15 A
, If I thought the pilot-operated relief valve had 16 failed open or stuck open, and I knew that, I would 17 shut the block valve.
18 Q
Right.
O.K.
19 And weren't you taught or didn't 20 you understand again prior to the time of the 1979 21 accident that you were not supposed to allow a condition 9
22 to exist in which the pilot-operated relief valve 23 remained open?
24 A
If I knew about it, yes.
\\J
~
25 Q
And you understood, did you not, that
1 Faust 673
/N(-
2 if the pilot-operated relief valve stayed open, 3
that mass woul d escape out through the valve?
4 MR. MacDONALD:
You are talking about steam h
5 now?
6 A
Steam mass, that's the way I thought of it.
7 MR. MacDONALD:
You have asked these 8
questions, Mr. Fiske.
We are going through your 9
book again.
It looks like we are starting the 10 deposition from day one.
11 MR. FISKE:
Mr. MacDonald, please.
12 These are preliminary questions.
13 Q
You knew, did you not, Mr. Faust, that 14 the water in the reactor coolant system was under 15 p re s s ure, under normal operations at 2155 degrees, or 16 pounds per square inch?
17 A
Yes.
18 MR. MacDONALD:
You asked that question.
19 Q
When you were discussing the possible 20 problems that migut be created by leaving a pilot-21 operated relief valve open, did it ever occur to you O
22 that one of the problems that could result is that 23 the water in the reactor coolant system which was
~
24 under that amo unt of pressure would be forced out 25 through the, opening at the top of the system?
1 Faust 674 OG 2
MR. MacDONALD:
You are talking about 3
discussions at B&W during simulator training 4
or Met Ed classroom lectures?
I 5
MR. FISKE:
Any place.
6 A
I just don't recall the discussion like that.
7 Q
Well, when you visualized the condition 8
of an open pilot-operated rblief valve 9
A I have no doubts now any more.
10 Q
I am talking about before the accident.
11 A
I know you are.
.12
-Q You knew there was a condition in b)
(_
13 which the pilot-operated relief valve could remain 14 open, correct?
That was something you wanted to 15 prevent?
16 A
That's right.
17 Q
Right.
18 And when you were visualizing that 19 condition, that is, an open pilot-operated relief 20 valve, did it ever occur to you that one of the things 21 you might want to prevent was the water in the 22 system escaping out through the pilot-operated relief 23 valve as a result of the fact that that water was (V) 24 under pressure at 2,000 pounds per square inch and i
25 there was a hole in the top of the system?
1 Faust 675 2
A I just don't recall discussing it like that.
3 Q
or thinking of that?
4 A
I don't recall at this time about it because 5
it's 6
Q Is it fair to say, Mr. Faust, that no one 7
at Met Ed ever told you, prior to the accident, that 8
if the pilot-operated relief valve stayed open, 9
there was a danger that the pressurized water in the 10 reactor coolant system could escape as a result of 11 that pressure through the hole in the top of the
.12 system?
(~)
(J' 13 MR. Ma cDONALD >
I will object to that.
~
14 You asked him a question two minutes ago 15 whether that was discussed, and I asked you 16 specifically whether you were talking aboht B&W 17 or Met Ed, and you said "anyone."
He said 18 he didn't recall.
19 Now you are going back and asking it 20 again.
We have already gone through these
(}
21 questions at the prior deposition.
22 MR. FISKE:
Not this one.
23 A
I just don't recall discussing it that way.
og Q
You testifi'ed I believe the last time 25 we were here that at or about the time the second
1 Faust 676
/~(_))
2 set of reactor coolant pumps were turned off, HPI was 3'
turned on.
4 Do you remember that?
I 5
A I believe I said that.I I believed that was 6
when it was.
That was when I thought it was.
7 Q
You knew, did you not, be fo re that occurred, 8
that pressure had come down below the actuation point 9
for HPI and it stayed below that point for some 10 period of time?
11 A
That's what I don't remember.
12 I,just remember that the high pressure
(~')
\\-
13 injection came on.
I remember the pressure was low.
14 Then I don't remember how low.
I think I actually 15 perceived it as being somewhere around'1600 pounds.
16 I don't recall how low it was.
17 Q
Did you understand that if pressure stays 18 below the actuation point for HPI that you are supposed 19 to take steps to bring pressure bach up to its normal 20 1* Vel?
i 21 MR. MacDONALD:
Can I hear that again, 22 please, Mr. Shapiro?
23 (Question read by the reporter.)
1 b 24 A
Yes.
R.J 25 Q
Did you yourself take any steps on the
1 Faust 677 2
morning of the accident during that first 100 minutes 3
to try to bring pressure back to its normal level?
4 A
I wasn't working over there.
5 Q
So the answer is no?
6 A
I was working the secondary side of the plant.
7 It's already been established pretty well.
8 Q
so the answer is no.
9 A
You like yes or no answers, don't you.
10 Q
Well, we will move faster if we get them.
11 MR. MacDONALD:
It is not necessary that 12 all answers to Mr. Fiske's questions be yes or I~)
(/
13 no.
14 A
No, because I was working on the secondary side 15 of the plant.
16 Q
Did you discuss with anybody during that 17 period of time whether or not HPI should be turned back 18 on?
19 MR. MacDONALD:
We have already established 20 at some point in time it was not turned off.
21 You have used the term " throttled" before.
9 22 You are saying now " turned back on."
23 Q
It is a fact that the C pump was turned i
f~)T 24 off at about four minutes, I believe?
That's what I am
~.
25 referring to when I say HPI was turned off.
l l
l
1 Faust 678 t
k-2 A
On that day if I knew that?
3 Q
Yes.
4 A
On that day I wasn't aware of it at that point.
(h 5
Q Well, you knew that the flow of HPI had 6
been reduced, correct?
7 A
That period of time?
l 8
Q Yes.
I l
9 A
I made an assumption in my interviews.
That's l.
IG what I would have expected.
11 Q
Before the time the second reactor 12 coolant pumps were turned off, were you involved in l
l
/~T l
'_)
13 any decision as to whether or not to turn HPI back on?
(
14 MR. MacDONALD:
If there was such.
You
{
l 15 mean any discussions, is what you are focusing 16 on?
17 MR. FISKE:
Yes.
18 A
I don't think I can recall exactly what I was 19 what discussion I was in on,at what point in time.
20 Q
so you don't recall one way or the other?
21 A
No.
l 22 Q
Had you had any experience before the 23 Three Mile Island &ccident in 1979 with operating a
(~
24 reactor coolant system at a time when the plant was V
25 in a solid condition?
1 Faust 679 O
2 A
At the time, I recall, would have been in the 3
Navy that I actuully Swt involved with operating 4
a solid.
5 Q
And while you ware in the Navy, did you 6
ever operate a reactor while it was in a solid condition?
7 A
Operate.
O.K.
8 A clarification here.
The reactor was 9
shut down when we went solid.
We never operated solid.
10 Q
Did you have an understanding on the day 11 of the Three Mile Island accident as to whether the
.12 plant would be solid if there was saturation in the
(~) -
s' 13 reactor coolant system?
14 A
It doesn't make sense.
15 MR. SELTZER:
Can I hear that again?
16 (Question read by the reporter.)
17 MR. MacDONALD:
You are talking about the 18 saturation in what respect?
19 I just want to be clear what we are l
20 talking about, the nuclear boiling or --
l 21 MR. FISKE:
No.
l 22 MR. MacDONALD:
Just what are you talking 23 about?
I
[)
24 Q
Other than the nuclear boiling that we l
%J 25 have referred to before.
1 Faust 680
\\/
2 A
This is the first time I heard it phrased like-3 chat.
4 Q
Let me read you a question and answer 5
from Mr. Toole's deposition..
6 First of all, do you know who Mr. Toole is, 7
Ronald M.
Toole?
8 A
He works at TMI.
9 Q
You know Mr. Toole?
10 A
I became -- I think I had an interview with him.
11 Q
I would like to read a question and answer 12 from page 1060 of Mr. Toole's deposition ~
)
,)
13 MR. Ma*cDONALD:
In what, in this case?
14 MR. FISKE In this case, yes.
15 Q
The question, "Does your definition 16 of ' solid system' include the possibility of voids in 17 the reactor coolant system?
18
" Answer:
No, other than what would be 19 in the top of the pressurizer."
20 Does that statement by Mr. Toole reflect 21 your understanding of what the solid system was as of 22 the day of the accident?
l t
l 23 MR. MacDONALD:
Are you asking him if his l
/")
24 understanding on the day of the accident was to N./'
25 have a solid system and that would be solid with
1 Faust 681 OU 2
water?
Q Do you agree with Mr. Toole?
3 A
I don't know.
He was asking the question.
4 5
Q Pardor me?
A He was asking the question.
6 7
MR. SELTZER:
I don't understand.
g Q
The question to Toole was, " Question:
Does your definition of ' solid system' include the 9
10 possibility of voids in the reactor coolant system?
" Answer:
No, other than what would gy be in the top of the pressurizer. "
12
('N
(_)
13 A
I might have misunderstood what he was asking.
I don't necessarily recall that deposition.
14 15 Q
No, I'm sorry. You probably don't 16 understand, Mr. Faust.
I am reading to you a question that one of the lawyers for Babcock & Wilcox asked g7 18 Mr. Toole when he gave a deposition similar to the one you are giving now.
19 A
oh, asker. Mr. Toole?
20 21 Q
Yes.
[gg 22 MR. MacDONALD:
Ask Mr. Faust the same.
23 question.
(')
MR. FISKE:
I thought Mr. Faust was 24 v
e nfused by the procedure.
25
(
1 Faust 682 1
7-2 A
I thought that was me.
3 Q
No.
4 A
I thought that's what you are asking.
h I
5 Q
No.
If I didn't make that clear before, 6
I hope I made it clear a moment ago.
7 This is a question that was put to 8
Mr. Toole and an answer given by Mr. Toole, and the 9
question put to Mr. Toole was, "Does your definition 10 of ' solid system' include the possibility of voids 11 in the reactor coolant system?"
12 His answer was, "No, other than what o--
13 would be in the top of the pressurizer."
14 MR. MacDONALD:
Objection.
I don't know 15 what the time period was of that particular 16 knowledge that Mr. Toole said he had.
17 MR. FISKE:
I'didn't ask the question yet.
18 MR. MacDONALD:
You asked a question twice 19 and he didn't understand what you were talking 20 about.
I don't think it is good procedure.
21 Why don't you j ust ask him the question. He 22 will give'you his answer.
23 MR. SELTZER:
Off the record, 24 (Discussion off the record.)
tw 25 (Continued on next page.)
1 Faust 683 i b')
l 2
Q Again we are talking about the day of the l
l 3
accident.
Was it your understanding as of the day of 4
the accident that the reactor coolant system would 5
not be solid if there were voids in the reactor 6
cooling system?
7 A
I knew the re were -- if I knew there were voids 1
8 in the system, the system wouldn't be solid, no.
9 Q
Did you ever.have an expe rience when you 10 were in the Navy with turning on HPI at a time when 11 the system was in fact solid?
12 A
I think it was called charging.
It was
('N
(_)
13 referred to as a charging water p ump.
14 Q
That served the same purpose as 15 high-pressure injection?
16 A
It is a long way back.
17 When we were taking the system solid, 18 that would have been the time that we would have 19 charging wate r pumps on.
That would have been --
20 that would have been at that time period that it (l) 21 would have been right as it went solid that we would 22 ha ve seen that.
23 Q
Seen what?
24 A
Rapid increase in pressure.
Now, the re is 25 anothe r p roblem here.
I am theorizing, too, because
l 1
Faust 684
/~U, 2
where I was at a lot of times when we took the plant station located do'wn in the bottom 3
solid, I was on o 4
of the boat without much instrumentation.
The RO 5
was up in the control room.
)
6 Q
Did you have an unde rstanding on the date 7
o f the Three Mile Isaind accident as to what 8
conditions you would expe ct to see in the system if 9
hi gh-p re s s ure inje ction were turned on when the system 10 was solid?
11 A
I would have expected to see a sharp rise in
.12 pressure.
O k/
13 Q
After high-pressure inje ction was 14 re s ume d at or about the time the reacto r' coolant 15
- pumps, second set of reactor coolant pumps were 16 turned off, did you se e at that time any sharp 17 increase in pressure ?
18 MR. MacDONALD:
I think he said he 19 thought it was resumed.
20 A
I wasn't sure -- I wasn't even sure it was
(}
21 taken off at that time.
22 Q
I am re fe rring --
23 A
This was fe d back later on in my depositions,
)
24 in my interviews.
v 25 Q
I am refe rring to your prior te stimony,
1 Faust 685 g(3 2
Mr. Faust, and as to the statements that yo u h ave given 3
prior to the time that you gave this deposition.
4 I am simply asking you at any time after --
5 put it this way:
Any time after the second set of 6
reactor coolant pumps were turned off did you see any 7
sharp incre ase in pressure?
8 A
I wasn't watching pressure.
9 Q
We have previously marked, Mr. Faust, as an 10 exhibit to this deposition, the chronology which GPU 11 filed with the Nuclear Regulatory Commission.
12 I would like to show you a graph,
(~h k-)
13 Figure 60, which is part of that chronology submitted 14 by GPU to the NRC.
15 we will mark this as the next exhibit, 16 which is Exhibit 280.
17 (Graph entitled Figure 60, above referred 18 to, was marked B &W Exhibit 280 for 19 i de n ti fica tio n, as o f this date.)
20 (Document handed to the witness.)
21 Q
Do you have that exhibit in front of you, g
22 Mr. Faust?
23 A
Yes.
()
24 Q
Did you participate in the preparation of 25 that exhibit?
1 Faust 686 2
A No.
3 Q
Do you know who did prepare it?
4 A
No, I don't.
5 Q
This GPU chart shows that make up pump 1-C 6
was on for less than five minutes at or about the zero 7
time, right after the accident started, and was on 8
again for less than five minutes sometime between an 9
hour and a half and two hours into the accident.
Do 10 you see that?
11 A
When was this made ?
12 Q
This was submitted by GPU to the Nuclear
(_
13 Re gulato ry Commission as part of the official 14 chronology of the acci den t in September 1980.
15 A
O.K.
16 Q
What?
17 A
Right.
18 Q
I am just directing your attention to that.
19 what I will ask you, Mr. Faust, is whether 20 you were aware on the morning of the accident o f any (gg 21 reason why pump 1-C should be turned off five minutes, 22 within five minutes after it had been turned on?
23 Did you personally have re ason for doing 24 that?
25 A
You mean at that time did I know what was going
1 Faust 687 ty O
2 on, why it was turned off?
3 Q
was there any reason you had at that time 4
to turn that pump o f f ?
O 5
A From whe re I was?
6 Q
Yes.
7 A
From whe re I was and what I was watching I 8
didn't'have anything to do with the makeup pumps.
9 Q
I am not suggesting that you actually 10 t urn e d i t o f f.
All I am asking you is, did you i
11 yourself have any reason why that pump should have 12 been turned off?
13 MR. SELTZE R :
I object.
There is no 14 foundation. If he said he had nothing to do 15 with the p ump, there is no founda' ion for t
16 asking him whether a pump should or shouldn' t be 17 shut off.
18 MR. FISKE:
Maybe if he had nothing to 19 do with it, the answer will be "No."
20 MR. SELTZE R:
I think the answer is,
[gg 21 the re is no foundation for the question.
22 A
From what I was looking at, I didn't -- I don't 23 know -- I guess I am wondering why you are asking me
(~N 24 the question.
25 Q
What you are telling me is that if you
1 i
1 Faust 688 2
di dn ' t have any reason to turn it off, fine.
3 A
I was over on the secondary side o f t he plant.
4 I wasn' t even looking at that part of the parameters O
5 that I would have made, j udgment on it.
6 Q
So you were not aware of any condition in 7
the plant at that time that would have calle d for 8
turning of f the pump?
9 MR. SELT ZE R:
Objection.
There is no 10 foundation he has any basis fo r an opinion one 11 way or the othe r.
12 MR. FISKE:
I understand.
O)
(_,
13 Q
Do you want to hear the question again?
14 A
Oh, you are still asking me?
15 Q
The same question.
16 A
Do you want my theoretical answer on it?
17 MR. SELTZER:
No, don't give a theoretical 18 answer.
19 If you don' t have a basis in fact, then 20 you shouldn' t speculate.
g 21 Q
If you don't have a reason, just s ay -ou 22 don ' t h a ve a reason.
I would like an answer to the 23 question.
You can explain.it any way you want.
(~N 24 A
O.K.
Based on the fact that I was working on v.)
i 25 the se condary side, I didn't have a reason to turn off l
l l
1 Faust 689 O
2 the pump.
3 Q
o.K.,
fine.
4 (Re ces s taken. )
5 Q
Mr. Faust, you said earlier you had 6
thought that the HPI actuation had come on because of 7
an overcooling, that is, on the morning o f the 8
accident?
9 A
That is what I had come up with, my reason to be.
10 Q
During this period, 100 minutes or so from 11 the time the a cciden t started to the time the second 12 reactor coolant pumps were turned off, did you try to
[
13 determine what could have caused an overcooling in the 14 firs t few minutes o f th e accident?
15 A
The fi rs t few minutes of the accident I became 16 involve d with -- I be came involved with the loss of 17 feed that thought had occurred then at that point.
I 18 wasn't thinking about overcooling that I can think of 19 right now.
20 Q
You were conce rned about a loss of feeds g
21 correct?
22 A
At that at that point.
l l
23 Q
Right.
And you knew that in prior
()
24 transients an overcooling had been caused by 25 overfee ding s isn' t that corre ct ?
l
1 Faust 690 N
2 A
Yes.
3 Q
And you knew that at least at or about the 4
time that you discovered the 12's were closed, you we re 5
concerne d that you might be boiling the steam generators 6
dry isn't that correct?
7 A
That's right.
8 Q
Now, at any time during the fi rs t 100 9
minutes of the accident did it occur to you that you 10 couldn't have an overcooling transient f what had 11 occurred during a period of time prior to opening the 12 12's was a loss o f fee d water?
13 A
I had thought initially -- that is what I am 14 saying,I don' t know what time I formed that opinien.
15 (Continued on Page 691.)
16 17 18 19 20 (Il 22 23
[]
24 I
m 25 i
l l
sk 1 1
Faust 691 OV 2
Q And you did come to the conclusion that 3
since there was a loss of feedwater rather than an 4
overfeeding, that you did not have an overcooling 5
accident?
6 MR. MacDONALD:
You are talking about at 7
some point in time during the day?
8 Q
Is that correct?
9 A
ht that point during the day I don't remember 10 everything I was thinking again.
11 I had. thought I had -- I found out I had a 12 loss of feedwater.
C\\
\\-
13 Q
Right.
14 A
That's pretty well established, but the point 15 that initiated high-pressure injection, I am not sure 16 why or how I pieced together, but I felt strongly that 17 I had been overcooling the primary.
That's what I am 18 trying to say.
You are making it nice and clear.
I 19 was trying to -- at the time I was trying to come up 20 with reasons on things and when I perceived decreasing 21 temperature and the pressure, that's when I had come qgg 22 up with -- well, maybe high pressure injection 23 initiated because of that.
(a; 24 Q
But you knew that at least at the time you 25 discovered that the 12's were closed, that in fact
9 1
Faust AU 2
there had been a loss of feedwater, correct?
3 A
Right at that point I knew there was.
j 4
Q And you knew at that point that the 5
condition that had existed up to that point was not 6
an overcooling?
7 MR. MacDONALD:
You are asking if he thought 8
of it at that point?
9 Q
You knew that, didn't you?
10 A
I guess what I thought at that time was, I found 11 feedwater isolated from the generator and I 12 reinitiated feed.
~
13 Q
when you learned that during the period of 14 time up to the time that the 12's were opened there 15 had been no feedwater to the generator, you knew then 16 that during that period of time you had not had an 17 overcooling, isn't that correct?
18 A
Maybe I am still getting something mixed up.
You looking when I perceived high pressure came on?
19 are 20 Q
At the moment I am just asking you, isn't 21 it a fact that after you discovered that the 12's had
[g 22 been closed and as a result of that, there had been feedwater to the generator for a certain period of 23 no
(~h 24 time --
\\)
25 A
Eight minutes.
l l
3 1
Faust 693 O
k-2 Q
-- that you knew that during that period of 3
time you had not had an overccoling?
4 A
Do you know what I remember?
Thinking very hard 5
about why I wasn't getting feedwater into the 6
generator at that point. I became sessed with trying to figure out why, if the generators were 8
indeed boiled dry.
Until I found the 12's open, in 9
fact I wasn't absolutely sure at that point that the 10 generators were dry, because I thought -- we thought 11 this initially occurred in a matter of a minute.
,12 Q'
But you saw conditions as you have testified 13 many times up to the time when you opened the 12's 14 where the level in the steam generators had dropped 15 almost down to ten inches, isn't ' chat correct?
16 MR. MacDONALD:
You are asking whether he 17 has testified to that many times, or are you just 18 trying to increase the strength of the question?
19 MR. FISKE:
That doesn't need any 20 increasing.
21 MR. MacDONALD:
Then don't try to embellish
[}
22 it.
Just ask the question.
23 A
Say again now?
("3 24 Q
You knew before you discovered that the Q
25 12's were closed that the level in the steam
1 Faust 694 AU 2
generator had dropped down to almost ten inches, is 3
that correct?
4 A
I knew the level in the generator was indicating 5
ten inches on both generators.
6 Q
Based on that level, you concluded, did you 7
not, that the steam generators might very well be dry?
8 A
I was trying to figure out if they were.
9 Q
And you knew that because the 12's were 10 closed, there had been no feedwater going into the 11 generators from the time of the trip to the time you
.12 opened the valves, isn't that correct?
O 13 A
I think it dawned on me, like the 12's are shut, 14 the generators, but I wasn't sure after I opened them 15 that they had boiled dry.
16 Q
Isn't it a fact that once you learned that 17 the 12's had been closed for a period of time after 18 the accident started, that you knew that during that 19 period of time there had not been an overcooling 20 transient?
21 MR. MacDONALD:
Are you asking if he thought
~
22 about that?
23 MR. FISKE:
Yes.
I asked him if he didn't
(-
24 know that.
25 A
I am also throwing in this, the time period I
695 5
1 Faust O
2 was thinking at that time.
All of us thought it 3
Securred in the minute's time.
4 Q
I am not asking you to tell us what the 5
time period was.
All I am asking you, isn't it a fact 6
that once you learned that there had been no emergency 7
feedwater into the generator, in the generators, during 8
the period of time that the 12 valves remained closed, 9
that you knew that during that period of time while 10 the valves were closed and while no emergency feedwater 11 was going in, there was not an overcooling transient 12 going on?
13 MR. MacDONALD:
I think he told you he 14 hadn't necessarily thought about it at that time.
15 MR. FISKE:
He hasn't answered that question 16 and I would just as soon let him answer it.
17 MR. MacDONALD:
I think he had.
18 A
It all comes I knew I wasn't feeding the 19 generator.
I realized that.
20 Q
O.K.
21 A
.I don't know if I specifically thought I don't 22 have an overcooling accident at this point in time.
23 I don't remember thinking specifically that.
I
()
24 remember thinking, being very concerned that whether
\\/
25 I was feeding or was not feeding the generator and
6 i
Faust 696 2
whether the generators boiled dry.
3 Q
was it important to yua to try to find 4
out whether there was an overcolling transient going on?
5 A
At that point it was important to me to get 6
feedwater back into the generators or to insure myself 7
that I wasn't sure that I wasn't feeding the generators 8
at that point.
I thought maybe the valves had 9
throttled and maybe weren't feeding at a rate that 10 it would keep up with the mass that would be boiling 11 off.
12 Q
Is it your testimony that after you opened 13 the 12's, that you at th'at point' still thought that 14 you had had an overcooling during the early minutes 15 of the accident?
16 A
I think I
gave it to us.
17 Q
Pardon me?
18 A
That's what I am saying.
I think I had thought 19 I had given us an overcooling accident when I 20 reinitiated feed to the steam generators.
21 Q
You are saying you thought you might have qgg 22 caused an overcooling transient by opening the 12's?
23 A
Yes.
/"kT 24 Q
That isn't my question.
My question is,
/
25 once you opened the 12's, didn't you realize that up
bt 1
Faust 697 O'
2 to that point you had not had an overcooling transient i
3 because you had had no feedwater?
4 MR. MacDONALD:
Objection.
I think he 5
told you a few times when he wasn't specific 6
on when he thought he had an overcooling, 7
and you are trying to pin it down.
8 A
I am telling you what I thought.
9 Q
Yes.
10 A
What do you want more?
11 Q
That's 12 A
I'm telling you what I thought.
I was thinking 13 I wasn't feeding the generator.
That's what I thought 14
- that morning.
I was very concerned in feeding the 15 generators.
I became focused -- my whole ~ attention 16 became focused on feeding the generators at that 17 period of time and ensuring or trying to figure 18 out I keep saying that wrong -- if I indeed 19 boiled the generators dry.
That's what I was thinking 20 about.
[gg 21 Q
But isn't it a fact that having no 22 feedwater going into the generator is inconsistent 23 with an overcooling?
24 MR. MacDONALD:
Are you asking if he 25 thought that?
+
\\
2 1
Paust 698 (3
2 MI4. ' n'IS KE :
Yes.
3 MR. MacDONALD:
Well- -
)
4 Q
Didn't you understand on the day of the 5
accident that!it was inconsistent with an overcooling s
6' transient to have no feedwater going into the steam
- s 7
generator?
8 Mr. MacDONALD:
Are you asking if that's g
what he thought during the day?
10 MR. FISKE:
Yes, didn't he understand
\\
11 cn the day of the accident that it was inconsistent
,12 with an overuooling transient to have no feedwater
[\\
i,/
13 going 1.sto the generators?
s_
}q A
The day oi the accident, no feedwater going into 15 a generator would not have been an overcooling accident.
16 Q
O.K.
17 A
Can I throw something else in there?
,18 MR. MacDONALD:
If you want to.
19.
Q The question is af ter you learned that 20 there had been no feedwate r going intet th'e generators
/~h 21 for the period of time up to the opening of the 12's, u
22
'Jidn't you then learn that be cause of 'HPI actuation, 23 it could not have been an overcooling transient?
s
(~D 24 A
Wrong.'
l N-]
25 What I perceived -- it became a little i
i I
3 1
Faust 699
[\\
\\/
2 clear, and I didn't realize high pressure injection had 3
initiated at that point apparently beccuse I associated 4
it with a cooling accident, a cooling transient.
5 That's,what my problem is.
I was thinking I was giving 6
them an overcooling accident when I reinitiated 7
feedwater to the generators.
What's when I perceived 8
s aying that --- that's why I think I gave high pressure g
injection.
10 Q
You mean you thought high pressure 11 injection had not come on until after you opened the 12 12's?
O(_)
13 A
That's app'arently what I think on it, yes.
14 Q
Ian't it a fact, Mr. Faust, that if HPI 15 came on before the 12's were opened, that that HPI 16 actuation would be inconsistent with an overcooling?
17 MR. MacDONALD:
Are you asking if he ever 18 thought about that on the day of the accident 19 or just a hypothetical?
20 A
You are thinking why I came up so strong, 21 why I gave an overcooling accident.
That's really 22 the best way what I was thinking at that time.
23 Q
You thought the overcooling occurred 24 after you had opened the 12's, not before?
25 A
Yes.
That's the thought, that was a very short i
1 Faust 700
~~#
2 period of time at that time.
3 Q
Now, so you knew that there had not been 4
an overcooling before the 12's were opened?
5 MR. MacDONALD:
Objection.
6 Q
During the time there was no feedwater, 7
you knew there was no overcooling?
8 A
I told you what I was thinking that I can 9
recall prior to that.
10 MR. MacDONALD:
You probed this about 11 four hours' worth at least in his prior 12 deposition, and you are asking basically about
[^h
(_)
13 the same time period, the same questions now 14 again for another hour or so.
I think he has 15 given you what he has recalled.
16 MR. FISKE:
I believe we are making some 17 progress.
18 A
You are helping me out.
19 Q
Good.
That's all we are trying to do is 20 get all the facts as we can as accurately as possible, 21 and I am just trying to make sure we understand each
[gg 22 other that as of the time that you opened the 12's 23 and realized that for a period of time before that f~)
24 there had been no feedwater going into the generators, s-25 you knew then that during that period of time there
1 Faust 701 (k/
2 was not an overcooling?
3 MR. MacDONALD:
Objection.
I think he gave 4
you the answer to that just two minutes ago.
(lh 5
A You want what I was thinking?
6 Q
Yes.
7 A
I told you what I was thinking.
I didn't 8
squeeze anything else there at the time.
9 Q
What were you thinking --
10 A
That I can think about.
11 Q
What you were thinking was if there was 12 an overcooling, it started when you opened the 12's?
13 A
Yes.
14 Q
O.K.
15 Let me show you, Mr. Faust, a document 16 that has been previously marked as Exhibit 258 which 17 is a statement that you gave to Mr. Long and Mr.
18 Reppe rt of the NRC which you gave at TMI on March 30, 19 1979.
This is the document which bears your signature 20 on the last page.
21 I would like to direct your attention to 22 page 4,
the second question and answer, and I will 23 ask you to read that, and I will ask you whether that 24 doesn't refresh your recollection that you learned 25 that HPI had come on before you opened the 12's.
I Faust 702
(~)
LJ 2
A where am I on here?
(Indicating) l 3
Q It's the second question and answe r.
4 A
You are trying to get me to separate this all 5
out?
4 6
Q I am just asking you at the moment whether 7
it refreshes your recollection, just that one question 8
and answer is all that is relevant to my question.
9 A
I wouldn't take this as a sequence of events.
10 In one paragraph I mentioned the RC pumps; 11 that puts you in a different place.
12 Q
Let me read this --
(~)\\
\\-
13 MR. MacDONALD:
Let him read it to re f r'e s h 14 his recollection.
15 MR. FISKE: Yes.
16 Q
Just that one question is all I am asking 17 about, Mr. Faust.
I don't believe there is any reference 18 to the RC pumps in that question and answer.
19 A
I was just reading the whole thing.
20 Q
I am asking about the question by Mr. Long 21 that goes, "Were you fellows talking to each 22 other or were you pretty much doing things i
i 23 independently?"
&nd the answer that follows that.
()
24 A
You asked me if I recall saying that?
25 I don't recall the specific things.
I know t
l
1 Faust 703 0
2 we were talking to Long.
3 MR. MacDONALD:
Can we have the question, 4
please, Charlie?
5 (Question read by the reporte r. )
6 Q
Does it refresh your recollection that 7
you knew that the high pressure injection had come 8
on be fore the 12's were opened?
9 A
No, it doesn't.
10 Q
Then let me ask you, Mr. Faust, whether, 11 on March 30, 1979, you were asked this question and 12 gave this answer to Mr. Longs b
(_/
13
" Questions" by Mr. Long -- "Were you 14 fellows talking to each other or were you pretty much 15 doing things independently?
16
" Answer:"
-- by Mr. Faust "I was 17 calling out to Ed and Ed was right ove r beside me.
18 I don't know where Fred Schiemann came in.
I looked 19 over and Ed was, I believe, on the makeup pumps.
And 20 Fred was on the end of the pressurizer panel, the 21 right pressurizer heater.
I knew they had problems; g
22 I heard Ed saying that we had a high level on the
{
23 p re s surize r.
I knew we had started the pumps and I
[)
24 knew he was shutting one of them of f somewhere along
[
l
\\-
25 there to try to control pressurizer level.
I figured l
l I
Faust 704 1
/~'N
\\\\ 'l 2
we were just j amming a lot of water into the 3
p re s s uri.t e r.
I was telling him I lost flow and I was 4
telling him I reestablished generator levels.
I s aid, lb w
5
'I still had ten inches indicated, but it was 6
possible that we boiled dry.'
But I was saying 7
that we still had indications of pressure in 8
the generators.
Then I yelled out about the 12's to 9
him.
I think I said, 'We haven't been feeding.
10 12A and B are shut!'
And I reopened them.
He was 11 trying to page and get out and cover behind us to look 12 at the overall plant. The natural thing would be to
/~N
(,)
13 get them open. By the time he looked at it I was 14 opening them and telling him that I was doing it."
15 Were you asked that question and did 16 you give that answer?
17 A
I remember talking to Long.
I was telling 18 him about the accident the way I perceived it, the way 19 I thought I perceived it.
20 Q
Again my question to you, Mr. Faust, is
[gg 21 is the answer yes or no?
22 A
I don't recall it, no.
23 Q
Do you have any basis as you sit here
{~3 24 now for believing that you did not give that answer
~-)
25 to that question by Mr. Long?
1 Faust 705 (y
i-1 2
A I just don't recall the question.
3 Q
Before the accident you had received 4
training, had you not, on how you could tell whether 5
you had a loss of coolant accident as opposed to a 6
steam line break or a steam generator tube rupture?
7 A
Yes, we had training on that.
8 Q
And let me ask you whether, before the g
accident, you received either from Met Ed or B&W the 10 Table 5-1 called " Leak Identification Table" which 11 appears in the document that has been narked as 12 Exhibit 278.
(Handing document to the witness.)
13 A
This (indicating).
14 MR. MacDONALD:
No, this is 277.
15 MR. FISKE:
It's the same.
16 MR. MacDONALD:
It is not entirely.
17 MR. FISKE:
It is page 1261 in Exhibit 18 277.
19 Q
Had you received, before the accident, 20 Table 5-1,
" Leak Identification Table," which is part 21 of Exhibit 277, the documents produced from your file g
22 and Exhibit 2787 23 MR. MacDONALD:
Which is separate and 24 apart from the entire document you are asking 25 about now.
N
1 Faust 706 O
2 You are just asking about this specific 3
page?
4 MR. FISKE:
I am asking him whethsr he (h
5 received that information from any source.
6 MR. MacDONALD:
So you are not just dealing 7
with the page itself.
8 (Continued on next page.)
9 10 11 12 O
13 14 15 16 17 18 19 20 h
21 22 23 OO 24 1s
1 Faust
('T U
2 Q
Well, let's start with the page.
3 A
I don't recaAl the specific document, no.
4 Q
Did you understand on the day of the
()
5 Three Mile Island accident that it was a symptom of 1
6 s steam line break that there would be a rapid 7
de cre as e in pressurizer level?
8 A
I knew we would have a de crease in pressurizer 9
level due to a break in the steam line in connection 10 with a temperature de cre a s e.
11 Q
And you knew for a steam line break there 12 would be a rapid reduction in reactor coolant system O
kl 13 cold leg tempe ratures, did you not?
14 A
Ri gh t.
It would be cooling it down.
15 Q
Did you know that a symptom of a reactor 16 coolant system rupture would be a de cre a s e in 17 pressurizer level and/or reactor coolant pressure 18 without associated decrease in coolant average
'9 te mpe rat ure ?
20 A
Yes.
(gg 21 Q
Is a reactor coolant system rupture one 22 type of loss-o f-coolant a cci de nt?
23 A
Yes.
()
24 Q
Did you know that it would be a symptom'of 25 a reactor coolant system rupture to have
{
1 Faust 708 i
O 2
reactor-building radiation level temperature and/or 3
pre s s ure increasing?
4 A
Temperature and radiation or press ure.
That 5
also goes into a steam line break, too, except fo r 6
t.h e radiation necessarily.
7 Q
I was trying to take them one at a time.
8 Did you understand that if you had reactor-building 9
radiation level increasing, te mpe rature increasing, 10 or pressure increasing, that that would be a symptom 11 of a reactor cooling system rupture?
12 MR. MacDONALD:
Would you read that back, O
13 please, Charlie?
14
( Re co rd read. )
15 MR. Ma c DONALD:
It is not quite the way 16 it is stated here.
17 A
You are talking about what I understood?
18 Q
Yes.
19 A
I understood if we had an increasing re acto r 20 building pressure or temperature with a radiation alarm
()
21 in the reactor buil din g, there was an indication 22 of leak inside the building on the primary, but I also 23 unde rstood that you could also have that, a primary
()
24 to se condary tube sheet leak with a steam line break.
25 MR. FISKE:
Could I hear that answer l
l
709 1
Faust f3 U
2 again, please?
3 (Re cord rea d. )
4 Q
Are you saying, Mr. Faust, that an 5
increasing building temperature was a symptom of a 6
loss, reactor cooling system rupture, also a steam 7
line bre ak, and also a steam generator tube rupture ?
8 A
Increase in tempe rature in the building, 9
reactor building temperature in cre as e could be an 10 indication of a steam line break or a leak in the 11 primary system.
12 Q
o.K.,
and that is also true of an
/^%
k_/
13 increase in building pressure?
14 A
An increase in building pressure.
The 15 radiation one is the one that can be a problem with 16 it.
It's usually used to distinguish between 17 p rima ry, a leak on the primary and a leak in the 18 secondary.
All righ t?
The thing of it is, it also 19 can -- and I think one of our EP's, if I re me mbe r 20 right, talks about a possible tube sheet leak with a g
21 steam line break, or we have a leak in the steam --
22 the generator that you could end up getting a 23 radiation alarm on the primary side, too.
The (G~)
24 con side ration in there.
25 Q
You mean, if you had both a primary to
1 Faust 710
(~')\\
\\
2 secondary tube leak an d a ste am line break 3
A I titink I threw that in the re.
4 Q
Is that correct?
5 A
I think I threw that in there, if I re me mb e r.
6 I have to look that up again.
7 MR. SELTZER:
It is on the table.
8 Q
In other words, just so I un de rs t an d, a 9
combination of a primary to secondary tube leak with 10 a steam line break on the secondary side could 11 activate a radiation alarm?
12 A
Yes.
O 13 Q'
In the buidling; is that right?
14 A
Yes, but you would expect to get 74 8, too.
That 15 is not what you wante d?
16 MR. FISKE: I think we can pick this up 17 in the morning.
18 19 Craig C.
Faust 20 gg 21 Subscribed and sworn to 'be fore me 22 this day of 1981.
23
/~h (j
24 Notary Public 25
1 711 V
CERTIFICATE 2
STATE OF NEW YORK
)
3;
. ss.-
COUNTY OF NEW YORK
)
I, CHARLES SH APIRo,
C.S. R.
aWhy Public of the State of New York, do hereby certify that the continued deposition of 7
CRAIG C.
FAUST was taken before 8
me on September 24, 1981, consisting 9
of pages 569 through 710 I further certify that the witness had been.previously, sworn and that the within transcript is a true record of said testimony; 13 That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter 16 in controversy, nor am I in the employ of any 17 3
of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my 19 g
hand this b
day or ochoaEtt 1981.
20 21 j m) if t
22 Charles Shapiro, C. S. Rh
' O u
t
712 INDEX WITNESS PAGE CRAIG C.
- FAUST, Resumed 571 5
EXHIB I T S B&W FOR IDENTIFICATION 276 Page 2698-5-1, plus Pages 1034 th rough 1524 573 277 Pages 1101 through 1276, from a Folde r No. 2699-1-1 593 278 B & N Videotape Training Manual 602 1
279 Docume nt he a de d " Memory Trip j
Re vi ew, " n umbe re d 9 7 2 7 659 l
l 280 Graph entit3 ed Figure 60 685 l
9 9 9 f
..... _~..,
_ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _