ML20072H733
| ML20072H733 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/23/1982 |
| From: | Faist F BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-06, TASK-07, TASK-09, TASK-1, TASK-11, TASK-2, TASK-3, TASK-6, TASK-7, TASK-9, TASK-GB NUDOCS 8306290704 | |
| Download: ML20072H733 (148) | |
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p- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK i
- - - - - - - - - - - - - - - - -- - - -x GENERAL PUBLIC UTILITIES CORPORATION, :
/1 JERSEY CENTRA,L POWER & LIGHT COMPANY, N METROPOLITAN EDISON COMPANY and
) PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-against- -
THE BABCOCK & WILCOX COMPANY and t J. RAY McDERMOTT & CO., INC., a Defendants. t :
- - _ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Deposition of Defendant Babcock & Wilcox 0 -
Company by FRED FAIST, taken by P aintiffs,
, pursuant to letter agreement, at the offices of Kaye, Scholer, Fierman, Hays & Handler, Esqs.,
425 Park Avenue, New York, New York, on Tuesday, March 23, 1982 at 9:55 o' clock in the-forenoon, t .-
L before Nancy A. Rudolph, a Shorthand Reporter and Notary Public within and for the State of New York.
s .
5 4 Q6gy4 0 PDR DOYLE REPORTING, INC.
T CERTIFIED STENOTYPE REPCRTERS 369 LaxtNGTON AVENUE WALTER SHAPIRO, C.S.R.
New Yonx. N.Y. 10017 CHARLES SHAPIRO, C.S.R.
TELEPNo N E 212 - 867 8220
( m
1 2 4
2 Appearance s:
3
} 4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 5 425 Park Avenue
BY: RICHARD C. SELTZER, ESQ.,
7
. of Counsel 8
t 9
DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants g One Chase Manhattan Plaza -
l 12 BY: ROBERT F. WISE, JR., ESQ.,
~~
f 13 of Counsel l i 14
}
i 15 Also Present:
! 16 DAVID TAYLOR 17 18 -oOo-19 -
20 IT IS HEREBY STIPULATED AND AGREED by and 21 between the attorneys for the respective parties
! (.- 22 hereto that the sealing, filing and certification 23 of the within deposition be, and the same hereby
- 24 are, waived; that the transcript may be signed
%s 25 before any Notary Public with the same force and i
t
\ - , ~ ~ , , - e-- ,- c- -
m
1 1 3 2 effect as if signed before the Court.
3 IT IS FURTHER STIPULATED AND AGREED that 4 all objections, except as to the form of the question, are reserved to the time of trial.
( 5 6
7 -ooo-8 9 F RED F AI S T ,. having been first 10 duly sworn by the Notary Public (Nancy A. Rudolph),
11 was examined and testified as follows:
12 EXAMINATION BY MR. SELTZER:
] 13 Q Please state your name and address.
14 A Fred Faist, 7 Oakglade Drive, Hummelstown, 15 Pennsylvania.
16 MR. SELTZER: I would like to mark as 17 GPU Exhibit 486 a resume of Mr. F ai,s t .
18 (Resume of Mr. Faist was mark'ed GPU Exhibit t
19 '486 for identification, as of this date.) '
20 Q Would you identify, please, GPU Exhibit 4867 21 A It is my resume for Fred Robert Faist.
22 Q Did you prepare it?
23 , A- Yes.
24 Q When is the last time that you reviewed it?
25 A The last time this resume was reviewed was
1 Faist 4 2 about two years ago.
3 Q Was it accurate at the time you prepared it 4 and last reviewed it?
A Yes.
( 5 6 Q The entry for July 1979 to present reads, 7 "B&W, Resident Engineer - TMI Unit 1."
8 Has that continued to be your position?
9 A Yes. _
10 Q So GPU 486 continues to be an accurate resume 11 for you?
12 A Yes.
O 13 Q To your knowledge, does B&W maintain an 14 employee experience profile for other managers?
15 A I don't know that.
l 16 Q For what purpose did you prepare your 17 employee experience profile? .,
18 A This was prepared for the Rogovin report.
10 Q Do you mean it was prepared prior to your 20 deposition by the NRC Special Inquiry Staff?
21 A I was asked to update it a few years ago.
22 Q Are you saying that you had an employee 23 experience profile on file at B&W and you were 24 requested to update that?
25 A I was requested to update it.
l l
. 1 Faist 5 l 2 Q Update what?
3 A My resume.
4 Q Where was the resume that you were requested 5 to update?
(
6 A I had an old copy of my resume in my file i
7 and I was asked to update it.
8 Q For what purpose did you previously prepare 9 a resume?
10 A It was originally preparedethe last time 11 prior to that when I was going to be offered the position 12 as resident engineer at TMI-1.
J v 13 Q Did you study any nuclear engineering at 14 Stevens?
15 A No. ,
16 Q Did you study thermal hydraulics at Stevens?
17 A I studied thermodynamics. ,
~
18 Q What, if anything, is the re1ationship 19 between thermodynamics and thermal hydraulics?
20 A Thermodynamics is theory, differential 21 equations. Termal hydraulics is fluid flow calculations.
22 Q At the time that you worked in the thermal-23 hydraulics engineering section, what department was.that 24 in at NPGD?
25 A I don't remember the title of the department.
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Faist ~6 s I s
2 Q' ' How would you d'e scribe g'unerally the s e'o p e f
3 of the department? - )
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4 A NSS design.
l
() 5 g Up to the time of the Three Mile Island s 6
f accident, did there continue to be a thermal-hydraulics i
7 engineering section? s 0
A I don't know that.
9 Q After you left tne thermal hydraulics i 10 !
engineering section, did there continu$.to be.a section l 11 by that name? "
12 A I don't know that.
O 13 Q Do you believe that the unit was' disbanded s
s 14 upon Fred Faist's leaving it?
la, 3 m
A I don't know what happened to the unit
,' c 16 '
after I left it. ' '
.,N 17 Q Is there anything'that caused you Ito' believe 18 that the unit was being disbanded.when you lef.t it?
19 A
'h I have no idea what ha'ppened to the' unit 20 after I left it. N 21 '
sx Why did you leave it?
( 22 Q ,
i ,
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A For an assignment in field service. ,,
x 23 Q Who was your immediate superio'r,in t,hermal-lO 24 sve 11o et ri e> -
. ._ _ l 25 A My first supervisor was Tom Helms.
- s j
_ 1
1 Faist 7 2 Q Who were your subsequent supervisors?
3 A Robert Walker. That's all.
l 4 Q How many engineers were in the section while l 5 you were in it?
6 A Five to eight engineers.
7 Q Is it correct that you worked in that 8 section for over three years?
9 A Close to three years.
10 Q You worked in the section 1,n excess of 11 three years, right?
12 A I worked in that organization from August O 13 of 1968 to November of 1971. .
14 Q That's in excess of three years, right?
15 A Yes.
16 Q Why does GPU 486 say that you began work in 17 that section in June 1968 and the resume.that you handed 18 us today says you began work in that section in June 19 1978, and just now you testified that you didn't begin !
l l
20 work in that section until two months later than June 21 19687 22 MR. WISE: I think you misspoke. You said 23 June 1978 on the resume that we produced today. l
{g 24 I think you meant to say June 1968.
)
25 MR. SELTZER: Thank you. I did.
1 Faist 8 2 A I joined B&W in June in 1968 and was going s
3 to be assigned to the thermal-hydraulics section. I 4 spent six weeks on a companywide orientation program
( 5 before reporting to Lynchburg in August.
6 Q So GPU 486 would be more correct if it said 7 " August 1968-November 1971, worked in thermal-hydraulics 4
f 8 engineering section," right?
9 A Yes.
10 Q Did you have a variety of d,1fferent 11 assignments while you were in the thermal-hydraulics 12 engineering section?
13 A Yes. ,
14 Q Is it correct that one of th things which 15 - you did while you were in that section was worked in 16 the area of reactor vessel internals design?
17 A I did not do specific work on reactor-2 18 vessel internals design.
19 Q could you explain why your resume which you 20 said was accurate indicates that you worked in the
-21 thermal hydraulics engineering section in the areas of, 22 and one of the areas listed is. reactor. vessel internals 23 design?
( 24 A The design was determined prior to my comiSg 25 to' work with B&W. I performed calculations to
1 Faist 9 2 substantiate previous calculations.
3 Q So, then, you did do work in the area of 4 reactor vessel internals design?
l 5 MR. WISE: I think you are quibbling with him 6 over words.
7 MR. SELTZER: I am not trying to quibble.
8 If you will pardon me, the witness is being a 9 quibbler. I am looking at a resume that says he 10 worked in the section in the arek of reactor 11 vessel internals, and first he said he didn't 12 do anything in that area. Now h explained that O 13 he did verify calculation's in that area, and I am 14 just trying to make sure I don't misapprehend what 15 he is saying.
16 MR. WISE: I understand, but I think your 17 question the first time around was different. I 18 don't think you asked him if he wor ed in the
. 19 area of reactor vessel internals. I think you 20 asked him if he designed reactor vessel internals 21 and there may be a difference in his mind.
22 I think he is telling you candidly what he 23 did and you are free to pursue it. This is some C)
(_ 24 time ago and not that relevant. I don't see that 25 it is worthwhile to quibble with him over whether I
1 . Faist 10 t
V 2 something was the design or working in the area 3 of a design.
l 4 MR. SELTZER: Fine.
( 5 BY MR. SELTZER:
l 6 Q Could you describe generally what your I
7 responsibilities were in connection with the area of 8 reactor vessel internals design when you were in the 9 thermal-hydraulics engineering section?
10 A Primarily verification of kressure drops, 11 fluid flow calculations.
12 Q What kind of pressure drops are you referring O 13 to?
14 A Primarily fluid flow, determination of fluid 15 ficw pressure drops to the reactor vessel and internals.
16 (Answer read) 17 Q At what particular locations in the primary 18 loop were you studying pressure drops?
19 A The reactor vessel.
20 Q Were you studying it at particular places 21 in the reactor vessel such as at inlet or outlet 22 nozzles?
23 A I had done work on pressure drop calculations f
s 24 on inlet, across certain components on the internals j
25 and pressure drop calculations across various parts of l l
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l Faist 11 l
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2 the internals.
3 Q Which parts of the internals?
4 A Surveillance specimen holders, flow (l 5 deflectors and flow vanes.
6 Q Did you ever do any calculations relating i
7 to pressure drops in the reactor coolant pumps?
8 A No.
0 Q Did you ever do any work with net positive 10 suction head curves? (
11 A Not at that time.
12 Q When if ever did you do any work with NPSH7 13 A In the field. .
14 Q When?
15 A Arkansas Power & Light, Davis-Besse.
16 Q Have you described all the places in the 17 primary system where you studied the effects of pressure 18 drops when you were in the thermal-hydrau ics engineering 19 section?
20 A No.
21 Q Where else did you study the effects of 22 pressure drops?
23 A Just the reactor vessel.
( 24 Q Wh'ere other than the places in the reactor 25 pressure vessel that you have already mentioned did you
12 1 Faist 12 l O
2 study the effects of pressure drops?
3 A 'Across reactor fuel assemblies.
4 Q Are you finished with your answer?
k 5 A Yes.
l 1
6 Q so you have now told me every place in the i 7 reactor pressure vessel where you studied the effects 8 of pressure drops?
9 A Yes.
t 10 Q Did you ever analyze the effects of pressure 11 on any reactor vessel components or internals produced 12 f- by high-pressure injection?
%.)
13 A No.
14 Q Do you know whether anybody has ever 15 studied that?
16 A Yes.
17 Q Who to your knowledge has stddied that?
18 A There are some B&W topical reports out on 19 HPI and reactor vessel internals or reactor vessel.
20 Q To the best of your recollection, when were 21 the earliest that reports were prepared?
22 A The only ones that I know about were 23 prepared within the past two years.
(D ,j 24 Q Who prepared those?
25 A B&W.
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1 Faist 13 l
2 Q Do you know which unit?
3 A -Prepared to the B&W owners group.
4 Q Prepared to the B&W owners group?
I
( 5 A By the B&W owners group.
6 Q Is the B&W owners group a B&W company 7 operation?
8 A No, it is just managed by B&W, and the work g that they do is work that the B&W users request them to 10 do and fund and pay for. E 11 Q So it was done for the B&W users group, but 12 who in B&W did the work, which section in B&W did the
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13 work?
14 A I don't know all the sections that were 15 involved in that group.
16 Q Which sections do you know were involved 17 in it? .
18 A I don't know.
19 Q Do you know any,section that was involved-20 in it?
21 A That's not part of the published report of 22 what sections do the work, so I couldn't tell you what 23 specific sections or if any of them did the work.
() 24 Q Do you know the name of any of the authors?
25 A No, I don't know the name of the people that l
1 Faist 14
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V-2 actually wrote parts of that.
3 Q If y u wanted to get a copy of those 4 topical reports, how would you do it?
( 5 A I would have to go back through Lynchburg, 6 either contact the licensing people or work through my 7 supervisor in Lynchburg to locate those reports.
8 Q How did you become aware of those reports?
9 A Through discussions with B&W people and the 10 owners group that are managing the grob,p.
11 Q I take it you read the reports?
12 A Yes.
O 4 13 Q When you were in the thermal-hydraulics 14 engineering section, what work did you d in the area 15 of control components?
16 A Heat transfer calculations.
17 Q For which control components?-
18 A orifice rods, burnable poison rods,. control 19 rods and axial power shaping rods.
20 Q Did'you/do any thermal hydraulics work 21 related to any loss of coolant accident?
22 A No.
n 23 Q Did you do any thermal hydraulics work in
) 24 relation to any hypothesized loss of coolant accident?
25 A No.
i 1
Faist 15 (J
2 Q Was the re anyone in the section who while s
~
3 you were there was working .cn1 a thermal hydraulics 4 analysis that had anything to do with loss of coolant
( 5 accidents?
6 A Yes.
7 g What were they doing?
8 A Calculations for DNBR.
9 Q What is DNBR?
)
t 10 A Departure from nucleate boiling. !
11 Q What else were they working on in relation g- 12 to loss of coolant accidents?
\_J 13 A I don't remember everything else that they 14 were working on.
15 Q What are the other things that you can 16 recall they were working on?
17 A All areas of design for the r'eactor vessel 18 internals, fuel in the areas of thermal hydraulics and 19 heat transfer.
20 Q I meant the people who were working on 21 thermal hydraulic analysis as it related to loss of 22 coolant accidents, other than calculations for departures 23 from nucleate boiling, what else were they studying?
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1 24 A I don't know. You would have to ask them.
25 g who were they?
I 1 Faist 16 O
v-2 A Bill Hennessy, Frank Le ve ndos ki .
3 Q Did you do any work when you we re in the 4 the rmal-hydraulics engineering se ction with regard to the
( 5 ef fects of saturation in' the reactor coolant system?
6 A In working on fuel as se mblies and heat 7 transfer calculations with fuel assemblies saturation, 8 p ress ure temperature relations hip s is a part of that
, 9 evaluation. So in e ffect where you have pressure ,
10 where you have te mp e ra t ure and you do h' gat t rans fe r 11 fluid flow calc ulatio ns you do get in volve d in th at 12 type of work.
/N O 13 Q Did you study the e f fects o,n heat trans fe r 14 o f saturation in the reactor coolant syst m?
15 A No.
, e 16 Q Did you study heat transfer from fuel i 17 assemblies? .
18 A Yes.
l 19 Q You did not' study the extent, if any, to 20 which the heat transfer is affected by saturation 21 occurring in the reactor cooling system?
k.
22 A Yes, there was, I recall now, there was 23 some work that I had done on hypothetical accident,
() 24 flow blockage type calculations, and the e ffect on fuel 25 assemblies.
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1 Faist 17 2 Q Just so that I don't get lost: In other 3 words, you're amending your prior answer where you had 4 said you hadn't studied the effects of s aturation on 5 heat transfer?
(
6' A I hadn't remembered that until you asked O
7 this question.
8 Q In any of your analysis of saturation
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9 occurring in the reactor coolant system, did yo u e ve r 10 consider the e f fe cts of saturation on pressurizer 11 water level?
12 A No.
13 Do you know of anyone in the thermal Q
14 hydraulics engineering section who considered the 15 ef fe cts of s aturation in the reactor coolant system on
~
t 16 press urizer water le ve l?
17 A I don' t know o f anyone that did that.
18 Q Have you ever learned that any such analysis 19 was done prior to the Three Mile Island ac'cident?
20 A I don't know.
21 Q You don't know o f any such work having been 22 done be fore the Three Mile Island accident?
23 A I don't know o f any .
ID 24 Q You learned as a result o f the Davis-Besse d
25 Septembe r 24, 1977 transient that saturation'in the
1 Faist 18 b
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2 reactor coolant system had pushed pressurizer water s
3 level up, didn't you?
4 A Yes.
5 Q Kad you ever heard of any other transient 6 occurring at a B&W plant in which saturation in the 7 reactor coolant system had pushed pressurizer water 8 level up?
9 A No.
10 Q Kave you ever heard of any (incident in any 11 p ressurized wate r reactor where saturation in a 12 reactor coolant system had pushed pressurizer water
(~)> >
13 level up?
~
e 14 A No.
15 Q so at the time that you heard of that 16 phenomenon occurring at Davis-Besse, th at was the first 17 time that you heard of it occurring; is that right?
18 A
, That was the firs t time I heard of 19 s aturation conditions in a reactor cooling system 20 raising press urizer level up. That is not the first 21 time I heard of a reactor cooling system.
22 Q Prior- to the Davis-Besse September 24, 1977 l
l 23 event, have you ever heard of saturation occurring in a I 24 O) B&W reactor after fuel loading?
25 A Yes.
1 Faist 19 2 Q Which instances?
3 A Let me correct that. It was prior to fuel 4 loading. It was during hot f unctional .teiting,
( 5 Q so would you answer my question? Let me 6 put it again: Prior to the Davis-Besse Septembe r 24, 7 1977 transient had you ever heard of an occurrence of 8 saturation in the reactor coolant system of a B&W 9 reactor after fuel had been loaded?
10 A No. ',
11
- Q Prior to the Davis-Besse September 24, 12 1977 event had you ever heard of an instance in which O
13 pressurizer water level rose while reactor cool.abt 14 system pressure fell?
15 A No.
16 Q Prior to the September 24, 1977 transient 17 at Davis-Besse did you regularly receive reports of 18 transient's occurring at B&W nuclear plan s?
19 A First of all, de fin e the term " regularly."
20 Q Routinely. Was it part o f the memoranda 21 and reports which were regularly routed to you for you 22 to be advised of abnormal occurrences or transients 23 at B&W nucle ar plants ?
fv 24 A I received reports. I don ' t know how 25 regular you can define that.
1 Faist 20 s .
)
C_/ .
2 Q To your knowledge did B&W have any sys tem 3 for regularly writing up the occurrence of abnormal 4 e ve nts at B&W-designed nuclear plants?
]( ) 5 A Yes.
6 Q What was that system?
I . 7 A The site problem report.
8 Were you on the regular distribution for Q
9 site problem reports?
10 A I received site problem r e p'o rt s from some 1
11 sites.
I did not receive site p robl em reports from 12 all sites, and I did not receive all s te problem n#
\- 13 rep o r ts .
14 Q Other than site problem reports did B&W 15 have any other regular typ e of communication that it 16 c re a ted that summarized the occurre nce of transients?
17 A Site instructions were sometimes used to 18 relay information to the field pe rsonnel.
19 Q Was a site instruction, a procedure whereby 20 B&W field representatives were asked to communicate 21 information to their respective owners?
22 A Site instructions weren't necessarily 23 directed towards field personnel. They sometimes were C 24 directed through project management to transmit.
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25 Q Was it the function of a site instruction
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1 Faist 21
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2 that the B&W recipient of it was supposed to communicate 3 its contents to the owner of the B&W plant to which 4 that B&W employee was assigned?
( 5 A Yes, the respons ible party for that site 6
instruction was to communicate either verbally or in 7
w ri tin g to the owner or the utility that he was working 8 with.
9 Q Before the Three Mile Island accident did 10 B&W have occasions on wnich they would pall together i
11 most or all of their principal site rep re s entative s ?
rx 12 A
(, I can only talk in terms of the period of 13 time when I was a resident engineer af ter the TMI-2 14 incident.
15 i Q Let me refer you to the period when you were 16 site operations manager. During that time did B&W 17 convene any meetings for some or all o f its site 18 operations managers?
19 A I don't recall being involved in any meet-20 ings invol ving all site operations managers.
21 Q Do you recall being involved in meetings L
22 for some site operations manage rs ?
23 n
A Only a site operations manager in --
as I'
i' 24 boss, particularly myself and my boss. I don't recall 25 any occasion where specifically mee ting with other site
1 Faist 22 5
V 2 operations managers or their meeting with others.
3 Q What was your understanding as to why some 4 site problem reports were routinely s ent to you from (I 5 particular sites?
t 6 A My understanding was for in fo rma tio n , and 7 if there was something pertinent in that SPR that may 1
8 be applicable to the customer, I was working with to 9 at le as t in fo rm that cus tomer of a particular incident 10 or event that may have happe ne d elsewhe're.
11 Q Did you regularly read the site p roblem 12 re po rts that were sent to you?
. 13 A Yes.
14 Q When there was something that had happened 15 at another plant which was applicable to the plant 16 where you were working did you inform the owner or 17 operators of the plant whe re you were working?
18 A If I thought something was applicable to 19 the plant that I was working at, I would inform the 20 owner of the potential, and it would -- between himself 21 and his s taff try to make that-evaluation. They are 22 certainly more familiar with the plant th an I am.
i 23 Q In informing the owners or operators of (A) 24 the plant where you were assigned did you always do it 25 in writing or did you sometimes do it orally and sometimee e m. ,wi- + "
y y,- y
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1 Faist 23 2 in writing?
3 A S metimes in writing. Sometimes just 4 orally.
Q Were the site problem reports the best
( 5 6 source of information that you had about problems of 7 generic applicability affecting equipment within the 8 B&W scope of supply?
L 9 A You are making a statement that site 10 problem reports that I received are gederic 11 app licabili ty . -
12 Q No, I am not; and thank you f or raising
\- 13 that.
14 MR. WISE: Let him finish. Let Mr. Fais t 15 finish what he has to s ay and then you can t
16 rephrase the ques tion if you like .
17 A site problem reports are not by all means 18 generic. I re ceive site p roblem rep o rts for information 19 and for me to pursue those or look at those, I make a 20 de termination if we potentially have the same problem, 21 and they certainly are not gene ric across the board L 22 for all plants.
23 Q You would review the site p roblem reports 24 to see if the problem which it was describing had s
25 applicability to your plant; -right?
l 1 Fais t 24 2 A Yes, I would look at that.
3 Q And y uw uld be looking for an applicability 4 to your plant even though the site problem report had
( 5 riginally been written about a problem that had arisen at an ther B&W plant; right?
6 A Yes.
7 8 Q Were the site problem reports your best g source of information about problems which had arisen 10 at other B&W plants which might be appI,1 cable to the 11 plant at which you were assigned?
12 A I would have to say no on that. Site O 13 problem repo rt s were not by any means written on every 14 transient or problem. And there was quite a bit of 15 verbal communication between the Lynchburg home office 16 and myself.
17 Q When you use the word "ve rbal;' do you me an 18 oral?
19 A Yes. '
20 Q Among the source of information that you had
. 21 ab ut problems at one B&W plant th at migh t be i
22 applicable to the particular B&W plant to which you l
23 were assigned, were S PR' s an important source of that 24 type of info rmation?
25 A I would have to s ay that e ve ry thing that I l
1 Faist 25 O
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2 re ceived was treated in re tros pe ct on an equal basis.
3 All sources of information, whether hone communications 4 o r S PR 's or site instructions were sources of information
(, 5 that you tre ated equally.
6 Q Did you get telephone communications from 7 other B&W site rep res e ntative s ?
8 A I'm sure at sometime during my courses being 9 in the field, I talked with other nite operations 10 manage rs . ',
11 Q Let me re fine the question. Focusing just 12 on gaining information about problems at anothe r plant
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13 that could be. applicable to th'e plant wh'ere you were 14 assigned, from whom were you getting telephone 15 c ommuni ca tio ns ?
16 A P rimarily the Lynchburg home office.
17 Q Who in Lynchburg was originating those 18 calls?
19 A Primarily Bill Spangler, my boss.
20 Q During the time that you were site
. 21 operations manager at Davis-Besse, with what f re quency ,
22 speaking app roxima t ely , did you get calls like that 23 from Bil1 Spangler?
m
() A I spoke with Bill Spangler every day. It 25 was not ne cessarily with regard to events at othe r
1 Faist 26 Nm-2 sites. The p rimary purpos e was to dis c us s the status 3 of Davis-Bes se during s tart-up.
4 Q Was it part of your daily routine to speak
( .5 with Bill Spangler on the telephone?
6 A Yes, it was.
7 Q Did you call him or did he call you?
8 A I usually called him.
9 Q Was it your unders tanding that all site 10 operations managers were expected to phone in to Bill 11 Spangler once a day?
(~'
12 A You would have to talk to Bill Spangler.
)
13 I don't know what his requirements were for the other 4
14 site m anage rs .
15 Q Kave you ever heard that any other site 16 manager reported daily over the telephone to Bill?
17 A I can't say whether other site managers 18 reporte d daily.
19 Q In the daily conversations that you had with 20 Bill Spangler, he from time to time told you about 21 problems that had arisen at other B&W plants ? Is that 23 right?
-m 23 A He would sometimes tell me of events at
_- 24 othe r plants , not necessarily describing the problem.
25 Q When you s ay "e ve nts , " do you mean an
i l
l i i Faist 27 O
?
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2 abnormal e vent?
i 3 A I migh.t talk about anything from ar equipment 4 f ailure to possibly a transient.
( 5 Q Did Bill Spangler ever say to you this is 6 an equipment failure or a transient that arose at another 7 B&W plant, this is something that you ought to be 8 watching out for at your plant?
9 A Bill Spangler talked abo ut problems , and I 10 took the initiative based on his phone Icalls to check 11 into it in our plant.
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12 , Q Was it your unde rs tanding hat Bill
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13 Spangler was taking the t ro ub le to tell you about 14 problems at othe r plants , so that you could check on 15 whether those problems had applicability to the plant 16 where you were assigned?
17 A Not necessarily. Sometimes those are just 18 in fo rma tio n-o nly typ e discussions.
19 Q Did you unders tand that at least some of 20 the problems that he was telling you about at other 21 plants were problems he was describing to you so that 22 you could describe whether they were applicable to the 23 plant where you were assigned?
I s_/ 24 A In come cases, yes.
25 Q In your daily conversations with Bill
,_s 1 Faist 28
)
2 Spangler, did you describe to him any unusual events 3 that occurred at Davis-Besse?
4 A Yes.
( 5 Q Did you eve r s ugges t to him that any of 6 those events were events which should be related to 7 B&W rep re s e n ta ti ve s respons ib le for othe r plants ?
8 A I pass information back to Bill Spangler 9 with regard to problems and situations that wc had at 10 our plant at Toledo Edison. We would thave sometimes 11 dis cussions with regard to what happened, the details
,/~1 12 o f whi ch , and for the most part we would follow th at u-13 up with a site problem report and the site problem 14 report would normally be the mechanism to pass this 15 information on officially to Lynchburg.
16 Q To what if any extent did you receive 17 anything like or related to control room operator 18 training?
19 A I participated in some o f the operator 20 training courses and simulator courses.
21 Q Did you participate in all or any of those 22 before the Three Mile Island accident?
23 A I participated in th os e be fore the Three (m
l Mile Island accident. I participated in simulator 24 25 training after the ac ci ddn t as well.
1 Faist 29 2 Q Approximately how long were you engaged I
3 in operator training courses other than in the l 4 s imul ato r?
5 A That was quite sometime ago, and I don't
{
6 recall the exact length of time that I was involved.
7 Q Well, just to put some oute r bound on it, 8 could you say you know it wasn't more than, and can give 9 me a numbe r o f months or weeks?
10 A Are you asking for the time'~. I spent in i 11 classroom or the duration of time that I was involved, 12 the total involvement?
! s e) 13 Q The total involvement.
14 MR. WIS E : Is it cle ar to you what is 15 being asked?
].
16 THE WITNESS:
, I understand th a t the duration 17 of my involvement, meaning -- whether that be 18 a part-time basis, I don't consider it a full-time f
19 basis. I conside r it p art-time. Perhaps a week 20 here, a week there. Like ove r a pe riod of a year i 21 and a half.
22 l Q In addition to clas s room training what
!~
23 othe r nonsimulator training did you have be fore the 21 Th re e Mile Island accident?
25 A on what s ub j e cts ?
] 1 Faist 30 p -
{ 2 Q Training that is in any way like or related j
3 to control room operator training.
4 MR. WISE: I object to the form of that.
5 You may answer it if you can figure out
.[ (
, 6 what it is that you are answering.
! 7 A I inte rp re t that to mean what classroom i
8 sessions and simulator training I have had prior to 9 Three Mile Is land , and I have given that answer. I 10 don' t know o f any or recall of any other times or any I
- 11 other training courses that I participated in it that i
j 12 were direct operator-training programs .
13 Q We re the training courses that you took a .
1 14 week he re , a week.there, courses that were given by 15 the Training Department at Lynchburg?
16 A I can't say the training program was in
}
17 charge of all of these training programs., This'is in=
18 the ve ry early. seventies and I am not sure if I-19 remember whe ther it was entirely training 'rogram'or p 20 some field service i nvolve men t , but there was also l
, 21 engineering. personnel te aching some of these courses.
' k.
- 22 I don't know who or recall who was totally responsible 23 for coordinating all the time.
( 24 Q Were the training programs in which,you 25 participated programs which were conducted.just for B&W l 4
- , - - . . , - . _- , -. . - . - - . . - - . , . .. . - ,._..,.. , -.- -- - ..\
1 Faist 31
()h 2
employees?
3 A No.
4 Were there customer personnel sitting in on Q
( 5 the same classes that you were in?
6 A Yes.
7 witen you went to the simulator were there Q
8 customer personnel engaged in the simulator training 9 simultaneously?
10 A No, my simulato r training dps s tri ctly B &W 11 pe rso nne l .
12 Q About how much time did you spend in O 13 simulator training before the Th re e Mile Island accident?
14 A About 4 0 ho urs , 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of class room 15 related to simulator and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of simulato r, e
16 Q Approximately when did you take this 17 simulator training? -
18 A I don't recall, but I know it was the 19 early se venties .
20 Q Was the simulator training that you 21 received something that you understood was like the 22 simulator training which B&W gave to c us tome rs operating 23 personnel?
() 24 MR. WISE: I object to the form.
25 The witness may answer it if he can.
t t
t i
i t
1 Faist 31-A i 4
l-i 2 A I can't attest to what the training was on
! 3 the simulator for operators. So I can't compare that.
i 4 (Continued on Page 32.)
l-( 5 6
i
! 7 i
i 8
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i 10 t 11
, 12 l
13 4
- 14 1
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15
! 16 15
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- 18 l-19 j 20 2l !
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- 24 25 l l
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I 1 Faist 32 I 2 Q Are you saying that nobody ever told you 3 and you never gained any impression whether what you 4 were receiving on the simulator bore any resemblance
~( 5 to what operators received when they came for simulator 6 training?
7 A I don't know what operators received.
8 Q And nobody ever told you what they got?
9 A Specifically, no. I know they had simulator 10 training and I know they had classroom. training.
11 Q Are you aware that after the Three Mile 12 Island accident, the Lynchburg simulator was reprogrammed O 13 so that it could simulate the response.of the reactor 14 coolant system to the type of upset that occurred during 15 the Three Mile Island accident?
+
16 A Yes.
17 Q' Are you aware that prior to the Three Mile 18 Island accident, the Lynchburg simulator could not have 19 simulated what happened during the Davis-Besse 20 September 24, 1977 event?
21 A I could not attest to what the simulator 22 could or could not do before the Davis-Besse' event.
23 Q I think you have jumbled the time period
, 24 that I was talking about. Do you.know as you sit here 25 today that between September 24, 1977 and March 28, 1979
s I
1 Faist s 33 I() I 2 the Lynchburg simulator was incapable-of reproducing the s .. .
3 principal features of the Da'vis-Besse September 24,
! 4 1977 transient?
( 5 A I had no knowledge of what the capabilities s '
6 were of the simulator to simulate any specific transie~nt.
7 Q You are putting your answer in the past 8 tense. I am asking you today, are you aware that before 9 the Three Mile Island accident, the Lynchberg simulator i
10 could not simulate all of the principal, feat'ures of he -
, - 3 11 Davis-Besse transient? In other words, have you over A
12 come to know that the programming was' incapable of O 13 reproducing the Davis-Besse event? ,
1 A
l $
14 No.
15 Q Have you ever come to know that it was ,,
x
~
( *.
16 only after the Three Mile Island accident that the 17 simulator was capable of showing saturation' or boiling
. ' %q 18 occurring in the reactor coolant-systnm outside the-s s.N 19 pressurizer? "
i 20 A I know they made changes. I don't know , ,
,~%
21 what changes. I don't know h'ow close a simulation you 22 are referring to. You have asked a question thatisays 23 simulator can simulate. To what degrao\of simulaticn? ,
O .. . i
() 24 Q Let's break it down into, smaller pieces.
s se g *.
25 saturation is a synonym for boiling,"right, o
s J \
< s
. _ _ , , . - . . . , . -m. -
, - - - . , , _ - . -,-_.m. . . . _ . - , + , . , _ . .
1 Faist 34 2 pot boiling, pool boiling?
3 A Yes.
4 Q Saturation occurs at a conjunction of 4
temperature and pressure, right?
l ( 5 i
6 A Yes.
1 l 7 Q For any temperature, there is a unique 3
8 pressure which produces saturation?
9 A That's correct.
1 10 Q Have you ever learned befobe today, and
!r 11 other than from an attorney, that the B&W simulator did i
12 not have in its cerebrum anything which would tell it
(~% ,.
\~ 13 to show saturation occurring when the -temperature e
14 pressure combination was such that a steam table would 15 show saturation should be occurring?
16 MR. WISE: I object to the form.
l 17 The witness may answer it if.he understands 18 it.
19 A I did not know the specifics of what the 20 simulator could do in that detail.
1 21 Q You say "I did not know." At what prior 22 point in time are you referring when you used the past 23 tense in your last answer?
/~
'( 24 A As resident engineer of Three' Mile Island, 25 I was made aware that there were simulator changes being
1 Faist 35 2 made. The specifics of those changes,I couldn't tell 3 vou what they were, so I cannot attest to what that 4 simulator could simulate after or before.
i l 5 Q Have you ever heard that the simulator had 4 6 to be reprogrammed in order to model or demonstrate a I
7 reactor coolant system going solid?
- 8 A Again you are asking the specifics about g that?
10 Q That's right. I am asking t one specific. I 11 am not asking for a plethora. I am not asking for all 12 that you know. I am just asking for one specific.
~h (V 13 Did you ever hear that the Lynchburg simulator had to be i 14 reprogrammed after the Three Mile Island accident in 15 order to model a reactor coolant system going solid?
16 A I never heard of any changes that had to be 17 made to do something specifically. I have heard 18 changes were made to refine the system. I don't know 19 what specific changes.
20 Q Is the answer to my question "No"?
21 MR. WISE: I think he's given you the answer 22 to the question.
23 A I don't know what changes were made, so I
( 24 can't answer your question to that specific subject or 25 any other changes that were made to the simulator.
n .-, , ~ , - ,. ,.,- --=w - - , - - - - - -
-4 + -e .
- 1 Faist 36 O 2 Q Before the Three Mile Island accident while 3 you were still at Davis-Besse, were you ever consulted 4 on the content of any training program for any
( 5 Davis-Desse operators?
6 A No.
~
7 Q According to a regular report which you 8 issued from the Davis-Besse site during the week or two g weeks after this September 24 event, you indicated 10 that Norman Elliott had visited the day,is-Besse site on 11 or about September 26. Did you meet with Norm Elliott 12 at that time?
13 A I don't recall the report you are talking 1
- 14 about and I don't ever recall meeting wi h Norm Elliott.
15 Q Let me ask you about whether something was 16 your regular practice.
17 When managers from B&W Lynchburg came to the 18 Davis-Bosse plant while you were site operations 19 manager, was it your regular practice to.see.them and 20 talk to them?
l 21 A When any B&W personnel came to the site, it 22 was desirable for them to meet with us. It was not a 23 requirement. Quite often the customer would bring in
() 24 B&W personnel directly and there are times we wouldn't 25 even see them.
l
1 6 1 Faist 37 2 MR. WISE: Off the record.
3 (Discussion off the record) 4 Q You regularly prepared a site office report
( 5 when you were SOM at Davis-Besse, right?
6 A Yes.
7 Q And among the data that you listed were who 8 had been the visitors to the site, right?
9 A That's correct.
10 Q Let me show you what we wil,1 mark as GPU 11 Exhibit 487 and ask you if this is a copy of a site 12 office report which you prepared on or about October 10, O 13 1977-14 (Babcock & Wilcox site offic report dated 15 10/10/77 marked GPU Exhibit 487 for identification, 16 as of this date.)
17 A 'In my b e s t recollection, I p r.e p a re d , ,I am 18 sure, part of this report.
19 Q To the extent that there are any parts which 20 you did not prepare, were they prepared for you and 21 under your direction?
22 A When you say " direction," I signed off and 23 issued the report after reading it. I did not provide
() 24 specific direction to anyone that may have written it.
25 Q At the time that you read it and signed off j l
l
1 Faist 48 2 on it, I take it you believed that the information 3 contained in it was accurate, is that right?
4 A I would assume that at the time it was
( 5 correct.
6 Q The list of visitors on page 5 is a list of 7 people who had come to the Davis-Besse site between 8 September 16 and October 7, 1977, is that right?
9 A That's what it says.
I 10 Q And you believe that it ista correct 11 representation of those facts, right?
12 A I couldn't attest to that because the 13 visitors section is not prepared by me.
14 Q At the time that you included it in the 15 report which you signed, did you believe that the 16 information that it contained had been gathered in a 17 responsible manner and that the'information should be 18 accurate?
19 A It was gathered in a responsible manner and 20 yes, it should have been accurate.
21 Q so, among other things, you believe that 22 Norman Elliott, the manager of training for B&W, had 23 been at the Davis-Besse site on September 27, 1977, right?
[R.)T o4 25 A That's what this document says.
1 Faist 39
(\-J.
2 Q And you believe that that is accurate, right?
3 MR. WISE: Does he believe today that it's 4 accurate or are you asking him did he think about
( 5 it at the time and pursue it to find out whether 6 or not it was accurate?
7 You are asking two different questions and 8 you switch from one to the other.
9 Q All I am trying to find out is, do you 10 believe, based on methods of reliable 1,nformation 11 gathering which was used to prepare the visitors section
'T 12 and based on the review and signing which you gave to
[O 13 this, that Norm Elliott was'at the Davis-Besse site 14 on September 27, 1977?
15 MR. WISE: I don't know if this point is 16 worth belaboring; if he has any recollection, Mr.
17 Seltzer. .
18 MR. SELTZER: I am not asking for any 19 independent recollection of whether Norm Elliott 20 was there.
MR. WISE: l 21 If he has any independent 33 recollection of whether Norm Elliott was there, you 23 are perfectly able to get that. You have a
() 24 document here which he says he didn't prepare the 1
1 25 portion which relates to visitors. We can all )
1 Faist 40 l 2 read it and see that it says that Norm Elliott )
3 visited the plant on September 27, 1977.
4 If you are asking the witness if he can read l 5 that and sees that there, that's fine. If you are 6 asking him if he has any reason to believe that's 7 incorrect, that's also fine. If you are asking 8 more than that --
9 MR. SELTZER: Let me ask the question.
10 BY MR. SELTZER: 1 11 Q Do you have any reason to believe that the 12 statement of B&W that Norm Elliott was at the Davis-13 Besse site on September 27, 1977 is in any way incorrect 14 or inaccurate?
15 A I can't attest to whether it's right or not.
16 Q Do you have any basis to believe that it's 17 inaccurate? Is there any fact that you can put on the 18 table from which you conclude that that fact is not true?
19 A No, I can't attest that it is true or isn't 20 true.
21 MR. WISE: He is asking you a different C question, Mr. Faist.
22 He simply wants to know, do 23 you have any information or knowledge today, O)
( 24 sitting here, which leads you to believe that what 25 is said there is wrong?
i l
0 1 Faist 41 I
2 A No.
3 Q Now, you previously testified that you 4 believe that the information on the list of visitors was l 5 gathered in a responsible manner.
6 A Yes.
7 Q When you said that,that would include the 8 information that Norman Elliott was at the Davis-Besse 9 site on September 27, 1977, right?
4 10 A Yes. 1 11 Q Do you see the phrase after " Norman Elliott 12 B&W," " Audit for Isley"?
13 A Yes.
14 Q What, if anything, does the phrase " Audit 15 for Isley" mean to you?
16 A I know Tom Isley was involved in training 17 for Davis-Besse. Norman Elliott is invol.ved in training 18 for B&W, and I assume they were conducting some sort 19 of business between them.
20 Q Isley reported to Jim Hickey, the head of 21 Toledo Edison training?
22 A I don't know if Jim was his direct 23 supervisor or not.
() 24 Q Isley was subordinate to Hickey in the 25 Toledo Edison organization, is that right?
f
- , , - - -- , , y --
. =.
1 1 Faist 42 2 A I know Tom worked for training. Who 3 specifically -- and I know Jim Hickey worked for 4 training. I don't remember their capacities.
( 5 Q You know Hickey was higher than Isley?
6 A Yes.
7 Q That's all I meant by " subordinate."
8 MR. SELTZER: Let's take a break.
9 (Recess taken) 10 BY MR. SELTZER: I 11 Q A year ago when Norm Elliott was deposed in 12 this lawsuit, he testified that you and he had met on 13 the occasion 'of his September 1977 visit to the Davis-Besse site and then he went on to describe some of the
~
14 15 things that you and he had discussed.
16 Do you recall that you did meet with Norm 17 Elliott at the time that he visited the Davis-Besse site 18 shortly after the September 24, 1977 transient?
19 A I don't recall ever talking with Norm Elliott 20 at Davis-Besse or him even being on the site.
21 Q Whom do you recall cc:.ing to the Davis-Besse 22 site from Lynchburg shortly after the September 24, 23 1977 transient?
4 O A Immediately after the transient was Joe i j. 24 25 Kelly.
62 1 Faist 43
/~' ,
l fk m .
2 Q Anyone else?
3 A Sometime later in the week, of course, some 4
4 engineering people and some project management people.
i l ( 5 Q Did anyone tell you that Joe Kelly was 6 being sent to the site before he arrived?
7 A Yes.
8 Q Who told you?
- 9 A Bill Spangler.
t 10 Q What did you understand was,the purpose of 11 Kelly's visit?
i i
- 12 A To help gather data on the September 24 i 13 transient. -
i 14 Q Did you work with Joe Ke lly in gathering
) 15 data on the September 24 transient? '
4 <
16 A For the most part, on and off with him, 17 but he was primarily responsible for getting that data 1
j 18 while I did some of my normal other functions.
i .
19 Q .What is your best recollection about what ,
20 you and Joe Kelly did to gather data on the September 24 2,1 transient?
22 A I recall looking at some of the plots and 23 graphs that Joe put together, some general discussion on i
'/~T
- (_). 24 what he ha'd been gathering. I 25 -Q Had he obtained copies of the reactimeter i.
13 1 Faist 44 2 plots generated during the September 24 transient?
3 A Yes, they were available to him.
4 Q Were the control room logs available to him?
( 5 A I don't know if he got copies or reviewed 6 the control room logs.
7 Q Prior to the training room B lecture'that 8 you and Joe Kelly gave back in Lynchburg, what Davis-9 Besse personnel did you speak to regarding the September 10 24 transient? (
11 A And the training roomlecture you are
- 12 referring to is the one on Wednesday following the i
13 incident? ,
i 14 Q Right.
15 A The only conversations I recall specifically 16 having were with Lynchburg people on Monday following 17 the incident. .
18 Let me finish.
19 There is also a phone call on the Sunday to 20 Lynchburg.
21 Q That's not really responsive, because I.had 22 asked you what Davis-Besse personnel you spoke to 23 regarding the incident before you went to participate 24 in the training room B lecture.
25 Do you recall that you did speak to some
I i 1 Faist 45
~ l l
'\_) '
2 Davis-Besse people sbout the incident before you went )
3 to deliver the lecture?
4 A I don't recall who I spoke to.
( 5 Q That wasn't the question. Do you recall that 6 you did speak to some Davis-Besse people?
7 A Yes, I spoke to some Davis-Besse people.
8 Q Do you recall that you spoke to some 9 Davis-Besse people who had been in the control room 10 during the September 24 transient? I 9
11 A Yes, but I don't remember the time frame 12 that was.
,r m
( ) -
13 Q The time frame in which you spoke to them or 14 the time frame in which they were in the control room?
15 A The time frame in which I spoke to them.
16 Q So you can't testify today whether you spoke 17 to them before the training room B lectur,e or after?
18 A That's correct.
~
19 Q You spoke to Mike Derivan, right?
20 A Yes.
21 Q He was the shift supervisor at the time of 22 the transient?
23 A Yes.
(ol v 24 Q Did you speak to Terry Murray, who was the 25 assistant station superintendent and had also been in
l 15 1 Faist 46 2 the control room?
4 3 A I d n't remember specifically talking with 4 Terry. I remember Terry talking to a group of people which I was part of.
l( 5 6 Q He was talking about the September 24 7 transient?
8 A Yes.
- 9 Q Whom else from Davis-Besse do you recall 10 talking to or hearing talk about the September 24 11 transient other than Terry Murray and Mike Derivan?
12 A Jack Evans.
13 That's really all I recall. -
14 Q Jack was a station superintendent?
15 A Yes.
16 Q After the september 24 event, you know that 17 Toledo Edison prepared an LER, a licensee, event report, 18 right?
19 A, No, I didn't know they prepared one.
20 Q Do you know today that they prepared one?
21 A I know today that they prepared one, yes.
22 Q so why did you'say that you didn't know?
23 A I knew it -- I didn't know it at the time.
() 24 Q When did you come to know that they had 25 prepared an LER?
16 1 Faist 47
(~
V) A In discussion with counsel, for the 2
3 preparation of this.
4 Q Weren't you aware that in October or November l 5 1977 B&W was supplying Toledo Edison with textual 6 material and graphs to be used in a licensee event 7 report relating to the September 24 transient?
8 A I can't recall what exactly was supplied.
9 Q Are you aware that during the time that you l 10 were site operations manager, Toledo Ed,ison submitted 11 licensee event reports to the NRC relating to the Davis-12 Besse plant?
f_
13 A I knew they submitted LER's.
14 Q Was it part of your practice as site 15 operations manager to get copies of any LER's that were 16 generated by Toledo Edison at the time you were site 17 operations manager? >
18 A If I was aware of them, I would get a copy.
19 It was not necessarily true in all cases, though.
20' Q How do you know it wasn't true in all cases?
21 A LER's are sequentially numbered. I obviously l k
22 did not have a file of all LER's. That was a customer 23 document.
(~h
(_) 24 Q You say "obviously I didn't have a copy of !
1 25 all the LER's." From what do you draw that conclusion? j
I 7 1 Faist 48 f%
N 2 A They are sequentially numbered. If I had 3 an LER number, a certain number, obviously the customer 4 has submitted others prior to that or after that. They
( 5 continue to issue LER's and number them sequentially.
6 Q When, if ever, have you reviewed the Davis-7 Besse site file to determine that there were LER numbers 8 missing from the site file maintained during the -time 9 that you were SOM7 10 A I did not maintain an LER d,ite file.
11 Q When did you ever check any file to see
- 12 whether there were sequential numbers missing from
.A 13 . LER's supplied by D' avis-Besse to your ffice when you
, 14 were SOM?
15 A It was not my practice to obtain a file and 16 a log of all the LER's.
17 Q All I am trying to focus on is, you said 18 that obviously you didn't get them all because they were
~
i 19 sequentially numbered. From that, I deduced that you 20 must have thought there was some time when you compared 21 the numbers on the LER's that you did have and found 22 that there were gaps in those numbers.
23 Now I am just trying to find-out when, if
((m) 24 ever, do you recall making t h a't analycis of the LER's 25 that were in your possession or accessible to you?
I I
l l
18 1 Faist 49 f~%
d MR. WISE: I am going to object to the form.
2 3 I think that probably everybody in this room can 4 figure out other ways in which he could have como
() 5 to the conclusion than the one specific one that 6 you put to him. If)te can answer the question in 7 his own words and simply tell you what it is that 8 leads him to believe that he didn't get all the g LER's, he may do so.
10 BY MR. SELTZER: (
11 Q I want to focus on your answer that it was 12 because they were sequentially numbered that you knew 13 you didn't have all of them that were generated while -
14 you were SOM, and I want you to explain w' hat the i
15 relationship is between the sequential numbering and
=.
16 your conclusion that you didn't have all that were 17 issued while you were SOM. .
18 A It was not necessary to have copies of 19 every document that the customer ever produced, LER's
, 20 included..
21 Q I am not asking whether it was necessary to.
i 22 MR. WISE: Mr. Faist, I think the question I
r 23 is probably simpler-than you are making-it or that ;
i
- 2 0( j 24 Mr. Seltzer is making it appear.
l 25 He simply wants to-know why it was you j l
l l
. . . _. , ~. , . _ . _,- .. . . , - - -
f 1 Faist 5a j 2 deduced you didn't have them all from the fact 3 they wera sequentially numbered, and it seems like 4 a very simple question, but believe me, that's as
( 5 aimple a question as he's asking.
6 MR. SELTZER: I think your counsel has 7 restated verbatim what my question was to you.
8 A LER's that I had in the site office or had 9 got copies of because they related to different subjects 10 and they were not periodically fi ven to,me by the 11 customer. I had no means of keeping track and upon 12 reviewing or looking at what the customer is issuing to 13 the NRC, one can easily tell if he is missing or the 14 customer has issued documents periodically.
15 Q Did you ever look at the LER's that you 16 did have and determine that there were LER's that you 17 didn't have? ,
18 A Yes.
19 Q Have you ever made 'any examination of the 20 files that were maintained while you were site operations 21 manager to determine whether you had received a copy 22 of the LER for the September 24, 1977 event?
23 A I didn't even know one was written, so I 24 couldn't ask for one, and I would not have been 25 normally given one.
20 1 Faist 51 O
h.
2 Q You wouldn't normally be given one if you 3 didn't ask for it?
4 A If I knew an LER existed on a specific
( 5 subject or so or someone had told me that they were 6 writing an LER on a specific subject and if I had asked 7 for it, I would have gotten a copy of it.
8 Q By the end of September 1977, you knew that 9 during the initial minutes of the September 24 transient l
10 the Davis-Besse control room personnel ,had shut off 11 high-pressure injection when they saw the pressurizer 12 water level rising above its normal range, right?
O 13 A I realized that they had terminated HPI when 14 pressurizer level was increasing above its normal 15 range.
16 Q And you knew that was something they had 17 done within the initial minutes of the transient, right?
18 A Yes.
19 Q You also knew that they had shut off or, to 20 use your word, terminated high-pressure injection at 21 a time when pressurizer level was rising but before 22 reactor coolant system pressure had stopped declining, 4
23 isn't' that right?
rh
(_,) 24 A I don't remember exactly. I would have to 25 take a look at the parameters. I don't recall what all l
l
. _ _ . _= - _ . . _
1 Faist 52
['T ~
V 2 the parameters were doing at that instant.
3 Q Are the parameters to uhich you are referring 4 parameters that were shown in the site problem report 5 which you signed for the September 24 event?
(l 6 A Yes, it would be primarily system plant 7 parameters.
8 Q And they would be in the site problem 9 report that you signed for the September 24 transient?
10 A Yes. (
11 Q Let me show you what's previously been 12 marked as GPU Exhibit 133, which is site problem report O 13 372, signed at the top of the second p ge by F. R.
14 Faist, the date of transmittal, October 1' 1 , 1977.
15 Do you recognize GPU Exhibit 133 as a copy l
16 of the site problem report prepared by B&W for the l 17 September 24, 1977 transient at Davis-Bes.se?
18 A Yes.
19 Q You assisted in the preparation of this, 20 didn't you?
21 A That's correct.
22 Q Were you the person who had ultimate 23 responsibility at the site for the assembly of this site
/~T I problem report?
_j 24 25 A Yes.
!2 1 Faist 53 J
(-s_) l 2 Q So you had to get the descriptions, the l 3 sequence of events and the plots together which compose 4 the site problem report?
(. 5 A I had a responsibility for seeing that it was 6 put together. I had people help collecting some of 7 that information.
8 Q But it was at your direction that the 9 different pieces of this report were obtained and put 10 together to make up the site problem r6 port?
11 A Yes.
12 Q I take it you reviewed it efore it was O 13 disseminated? ,
14 A Yes.
15 Q And you believed it was accurate?
a.
16 A Yes.
17 Q Take a look at page 9 of 85. - Is that the 18 page that is open in front of yo2?
19 A Yes.
20 Q Does that show the plot that you were.
21 referring to in your answer before I marked the site 22 problem report or before I showed you this site problem 23 report?
(O_) 24 A That is one of the plots.
25 Q Does.that~ plot which you opened to yourself l
1 Faist 54 2 before I asked you to turn to page 29 show what was 3 happening to reactor coolant system pressure during the 4 transient?
( 5 A Yes, this is the plot that shows a number of 6 the parameters compared to each other. There are other 7 plots in there that will show that, but not on an 8 overlay.
9 Q Page 29 and page 30 are a continuum of the 10 same plot, right? t 11 A Yec.
_s 12 Q Page 29 has the initial two minutes of the 13 transient and page 30 begins at two minutes and runs 14 just beyond eight minutes, right?
15 A That's what those plots show, yes.
16 Q At approximately four and a half minutes, 17 do you see the notation "HPI pump turned of f"?
18 A Yes.
19 Q Now, you said you would have to look at the 20 plots to see what was happening to pressure at the time 21 the high-pressure injection pumps were turned off.
22 Looking at the chart that you selected, it's 23 a fact, is it not, that pressure was still trending p) qp 24 downward at the time the high-pressure injection pumps f 25 were turned off?
1 Faist 55 rx -
2 A Yes.
3 Q Had you reviewed these plots or plots of 4 this data prior to the training room B lecture?
( 5 A Do you mean I took the raw data and compared 6 that these were plotted accurately?
7 Q No, all I am really asking you is, were you 8 already aware of the data that is reflected on these 9 plots before you participated in the training room B 10 lecture? t 11 A Yes.
12 Q So you knew at the time of the training room 13 B lecture that the. operators had turned off high-pressure 14 injection at a time when reactor coolant system pressure 15 was decreasing?
16 A Yes.
17 Q The pilot-operated relief valve had failed 18 in an open position very early in the Davis-Besse 19 transient, right?
20 A Yes.
. 21 Q It had failed in an open position prior to L
22 the operators terminating high-pressure injection, 23 right? .
1 r
( 24 A Yes.
25 Q Did you know before you participated in
1 Faist 56 O the training room B lecture that it was approximately 2
3 21 minutes ihto the transient before the operators 4 closed the block valve?
( 5 A Yes.
6 Q I take it you also knew before you 7 participated in the training room B lecture that the 8 operators in the Davis-Besse control room did not resume 9 high-pressure injection of coolant until almost half an 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after they had closed the block vdives specifically, 11 28 minutes?
12 A I don't remember the exact time. I knew it 13 was restarted sometime later on into the transient.
14 Q You knew that it wasn't restarted at or 15 about the same time that they closed the block valve, 16 right?
17 A I knew it shouldn't have been- terminated to 18 begin with, and that was obvious from the type of 19 event that was going on, depressurization where the primary system is decreasing and continues to decrease, 20 l 21 operators should have never terminated the high-pressure L
22 injection because of the decrease in RCS pressure.
23 Q And you knew that before you participated
()
O 24 in the training room B lecture?
25 A Yes.
1
- )
i 1 Faist 57 O 2 Q You knew before you participated in the s
3 training rodm B lecture that the operators did not 4 initiate HPI, in other words, turn it bach on until
( 5 they saw pressurizer water level falling below its 6 normal range, right?
7, A Well, you say normal range --
8 Q 220 inches.
9 A 220 inches is the normal operating range.
10 I don't recall what the exict level was, 11 but you can look at the plots as well as I can and 12 determine that.
(~)h
\-
13 Q Which plots would show pressurizer level 4
14 when HPI was reinitiated?
15 A These particular plots that you referred to, 16 29 and 30, dcn't go far enough in time.
- 17 Q Take a look at page 38. Do you see the 18 notation down in the lower right-hand corner, "high-19 pressure injection pumps onto recover level"?
20 A Yes.
21 Q Do you see the line that runs from that 22 notation to the , trace of pressurizer level ?
23 A Yes.
'(O)
, 24 Q Before I-ask you what that indicates, take 25 a look also at page 8 of the site problem report which
l l
1 Faist 58 2 you assembled. Is page 8 part of the sequence of 1
3 events?
t 4 A Yes, it is.
( 5 Q Do you see the notation at 36 minutes, 25 6 seconds?
7 A Yes.
i 8 Q Does that indicate that pressurizer average 9 level was reading low?
10 A It's indicating that it's keading below the 11 low alarm set point.
12 Q And does the next line indicate that at 46 13 minutes and 49 seconds into the transient the operators 14 restarted the high-pressure injection in order to help 15 recover pressurizer level?
16 A That's what this says.
j 17 Q And was it your understanding at the time r .-
18 that you went to participate in the training room B 1
19 lecture that the operators did not restart the 26 high-pressure injection pumps until they believed it 21 was necessary to do so in order to regain pressurizer 1
(- '
l 22 water-level?
23 A No, it's my understanding that.the operations A
(,) 24 people had experienced a LOCA or a small break, a leak 25 of some sort, and had failed to recognize that
l l
1 Faist 59 2 immediately and got confused, and in so getting confused, 3 they were ob'viously not looking at all of the parameters 4 of the reactor coolant system to determine what they
, () 5 should do. Apparently they just looked at one parameter.
6 Q Which parameter?
7 A Pressurizer level.
8 And not taking a look at the total plant's 9 performance and the operation of the plant, looking at 10 pressures and temperatures, and from that they -- their 11 ' narrow view initially caused them to terminate HPI 12 prematurely and reinitiate it for the wrong reasons. It 13 should have never been terminated to begin with.
14 Q You knew that throughout the transient 15 they were regulating,whether high-pressure injection 16 was on or off, with regard solely to pressurizer water ,
17 level, right?
18 A No.
19 Q Did it appear to you --
20 MR. WISE: Excuse me. Let the witness 21 finish his answer.
22 A At the time of the transient, the operators 23 by their actions indicated that they were following
(
\,, -
24 pressurizer level initially. By following and 25 terminationg HPI, they were obviously only looking at
a - - - .__-_.-a_h I
l 1
1 1 Faist 60 g) 2 one set of conditions.
3 In the follow-up in the transient of 4 reinitiating HPI, they apparently made another mistake
( 5 in concluding that they had saturation conditions in 6 the primary system. They recognized the break. They 7 recognized that they did have a leak. They isolated 8 that, but it took some time to figure out that they had g saturation conditions and repressurized the system.
10 Q You say it took them some 6,ime to recognize 11 that they had saturation conditions. When you said 12 that, was it your understanding that i was sometime O 13 after they closed the block valve before they recognized 14 that they had had saturation conditions?
15 A well, my discussions with Mike Derivan, e
16 Mike indicated that he kind of made an error, he made 17 a mistake in the initial part of the transient where he 18 failed to look at all the parameters that were obvious 19 to him and kind of was down upon himself dor not having 20 recognized the problem earlier in the game. He had a
- 21 small break. He had a condition where he should have 22 kept the primary system on -- the HPI system onto the
[ 23 primary system, and initially he failed to recognize
/ 24 that.
! 25 Q Did Mike Derivan tell you that there did l
t
4 s %
u . <
1 Faist 61
(% ~
b 2 come a point when ha even'tual'ly recognized that there s s ,
3 was saturation? ,
4 A Mike in'dicated that he knev Ge had a small
( 5 leak and he shad'depressurized.
s %
He had., indicated that he
, N 6 had a situation whers he -cou,121 get into a situ'atton 7 where he needed HPI. He should have kept it going.
8 He also indicated that if he had followed 9 this procedure, just like he'had, he probably would not 10 have had this problem. THe had been trhined to look at
_ .l 11 all of the parameters in the primary system and realized
~ .
12 a few minutes'into the.tthnsient' that he had not'done O ',
s, .- 1 3
13 what he was supposed to have been doing s and had t'o step -
3 _
14 back and take a d13ser look at everything. And s 15 realizing his mistake,'hefclosed theiblock valve for the I
- 8 g g PORV. ~
16
\., \ '
, s 17 Q I don't thiHk that you.are intentionally 1 s. . e 18 trying to avoid answering my question, but we have had
~
,{..
19 some disputes with opposing.counsd1 about whether 20 witnesses have been responsi e,'and there have been
( 21 22 accusations that witnesses were directly intedding not to respond, and I am not accusing.y,ou,of t h a t', but I w,
~ '
l 23 wish you would listen to my question, and I'would like fm ,
'\~
you to try to answer the question that 1Ns,,kedi <
( s)
~
24 8
s ; , ,
25 MR. WISE: I tifink your comment is uncalled mr <
\ ,
, lx
- s
1 Faist 62 2 for. I would be happy to sit down and show you 3 Mr. Faust's deposition and Mr. Scheimann's 4 deposition or parts of Mr. Zechman's deposition l 5 and Mr. Kunder's deposition, which I think any 6 person reading will understand what the basis of 7 our objections to their nonresponsivness were.
8 Mr. Faist I think has been responsive to 9 your questions and I have not made any objections 10 or attempted to cut you off as sd, frequently 11 happened during the depositions that we attempted 12 to take of GPU witnesses.
O 13 I have no obj e ction to your, continuing to 14 examine this witness and ask him questions, and 15 if you feel that the answer he's given is not 16 responsive to the question that you asked, I 17 permitted you to continte along and.to ask further
- i. .
18 questions.
19 That was not a courtesy that was provided 20 to us during the Faust an'd Scheimann depositions 21 where we were repeatedly met with objections by 22 GPU counsel that the question had been asked and 23 answered and directions to the witness not to fv 24 answer the question again. So I think there is 25 quite a difference.
s
1 Faist 63
[ '1 '
(_) '
2 As I say, I have no objection to your 3 continuing to ask the witness questions, and if 4 you feel that one answer has not satisfied the k, 5 matter that you are looking into, you may ask him 6 another.
7 MR. SELTZER: I reviewed many of the portions 8 of the Scheimann transcript and I saw that your 9 associate, Mr. Wurtz, was permitted repeatedly to 10 phrase and rephrase his inquiries,and there was 11 not any obstruction by GPU's counsel, nor was 12 there any direction not to answer.
be'#
13 I think as the court reporter rereads my 14 last question to you, you will see that I was 15 asking you the question about whether there came 16 a point in time when the Davis-Besse operators 17 recognized that they had saturation.
18 Could you reread the last question, please?
19 (Question read) 20 MR. WISE: Off the record.
21 (Discussion off the record) 22 A I don't remember him saying when he saw it.
23 (continued on next page)
(%
q_j 24 25
1 Faist 64 2 BY MR. SELTZER:
3 Q "Did you get the understanding that there 4 came a point in time when the Davis-Besse operators,
( 5 any of them, recognized that there was saturation 6 in the reactor coolant system?
f 7 A The only operatcr I spoke with was with 8 Mike.
9 Q O. K. That is why I asked it specifically.
10 Did you ever get the understanding frok Mike Derivan 11 or did you ever hear from Terry Murray, whom you heard 12
,O talking about the incident, that there came a point i 13 in time when the people in the control. room recognized .
I 14 that there was saturation?
15 A I know Mike recognized a cond,ition that 16 he had, decreasing pressure and losing coolant to the:
17 system. I don't remember Mike ever sayin'g at such a 18 time in the transient he realized he had aturation 19 conditions.
20 Q Is it-correct that you have no knowledge 21 about whether the Davis-Besse operators ever recognized 22 that they had saturated conditions?
23 A I know later in discussions, they. knew O(,j 24 that the conditions that they had in the system and 25 they were saturated.
-%g %- -a- , - - . , ,, -<c-w- , , - , . , - - ---
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7 r-m?- M -r---T
1 1
f l
1 Faist ,
65
.r U) 2 Q Did you ever hear that during the 3 transient wh'ile they were still dealing with it, they 4 recognized that they had saturation?
( 5 A _I don't recall, like I said, Mike 6 saying that specifically during the transient.
7 Q Do you know that the only thing that 8 induced the Davis-Besse control room personnel to 9 restart high pressure injection was falling pressurizer 10 (
water level? -
11 A I can only speak about conversations that 12 I had with Mike Derivan and him being the shift O
V 13 supervisor at the time he recognized the fact that he t
14 had made a mistake. The primary system was decreasing 15 in inventory. His only means of maintain,ing that 16 inventory was through high pressure injection. He 17 indicated that if he had followed his procedures, he 18 wouldn't have had that.
19 MR. WISE: Mr. Seltzer --
20 MR. SELTZER: I move to strike that as 21 nonresponsive to my question.
22 MR. WISE: Mr. Seltzer asked you a more 23 specific question. Listen to his question. He
( 24 wants to know whether in your conversations 1
25 with Mike Derivan or anyone else, you came to l
1
1 Faist 66 O
V.
2 learn what the reasons were for the operators 3 turning HPI back on at some 46 minutrs into 4 the accident.
( 5 Q I am just asking for your understanding.
S You may include in your understanding, if it is 7 refreshed at all, at page 8 where it says, " Started 8 by operators to help recover pressurizer level. " You 9 may use all that.
10 The question is, did you ga<lp an 11 understanding subsequent to the September 24th 12 O transient that the operators had reinitiated, turned V 13 back on, high pressure injection in resp,onse to t
14 falling pressurizer water level?
15 A Yes, based on the computer sequence, 16 the sequence of events.
17 Q That was your understanding? -
18 A Yes.
19 Q Is it your understanding that when Mike 20 Derivan said he knew that he needed to reinitiate 21 high pressure injection in order to replace lost 22 inventory, he had deduced that he had lost inventory 23 because pressurizer water level was down below its 24 normal range?
25 MR. WISE:
! Could I have that reread?
I
1 Faist 67 2 MR. SELTZER: I will restate it.
3 'MR. WISE: Are you withdrawing that one?
4 MR. SELTZER: Yes.
( 5 Q You said that you had gained certain 6 understandings from Mike Derivan and one of them 7 that you testified to was that Derivan realized that 8 they had to turn high pressure injection back on in 9 order to replace lost inventory.
10 t Is that a fair paraphrasing. of what l 11 you said? -
12 MR. WISE: Part of what he said.
13 A Partly, yes.
{
(
l 14 Q So much as I stated was correct, right? )
15 A Yes.
16 Q Did you understand that when Derivan 17 told you he needed to turn high pressure ' injection l 18 on to replace lost inventory, Derivan had deduced 19 that there had been a loss of inventory from the 20 fact that he observed pressurizer water level falling 21 below its normal ran ge ?
22 A I can't recollect what he deduced 23 specifically to that.
24 Q So you don't know what Derivan was 25 relying on when he concluded that inventory had'been
f I
l 1 Faist 68 l i
t N.
2 lost? In other words, you don't know what indicated 3 to Derivan that the inventory had been losts is that 4 right?
( 5 A I recall Mike indicating that he realized 6 that he had lost inventory through the PORV. Pressure 7 had dropped. Once you lose it, you have to make up.
8 His pressure had' decreased and in recovering from 9 the transient, they increase pressure; increasing 10 pressure in the system would have made up inventory 11 to the system. I don't recall when Mike said 12 specifically or if he said specifically, "Yes, I have
(./
13 to make up inventory."
e 14 MR. SELTZER: I move to strike your last 15 answer as nonrecponsive because I ap not 16 interested right now in how you might have 17 deduced that inventory had been lost.
18 Q All I am asking you is, did Mike Derivan
- 19 tell you how he had deduced that inventory had been 20 lost?
21 A No.
22 t
Q You said that by the time you spoke with 23 Derivan, he recognized that he had made a mistake. i
'(O
_,1 24 Did Mike Derivan tell you when for the first time he 25 re cogniz e d that he had made a mistake in the control 3
_. ._ .~.. __ _
l
l 1 Faist 69 O.
2 room in handling the September 24th transient?
3 A 'w uld y u repeat that again, please?
4 (Record read.)
l 5 A It's about 20 minutes into the transient 6 when the PORV was closed. Sometime prior to that, 7 Mike indicated that something was wrong and he had 8 to reassess what was happenirg and take a look at 9 all the primary conditions and all the parameters to
(
10 determine why the system was responding.the way it 11 did. He assessed at that time that something was 12 wrong and he closed the block valve. He did not O 13 specifically say to me what time in the transient he 14 realized he made a mistake or he recognized his 15 mistake.
16 Q Did he ever indicate to you that his 17 first recognition of a mistake came while*they 18 were still dealing with the transient rather than 19 sometime after the transient was completely over?
20 MR. WISE: I object insofar as your 21 question implies that the previous question 22 was not an answer to this one.
23 MR. SELTZER: Now I think you are 0) g 24 obstructing my examination. This was a 25 perfectly proper follow-up question. If the
1 Faist 70 O' 2 witness wants to suggest anything along the i s I
3 lines-that you are trying to insert, he may.
i 4 But as long as we are talking about I
(' 5 attorneys obstructing, I will make the comment 6 that I wouldn't otherwise make.
7 Q Could you answer my pending question, g please.
9 MR. WISE: Let's have it read back first.
l 10 (Question read.) ',
11 MR. WISE: You should place on the record 12 my objection to the form of that question as 4
4 13 .
being contrary to the record. .
1 14 Q Do you understand the question or do 4
15 you want me to clarify it?
e 16 A Would you clarify it?
17 Q Did Derivan indicate to you that he 18 recognized that he had made a mistake while the 19 transient was still in progress?
i In other words, did 20 he tell you that his recognition of having made a 21 . mistake came to him while they were still trying to i (-
22 deal with the transient?
A 23 No, Mike did not tell me at what time he
() 24 recognized he had made a mistake. Our discussions were 25 that he did make a mistake and he did not specifically
1 Faist 71
'g
'%Y 2 say when he made that mistake and when he recognized s
3 it.
4 Q You knew before you participated in the ,
(: 5 training room B lecture that the operators at 6 Davis-Besse had made a mistake in terminating high 7 pressure injection at the time they did, right?
8 A Yes.
9 Q And you knew it before you participated 10 in the training room B lecture that the, operators 11 had turned off high pressure injection in reliance o n-12 pressurizer level rising and did not turn high 13 pressure injection back on until they saw pressurizer 14 level falling below its normal range, right?
15 A I can't recall, you know, if I had operator 16 input. My discussions with Mike Derivan prior to that 17 meeting were not so. My discussions in that 18 meeting in Lynchburg were based on that p per work you 19 see in that SPR.
20 Q In other words, you knew that high pressure 21 injection was not reinitiated until whatever the 22 number of minutes are after the block valve was 23 closed, as shown by the plots and printout in the O
\j 24 site problem report?
25 A Yes.
4
. . . . . - ~ . - - . - . ~ _ _ - - . . - . - . . - . _ _ _ . - - - .. .-.
I i
1 Faist 71-A
' 2 MR. SELTZER: Why don't we break for 3 lunch.
l I
4 (Whereupon, at 12:45 p.m., a luncheon i
'I
(> 5 recess was taken.)
6 i
7 i
8 i 9 10 .
I 2 , 11 4
i
. 12 M
13 .
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15
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19 1
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! 22
- l l 23 a
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( 24 i
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25 i
(
1 I
1 72 2 AFTERNOON SESSION 3 2:15 p.m.
4 F RE D FAIS T, resumed.
l[ 5 EXAMINATION (continued) 6 BY MR. SELTZER:
7 Q After you learned that the Davis-Besse 8 control room personnel had shut off high pressure 9 injection when pressurizer level was rising and 10 didn't turn it back on until pressurize'r level fell 11 below its normal range, did you check the Davis-Besse 12 procedures to see to what extent, if any, that O 13 method of regulating high pressure injection was ,
4 14 consistent with Davis-Besse procedures?
- 15 A I don't recall checking those.
16 Q Did you ever ask anybody else to check 17 the procedures to see to what extent, if any, what 18 Davis-Besse's operators had done was consistent with 19 procedures?
20 A I don't remember asking or directing 21 anyone to check that.
L 22 Q Did you'ever hear anybody discuss what the 23 Davis-Besse operators had done in terms of whether
(~s t
() 24 their actions were consistent with the procedures?
25 A Yes.
1 Faist 73 (VD 2 Q Whom did you hear discuss it?
3 A Mike Derivan indicated to me that their 4 procedures were correct, they had an abnormal
~
5 situation in which they didn't follow their procedures.
6 Q Which procedure?
'7 A He didn't specifically mention.
8 Q Before the Three Mile Island accident, 9 were you aware that B&W prepared something called i
10 " Limits and Precautions"? *
- 11. A Yes.
12 Q What is your understanding about what j ~
13 function B&W, prepared " Limits and Precautions" for i
14 B&W supplied nuclear plants?
15 A
. Guidelines for limitations on, equipment, 16 operation of equipment.
17 Q Guidelines for the operators 6n how they 18 should operate B&W supplied equipment?
19 . A Guidelines for input to their procedures.
20 Q Were you aware before the Three Mile 21 -Island accident that B&W had prepared " Limits and 22 Precautions" which related to the maximum amount of 23 water that could be put into a pressurizer except under i
(')N
\_ 24 l hydrostatic test conditions?
25 A Maximum amount of water --
l
1 Faist 74
[~i
\n) -
2 Q Level of water?
e 3 A 'Yes, " Limits and Pre cautions" specifies 4 normal water level and tells you what normal
( 5 steam space is.
6 Q Were you aware that B&W had drafted and t
7 circulated to its operators a limit and precaution 8
that said the pressurizer should not be filled solid 9 with water, in other words, completely filled with e
10 water except under hydrostatic test conditions?
11 A I don't remember that. I know I was aware 12 of guidelines that were in their procedures.
I 13 Q To what effect?
14 A Ope rating procedures.
15 Q You were aware that there were guidelines 16 in the operating procedures regarding the maximum 17 level of pressurizer fill? .
18 A i
Alarms procedures and pressurizer operating, 19 procedure.
20 Q What is a hydrostatic test?
A 21 It is a pressure test of a system 22 verifying that there are no leaks or determine if 23 there are leaks.
() 24 Q And the prefix " hydro" means that it is 25 i a pressure test in which water is used as the i
w- . .- .c ,, y -- ,. . --
r---. ----r. . . - . . s ,-,-<y
l 1 Faist 75
~h '
(G 2 pressurizing medium; is that right?
s 3 A Yes.
4 Q In other words, the vessel or component
( 5 that is to be hydrostatically tested is filled with 6 water and the water is placed under pressure?
7 A Yes.
8 Q Were you aware that there was a B&W 9 drafted procedure for B&W nuclear plants that said 10 that the reactor coolant system was nod,to be 11 filled solid with water except under hydrostatic 12 conditions? By " reactor coolant system" I mean the O 13 whole primary coolant system, includin the 14 pressurizer.
15 A I know draft procedures were issued. I 16 don't remember a specific draft procedure so stating 17 that. .
18 Q And you don't remember that t ere was a 19 limit and precaution stating that?
20 A No, not right offhand.
21 Q According to the data in the site problem L 22 report which you assembled, high pressure injection 23 was not reinitiated until 26 minutes and 49 seconds
(~
( ,), 24 after the start of the transient. Did you know prior 25 to the training room B presentation that you
l 1 Faist 76
~
('%
U 2 participated in, that for approximately three-quarters l
3 of an hour high pressure injection had been l
4 incorrectly used during the September 24th transient?
5 MR. WISE: I will object to the form of
(
6 the question.
i 7 The witness may answer it if he can.
8 MR. SELTZER: Let me withdraw that and 9 rephrase it in light of Mr. Wise's remark.
10 Q Had you formed the view before the training 11 room B presentation that up to the point where high 12 pressure injection was reinitiated at 46 or 47
T .-
/ 13 minutes into the transient, high pressure injection had 14 not been correctly used during the Davis-Besse 15 September 1977 event?
16 MR. WISE: I continue my objection but the I
17 witness may answer. .
18 A I can't remember the opinion brthe 19 consensus that I had with usage of the HP[ system. I 4
20 don't remember what specific opinion I had.
21 Q Well, when is the first time that you 22 recognized that the operators had mismanaged high 23 pressure injection during the Davis-Besse event?
[)
'u 24 A In viewing the data after it was 25 assimilated.
1 Faist 77 2 MR. WISE: You mean accumulated?
3 A -Accumulated. High pressure injection was 4 not used throughout the depressurization. It was
( 5 terminated. In discussions on that subject,.I had 9
6 no inclination to believe that it was used improperly.
7 I was led to believe that the staff realized that 8 they had made a mistake. I don't specifically know 9 when --
I don't sp'ecifically remember when in time 10 I formed a final opinion. *l 11 Q For the sake of anybody understanding 12 wh at you are saying, I better try and clarify this.
(', )
13 You knew from reviewing the data that 14 you had accumulated that there was a depressurization 15 event going on and you knew that while that v
16 depressurization event was proceeding HPI was off, 17 right? .
18 A Later on, yes, after reviewing the data.
19 Q When you reviewed the data, you knew 20 that HPI was off while the depressurization event was l
21 ensuing, right? j L 22 A Yes.
23 Q When you saw those two facts simultaneously, 24 did you know as soon as you saw those two facts 25 that HPI had been mismanaged?
1 Faist 78 O
v 2 A Yes.
3 Q 'You had reviewed that data before the 4 training room B presentation, right?
( 5 A I don't recall specific -- yes, I looked 6 at that data before the training room B.
7 Q so you knew before you went into the 8
training room B presentation that during the 9 September 24th transient, high pressure injection had 10 (
been-mismanaged, right? -
11 A Yes.
12 Q Had you ever heard of any o,ther transient
' O 13
, at a B&W plant in which operators had mismanaged high 14 pressure injection for a period of approximately 15 three-quarters of an hour?
16 A No.
17 Q Let me just review a few points.
18 Prior to the training room B presentation, 19 it was your state of knowledge that the Davis-Besse 20 event was the first time in which a B&W plant had 21 gone to saturation in its reactor coolant system at 22 a time that was not prior to fuel loading? Isn't that 23 correct?
( 24 A I am sorry. Would you rephrase that?
25 Q Before the training room B presentation,
, . - ,.e n .,--
y.- r ,, y , _ . - -
1 Faist 79 O 2 to your knowledge, the Davis-Besse event was the t
3 first time t' hat a B&W plant had gone to saturation, 4 in other words, boiling in its reactor coolant
( 5 system, after fuel had been loaded?
6 A To my recollection, I don't recall any 7 other events with a B&W plant or any other plant.
8 Q Where there had been boiling?
9 A Yes, there there had been boiling.
l l l i
10 Q t
Prior to the training room B presentation, 11 you knew of no event other than the recent Davis-Besse 12 event where pressurizer level had gone up while 13 reactor coolant cystem pressure fell; isn't that 14 right?
15 A I don't recall any event wher,e that 16 occurred. I recall events where there was a steam 17 formation in the hot legs and that there may have been 18 indications of pressurizer increase.
19 Q As you sit here today, though, you can't 20 testify that you knew of an event where pressurizer 21 level rose while pressure fell other than the 22 Davis-Besse event; isn't that right?
23 A Yes.
24 Q Yes, that is correct?
25 A Yes, I can't recall of any other events.
1 Faist 80 1
\./ .
J 2 Q At the time that you were participating 3 in the training room B session, it is a fact, is it 4 not, that the Davis-Besse incident of September 24th
( 5 was the only time you were aware of where operators 6 had incorrectly managed high pressure injection for 7 approximately three-quarters of an hour? Isn't that 8 correct?
9 A I was under the impression that this was 10 a Davis-Besse unique situation and the l pperators 11 there had done something that wouldn't normally have 12 been done, that there was no evidence to show that O~ 13 their procedures were incorrect or --
14 Q I think you are trying to anticipate a 15 future question. Could you try to be more responsive 16 to the question that I posed, please?
17 MR. WISE: Perhaps you can reread the 18 question.
10 (Question read.)
20 A I didn't specifically bring that question 21 up. I don't remember any other instance where that
(
22 had occurred.
23 Q You said that the presentation that I
) 24 have referred to as the training room B session 25 occurred on the Wednesday immediately after the
i l
l 1 Faist 81 l
f')
kJ 2 September 24th event, right?
3 A Yes.
4 Q So that would be on the 28th of
( 5 September, right?
6 A Yes.
- Q It is correct, isn't it, that the training 8 room B presentation was convened solely to address 9 the Davis-Besse September 24th event? .
10 A That's correct. '.
11 Q Let me clarify something.
12 You testified to Rogovin that the training O 13 room B session was on September 29th and we have a 14 document produced from the Davis-Besse site files of 15 B&W that shows you attending a meeting to review.
16 the September 24th event and it is a meeting on 17 September 28, 1977. Is that your signature written 18 at the bottom of the page?
19 MR. WISE: Could we have the document 20 marked if it hasn't already been marked?
21 MR. SELTZER: We will make a copy of it L 22 and mark it.
23 A This meeting was not the Lynchburg meeting.
() 24 Q I know it. And I am introducing it to 25 suggest that if you were at that meeting with those l
1 Faist 82 g
^
u).
2 People on September 28th, that you may be in error 3 today in sug'gesting that the Lynchburg meeting was 4 also on the 2 8th.
( 5 MR. WISE: First of all, I am confused
)
6 now. Some document has been trotted out, 7 shown to the witness. I haven't had a chance 8
to review it and I'm afraid I am at a loss to 9 know what it is, i
10 MR. SELTZER: You don't have to make a 11 big hubbub on the record. Take a look at the
("%
12 document.
s 13 MR. WISE: What is this document?
14 MR. SELTZER: You may take a look, 15 Mr. Faist. '
16 What is it?
17 MR. WISE: Mr. Faist, do you r'ecognize 18 this document, which we will have marked in a 19 moment? Have you ever seen it before?
20 MR. SELTZER: Take a look at the first 21 sheet.
(. 22 A The first sheet I recognize. !
23 Q What is the first sheet?
() 24 A The first sheet is a list of attendees 25 at a meeting.
1
, . . _ _ , , . _ . , . . ,-_.~----- - - - - --- -
1 Faist 83
~N (d
2 Q Is that your signature at the bottom of 3 the page?
4 A Yes, it is.
( 5 Q What is the date of the meeting as 6 indicated on that sheet?
7 A The 28th of September 1977.
8 MR. WISE: Where did that meeting occur?
9 THE WITNESS: It had to have occurred at 10 (
the site because of the people involved.
11 Q And by the " site" you mean the Davis-Besse 12 plant?
/
13 A The Davis-Besse site. 2 14 Q At some point during the week after the 15 Davis-Besse a c ci den t , you flew back to Ly,nchburg for 16 the training room B presentation, right?
17 A Yes.
- 18 (Continued on the next page.)
19 20 21 k.
22 i
23 24 25 1
1 Faist 84
/~h
~
U.
2 MR. SELTZER: Let's mark for identification 3 as GPU Exhibit 488 the notes that you just have 4 been looking at.
k 5 (Five-page document entitled " Review of 6 Incident on 9/24/77" marked GPU Exhibit 488 for 7 identification, as of this date.)
8 Q Take a look at your testimony before the 9 Rogovin people, page 2.4 . Do you see there where you 10 testified at line 14 that on the 29th b,f September we 11 had met in Lynchburg?
12 A Yes.
13 Q I don't want to make a big, deal of it, 14 because whether it's the 28th or the 29th probably 15 doesn't change the way the world turns and how this 16 litigation is going to be resolved.
17 Looking at your prior testimony, which is 18 under oath, looking at the document we have marked as 19 GPU Exhibit 488, does it appear likely, as I am 20 suggesting, that the Lynchburg meeting was not on 21 September 28th?
22 MR. WISE: I am going to object to the form 23 of that. What might appear likely or not today
) 24 is not very relevant. Why don't you just ask him 25 what he remembers and then if looking at these
1 Faist 85
~
/~'
' (_))
2 various documents refreshes his recollection, 4
3 instead of insisting insisting on it in a form that 4 you know is not proper.
I 5 MR. SELTZER: Oh, Robert, you're so proper 6 sometimes that I just can't keep up with you. I 7 mean everybody can't be quite as prim as you. I 8 am trying to show the witness documents, of course, 9 that will refresh his recollection, and I have 10 been trying to do this expeditiou. sly.
11 BY MR. SELTZER:
12 Q Can you reconstruct from what's in front of O 13 you what appears to be or what you can.best recall is 14 the date of the Lynchburg meeting?
15 A I know it was late that week. I remember 16 and thought it was Wednesday.
17 Q If the meeting that's memorialized in GPU 488 18 was en Wednesday, would that mean to you hat the' l 19 Lynchburg meeting must have been some day other than 20 Wednesday?
21 MR. WISE: I object to the form.
22 MR. SELTZER: Okay, you may answer the 23 question.
I O(m/ 24 A The B&W meeting was in Lynchburg, conference 25 room B, with Joe Kelly and myself involved in that.
i i
l 1 Faist 86
(~
u) 2 I don't remember this specific meeting.
3 MR. WISE: By "this," the witness is 4 indicating the meeting reflected on GPU Exhibit
( 5 488.
6 A And I know when Joe Kelly left the site to 7 go back to Lynchburg with me, he didn't return, and this 8 meeting had to have occurred at the site. If that was 9 on the 28th, then my recollection of this B&W meeting 10 happening on Wednesday, it had to have lbeen Thursday.
- 11 Q Thursday would be the 29th?
l 12 A Yes.
13 Q Did you return to Lynchburg for the purpose 14 of participating in the training room B meeting?
, 15 A Yes.
16 Q Is it correct that there were approximately 17 30 to 50 B&W managers in attendance at the training 18 room B session?
19 A I don't know if the number is right, but 20 there was a considerable number of people there.
21 Q Who was it who summoned you back to 22 Lynchburg for the training room B presentation?
23 A Bill Spangler.
24 Q Had you ever been a speaker at a presentation 25 like the training room B session, in other words, a l
)
.1 1 Faist 87 i
(~ -
l
\-)) l 2 session convened to apprise a considerable number of 3 B&W managers about one specific recent transient?
4 A No, I don't recall.
( 5 Q You don't recall ever participating in any 6 such event previously?
7 A Yes.
8 Q Subsequently, have you ever been a speaker 9 at any similar presentation?
10 A I have been a speaker at pkesentations, 11 but -- -
12 Q I am not talking about any presentation 13 since God created the earth and put you on it. I am 14 talking about this type of presentation, namely, a 15 presentation to a considerable number of B&W managers 16 to discuss one specific recent transient.
17 A No. .
18 Q Before the Three Mile Island accident, had 19 you ever attended a presentation such as this one, 20 namely, a presentation to a considerable number of B&W
. 21 managers to discuss one specific recent transient?
k.
22 A I don't recall sitting in on such 23 discussions.
! 24 -Q To the best.of your recollection, what did 25 Bill Spangler tell you would be expected of you'at the
s 5 i Faist 88 2 training room B session to which he was summonihg yo'u?
3 A To provide an understanding of what had 4 happened at Davis-Besse.
( 5 Q Did he ask you to bring any data with you?
6 A Yes.
] 7 Q What did he ask you to bring?
l 8 A As much information as we could with regard 9 to the transient itself.
10 Q Did he leave it up to you b,nd Joe Kelly to 11 divide between yourselves the material that would be 12 presented?
13 A Bill didn't specifically say, " Joe, you do 14 this" or " Fred, you do that." Bill sent Joe to the site 15 to help out any way he could.
16 Q Did you review with anybody what you and 17 Joe Kelly were going to say before you gave the 18 presentation in training room B?
19 A To some degree, yes. .. . . , .
, 20 Q With whom did you review it?
21 A Just generally, Joe'and I talked about some -
22 topics and decided amongst us who would present what. '
23 Q Did anybody other than you and Joe speakat\
.p d 24 the training room B session? I mean in the formal part 25 f the presentation. '
.. .' N -
\ _
v- . -
1 Faist 89 l q
V 2 A I don't recall if anyone else spoke as part 3 of the presentation.
4 Q And you have no recollection of anybody else
( 5 speaking, is that what you are saying?
6 A Not as far as presenting the discussions 7 or event of Davis-Besse.
8 Q Was there anybody who introduced you and Joe 9 Kelly and introduced the purpose of the presentation?
10 A Yes. ',
11 Q Who?
12 A Bill Spangler.
O 13 Q What, as best you can recall, did Spangler 14 say, in words or substance?
15 A I don't remember what he specifically said.
16 I know he turned the meeting over to Joe and m*/self.
17 Q Do you remember him saying anything 18 generally about why the meeting was convened?
19 A I don't remember what he said.
20 Q You said that the training room B 21 presentation is the only session that you have ever L
22 participas c' in, either as a speaker or as a listener, 23 that was of that particular type. Did you recognize p
Q 34 before you gave the training room B presentation that 25 there was something which other B&W employees should
i i Faist 90 (x
k 2 learn about the Davis-Besse event?
i 3 A I thought people should have an 4 understanding of what the facts were and what really
(. 5 happened at Davis-Besse.
6 Q Did you have an understanding that there 7 was something that was important for them to know about 8 Davis-Besse that was different from other transients 9 that had happened? In other words, did you have some 10 sense that a very special meeting was 6,eing convened 11 because there was something special about the Davis-12 Besse event?
(~1 13 A No, there was an air of feeling that there I 14 was a lot of data that had to be collected and had to 15 be presented in a timely manner and the best way to do e
16 that was to assemble that data and bring the data to the 17 people, as opposed to wait until it's all tabulated.
l .-
18 Q You indicated that in your experience the
, 19 training room session was unique. You don't know of any 20 other session that was like it. Have you ever heard of 21 any other session like that having been convened before 22 the Three Mile Island accident?
23 A I don't recall of any other session like that rO (wJ' 24 where I participated in.
25 Q Or heard about?
l l
i
. 1 Faist 91 t~% ~
U. A I don't remember any.
2 3 Q Do you have any notion why such a session 4 was convened for Davis-Besse and its September 24
( 5 event and, to your knowledge, had never been convened 6 for any other transient at a B&W plant? To your 7 knowledge, I am talking about.
8 MR. WISE: I think you are stretching the 9 bounds of what's an appropriate way to go about 10 your examination. I will object (to the form of 11 that but allow him to answer.
12 A There may have been other meetings on other
( 13) transients.
13 .
14 Q I am limiting it to what you'know of. You 15 don't know of any other that was like?
16 A I don't know of any.
17 MR. WISE: What's the question now?
18 Q Do you have any idea why this special 19 meeting was convened for the Davis-Besse September 1977 20 event where you know of no similar meeting for any other 21 transient having been convened before the Three Mile 22 Island accident?
23 MR. WISE: I object to the form. You can't g i s 24 have it both ways, Mr. Seltzer. On the one hand, 25 you have limited your question to what knowledge
l 1
1 Faist 92
'N -
(O 2 he had, and now you have characterized the 3 meeting as being a special meeting, when he's i
i 4 already told you he can't testify as to whether it
(, 5 occurred for other plants.
6 You can't have it both ways.
7 MR. SELTZER: All right. Your objection is 8 very clear. You don't have to state it for a 9 fourth time.
10 You may answer the questiod.
11 A The impression given was that Davis-Besse 12 had undergone a transient that was a depressurization, O 13 a drop in pressure, and that in order to understand how A
14 the plant performed or responded, people were anxious 15 to see the data on that transient.
16 Q Why was it important, if it was at all 17 important, for a considerable number of B&W managers 18_ to be quickly informed of this depressurization event?
19 MR. WISE: I object to the form of that.
20 You may answer.
21 A That was not my decision to have that 22 meeting.
23 Q Did you have any understanding why it was
, Oy j 24 important, if it was important? Somebody else made the 25 decision, I understand that. Did you have any
1 Faist 93 gs -
l 2 understanding about why it was important to convene such I 3 a meeting?
4 MR. WISE: I object on the basis it has
() 5 been asked and answered.
6 The witness may answer it again.
7 A A means of bringing all the information 8 together to all the people that may ultimately get 9 involved in looking at what had happened.
10 Q To your knowledge, the meeting accomplished 11 that purpose, right?
-s 12 A To my knowledge, we presented what we had
)
(G known to the people present to the best of our 13 4
14 knowledge on what we had gathered in researching that 15 transient.
16 Q Would you answer my question, please?
17 MR. WISE: I think it was in'* answer to your 18 question. He is not required to answer it yes 19 . or no.
20 Q Would you answer my question, please?
21 -(Record read) 22 Q The question is, do you think the meeting 23 accomplished the purpose that you described?
24 A Yes.
25 MR. SELTZER: You see, he was able to answer
1 Faist 94 2 it yes or no.
3 MR. WISE: I might say that your associates 4 during the depositions of your witnesses have not k 5 been so lenient repeatedly.
6 MR. SELTZER: Well, I can see that they 7 must be taking their instructions from you. I 8 think it's very unusual for you to be objecting 9 to what my associates do when you, a partner at 10 Davis, Polk, are making some of khe came 11 objections.
12 BY MR. SELTZER:
~
13 Q Did you and Joe Kelly divide up by topic or 14 by any other means what he would present 'and what you 15 would present?
16 A We obviously came to some conclusion about 17 who was going to speak about what, because he gave part 18 and I gave part.
10 Q Right, I have heard that. The question is, 20 did you and he parcel out what the two of you would 21 present so that he took some specific topics and you 22 took some other topics?
23 A Yes, that's true.
24 Q I am not asking for a verbatim recall, but 25 as best you can recall, what topics did yr.2 take and 1
1 1
1 Faist 95 2 what topics did he take?
3 A I recall Joe discussing the transient and 4 answering some questions, talking about their safety, 5 steam feedwater rupture control system.
6 I remember talking a little bit about the 7 steam water feedwater rupture control system also, 8 and reasons why the PORV stuck open and fluctuated, and 9 that's all I recall.
10 Q which of you described the lpperators' 11 mismanagement of high-pressure injection?
12 A I don't recall.
13 Q You "o d recall that one of .the two of you 14 described the operator mismanagement of high-pressure 15 injection, isn't that right?
d 16 A I recall that the transient was discussed.
17 I don't remember who exactly discussed what particular 18 aspect of that.
19 Q Right, I am past that now. Now I am asking 20 you, it's a fact, isn't it, that one of the two of you, 21 and I am not asking which one, did describe how the 22 operators had handled high-pressure injection? That 23 was a subject that was presented to the considerable O number of attendees, right?'
(_ 24 25 A I don't remember that specific item. I a
l
)
1 Faist 96
/~'T V
2 don't remember all the details. It may have been 3 presented and I don't remember who presented it.
4 Q Take a look at page 24 of your Rogovin
( 5 testimony. Do you see there you are being asked about 6 the operators shutting off high-pressure injection at 7 approximately four and a half minutes into the transient?
8 MR. WISE: Where are you reading from,the 9 top of the page?
I 10 MR. SELTZER: Yes. '
11 Q Do you see that?
12 A Yes.
(:) 13 Q At line 13, you are being asked about that 14 termination and the question is, "When did you discover 15 that it was not appropriate?"
16 " Answer: On the 29th of September when we 17 had met in Lynchburg and discussed it with our 18 engineering people and got our safety analysis people 19 involved in all the facts that had occurred."
20 The meeting on September 29 in Lynchburg 21 that you were referring to in that sworn testimony is 22 the training room B meeting, right?
23 A I believe so.
C)'
q_ 24 Q And whan you say " discussed it with our 25 engineering people," you mean the discussion with the
1 Faist 97 m -
! 2 considerable number of people who attended the training 3 room B presentation, right?
4 A And also the follow-up questions and so l 5 forth and side meetings after the regular meeting.
6 Q Side meetings that had been stimulated by 7 the facts presented at the main meeting, right?
8 A Yes.
9 Q Does that refr'esh your recollection that you 10 did include in the presentation that ybu or Joe Kelly 11 made information about the operator mismanagement of 12 high-pressure injection during the September 24 event?
O 13 A You mentioned mismanagement, a mistake that 14 was made, and when they terminated HPI and stopped 15 HPI, yes, that was discussed. I don't remember the 16 details surrounding that.
17 Q I am not asking for the detai1s. All I am 18 trying to establish is the threshold fact that one of 19 the two people on the podium who was coming back with 20 information from Davis-Besse did present the facts to 21 the considerable number of B&W managers that there had 22 been an incorrect handling of high-pressure injection 23 out at the Davis-Besse plant. Is that threshold fact 24 . correct?
25 A Yes, it is. That was brought out and w +M
- is 4 '* "' "* ++ e w- --%r- d----w'wr -*' --c"'-i*
- 1 Faist 98 2 discussed because there is obviously questions that 3 were brought out afterwards about it.
4 Q Before the main meeting broke up and the l' 5 considerable number of attendees dispersed, was there 6 a question-and-answer period?
7 A Yes.
8 Q During that question-and-answer period, g was there discussion coming from the floor related to the 10 operators' incorrect handling of high-pressure 11 injection?
12 A I don't remember the specific questions.
O 13 Q In either the discussion from the floor or 14 in the side meetings which you have just indicated 15 occurred after the main meeting, do you recall that 16 there was discussion of the incorrect operator handling 17 of high-pressure injection? -
18 A Yes.
19 Q It's correct, is it not, that Bert Dunn 20 was one of the principal participants in that discussion?
21 A In one of the side discussions, yes.
22 Q You knew at the time that Dunn was manager 23 of the emergency core cooling system analysis unit?
O)
\_ 24 A Yes.
l 25 Q Did Bert Dunn express some insights into l
1 1
i 1 Faist 99 l 2 what had happened at Davis-Besse that went beyond any 3 of the thinking that you had developed up to that time?
4 A I don't know what Bert Dunn's insights were.
( 5 I don't recall what Bert Dunn's specific insights were G into the whole transient.
7 Q Well, take a look again then at page 24 8 and see if that refreshes your recollection.
9 A I remember one remark and that's about all 10 I remember in that conversation. I 11 Q The question at line 19, "And those people 12 identified that the securing of the high-pressure 13 injection was in error?"
14 " Answer: Yes.
15 " Question: Who specifically was that?
16 " Answer: Bert Dunn, Bob Jones," et cetera.
17 MR. WISE: Well, finish the re s t of the 18 answer.
19 MR. SELTZER: "The general comment came from 20 the safety analysis group, who specifically stated 21 that, I don't recall."
22 Do you want to read more?
23 MR. WISE: "But that was a ccmment from the O)
(_ 24 _ meeting, a trite comment from the meeting that 25 the HPI pumps should have never been turned off,
1 Faist 100 0 2 the reason being, you may not get them started 3 again if you really need them."
4 That's the end of that answer.
1 l 5 BY MR. SELTZER:
6 Q Is it your recollection that it was only I
~
7 as a result of the situation with Dunn or Jones that you 8 realized that terminating high-pressure injection had 9 been a mistake?
10 A It reinforced that thoughti, 11 Q At page 25 you refer to something which is 12 transcribed as "a trite comment." You go on to discuss 13 on that page and the next the possibility that when a l .
14 pump is shut off, it may not be able to be restarted.
15 Do you see that testimony on pages 25 and 16 267
{ 17 A Yes. .
- , 18 Q At the time of the training room B meeting 19 and immediately thereaf ter, are you indicating that it 20 was your notion that that is the reason why it was a 21 mistake to have shut off the high-pressure injection 22 pumps?
23 A That's all I remember, b
(j 24 MR. WISE: Have you finished your answer?
25 A That is all I specifically remember about ,
I that conversation.
1 Faist 101 2 Q I am not limiting it just to the 3 conve rs atio n . I am saying, is it your unde rs tanding 4 as of the date of the Training Room B meeting, 5 Septembe r 29, 1977, that the reason there was anything
((
6 wrong with shutting off the high-p ress ure idjection 7 pumps during a depressurization event is that you might 8 not be able to restart them?
9 A No, when you have a depressurization, the 10 only means of making up to the p rimary (sys tem is th ro ugh 11 high pressure inje ction at highe r pressures . When you 12 have a bre ak , you need HPI.
(~ .
13 Q If it's a break that doesn't lead to rapid 14 dep res s uriz ation ; right?
15 A HPI comes on, but there are other systems 16 that handle large r b re aks.
17 Q Is it your recollection that Dunn, Jones 18 and other people in safety analysis were suggesting 19 that the reason they were concerned about HPI being 20 shut of f was , they were afraid the pump wouldn't restart.
21 A I mentioned I heard this comment on pump L 22 restart as a side comment. I don't remember what else 23 was s ai d ,
n (Ji 24 Q Do you recall Dunn, Jones or anybody else 25 s aying that the termination o f high-pressure injection
1 Faist 102
("'s ~ )
NY 2 was in error because during a small break loss of '
3 coolant accident, there was a need for emergency 4 replacement of lost coolant?
5 A I don't remember anyone saying that, but
((
6 it is pretty obvious that when you have a break or a 7 small break or any kind of a break, you need a makeup 8 system or high-pressure injection system. That's 9 obvious.
10 Q If that is so obvious, thed why did it 11 take you until September 29 to recognize that it was 12 a mistake for them to have shut off high-pressure
(%
N 13 injection at four and a half minute?
14 A I don't know. I know that calling for 15 depressurization to HPI system is required. I don't 16 remember specifically about the Dunn side conversation 17 or terminating pumps because they weren't. started. I 18 remember that conversation. That is the hirst time I 19 heard that specific reason.
20 Q Your answer is, you don't know why it took 21 you until September 29 to know it was a mistake to k-22 turn off high-pressure injection at four and a half 23 minutes?
g 24 A No, I don't remember the conclusion I came
%)
25 to beforehand.
1 Faist 103 2 MR. WISE: Do you unde rs tand what Mr.
3 Seltzer is asking you?
4 THE WITNESS: He is asking if I realized that HPI should have not been te rminated. It
( 5 6 was a mistake to te rminate that.
7 Q Let me clarify. You testified to Rogovin 8 in October 1979, two and a half years ago, that you 9 did not recognize that terminating high-pressure 10 injection at four and a half minutes way right or wrong 11 at the time.
12 The question at Line 13, "When did you em ,
13 dis cove r that it was not appropriate?
14 " Answer: On the 29th of Septembe r when 15 we had met in Lynchburg and discussed it with our 16 engineering people."
17 Are you saying that as you sit here today 18 you can't explain why it. took you until S$ptember 29 19 to recognize that shutting off high-press u're injection 20 was the wrong thing to have done?
21 A That is probably the fi rs t time I sat down 22 to hones tly form a final opinion and my recollection of
)
23 that time frame is somewhat confused with things that have happened since that time.
[G'l 24 25 g would it be fair to say that your
._. - . . _ = = _ . .-_
i Faist 104 O 2 recollection of the Davis-Besse events was fresher in' 3 your mind in Octobe r 1979 than it is today?
4 A Yes, that's probably true.
(( 5 Q Did you believe that you were testifying 6 truthfully and accurately to the best of your recollec-7 tion when you gave the Rogovin Committee testimony in 8 October 1979?
9 A Yes.
10 Q As best you can recall, otHer than Dunn and 11 Jones, who else was in attendance at the training room B 12 co nclave ?
13 A The only othe r ones that I can remember are 14 Bill Spangler, Al Lazar, Joe Kelly, of course, Tom 15 Fairburn and Joe Laue r.
16 Q Do you remember who was the head of the 17 Nuclear Power Generation Division at that. time, what his 18 name was?
^ '
19 A I believe John McMillan was the head at 20 that time.
21 Q Do you remember that he attended all or L 22 patt of the Training Room B session?
23 A I don't remember him attending. I don't have
( 24 any recollection of any more than those people I just 25 mentioned.
l l
i 1 F ais t 105 '
2 Q I would like to ask you to look at Page 28 4
3 of your Rogovin Commission testimony. At the top of 4
the page, it begins with your answer, "Af te r TM , yes.
l l[ 5
" Question: 0.K. What did you conclude?
6 " Answer: I concluded that we probably could 7 have had 4
a similar accident at Davis-Besse if a similar
! 8 i
situation had existed. '
9 " Question: By 'similar situation' you mean 10 the higher power level? .
11 " Answer: Yes, and longe r time at power, 12 higher extende d core lif e. "
13 1
were you asked those questions and did you 1 .
14 give those answers?
I
! 15 A I don't remember what all I said, but this
[ *.
16 is how it re ads he re , but I don't remembe r specific 17 questions, but those are answers that they had taken l
18 during that deposition.
19 Q Do you have any reason to doubt that you were i
- 20 asked those questions and you gave those answers?
21 A No. 1
(. I 22 Q No, you have no reason to doubt it?
23 A No. I don't recall.
24 Q I am j ust worried about the ambiguity of 25 the'one-word answer, "No." Is it correct that you don't
1 F ais t 106 O
~
2 have any reason to doubt that you were asked these 3 questions and then you gave those answers?
4 A I have no reason to doubt it, yes.
( 5 Q When is the first time you be came aware of 6 the concern that was gene rated in the Engineering 7 Department about premature operator termination of 8 hi gh-p re s s ure injection following the Davis-Besse event?
I g A In the September 29th meeting a statement 10 was made that should have never terminated HPI.
11 Q That shouldn't --
12 A I remember that statement, should not have 13 . terminated HPI.
14 Q The ope rators should not have terminated 15 HPI?
16 A That is correct.
17 Q Subsequent to the presentation and the
~
18 discussions off to the side after the presentation 10 when is the firs t time you became aware of'the concern 20 that followed in the Engineering Department at B&W
, 21 about operator te rmination o f high-prescure injection?
23 I am skipping a step. You are looking at me blankly 23 so let me be more explicit.
24 Joe Kelly wrote a memo on Novembe r 1, 1977.
25 Burt Dunn' wrote two memos in February 1978, which have i
.. _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . . _ _ _ _ _ _ . _ -J
1 Faist 107 1
s 2 become almost as famous as th e Ge ttysburg Address . Don 3 Hallman wrote a memo in August '78. When for the first 4 time did you become aware of the concern that was 5 generated in the Engineering Department about p remature
((
l i 6 operator termination of high-p ressure injection 7 subsequent to the September 29th meeting?
8 A It was af te r Three Mile Island 2. I had 9 seen a copy of the memos from counsel. I had not seen i
10 those copies be fore that. I had heard 'o f them, but I 11 had not seen them. -
12 Q At the time of your Rogovin testimony, had 13 you seen any of those memos?
14 A No.
15 Q Other than the Rogovin testimony have you 16 given any other sworn testimony in connection with the 17 Th re e Mile Island accident? .
18 A No.
19 Q Eave you given any interviews to non-B&W 20 people about anything related to the Three Mile Island 21 accident?
l 22 MR. WISE: Other than Rogovin.
23 Q Were you interviewed by Rogovin?
/N 24 A Yes.
(]
25 MR.. WISE: We have got the transcript.
- - - . , - , , - - - ,- -er -
m -m--e y i,~1- ,, -e--
1 Faist 107-A O
~
~
2 I don't conside r a deposition an interview.
Q 3 Were there any inte rviews with non-B&W 4 Personnel in any way relating to the Th re e Mile Island
( 5 accident?
6 A No.
7 (Continued on Page 108.)
8 9
10 (
11 12 13
/
14 15 16 17 ,,
18 gg +
20 21 L 22 23 O 24 25
l 1 Faist 108
~ '
($) Let me clarify something that I think is 2 Q 3 a typographical error.
4 Did you ever submit any corrections to
( 5 your Rogovin testimony?
6 A I submitted some.
7 Q Take a look at page 30.
8 Am I correct that the last word in line 9 12 should read " pressure" and not "p re s s uriz e r" ?
10 MR. WISE: I will state fod,the record 11 that that particular part that you are asking 12 Mr. Faist about is part of what apparently was 13 a question by one of the people f, rom Rogovin 14 rather than what Mr. Faist said in his answer.
15 MR. SELTZER: Well, it is a leading 16 question to which he gave the very succinct 17 answer "Yes," so he has incorporated in his 18 answer-the substance of the question.
19 THE WITNESS: It doesn't make sense the 20 way it is there.
21 Q And does it make sense-to you and would it 22 be consistent with the answer that you gave if the 23 word " pressurizer" is instead written as " pressure"?
()
t 24 A Yes.
25 Q At the time that you were site operations
l l
! l l
l 1 Faist 09
(
2 manager at Davis-Besse, you were aware, were you not, 3 that Lee Rogers was your counterpart at Three Mile ~
4 Island?
( 5 A Yes.
6 Q In GPU Exhibit 133, which is the site 7 problem report for the Davis-Besse incident, Lee 8 Rogers is indicated to be somebody who should have 9 received a copy of the Davis-Besse site problem-report.
10 What is your understanding,',1f any, as 11 to why a copy of the Davis-Besse site problem report o 12 was being sent to Lee Rogers at Three Mile Island?
~
13 A First of all, I don't know.whether 14 everyone on distribution got it. I assume that it was 15 by procedure, that it was on standard distribution 16 and that it was issued accordingly to that distribution.
17 MR. WISE: The question was a different 18 one, Mr. Faist.
19 Q Just for your information and background, 20 Lee Rogers has already testified that he got the site 21 problem report, so I am not seeking to pin him down L 22 to having got it through you. The question is, what 23 is your understanding, if any, as to why Lee Rogers I%d') 24 at Three Mile Island was being sent a copy of the 25 Davis-Besse September 24, 1977 site problem report?
g Faist 110
(~) -
'( /
2 A My understanding was like all the SPR's, 3 for informatlon.
4 Q Is it correct that he was being sent this
( 5 SPR so that he could determine whether there were 6 features of the September 24th Davis-Besse accident 7 that were applicable to either of the Tnree Mile Island 8 units?
9 A I don't know why he -- what his purpose 10 or what the purpose was in sending it t,o Lee. I know 11 I can speak for myself. They are sent to me for 12 me to look at and I would lock at them.
("}
13 Q To determine whether there were points l 14 that were applicable to Davis-Besse?
t 15 A Not necessarily. In some cases, it is 16 just for information, just to understand what happened 17 someplace else, and it may not even be applicable to 18 that contract.
19 MR. SELTZER: I would like to mark'for 20 identification as GPU Exhibit 489 a site 21 instruction from Wandling to distribution 22 with R. J. Baker included among the people 23 on distribution. "
Subject:
Electromatic
() 24 Relief Valve Malfunction," dated July 15, 1975.
25 (Site instruction from Wandling to 1
1 Faist 111 2 distribution, R. J. Baker included among the people' on districution, "
3
Subject:
Electromatic 4 Relief Valve' Malfunction," dated July 15, 1975, 1
( 5 was marked as GPU Exhibit 489 for identification, 6 as of this date.)
7 Q Where were you in July 19757 8 A I was at Davis-Besse.
3 Q Who was R. J. Baker?
l 10 A He was a site operations manager at 4
4 11' Davis-Besse.
I i
12 Q Did you report to him?
13 A Yes.' .
14 Q Are you familiar with documents of the i
15 format which appears in GPU 489, namely, ,a site 16 instruction?
i 17 A Yes. ~
18 Q This is a standard form for a site 19 instruction?
20 A Yes, it is.
21 Q Do you see the customers listed at the 22 top?
23 A Yes.
24 'Q One of those customers'is the owner of the 25 Davis-Besse. plant,-right?
I f
y -
y y,,..y ,...<r ,. -.--,-y ,,,,v._e%-, , . . , , . , , .m , . , - . . _ _ , , , , , , . . , ,,, , , , , , . , ..v.w.._...,3_,.
1 Faist 112 0 2 A That's right.
3 Q Namely, Toledo Edison Company?
4 A Yes.
( 5 Q was it your understanding from a site 6 instruction such as this that the B&W site staff at 7 Davis-Besse were to communicate the contents of this 8 site instruction to the owners of the Davis-Besse 9 plant?
10 A Yes. t 11 Q This particular site instruction refers 12 to a malfunction of the pilot operated relief valve, f'
13 right?
14 A Yes, it does.
15 Q And the malfunction that is referred to 16 here is one that had occurred at the Oconee station 17 owned by Duke Power, right? .
18 A Yes.
19 MR. SELTZER: I would like to mark for 20 identification as GPU Exhibit 490 a letter by l
- 21 R.J. Baker to Jack Evans dated July 31, 1975, 22 "
Subject:
Solenoid Pilot Operated Pressurizer 23 , Relief Valvs - PSV-RC2."
( ) 24 (Letter by R.J. Baker to Jack Evans, 25 dated July 31, 1975, "
Subject:
Solenoid Pilot
1 Faist jg3 0- 2 Operated Pressurizer Relief Valve - PSV-RC2,"
3 was marked as GPU Exhibit 490 for identification, 4 as of this date.)
5 Q Is GPU Exhibit 490 a copy of a letter
((
6 which you sent to the station superintendent at 7 Davis-Besse communicating the contents of the site 8
instruction previously marked as GPU Exhibit 4897 9 A Yes, it is.
10 Q Was it your understanding d hat you were 11 communicating to the Davis-Besse plant a problem that 12 had occurred on another B&W plant, pil t operated o)
(- 13 relief valve, because B&W perceived that the problem 14 that had occurred at Duke Power's unit might be 15 applicable to Davis-Besse?
16 A Yes, it was.
17 Q And it was your understanding'that there 4
18 could be such an applicability from one unit to 19 another even though Duke Power had a Dresser valve !
20 and Davis-Besse had a Crosby valve?
21 A That's correct.
L 22 Q After the September 24, 1977 transient at 23 Davis-Besse, you created more than one site problem f'N J
24 report relating to that transient, didn't you?
25 A I don't know how many site problem
1 Faist Il4 2 reports are created really for that.
3 Q All I am asking you is, you created more 4 than one, didn't you?
i
( 5 A You asked specifically to that transient i 6 and I don't remember any more than j ust the one.
7 MR. SELTZER: Let me mark for 8
identification GPU Exhibit 491, which is a site r-9 problem report which you originated on November 2, 10 1977 and signed in March 1978, e5#itled j 11
" E: < tromatic Relief Valve Modification - .
12 SPR J 2."
13 (Site problem report originated-by Mr.
14 Faist on November 2, 1977 and signed in March a
15 1978, entitled "Electromatic Relief Valve 16 Modification - SPR 386," was marked as GPU 17 Exhibit 491 for identification, _aslof this date.)
18 Q Is GPU Exhibit 491 a copy of he site 19 problem report which you originated in November 1977 20 and signed in March 1978? '
n 21 A It was originated'in November 1977 and the
(_ 22 a SPR was signed off, closed off by me on what looks like ~
1 23 t the date of 3/78.
^ .r5
. .(j[ 24 Q It is correct, isn't it, that this site-25 problem report describes repairs to the Davis-Besse
s l i \
'a 3 1 Faitt 115 O
d .
T 2 pilot o'perated relief valve following the September'24, 3 1977 transient? t g *
,. i s 4 A 'Yes, that is a description of it.
5
({ Q I would like to refer you to the earlier 6 SPR that grew out of the September 24th event, GPU' s
. s 7 133.
n '
8 '
Do you'see the title in 3the upper right- ,
T 9 hand corner of the first page? '
, s 10 A Yes. ,
11 Q It looks like, "SFRCS trip /reactbr trip /-
12 coolant spill." ' '
13 -
' What does the phrase " coolants spill" 14 refer to?
15 A Primary system water leaking out of the 16 primary system. '
t 17 Q In other words, a loss-of-coolant 18 accident?
19 A In at u ; 7 icular case, yes. The spill 20 here is referring to water that had been spilled into 21 the containment building fro,m the quench tank.
L 22 Q Prior to the Davis-Bess 6 September 24, 23 1977 event, had you ever heard of any other event
() 24 in which a rea~ctor coolant drain tank rupture disk 25 had blown? '
- 1
1 Faist 116 2 A I recall hearing about a rupture disk or 3 a rupture disk blowing. I don't recall 4 specifically what plant.
( 5 MR. WISE: I just might say I let him 6 answer that question. If you want to have a 7 memory test, that's fine. You marked a letter 8 dated July 31, 1975 that he signed as GPU 9 Exhibit 490 that refers in the first paragraph 10 to the quench tank rupture disk b, lowing. I 11 believe that was with respect to the Oconee 12 event.
13 MR. SELTZER: I had forgotten about that.
1 0
14 A Let me mention these documents that you 15 are showing me right now, I had completely forgotten 16 about that until counsel brought them to my attention 17 last week. .
18 Q Which documents are you referring to?
19 A The SPR revision or'the SPR on the 20 e'lectromatic relief valve, site operations manager 21 letter on that subject.
L 22 Q .Did you ever discuss with anybody who 23 had any responsibility at B&W for training, the
( 24 matter of changing the training so that the type of 25 confusion and mistakes which had occurred in the r - , w -r = w y v yw
1 Faist 117
/ T NJ 2 Davis-Besse control room on September 24, 1977 could 3 be avoided in the future?
4 A I don't remember discussing with anyone 5 in training about trying to avoid mistakes that
({
6 Davis-Besse operators made. I was totally convinced 7 by the TMI or the Davis-Besse personnel that it was 8 just a problem with their operation and in not 9 following their procedures. I had no reason to 10 believe that there was any procedure of retraining 11 that was required. Discussions with Mike Derivan 12 led me to believe that, that he realized the mistake
~./ 13 and that if they had followed their procedures, they 14 would not have had the problem. He-admitted knowing 15 that they were in error. There was no reason for me 16 to discuss with anyone in training about retraining.
17 Q So the answer is, no, you never discussed 18 it with anybody in the B&W training grouph 19 A That is correct.
20 Q Do you know that Davis-Besse personnel 21 repeatedly asked B&W to include in its simulator L 22 training, training on events like the Davis-Besse ,
23 transient of September 24th?
l'(/) . 24 MR. WISE: I object to the form of that 25 question. The witness may answer that.
l' Faist 118
(~)
\'
A 2 I can't answer that. I have no knowledge 3 f that. .
4 Q You took Derivan's word for it when he said the operators' -actions were inconsistent with the
{ 5 6 procedures?
~
7 A That's correct, I did.
8 Q Tc . iti s day, have you ever looked at the 9 Davis-Besse procedures that were in effect to see 10 whether the operator action was con sisten t or 11 inconsistent with those procedures?
12 A I know they were inconsistent from looking s
13 at their procedures.
14 Q Let me show you the procedure that was in 15 effect at Davis-Besse on September 24, 1977 and you 16 show me what was inconsistent in there.
17 I am showing you GPU Exhibit 1004.
18 MR. WISE: Mr. Seltzer, could we have 19 identified what Exhibit 1004 is? Exhibit 1004 20 appears to be e copy of the emergency procedure 21 1202.06 for the Davis-Besse plant entitled L 22 " Loss of Reactor Coolant and Re actor Coolant 23 Pressure."
f~)
v 24 MR. SELTZER: This is Revision 1, which 25 was in effect until Revision 2 replaced it
1 Faist 119 A
~/
2 on December 8, 1978.
3 A .I don't ever remember reviewing this 4 specific procedure.
5 Q What procedure do you believe their
((
6 termination of high pressure injection was inconsistent 7 with, then, if you don't remember reviewing this 8 procedure?
9 A I had no idea what pro'cedures they were 10 using in the control room. In the transient they 11 could have used a series of procedures.
12 Q How could you be so dogmatic in saying
/~h
.(_)
13 you know it was inconsistent with the procedures if 14 you don't know what procedures were in effect at the 15 time?
~
16 A I accepted Mike's explanation and his 17 judgments as a responsible shift foreman that they 18 were in error.
19 Q So you retract your prior testimony that 20 independent of Derivan, you knew that it was 21 inconsistent with the procedures?
22 MR. WISE: I don't know if it was clear 1
l 23 that that is what the witness was saying. l
()
v 24 MR. SELTZER: Read back his prior answer.
25 (The.cnswer was read as follows: "I know
1 Faist 120 0 2 they were inconsistent from looking at their l
3 procedures ")
4 Q That is the answer. "I know they were 5 inconsistent from looking at their procedures."
6 Do you retract that answer?
7 A If your question is do I specifically 8 recall --
9 Q The question is that you said you knew 10 that their action was inconsistent with,those 11 procedures, you knew that it was inconsistent 12 through looking at those procedures, you testified?
T .
'-- 13 A If I said that, I didn't mean to say -
14 '
that.
15 Q Do you retract that testimony?
16 MR. WISE: Let's not get silly.
17 MR. SELTZER: I beg your pardon. I am 18 not being silly. I am being extremely serious.
19 A I accepted Mr. Derivan's word and the 20 checks that he had done.
21 Q So do you retract your prior testimony.
22 where you said you knew from looking at the procedures 23 that the operators were in error?
24 A Yes, I didn't mean to say that I went 25 and reviewed those procedures line by line.
.w- -
1 Faist 121 0 2 Q Did you review those procedures in any 3 way, shape or manner, line by line or otherwise?
4 A That.was not my responsibility, to go 5 through line by line those procedures.
6 Q I am not asking you whether it was your 7 responsibility. I am just asking, did you in any 8
way, shape or manner ever compare the operators' 9 actions with the procedures?
10 A I had no reason to and I df,d not do that. ;
i 11 I accepted Mike Derivan's word on that, 12 k Q Did you have at your disposal a copy of 1 '
'- 13 the Davis-Besse plant's procedures? ,
\
14 A Could have gotten a copy, y e s '.
15 Q Did you ever from time to time look at 16 any Davis-Besse procedures?
17 A For information, yes. '.
18 g other than through conversations with 19 i attorneys fo r B&W, have you ever learned that in the 20 licensee event report for the september 24th transient, 21 Toledo Edison stated that the operator actions were 22 timely and proper throughout the sequence of events?
23 A As mentioned earlier in my testimony, I had (a') 24 not seen any of those LER's until counsel had shown 25 them to me last week.
1 Faist 122
>x '
U 2 Q Have you ever learned in any way -- l 3 you don't have to read something to learn that it is 4 contained in a writing -- have you ever learned in -
g 5 any way other than through counsel that the' licensee 6 event report for the September 24th transient 7 announced that the operator action was timely and 8 proper throughout the sequence of events?
9 A No.
10 Q Based on your understanding,of the 11 Davis-Besse operators' conduct on September 24, 1977, 12 you knew that it was not timely nor proper throughout i
fx-'I 13 the sequence of events; isn't that right?
14 A No, that is not true. The overall 15 response of the operators was not completely ,
16 understood on my part until discussions with Mike 17 Derivan, and I don't recall when that actually took 18 place.
19 Q You knew as of the September 29, 1977 20 meeting that the operators' actions in terminating 21 high pressure injection at'four minutes and a half L 22 was incorrect, didn't you?
23 A Yes, I did.
24 That was action that they took during Q
25 the sequence of events of the September 24th transient,
l 1 Faist 123 p .
U 2 right?
3 A Yes.
4 Q So you knew that what they did at
{ 5 4-1/2 minutes was neither timely nor proper conduct, 6 right?
7 A At some time, yes, I realized that it 8 was not timely nor proper conduct in doing that.
9 Q You knew that on September 29th?
10 A Yes, in the B&W meeting. E 11 (Recess taken.)
12 MR. WISE: I just have a couple of 13 questions.
14 BY MR. WISE:
15 Q Mr. Faist, you were the site operations 16 manager at Davis-Besse, as I believe has been 4
17 testified to on direct, during 19777 .
18 A Yes.
19 Q You were located in Ohio where the plant 20 is located?
21 A Yes.
L 22 Q The September 24th transient occurred 1
23 on a Saturday, I believe?
24 A Yes.
25 Q Were you on site at the time?
1 Faist 124 2 A During the day but not during the actual 3 transient.
4 Q You were off site when the transient 5 took place?
(
6 A Yes.
7 Q You were not present in the control 8 room?
9 A No, I was not.
10 Q When did you first learn t h,at the 11 transient had occurred?
12 A Saturday evening. Late Saturday evening.
13 Q How did you come to learn of it?
14 A I got a phone call from Jack' Evans.
15 Q How long a telephone call was that?
16 A Five minutes.
17 Q Did you do anything further on Saturday 18 the 24th with respect to the transient?
19 A No.
20 Q Did Mr. Evans tell you whether the plant 21 had been put into a stable condition as of the time L 22 that he talked to you on the phone?
I 23 A Yes, he did.
[J
~T 24 Q Was it in a stable condition at that time?
25 A I can only attest to what Mr. Evans told
1 Faist 125
-s -
U) 2 me that it was stable.
3 Q Did you do any work on the Saturday 4 transient during the following day, Sunday, the
( 5 25th?
6 A Yes.
7 Q Could you describe what you did?
8 A I sat in on a meeting that Jack Evans 9 had called in which he described the events that 10 preceded the night before and listened (to a report 11 that Terry Murray had r'ead with regard to the 12 transient ~ and listened as Jack Evans discussed what 13 follow-up action he wanted to take as far as repairing 14 the damage to the plant.
15 Q Were you to be involved in any of the work 16 that would be required as a follow-up to the transient?
17 MR. SELTZER: You mean as B&W site 18 representative?
19 MR. WISE: Yes.
20 A We had been asked, B&W had been asked to 1
I 21 help delog the reactimeter data. And I had called L 22 some engineers into the site to do that and start 23 delogging and tabulating data.
l
(~% 24
( ) Q That occurred on Sunday, the 25th?
25 A Yes.
o 1
Faist 126 l9
\_)
2 Q Did that work continue on Monday and 3 Tuesday the 26th and 2 7th?
4 A Yes, it did.
5
(( Q I believe Mr. Seltzer marked some notes 6
and attendance list for a meeting that occurred or 7
appears to have occurred at the Davis-Besse site on 8
the 28th, which would have been a Wednesday.
9 To your recollection, had'all of the 10 information and data concerning the Saturday 11 transient been assembled as of the time of the 12 meeting at Davis-Besse on Wednesday, t e 28th, if that O 13 is the correct date, or was that work still continuing?
14 MR. SELTZER: I object. I think the 15 question is unfairly vague, since you are not.
16 specifying what data. He has already said 17 they had reactimeter data that showdd what the 18 temperatures and pressurizer level'were.
19 MR. WISE: I think he said the work had 20 begun on Sunday in getting that information 4'
21 out of the machine. I am simply trying to I k.
22 establish whether the work on collecting the 23 data was still ongoing during the early part of
[\_)) 24 the week which began on Monday the 26th, that's 25 all.
1 Faist 127
(~ ~
U) 2 A Yes, the reactimeter data was collected 3 and plotted prior to Wednesday. I don't know if 4 all the data, all that we know today, was collected for that Wednesday meeting.
{ 5 6 Q Were you involved during this period of 7 time in any work required to make repairs to the 8 Davis-Besse plant as a result of the transient?
9 A Not B&W; Toledo Edison took all the action 10 to repair the damage. !
11 Q Now, you have testified about the meeting 12 in Lynchburg on the 29th. I take it you flew down
(~h -
\- 13 to Lynchburg for that meeting?
14 A Yes.
15 Q And then did you return from Lynchburg 16 to the site thereafter?
17 A Yes. .
18 Q Was that the same day?
19 A I believe it was the same day.
20 Q Was there a further meeting at the Davis-21 Besse site following the Lynchburg meeting on the L 22 29th?
23 '
A Yes, there was.
l
[)
V 24 Q When did that occur?
25 A I believe that was on the 30th, the day l
1
1 1
1 1
Faist 128 a 2 after I had gotten back from the site.
3 Q Who was present at that meeting?
4 A A number of NRC personnel, Jack Evans,
( 5 Terry Murray, Larry Stalter, Lowe Roe. Several B&W 6 people who had come up with me from Lynchburg.
7 Q Who are the B&W people who had come up 8 with you?
9 A I remember Joe Lauer, George Myers, Art 10 McBride, John Dempsey. ,
11 Q Well, who spoke on behalf of the Toledo 12 Edison Company?
Cs 13 A Lowe Roe did the speaking.
14 Q Did anyone else from Toledo Edison speak?
15 A Yes, Larry Stalter spoke, explaining 16 some of the transients, and Te rry- Murray also spoke II with regard to operators, operator action.
18 Q What did Mr. Murray say about operator 19 action during the transient at that meeting?
20 A Mr. Murray indicated --
21 MR. SELTZER: I object. There is no C 22 foundation that this witness can recall the 23 detail.
()- 24 Q You may go, ahead and answer the question.
25 A I specifically remember Terry Murray
- _ , _ _ ~ - - - - , -- __ _ , ___ - . , . ._
1 Faist 129 2 making the statement that B&W had told them they i
, 3 had made a mistake in terminating HPI.
4 Q Do you remember anything else that Mr.
5 Murray said?
{,
6 A Not specifically on that.
7 MR. WISE: That is all I have.
8 (Continued on the next page.)
t 9
10 t 11 q 12 6 13 "
14 15 16 17
' e 18 i
19 ,
20 21 22 23 24 4 25
1 Faist 130 l
\- 2 FURTHER EXAMINATION 1
3 BY MR. SELTZER:
4 Q Did Murray say who from B&W had said they 5 made a mistake in te rminating HPI?
{
6 A He did not mention names. There was a 7 pre-meeting between B&W and Davi s-Be s s e on site prior 8 to the NRC meeting. It was discussed in that meeting 9 and it was b ro ugh t out that Terry Murray and those present.
10 of the operators did make a mistake in te rminating HPI .
11 Q Did Murray say when B&W had told him that 12 the operators had made a mis take?
(h N._/ 13 A In the NRC meeting?
14 Q In the meeting where Murray said that B&W 15 told them they made a mistake in terminating HPI.
16 A In the NRC mee ting Terry Murray did not say 17 when B&W had told them.
18 Q I thought you said that Murray's statement 19 was made at a pre-meeting between B&W and Toledo Edison?
20 A B&W informe d Terry Murray in the p re-me e ting 21 th at the ope rato rs did indeed make a mistake by 22 terminating HPI. Terry Murray in the NRC meeting 23 passed only th at comment to the NRC and those prese nt .
24 Q Did you take any notes at that meeting 25 between Toledo Edison, B&W and NRC on Septembe r 30, 1977?
1 Fais t 131
/~')
("/
2 A No, I di dn ' t .
3 Q What if anything has refreshed your recollec-4 tion that Te rry Murray made the statement to the NRC?
5 MR. WISE: I object. The re has been no
{
6 evidence that his recollection has been refreshed 7 or needed to be re f re s h e d . The witness may answer 8 the question.
9 A I specifically remembe r Terry s tanding up 10 and making that statement. t 11 Q Have you ever told anybody else other than 12 counsel in preparation for this deposition that Te rry
/~N (s 13 Murray made that statement?
l 14 A I don't reme mbe r if I have discussed that 15 with anyone else.
16 Q What, as best you can recall, did Te rry 17 Murray say? .
18 A Terry Murray was in the back of the room 19 and Jack Evans had a seat up front. When the 20 discussion of operator response or the question of 21 operator response had come up, Jack Evans turned around 22 to Te rry Murray and Terry Murray had made the statement l
23 with regard to HPI termination. And I remember that I
[')
U 24 specifically because I was sitting about four se ats away 25 from Jack.
l 1 Faist 132 A .
U 2 Q You are getting warm, but I am seeking to
! 3 know what did Terry Murray say. You said he made the 4
statement with regard to HPI termination. What did he
{ 5 say? What is your best recollection of what Te rry 6
Murray said regarding HPI?
7 A I recall Te rry s aying that we had had a 8
discussion with B&W 1ast night. B&W had told us 9
that we had made a mistake in terminating HPI.
10 HPI was --
should not have been te rmindted.
11 Q Did anyone from the NRC respond to that 12 statement by Murray?
13 A There was no reaction. Not in that meeting, anyway.
14 And I think because of that Terr Harpster 15 was involved in some of these meetings and discussions 16 and was aware of that also.
17 Q Lid Murray explain in what way the 18 operators handling of high-pressure injection was in 19 error?
20 A I don't recall him ever getting into that 21 discussion there.
L 22 Q Did anybody i
explain to the NRC at that 23 meeting what it was that had misled the operators !
l (~}
%./
24 into terminating high-press ure injection.
25 A Th at was the only thing I remember with i
i
=
, - --m - , w e-- - - .. ..-.n
1 Faist 133 O 2 regard to terminating the HPI. That was stated by Terry.
3 Q In other words , you don't recall anybody 4 stating to the NRC what had misled the operators into
( 5 terminating high pressure injection?
6 A No.
I 7 Q No, you do not?
8 A I don't remember.
9 Q Do you re call that at a September 28, 1977 10 mee ting which you attended as I think you indicated by i
11 your signature on the attendance sheet, GPU Exhibit 488, 12 that Toledo Edison personnel stated th at as a result O
k- 13 of the Sep te mbe r 2 4 e ve n t they wanted an in te rlock I
14 installed at their plant to shut the block valve if 15 the pilot operated relief valve failed in the open l
16 position again?
17 A I didn't even remember that meeting.
18 Q Do you remember any meeting at Davis-Besse 19 after the September 24 event at which anybody from Toledo 20 Edison indicated they wanted an automatic inte rlock to 21 close the block valve if the pilot-operated relie f valve m
22 failed open?
23 A I remember the subj ect coming up. I don't Ih
\j 24 know who brought it up. I know there was not a strong 25 feeling to input it, to make that change, and I remembe r
s 4
i Faist 134 I i
)
Fred Miller of Toledo Edison having voiced quite a bit s
3 of engineering arguments on it.
i 4
Q Do you recall subsequent to the September
]
5
{ 24, 19 77 transient that Toledo Edison personnel said 6 they wanted to have a more direct indication of the i
j 7 open or shut position of the pilot-ope rated relie f 1
8 valve?
9 A Yes.
J 10 l
Q What if anything did B&W dd, after the
! 11 September 24 event at Davis-Besse to design or install
) _
12 or re commend the installation of a more direct 13 j i,ndication of the open and shut positio,n of the 14 pilot-ope rated relie f valve ? '
i 15 A There was a response to-that request by 1
i ?
4 16 Toledo Edison that basically said the instrumentation 1
i j 17 that you have available is sufficient to determine that 4
! 18 the PORV is open or partially open.
Ther was no i
19 positive means of dete rmining actual valve' position 20 because of that -- the desi'gn of that valve certainly i
21 available at th at time. It was based on what was known l
- k. 22 at that ti me .
l 23 Q Who made the response th a t you just l 24 des cribe d?
~}
25 A I believe it was Tom Fairburn.
1 Faist 135 O
~
2 Q What form did his response take?
3 A In the form of project management letter to 4
I think it may have been Chuck Domeck.
5 Did you see that letter in the course of Q
6 your preparation for deposition?
7 A I couldn't find it. I did not see it. I O
recalled it.
< 9 Did you look, for it in the course of Q
10 preparation?
11 A I did not specifically, but counsel 12 did.
IO 13 MR. SELTZER: I have no f urther ques tions .
14 MR. WISE: Could you identify for the 15 record who Mr. Harpster is? You mentioned him 16 during one of your responses to Mr. Seltzer.
17 THE WITNESS : Te rry Ha rps te r .was an employee of the N RC .
10 MR. WISE: Thank you.
20 (Time noted: 4:30 o' clock, p.m.)
21 22 Fred Faist Subscribed and sworn to before me "3
this day of 1982.
24 p%/ {
l 25 N tary Public '
l
, \
1 136
=
2 CERTIFICATE 3 STATE OF NEW YORK )
t
- ss.*
4 COUNTY OF NEW YORK )
5 6 NANCY A. RUDOOH ~
I, , a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9 og FRED FAIST Was taken before 10 Tuesday, March 23, 1982 me on h 11 That the said witness was duly sworn 12 hi8 before the commencement of testimony and O ^ 13 that"the within transcript is a true. record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with.any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
J
, 20 IN WITNESS WHEREOF, I have hereunto set 7~
21 my hand this 2 5 ) day of /7I e 1982.
L _
22 93 O' 24 wWe h1 NANCY A. RUDoLPH -
25
137 I N DE X WITNESS PAGE FRED FAIST 3 EXH I B IT S GPU EXHIBIT FOR IDENTIFICATION 486 Resume of Mr. Faist 3 e
487 Bab co ck & Wilcox site office repo rt dated 10/10/77 37 488 Fi ve-p age document e ntitle d I
" Review o f Incident on 9/24/77" 84 l
e 489 Site instruction from Wandling to dis t rib uti o n ,
which includes R. J. Baker,
~
subject: Electromatic Re lie f Valve Malfunction, dated July 15 , 1975 110
\
490 Lette r by R.J. Baker to Jack l Evans, dated July 31, 1975, I "S ub j e ct : Solenoid Pilot Operated Pressurizer Relief Valve - PS V- RC2 " 112 491 Sito problem report origi-nated by Mr. Faist on No v. 2, s,/ 1977, signed in March 1978, entitled "Electromatic Relie f l Valve Mcdification - SPR 386" 114 I 1
, / yy M w c 5. LA d-P* 2, Q MNMhW
~
h -
DESIGNATION OF \~ l FRED FAIST DEPOSITION '/
I i
Direct Examination bv R. Seltzer l l
1 Pace Line to Page Line Summary g n d Sp i 3 23- Eu i j 4 6 4 k Currently esident Engineer -
TMI Unit 1 (since 7/79)
,v 5 2K 6 4 At B&W Faist worked in thermo-hydraulics engineering section.
NSS design.
t 6 23 7 15 Faist in thermohydraulics for 3 yearc (1968-1971) 5-3 en-gineers in section; supervisors Tom Helris, Rbt. Walker.
O V T f , 8 19 9 2 Did calculations to substan-
/ tiate previous . calculations in reactor vessel internals, h- 10 6 11 11 Verification of pressure dropsf-
.h fluid flow calculations in reactor vessel on inle , across various components of internals; hot reactor coo). ant punps, NPSH curves. ,
11 10 11 23 i (j/ jo d .,g p&gBr.W. suretopic from*ae HPIon on -effect reactorofvessel pres-MMp A M components, prepared within W cu u ) last two yez.rs.
> /
12
& & hf
? M)Ay B&W owners group. ~l-l p j
j:I, , . , Yr r l /~ G ! 1-5 9 - a Q cf y
'. A 14 13 14 19 In therrial hydraulics section l c'
c'M4;uri~,. Faist did heat transfer cal-culations for certain control l
l C) components (rods - orifice, i - burnable poison, control and I axial power shaping).
i'
- 1 Page Line to Page Line Summary ~
14 20 14 25 Faist did no work on LOCAs.
i 15 2 15 10 Thermal hydraulics section did calculations for DNBR (departure from nucleate boiling) (Hennessy, Levandoski).
16 19 17 7 Faist did some work on hypo-thetical accident which involved effects of saturation on heat transfer. -
4 %%dV4
/ A7 13 17 23 No knowledgen M ykis oI RCS saturation on pzr level (pre cW-et TMI) .
. E
/* M7 24 18 21 Faist learned as a result of DB 9/24/77 event that RCS saturation raised pzr level.
Never heard of other transient O at B&W plant or any other incident like that. DB 9/24 first time h'e'd heard of that phenomenon.
f
v
- 4 11 19 15 Prior to DB 9/$.4 Faist never heard of pzr level rise while
- pressure fell.
- / 19 20 21 8 M
Faist receivedasite problem reports (SPRs) (of transidnts at other plants) from some sites (not all). Also received Site Instructions to communicate information to plant management.
/21 15 22 2 No company wide meetings of site operations managers.
O '
i I
i ..
Page Line to Page Line Summary 42 3 22 10 SPRs sent for information -
if applicable to " customer",
Faist would inform of event or incident at another plant.
42 11 22 22 Faist regularly read and in-formed. Plant staff made evaluation of applicability
("They" more familiar with plant).
. l A 23 23 4 Information from SPRs sometimes in writing, sometimes orally. i d3 23 24 7 Faist reviewed SPRs for appli-cability to his plant.
iM!4 8 24 19 Faist denies SPR's best source of information on problems at other plant - SPRs not written on every problem, much oral communication with Lynchburg.
/24 20 25 5 All sources of information treated equally (phone site instructions SPRs). j
^~ - - - Faist in daily telephone con-g-g tact w/ Bill Spangler at Lvnchburg cam }w & 4cJ k 4 %on DB start-up status;
- d5 20 27 24 . Spangler mention events at other plants. Sometimes in-tended Faist to determine applicability aty DB A%
/ 27 YkD 25 28 15 Faist described unusual events at DB in calls to Spangler.
(Sometimes followed by SPR.)
$ PW,, E M N
(
O .
g . +. *
, _y -
Page Line to Page Line Summary 28 16 28 25 Faist participated in some operator training and simu-lator courses prior to TMI (additional simulator post TMI).
>'9 30 13 30 23 Training courses were sporadic
("a week here a week there") in early 70's by Training Depart-ment and perhaps by Field Services. *
)( .31 7 31 19 Prior to TMI Faist had 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> simulator training (20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> classroom 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> at simulator) in early 1970's*
(B&W personnel only).
- y. 32 11 33 14 Faist knew B&W Simulator re-n programmed after TMI-2, but unaware of its capabilities O between 9/24/77 and 3/28/79.
V, 34 10 35 25 Didn't know simulator could not
'\ show boiling; going solid.
-36 2 36 6 Never consulted on content of training program for DB ops.
l f3) 42 11 42 20 No recollection of meeting with Elliot on site at DB.
,- 4- ,
g,
- v4~2 21 43 15
, Faist recalls Kelly coming to
- . L g.v .
site shortly after 9/24.
f s y3 .
Spangler said Kelly would
- E Mg s.q3 fg f g.
gather data on 9/24 transient.
- V3
( 17 V3 li g 1 * -(3 25 44 6 Kelly obtained reactimeter data.
M(,$d).I Uncertain whether Kelly got i 7 ,4T control room logs.
45 19 46 15 Faist spoke to DB personnel --
bk can't recall before or after Trng Rm B Lecture. Spoke to Derivan, Evans (station mana-ger) -- Murray spoke to " group" (Faist) was part of. .
, 4 .
O ee e w=*
- - -- - --._m _ .,m-- - - - - - . _ . , - , __.-_m , . - , , ..p-. 9, -9
, s Page Line to Page Line Summary
- 46 16 47 2 v- Faist did not know DB prepared A (credibility) LER on 9/24 event prior to
. preparing for deposition.
47 4 47 8 Faist could not recall what information supplied to DB from B&W [for LER].
,h 47 14 47 22 Faist received some LERs sub-mitted by DB but not all.
% (credibility)50 19 50 25 His files did not have LER of 9/24 event.'
b y ~l4 9h'1 Al 8 51 18 Faist knewdDB ops. terminated HPI when pzr above normal range in initial minutes of transient.
- d2 11 52 25 Faist prepared SPR for 9/24 event (GPU Ex. 133) ultimate responsibility.
- v53 12 53 16 Reviewed prior to dissemination --
believed accurate.
O
- v53 25 55 2 Faist examined charts on pp.
29-30 showincj plant parameters compared with each other. True
/ that when HPI turned of CS 9/ pressure trending.4
./.
- tA 5 7 56 13 Faist knew prio'r to Trng Rm B T
f g Lecture that HPI terminated P when pressure 4r; knew 21 minutes fy ,_ g y ;7 to close block valve for stuck PORV. HPI started later.
] ~
/!- 56 17 56 25 Faist stated " knew [HPI]
.I' (B&W) shouldn't have been terminated 7 to begin with. . " because of RCS pressure. . .hriorto Training Rm B Lecture (contra-dicted at pp. 71,76)] 2.5-t/
A7 24 58 16 Confirms chart reading that ops, restarted HPI (only) when pzr fell belowjoperator range.
M aftm ,d y'W l ,
7 t l s ,
I Page Line to Page Line Summary. ,
- 50 17 60 9 Faist understanding that
, (B&W) operators experienced LOCA, failed to recognize, got con-fused, not looking at all para-3.& 60 .2Y meters, just pzr. "Their narrow view initially caused them to terminate HPI prematurely and reinitiate for the wrong -
[ reasons." Operators indicated following prr -- made another mi. stake in sconcluding they had saturation (sic). ,
- 60 10 60 24 De'ivan r told Faist he had made (credibility) an error by failing to look at all parameters. Derivan was
" kind of down on himself".[ Note
, Derivan denies this.]
l
~ -
- 61 4 61 16 , Decivan said'he'd been trained (credibility) : to look at all parameters.
M y64 9 64 19 Faist eennot recall when-DerivanJsaidvhe saw saturation.
O. * .-46 5 66 18 e+ Jioud.r W 4~g G kla '
Faist understand operators turned on HPI based on falling pzr level.(computer sequence).
N ~
70 16 71 3 Derivan did not indicate that
/' he realized hig, mistake z while decling with the transient. s dl 9 <
71 25 \ksAt Training Room B meeting Faist knew that operators had made a mistake.in terminating
,y., new HPI not initiated until m2.nutes af ter block valve shut.
r
- 72 7 72 '21 ' Faist didn't recall checking i (credibility) DB procedures to determine I whether operator action as l , consistent.
J 7% :1.L ~13 f '
, A
- 72 22 73 7 Derivan said didn't follow yj (credibility) n procedures . [Larivan denies.]
' K.
73 12 74 12 Faist aware of Limits & Pre-ss cautions. '
Not aware of L&P on P*#* \
! , T ,
. xN s ,
l
~ - - ~ - - - - - - - ~ - ' - - - - - - -
, s Page Line to Page Line Summary 1
- 76 10 76 20 Faist does not recall his opinion prior to Training Room B of " incorrect use of HPI"
'11 13 '19' 2 - C U b m of efHM (credibility) 77 13 78 11 fg*
- Contradicts when saw & O.
depres-s_ur,ization with no HPI - knew 9
j g) HPI misma lniid W hefore Training '
Room B.
i N i
% Prior to Training Room B presen-
/ tation, no knowledge of other
[. / B&W plant:
N Nu Y*/,. d8
- 25 79 7 n with fuel loaded.
Y 4 to 99 /2 g* */ * }79 19 79 25 pzr level up while pressure #
- A0 2 80 22 Operators had incorrectly
, managed HPI6 GPU Ex. 488 Site Meeting 9/28/77 Confusion as to date of Lynchburg, meeting (9/29/77).
i' 46 13 86 23 Faist travelled to Lynchburg for 9/29 meeting. Bill Spangler
- summoned# . A large number of B&W managers attended.
- -O 18 87 23 No recollection of another of that sort of presentation prior to TMI-2.
-M 24 88' 4 Faist asked to_" provide an understanding ,of what happened
$)<
g [.A 9 89 7 at DB". ,
4 -
Recalls only himself and
/
x/
- f e
Vs0 p.9 3 6
fo 90 24 c Kelly spoke %
- leeting was unique -- feeling'of i
/ # 01% lot of data to be collected and
/ M* . M MN presented timely manner. [But i
- .y4, % Faist never got a copy of Y, " L1;f LER.. 71]
g %
,s vs4 13 96 3 Kelly and Faist divided topics:
!' Kelly'SFRCS, Faist SFRCS and PORV Sticking. No recall of pd who discussed HPI) Lt g h
" H-
Page Line to Page Line Summary
_447 17 98 13- Either Faist or Kelly presented fact of mismangement of HPI.
A8 13 98 21 Bert Dunn principal participant in. discussions.- ,
% 4A pw-- = ~
- dOO 6 100 10 Re: Rogovin testimony at 25 --
(credibility) Dunn's statement reinforced Faist's conclusion that HPI , /
termination in error.
4 01 2 101 23 Concern about pump reptart --
side i-n% senew p_,- m - dt+ &
4 /102 10 102 25 Faist doesn't know why took
\
4
/ .
until y/29 know mistake to 4 S t rmirikte m u.x HPIo at_m 4 ,l/2 m g min.&, -
'Q Y t/*['
Review of Rocjovin deposition V testimony:
{/- b to3 .2. /03
., y v v106 5 106 16 First became aware of Eng. Dept.
\ #\/ concern over premature termina-tion was at 9/29 meeting.
- 106 17 107 11 Contradiction -- first time be-(credibility) came aware of Kelly, Dunn memos after TMI-2 after Rogovin testimony.
d 09 19 110 3 Rogers at TMI got SPR for information.
d 10
~
- 112 19 4 GPU 489 Site Instruction 7/15/75 Wandling to distrib. re Elec.
Valve Malf. -- standard form,
,- sent to TECO.
/12 5 112 10 Faist's understa'nding that B&W staff to communicate fo DB.
W /2 c A M 4 12 11 112 18 GPU 489 concerned valve malfunc-tion at Oconee.
A'13 10 113 21 GPU 490 letter Baker (B&W) to Evans (TgCO) re valve to com-municate p M lem even though DB had Crosby valve and Duke had Dresser.
- Mgm.G ge 4 eM et es eg a e&O 4
,e - - . - . . -, - , - . _ _ . . , - . y- . _ . . . - - ,
. , . , , ,y . ,y
e-Page Line,to Page Line Summary
./ 114 10 115 4 GPU 491 SPR 386 -- mod. to yalve created 11/77 signed 3/78.
Id'd describes repairs to DB PORV following 9/24.
116 2 117 16 Never discussed changing training because he was " totally con-
/[
~
.[*y 117 vinced" that was problem with 4~-
operation and not vunproc.
m
, 20 118 3 No knowledge of request to include 9/24 in simulator.
- / 118 4 118 13 Faist knew operators action
), inconsistent from looking at
,/,[k'y t
/ 118 14 119 11 their proc. -- No recall of
.d ,
credibility) looking at EP 1762.06. No 7,#,
Tliq la /1r idea what proc. they were using.
J17 -
5 * /119 12 119 /V Faist " accept'ed Mike's explana-(credibility) tions as a responsible shift fore-1 man that they were in error."
/120 9 120 25 Faist retracts testimony that O (credibility)
Qti (, Q
~
/121 10 he knew from looking at proc. --
didn't look at them at all (but were available) .
122 2 122 9 Never learned that LER reported (credibility) operators' action timely and proper.
?
122 10 122 18 Faist didn't " completely under-
.. stand" operator response until conversation with Derivan - can't recall when took place. [Derivan says never.] -
(
- 122 19 122 23 Knew on 9/29 that EPI termina-tion was incorrect.
- Cross Exam by R. Wise j
123 22 124 19 Faist not present during transient. Evans called late p evening. Evans said plant f e,,4' .p / g / 2 e/ -
// /2 y 9 stable.
M# /h 3 h 14 faistattendedmeeting9/25.
f,;,yf MurYai described transient.
. Evans discussed repair.
l 1
1 Page Line to Page Line Summary .
l
- / 125 15 125 25 B&W asked kelog reactimeter data.
{k y 1] /127 5 Reactimeter data collected 4
and plotted prior to 9/28.
127 6 127 10 TECO repaired all damage.
q 127 11 127 19 Faist flew to Lynchburg for meeting.
y '
127
/A7 20 D
128
/:LP 17
(,
9/30/77 meeting at DB with 0 9, NRC personnel a~nd B&W* people came from Lynchburg (Laver, Myers,;
- f2 9, /s g,pf 3 , McBride, Dempsey); Murrayy and Roe spoke for TECO. St & )
. ,v
- 128 18 129 6 Murray said B&W told them made
/ (credibility) a mistake terminating HPI. No
- , recollection ~of anything else.
- [Give me a break...!]
x/
i Redirect Exam by Seltzer Y * /130 4 130 23 Pre-meeting between B&W and i
TECO -- then B&W informed Murray that operators "did indeed make a mistake."
(jumbled testimony) Murray passed that comment at the
- NRC meeting. [No one else has
'M ever said that;]
-- D G 130 24 131 2 Faist took no notes at 9/30 is/ J /3/ fo meeting -- spec,ific recollection gj /4 /s/ af of Murray. ,
4 A32 2 132 10 Murray said discussion with B&W .
f (# y thatHPIshoulpyterminated.
d32 11 132 16 No reaction from NRC. Harpster j aware. .
d32., 17 133 2 No further explanation at that meeting.
i K .,S-133 9 133 17 No recollection of 9/28 meeting and request for interlock.
O -
, , ,-- ' , ,-p y ,,-- - - . - - , ,
9 *- ,
e l
j l Page Line to Page Line Summary j .
. 133 18 135 8 Recalls subject coming up --
no strong feeling to implement it. Miller of TECO objected.
TECO (sic.) said available l instru. adequate, no positive means available. (Fairburn to Dorneck letter -- couldn't be forcing (?) .
e 6
END OF DEPOSITION e
't m
e 9
9 4
l lO i
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