ML20072H734

Deposition of CC Faust on 810925 in 810925.Pp 713-898

ML20072H734
Person / Time
Site:	Crane
Issue date:	09/25/1981
From:	Faust C METROPOLITAN EDISON CO.
To:
References
TASK-*, TASK-01, TASK-02, TASK-03, TASK-04, TASK-07, TASK-1, TASK-10, TASK-2, TASK-3, TASK-4, TASK-7, TASK-GB NUDOCS 8306290705
Download: ML20072H734 (185)

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{{#Wiki_filter:. P/ k UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (5k-] -x GENERAL PUBLIC UTILITIES CORPORATION, a JERSEY CENTRAL POWER & LIGHT COMPANY, '( METROPOLITAN EDISON COMPANY and h PENNSYLVANIA ELECTRIC COMPANY, a Plaintiffs, 80 CIV. 1683 (R.O.) -against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., a Defendants. -x Continued deposition of METROPOLITAN EDISON COMPANY, by CRAIG C. FAUST,' taken by b Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on ,s Friday, September 25, 1981 at 9:55 o' clock in the forenoon, before Robert E. Levy, a Certified Shorthand Reporter and Notary Public within and for the State of New York. .(- h DOYLE REPORTING. INC. n CERTIFIED STENOTYPE REPORTERS 369 LsxtNGTON AVENUE WAl.TER SH APIRO. C.S.R. Nsw Yonsc. N.Y. 1o017 CH ARLES SH APIRC. C.S.R. TgLapNoNr 212 - 867 8220 8306290705 810925 PDR ADOCK 05000289 \\ T PDR

1 714 2 APpearanee s: 3 4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS. lh Attorneys for Plaintiffs 5 425 Park Avenue New York, New York 6 ANDREW MacDonald, esq., BY: 7 of Counsel 8 9 LeBOEUF, LAMB, LEIBY & MacRAE, ESQS. 10 Attorneys for the Witness 1333 New Hampshire Avenue, N. W. 11 Washington, D. C. 20036 i 1 12 BYs KEVIN M. WALSH, ESQ., l 13 of Counsel t i 14 15 DAVIS POLK & WARDWELL, ESQS. Attorneys for Defendants 16 One Chase Manhattan Plaza New York, New York 10005 17 l BY: ROBERT B. FISKE, ESQ. 18 WILLIAM E. WURTZ, ESQ., i RODMAN W. BENEDICT, ESQ. 19 -and-JONATHAN WUINN, ESQ. 20 of Counsel 21 22 -oOo-23 ' O 24 25

715 1 O 2 CRAI G C. FAUS T, having been j 3 previously duly sworn, resumed and was examined 4 and testified further as follows: 5 EXAMINATION (continued) 6 BY MR. FISKE: 7 Q Mr. Faust 3 you realize that you continue to 8 be under oath? 9 A Yes. 10 Q I would like to show you what has been 11 previously marked as Exhibit 263, which is the diagram 12 of the control room, and direct your attention to the O 13 initials CF. 14 A Yes. 15 Q Which I believe either you or I placed on 16 there during an earlier session of your deposition, 17 indicating the position at which you were at during the 18 early minutes of the transient, is that correct? 19 MR. MacDONALD: During all the early minutes 20 or -- I don't think that was the testimony. l h. 21 MR. FISKE: It is a fact -- 22 Q That let's say during the first 15 minutes 23 of the transient, except for a time when you left the ) 24 panel entirely, you were in the position indicated by f 25 "CF"? l

1 Faust 716 j 2 A I don't think I ever left the panel entirely 3 during the brief -- for the four hours easy I was right 4 in this area of the panel (indicating). 5 Q Fine. 6 A And then -- 7 Q O.K. It is a fact, is it not, that there 8 was a strip chart which showed reactor coolant system 9 pressure from the beginning of the transient forward, 10 which was located on that panel. 11 MR. MacDONALD: What panel? 12 MR. FISKE: The panel in front of the O 13 witness. 14 Q Panel 47 15 MR. MacDONALL: He indicated that he was 16 standing -- 17 A The strip chart for pressure was on the opposite 18 end of the panel from where I was at, yes. 19 Q And how many feet from you was that? 20 A I think I estimated the panel about 12 feet. Ten k 21 or 12 feet. 22 Q And there was also on that same panel, was, 23 there not, a strip chart which showed steam /N (d 24 generator -- withdrawn -- which showed T av. from the 25 beginning of the transient forward?

1 Faust 717 2 A That also was on that panel. That is the one I 3 couldn't remember yesterday, if it was a strip chart. 4 I think it is. 5 Q so there we.s a T av, strip chart and a 6 reactant coolant pressure system strip chart within 7 10 to 12 feet of the first hour, correct? 8 A Yes. 9 Q Is it your testimony that at no time did 10 you ever go look at those charts to see what the 11 temperature had been when the pressure went below 1640? ~12 A No, I didn't go look at them because I was 13 performing my function on that secondary side of the 14 panel, working the secondary side. 15 Q Now, I believe you testified earlier in this 16 deposition, Mr. Faust, and we can get the page if that 17 becomes important, that you would expect after a 18 normal reactor trip that T av. would be around 547 19 to 5507 20 A That is what I would expect. 21 Q By a normal reactor trip, I assume you mean 22 a reactor trip in which there is not a sharp drop in 23 pressure which activates HPI? ( 24 A Normal reactor trip to me at that time from my 25 prior experiences had included actuation of I l 1

1 Faust 718 p) \\v 2 high-pressure injection. 3 Q Did you understand that if immediately after 4 a reactor trip the T av. temperature leveled off at 5 547 to 550, that that would cause c.n actuation of HPI? 6 3 7.m just telling you what I became accustomed 7 to in quite a few of the trips we had. I necessarily 8 wasn't always looking at the meter to see what it was. 9 I'm just saying what I expected it to be. Q I believe you testified before that with 10 11 the exception of the transient which involved the failed- /3 open PORV, every case that had resulted in the actuation '12 ] 13 of HPI was what you described as an overcooling 14 transient. 15 MR. MacDONALD: Are you asking him to 16 confirm testimony or are you asking that question once again? I mean, you know I don't want to go 17 18 back over five days of testimony. 19 MR. FISKE: Neither do I. Because I think 20 what I just said -- 21 MR. MacDONALD: I don't think that is 22 necessarily correct. 23 MR. FISKE: If you want me to get back all ~x d 24 the reference, I will. I don't think Mr. Faust 25 will disagree. Why don't you let him answer?

1 Faust 719 O 2 MR. MacDONALD: I don't want you to mischaracterize the prior testimony. 3 4 MR. FISKE: I can assure you I'm not. 5 BY MR. FISKE: 6 Q With the exception of the transient that 7 involved the failed-open PORV, I think you characterized 8 each of the other three situations in which you knew 9 of HPI actuation as being overcooling transients. 10 A I'm saying three of the trips that -- two of the 11 trips specifically that I remember were overcooling 12 transients. I had other overcooling transients that 13 were carried out at the simulator if that is what you 14 mean. I'm not just limiting my experience just to the there were various other accidents that 15 plant. I 16 were given. 17 Q Involving actuation of HPI? 18 A Involving actuation of HPI. 19 Q On overcooling transients, right? 20 A Some of them, yes. 4 21 Q Well, was there any transient that you ever 22 s aw on th e simulator at B&W that involved the actuation 23 of HPI which was not either a loss of coolant' accident b' d 24 or an overcoolant transient? 25 A Yes.

1 Faust 720 2 Q What was that one? 3 A We had transients that -- well, there was a loss it was a loss of steam from the 4 of mass. We didn't relief valve opening being a stuck-open relief. 5 ~ 6 Q O.K. 7 A I'm getting formed into that term. The pilot-8 operated relief valve opened. 9 Q That is a transient that you actually 10 experienced at Three Mile Island in 1978, isn't that 11 correct? 12 A I also experienced it at the simulator. 13 Q Apart from that type of transient which 14 you have just described, was there any other transient i 15 that you ever experienced or knew about at TMI or on the 16 simulator that did not involve an overcooling? 17 A We had turbine trip, ended up in a runback. 18 Q Right, and did that actuate HPI, if there 19 was a runback? 20 A I don't think it did, h 21 Q O.K. I'm talking about a transient that 22 actuated HPI. Was there any transient that actuated 23 HPI other than this failed-open PORV or an over -- 24 some form of overcooling transient? 25 A well, the overcooling accident carries in with

1 Faust 721 0 anything that would 2 it a lot of your accidents that 3 cause cooling of the water. 4 Q I 5 A The steam generator, for one thing. 6 Q I understand that the phrase " overcooling 7 transient" may include several different types of 8 transients. I understand that. f* 9 A O.K. l 10 Q But with that understanding, is it correct l 11 that up to the time of the Three Mile Island accident, 12 you had not been aware of any transient either by 13 actual experience or by the simulator or from any 14 other source that involved anything other than either 15 a failed-open PORV or an overcooling in which -- 16 withdrawn. Let me withdraw that and start all over 17 again. 18 Isn't it correct that up to the time of the 19 Three Mile Island accident you were not aware of any 20 transient that would cause the actuation of HPI other 21 than a failed-open PORV or some form of overcooling 22 transient? 23 MR. MacDONALD: Objection to form. He told 24 you that there were other overcooling transients. a LOCA. 25 A I just want to make sure I

Faust 722 1 ,(j 2 Q So -- 3 A Which is a form of LOCA. 4 Q Does that complete your answer? 5 A I think it does. 6 Q O.K. 7 A Fine. 8 Q Now, going back to the transient you had experienced previously which you characterized.as an 9 10 overcooling transient, where HPI had come on, isn't 11 it a fact that in each of those situations the '12 temperature dropped below 547 degrees, that is,T av.? g- 's_/ 13 MR. MacDONALD: At what point in time? 14 A I don't know if I can answer that. To tell you 15 the truth, I expected temperature to go to 547. 16 (Continued on next page.) 17 18 19 20 21 22 23 m \\_ )' 24 / 25

1 Faust 723 O 2 Q And when you talk about an overcooling, 3 you are talking about a situation in which the 4 temperature is colder than what you would normally 5 expect, right? 6 A Right. 7 Q 0.K. 8 Is that decrease in temperature below that 9 level that you would ordinarily expect which you 10 testified causes the shrinkage in the primary system -- 11 MR. MacDONALD: Talking about general 12 knowledge now or what he experienced? (-)) \\_ 13 MR. FISKE: General knowledge up to the 14 time of the accident. 15 A I don't think there is any question about 16 that. I didn't think there was, that we or I myself 17 understood that kind of thing. 18 Q Now, so that recognizing what you just 19 said that in a situation in which there was a 20 reactor trip and the temperature never dropped 21 below 547 degrees but just stayed steady at 547, 550, 22 you would not expect a drop in pressure on the primary 23 side sufficient to actuate HPI? i 24 MR. MacDONALD: Has he ever experienced 25 that before the accident?

I Faust 724 OO 2 Q As an overcooling transient. 3 A Didn't you ask this yesterday? 4 Q I'm trying to -- 5 A We went over the same thing yesterday. 6 Q I don't think so. 7 A I've already stated that I understand 8 that an overcoolant accident, if you don't have an 9 overcoolant accident, you are not going to drop 10 temperature. 11 That is what you want? 12 Q Below 547 13 MR. MacDONALD: Just answe r his question. 14 Q In other words, if you had a transient 15 in which the temperature stayed at 550 degrees from 16 the beginning of the reac, tor trip and HPI came on, 17 you would look for some cause other than an overcooling, 18 is that correct? 19 MR. MacDONALD: Talking about his 20 understanding prior to the time of the accident? O 21 MR. FISKE: Yes. 22 MR. MacDONALD: I don't want to deal with 23 hypotheticals. If he ever recalls having that 1 24 un de rs t an ding. 25 Q Yes, your understanding up to the time of

1 Faust 725 [J j \\ 2 the accident. 3 A My understanding up to the time of the accident, 4 if I didn't have an overcoolant accident or an 5 overcoolant condition? 6 Q If after a reactor trip the T av. leveled 7 off at 550 degrees and stayed 550, and HPI came on, 8 isn't it a fact that you would look to some cause for 9 HPI actuation other than an overcooling? 10 MR. MacDONALD: Objection. I think that 11 unless he has seen that or experienced it, it 12 is hypothetical. g~b 13 MR. FISKE: It's just a question of the 14 witness' understanding. 15 MR. MacDONALD: Based on whether or not 16 it happened? 17 Q Can you answer the question? 18 A It depends on what I'm doing and what I'm 19 involved with if I would be able to look for it. 20 I might get hung up at a station and I might not be 9 21 free to do it. 22 Q I'm not suggesting -- let me put it this 23 way: All I'm asking you, Mr. Faust, is your ('h' (_/ 24 understanding of the way the reactor coolant system 25 and the steam generator worked as of the day of the

s s 1 I Faust 726 O 2 accident; just your understanding of the whole system. 3 A I'm positive I gave you that. 4 Q I'm just asking based on that 5 understanding of the way the system worked if you had 6 a reactor trip where the T av. stayed at 550 and 7 leveled off at that level and HPI c a'm e on, isn't it a 8 fact that'under tilose conditions you would>look for 9 some cause of HPI actuation other than an overecoling? 10 MR. MacDONALD: 0bjection to' form. I den t 11 think there is any foundation that he experienced s '12 those exact conditions in a vacuum'without O 13 other conditions taking place in thh s,im'lator 14 or at TMI; totally hypotheticalt y e 15 Q Go ahead, Mr. Faust. i { 16 A I feel like I've given you that answer. 17 I think I've answered that. 18 Q To save time just tell me,what'the answer t 19 was so we can move on. t 20 A If I'm free for one thing, that is a big point ', G 21 here, if I'm in a transient condition -- 22 Q I'm assuming you are aware o,f these t 23 conditions. i ' e 3 g, 24 A I f -- t - \\ 25 MR. MacDONALOne Objection. It i s, 6 / t s s } ( 'ly 1 (- j [..'/- . 4 e ? a. . i - ~ l <A a

1 Faust 727 O 2 hypothetical question. 3 Q Go ahead. 4 A If I'm aware of certain conditions that you are 5 proposing and I'm free to investigate them, I would go 6 investigate them. 7 Q And under those conditions, you would 8 look for some cause for HPI other than an overcooling 9 where the temperature, T av., is at 550 and steady? 10 MR. MacDONALD: I continue to object. 11 I don't think there is any foundation. rs 12 A I already said what I would do. 13 Q What would you do? You said you would 14 investigate it. 15 A I said if I were free. 16 Q I understand. 17 A And I didn't have other things that were 18 distracting me. 19 Q You would investigate it? 20 A Especially like followup action, I would 21 attempt to figure out what the configuration that 22 the plant was in. 23 Q One of the things you would look for is ) 24 whether there was some cause for HPI actuation other 25 than an overcooling, isn't that correct?

1 Faust 728 2 A If I steadied out, if I got the plant stable, 3 and I had followed up on my procedures and I was 4 sure I wasn't having concerns that I was violating 5 other tech spec limits, would I then investigste it? 6 I would investigate anything that I had 7 the chance to do. 8 Q Isn't it a fact based on your 9 understanding at the time of the accident that if 10 you had a situation where, after a reactor trip, the 11 temperature never dropped below, let's say, 547 degrees, 12 that you could exclude an overcooling as the probable 13 cause? 14 MR. MacDONALD: Objection. Totally 15 hypothetical. There is no evidence that he 16 ever experienced anything like that in the 17 simulator or in actual experiences at TMI 18 exclusive of other conditions at the plant. You 19 are in hypotheticals. We could sit here all day 20 asking him hypotheticals from now until doomsday, 21 MR. FISKE: This is asking Mr. Fause simply 22 what his understanding of the plant parameters 23 were. He is an operator at TMI. He is 24 licensed by the NRC. 25 I'm just trying to find out what his

1 Faust 729 O 2 understanding was of how the system worked. 3 MR. MacDONALD: Ask him what his recollection 4 is whether he saw certain things during transients. 5 MR. FISKE: We are trying to find out what 6 his training was, what his experience was, 7 what his understanding based on that training 8 and experience was at the time the accident 9 occurred. 10 MR. MacDONALD: You a re pulling completely 11 out of the air hypotheticals, if this happened, -12 would this happen, based on no foundation of O 13 experience or knowledge that he saw those two 14 things at any particular time at the same point 15 during his training. 16 Q The question is really very simple. 17 A I've answered it. I feel like I've answered 18 your question. 19 0 0.K. 20 Do I understand that the answer is that 21 if you saw that situation based on your training and 22 experience, you would look as part of your investigation 23 for the possibility that HPI had been actuated for () 24 some reason other than an overcooling? 25 MR. MacDONALD: You can read back the

I 1 Faust 730 b,~ 2 last answer and find out what his answer was to the exact same question. There is no reason 3 4 for him to answer that again. It's the same answer. He already told you. 5 6 Q Do you want to answer that? A Again? 7 Q Yes, please. MR. MacDONALD: Do you want your prior g 10 answer to be read? 11 THE WITNESS: I wo ul dn ' t mind. 12 MR. FISKE: Read the prior question and g- ~3 \\ l 1 9 answer. 13 (Record read by the repo rte r. ) 14 15 MR. MacDONALD: Objection; instruction not to answer. You just got an answer to it. 16 We can stay here for days and days doing this. 17 18 Q Mr. Faust, are you going to follow 19 Mr. MacDonald's instruction not to answer the question? A I think I answered it. He didn't have to give 20 h the instruction. 21 22 Q Unless he instructs you not to answer, 1 23 you have to answer my question, so you can follow his l instruction or answer my question. (,) 24 A I'll keep answering it the same way. That is the 25

1 Faust 731 r'T U 2 Proper answer. MR. MacDONALD: That is the reason for 3 4 the instruction. 5 Q In other words, you will not give an answer 6 to that question other than the one that you just gave? 7 A What is wrong with it? 8 Q Is that your answer to my question? 9 A What is wrong with the answer? 10 MR. MacDONALD: It's the same question. 11 Q I want an answer, yes or no. That is what t 12 is wrong with it. Ot 13 I asked you whether as part o f this 14 investigation you said you would make you would 15 consider the possibility that HPI had been actuated 16 for some reason other than an overcooling. I don't 17 believe you have answered that question. 18 MR. MacDONALD: He has answered it. He 19 told you three times. When you had the question 20 read, it was the exact same question and it had h an answer. 21 22 MR. FISKE: It was not a responsive 23 answer. If you want to instruct him not /- (3) 24 to answer -- 25 MR. MacDONALD: He gave you the answer.

1 Faust 732 7.0 2 He gave you exactly what you wanted. O.K.? 3 MR. FISKE: I'm not getting any better 4 responses from you than I am from Mr. Faust. 5 Are you instructing him not to answer the 6 question yes or no? 7 MR. MacDONALD: We will deal with that 8 later. 9 Q Now, Mr. Faust, going back to your testimony 10 yesterday, you said at some point during the 11 sequence of events you thought that you might have (~N 12 created an overcooling transient by opening the 12's y 13 and allowing feedwater to rush into the generator. 14 Do you remember that testimony? 15 A Yes. 16 Q Now, isn't it a fact that after you 17 opened the 12's, the temperature or the T av. came down I6 from somewhere 575 degrees or higher down to 550 but 19 neve r went below 550 after that? 1 20 MR. MacDONALD: You are asking him if he 9 21 recalls it now, not from some strip chart? 22 Q Do you remember that? 23 A I remember the temperature dropped. I don' t 24 remembe r where it steadied out at this time. 25 Q When you were trying to decide whether or I

I 1 Faust 733 (D U 2 not you had created an overcooling by opening the 12's, 3 did you make any effort at that point to find out how 4 far down the temperature had dropped? 5 A I remember feeling relieved that I got feedwater at least 6 back. I remember 547, but I think I thought 7 the way I re call it right now -- I thought I cooled 8 down further than that at the time. 9 Q Did you ever look at an instrument that 10 showed that the temperature was, the T av. was below 11 5477 '12 A Did you ever have something impress itself on-13 you? What I recall looking at I wanted to see around 14 547. 15 Q Right. 16 A After I saw that I had gotten down to what around 547, I believe. 17 I 18 Q I think you have testified that you 19 wanted to get back to 547 because that was sort of 20 the normal temperature that you wanted. 4 21 A After I got the 547, I don't know what point 22 in time I had gotten to that. It almost seems when 23 I opened the 12's I was there. Then it seems like I 24 was -- that we were cooling down even further than 25 that. That is the way I recall it.

l I Faust 734 v 2 I remember thinking they were having 3 problems with pressure on the primary side. The 4 side pressure was low, as I recall it, and I just 5 remember thinking it's probably from me. I probably 6 overcooled the primary. 7 Q Well, was it your understanding at that 8 time that the problems they were having with the 9 pressure on the primary side didn't start until after 10 you opened the 12's? 11 A That is what I was thinking. I don't know 12 at what point in time I was thinking these -- that 13 is part of our problem. 14 Q Well, did you ask anybody at that time that 15 was standing within a few feet of you when the 16 problems with the p re s s ure had started? 17 MR. MacDONALD: When you say "at that 18 time" 19 Q At or about the time that you thought you 20 might have created an overcooling. G 21 A I don't think at the time I thought to ask 22 somebody when our problems with pressure started. 23 1 just recall knowing that you're having problems 24 with the primary system pressure at the time. I was 25 continuing on with trying to figure out how I

1 Faust 735 OLJ 2 effected it by the generator. 3 Q Did you see any instrument that indicated 4 any temperature below 547 degrees within the first 5 hour of the accident? 6 A I couldn't tell you that. 7 Q Can you tell us now, Mr. Faust, how 8 far below 547 degrees the temperature went? 9 MR. MacDONALD: His recollection at the day 10 of the accident? 11 Q Yes. '12 A I don't remember. I didn't keep it in mind. 7-N- 13 There was no reason for me to keep it in mind right 14 now, how far down it got. 15 (continued on next page.) 16 17 18 19 20 21 22 23 O() 24 25

l l 1 i Fouct 736 l 1 /3 () Q Let me show you what has been marked as 2 Exhibit 267 which indicates the TH and TC temperatures 3 for each of the reactor coolant loops, and ask if lll you can -- do you have that in front of you? 5 A Yes. 6 Q O.K. 7 A I have it in front of me, yes. 8 Q And that would reflect, would it not, 9 what the T av. was for the first 30 minutes? I 10 MR. MacDONALD: On the instruments I 11 themselves without any variations at all? 12 ID MR. FISKE: Yes. V 13 A Once again, I didn't see this. This is something -- that was produced later on by people that had hours 15 to do it. 16 Q You didn't see the chart that is in front 17 of you? 18 A No, I did not. 19 Q But you did see the instruments that l 20 were reflecting the T av. at that time? MR. MacDONALD: The entire time. 22 A I saw the T av. 23 MR. MacDONALD: For the entire time (~h () 24 it was on the charts. 25 MR. FISKE: He answered it.

Faust 737 1 (3 () Q Do you have any basis, Mr. Faust, as 2 you sit here, for believing that that chart prepared 3 by GPU and submitted to the NRC does not accurately f reflect what the TC and TH temperatures were for the 5 first 30 minutes? 6 MR. MacDONALD: Objection to form. No 7 foundation. 8 MR. FISKE: He can answer the question. 9 A I don't have any opinion on it, to tell you the 10 truth. 11 Q One way or the other? 12 [) A I've seen mistakes made on material. s-13 Q I'm asking you, this is a chart prepared 14 by GPU, Mr. Faust, and submitted to the NRC a year 15 and a half after the accident. I'm asking you whether 16 as you sit there you have any basis for saying that 17 that chart is wrong. 18 A I don't feel like I need to express my opinion 19 on whether that chart is right or wrong. 20 Q So the answer is no? A I just told you my answer. 22 Q You don't want to express an opinion. I'm 23 asking -- 7-( ) 24 l A I don't need to. Why should I? l 25 i l i

N l 1 Faust I 2 Q I'm simply asking you whether you have 3 any basis as you sit here for telling us that that chart i 4 does not accurately reflect what those temperatures 5 were. 6 MR. MacDONALD: Objection. He told you 7 what his recollection was that perhaps the 8 instrumentation may have shown what was lower 9 than what was on the chart. i 10 MR. FISKE: He didn't say that. You 11 are putting those words in his mouth. ~12 MR. MacDONALD: He testified before he 13 had the impression of what the temperature was. 14 You showed him a chart that shows indications 15 on a trip chart that is produced after the 16 accident. 17 Q If you want to give that answer that 18 your counsel just suggested, go ahead, if that, in i 4 19 fact, is what you want to tell us under oath. MR. MacDONALD: There is no suggestion. 20 21 He told you his answer. 22 Q As you sit here now, do you have any basis 23 for telling us that that chart prepared by GPU and submitted to the NRC does not accurately reflect 24 25 what the TC and TH temperatures were in the first 30

739 1 faust r~N f ) 'wi 2 minutes? 3 MR. MacDONALD: Objection. I think he 4 told you the answer to the question. 5 A I don't have an opinion on it. 6 Q O.K. 7 When you said, Mr. Faust, that you thought 8 that your action in opening the 12's and allowing 9 emergency feedwater to go into the steam generator 10 might have created an overcooling, was that conclusion 11 that you reached based on a drop in temperature of ( 12 the T av. below 547 degrees? V] 13 A You keep pinpointing 547. I'm trying to tell 14 you I was cooling down and I don't remember the values 15 I was seeing. I remember 547 at one time and during I didn't keep track 16 the day I hit it somewhere. I 17 of every time that indicator changed positions. 18 (continued on next page) 19 20 21 22 23 O) 24 25

Faust 740 g 0 2 Q All I' m trying to find out is, to the 3 extent you tho ught the re might have been an 4 ove rcooling -- 5 A I' m s aying I have a menory like a strip chart 6 which wasn't in front of me at the time. 7 Q You could have gone ove r anytime to see 8 it? l* 9 MR. MacDONALD: Objection. 10 A I was busy on the secondary side o f the plant. 11 I had four stations at manual. I was given dire ctions 12 at some point in the day by my supe rvisor to stay on 13 that side and work with the p roblems -- 14 Q Are you telling us that in the first hour 15 and 40 minutes of this accident that if you had 16 wante d to walk ten fe e t over and look at the two strip 17 charts, you couldn' t have done that? I 18 A I'm telling you what I did. 19 Q Was the re anything that prevented you 20 during that hour and 40 minutes from looking at that h 21 temperature st rip ch a rt ? 22 MR. MacDONALD: Objection. He told you 23 what he was doing. 24 A At the time I didn' t think I had a reason to do 25 th at. I was wrapped up with the secondary side of the

d 1 Faust 741 bo 2 plant. 3 Q O.K. 4 Are you saying, Mr. Faust, that if you had 5 wanted during that hour and 40 minutes to take the 3 6 time to walk ove r and look at those strip ch art s that 7 at no time during that hour and 40 minutes could you 8 have done that? 9 A That is a hard question to answer. It re ally is. 10 I was busy on the se conda ry side. 11 MR. MacDONALD: He gave you that answer 12 eight times, I think. O 13 MR. FISKE: We will all draw our own 14 conclusions. 15 MR. MacDONALD: You are entitled to draw 16 whate ve r conclusions you want. 17 Q All I'm trying to go back to fo r a minute is 18 when you said you thought that you might have created 19 an overcooling by opening the 12's, was that conclusion 20 based on a belief that the temperatures had dropped at h 21 some point below the level at which you would normally 22 e xpe ct to see them after a reacto r trip? 23 A I would have give n you that answer if I could 24 recall it. 25 Q Did you believe -- putting it another way,

I 1 Faust 742 q C/ 2 isn' t it fair to say that a drop in tempe rature from 3 575 degrees down to 55 0, 547, whate ve r the normal level 4 that you would expect to see, that that drop in 5 tempe rature would not be an ove rcooling transient that 6 you would e xpe ct to cause a drop in pressure down 7 below 1640. 8 MR. MacDONALD: Did he think that on the 9 day of the accident? 10 MR. FISKE: Yes. 11 A I had a problem on the day o f th e acci de nt. 12 Part of tte things -- at some point in time one of /-s\\ %_) 13 the things that confused me that day, if you want, and 14 it was playing on my mind to figure out how I was 15 affecting it, f rom whe re I was at, was a divergence o f 16 the levelized pressure 17 Q We will come to that. 18 A I know. Believe it or not, it didn't play into 19 the past e xpe rie nce I had or simulator transients that 20 I had gone un de r. 21 Q O.K. I' m going to move to strike that 22 answer as nonresponsive. 23 I can assure you, we will get to the (~) t (,) 24 que stion of pre ssurizer level and pressure. 25 MR. MacDONALD: That was responsive.

1 Faust 743 ] 2 MR. FISKE: Somebody will de cide that at 3 some point. 4 MR. MacDONALD: That is true. 5 Q All I' m t rying to find out now, Mr. Faust, 6 ls with respect to the conditions that you were seeing 7 on the secondary side as you have emphasized re pe a t e dl y 8 during your testimony. At the moment I'm not asking 9 about what was going on in the primary side. I'm just 10 trying to find out when you said that you thought you 11 might have caused an overcooling by opening the 12's,'I 12 take it that the drop in temperature from 570 back to 7-Y' 13 what was the normal post-trip temperature was not 14 what you would conside r the typical ove rcooling that 15 would cause HPI to come on? 16 A Sitting he re now? 17 MR. M ac DON ALD: No, he is asking you on 18 the day of the accide nt. 19 A I understand he is. I can't give you an answer 20 that I can remember e ve rything I was thinking about 21 that day. 22 Q Is your answer you don' t reme mbe r ? 23 A The way you want me to answer the question, I /~N (_) 24 don' t re me mbe r. I don't remembe r eve rything I was 25 thinking about.

I Faust 744 O V 2 Q Didn't you understand as of the day of the 3 accident that a d rop in tempe rature from a level above 4 the normal post-trip level back to the normal post-trip 5 level would not be the kind of drop in temperature that 6 would be the type o f overcooling transient that would 7 actuate HPI? 8 A This is the day of the accident? 9 Q Yes. 10 A Repe at that again. 11 Q Maybe you better read it b a ck. -12 ( Re cord read.) 13 MR. MacDONALD: Objection. I think he gave 14 you that answer. 15 A Once again, I'm not sure what I was thinking 16 about the day of the accide nt o n that. 17 Q O.K. Mr. Faust, you mentione d a moment ago 18 a divergence between pressure and pressurize r level, 19 and I -- withdrawn. 20 You mentioned a moment ago a dive rge nce 21 between reactor coolant system pressure and pressurizer 22 level. You understood that those conditions were being 23 seen on the primary side of the plant; corre ct? 24 MR. MacDONALD: Talking about at some point 25 in time?

1 Faust 745 O 2 A Once again, you have to get that. I couldn't 3 tell you at what point I be came aware of these things. 4 Q But this is sometime within the fi rs t 5 hundred minutes? 6 A I don' t know that. I'm -- I think it was, but 7 I'm not positive on it, the point in time of things. 8 Q O.K. Now, you knew, did yo u not, as part 9 o f your t rainin g and expe rience that if pressure 10 droppe d f ar enough, that could cause saturation in the 11 reactor coolant system? '12 MR. MacDONALD: Objection to the form. I 13 think he has testified to this last week for 14 about an hour and a half. 15 lid. FISKE: It's a preliminary question. 16 MR. MacDONALD: We went o ye r it for two 17 hours one morning. 18 MR. FISKE: Please. This is e le me nt a ry. 19 MR. MacDONALD: No, it is not elementary. 20 MR. FISKE: The answer is yes or no. 21 MR. MacDONALD: No, it is not. We -- I 22 remember when we went through this for two hours. 23 MR. FISKE: If you' re not going to let him 24 answe r this question, we will sit here all day 25 unless we will go to the Magistrate.

Faust 746 1 /7, Nj 2 MR. MacDONALD: Do n' t th re aten me. I'll 3 pull out the t ran s c rip t and we can so through 4 what you questioned him on regarding saturation 5 in the primary system, what he knew about it 6 prior to the accident 7 MR. FISKE: It took two hours, because 8 the re we re so many inte rruptions and objections. 9 MR. Mac DON AL D : You asked the questions 10 fo ur times because yo u didn' t hear the answers 11 that you wanted to hear. 12 MR. FISKE: Let's go. 13 MR. MacDONALD: I'm not finished with my 14 objection. 15 MR. FISKE: Go ahead. Make a speech. 16 MR. MacDONALD: No more sp ee che s. 17 Now you can go ahead. 18 BY MR. FISKE: 19 Q Mr. Faust, you knew, didn't you, as part 20 of your training and experience t!.at a drop in 21 reactor coolant steam pressure could cause saturation 22 in the primary system? 23 A You' re asking a flat-out question? im (.,) 24 Q Yes. 25 A I knew of a relationship between saturation and

1 Faust 74 7 O 2 tempe ratu re and pressure, yes. 3 Q You knew that if pressure dropped far 4 enough, the re would be a point in time where the S 5 P re ss ure-tempe rat ure relationship could be such that 5 saturation would occur? 7 MR. MacDONALD: During any type of 8 transient, normal operating conditions? 9 MR. FISKE: I' m j ust saying -- 10 (Continued on Page 748.) 11 12 0 13 14 15 16 17 18 19 20 f 21 22 23 24 25

748 1 Faust IU 2 Q You understood that a drop in pressure, for 3 whatever reason it had occurred, if that drop in 4 pressure went low enough, that there could exist a 5 pressure temperature ratio which would produce 6 saturation? 7 A I think I already answered that, too. 8 Q Is the answer yes? 9 A What was it? 10 Q Well, you tell me. 11 MR. MacDONALD: LOCA situation? What '12 situation? b 13 MR. FISKE: I said for any reason the 14 pressure dropped. 15 MR. MacDONALD: He told you back when 16 for two hours one day. 17 MR. FISKE: This is more and more 18 obstructive. You are being absolutely 19 ridiculous in this deposition. 20 MR. MacDONALD: Not at all. Because you 21 didn't get the answers you wanted early on, 22 you come back now and ask him the same 23 questions again. Didn't he testify to this two n() 24 hours one morning? I recall it. 25 MR. FISKE: I am trying to get one answer

1 Faust [h V 2 which has to be yes and then we will move on. 3 MR. MacDONALD: It doesn't have to be. 4 MR. FISKE: Are you trying to suggest that 5 the answer to that question could be anything 6 other than yes? 7 MR. MacDONALD: Don't try to imply to my 8 witness what the answer has to be. He testified 9 for two hours as to his knowledge as to 10 saturation and what its relation was to pressure 11 in the primary system. If you want him to go 12 back through two hours of testimony, go ahead. (~ G 13 MR. FISKE: I want an answer to this 14 question. If I don't get it, we will go to l 15 the Magistrate. 16 MR. MacDONALD: Don't threaten me. l 17 MR. FISKE: Are you going to let him 18 answer? 19 MR. MacDONALD: I am going to instruct him 20 not to answer if you continue on this line. 21 MR. FISKE: It is one question to -- l 22 MR. MacDONALD: It is not a preliminary 23 question. O N / 24 MR. FISKE: I represent it is. s-25 MR. MacDONALD: You couldn't get the answer

750 1 Faust 0 2 in two hours because you didn't like the 3 answers. 4 MR. FISKE: Are you suggesting seriously 5 that anybody who is a licensed operator at a 6 nuclear plant will answer that question any 7 way other than yes? 8 MR. MacDONALD: I am not here to testify. 9 He testified for two houru. Don't try to put 10 answers in my witness' mind. I think you are 11 going into something that has been covered for 12 two hours on another day. We will be here for O 13 another three days. 14 MR. FISKE: If you allowed him to answer 15 the question, I would have been through with 16 this whole line of questioning. 17 MR. MacDONALD: You could have been 18 through with it three days ago. 19 MR. FISKE. Will you read the question 20 back -- h 21 Q Do you want to hear it again, Mr. Faust? 22 A You are asking me a theory question? 23 Q Sure. Did you learn any theory in your i j (~)s 24 training? s, 25 A Sure.

1 Faust O 2 Q Fine. O. K. Good. I am trying to find 3 out simply whether you understood that as a result 4 of the pressure-temperature relations in the reactor 5 coolant system, that if pressure continued to drop 6 there would be a point at which saturation could be 7 produced in the reactor coolant system. 8 MR. MacDONALD: My objection stands. 9 A we talked on theory, if you want, about ~ 10 saturation conditions, yes. 11 Q O. K. And one thing that could produce 12 saturation conditions was a drop in pressures isn't O 13 that right? 14 A I don't think I ever had any problems with that. 15 Q Good. Now, isn't it a fact that you also 16 knew -- withdrawn. 17 Did you know on the day of the accident 18 that a rising pressurizer level was a symptom of 19 saturation in the reactor coolant system? 20 A I don't believe I did. 21 Q I would like to have you look at Exhibit 22 276 and particularly the page that has been numbered 23 1291, which is page 10 of Chapter 4 of the book ( 24 entitled " Nuclear Power Preparatory Core Performance." 25 I'm sorry. I misread that. It is 4-20.

1 752 f 1 Faust rh() 2 Now, do you have page 4-20 in front of you? 3 A Yes. 4 Q This is a document that you produced from 5 your own files to your counsel for production to us: 6 is it not, Mr. Faust? 7 A This is the one -- yes. 8 Q O. K. I would like to read the paragraph, 9 a paragraph at the bottom half of page 4-20 which 10 says, "The reactor coolant system in a PWR System 11 is kept under pressure to prevent bulk boiling in the 12 core. In the case of an abnormal transient where \\ / 13 this pressure is lost and some steam is generated in 14 the core, how will we know it? We will see a large 15 increase in level in the pressurizer until pressure 16 is built back up above the saturation value 17 corresponding to the temperature in the core." 18 Now -- 19 A so? is it your testimony that you were not 20 Q P 21 aware of that fact before the Three Mile Island 22 accident? 23 A I said I don't think so. There are a lot of O) (, 24 things that I don't remember, things that were not 25 stressed in my training. I don't remember.

Faust 753 sk 1 1 G 2 Q You testified that this book was used in the training program at Met Ed? 3 A I said I think it was. 4 9 MR. MacDONALD: At some point in time. 5 6 A I don't remember when. 7 Q You said that you went over at least 8 portions of this book in class at Met Ed? MR. MacDONALD: Prior to the accident, after g 10 the accident or any time? It's important. MR. FISKE: He originally said prior to the 11 ~12 accident and after a recess he came back and said ~ ' he couldn't remember. 13 14 A I was not sure of it. 15 Q Now, in any event, you did testify that 16 you did go over this book in class training at Met Ed, 17 isn't that correct? 18 A I also testified I wasn't sure I went over all 19 parts of it. 20 Q That's correct. Now I'm asking you, was lh 21 Chapter 4 of this book gone over in class? 22 A I couldn't tell you specific chapters. I would 23 assume I went over core performance. 24 Q Well -- 25 A Heat transfer and generation. Q Pardon me. Core Performance is the titic

i Faust 754 1 /x t lV 2 of the book, is it not? A Heat transfer and hoat generation that I'm reading 3 4 now. lI l S Q Reading from page 4-20 you mean? 6 A You are asking me if<I recall the book? 7 Q I'm asking you whether in your classroom 8 training at Met Ed you went over the page that I just was referring to. 9 10 A That is what I don't recall. 11 Q You also testified, Mr. l'a u s t, that you read. 12 at least portions of this book, which is Nuclear Power I i 13 Preparatory Training Core Performance? A I did. 14 15 Q You did read it? 16 A Yes, portions of it. I might have read more than 17 portions of it. I don't recall. 18 Q Do you have any basis as,you sit here now 19 for telling us that you didn't read the whole book? A I didn't say that at all. I don't know. 20 k To tell you the truth, I do have a basis. 21 22 I don't remember. 23 Q Do you have any reason for telling us that n( p) 24 you would have deliberately not read Chapter 4 of this book? 25 e 9

1 Faust 755 p\\b 2 A Am I supposed to remember everything I've read? MR. MacDONALD: No, you are not. You 3 testified - you have testified as to what you have 4 d0n** 5 6 MR. FISKE: What is the answer? A I'm not sure of what I read and what I didn't read. 7 8 Q You don't have any basis for telling us now 9 that you didn't read Chapter 47 10 A Am I supposed to remember everything I have read? 11 If I read it? 12 MR. MacDONALD: He told you he doesn't (~% '\\ - recall. One way or the other it is not going to 13 14 make any difference. 15 A I honestly don't recall reading all the material 16 by any means. 17 Q You did read Chapter 2, did you not? 18 A What is this, a piecemeal thins? 19 Q We are trying to take it one step at a time. Your handwriting appears, does it not? 20 lll A I didn't say it didn't. I acknowledged that. 21 22 Q On Chapter 2. 23 MR. MacDONALD: We went over that yesterday. [a] 24 Q Your handwriting appears on certain pages 25 in Chapter 2, I guess 2-43, 44, 45.

Faust 756 1 O MR. MacDONALD: You read them into the 2 record yesterday. 3 4 Q It's No. 1456, 57, 58. O A 2 dash what now? 5 5 Q Well, it's 43, 44, 45. MR. MacDONALD: Is there a question based 7 8 on that or -- you asked it yesterday and he agreed that was his handwriting on certain of those g 10 pages. MR. FISKE: Fine. 11 MR. MacDONALD: I don't think you have to 12 O 13 go back into it. g4 Q Didn't those pages in Chapter 2 that I have 15 just been referring to deal with a calculation of 16 dif f erent pressure -temperature relationships in relation 17 to saturation? 18 MR. MacDONALD: Everything on all those 19 pages? 20 Q Let's direct your attention to page 2-43. llh That is 1457 in the numbers. 21 A What about it? 22 23 Q Question No. 9, do you see that, "What must 24 be the temperature of saturated steam at a pressure of," () 25 and then there are various pressures listed?

Faust 757 1 O 2 A Yes, what about it now? Q Then question 8, "What must be the 3 4 temperature of saturated water at a pressure of," and 9 then various pressures are given. Do you see those two 5 6 questions? A Yes. 7 8 Q Then you have written something in the margin? A Yes. g 10 Q Does that say, "Look in steam table"? 11 A Sure does. 12 Q So there is no question, is there, Mr. Faust, O 13 that before the Three Mile Island accident that you know that you could determine whether or not you had 14 15 saturation in the reactor coolant system by looking at 16 the relationship between pressure and temperature? MR. MacDONALD: Objection. If you are 17 18 basing it on what you just read in No. 9, he told 19 you four times that he didn't recall whether he received it, whether he read this docuivnt, whether 20 llh it was before or after the accident, so if you are 21 22 trying to imply, based on that, that he had that knowledge before on what you just read, it is not 23 () 24 Proper at all. 25 Q You can answer the question, Mr. Faust.

Faust 758 1 O Let me put it to you this way, so there is 2 n conceivable basis for any objection. 3 After looking at page, the page I just 4 showed you with the questions and your writing in the 5 6 margin, isn't it a f act that on the day of the Three Mile Island accident you knew that you could determine 7 g whether or not there was saturation in the reactor coolant system by looking at the relationship b,etween 9 10 pressure and temperature? MR. MacDONALD: Objection to that again. 11 12 It has nothing to do with looking at this page. O there is no foundation that he 13 This page wrote this before the accident or that he saw 14 this beforu the accident, Mr. Fiske. You don't 15 have to refer him to the page, because it doesn't 16 17 do anything to add to what he is about to 18 testify to. MR. FISKE: I will connect that up, I can 19 20 assure you, before this case is over, believe me. h If that is the only foundation for your objection, 21 22 you are out on the end of a long limb. MR. MacDONALD: That is a primary one. 23 BY MR. FISKE: 24 25 Q Go ahead and answer the question, Mr. Faust.

Faust 759 1 s. 2 A If you are asking me whether I understood saturation before the day of the accident? 3 4 Q After looking at this page -- A I d n't have to look at the page. 5 6 Q Then answer it without looking at the page, if that is easier. 7 8 Isn't it a fact that on the day of the accident you knew that you could determine whether there 9 10 was saturation in the reactor coolant system by looking 11 at the relationship between pressure and temperature? 12 A I knew on the day of the accident how to determine V saturation. 13 14 Q Yes, by looking at the relationship between 15 pressure and temperature? 16 A You are talking about using this graph here. If 17 somebody gave me a pressure and -- I would go to a set 18 of steam tables and look it up if I didn't happen to 19 know it, which I wouldn't have happened to have known. 20 Q You knew how to do that on the day of the accident? 21 A I never had any problems with steam tables. 22 Whether to use them in conjunction with a transient that 23 TN I was in the middle of is another story. I don't think () 24 B&W ever told me that, to stop in the middle of a l 25

1 Faust 760 /'N 2 transient and pull out steam tables. 3 Q Are you suggesting that at no time in your 4 training -- 5 A No, I'm not suggesting -- 6 Q Well, I'm going to press this question in 7 light of your last answer, which was nonresponsive to 8 my previous question. 9 MR. MacDONALD: I think it was responsive, 10 Mr. Fiske. 11 MR. FISKE: Motion to strike the previous '12 answer. I will put another question. 7-O 13 Q Didn't you learn in your training that if 14 you had a concern during a transient as to whether there 15 might be saturation, that you could determine whether 16 there was saturation by looking in a steam table? 17 MR. MacDONALD: Objection. He testified 18 as to what his training was in saturation, if at 19 all, in relation to particular transients, I 20 think he has given you for two hours the other 21 morning, and we are not going to get back into 22 different transients and what he knew and what he 23 was trained on just because you didn't hear what p) (_ 24 you wanted to hear in the first two days of the 25 deposition.

l Faust 761 l 1 O l 2 A I guess what I meant was in relation to particular l i l transients, a large break, there wasn't any question 3 and it wasn't stipulated to go look at a set of steam 4 tables. We assumed the system saturated. 5 6 Q All I'm saying -- A on a small break that was within the capacity of 7 8 the makeup pumps, it was never indicated that we would have a problem with it. We always kept up with the g 10 Pressure. I'm trying to make sure you understand the 11 12 way I remember my training to have been. O V 13 Q And nobody ever told you that if pressure 14 starts dropping, you might have to be concerned that 15 maybe that would produce saturation? MR. MacDONALD: In a small break? 16 MR. FISKE: For any reason. 17 18 A I don't know if -- it is actually possible that we didn't stress it this way because we didn't think 19 we were g ing to have a problem with it. Do you 20 lh understand that? 21 i 22 Q You have just given me an answer that 23 something was possible. I'm asking you for your ( recollection, and simply put 24 A That is what I'm saying. I don't necessarily 25

1 Faust 762 ( \\ L} 2 recall the situation coming up that I would recall for the answer you are looking for. 3 4 Q Are you telling us that you didn't understand 5 on the day of the accident that if there was a sharp 6 decrease in pressure, one of the things you might want 7 to do was look at a steam table to determine whether 8 you had saturation? MR. MacDONALD: During a small break? g 10 MR. FISKE: For any large drop in pressure. 11 A There was a problem, too, in the sharp increase '12 in pressurizer level along with a drop in pressure. V 13 I don't remember that one being covered in my accident 14 analysis down at B&W. 15 Q You are saying nobody at Met Ed ever took 16 that chapter out of the book and told you if there was 17 a high pressurizer level, that itself was a symptom of 18 high pressure in the system? 19 A I don't recall that. MR. MacDONALD: He testified that he doesn't 20 h recall whether it was before or after the accident. 21 MR. FISKE: That is what he said after the 22 23 recess. /~N Let's take a recess now. ij 24 MR. MacDONALD: That is his best 25 I

1 Faust 763 O 2 recollection, as I understand. f MR. FISKE: Let's take a recess now. 3 4 (Recess taken.) BY MR. FISKE: 5 6 Q Let's go back to the morning of the accident. Isn't it a fact that you never saw any T av. 7 8 temperature below 540 degrees in the first hour and 40 g minutes of the accident? 10 A From my recollection, I don't know. 11 MR. MacDONALD: He told you that a few times. ~12 MR. FISKE: Let me mark as the next exhibit O 13 a strip chart reflecting reactor -- reflecting 14 T av. temperature on the morning of the accident 15 and we will mark this as Exhibit 281. 16 (Strip chart reflecting T av. temperature on the morning of the accident was marked B&W 17 18 Exhibit 281 for identification, as of this date.) 19 Q Do you have it in front of you, Mr. Faust, 20 Exhibit B&W 2817 A Yes. 21 22 Q Looking ct that strip chart, does that 23 refresh your recollection that T av. temperature did i 24 not drop below 540 degress during the first hour and 25 40 minutes of the accident?

l 1 Faust 764 O 2 A You are saying whether I realized that? 3 Q Yes. 4 A I don't think I realized it at that time. O 5 wasn't looking at T av, on the strip chart. 6 Q So is it your testimony now that you don't 7 remember one way or the other whether on the day of 8 the accident you saw any T av. temperature below 540? 9 A On the day of the accident my testimony is, 10 I perceived a sharp drop in temperature. It's up to 11 you to put it together or whoever as to whether it ~12 occurred. 13 Q All I'm saying -- 14 A I'm saying in my mind I thought I was overcooling 15 at some time and I remember thinking that I was causing 16 problems on the primary side of the plant because of 17 it and I even remember voicing that to him, that I 18 might be overcooling, might be causing your problem 19 over there. 20 Q Do you,as you sit here now, is it your h testimony that you remember seeing a T.av. temperature 21 22 on the morning of the accident below 540 degrees? 23 MR. MacDONALD: At any time? 24 Q In the first hour and a half. A I just don't recall. 25 - ~ ,y-

1 Faust 765 2 Q O.K. f 3 MR. MacDONALD: So the record is clear, 1 4 would you indicate where this came from? ? 5 MR. FISKE: Exhibit 281 is a document that 4 6 was produced by GPU during the course of this J j 7 litigation. t j 8 Q Mr. Faust, do you recognize Exhibit 281 as l. 9 a strip chart of the reactor coolant unit T av. 1 10 temperatures on the morning of the accident? ,i 11 A On the morning of the accident? 1 12 Q On the morning of the accident. O. 13 A All I was saying was,1f you were listening to i t 14 me 15 Q No, I wasn't. l 1 16 A I was just saying -- 17 M,R. MacDONALD: You don't have to repeat. 18 A It looks like a strip chart from the T av, meter 19 on the panel. 20 Q Have you seen this strip chart before? 21 MR. MacDONALD: This specific -- 22 MR. FISKE: Yes, 281. I l 23 A Do I remember seeing it? l '\\ 24 Q Yes. 25 A This specific one? I remember seeing strip charts

1 Faust 766 O 2 of the sequence of the accident, the accident itself. Q Well 3 MR. MacDONALD: Mr. Fiske 4 I have a hard time specifically when A I hate 5 6 you put a document in front of me and you say, did you see specifically this one? I start making assumptions 7 g like maybe I saw it. g Q Let me just ask you the question whether 10 you have any basis as you sit here now for telling us 11 that this strip chart does not accurately reflect what 12 the T av. temperatures were on the morning of the O 13 accident. A If that is the strip chart they pulled off, it 14 traced what it traced. 15 16 Q I think you did testify earlier, so there 17 is no question about it, that on the morning of the 18 accident you did not look at this strip chart, correct? 19 A That's right. 20 Q O.K. Isn't it a fact, Mr. Faust, that you I did not see a T av. temperature on the morning of the 21 accident below 540 degrees? 22 MR. MacDONALD: He told you the answer to 23 o that question already. h 24 i MR. FISKE: It's preliminary questions. 25 l (

1 Faust 767 O 2 A I don't recall. 3 Q All right. Let me direct your attention to 4 a document th at has been marked previously as Exhibit O 271, and -- which is a transcript of an 171 5 6 interview on April 3rd, 1979 that you had with Mr. 7 Madden and Mr. Rogers of the Nuclear Regulatory g Commission, and I direct your attention to page 22. 9 Do you have page 22 in front of you? 10 A Yes. 11 Q At the top of the page it says -- where it 12 says "Frust," I'd like to point out that some of the U 13 things that I was seeing at the time now that I had 14 reestablished flow in the generator was that T av. 15 was dropping. T av. came down from around 575 where 16 it was hanging, dropped down to the range of 540. Then 17 a statement by Mr. Sawig, "Before I left the control 18 room to check on the bypass valves in the polishers, 19 I looked and the average temperature was 528, 529. I 20 remember yelling, 'Take off the fourth pump if we drop h less than 525.' So we did get around to 528 or so. 21 22 Apparently I didn't catch tb eT av. and it must 23 have drifted back up and at und 540 degrees." O A That was an assumption. V 24 25 (continued on next page.)

768 1 Faust N-l 2 Q Did you make that statement to Mr. Madden 3 and Mr. Rogers on April 3, 19797 4 A I don't recall it but I'm just saying the way 5 it is stated there I was just saying apparently. I 6 didn't know. 7 Q Now, yesterday afternoon we were talking 8 about diagnosing -- 9 A Yes. 10 Q -- a loss of coolant accident. I would 11 like to show you again an exhibit that was marked /'~ 12 previously, which is Emergency Procedure 2202-1.3, N3J 13 " Loss of Reactor Coolant / Reactor Coolant System 14 Pressure." This has been previously marked as 15 Exhibit 272. 16 I direct your attention to page 6 of that 17 exhibit, and I direct your attention to the portion 18 of that page that is headed " Symptoms." 19 Do you see that? 20 A sure. h 21 Q Those are, what are listed under that, are 22 symptoms of a loss of coolant accidents is that l l 23 correct? (n) l 24 MR. MacDONALD: Before we continue, have \\/ l 25 we ever established for the record that either

1 Faust 769 O 2 this page or this particular -- at least 3 Mr. Faust's recollection of this page of this 4 particular document was the one that was in 5 effect at the time of the accident? 6 MR. FISKE: This has been produced to us 7 by GPU in the course of discovery when we 8 asked for it. 9 MR. MacDONALD: There may have been others 10 produced. 11 MR. FISKE: If it turns out this was not 12 the one in effect at the time of the accident, 13 then you can later make whatever argument you 14 want to make based on that. 15 MR. MacDONALD: It would be easier if you 16 asked Mr. Faust's recollection. 17 MR. FISKE: I am prepared to operate off 18 the basis of this document. 19 BY MR. FISKE: 20 Q You testified earlier, Mr. Faust, that 21 there are certain plant conditions which are symptoms 22 of both a loss of coolant accident and a steam line 23 breaks is that correct? 24 A Yes. 25 Q O. K. On the morning of the accident, did

1 Faust 770 [~)t 'u 2 you attempt to analyze what the conditions were to 3 determine whether you had a steam line break as 4 opposed to a loss of coolant accident? 5 A I was working trying to figure out what 6 procedure I should go to, yes. 7 Q Now, directing your attention to this 8 document, page 6 of this document that you have in 9 front of you, Item 1 10 A You have one on steam line break, too. 11 Q Yes, we do. 12 A could I see that one? 3 V 13 Q Sure. 14 MR. FISKE: We will mark as Exhibit 282, 15 a document which is " Abnormal Procedure 2203-2.3" 16 entitled " Steam Supply System Rupture." 17 (Document entitled " Steam Supply System 18 Rupture," " Abnormal Procedure 2203-2.3," was 19 marked as B&W Exhibit No. 282 for identification, f 20 as of this date.) I 21 Q Do you have that exhibit in front of you, 22 Mr. Faust? l 23 A Yes. N, N.-) 24 Q Is that the steam line break procedure 25 that you requested?

1 Faust 771 0 2 A Yes. steam line supply system rupture. 3 Q O. K. And 9n page 1.0 of that document 4 there is a list of symptoms for a steam line break; 5 isn't that correct? 6 A Right. 7 Q All right. Now, both the LOCA, loss of 8 coolant accident, procedure and the steam line break 9 procedure indicate as a symptom a decrease in 10 pressurizer level, do they not? 11 A Right. ~12 Q Both of them indicate a drop in reactor O 13 coolant pressure as a symptom, do they not? 14 A O. K. 15 Q The LOCA procedure lists as 16 A It says " continuing crop in pressure." It says 17 " rapid continuing decrease of coolant system pressure." 18 Q O. K. 19 A That is in the small break or the break, loss 20 of pressure. 21 Q Under the " rapid continuing decrease in 22 reactor coolant pressure," three things are listed, 23 one, low alarm at 2055 psig, two, low, low alarm 24 at 1700 psig, and three, safety injection actuation 25 at 1640 psig. Isn't that correct?

1 1 Faust 772 ) ("N, 's. 2 A That's right. 3 Q And you learned sometime during the first 4 hundred minutes of the accident that all three of 5 those things had occurred, dicn't you? 6 A I don't think I was thinking about 2055 and 1700 7 pound alarms coming in. If that is what you mean. 8 Q But you knew that HPI had been actuated 9 at 1640, right? 10 A If I had you there and you said that happened, 11 I would have said yes. '12 Q You knew HPI had been actuated at 1640, 7-N_) 13 right? 14 A I knew that 15 MR. MacDONALD: In the first hundred 16 minutes? 17 MR. FISKE: Yes. 18 A HPI came on at some time. I don't remember the 19 specific time. 20 Q I am not asking -- my question is, 21 sometime during the first hundred minutes, you learned 22 that HPI had come on? I l 23 A That's right. ('N l (,) 24 Q All right. You knew that was at 1640? l 25 A I knew it would have occurred at 1640. l

1 Faust 773 ("% In 2 Q You would know from that that both the low alarm and the low, low alarm set points had been 3 4 Passed? O A If somebody asked me at that point 5 6 Q Right. A I don't think I thought about it. 7 g Q Now, you knew, did you not, going down the list of symptoms in the LOCA procedure, that g 10 temperature in the reactor building had increased? MR. MacDONALD: At some point in time gg -12 during the morning of the accident? O '~# MR. FISKE: These questions are all 13 14 during the first hundred minutes. 15 Q UP to the time the second reactor 16 coolant pumps were turned off. A Just a minute. Within the first hundred minutes? 17 18 I would tend to say within the first hundred minutes I knew the reactor building pressure was going up in gg 20 temperature. lll MR. FISKE Read the answer back. 21 (The reporter read back the last answer.) 22 23 Q Does that mean that you knew that both ['N reactor building pressure and reactor building .) 24 1 I 25 temperature were going up? I t I

1 Faust 774 O V 2 A I think that is what I became aware of. 3 Q Did you learn, again during the first 4 hundred minutes, that is, up to the time that the 5 reactor coolant pumps, second set, were turned off, 6 that there was a high reactor building sump 7 level? 8 A I don't recall that, no. ~ 9 Q If you look further down, Mr. Faust, in 10 the LOCA procedure at the bottom of the page, it 11 says, under Note, "The operator may distinguish 12 between a loss of coolant inside containment in O 13 OTSG tube rupture-steam line break by the following 14 symotoms due to aforementioned accidents," and under 15 No. 3, where it says " Steam break irside of a 16 reactor building," the first one is " Low condensate 17 storage level alarm - and/or low hot well level alarm." 18 You previously testified that you did 19 not see in the first hundred minutes of the accident 20 a low hot well level alarm. h 21 A I saw a low condensate storage tank level. 22 Q was there an alarm that went off? 23 A I was over there watching the storage tank level 24 drop at some point in time, too. 25 Q What time was that?

1 Faust 775 2 A I believe it would have been, as you are 3 putting it, within the first hundred minutes. 4 Q Did you see -- No. 2 says that, "Feedwater G 5 latch system actuation." 6 A I don't think I saw that. I don't recall 7 seeing it. 8 Q I think you testified earlier that you g actually were concerned because there was a high 10 level in the hot well. 11 A Yes. I was. That is what was getting 12 confusing. Things I was seeing weren't all fitting 13 into one nice package. I was having a hard time with 14 them. 15 Q Is it fair to say that a high hot well 16 level is inconsistent with a steam line break? 17 A It is fair to say I was getting confused that 18 day, yes, 19 Q Now, we had some testimony previously, 20 and I am not going to go back over all of it again, g but Item 1.3, which is the high radiation alarm in 21 22 the reactor building, do you see that, on the LOCA 23 Procedure? 24 MR. MacDONALD: What is the number? 25 MR. FISKE: 1.3.

1 Faust 776 m iJ 2 A Did you ask me a question? 3 Q I am just directing y2ur attention to 4 that item, high radiation alarm in the reactor 5 building. 6 A Yes. 7 Q Yes, and did you understand that if there 8 was radiation in the building, that that was a symptom ~ 9 of a loss of coolant accident? 10 A Yes, I understood it was a symptom of a loss of 11 coolant accident as well as other possible things. 12 Q Now, I think you testified before, Mr. 13 Faust, that you did become aware that the 1091 and 14 the 1092 radiation alarms went off. 15 A The intermediate closed letdown coolers. 16 Q Now, it is a fact, is it not, that you 17 had never seen the 1091, 1092 alarms in a high-alarm 18 state before? 19 MR. MacDONALD: Before when? 1 20 Q Before the day of the accident. h 21 MR. MacDONALD: At the Island itself? 22 MR. FISKE: Yes. 23 A I don't know if I can really say I did or (( 24 didn't. I knew they had gone to alert and we were 25 close to the alarm.

1 Faust 777 (~ 'ud 2 Q But isn't it a fact that the high alarm 3 is a step beyond alert? 4 A Oh, yes. 5 Q And isn't it a fact that you had not seen 6 a situation in which the radiation monitors had been 7 in a high-alarm state prior to the Three Mile Island 8 accident? 9 A That is what I just said, I'm not sure. 10 Q O. K. Now, where are the 1091, 1092 11 monitors located? ~12 A Located down in the basement of the reactor -3 'A 13 building where the reactor building sump is. There 14 is a division there and they are in a room separate 15 from it. Adjacent to it. 16 Q Adjacent to what? 17 A The sump. There is a division down there and 18 there are two letdovn coolers in this other room. 19 I think that is where the monitors are located. 20 Q How far from the sump are the monitors? k 21 MR. MacDONALD: Physical distance? 22 MR. FISKE: Yes. 23 A I can give you an approximate -- probably from (3 (s/ 24 where I'm sitting to the wall (indicating). 25 Q That would be about 12 feet?

1 Faust 778 (~h (_/ ~ 2 A More than that. 3 MR. MacDONALD: From where he is sitting 4 to the wall? 5 A It's more than that. 6 MR. MacDONALD: Off the record. t 7 (Discussion off the record.) 8 A Call it 12 feet. That is close enough. l* 9 Q what is the purpose of the 1991, 1092 10 radiation monitors? 11 A They are used to detect a leakage in the letdown 12 system coolers into the secondary or the nuke 13 services closed excuse me -- into the intermediate 14 closed cooling system. 15 Q Is it correct that the intermediate i 16 closed cooling system is used to cool down the water i i 17 that is flowing through the letdown? i 18 A That's right. 19 Q Is it roughly analogous to the same 20 process that goes on in the steam generator? 1 l I 21 A It removes heat. 22 Q O. K. It removes heat by having water 23 flowing through pipes and cools the water around its 24 is that correct? 25 A I don't know if there is any -- yes. 1

1 Faust 779 v 2 Q Now, the intermediate closed cooling 3 system water is in a closed system; correct? 4 A That's right. 9 5 Q It is inside a pipe and that water is 6 cooler than the water in the letdown that it is 7 supposed to be cooling down, right? 8 A Yes. 9 Q O. K. The intermediate closed cooling 10 system water is kept separate from the letdown 11 water? 12 A Yes. OO 13 Q O. K. The purpose of the monitor is to 14 determine whether any radiation has gotten into the 15 intermediate closed cooling system water; is that 16 correct? 17 A Yes. 18 Q Would that occur as a result of some leak 19 in the intermediate closed system which allowed 20 letdown water to mix with the cooling water? I 21 A That would be one case, yes. 22 Q Did you understand on the morning of the 23 accident that there was any other way that radiation f 24 could get into the closed intermediate cooling system? J 25 A Background might affect the monitors. I'm

1 Faust 780 <3 O 2 trying to I think the monitors themselves are 3 sitting outside the room there. I can't remember 4 where the monitors are. 5 Q By " background" you would mean radiation 6 in the building itself? 7 A That is what we were hacing a problem with 8 before the accident on that system. They had been 9 indicating increased background readings on them. 10 That is why they were up at the alert. It had been 11 attributed to background area. Being higher. ~12 Q so that is it fair to say that on the <3 (j 13 morning of the accident, you understood that if these 14 alarms went off, it would either be because of a 15 leak from -- of the letdown water into the cooling 16 water or else as a result of background radiation? 17 A I can tell you what we were attributing it to 18 that morning. Do you want to know? 19 Q We are about to get there, I think, if 20 you could just answer this question. k 21 MR. MacDONALD: I think we got there 22 four days ago. 23 A You are asking symptoms and I am telling you /%, (_) 24 the answer that I could give it. I am also telling 25 you what we thought.

1 Faust 781 2 Q That is what I would like to have. 3 A Symptoms are background radiation levels going 4 up, right? 5 Q Right. 6 A And one of the things we were attributing it 7 to was the letdown system. Radiation level in the 8 letdown system going up. We thought we were seeing 9 it on those monitors. That is a fair assumption. 10 Q But as I understand it, how did you 11 understand that radiation had gotten into the '12 building which was creating the background radiation 13 that triggered the alarm? 14 A It doesn't necessarily have to get into the 15 building. It could be -- did you ever talk about 16 attenuation to a pipe to,effect -- physical -- 17 Well, physical particles. I mean, you don't have to 18 have a leak. It could be in a pipe and it could 19 create a radiation area in a general area around the-20 pipe. If that source becomes stronger within the 21 pipe, your area that you are seeing is going to 22 expand out further from the pipe. 23 0 It is your testimony that these monitors 24 indicated to you that there was radiation within the 25 pipe that was triggering the monitors? i

1 Faust 782 [m\\ t_/ 2 A I thought we had a crud burst possibly. 3 Q Did you or anyone else to your knowledge 4 attribute the background radiation readings to 5 radioactivity in the area of the sump? 6 A At that point? 7 Q At the time ~the second; reactor coolant 8 pumps were turned off. 9 A My recollection of it? ~ 10 Q Yes. 11 A I remember talking about it in relation that I ~12 had just shocked, th e possibility -- shocking the b %J 13 generator, and one of the things we thought was 14 maybe we really chook'the system up and we had a '~ 15 crud release and we were seeing it in that crea of 16 the letdown coolers. I think that is what I was 17 seeing from what I remember. 4 18 Q Did you hear anyone express the view that 19 the radiation might be coming from the sump? 20 A At that point if I remember that? 21 Q Yes, within this first hundred minutes. 22 A Whe ther I myself remember hearing that? 23 Q Yes. (~ ( )% t 24 A 1 don't. 25. Q Did you determine, then, on that uorning

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1 Faust 783 O 2 that there was not a leak of the letdown water into 3 the intermediate closed cooling system? 4 A Well, one of the things we were doing. That 5 was another little problem, and we were trying to 6 answer the question and we looked at the intermediate 7 closed sump tank and -- I should -- I didn't look 8 at it. 9 Q Somebody had looked at it? 10 A Yes. 11 Q If there had been a leak, you would expect 12 an increase in the sump tank level; correct? O 13 A Yes. 14 Q And you saw no such increase? 15 A Not that I recall. I didn't see it. I didn't 16 get -- I guess when the question was -- when the 17 question -- you want a simple answer. It's just that 18 if you are asking me how I heard back, I don't 19 remember. j i 20 Q Did you learn within the first hundred k 21 minutes that there was no increase in the sump tank 22 level? 23 A I remember talking about it. The letdown 24 coolers and those alarms -- I think I pointed the w 25 alarms out to Bill and we talked about it. j i

1 Faust 784 2 Q And in the course of talking about it, 3 did you find out -- 4 A The answer was because of background from the 5 letdown coolers going up. 6 You are asking what I recall of that day? 7 Q Yes. 8 A You are -- I'm not talking for anybody else 9 now. 10 Q Just you. 11 A In prior testimony I had been talking for the ~12 group after we went in with them talking about 13 reasons they had possibly been thinking and I was 14 quoting some of the things they said. I was using 15 it in my depositions when they would ask what took 16 place and I continued -- then I gave my opinion of 17 what took place and what I had heard after the 18 accident from a lot of the information that was being 19 brought together. 20 Q well, let me read to you, Mr. Paust, h 21 from testimony that you gave to the Nuclear Regulatory 22 Commission on April 21, 1979 to Mr. Morris, Mr. Hunter 23 and Mr. Jackson, and I know this has been previously 24 marked as Exhibit 273. 25 I direct your attention to page 54.

l l l i 1 Faust 785 2 A 547 3 Q Yes. You are free to read the whole 4 question and answer but I would just like to read 5 you the last two sentences. 6 MR. MacDONALD: Didn't we read this 7 question and answer into the record in the 8 earlier part of his deposition? I am sure 9 we did. 10 MR. FISKE: We did. It is quicker to 11 read it from here than go back and find it. '12 Q "And we really didn't have any problems O 13 with the level on the intermediate closed sump tank 14 to indicate a primary / secondary leak on the letdown 15 coolers." 10 Do you see that sentence? 17 A Right. 18 Q Does that refresh your recollection that 19 you did learn during the time period that I referred 20 to that there had been no increase in the sump tank 21 level? 22 A Keep reading. 23 Q I am trying to take these sentences one 24 at a time. 25 A No, you are not.

1 Faust 786 O 2 MR. MacDONALD: You asked the question 3 the last time. 4 MR. FISKE: I didn't ask anything about 5 the sump tank level. 6 A You are up here on 547 7 Q Yes. 8 A Line what? 9 Q Line nine. 10 A O. K. Line nine. 11 Q "We really didn't have any problems with ~12 the level on the intermediate closed sump tank 13 to indicate a primary / secondary leak on the letdown 14 coolers." 15 A O. K. 16 Q Now, first of all, did you make that 17 statement to the NRC on April 21st? 18 A I don't recall this whole document. I am going 19 over this with the idea with you right now that it is i 20 there. O. K. 21 Q O. K. 22 A I don't remember what I was saying to them, and 23 the problems -- that is what I want to make perfectly 24 clear -- the problems I was having at that time, I was 25 talking as we, as a group, not specifically just what I I

1 Faust 787 2 I saw. 3 Q That is what I am trying to find out. 4 A O. K. 5 Q when you say "We didn't have any problems 6 with the level," did you include yourself in the word 7 "we"? 8 MR. MacDONALD: Objection. He said he g didn't recall giving that answer. 10 MR. FISKE: All right. 11 A I am saying that what I'm trying to do now is 12 make sure that I just put out what I did. 13 Q Yes. 14 A And what I recall myself doing and not assume 15 what somebody else was doing or what the information 16 they had -- had derived f, rom where. 17 Q That is all I want you to do in this 18 deposition. 19 MR. MacDONALD: So you have asked him 20 that question. 21 Q I am asking you now, looking at that 22 sentence, does that refresh your recollection that 23 you personally learned at some point during the first 24 hundred minutes that there had not been an increase 25 in the level of the sump tank?

1 Faust 788 O 2 A I think I just said earlier that I thought I had 3 checked that out within the first hundred minutes. j 4 Q O. K. Now, the next sentence says, 5 "So it was just reasoned out, it's down near the 6 sump pump down there and it is high, probably high 7 background because we were dumping water in the sump." 8 Do you see that? 9 A Yes. 10 You can keep going, too. 11 Q When you said it was just reasoned out, 12 whose reasoning were you referring to? 13 MR. MacDONALD: Objection to the form. 14 He told you that he doesn't recall the question 15 and answer, so it is not proper to take him 16 back into the answer he doesn't recall giving. 17 MR. FISKE: We will establish as a proper 18 predicate for the question that he did make 19 that statement right on the tape so -- 20 MR. MacDONALD: We are not talking about lh 21 that. You are talking about his recollection. 22 His recollection is that he does not recall 23 giving that answer to the question that starts 24 on page 53. So to direct him to a specific -- 25 just ask the question.

Faust 789 g \\ss 2 Q can you tell us, Mr. Faust, now what the 3 basis was for the statement that I just read that you 4 gave to the N RC 7 O 5 MR. MacDONALD: Objection. 6 Q what you recall now. 7 MR. MacDONALD: Objection. No foundation 8 for the question. 9 Q Go ahead, Mr. Faust. 10 A It was base d on, after the a cci den t, when I was 11 in with a group as a group discussion on these things. ~12 Q Telling -- 0 13 A Things I heard. You will see what I thought if 14 you go on through the do c ume nt. 15 Q I'm asking you now what the basis was for 16 this particular statement. 17 A It's the whole damn statement. 18 Q I take it, Mr. Faust, that somebody told 19 you, somebody told you that it was their reasoning 20 that there had been high background because of water lh 21 going into the sump? 22 A No, what happened was, I was in with them as I 23 a group, and we were trying to decipher out things 24 that had happe ned. I don' t remembe r which one said 25 it, or who would have said it. We were in a group. i

1 Faust 790 g NY 2 I was just sitting there listening and talking, trying 3 to fill in what I remembe re d o f the accide nt and give 4 my viewpoint on it as well, and later on I was asked 5 q ue s tio ns about the ac cide nt in general as to, well, 6 what happened as a storybook form. 7 Q Isn't it a fact that in this answer when 8 you said, "It was just reasone d out," you were 9 re fe rring to reasoning that you understood had gone 10 on during the a c ci de n t sequence? 11 MR. MacDONALD: Obje ction to the form. -12 A Not necessarily. Not that I unde rstood on the O 13 day of the accident that was taking place. On the 14 day of the accident I was thinking things I was 15 thinking, and the ones I was thinking were -- on that 16 part was due to the letdown coolers. _And the fact 17 of a crud burst. 18 Q So your testimony is that at no time on 10 the morning of the accident, the first hundred 20 minutes did you hear anybody say anything about the llh 21 Possibility that radiation from the sump might be 22 triggering these alarms? 23 A It is a poor question, because I don't recall [l 24 what I heard and didn' t hear. %J 25 Q So the answer is, you don' t recall?

Faust 791 g k 2 A Yes. 3 Q Mr. Faust, were you aware on the day of 4 the accident of an alarm called the 720 ala rm ? 5 A 7207 6 Q Call it the letdown line radiation 7 monitor. 8 A Talking -- O.K. All right. I'm with you. 9 Q You we re aware of the existence of.such an 10 alarm? 11 A That's right. '12 Q Did you check to dete rmine whether or not 13 that alarm had been t ri gge re d? 14 A I didn't see it. I don' t reme mbe r. 15 Q Well, isn't it a fact as you unde rstood 16 this sometime on the day of the accident that if the 17 radiation from within the pipe was strong enough to 18 put the 1091 alarm in a high alarm state that you 19 would expect it also to set off the letdown line 20 monitor? llh 21 MR. MacDONALD: Objection. You are asking 22 for what his thought was on the day of the 23 accident? O i / 24 MR. FISKE: Yes, his un de rs ta n ding. s i 25 A I already told you what I remember my thoughts

i 1 Faust 792 ("h \\] ~ l 2 we re on the day of the accident. You' re trying to get 3 me to say othe r things that I'm not sure I remembe rd l l 4 or not. 5 Q No, I haven' t aske d you anything about 6 the letdown line monitor. 7 A You want me to reason out the accident and -- 8 nice, plain and simple as to what I should have 9 thought by you. 10 Q I' m asking you what happened on the day 11 of the accident, and I'm asking you when you were '12 trying to figure out what might be causing the 1091 fs (a\\ 13 and 1092 alarms to go out, to go off, and you were 14 conside ring that as a possibility that it was because 15 of radiation from within the pipe, did you also 16 conside r that if that were true, then the letdown 17 line monitor should also go off? 18 A I don't recall what I was thinking altogether. 19 I may have thought something -- if you want to surmise 20 something -- h 21 Q No, I want your recollection of what 22 happened. 23 A I just do n' t recall eve rything I was thinking. /~N () 24 I recall attributing my letdown area or the letdown 25 cooler alarms in my -- the way I was thinking about

1 Faust 793 >0 V 2 it, to a crud burst at the time. Now, whether I 3 reasoned out at that time some thing el se as to why I 4 didn't get 720 as you were putting it, I don't recall. 5 Q So your testimony is as you sit here now, 6 you can' t tell us whethe r or not you e ve r che cke d to 7 see whether or not the 720 alarm had gone off? 8 A Best I can tell you is, I look ed-in the back 9 panel and I had two alarms at that time. 10 Q Are you telling us you looked to see 11 specifically whether the 720 alarm went off? 12 A I looked at Panel 12. Have you been in the C),r 13 con t rol room yet? 14 Q No. 15 A Take a visit some day. The only two alarms I 16 remembe r seeing were the,two intermediate closed 17 alarms. 18 Q My question is, did you try to find out 19 whethe r or not the 720 alarm had gone o ff ? 20 A What did I just say? lll 21 Q You told me you looked at a panel and 22 only saw two alarms? 23 A 720 is back the re. O) ( 24 Q You looked at the 720 25 A I looked at Panel 12. I saw two red alarms

Faust 794 g O 2 and two yellow alarms on. They are both associated 3 with those particular alarms. 4 Q Did the fact that the 720 alarm had not 5 gone off indicate to you in any way that the reason 6 the 1091 and 1092 alarms had gone off was not because 7 of radiation from within the pipe? 8 A Did you ever hear of be coming, as I said e arlier, 9 trying to reason out why you only get parts of things 10 and fit them into a procedure? 11 Q I just would like an answe r to that 12 q ue s tio n. O 13 A That is the answer. I was trying to reason out 14 why I was getting things. Certain symptoms and not 15 others. 16 Q So it -- is it fair to say, then, that the 17 fact you did not is it fair to say, the fact 18 that the 710 alarm did not go off was an indication 19 that the reason for the 1091 and 1092 alarms going 20 of f was not ra di ation from within the pipe? llh A No, it's not fair to say. It's right what I 21 22 h ave been saying. I can't answer the question you' re 23 trying to pose right now, because I don't remember () 24 e ve rythin g I was thinking. Why I would have 25 eliminated, say, the 720 alarm. And why it went off

l 1 Faust 795 O 2 or didn't go off at that time, if you want. 3 Q Just so I unde rstand you, Mr. Faust, then 4 is it your testimony that when you referred to the S 5 crud burst, that the crud burst caused radiation 6 within the pipe and that that radiation passed through 7 the pipe and triggered the high alarm on the 1091 8 and 1092 alarms? 9 A I was trying to figure it out. 10 Q But when you referred earlier to a crud 11 burst as the cause of the 1091, 109 2 high leve l alarms, 12 did you -- 0 13 A You know, I had something else bothering me at 14 that time, too. I was working on the hot well level, 15 too. 16 Q Le t' s s tay -- 17 A I can' t, because it wasn't just that that I was 18 looking at in problems I was having that day. 19 Q We have to take these things one at a time. 20 If there is anything when we get all through that j lll 21 hasn't been covered, your counsel will have ample 22 opportunity to -- 23 MR. MacDONALD: If he thinks it is 24 important to clarify as he goes along the 25 answer, he is entitled to do that. You don't

1 Faust 796 O 2 want to cut his answer, I'm sure. MR. FISKE: I don't want to restrict your 3 4 a nswe rs insof ar as we' re talking about crud O 5 burst, but let's stay on the topic of crud 6 burst. 7 A something.else was in the re. 8 Q I'm at the moment trying to understand g how you thought a crud burst could trigge r the high 10 level alarms on the 1091 and 1092 monitors. And if 11 I understand you correctly, what you said is, you 12 tho ugh t that the crud burst produced radiation within 13 the pipe which passed through the pipe, and as 14 background triggered the monitor; is that co r re ct ? 15 A What is wrong with that? 16 Q Nothing -- 17 A You keep asking me about it. 18 Q I wanted to be sure I unde rstood it. 19 A O.K. 20 Q The crud burst as you understood it would llh 21 be something that occurred within the primary loop. 22 MR. MacDONALD: Asking for what his 23 thought was on the day of the accident? () 24 MR. FISKE: Yes. 25 A Where else would it be? It would be in the

1 Faust 797 ) (~) U 2 p rima ry loop. 3 Q O.K. Just a couple of more questions 4 on this, Mr. Faust, just to be sure we all understand O 5 it. The 1091, 1092 monitors were monito rs that we re 6 monitoring what was inside the intermediate closed 7 cooling system; co rre ct ? 8 A Yes. 9 Q O.K. As you understood it, if there 10 were a crud burst in the primary system, the radiation would then pass through the letdown, 11 would the n be 12 the water in the letdown line; correct? IO b 13 A That is what I have been saying. 14 Q Unless there was a leak, it would not get 15 into the intermediate closed cooling systems right. 16 MR. MacDONALD: What do you mean, the 17 radiation? 18 A You have to understand radiation. 19 Q The water in the letdown line would not 20 go into the inte rme diate closed cooling system unless lh 21 there was a leak. 22 MR. MacDONALD: Are you implying that the 23 radiation wouldn't? O (,! 24 MR. FIS KE : I'm just asking about the 25 water.

1 Faust 798 O 2 A The water -- 3 g yo saw an alarm go off that monito rs 4 what was going on inside the intermediate closed 5 cooling system; right? 6 A Yes, but the monitors are located down near 7 the area of the letdown coolers. 8 Q If there had been a crud burst, then the 9 radiation from that crud burst would be in the 10 letdown wate r its elf; co rre ct ? 11 A Yes. 12 Q And how could you conclude that it was 13 radiation in the letdown line that was causing the 14 intermediate closed cooling system alarm to go off 15 if an alarm specifically designed to measure 16 radiation in the letdown line did not go off? 17 MR. MacDONALD: Are you asking, did he 18 reach that conclusion, or how could -- are you 19 asking for what he thought on the day of the 20 accident? I 21 MR. FISKE: Yes. 22 A I told you what I thought on the day of the 23 accident. You' re asking me if I did an analysis of () 24 it at that point in time? 25 Q Yes.

I Faust 799 O 2 A I didn't. 3 Q Did you make an analysis of whether it 4 ma de sense to conclude that it was a crud burst O 5 causing the 1091, 1092 alarms to go off when there 6 was an alarm specifically designed to measure 7 radiation in the letdown line that did not go off? 8 A I already told you my answer. You can say it 9 any way you want. What I said is what I was thinking. 10 Q I guess the answer is "No." 11 MR. MacDONALD: Objection to that. That 12 is not the answer. The answer is what he said. O 13 A I don' t know everything I was thinking that day. 1 14 Why I reasoned some of the answers out to me that I 15 was reasoning. 16 MR. MacDONALD: This is a good time to 17 break. 18 ' MR. FISKE: I think we should finish 19 this af te rnoon. I 20 MR. MacDONALD: 0.K. k 21 (Whereupon, at 12:10 o' clock p.m., a 22 luncheon recess was taken.) 23 24 25 1 ~

Lk 1 1 800 0 2 Afternoon Session 3 1:37 o' clock p.m. 4 9 5 CRA IG C. FAU S T, resumed: 6 BY MR. FISKE: 7 Q Mr. Faust, isn't it correct that the 8 condensate storage tank is intended to provide 9 water for the hot well when the level in the hot 10 well becomes low? 11 A Yes. -12 Q The principle is that as long as' the O 13 hot well is at its normal level, then no water will 14 flow from the condensate storage tank into the hot 15 well, right? 16 MR. MacDONALD: Talking about during 17 normal operations? 18 MR. FISKE: Yes. l 19 MR. MacDONALD: You are asking for his 20 understanding when? llh 21 MR. FISKE: At the time of the accident. 22 A Normally none -- I should not say none. During 23 normal operations, the hot well level would surge () 24 along with the storage tank which might be making up 25 for :he level in it or it might be returning to the storage tank.

801 1 Faust 0 2 Q Right. 3 On the morning of the accident during 4 this 100-minute period we have been talking about, 5 you understood that there was an unusually high level 6 in the hot well, correct? 7 MR. MacDONALD: The entire 100 minutes 8 or at one point in time? 9 MR. FISKE: Right. 10 Q It came to your attention during that 11 period of time that the hot well level was abnormally ~12 high? O 13 A At some point in time, I was working with the 14 hot well level. 15 Q And isn't the fact that the hot well 16 level was abnormally high inconsistent with a low 17 storage tank level, a low condensate storage level 18 dropping? 19 A Is it inconsistent? 20 Q With a dropping condensate storage tank h 21

level, gg A

Is it inconsistent with a drop -- 23 Q To have the hot well level abnormally high. 24 MR. MacDONALD: What do you mean by 25 " abnormally high'?

Faust 802 3 1 0 2 MR. FISKE: Higher than it is supposed 3 to be. 4 A Inconsistent? I would say it would be inconsistent 5 with it. 6 Q Well, the normal -- 7 A Possibly. 8 Q The normal purpose 9 A Depends on what is happening. 10 Q The purpose of the condensate storage tank 11 is to make up water into the hot well when the hot ~12 well becomes low, correct? 13 A Yes. 14 Q And -- 15 A one of the purposes. if the hot well was at 16 Q So presumably, 17 its normal level you wouldn't expect water to flow 18 from the co nde n.m a te storage tank into the hot well; 19 is that correct? 20 A If the hot well level had been normal? 21 Q Yes. 22 A It wasn't normal. 23 Q If it were normal you wouldn't expect the 24 water to flow out of the condensate storage tank into 25 the hot well, right?

803 4 1 Faust O 2 A That's right. If it were normal, I wouldn't 3 expect that. 1 i 4 Q And if it were higher than normal, you 5 wouldn't expect water to flow from the condensate 6' storage tank into the hot well, would you? 7 A It became a little baffling that day. 8 Q So you wouldn't expect that? g A It was another point that added to the confusion. 10 Q Let me show you a document which we 11 will mark as Exhibit 283, which was one of the 12 documents that was produced to us by, I believe, Mr. O 13 Walsh last time. 14 Do you have that document in front of 15 you, Mr. Faust? 16 A Yes, I have it in front of me. I 17 (Document entitled " Preliminary Annotated 18 Sequence of Events, March 28, 1979" was marked B&W Exhibit 283 for identification, as of this 19 date.) 20 21 Q All right. That document was contained llh 22 in your files at one point, was it not? 23 A Mr. Walsh gave it to you. That is where it O came from. (_) 24 MR. WALSH: It was Ms. Penny, actually. 25 1

804 f 1 Faust '(2) 2 Q This is entitled " Preliminary Annotated 3 sequence of Events, March 28, 1979," is it not? l 4 A Yes. G 5 Q Were you given this document by someone 6 at GPU at some point in time to review? 7 A I reviewed over documents again. 8 Q Including this one. 9 MR. MacDONALD: Are you asking whether he 10 recalls 11 A I reviewed over documents of the event. 12 Q 0.K. O 13 Do you see the handwriting on the first i 14 Page? 15 A Yes. 16 Q Is that yours? 17 A Looks like my printing, yes. 18 Q On the page that is numbered 16065, is that 19 your handwriting? 20 A Where -- 16 -- llh 21 Q Is that your handwriting on page 27 22 A I believe so, yes. 23 Q 16065. O 24 e.x. 25 Q on page 2, 16066, is that your handwriting?

805 1 Faust O 2 A Yes. Looks like my handwriting. 3 Q Page 5, is that your handwriting? 4 A Looks like it. 5 Q Page 7, is that your handwriting? 6 A Yes. 7 Q Page 8, is that your handwriting? 8 A Handwriting looks like mine. 9 Q Is that your handwriting on page 9? 10 A Yes. 11 Q Is that your handwriting on page 107 -12 A Yes. 13 Q Is that your handwriting on page 11? 14 A Looks like it, yes. 15 Q O.K. 16 Is that your handwriting which appears 17 on page 127 18 A Yes. 19 Q Page 13? 20 A Yes. 21 Q Page 147 22 A Looks like it again. l 23 Q Page 157 24 A Is there a reason for this? 25 Q What?

i 1 Faust 806 O 2 Is that your handwriting on page 157 3 A Looks like it. 4 Q On page 15, in the left-hand side where O 5 it says, "high vibrations"and low amps". Is that 6 your handwriting? 7 A Yes. 8 Q Were you referring to the reactor 9 coolant pumps in making that notation? 10 A What do you mean was I referring to -- 11 Q Were you referring -- -12 A I was reviewing this and I think it may have 13 been one that I mentioned earlier that we had been 14 in the room once going over the annotated sequence 15 of events trying to put in other things that -- not 16 just me in the room but all of us. 17 Q In any event, the notation there refers 18 to the reactor coolant pumps? 19 A Yes. 20 Q Is the rest of the writing on page 15 h 21 yours? 22 A Looks like it. 23 Q Is there any' writing that you have seen fD 24 on this exhibit up to this point that is not your N_/ 25 handwriting?

I 1 Faust 807 Okl A That I have seen so far? 2 Q Yes. 3 A Looks like it is mine. Q O.K. 5 Is that your handwriting on page 187 6 A Yes. Well -- yes. 7 Q Is that your handwriting on page 19? 8 A Looks like it. ~ 9 Q Is that your handwriting on page 217 10 A Looks like it. 11 Q And page 247 3 ^ (~T 's,) A Looks like it. 13 Q Well, we have some questions on leak rates. 14 MR. FISKE: Mr. Benedict is going to ask 15 those questions. 16 EXAMINATION BY 17 MR. BENEDICT: 1 18 I Q Mr. Faust, prior to the Three Mile Island 19 i accident, were you aware that there were certain limits 20 as to leakage from the reactor coolant system? 6 21 MR. MacDONALD: Limits prescribed where? 22 MR. BENEDICT: Let's see if he can 23 answer the question and we will go from there. g y,) 24 Q Were you aware there were limits with respect 25

I 808 1 Faust bv 2 to leakage prior to the Three Mile Island accident? 3 A Yes. 4 Q Were those limits prescribed in a technical O 5 specification? 6 A Yes, they were. 7 Q I'd like to show you a document previously 8 marked as B&W Exhibit 251 which is headed " Reactor 9 Coolant System," then number 3/4.4.6 reactor coolant 10 system leakage, leakage detection system. 11 Is this the technical specificaion that -12 indicates the leak rates that are permissibin? O 13 MR. MacDONALD: At what time? 14 MR. BENEDICT: Prior to the accident at 15 Three Mile Island. 16 Q Referring to the third page of the document. 17 MR. MacDONALD: Let's take a minute and 18 let him read through it. 19 MR. BENEDICT: Well, I may be able to help 20 him identify it, k 21 (Pause) 22 A Looks like it, yes. 23 Q Turning to the third page of the document, I () 24 Page number 3/44-15 which is headed " Reactant Coolant 25 system operational Leakage Limiting Condition for l I 1

1 Faust 809 (U 2 Operation, section 3.4.6.2," it lists five leakage rates. Are those what you recognize as being the 3 4 limitations for operational leakage at Unit 2 prior S 5 to the accident? 6 A Prior to the accident, yes. 7 Q Do you understand if the leakage rates 8 that are indicated in the section I have just referred 9 to are violated, you are required to go to the action 10 station on that page which -- 11 A If the ones on the page are exceeded, I'm referred 12 to go to the surveillance requirements or the follow-up O ~ 13 action, in other words. 14 Q Is that the 2A and B subparagraphs under 15 the word " Action" on this page? 16 A Yes. 17 Q Therefore, if you exceeded a limit in 18 A through E listed under 3.4.6.2, you are required 19 to take the actions indicated as appropriate in either paragraph A or paragraph B under " Action." Is that 20 h 21 right? 22 A As far as reference to the action statement, t 23 if your leakage exceeds that listed there. [) 24 Q So you have to step in to do one of those 'o 25 things? Y \\ s

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J _, /),- e ~ f +. [ way.; a. ]ttempting to p61nt o u t,. 16 A That is what f - Ple'af.e.' horl at y /'$ r, 1 f i 17 Q t j P. hat we have/ ob a valid leah' 78 A If we determine b 1 /u ',j, ) i ? a f ] ~. ) i e h I "" ~ M ' ' +',' 19 rate, we would step into this procehld. t + , le ,4 ' o - ,o x + i.; o 20 Q Upon -- y' j y r j [r ,/ / 'b,' ,d1 'A Theactionstatea$nt. .I .,/ # eW p. .[ I ( 22 Q Upon entering into,the a c ti on i s h a't eme nt, t l t/ . -) ,o r i Ot 27, you are required to reduce the le6cag['.wi'th*in f our i ,r' d' 'l y*.) et,$nd,by, within hours,kh within limits.orIgo,into hot [7 24 i .;-)

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l raust 811 1 0 30 hours thereafter; is that right? 2 l A That is the way I understand it. 3 4 Q That is how you understood it prior to O the accident at Three Mile Island? 5 6 A Yes. 7 Q Continuing down the page, are you aware 8 that there are requirements for ascertaining or for testing the leak rates from the system? g 10 A There is a surveillance that we run on it which 11 you don't have the full surveillance procedure here. 12 Q Right. Turning to Section 4.4.6.2, subparagraph D 13 g4 reads, " Performance of a reactor coolant system water 15 inventory balance at least once per 72 hours during 16 steady state operation." Is this the requirement for the testing 17 18 of the leakage from the reactant coolant system? 19 A The surveillance performance -- by this tech spec you are required to do it within 72 hours. 20 Q Let me show you a document marked previously h 21 as B&W Exhibit 252 and ask you whether this which is 22 headed "Three Mile Island Nuclear Station Unit 2 23 Surveillance Procedure 2301-3D1RCS Inventory," is the 24 Procedure you were referring to when you said there 25

Faust 812 1 0 2 was a surveillance procedure to determine leakage. A Looks like the one we would use to determine it. 3 4 Q Have you ever performed a leak rate test 5 Pursuant to this procedure? 6 MR. MacDONALD: This one that he has in 7 front of him? 8 MR. BENEDICT: Thir, procedure headed "2301-3D1," whether it was this particular 9 10 revision or a later revision. 11 A I Performed leak rate tests according to this 12 procedure. O 13 Q To clarify things, you are not licensed 14 on Unit 1; is that correct? 15 A That's right. 16 Q So you have only performed Icak rate 17 tests for Unit 27 f 18 A No. 19 Q You had performed leak rate tests for Unit 17 20 A Yes. 21 Q Under what circumstances did that occur? 22 A I had been a candidate for a license. I was 23 a trainee in Unit 1 at one time, CRO trainee. 24 Q During that time you did perform leak rate tests for the Unit 1 reactor? 25

3 Faust 813 14 g U) 2 A Under the surveillance of another operator, licensed operator. 3 4 Q Right. O From that experie. ace, are you aware of 5 6 any differences between the procedures for the Unit 1 reactor and the Unit 2 reactor for measuring 7 g leakage? MR. MacDONALD: What time? 9 MR. BENEDICT: Any time prior to the Three 10 Mile Island Island. 11 I'd have to go back and look. 12 A I couldn't 'V Q You don't recall at this point that there 13 was any difference? 14 A Any specific differences, not that I recall. 15 16 Q When you perform leak rate tests for either Unit 1 or 2, did you utilize the computer? 17 18 A

Yes, gg Q

And had you ever performed for either of those two facilities a leak rate test where rather 20 than using the computer, you used one of the attached 21 data sheets? 22 MR. MacDONALD: Are you referencing some 23 m P*9'*I ) 24 MR. BENEDICT: Data sheet number 2, page 13.0 25

Fcuot 814 1 r3 k.j of Exhibit 252. It indicates that it is for 2 use when the computer is not available. 3 Q Did you ever have to utilize this? 4 lh A I did it on a training basis. 5 Q You never had to do it f or purposes of 6 performing an actual leak rate calculation? 7 A Not that would have been used to indicate 8 the leak rate. I did it for my own purpose. 9 Q Do you understand that this procedure 10 requires that you conform the measures of fluid 11 from the make-up tank and the reactant coolant 12 p) drain tank to be consistent measures? ( IJ MR. MacDONALD: What his understanding 14 was prior to the accident? 15 MR. BENEDICT: Yes. 16 A Did I conform -- 17 Q Maybe if I take it in smaller steps, it is 18 easier. It is true that temperature of water will 19 affect its volume for a given mass of waters isn't 20 that right? 1 A That is true. 22 Q Hotter water of a given mass will take up 23 more volume than cooler water of the same mass; is that ~3 LA 2A right? 25

5 1 Faust 815 \\_) 2 A That's right.. 3 Q And isn't it true that measurement of 4 inventory in the make-up tank or of inventory in the O 5 reactant coolant drain tank is volumetric rather 6 than by mass? 7 A No problem with that. 8 Q It is volumetric, the measure? 9 A Yes. 10 Q so if the water in the reactant coolant 11 drain tank were a different temperature than the 13 water in the make-up tank, the same volume of water (~; \\' 13 would not be the same mass of water? 14 MR. MacDONALD: Are you asking whether 15 that ever occurred? 16 MR. BENEDICT: I am trying to understand 17 the procedure. 18 A They have the same mass. They just don't have 19 the same volume. ( 20 Q Right. h Isn't it true in normal operating 21 22 circumstances the make-up tank temperature is different i 1 23 than the reactant coolant drain tank temperature? l l r~. 24 A Yes. \\s) l I 25 Q So in order to measure volume amount to

Faust 816 I 1 O 2 volume amount on a consistent basis between the RCDT i and the make-up tank, you have to somehow conform 3 4 the amounts on a mass basist is that right? 1 5 A You are asking me to verify who made this 6 procedure up -- 7 Q No, I'm trying to understand the procedure 8 and how it works rather than just look at a bunch 9 of numbers. I'm trying to understand.what the process 10 of the procedure is and you as someone who has been 11 trained on it and used it may be able to help me with 12 that. O 13 A I have a problem with that. 14 Q If you tell me the problem, maybe I can 15 clarify my question. 16 A Say your question again. 17 Q Isn't it true that this procedure, if 18 in effect, calculates unidentified leakage by 19 subtracting a figure that is called total leakage 20 or subtracting from a figure called total leakage h 21 a figure called identified leakage and the remainder 22 is unidentified leakager isn't that how this procedure 23 works, affectively? O (_/ 24 MR. MacDONALD: That is all the procedure 25 does prior to the time of the accident.

Fouot 817 '8 1 /N ( ) v' 2 MR. BENEDICT: I am asking if that is 3 how the procedure identifies unidentified 4 leakage. 5 A Procedure uses the change in mass to figure 6 out if you have a leakage in the system. 7 Q And does the procedure define total 8 leakage as being that amount of water lost from the 9 make-up tank during the test time period? 10 A I don't think I reacil the procedure fully in 11 that sense. 12 Q The procedure does, however, utilize the g~g U 13 concept of total leakage and identified leakage and 14 by subtracing identified leakage from total leakage, 15 the determination is then the unidentified leakage; 16 is that right? 17 A Right. 18 Q Is the identified leakage determined by 19 measuring changes in the reactor coolant drain tank? 20 MR. MacDONALD: Was it? 21 MR. BENEDICT: Was it prior to the Three 22 Mile Island accident? 23 A Just from that point. i (_ 24 Q That and those leakages that you found out ( )) 25 in the plant and mcar.ured on an individualized basis, 1

19 1 Faust 818 O 2 isn't one of the elements of the identified leakage 3 the increase in volume in the reactant coolant drain 4 tank during the testing period? O 5 A You are asking me for my opinion on it and -- 6 Q Your understanding of how this procedure 7 works. I don't think I can recall totally 8 A I don't 9 how the procedure worked at that time. If I read 10 right, I'd have to identify -- I did it once by the 11 longhand form that I can recall. The majority of 12 the time I went to the computer which was just normal O 13 procedure to do it by the computer program. 14 Q In order -- 15 A Which I didn't always keep track of what was 16 going into the computer program on it. 17 Q In order to use the computer, you had to 18 provide the computer with certain information and 19 you didn't have to do any calculations? 20 A That's right. lll 21 Q The times that you recall doing the leak 22 rate test for purposes of satisfying the tech spec 23 that we talked about, you used the computers is that () 24 right? 25 A That's right.

1 Faust 819 OV 2 Q What did you get back from the computer? 3 MR. MacDONALD: In terms of type of 4 output? O 5 Q What did it look like and what did it S tell? 7 A There should be a copy of it in here. 8 Q Of an example attached to this? (In dic a ting ) 9 A Yes. 10 Q Well, I actually notice that that is 11 referenced in the text of this procedure and couldn't 12 find it, so I can tell you that it is not attached O 13 to the copy you are looking at. The computer provides 14 you with a printout, though? 15 A Yes. 16 Q And the printout gives you in numbers, 17 as gallons-per-minute numbers for identified and 18 unidentified leakage, is that right? 19 A I'd like to see the computer printout. 20 Q I wish I had it. This is a procedure 21 which was provided to us by your counsel and it came 22 incomplete, so I can't show' you one. 23 A I'm saying I thought it was on the back of this. 24 Q I think you're right. I think -- it is 25 mentioned in this procedure.

820 I Faust tO 2 As I say, it does say that there is an 3 attached example of the computer printout but we didn't get one. 5 MR. MacDONALD: This is that copy of the 6 procedure. 7 MR. BENEDICT: Perhaps. 8 Q In any event, it is true, is it not, 9 that the computer printout that you get has a line 10 wh ich specifies, for example, unidentified leakage 11 and then gives a number which is gallons per minute, 12 a number greater or less than one gallon? O 13 A Right. I don't remember everything that came out 14 on it. 15 Q But it did at least have that information? 16 A It had unidentified leakage on it. 17 Q And it gave a number -- 18 A Total leakage? 19 Q Right, identified leakage? 20 A Right. 21 Q The computer would provide you with basically 22 a line item which would read " Unidentified Leakage," 23 and then it would be followed by a number broken down 24 into -- taken down into several decimal points 25 which was gallons per minute, a gallons-per-minute

821 1 Faust 0 2 number, is that right? 3 A At one time they made a change in the program. 4 Q What was the change? O 5 A I don't know if 16 broke down. I believe it h rounded it off to a whole number one. l I 7 Q Then it had less than one or one? I 8 A I'm not sure. ll* 9 Q It did, however, provide a number in l l 10 gallons per minute? l 11 A Yes. l ~12 Q Did you ever, in the course of running O 13 the leak rate test, obtain a number for unidentified 14 leakage from the computer which was in excess of one 15 gallon per minute? 16 A Yes. 17 Q What did you do when you obtained that 18 number? 19 Firstly, on how many occasions, do you 20 recall? 21 A I don't recall. 22 Q Do you recall whether it was more than five? 23 A I don't recall how many it was. 24 Q You can't say that it was less than ten or 25 more than ten or less than five?

822 1 Faust g~g 2 A No. 3 Q O.K. 4 Was there more th n one occasion when 5 that happened? 6 A There was more than one. 7 Q on those occasions what did you do when 8 you received a number for unidentified leakage that 9 the computer said was in excess of one gallon per minute? 10 MR. MacDONALD: His recollection as he can 11 recall? 12 MR. BENEDICT: Yes. -s 13 A Proceeded to verify whethe r it was greater 14 than one or not. 15 Q How did you go about that? 16 A By checking -- one of the things.I would do, 17 let the Foreman know unless I already knew the answer. 18 Q If you got to the numbe r -- 19 A or the Supervisor. you would talk to your Shift Supervisor 20 Q h 21 or Foraman and then you would take 22 A I already knew the answer. In other words, if 23 I had affected the leak rate where I knew that one of A () 24 the other operators in the control room had affected l 25 it by -- without the two of us getting together on

823 1 Faust O 2 when the leak rate had been entered and when the 3 other man might have been adding water to the system. 4 Q In other words, you are not supposed to 5 add water to the system during a leak rate test? 6 A Not necessarily. 7 Q If you do, however, you are required 8 to take a count of it by using one of the attachments 9 to this procedure, isn't that right? 10 A Right. You would enter it into the system. 11 It would be entered into the leak rate. 12 Q In those situations where you didn't O 13 know the answer to why the number was in excess of 14 one gallon per minute, you say that you would mention 15 it to your shift Foreman or Shift Supervisor and 1 16 then what steps would you take? 17 A We would check to find out why it might be greater 18 than one. 19 Q What would you do? 20 A By looking at the plant itself, to see if the 21 parameters were in a steady state. 22 Q Did there ever come a time when you got 23 a n umb e r in e xce s s o f o r.e gallon per minute where 24 by examining the plant parameters from the control 25 room you were unable to explain the number in excess

824 1 Faust 2 of one gallon? 3 A There was a time when we would not be able 4 to explain it on our shift, yes. 5 Q What happened if you couldn't explain it 6 during your shift? 7 A well, we had four hours to correct the situation. 8 Q Right. 9 when you received a number from the 10 computer which said that it was in excess of one gallon, 11 did that mean that you moved into the action Statement 12 B in the technical specification marked as B&W Exhibit O 13 2517 14 A I'm trying to remember the situation where I think -- we didn't explain 15 we didn't explain it 16 it and another shift explained it. 17 Q Is it your understanding -- 18 A Another shift usually verified it on the leakage. 19 the additional leakage that we had 63 that time. 20 Q Was it also the case that there were times 21 when you would go out into the plant to examine the 22 physical plant itself to find leaks and identify 23 them, measure the amount that was leaking and ( 24 subtract that from the unidentified leakage? [ 25 A To have a proper leak rate, we would add it into l

i 1 Faust 825 O 2 another leak rate and run another one, see if it 3 came out within limits. 4 Q Do you recall doing that? 5 A We found additional leakage in the plant where 6 we entered it into another program that we started -- not 7 program, but entered another leak rate in. 8 Q There were at least two different kinds 9 of situations when you got a number in excess of one 10 gallon. On the one hand it was caused by changes f 11 in the condition of the plant during the leak rate 12 test, in other words, someone added water, or that O 13 you changed the thermal output of the plant where 14 there was some change that affected the calculation. 15 That would be one situation where you 16 would conclude that the one gallen per minute was not 17 a valid number, is that right? 18 A That is right. 19 Q And then there were other situations in 20 which there had been no changes to the condition of the 21 plant during the test period but you or another member 22 of the operating staff went out into the plant, 23 located leakage, measured it, and then ran another test b 24 using that as additional added leakage, that amount? q_j f 25 A Yes.

I i 826 1 Faust i O 2 Q so you agree with me, those are two 3 separate sorts of non-valid numbers? In other words, 4 those are two separate reasons for invalidating what 5 you got from the computer? 6 A That is right. 7 MR. MacDONALD: Are you excluding he could 8 ever have those together? 9 MR. BENEDICT: They may have worked in 10 combination, but they are separate items. 11 MR. MacDONALD: They can be separate? 12 MR. BENEDICT: Right. 13 Q Was it your understanding that upon 14 receiving from the computer a number in excess of 15 one gallon that you were then required pursuant to 16 the technical specifiation to get within limits 17 within four hours or move on to the next step which 18 was go into hot standby -- 19 A If we confirmed we had -- 20 Q -- by six hours? 21 A If we confirmed we had a valid leak rato, 22 it was my understanding we would go into the next 23 step if we didn't find it within four hours. () 24 Q In other words, upon receiving from the 25 computer a number that was in excess of a gallon, you

1 ~ Faust O 2 had four hours to get a valid number? 3 MR. MacDONALD: Objection. I think he just 4 gave the answer. Upon receiving a valid number, S then they would move on. It may be different 6 from just receiving a number out of the computer. 7 You have made the distinction and drawn it. 8 MR. BENEDICT: The answer he gave was l 9 longer than that and it seemed to me 10 containing in it two readings. 11 Q When you received a number from the 12 computer, put in the material necessary pursuant to the O 13 procedure and received a number from the computer, 14 was it your understanding that then upon that 16 receipt you had four hours within which to determine 16 that that number was not valid and to rerun the test 17 and get a valid number, a valid number that was under 18 one gallon per minute? 19 A We got a leakage that we couldn't if we had a 20 leakage that was in excess of one GPM, we had four 21 hours from that point to determine if the leak rate 22 itself was an invalid one and if it was proven to be 23 a valid one, we had four hours in which to find 24 the leakage or correct the leakage problem, and if we 25 didn't, we would end up going into the next mode.

) 1 Faust 2 Q Next mode. I'm having a little bit of 3 trouble distinguishing -- I recognize the distinction 4 you are drawing between the number from the computer 5 and what you call the valid number, and all I'm 6 trying to do is distinguish as to when you thought 1 7 you had only four hours before you -- be fore you 8 then had six hours to go into the next mode down. 9 Was it from the time that you got a number 10 in excess of one gallon from the computer or was it 11 from the time that you determined that that number '12 was a valid number? 13 A It is not for me to decide, really. 14 Q Who did you understand prior to the 15 accident at Three Mile Island was responsible for 16 making that decision? 17 A It would be my -- I guess I'm not sure I ever 18 thought of it in that term. 19 Q Was it your understanding that 20 A I guess I just thought when we proved we had a 21 valid or invalid one. 22 Q Did you receive at any time prior to the 23 Three Mile Island accident training with respect to O) (_ 24 the technical specification that is marked as B&W 251? 25 A I've read it, went over it. I've gone over it

I 829 I Faust V 2 in classroom training. 3 Q Do you recall -- 4 A As far as reading the tech spec itself like 5 you are trying to do right now is a dif ferent s to ry. 6 Q In the sense that you did not do it? 7 A I didn't have to inte rp re t it necessarily, as far as to what you are talking about. 8 9 Q It was not your view prior to the 10 accident that you were required to interpret the tech 11 spec. You felt it was for somebody else? 12 MR. MacDONALD: Interpret what part of ("} V 13 the tech spec? 14 A If I from the computer readout got greater 15 than one GPM, it was one thing to make sure that 16 we 17 Q Do you want to start again, Mr. Faust? 18 The question was was it your understanding or did 19 you believe prior to the accident at Three Mile 20 Island that your job did not involve the interpretation 21 of when you moved into Action Statement B under the 22 tech spec we were talking about? 23 A I don't think I had to make a determination ~'T (d \\ 24 like that that I can remember. 25 Q Prior to the Three Mile Island accident, i

0 2 1 Faust I 2 you were familiar with Action Statement B and the 3 requirement that if you get a valid measurement for i 4 unidentified leakage in excess of one gallon per 5 minute, you were required to take certain actions j 6 within certain time periods, is that right? 7 A That is right. I 8 Q And it was your enderstanding that 9 prior to the accident you didn't have a valid number 10 until you had run certain checks on any number you 11 got from the computer that was in excess of the 12 maximum allowable leakage? OV 13 A I don't remember having a problem like that, i 14 Q You have testified that there were times 1 15 when you got a number in excess of -- I j ust plain simply 16 A But I'm talking about 17 thought of it that'I had four hours to get the final 18 leakage or get it less. I don't think I thought I can't remember having a problem with 19 about 20 I guess what you are saying, getting close to the line. 21 Q Right. 22 You are saying you got the number from 23 the computer, you saw it as having four hours to get ( 24 that squared away, either determined that the number 25 was valid and move on to the next stage of the procedure,

3 1 Faust 831 OO 2 or to determine it was invalid and run a valid number? 3 A Valid number? 4 Q Or obtain a valid test result? 5 A If it came out invalid, if you want 6 Q You had to run another number? 7 A I can't give you an example of that right now. 8 Well, let me correct that. 9 I've already said that we have gone through 10 on ny shift and had leak rates that, depending on l l 11 what time of the shift now, that were -- we couldn't t 12 get a valid one, let's put it that way. OG 13 Q By that you mean that you can recall an 14 instance prior to the accident at Three Mile Island 15 where you received a leakage rate in excess of 16 one gallon per minute for unidentified. leakage and 17 could not during your shift, however much time was 18 left, establish that that number was invalid and that 19 leakage was in fact less than one gallon per minute? 20 A I remember turning over the next shift that I had 21 to get a good leak rate. They had to determine where 22 the leakage was at. 23 Q Referring to the back of the procedure ( 24 where there are some tables starting at page 30.0 25 through 32.0, are these steam tables?

4 1 Faust 832 0 2 A Looks like a set of steam tables. I should 3 say -- yes, yes. 4 Q what purpose were these tables put to 5 with respect to this procedure? 6 MR. MacDONALD: Are you asking if they were 7 put to any -- 8 Q Assuming they were attached for a purpose g by the people who drafted the procedure, yes. I thought 10 that was a reasonable assumption to make. 11 MR. MacDONALD: Never can make an assumption '12 without asking the witness what he knows. 13 Q Do you know of any purpose these tables 14 were to be put in the use of this precedure? 15 A I don't remember rer' erring to them if that 16 is what you mean right now. 17 Q Do you recall never having to use these 18 then in using this procedure? 19 A I don't recall using them right now. 20 Q Do you recall whether you used those h 21 tables in order to perform the one-hand calculation 22 that you did on your own for training purposes? 23 A I just don't recall. 24 Q Looking at what is headed as Figure 3 on 25 page 25.0 and immediately prior to that, I guess

5 1 Faust 833 2 these are Figures 1, 2, and 3. Le t's ref er to them 3 all together which are on pages 23.0 through 25.0. 4 Do you know what p urp o s e, if any, these 5 tables were attached to this procedure for? 6 A It's been a while. 7 Q Do you recall ever having to use these 8 tables -- I'm sorry, these are graphs. 9 A These graphs would have been used in doing 10 the manual calculation. 11 Q Does looking at the table, the steam '12 table we have identified, and these graphs, refresh 13 your recollection that in order to perform 14 this calculation it is necessary to convert all of 15 the different water volumetric, water measurement 16 into a single consistent water volumetric measurement? 17 A Would you -- did you just read it 18 g ze m asking if that helps your memory. 19 A I don't remember the procedure totally. 20 Q And seeing these tables, one of which 21 refers to water density, the steam tables relate 22 to saturation points, none of that re freshes your 23 recollection that in order to perform manually N 24 these calculations, it is necessary to convert the 25 water in the various parts of the reactor system i

5 1 Fauet 2 makeup

tank, the reactor coolant system itself, 3

which are all at different temperatures and pressures 4 to a consistent figure? 5 A If you -- I remember working with graphs. But 6 as far as remembering which graphs that were in this 7 procedure, I don't remembe r that. 8 Q Do you remember what the purpose was for g using the graphs, was it to confirm the measuroments 10 to one consistent measurement? 11 A Due to the different temperature changes in '12 the system, yes. O 13 Q Right. 14 From your understanding of this procedure, 15 understanding that you had up to the day of the 16 accident at Three Mile Island, is it correct that 17 for some reason in the course of performing the 18 calculations necessary, the amount of water in the 19 reactor makeup tank was overestimated, that the 20 result would be -- strike the question. Let me start h 21 over again. 22 Prior to the Three Mile Island accident, 23 did you understand that if yo-overestimated the ( 24 amount of water in the reacte coolant drain tank 25 or erroneously measured it so am tu at a numbe r that i

835 g Faust 7O 2 said there was more water than actually there, 3 vhile you correctly measured the water in the makeup 4 tank, that the result of that one error would be to 5 reduce the unidentified leakage measurement? 6 A was I aware of that? 7 Q Did you understand that that result would 8 occur with this procedure? 9 A If I added water to the makeup tank, it would 10 reduce my unidentified leakage. II Is that what you want? l '12 p Q Yes, that is very helpful, so to turn V 13 it around, is it true that if you overestimate the 14 water or, say, if you were to add water to the 15 reactor coolant drain tank, would that reduce the 16 unidentified leakage? 17 A Never added water to the drain tank -- 18 Q Or overestimated the water in it. l 19 A If you added to it, it's usually subtracted 20 from it so -- 21 Q Assuming that error -- you're right. 22 It should be subtracted from it, assuming it weren't? 23 A If I had just left it like that? 24 Q Yes, your understanding of the procedure 25 prior to the accident.

8 1 Faust 836 b('N 2 A I don't know if I thought of it. 3 MR. MacDONALDs Whether he -- 4 MR. BENEDICT: Understood it that that G 5 was indeed the case. 6 A I don't remember thinking about it. 7 Q O.K. 8 But you did know prior to the accident 9 that increasing the amount of water in the 10 makeup tank and not accounting for that increase 11 in the calculations would result in reducing the 12 measured unidentified leakage? -~ O 13 A Yes. 14 Q O.K. 15 Was adding water to the makeup tank one 16 of the errors that occurred during running leak tests 17 which permitted you to recognize the numbe r fromthe 18 computer as being invalid? 19 A Yes. 20 Q Did ycu ever receive from the computer a $h 21 number which indicated that the reactor collant 22 system had negative leakage? 23 A Yes. r~T (_) 24 Q What did you determine for those 25 occasions or occasion when you got a negative number l l

\\ 9 I Faust O 2 for identified or unidentified leakage, what did 3 you determine to have been the cause for that number? 4 A Usually if I determined that it was just the 5 way the systen, the way the printout or the computer. it tsok all the data' 6 looked at it, I pictured it 7 at one point and at another point it took another 4 8 picture -- I'm just saying within the tolerance t 9 of the instrumentation, it could have given an in c re a s e.d 10 volume either makeup tank or like you are saying, it 11 could have been giving it in the RC drain tank. ~12 Q Do you recall any situation in which c 13 you received negative numbers for the unidentified a 14 leakage where you determined the cause of the negative l 15 numbe r to have been an unaccounted for addition to I l 1 w 16 the makeup tank? .17 A Unaccounted for -- say that again. 18 Q Do you recall whether on any of the 19 occasions that you received a negative number for the 20 unidentified leakage that the cause, that you k 21 determined that the cause of that negative number was 22 that someone had added water to the makeup tank and the 23 computer hadn't taken account of that? N' 24 A Yes. 25 Q That did happen?

u .- r; j e se r J,,. .. t,,,o J t s e 838 3 1 1 't Faust /, ~ /. ' O 2 A Us ally "it.was a gross numbe r. n. c.- 3 ~Q j I do n ', t know wha t.,y'du mean by " gross A j 'r j_ [([ 4 number."/ f a h / - y / e[,

• • / f

' v e' S,, A' j,,Rather large negative in leakage. s6 i ,a. ,7 .s ,( lJ.) 5, Q What r,ec'ording requ.irements or reporting is -- j 7 requirements were there as to the taking of the tests t, t 8~1 required by the tecly s'pec;B&W 251 and performed pursuant l

• i 3

to this surveillance. procedure ~which is B&W 252? j, 10 MR'.' MacDONALDr Reporting in what cense or 11 recording 1n what sense? 12 MR. BENEDICT: In any sense; putting 13 pen to paper or typewriter to paper or clay to 14 scribe. 15 Q What did you do? 16 A What did I do? 17 Q Right. 18 A File the data. 19 Q What form did the data take? 20 A Usually a surveillance form. 21 Q You filled out a piece of paper? 1 22 A That is right. 23 Q Is that paper attached to this procedure? 24 A I didn't notice it. That is the one we were 25 talking about earlier.

1 1 Faust O 2 Q What would happen to that form after you 3 filled it out? 4 A If it was a valid one -- well, let me correct 5 that -- O.K., that is the way to say it. If it was 6 a valid one, it would be filed. is that 7 Q Did you fill out a data sheet 8 what you call it, a data sheet? 9 A Data sheet, leak rate. 10 Q Leak rate data sheet. 11 Did you fill out one of those for numbers 12 which you have classified as invalid? O 13 A I filled them out for ones that we hadn't 14 determined whether they were valid or invalid yet. 15 Q And the ones that you then subsequently 16 after you filled out this form that you determined 17 were invalid, what did you do with that fo rm? 18 A As far as I know, they got thrown away. 19 Q It was your understanding that the only 20 requirement was that you file the leak rate data h 21 sheets that contained leak rates which you had 22 determined to be valid? 23 A If the leak rate was considered valid; that is it. () 24 Q Where in physical fact were these papers 25 put? Were they stapled into the control room log? l

840 2 1 Faust O 2 A They were sent into -- I put them in the 3 surveillance box up in the control room and they 4 then went somewhere. 5 Q Was there any other recording requirements 6 that you know of, do you know if there was a 7 requirement that the results of the test be noted 8 in the control room log or in the Shift Foreman's 9 log or any other peridic reports? 10 A The leak log -- in the CCO's log. I don't know 11 if it was consistent 12 Q You know, note within the control room log 13 that a test was performed. 14 A Yes, that we were doing a leak rate. 15 Q Would you note the results of the test? 16 A I don't recall. I'd have to look up the log. 17 Q Did you, during any time prior to the 18 Three Mile Island accident, make entries in the 19 control room operator's log? 20 A Yes. j 21 Q was that part of your job to do that? 22 A Yes. 23 Q Who else would make entries on your shift C,D/ 24 besides you? s 25 A Could be any operator that was in there.

l 841 3 1 Faust 1 V(~N. 2 Q Including the Shift Supervisor and Shift 3 Foreman? 4 A I may have asked them to put something in, 5 but he would write things he did in the log he kept 6 and it was definitely a normal thing for the CRO to 7 keep the CRO logbook. 8 Q It would be one of the CROs in the 9 control room. 10 would it ever be done by an auxilliary 11 operator? '12 A I don't know; may have. He would have been -) G 13 under direction of the CRO. 14 Q Do you know of any other recording 15 requirements with respect to the performance of 16 leak rate tests pursuant to the procedure we have 17 been talking about? You have mentioned the data sheet 18 which you put in a box and then disappeared, it went 19 some place you don't know, and you mentioned the 20 control room operators log. h 21 Do you know of any others? 22 A I don't recall any. 23 Q On the occasions where you received O) (_, 24 from the computer a number in excess of one gallon 25 per minute for unidentified leakage, did you note

842 I 1 Faust 0 2 that fact in the control room operator's log? A I'm n t sure if I did or not. 3 4 Q If it were a situation in one of the times that you have described where you received 5 6 a number in excess of one gallon per minute, it was 7 then through some review process determined to be an 8 invalid number, do you remember any occasion when 9 you entered the fact that you received a number. in 10 excess of one gallon from the computer? 11 A I'd have to go back and look through the log. '12 Q You don't recall one way or the other at O 13 this point? 14 A No. 15 Q You do not recall that it was your 16 practice to enter the results of the computer run 17 regardless of what you later determined to be 18 their validity? 19 A You mean what we determined why it wasn't 20 valid? 21 Q Yes. 22 A I don't think that was a common thing; at least 23 I don't remember doing that. 24 Q What is the largest number of leak rate 25 tests you recall ever taking during a single shift?

I Faust 843 0\\ v 2 A I think three. 3 Q You can recall taking three? 4 A I believe so. 5 Q Did you take the second because the i 6 first was a number that was in excess of the amounts 7 permitted by the tech spec? 8 A May have been both ways. 9 Q I'm sorry? A Might have been a negative or it might have 10 11 been greater than one, but if we took it, it was because something that we determined during shift '12 13 that we had accounted for in the initial entry of it. 14 Q Same question for why did you take the 15 third, because the second was either providing you 16 with a negative number or a number in excess of the 17 permitted amount? 18 A Sometimes I would enter it wrong. 19 Q I don't understand. 20 A I would -- make an error? 21 Q 22 A Yes, and I would realize that I made an error 23 and I don't remember if I knew how to cancel that O 'u/ 24 time out of the computer. I would wait until the end 25 of the run came and then run another one.

I Faust 844 O 2 Q At the time that you recall having taken 3 three different leak rate tests during the one shift 4 A Back up. I'm saying I believe I took three. 5 I don't recall the time that I took it. I didn't mean 6 to give you that impression. 7 Q You understand, however, that the most 8 you took was three, that is what you recall? 9 A I believe. 10 Q Cther than the one time you have 11 mentioned where you could not establish or you could ~12 not obtain for one reason or another a valid number 13 under the specified limits and had to pass that 14 question on to the next shift, was there ever a 15 time when you could not obtain a valid number under 16 the limits specified? 17 A I really don't recall if -- you know, how many 18 times that might have been. 19 Q You do recall, however, that it. happened, 20 that you could not obtain a number that you considered 21 valid, it was under the specified maximums? 22 A I just recall that we turned over a leak rate 23 to the other shift. I didn't pinpoint if it was the 24 number of times. 25 Q In other words, you are not sure now whether

I Faust 845 O 2 it was only once that that happened or maybe it 3 happened more than once? 4 A I'm saying I just don't recall. 5 Q Right. 6 Do you know of any time, whether it was 7 on your shift or not, when the plant was put into a 8 lower mode of operation pursuant to the requirements 9 of the tech spec marked B&W 251? 10 MR. MacDONALD: Unit 1 or Unit 2? 11 MR. BENEDICT: Yes, although this tech 12 spec is only for Unit 2. 13 Q But do you know of any time when a leak 14 rate required that either Unit 1 or Unit 2 be put 15 in a reduced mode of operation? 16 A I thought we shut down one time 17 because -- I'm trying to remember -- I thought it 18 was on a letdown lane or the decay heat leg had a leak 19 rate on it, or had a leak on it. 20 Q Do you recall whether that was a situation 21 where the identified leakage exceeded ten gallons? 22 A I don't recall. I just -- we had a leak on the 23 valve. 24 Q And did it require 25 A I believe we couldn't get a good leak rate.

1 Faust 846 'O y/ 2 We could live with the leak but we couldn't get a 3 good leak rate less than the identified or unidentified identified, I guesc it was in that 4 requirement 5 case. 6 Q So that required that the plant be shut down? 7 A Yes. 8 Q Pursuant to this cech spec requirement? 9 A Right. 10 Q Did that happen on your shift? l 11 A I just remember the incident. I don't I don't know if it happened on mine or not. '12 remember 13 Q It was Unit 27 14 A That is what I don't remember. I just 15 remembe r the incident. 16 Q O.K. 17 Let me show you a document that has been 18 marked previously as B&W Exhibit 253 which is headed 19 "Three Mile Island Nuclear Station, Station 20 Administration Procedure 10-12, Shift Relief and Log 21 Entries." 22 Are you aware or were you prior to the 23 accident aware of the requirements of this procedure? f~) (! 24 A Do I remember them all? 25 Q No, sir.

1 Faust 847 O 2 A I don't remember them all. 3 Q Had you reviewed the requirements of 4 this procedure at any time prior to the Three Mile 5 Island accident? A At one time or another it was part o f my 6 7 training to review it. 8 Q Referring to page 7.0, and looking at sub-subhead unde r the heading 9 3.3.17 which is a 10 " General Requirements, Control Room Log," it specifies, 11 " Accomplishment of testing - Record title and number ~12 of the test performed, and the start and completion 13 times or time of suspension of the test. The performance 14 of all periodic tests and inspections required by 15 the technical specifications shall be recorded." 16 were you aware of this requirement prior 17 to the accident at Three Mile Island? 18 A I don't remembe r -- 19 MR. MacDONALD: This specific one being 20 in effect? 21 Q Were you aware of the requirement I just 22 read prior to Three Mile Island? 23 A I can't really recall if I was or not. I v 24 Q Isn't it true that you understood that 25 performance of all periodic tests and inspections was

1 Faust 848 OV 2 required to be logged into the control room 3 operator's logbook, not just tests that you had 4 subsequently determined to be ones that had valid 5 numbers? 6 MR. MacDONALD: He just told ycu he didn't 7 recall. 8 MR. BENEDICT: I'm pressing him on a 9 specific question. 10 A I know you are. There are a lot of other ones 11 listed there, too. rS 12 Q Yes, sir, but back to my question. U 13 A I just don't recall. 14 Q Turning to the next page, 8.0, and looking 15 at section 3.3.18, which reads, "The above sections," 16 which include 17, "are nct meant to be all inclusive 17 but merely indicates the type of entries that should 18 be made. When doubt exists, enter it in the log." 19 Did you understand that to be a requirement 20 of your procedures prior to the accident at Three 21 Mile Island? 22 A I don't recall. I don't recall what I thought 23 about it at the time. A i s \\m) 24 Q Wac there ever a time when you thought it 25 was appropriate to record within the control room

1 Faust 849 o 2 operator's log all leak rate tests regardless of 3 whether they resulted in what you have called valid 4 or invalid numbers? O 5 MR. MacDONALD: Ask him whether he did it? 6 MR. BENEDICT: Did there ever come a time 7 when he thought it would be appropriate. 8 A Why don't you get the logbook and see if I did. ~ 9 Q You've testified that your recollection 10 is that your practice in procedure was not to record 11 all tests whether or not they provided a valid ;. amber. 12 That is what I am basing my question on. (' 13 A I'm having a hard time remembering. I'd like 14 to see the logbook to see if I did or didn't. l 15 Q You don't recall at this point, and you 16 couldn't recall without seeing the logbook whether it f 17 was your practice to record all test results, whether k 18 or not they resulted in what you call a valid number? 19 A All test results 20 Q Performed pursuant to this procedure. l h 21 A You mean I didn't miss any? 22 Q No, sir. I'm asking whether it was 23 your practice prior to the accident at Three Mile ( )g 24 Island to record within the control room operator's 25 logbook all tests taken pursuant to this surveillance

ll I Faust 850 0 2 procedure marked as B&W Exhibit 252, regardless of 3 whether the number was determined ultimately to be as 4 you call it a valid number or not. 5 A I know I didn't record all. If you are talking 6 about leak rates 7 Q Yes. 8 A -- which I considered to be invalid? 9 Q Yes, that is what I am talking about. 10 You know you didn't record all of those. 11 If you got a number in excess of a gallon from the '12 computer, you did not 0 13 A Valid. 14 (Continued on next page.) 15 16 17 18 19 20 h 21 22 l 23 (~N 24 () 25 I

1 Faust 851 ) (d 2 Q Right, let's focus the question. If you 3 re ceive d from the computer a number in excess of one 4 o f the maximum limitations imposed by the Te ch spec 5 we have been talking about, you did not feel that you 6 were required pursuant to any administrative procedure 7 or other procedure to enter that fact, the fact of 8 receiving a numbe r in excess of the Tech Spec limits 9 from the computer in the control room logbook; you 10 only fe lt that you were required to enter those that 11 you subsequently determined to be valid? '12 MR. MacDONALD: He told you he didn't J 13 recall be fore. 14 MR. BENEDICT: That is not in fact what 15 he told me. 16 A Le t ' s read it back, be ca us e I'm not 17 Q You want to hear the question again? 18 A I do not recall everything in this procedure 19 that 1 was supposed to be doing. It is a lot of 20 things listed. Yh 21 Q I agree. I'm not quibbling with that. 22 I'm trying to focus 23 A You are getting ve ry specific and I'm telling O (,/ 24 you I don't recall specifically everything I logged 25 in the book. I' d like to see the log and dete rmine

1 l 852 1 Faust O 2 just how I logge d things. 3 Q Let's go back to my pending question and 4 read it and see if Mr. Faust can get an answer. If 5 not, we will go on. 6 (Re cord read. ) 7 A I really don' t recall. I may have logged othe r 8 ones. 9 Q You don' t recall what your practice was? 10 MR. MacDONALD: If he had a practice. 11 Q If you had a practice you don't recall what 12 it was, you don't even recall whether you had a 0 13 p ra ctice ? 14 A I don' t recall -- I know I didn't log every 15 leak rate I ever took. Does that help you? 16 Q Yes. 17 A I don' t recall if I had logged I believe what 18 you are after, invalid ones or no t. 19 Q I un de rstand, and it is helpful that you 20 say you know you didn' t lo g e ve ry te s t you e ve r took. k 21 I am turning to a somewhat dif ferent question, which 22 is, do you recall prior to the accident at Three Mile 23 Island whether you had an understanding as to what O 24 was required of you with respect to recording leak (j 25 rate test results; and if, you did, what was that 1 l

Faust 853 ,1 O f unde rstanding? 3 MR. MacDONALD: Talking about recording 4 in the CRO? 5 MR. BENEDICT: Now we're focusing on the 6 control room operator's icg. 7 A I think my understanding of it was to use the 8 data sheet at that time because I would end up 9 signing it if I did it and putting it in anyway. 10 Q Is it true if I re colle ct your 11 testimony previously -- isn't it true that those data 12 sheets were only preserved if they were what you call 13 valid numbers? 14 MR. MacDONALD: Who is "you," Mr. Faust? 15 MR. BENEDICT: Yes. He himself. 16 A The rates that we dete rmined that we re valid we re 17 the ones that would be kept. 18 Q Right. In fact, you filled out data 19 sheets for all the rates that you received from the 20 compute r but only saved those data sheets with respect h 21 to leak rates that you determined were valid; is that 22 right? 23 A No. 24 Q What did you do with the leak rate data 25 sheets containing info rmation about leak rates, test i 1 1

1 Faust 854 O 2 results that you dete rmined were invalid? 3 A Throw them away. 4 Q So they were not pre se rve d? 5 .A I threw them away. 6 MR. BENEDICT: Off the record. 7 (Discussion off the record.) 8 ( Re ce s s taken.) 9 BY MR. BENEDICT: 10 Q Mr. Faust, you've testified that ce rt ain 11 records with respect to the taking of leak rate tests 12 were thrown away. Are you aware of any time when O 13 results of tests o r documents indicating the results 14 of tests were thrown away when there was no valid 15 reason for rejecting the results which showed 16 e xce s si ve le akage under the tech specs? 17 MR. MacDONALD: What do you mean, no valid 18 reason? 19 MR. BENEDICT: He said -- 20 A Leak rate test. lh 21 Q Pursuant to the procedure we have been 22 talking about? 23 A Any time I know and those are the ones I was 24 involve d eith, that we re discarded were ones that were 25 conside re d invalid.

1 Faust 855 O 2 Q They we re considered invalid for the 3 re asons we have discussed previously? 4 A Yes. 5 Q Do you know whether or not they were tests 6 that you were with, do you know of any tests relating j 7 to leak rates taken pursuant to this procedure marked 8 as B &W Exhibit 252 that were disposed of or the records 9 were dest royed despite the fact that there was no valid 10 re as on for rejecting the results shown thereon? 11 A You mean considering it was good and it was ~12 thrown away? 13 Q Yes. 14 A Not that I know of. 15 Q You don' t know of any situation prior to 16 the acci de nt at Three Mile Island where documentation 17 concerning leak rate tests we re th rown away? 18 A That I 19 Q Despite the fact that the re was no reason 20 for disposing o f or for rejecting the results, no dlh 21 valid reason? 22 A No valid re as on ? l 23 Q Yes. ( 24 A Leak ratec that I knew that t.ere discarde d had 25 already been validated as being invalid.

1 Faust 856 v 2 Q Right. 3 A Those are the ones I know. 4 Q M d -- O 5 A That is just the ones I did. 6 Q I unde rstand that, and I am trying to be 7 a little broader and go instead on knowledge that you 8 may have acquired from talking to othe r people, what 9 yo u' ve heard. Obviously excluding anything your 10 counsel has told you, with respect to any incident or 11 instance whe re such documentation was thrown away ~12 where there wasn't or hadn' t been a determination that O 13 the n umbe rs were invalid. 14 MR. WALSH: Objection as to wh at he heard 15 around the plant. I just 16 MR. BENEDICT: On what basis are you 17 objecting? 18 MR. WALSH: I'm objecting to that question 19 be caus e it's an improper question as to what l 20 he heard around the plant. lh 21 MR. BENEDICT: Anybody knows in a 1 22 discovery deposition you can ask about hearsay, 23 and that is what I'm asking about. The re fo re, i () 24 it is not improper. 25 MR. W ALS H : My objection stands. m

i 1 Faust 857 O V 2 MR. MacDONALD: I will make an objection. l i 3 BY MR. BENEDICT: 4 Q I press for an answe r. 5 MR. MacDONALD: No instruction. 6 MR. BENEDICT: Fine. Why don' t you read 7 the question back. 8 MR. MacDONALD: I think he gave you the g answer to that also. 10 ( Re co rd read. ) 11 A Talking about be fore or after the accident? 12 Q I'm talking about an incident which O 13 occurred prior to the ac cide nt since TMI II I as s ume 14 hasn' t been utilizing this procedure, since the 15 accident, but it is not relevant to me whether you 16 heard about it before or after the accident. 17 A I heard a lot of things after the accident. 18 Q I'm sure that is ri gh t. I'm interested 19 in those things excluding what ; our counsel told you 20 in the situation where your counsel is the only llh 21 source of information that you have on it. 22 MacDONALD: Well, objection. 23 Exclude discussions when counsel was there, l () 24 or where you were on loan. 25 Q Do you recall the question?

1 Faust 85 8 O 2 A I'm trying to distinguish between before and 3 af te r. 4 Q You don't need to distinguish between 5 before and after. You need to distinguish only 6 whethe r or not the information that you have you 7 obtained only from meetings with counsel. The mere 8 fact that you talked about it with counsel if you 9 heard about it outside of counsel's presence, you 10 should tell me about those things. 11 MR. WALSH: Do not answer if he can't '12 distinguish between conve rsations where a 13 counsel was present and where counsel was not 14 p re sent. 15 MR. BENEDICT: As I did with Maile r, I 16 think that is unresponsive. And.if he gives the 17 answer that he cannot distinguish, I will move 18 to strike the answer as being unresponsive, and 19 if necessary if it comes the time, I will press 20 for a distinction, and I believe that e ve n i f Nh 21 it is necessary to have an in-camera hearing 22 with the Magistrate, that I am entitled to 23 that answer. If you cannot distinguish where O) 24 you learned it, I do not believe the privilege (, 25 protects it. The re fo re --

Faust 859 1 O 2 MR. WALSH: My instruction stands. If he 3 can' t discinguish -- l t 4 MR. BENEDICT: But his answer will have 5 to be that he can't distinguish, and I will note 6 my objection in that case. 7 A You are saying if I knew o f leaks greater than i 8 one GPM? 9 Q or any gallon limitations, the 10-gallon 10 or eight-gallon a minute for controlled leakage, or the 11 one-gallon primary to secondary leakage or the 12 no-leakage f rom the pressure bounda ry, I' m asking about 13 any le akage. 14 A I was aware of disagreements that had occurred 15 with operators, other operators, but I di dn ' t thi nk 16 they were -- I don't know if I thought about it that 17 much. 18 Q I'm not sure I unde rstand what you mean 19 by disagreement between the operators. Would you 20 elaborate? k 21 A I knew there was dis ag reement with some 22 operators with the way interpretations were made on it. 23 Q what did you know about those 24 dis ag re e me nts ? 25 A They just didn' t agree with whoeve r they were

1 Faust 860 0 2 discussing it with, t 3 Q Do you know who it was who had those 4 di s a g re e me n ts ? 5 A I couldn't te ll you now. 6 Q Do you know what the dis ag ree me nt was? 7 A Just basically they disagree d with leak rates. 8 Q An d -- 9 A I should not say leak rates -- l 10 Q Did the dis agre emen t relate to the 11 practice of disposing of records concerning the taking '12 o f leak-rate tests? 13 A I don't think so. 14 Q Do you recall any, the specifics of what 15 this dis agre e me nt related to? 16 A I think the re had been a disagreement on 17 something I didn' t believe was right, because I 18 always thought it didn' t a f fe ct it, the one I'm 19 thinking about. 20 Q Tell me what you' re thinking about. You ' re dh 21 talking in too much gene rality. 22 A There was a disagreement on adding hydrogen. 23 I didn't think it affected the leak rate. 24 Q And what was that disagreement, what i 25 were the two sides of the di sag ree ment ?

1 Faust 861 0 2 A one g uy said it af fe cted the leak rate. 3 Q Adding hydrogen to the make-up tank 4 affected the leak rate results? O 5 A The way I believe it. 6 Q That is what you understand? 7 A Yes. 8 Q What was the argument with respect to the 9 supposed e f fect or alleged effect that hydrogen had upon 10 the le ak rate results? 11 A They were saying that it affected the tank level 12 where I was saying it -- the indicator itself sensed 13 both side s. The re fe re n ce leg as well as the 14 low-level tap all saw the same in cre as e in pressure. 15 so it was nullified across the DP dete ctor as far as 16 I was con ce rn e d. I didn't think about it too much 17 after that. 18 (Continued on Page 862.) 19 20 l 21 22 23 M 25 f

862 1 Faust 2 Q was the argument on the other side that 3 the addition of hydrogen to the makeup tank reduced 4 the numbe rs you would obtain in taking c leak rate 5 test? 6 MR. MacDONALD: Reduce what numbers? 7 MR. BENEDICT: The results, gallons per 8 minute, leakage from the system. 9 A I think it went either way. 10 Q In other words, some people thought that 11 adding hydrogen would increase the numbers received 12 in the results of the test and other people thought 13 that adding hydrogen would decrease the numbers? 14 A Yes, I think that is the way it was; as far as 15 I remember it. 16 Q Do ycu recall any of the views on this 17 subject held by any of the other members of your shif t? 18 A Why don't you ask them? 19 Q I will, I assure you. I'm entitled to ask 20 you, too. h 21 MR. MacDONALD: If you can recall. 22 A I don' t remembe r what they were thinking, to \\ 23 tell you the truth. j 24 Q I'm not asking you to read their minds. 25 A I'm j ust saying this wasn't a long, hard discussion

863 1 Faust /% NY 2 It was just something that was going on. I didn't think it affected it. 3 4 Q During what period do you recall this O 5 discussion going on, what time? 6 A What time? 7 Q During the year, I mean, when? 8 A Some time. j l 9 Q Prior to the accident? I 10 A well, prior to the accident. l 11 Q Do you recall whether it was within the j { i '12 six months prior to the accident or much before that? { ( \\ \\ / 13 A No-14 Q What purpose would there be to adding 15 hydrogen to the makeup tank? 16 A overpressure you are supposed to maintain on the i 17 makeup tank for hydrogen to the plant, added to the 18 plant. That is how we added hydrogen to the plant. 19 Q By adding hydrogen gas to the makeup tank 20 it was then dissolved into the water in the makeup h 21 tank? 22 A That is right. 23 Q It was kept at a certain pressure in the (q ) 24 makeup tank? 25 A It was varied.

864 i 1 Faust O 2 Q If during the course of doing a leak rate 3 test, if this hydrogen pressure was varied, some 4 operators felt that that would affect the accuracy O 5 of the leak rate test? 6 A I believe so. 7 Q You can't at this point tell me any name, 8 any person that you recall held that view, that it 9 would affect the results of the tests? 10 A It was more of just a -- I don't remembe r holding 11 specific discussions with the individuals. They made ~12 a comment on it and I said I made my opinion on it that O V 13 I didn't agree with it. 14 Q Do you remember any of the people who 15 did make that comment to you that they felt it did 16 affect the results? 17 A No. 18 Q You don't recall -- 19 A I wouldn't be able to distinguish between the l 20 operators. 21 Q Do you remembe r whether -- l 22 A It wasn't that significant to me. 23 Q Do you remember whethe r any of the people j ( 24 on your shift held the view that it did affect leak 25 rate results? l l

865 1 Faust O 2 MR. MacDONALD: He just told you five 3 minutes ago he didn't recall what the views 4 were that were held by the people on his 5 visit. You can ask as to each person 6 but I don't think it's going to help. 7 A I could make a guess. 8 g Is m not asking you for you to guess. 9 MR. WALSH: Don't guess. 10 A I don't remember at this time. 11 Q It was your view that adding hydrogen 12 did not affect the accuracy of the test results? 13 MR. MacDONALD: I think he told you that. 14 A Yes. 15 Q Is that right? 16 A Yes. 17 Q The question to which you provided me with 18 the information about the dispute concerning hydrogen was do you know of any instances where test results 19 were disposed of or rejected even when there was no 20 21 valid reason for rejecting them? 22 I appreciate the answer you gave, and I 23 would like to make sure that that exhausts your 24 recollection on that subject. 25 Are there any other instances that you

866 1 Faust O ktsow of? 2 A Prior to the accident? Q Whether you learned about them prior 4 O to or subsequent to is not important, but I am 5 concerned with instances that occurred prior to the 6 r, accident. It doesn't matter to me whether you 7 learned about them yesterday, unless you learned 8 about them from counsel, then you should not tell me. g A I d n't really recall right now, 10 Q Are you aware of any instances in which gg the results of leak rate tests performed pursuant to 12 the procedure we have been discussing were recorded g in rre tly in either the data sheet or in the 14 control room operator's logbook or elsewhere? 15 A Now? 16 g7 Q Are you now aware of any such instances? MR. MacDONALD: Intentionally or -- ig MR. BENEDICT: Whether it's just a time 19 when it was recorded inaccurately. 20 Q Go ahead. Do you want to hear the 21 question again? 22 A The only one I can think of is the one g that is involved in the Grand Jury, as far as me. 24 Q Do you kr.ow -- g

1 Faust 867 O 2 A And that is not proven as far as I know. 3 Q I don't mean you to limit your answer 4 to me on things that are proven. I mean to focus 5 instead on what you have heard, what you know other 6 than what you know only through your counsel with 7 respect to instances where leak rate results were 8 recorded inaccurately. 9 MR. MacDONALD: It is not only through your 10 counsel; it's only through instances where you 11 may have learned things through individuals 12 where counsel was present. 13 I don't want him to be misled into the 14 fact that counsel necessarily spoke it. 15 Q If your only knowledge of a situation, 16 your only knowledge of a situation is knowledge 17 that you obtained in the presence of your counsel, 18 unless it was a public meeting of some kind, I would 19 exclude that. 20 A That I recall. I can't think of any right now. 21 Q You can't recall any at this point, any 1 22 instances in which you have heard about the recording 23 inaccurately of the test results of a leak rate test? (_) 24 A I can't distinguish when I heard about things 25 now. l

I Faust 86 8 O 2 Q So you can't recall whether you did 3 learn anything about what you have in your mind right 4 now independent of discussions in the presence of 5 counsel? 6 A No, unfortunately. I'm talking about my counsel, 7 him, over there. 8 Q Your private counsel. 9 MR. MacDONALD: Any counsel. 10 Q Are you aware of the allegations that 11 Harold Hartman has made with respect to the '12 performance of leak rate tests at Unit 27 O 13 A specifics of it, no. 14 Q Have you heard about it? 15 A I've heard about Harold Hartman. 16 Q Had you heard about Harold Hartman other 17 than through your attorneys or in the presence of your 18 attorneys? 19 MR. MacDONALD: Heard what of Harold Hartman? 20 MR. BENEDICT: Heard of him, dh 21 A Yes, I heard of him. 22 Q Did you know Mr. Hartman? 23 A Yes. 24 Q Do you know that Mr. Hartman has made 25 allegations with respect to tampering with the results l l

i 869 1 Faust A-V 2 of leak rate tests at Unit 2? l 3 MR. MacDONALD: If you have heard it 4 independently or can distinguish that you have 5 heard it independently when counsel was present. 6 A I learned about it from NRC. 1 7 Q Have you been interviewed by the NRC 8 with respect to taking leak rate tests? 9 A Yes. 10 Q Do you recall by whom you were interviewed? 11 A No. 12 Q Did you receive a ~ copy of a tape or a i 13 transcript of that interview? 14 A I don't re me mb e r. 15 Q You don't remember whether you received -- 16 A I received a lot of tapes, transcripts. 17 Q Did you return those tapes and transcripts 18 over to your attorneys? I 19 A I think I've turned them all over to my attorneys. 20 Q Did you turn them over to your private h 21 counsel? 22 A Private counsel? 23 Q That is who you gave what you gave, whether 24 you don't recall whether this tape was included 25 in that -- i

1 Faust 870 fh s/ 2 A I gave him everything. 3 Q You gave him everything. forget it. I gave it to him. 4 A Actually I gave 5 g o.x. 6 MR. BENEDICT: This subject came up with 7 Mr. Mailer, and I unfortunately do not know 8 the result of the examination that was done 9 pursuant to a request I made by letter to 10 Mr. Glassman of the Kaye, Scholer firm that 11 Mr. Faust's files in your possession or in 12 the possession of any other private counsel 13 he has retained. 14 I would request now that if that tape 15 of this interview hasn't been produced that it 16 be produced, an d in light of the. fact that 17 I requested it by a letter dated August 7, 18 if it in fact has not been received by us, I 19 will reserve calling Mr. Faust back to examine 20 him further on the subject of leak rates. 21 Q Are you aware that there is a pending 22 Grand Jury investigation on the issue of the 23 falsification of leak rate results? 24 A I know there is a Grand Jury investigation on 25 leak rates, yes.

871 I Faust 2 Q Right. 3 Do you know through sources other than 4 your counsel whether this Grand Jury investigation 5 relates to the allegations made by Mr. Hartaan? 6 MR. WALSH: Objection. 7 MR. BENEDICT: Grounds? O MR. WALSH: Because it's an ongoing 9 Grand Jury investigation and I think any 10 question concerning an ongoing Grand Jury 11 investigation and the substance of that 12 investigation is improper. 13 MR. BENEDICT: I disagree with you 14 categorically, but I will put an opinion in it. 15 If you want to direct the witness not 16 to answer, and if and when it be come s ne ce ss ary, 17 and we will go to a Magistrate on the question. 18 MR. WALSH: Fine. 19 MR. BENEDICT: I do not believe that he 20 is entitled simply because there is a pending 21 Grand Jury to avoid questions on that fact. 22 If Mr. Faust has an individual 23 constitutional privilege he wants to assert, 24 he is entitled to assert it. He is entitled 25 to have private counsel present, but it is not, l

1 Faust 872 0 2 I think, within the scope of private counsel's 3 purview, to object to a question on the ground 4 that you are asserting. I just don' t think that 5 is the basis. If you are going to s top me 6 about questions on the Grand Jury, we will have 7 to put an opinion in that, too. 8 MR. WALSH: Fine. Because we will stop 9 you conce rning que stions about the Grand Jury. 10 So -- it's already come up once, and it's come 11 up again, and we will follow the same course. 12 MR. BENEDICT: I app re ciate the fact it 13 came up earlie r. I thought that once you saw 14 the obvious relevance of the issue to this 15 proceeding, which is one of some import, that 16 you would realize that your objection is not 17 well fo unde d. 18 MR. WALSH: That objection is ve ry well 19 founded, and I would be glad to go to a 20 Magistrate any time. k 21 MR. BENEDICT: 0.K. 22 MR. MacDONALD: I think you've gotten what 23 I suggested Mr. Fiske do at the beginning, the O. 24 information he sought by asking questions as 25 to Mr. Faust's recollection is on le ak rates.

1 Faust 873 0 2 You can get it without going to the Grand Jury 3 proceedings. 4 MR. BENEDICT: Just as there are times 5 when someone's recollection changes as time i 6 p asse s, it is perhaps possible that things, i 7 j memo ry can be re freshed by discussions, by 8 1 questions with respect to previous discussions 9 on a s ub j e ct. As I say, if you' re going to 10 block all my questions with respect to Grand 11 Jury, I will put an opinion in that subject ~12 and we will cover it some other day. 13 MR. Mac DON AL D : I think you've exhauste d 14 it. 15 BY MR. BENEDICT: 16 Q Turning to anothe r issue on leak rates, 17 r d like to show you a document previously marked e 18 B &W 255 and tell you that it is identi fied as a 19 temporary change notice to Procedure 2301-3D1, RCS 1 20 inventory that the temporary change notice is dated .k 21 March 16, 1979. During the pe riod from March 16, 22 1979 until the accident on March 28, 1979, did you 23 perform any leak rate tests on Unit II? 24 A Yes. ' 25 MR. MacDONALD: Ask him whether he eve r I

Faust 874 1 OO 2 saw the document. 3 Q Did you perform them pursuant to the 4 document, the temporary change notice I have put 5 before you? 6 MR. MacDONALD: Ask him whether he saw 7 it be fore. 8 MR. BENEDICT: Well, he may have 're ceived 9 training on the temporary change notice without 10 actually having seen the document. I'm 11 interested rathe r in whether or not he utilize d ~12 the contents rather than whether he saw the 1 13 document. 14 A I p e r fo rme d le ak rat e s, yes. You are saying 15 pursuant with this particular one? 16 Q Yes, sir. 17 A I remembe r the re was a change in it. 18 Q You do remember the re was a change in the 19 p roce dure that has been marked as Exhibit 2527 20 A I remember the re was a change in the methods h 21 that we were doing of leak rates. 22 Q Do you recall that that was around the time 23 of the date of this document, March 16, 1979, 24 immediately be fore the Three Mile Island accident? 25 A Sometime prior to the accident there was a i - ~ _

1 Faust 875 ,~. 2 change, yes. 3 Q Did you receive any training with respect 4 to the change in that procedure? 5 A What do you mean by training? Instruction? 5 Q Yes. Any sort of instruction. 7 A It was on shift turno ve r. He showed me what he 8 was doing on it. If there was a TCN on it, he would 9 have pointed it out to me. 10 g "He" being your -- the person you were 11 . replacing? '12 A Re li e ving, yes. O 13 Q Relie ving. 14 A Yes. 15 Q Prior to the accident at Three Mile Island 16 did you understand the reason for this temporary change i 17 notice? 18 A I remembe r that it was due to the drain tank, 19 temperature change in the drain tank. 20 Q Do you remember that the procedure was h 21 change d purportedly to account for changes in the 1 22 drain tank during the test period? 23 MR. MacDONALD: Changes in what? 24 MR. BENEDICT: Change s in the pa ramete rs, i 25 A Te mpe rat ure s did, yes. l l l

1 Faust 876 O 2 g Was the result of this procedure to 3 ch ange the way the quantity o f the wate r in the drain 4 tank was calculated for purposes of using the O 5 p ro ce dure marked at B&W 252? 6 A That I don't recall everything about it. It 7 was associated with the drain tank, temperature 8 changes. 9 Q Have you since the accident become aware 10 that -- st rik e that. 11 Are you aware that the temporary change 12 notice marked as B&W Exhibit 255 presents an erroneous O 13 method for calculating reactor coolant system 14 leak age ? 15 MR. MacDONALD: According to who? 16 MR. BENEDICT: Metropolitan Edison. 17 MR. Ma c DONAL D : According to anyone 18 MR. B EN EDICT : According to Metropolitan 19 Edison in a letter to the NRC. I'm asking 20 whether he -- you are the one who says it is llh 21 incorrect. I'm asking if he knows it is 22 incorrect. If he knows it is not in co rre ct, 23 he can tell me. N ,/ 24 A At the time ? 25 Q Well, let's start with up until the day of

1 Faust 877 O 2 the accident were you aware that that was an 3 in corre ct proce dure for calculating le akage from the 4 reactor coolant sy st e m? O 5 MR. MacDONALD: Objection. I don't thi:.k 6 you' ve e stablished that it's incorrect. You' re 7 putting the cart be fore the horse. 8 MR. BENEDICT: I hope you won' t direct 9 him not to answer. Your client has a dmi tte d 10 th at this procedure was in violation to the 11 NRC. '12 MR. MacDONALD: We're dealing with a O 13 witness he re who is giving testimony, not with 14 any other piece o f evidence. 15 A If you already know that 16 Q My question is not whether or not it is l 17 incorrec I' m asking wh at you knew about it. That J 18 is the distinction that 19 A Up until the accident? 20 Q Yes. llh 21 A I do n' t think I was aware o f it. You're 22 talking about a time that I can' t put the times. 23 Q It's from March 16 when the temporary 24 change notice was issued until the date of the 25 accident 12 days late r.

Faust 878 g O 2 A A lot of things have happened since then, and i 3 it's been a long time since then, and I've talked to a 4 lot o f people. 5 Q Right. Can you tell me today whether or 6 not you knew th at this tempo rary change notice 7 presented an imp rope r, an erroneous method? 8 A I can't tell you -- I'm not sure of what I was L 9 aware of at that time. 3 10 Q You have since become aware that this 11 temporary change notice presents an incorre ct method o f 12 calculating reactor coolant system le akage? 13 A I'm not sure of what I remembe r any mo re. l I 14 Q Aside from when you learned it, as you sit 15 he re today do you in fact know that this te mporary 16 change notice is an improper or incorrect method for 17 calculating le ak age from the reactor coolant system. 1 1 18 A I j ust don't remember right now. I haven' t been 19 thi nking about i t.. 1 20 Q Do you recall prior to the accident at lh 21 Th re e Mile Island ever discussing with anyone this 22 temporary change notice marked as B&W 2557 l 23 A To figure out how it was done, yes. 24 Q Do you know with whom you discussed it? 4 25 A Look back in the log and see who I re lie ve d. 4 5 y, ,,,.,-.,.---,-,_...---,,.,._---w,.-- y ,w v- ,v %.,m-w.~. ,w.__,...,_ry,ya. ,w.. y-.-rr.w,.-w..-c,---,--- + - -, -

Faust 879 1 O 2 Q The person whom you discussed the procedure 3 with would be the first ope rator you relieve d following 4 the institution of this TCN on a shif t whe re you did O 5 a leak rate? 6 MR. MacDONALD: Is that your recolle ction? 7 A No. 8 MR. MacDONALD: Testify as to what your 9 recollection is. 10 A I really don' t recall. 11 Q You don' t recall receiving any specific '12 instruction other than what you may have discussed ' O 13 with the person whom you were relieving with 14 respect to this TCN? 15 MR. MacDONALD: Other than what person? 16 He said a person. I don' t know whe the r you 17 are re fe rring to a specific person on the first 18 shift after this was in or -- 19 MR. BENEDICT: The record is as it is. 20 I'm not trying to create something by my question. lh 21 Q Do you recall other than speaking with the 22 person whom you relieved on some occasion -- 23 A Asking me right now who it was, I don't recall 24 any more. 25 g I appreciate that. I'm asking you a l

1 Faust 880 0 2 separate question, which ist Did you receive any 3 other instruction or informaion or training with 4 respect to this TCN other than the conve rsation that G S might h ave occurred with your predecessor on a shift? i 6 A I tried to answer earlier to that be cause that l I thought it was just lo gi cal in that o rde r, but 7 8 I ' m -- I really don't recall who I got the instruction 9 f rom on how to do it. 10 Q The instruction -- but you can say at this 11 point you do not remember re ceiving any instruction 12 or training with respect to this TCN othe r than some 13 conve rs atio ns you may have had with the pe rson you 14 were relieving on some shi f t? 15 MR. MacDONALD: I do n' t think that is what l 16 he said. 17 A I couldn' t s ay that. 18 Q I' m j ust asking whether you can recall 19 any othe r. I'm not saying you didn't have any. 20 I said you cannot now state that you cannot now 21 recall? 22 M R. MacDONALD: Re collection is a two-way 23 street. He couldn't recall one way or the 24 other. You can take either side of that. 25 MR. BENEDICT: I think I just did --

1 Faust 881 0 2 Q What is the answer? 3 MR. MScDONALD: You'll have to go back and 4 re ad it. O 5 MR. BENEDICT: I think you don' t p urpo rt 6 to know, so read the question back, and then 7 we will get an answer, and then we can move 8 along. 9 MR. MacDONALD: He already testified he 10 can' t recall. 11 MR. BENEDICT: Please reread and retype '12 here the pending question. 13 (The repo rte r read the portion 14 re q ue s te d, as follows: 15 " Question: I appreciate that. I'm 16 asking you a separate question, which is Did 17 you receive any othe r instruction or information 18 or training with re sp e ct to this TCN other than 19 the conve rsa*. ion that might have occurred with 20 your prede cessor on a shift?") lh 21 Q In other words, can you recall receiving 22 any training other than what you think happened with 23 respect to some other operator on a prior shift? r~ l (_)/ 24 A I don't re c all. 25 Q O.K. That was the only point in my

1 Faust 882 n v 2 q ue s tio n. Are you today aware that from March 22, 1979 3 through until the accident on March 28, 1979 4 unidentified leakage from the reactor coolant system O 5 at Unit II was in excess of one gallon per minute? 6 A What was the first part 7 Q Are you aware to day ? 8 A I'm aware that something was going on on it, 9 o r the re was something pending on it. 10 Q Are you aware that it is in fact the case 11 that from March 22, '79 until March 28, 1979 and the '12 accident, the leakage, unidentified leakage from the a 13 reactor coolant system at Unit II was gre ater than 14 one gallon per minute? 15 MR. MacDONALD: On e ve ry le ak rate, on 16 eve ry shif t 17 MR. BE NE DI CT : I will stand by my question. 18 MR. MacDONALD: I think it's ambiguous. 19 I object. 20 Q You may answe r. llh 21 A I don' t know. 22 Q You don' t know whether the leak rate was 23 greater than one gallon per minute during that period? 24 A All the time ? I don' t know. 25 Q Do you know whether there was any time

i Faust 883 1 2 during that period when leak rate wac greater than 3 one gallon per minute? \\ 4 A That was de fined valid? i O 5 Q Yes. 6 A The 7 Q I'm not saying that the leak rate showed 8 up in s ome te s t. Isn't it t rue in fact, regardless 9 of the tests that were run, leakage was greater than 10 one gallon per minute? 11 A Did I know it then? '12 Q Do you know it now? 13 A I' m sure I do. 14 Q That is a di f ficult t 15 A I think the re is something -- I can't recall the 16 specific thing you are talking about, but I think 17 there is something goind on right now that is saying 18 it was. Nobody came up and discussed it with me. 19 Q I beg your pardon? 20 A I don' t think anybody discussed it with me. lh 21 Q Are you aware that the NRC issued a 22 notice of violation claiming that the le ak, the 23 unidentified le akage during the period from March 22 24 until March 28, 1979 was in excess o f one gallon per 25 minute and in violation of te ch spe cs, the reactor l

Faust 884 1 O 2 was not placed in a lessened mode of operation? 3 A That is what I imagine I was trying to re fe r to. 4 Q Are you aware that Met Ed admitte d that O 5 violation and paid the fine with respect to it? 6 MR. Ma cDON AL D : Ob je ct ion. I don't think 7 there is any evidence that they admitted it. 8 MR. BENEDICT: Turn to Page 29 of the 9 Appendix of the NRC letter in assessing the 10 fine dated January 23 to your client. You will 11 find that Met Ed concede d that that occurred ~12 and that they paid the fine. 13 MR. MacDONALD: All I'm here to do is to 14 hear your questions of the witness. 15 MR. BENEDICT: I' m entitled to ask that l 16 q ue stion. You are not entitled to block it. 17 Your client in letters to a public body has 18 admitted that this in fact o c cur re d. That is 19 enough foundation for me. I don ' t have to 1 20 lay a foundation at this deposition for it. h 21 MR. MacDONALD: My obj ection is noted. 22 I'm not going to -- 1 23 MR. BENEDICT: Reread my pending question, 1 ( 24 and you can have an answer. 25 (Re cord read. )

1 Faust 885 ~ [G 's 2 MR. Ma c, DON AL D : Knowledge that you gained 3 independently of any conversations you may have 4 had with counsel or where coun sel was p resent. 5 A Met Ed didn't tell me they paid a fine, if that 6 is that you mean. 7 Q Were you aware during the period from 8 March -- at any time during the period from March 22 9 to Ma rch 28, 1979 that at any time, the le ak rate from 10 the reactor coolant system at Unit II in fact e xcee de d 11 one gallon per minute unidentified? '12 A That was valid? O x_- 13 Q That in fact o ccu rre d. 14 A That in fact was valid, that was determined 15 valid? 16 g well 17 MR. MacDONALD: We were talking about times 18 when the compute r would kick out numbers that 19 were in exce ss of one gallon per minute. 20 Q Let me see if I can simplify things. h 21 We re you aw are during the period from March 22 to 22 March 28 and the accident at Three Mile Island that 23 at any time during that period, unidentified leakage n k _,) M from the reactor coolant system, the leakage, the s 25 . actual le ak age in f act excee ded one gallon per minute

1 Faust 886 O 2 unidentified regardless of what test results may have 3 shown? 4 MR. MacDONALD: Where the compute r kicked O 5 out a number greater than one GPM? 6 A I don't unde rstand the question. 7 MR. MacDONALD: I don't understand it 8 myself. 9 Q Do you recognize the dif fe re nce between 10 test re s ults and the actual fact of an event? 11 A I think I don't. '12 Q In othe r words, can you believe that there 13 could -- do you understand that the re could be a time 14 at the reactor where leakage was in excess of one 15 gallon pe r min ute where the test results would not 16 show that unide ntified leakage was in excess of one 17 gallon per minute? 18 MR. MacDONALD: Are you asking whethe r 19 he e ve r c ame across it? 20 MR. BENEDICT: I'm trying to lay enough lh 21 foundation,so I can ask a question that is 22 proper that is not difficult to unde rstand. 23 MR. MacDONALD: Obviously it was not, 24 because the witness said he di dn' t unde rstand it. 25 Q Do you understand my pending question?

1 Faust 887 O 2 A I' m not sure what you' re getting at. 3 Q Let me see if I can -- 4 A Make it simpler for me. O 5 Q I'm talking about actual leakage..Really 6 the stuff dripping out of the system, rather than what 7 any test result shows, are you aware that at any time were you aware that during the six-day pe riod I' m 8 9 talking about from the 22nd of March until the. accident 10 on the 28th, were you aware during that time that f 11 le akage was in f act in excess of one gallon per minute '12 unidentified from the reactor coolant system? 13 A Was greater than -- i f we thought it was greater i 14 than one GPM unidentified act3al, it would be avalid i 15 le ak rate, then we go into the action statement. Is 16 that what you are a fte r? Is that what you mean? 17 Q It is indeed true that I'm after the l 18 f act whether you personally knew or believed that 19 leakage was greate r than one GPM during that period, i 20 whether or not you went into the action statement or h 21 for whatever reason, whatever happened as a result 22 o f that knowledge. I'm trying to find out whether you 23 had that knowledge simply. ( 24 A I thought we had identified it. 25 Q I'm not sure I understand you. i

1 Faust 888 2 A It's -- 3 MR. MacDONALD: Probably because the 4 question is not very clear. G 5 A (Continuing) I thought we identi fie d 6 leakage. At that time. 7 Q It was your -- 8 A We accounted for leakage that was -- in other 9 words, we identified leakage to less than GPM 10 unide nti fi e d. 11 Q And there was not a period -- the re was '12 no time during that period, those six days, when, 13 re ga rdles s of what test results you may have had, you 14 belie ve d, you, Craig Faust, believed that leakage was 15 in fact greater than one gallon per minute? 16 A That is an open-ended question, to me. 17 MR. MacDONALD: What is your recollection 18 in those six days, if you have a recollection? 19 A (Continuing) I don't think I started thinking 20 about it until -- in the way you are asking the ll 21 question now. That is what I'm saying. I don't 22 really recall thinxing about it like that. 23 Q During that period -- O) 24 A I re member thinking that leakage was ge tting g_ 25 gre ate r, but we were accounting for the leakage, and

1 Faust 889 O 2 we were accounting for it in our procedure by 3 identifying the leakage. Therefore, the leak rate 4 be came valid. 5 Q Now it is your understanding that during 6 that p e ri o d, those six days, that although leakage was 7 getting greater, it was being accounted for properly 8 pursuant to the procedures in e f fect? 9 A That is the way I felt, yes. 10 Q And you did not believe that there was 11 anything incorrect or imprope r about the tests or ~12 the way they were conducte d, or the test results? 13 MR. MacDONALD: That is what he told you 14 be fore when you asked him that question. 15 A I didn't have any reason -- at le ast I didn't 16 have any reason to doubt,the procedure. 17 MR. MacDONALD: Off the record. 18 (Discussion o ff the record. 19 (Pause) 20 BY MR. BENEDICT: h 21 Q Earlie r in your testimony, Mr. Faust, you 22 mentioned that there was a dispute with respect to the 23 e f fe ct that adding hydrogen to the makeup tank had 24 on the validity of leak rates. Are you aware of any 25 other actions that were taken with respect to the

1 Faust 890 0 2 reactor coolant system during leak rate procedures, 3 the e f fe ct of which was to provide an incorre ct leak 4 rate result? O 5 MR. MacDONALD: I don't think he 6 characterized it as a dispute. 7 MR. BENEDICT: O.K. 6 Q A discussion. 9 A Wasn't e ven a discussion; it was a couple of 10 words. I can't think the main one I' m thinking 11 about is that at that time that we had. I don't think ~12 there are nay othe rs. 13 Q Are you aware of any actions whi ch we re ' uring leak rate d 14 t aken with re spect to plant systems 15 tests, the e f fect of which was to create invalid 16 results where those results were not accounted for 17 in examining the numbers received? 18 A I 19 Q Trying to be ge ne ral, but as an example, 20 are you aware of anytime., and this is just an llh 21 e xample of what I' m trying te get at, are you aware 22 of anytime when water was added to the makeup system 23 during the taking of a leak rate test where that 24-addition of water was not accounted for? 25 A If it is the one I'm thinking about, that NRC

1 Faust 891 lx_/ 2 p ro duct told me. 3 Q That was during this interview? ) i 4 A I think it was Christmas. O 5 Q The interview was ove r Christmas? 6 A No, the thing occurre d, what, in '78? That is 7 the way I remembe r it. 8 Q Is it your recollection -- you say it 9 was brought up by the NRC, in this interview that you 10 mentioned to me earlier? 11 A They looked at the logbook and I'm saying it '12 was a mis conception be tween the times it was entered '~' 13 in the logbook and when the actual le ak rate was run 14 and depending en where you look at time, it was within 15 five minutes. They are saying that it indicates 16 when you look at a log the leak rate sheet, that it 17 looks like we added five hundred gallons, I think it 18 was, we made up to the makeup tank without accounting 19 for it and that would have given one hell of a l l 20 negative leak rate. lh 21 Q And I take it 22 A And it doesn't show, the thing doesn't show a 23 big leak rate. I'm saying it was just logged out of /3 ! _) 24 -- it was probably the clock I looked at at the time. 25 Q That was the situation where the NRC was

Faust 892 g 2 interested in asking you about something that you were 3 involved in? 4 A Yes. 9 5 Q And it involve d what they wanted to ask 6 you about what is the apparent addition of makeup of 7 water to the makeup tank without accounting for that J 8 during the test, that is what they were interested in? 9 A Yes. 10 Q Do you know of any other situations other 11 than the one you just mentioned in which actions were ~ 12 taken with respect to the plant systems, the ef fect 13 o f which was to re s ul t in incorrect leak rate results 14 where that -- where those actions were not accounting 15 for? 16 A Not me. 17 Q Do you know of anyone else eve r having 18 done anything like that? 19 A I don't recall anybody doing that. 20 Q Yo u' ve never heard about that? I 21 A I just do n ',t recall it. 22 Q Are you aware of the fact that Mr. 23 Hartman has said that he did it? 24 A I' m aware o f an accide nt, yes. Af te r the NRC 25 involvement that he had said that. ..,4

1 Faust 893 O 2 Q Are you -- why did you exclude that from 3 your prior answer, did you think I meant things you 4 had learned about prior to the accident? O 5 A Yes. 6 Q Putting aside that and not excluding what 7 is prior to or after the accident, focusing on what you 8 know up to today, excluding what you know in the 9 presence of counsel, do you know of any other instances 10 where s uch actions were taken other than the actions 11 that Mr. Hartman says he took? '12 A I remember Hartman mainly. I can't reme mbe r O 13 any other ones. 14 Q You don't know of any other -- 15 A I don't recall any others. I don't recall. 16 Hartman -- Hartman's name is significant to me. 17 Q His name is significant? 18 A Yes. 19 Q Have you ever taken actions other than we i 20 have -- we have discussed the one situation that the lh 21 NRC raised, which apparently is covered in this 22 i nte rvie w. Other than that, have you ever taken any 23 actions with regard to plant systems during a leak ~s 4 ) 24 rate test, the result of which was to give an 25 inaccurate leak rate re sult and then you didn't

1 Faust 894 O 2 account for those actions? 3 A or that I wanted to? 4 Q What -- 5 A Th at I wanted to give it 6 Q Any acts, whether it was intentional or 7 ina dve rte nt ? 8 A I wouldn't know. I never tried to add water, 9 if you want, and not log it. 10 Q You never tried to create inaccurate 11 results that were under the maximums pre scribe d? '12 A go, d 13 Q Are you ever aware of anybody else e ve r 14 trying to do that, whether they succeeded or not? 15 A Hartman. 16 Q Other than that. 17 A That is the one I can remember, and that was 18 learned after. 19 Q That was after the accide nt that you 20 learne d about it? i h 21 A Yes. 22 (continued on Page 89 4-A. ) 23 24 25

1 Faust 894-A O 2 MR. BENEDICT: I think that is it on leak 3 rate. 4 (Time noted: 4 : 13 o ' clo ck p. m..' S 5 6 7 Craig C. Faust 8 9 subscribed and sworn to before me i 10 this day of 1981. ) 11 i ~12 Notary Public O 13 14 15 16 17 18 19 1 20 21 22 23 o u

l 1 895 i f CERTIFICATE STATE OF NEW YORK ) 3

ss.:

COUNTY OF NEW YORK ) 4 / I, ROBERT E.

LEVY, C.S.R.

, a Notary Public of the State of New York, do hereby certify that the continued deposition of CRAIG C. FAUST was taken before 8 me on F ri day, october 25, 1981 consisting f pages 713 through 894-A 10 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by' blood or 14 marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel. 18 IN WITNESS WHEREOF, I have hereunto set my hand this day of j N , 1981-20 21 q 22 Ohl / y- ~ 23 y ROBERT E. LEV -C. S. R. 24 25

030 INDEX O WITNESS PAGE CRAIG C.

FAUST, Resumed 715 EXEIBI TS B&W FOR IDENTIFICATION 281 Strip ch art reflecting T av.

tempe rature on the morning of the accident 763 282 Document' entitled " Steam Supply System Rupture," " Abno rmal Procedure 2203-2.3" 770 0 283 Document entitle d " Preliminary Annotated Sequence of Events, March 28, 1979" 803 e *

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