ML20072H750
| ML20072H750 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/04/1982 |
| From: | Frederick E METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-04, TASK-1, TASK-4, TASK-GB NUDOCS 8306290714 | |
| Download: ML20072H750 (128) | |
Text
us lqq) dob '
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
__ . _ -_ _ _ _ _ _ __ _ _ _ _ _ -u GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683
- (R.O.)
-againSt- -
THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., t Defendants. :
- _ _ _ _ _ _ _ _ _ __ _ _ _ _ ___ _ _x Deposition of METROPOLITAN EDISON COMPANY, by EDWARD R. FREDERICK, taken by Defendants, pursuant to Notice, at the offices of Davis Polk & Wardwell, Esqs.,
One Chase Manhattan Plaza, New York, New York, on Tuesday, May 4, 1982, at 9:40 o' clock in the forenoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York,
%. f4 .
8306290714 820504 PDR ADOCK 05000289 PDR b DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 Lex NGTON AVENur WALTER SH APIRO, C.S.M.
New YomK. N.Y. 10017 CHAMLES SHAP!RO C.S.M.
TELEPHONs 212 - 867-8220
1 i
1 I
l 1 2 l G'O 2 Appe arance s:
3 KAYE, SCHOLER, FIERMAN, RAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue New York, New York By: RICHARD C. SELTZER, ESQ.,
6 of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By: ROBERT B. FISKE, ESQ.
-and-12 WILLIAM E. WURTZ, ESQ.,
O 13 of Counsel 14 15 KILLIAN & GEPHART, ESQS.
Attorneys for the Witness 16 Box 886 Harrisburg,' Pennsylvania 17108 17 By: JANE G. PENNY, ESQ.,
18 of Counsel 19 20 Also Presents g 21 JONATHAN QUINN -
22 ERIC ABRAHAMSON l
I M
e . .
f 1 24 25 l
l l
I 1
3 0 2 IT IS HEREBY STIPULATED AND AGREED 3 by and between the attorneys for the 4 respective parties hereto that the sealing, h 5 . filing and certification of the within 6 deposition be, and the same hereby are, 7 waived; and that the transcript may be signed 8 before any Notary Public with the same force
. 9 and effect as if signed before the Court.
10 IT IS FURTHER STIPULATED AND AGREED 11 that all objections, except as to the form 12 of the question, shall be reserved to the 13 time of trial.
14 15 16 17 18 19 20 21 l 22 23 24
(~
0 25
1 4 O 2 EDWARD R. FREDE R ICK, residing 3 at 2141 Schoolhouse Road, Middletown, 4 Pennsylvania, having been first duly sworn by lh 5 the Notary Public (Joseph R. Danyo), was examined 6 and testified as follows:
7 EXAMINATION BY MR. FISKE:
8 Q How are you employed?
9 A I am employed by GPU Nuclear as a supervisor 10 of nonlicensed operator training.
11 Q How long have you held that position?
12 A Since March of this year.
13 Q That is March of 19827 14 A Yes.
15 Q Is there a supervisor for licensed nuclear 16 training?
l 17 MR. SELTZER: Do you mean operator 18 training?
19 MR. FISKE: Yes.
20 A Yes, there is.
21 Q Who is that?
22 A There are actually two positions; one held 23 at TMI-l and the other at TMI-2. The supervisor in
[~ 24 Unit 1 is Nelson Brown. The supervisor in Unit 2 is L)) l 25 Fred Scheimann.
l l
1 Frederick 5 l v
2 Q Just so I understand, what is your ,
3 position again?
4 A I am supervisor of nonlicensed operator k 5 training in both units.
6 Q Mr. Brown and Mr. Scheimann have held the 7 positions that you just described also since March of 8 this year?
, 9 MR. SELTZER: Are you asking whether they 10 began holding that position in March of this year?
11 MR. FISKE: Yes. Let's put it that way.
'12 A No. They had different starting dates O
13 than I did.
14 Q Just so I understand it, since March of 15 1982, there has been one supervisor of nonlicensed 16 operator training and that is you for both units, and 17 there are two supervisors of licensed operator training, 18 one for Unit 1 and one for Unit 2, one being Mr. Brown 19 and one being Mr. Scheimann, is that correct?
20 A That's correct. The position did exist 21 before I held it, though.
G 22 Q Who held it before you?
23 A Frank McCormick.
[)
v 24 Q What position did you hold before March 25 19827
l l
1 Frederick 6 i
G I was administrator of nuclear technical 2 A i
3 training in Unit 2.
4 Q For both licensed and nonlicensed operators?
h 5 A Yes.
6 Q How long had you held that position?
7 A Since June 1979.
8 Q What position did you hold before that,
, 9 that is, before June 1979?
10 A I was a control room operator, TMI Unit 2.
11 Q Are you aware that in connection with
, '12 this lawsuit a request has been served on counsel for 13 GPU for the production of documents?
14 A Yes.
15 Q Have you personally made a search of your 16 own records to produce documents pursuant to that 17 request?
18 A Yes.
19 Q Do you have any documents relating to your 20 duties as a control room operator prior to the accident 21 that have not been produced to turn over to your 22 counsel?
M A No.
r's
!s j 24 Q One of the lawyers appearing here today 25 with you is Mr. Richard Seltzer from the Kaye, Scholer
I 1 Frederick 7 O 2 firm, is that correct?
3 A Yes.
4 Q And in addition to Mr. Seltzer, Ms. Penny I 5 is here from the law firm of Killian & Gephart. She 6 is also representing you here today?
7 A Yes.
8 Q Is Mr. Seltzer representing you personally?
, 9 MR. SELTZER: I am representing him in his 10 capacity as a company employee.
11 Q I would like to know the date when it was 12 that you first retained Ms. Penny's firm.
s
-) 13 A I will give you an approximate date. I 14 believe it was April 1980.
15 Q Have you turned over any of your documents 16 to Ms. Fanny?
17 MR. SELTZER: Do you mean his only copy?
18 Q Have you given any copies of any documents 19 that at any time were in your possession to Ms. Penny, 20 whether they are originals or copies?
21 A Yes.
22 MR. FISKE: I would like to ask whether 23 those documents that have been given by
(~h 24 Mr. Frederick to you, Ms. Penny, have been L.-)
25 included in the documents that have been reviewed
l 1 Frederick 8 O
V 2 for production pursuant to the document request?
3 MS. PENNY: I am certain they were.
l 4 Q Since the accident, you have given testimony l 5 and given interviews on a number of different occasions 6 to different people, have you not?
7 A Yes.
8 Q I would just like to run through those 9 with you to make sure that we understand all of the 10 different people to whom you have given information 11 since the accident.
-12 You have been interviewed by people of 13 the President's Commission, the so-called Kemeny l 14 Commission?
15 A Yes.
16 Q And you also gave a deposition, did you l -
1 l
17 not, to a representative of the Kemeny Commission, !
18 questions and answers comparable to what we are doing 19 here today?
20 A I believe so.
21 Q You also testified in a public hearing 22 before the full Kemeny Commission?
23 A Yes.
( 24 Q Did you also testify before a commission 25 known as the Rogovin Commission?
I 1 Frederick 9 i
%J 2 MR. SELTZER: You are asking about a 3 deposition by Rogovin or a public hearing?
4 MR. FISKE: Let's start with a depositaon.
5 Q Did you give a deposition to representatives 6 of the so-called Rogovin Commission?
7 MR. SELTZER: That is also known as the 8 NRC Special Inquiry?
9 MR. FISKE: Yes.
10 A Yes.
11 Q Did you testify publicly before the
~12 Rogovin Commission in addition to giving a deposition?
13 MR. SELTZER: Objection. No foundation 14 that the Rogovin Commission had public hearings.
15 A I am having difficulty separating all the 16 people that interviewed me during that time, what 17 their names were.
18 Q So you don't remember ene way or the 19 other?
20 A No, I don't.
21 Q Do you remember being interviewed by 22 representatives of the Nuclear Regulatory Commission 23 Inspection and Enforcement Group?
24 A Yes.
25 Q That was done up at Three Mile Island?
I 1 Frederick 10 O
V 2 A Not all of their interviews were held on 3 Three Mile Island.
4 Q You were interviewed by them on more than I 5 one occasion?
6 A Yes.
7 Q You were also questioned, were you not, 8 by representatives of Metropolitan Edison or GPU?
, 9 A Yes.
10 Q And you were interviewed right after the 11 accident, were you not, by people from Met Ed?
~12 A I was interviewed in the days following O.
13 the accident, yes.
14 Q And then at some point after that, were you 15 also not interviewed by the so-called Keaten Task Force?
16 Robert Keaten.
17 A A GPU employee?
18 Q Yes.
19 A Again, I don't specifically recall that 20 testimony. If there is record that I have, I wouldn't 21 dispute that.
22 Q Were you aware at sometime after the 23 accident that a group had been formed within GPU to O
() 24 conduct a post-accident review of the circumstances 25 leading up to the accident?
1 Frederick 11 2 A Yes.
3 Q Do you remember now being interviewed by 4 anyone from that group?
5 .
MR. SELTZER: Is this different from the 6 questioning by Met Ed and GPU employees after the 7 accident you referred to earlier?
8 MR. FISKE: Yes.
. 9 A I have no singular memory of that particular 10 group interviewing me.
11 Q Do you remember being interviewed by anyone 12 that you knew at the time was a representative of GPU
() 13 as opposed to Met Ed?
14 A I made no differentiation between those two 15 groups in my mind.
16 Q Have you testified before anybody in 17 connection with the TMI-1 restart proceedings?
13 A No, I don't recall having done that.
19 Q Specifically, are you aware of a report 20 that was issued last week relating to cheating that 21 went on in connection with certain tests given at 22 Met Ed?
23 MR. SELTZER: Are you asking does he know I
("T 24 that such a report was issued?
O 25 MR. FISKE: Yes.
i 1 Frederick 32 j
[ )
2 A I know that such a report was issued, yes.
3 Q And my specific question is did you give 4 any testimony in the proceedings that led to that 5 report?
6 A No.
7 Q Have you received a subpoena to testify 8 before a grand jury in connection with anything having
. 9 to do with your employment as a control room operator 10 before the Three Mile Island accident?
11 A Yes.
12 Q Have you in fact testified before the 13 grand jury?
14 A Yes.
15 Q Have you given any testimony under oath 16 in any proceeding other than the ones that I have 17 covered in my questions up to now concerning anything, 18 having anything to do with the Three Mile Island 19 accident?
20 (Discussion off the record between the 21 witness and his counsel.)
22 A Just from memory, I couldn't confirm that 23 that is a complete list of all of the testimony I have
() 24 given.
U' 25 Q Have you testified before any congressional i
l 1 Frederick 13 I
V 9, 2 committees?
Y 3 A Yes.
4 Q In addition to that congressional testimony, h 5 adding the congressional testimony to the list of 6 different testimony that you described up to now, having l
7 done that, can you think of any other testimony that 8 you have given under oath before any agency?
9 A You are trying to make a list just of the 10 times that I testified under oath?
11 Q Let's start with that. I am trying to 12 break it down.
13 A That is difficult for me to remember the 14 times I was under oath and the times I was not. In 15 the list that you have given me, it did not include l
16 I guess it was a congressional committee of the 17 Department of Affairs, the so-called Udall Committee.
18 MR. SELTZER: Mr. Fiske was including the 19 congressional testimony in the list. Other'than 20 those interviews and the depositions and the f
21 interviews that you already described, do you G
22 remember any other occasions where you gave 23 sworn testimony about the Three Mile Island
(^'N 24 accident?
\~)
25 MR. FISKE: I will withdraw the pending
e -
4 1 Frederick 14 O 2 question and simplify it.
3 Q As I understand, you already told us you 4 gave testimony, sworn or unsworn, to the Kemeny k 5 Commission or its representatives, to representatives 6 of the Rogovin Commission, to representatives of the 7 Inspection and Enforcement Section of the Nuclear 8 Regulatory Commission, to various individuals at Met Ed 9 or GPU, before certain congressional committees 10 including the Udall Committee and in the grand jury.
11 Having listed all of those, I would now
- 12 ask you whether you gave any information, whether it O 13 was under oath or not, to any persons other than those 14 that I have described up to now?
15 MR. SELTZER: I object to the question as 16 too v' ague and ambiguous.
17 Q Have you been interviewed by anyone other 18 than the groups I have just described?
19 A You mean any information that I have given 20 to groups who were asking questions?
21 Q Yes.
22 A Yes, there were other groups. l l
23 Q Can you tell us who they are? ;
() 24 A The Essex Corporation.
25 Q what were the circumstances under which'you
I 1 Frederick 15 O 2 gave information to the Essex Corporation?
3 A The Essex Corporation was given the 4 assignment of trying to develop a detailed sequence h 5 of events for the day of the accident, and I was asked 6 to assist them in doing that.
7 Q Who did you meet with from the Essex 8 Corporation in connection with that effort?
9 A I don't remember any of their names.
10 Q How many different occasions did you meet 11 with them?
. 12 A Only one or two.
O 13 -
Q Did they complete a sequence of events?
14 MR. SELTZER: What do you mean by the verb 15 " complete"?
16 Q Did they produce a completed version of 17 the sequence of events?
)
18 A I believe they did.
19 Q Did you see it before it was in its final l 20 form?
l i 21 A Only during the occasions that we were i
l 22 discussing it while it was under development.
23 Q I guess my question is did you see a draft r
( 24 of the sequence of events under circumstances where l
25 you were shown the draft and given an opportunity to l
l s
I -_
I 1 Frederick 16 .
I v
2 comment on it?
3 A No.
4 Q Did you see any, draft of the final sequence k 5 of events before it became final?
6 A No.
7 Q So do I understand correctly that the first 8 time you saw a written sequence of events produced by 9 the Essex Corporation, it was the final version?
10 MR. SELTZER: I object. That is contrary 11 to his earlier testimony.
'12 MR. FISKE: I am trying to find out. If 13 that is contrary, then tell me why.
14 MR. SELTZER: He said they had shown him 15 something that they were drafting at the 16 interview sessions.
17 MR. FISKE: Then he just said a minute 18 ago that he didn't see any written version of it 19 before the final.
20 MR. SELTZER: No, he said they didn't ask 21 him to comment on it.
22 MR. FISKE: Would you go back so we are 23 not confusing Mr. Frederick. Would y,pu read back
(~N
(_) 24 the last question and answer.
[
l l
25 (Record was read back.)
I 1 Frederick 17 p
U 2 A I don't recall reviewing their sequence of -
3 events after it was completed.
4 Q I am not sure I understand the last answer.
h 5 Are you saying that you never even saw the final 6 version?
7 A I don't recall seeing it, no.
8 Q Do you know for a fact that there is a
. 9 final version?
10 A No, I do not.
11 Q Are there any other individuals to whom you 12 have provided information about the accident in response h
x/ 13 to questions other than the ones that you have 14 identified up to now?
15 A I don't recall any other groups at this 16 time. I don't want to imply that the list that you 17 have given me is total and complete without having 18 checked some of my records and testimony files.
19 Q Did you participate in discussions within 20 the GPU organization leading to the construction of 21 a sequence of events that eventually became the LER G .
l 22 that was filed with the NRC7 23 MR. SELTZER: Objection. No foundation
('^N q,] 24 l that this witness knows what the basis was for 25 the preparation of the sequence of events in the
l l 1 Frederick 18 O
V 2 LER.
3 Q Do you understand the question?
4 A Yes.
5 Q Can you answer?
6 A The question actually had two parts, as 7 I understand it. Did I participate in discussions and 8 were those discussions used in the development of the
, g LER.
10 Q If you want to break it down that way, 11 that is fine.
c12 A As I said, I did discuss with members of 13 the GPU staff and the Met Ed staff, but how those 14 discussions and testimony were used in the development 15 of the LER, I an unaware.
16 Q Have you seen the LER that was filed by 17 GPU with the NRC for the Three Mile Island accident?
18 It was filed, I believe, in September 1980.
19 A Yes.
20 (Discussion off the record between the 21 witness and his counsel.)
22 Q Did you see any drafts of that LER before 23 it was filed?
O V 24 A No.
25 Q Did you see any drafts of any sequence of
I 1 Frederick 19 (D /
\
2 events of the accident which you understood was being 3 Prepared by GPU for the purpose of filing with the 4 NRC7 h 5 A I don't recall having seen it.
6 Q Other than the discussions that you had 7 with the Essex Corporation,and I am putting those 8 aside, did you ever see any draft of any sequence of
. 9 events of the Three Mile Island accident?
10 I will change that question without the 11 qualifying phrase at the beginning. Let me just ask 12 you simply, did you at any time see any draft of a 13 sequence of events of ~ the events during the accident?
14 A Yes.
15 Q Under what circumstances?
16 A I don't recall the circumstances.
17 Q Who showed it to you?
18 A I don't remember that either.
19 Q Did you ever discuss any written draft of 20 the sequence of events of the accident in a group which 21 contained, in addition to yourself, other control room 22 operators who had been on duty during the accident?
23 A Yes.
l [)
\_
24 Q Was there more than one such discussion?
25 A I only remember one at this time.
l
h 1 Frederick 20 A
'0 2 Q Where did that discussion take place?
3 A That was a session led by an NRC I&E Group 4 at the Skyways Motel in Harrisburg.
5 Q Was there a tape recording made of that 6 interview?
7 A Yes.
8 Q Putting that aside, I am talking now of --
9 I am asking you now whether you had a discussion about 10 a written -- I am asking you whether you had a 11 discussion concerning a written sequence of events in
.12 draft form,which discussion was participated in by not O
\._ / 13 only yourself but other operators that were on duty 14 on the day of the accident? .
15 A No, I don't recall any specific times where 16 a review of that nature took place.
h .
17 Q You don't remember a time where the group 18 of you that were on duty during the accident were 19 sitting around discussing with others at GPU a proposed
- 20 draft of the sequence of events?
21 A, No.
22 Q Let me ask you specifically, do you 23 remember attending any meetings of the TMI-2 PORC in
'~h about the middle of May 1979 concerning an annotated (d 24 25 sequence of events?
c - -_-- - _
I 1 Frederick 20A O 2 A I don't recall attending a meeting of that 3 sort.
4 (Ccntinued on the following page.)
5 6
7 8
- 9 10 11
~'12 O 13 .
14 15 16 17 18 19 20 g 21 22 23 24 25
1 Frederick 23 O
~
2 Q Let me show you a document which we will 3 mark as B&W Exhibit 645, which is a letter writ' ten by 4 you to Mr. Paul Collins at the Nuclear Regulatory 5 Commission on July 5, 1977.
)
6 (Letter from Mr. Frederick to Mr. Paul l l
7 Collins at the Nuclear Regulatory Commission 8 dated July 5, 1977, was marked as B&W Exhibit 9 645 for identification, as of this date.)
10 Q Have you had a chance to look at this 11 document?
l 12 A Yes, I have read it briefly.
O i \- 13 Q This is a letter you wrote to the Nuclear 14 Regulatory Commission in support of your application 15 for a reactor operator's license examination; isn't 16 that correct?
17 A This is a letter that was composed for 18 my signature.
19 Q Who composed it?
20 A The administrator in the training department.
G 21 Q You reviewed it and were satisfied that it 22 was accurate, correct?
23 A Yes.
[)
G 24 Q Including the enclosure?
25 A Yes.
y Frederick 22
\- As I understand the section 2 of your 2 Q 3 letter to Mr. Collins, you graduated from Passaic 4 High School in 19677 5 A Yes, 6 Q And you spent a year at Paterson State 7 Teachers College after that?
8 A Yes.
, 9 Q And then you joined the navy?
10 A I joined the navy in March 1968.
11 Q In the second page of the letter describing
.12 your experience in the U. S. Navy, the first duties b
(_/ 13 aboard the USS SAM RAYBURN --
14 Do you see that?
15 A Yes.
16 Q -- can you tell us what the USS SAM 17 RAYBURN was?
18 A The USS SAM RAYBURN is a United States 19 Navy submarine.
20 Q A nuclear powered submarine, I take it?
A Yes.
gg 21 22 Q This says that your duties included 23 testing and initial start-up at the 53G core.
(~ 24 A S3G.
Q}.
25 Q What does that refer to?
1 Frederick 23 (xs 2 A That is the designator given to the type 3 of reactor core loading on that vessel.
4 Q Was that a pressurized reactor?
5 A Pressurized water reactor, yes.
6 Q Before you went aboard ship, did you 7 have training on a pressurized water reactor?
8 A Yes.
9 Q Where was that training conducted?
10 A Bainbridge, Maryland, and Windsor, 11 Connecticut.
'12 Q What did that training consist of?
O'~' 13 A Studies in science and mathematics and 14 practical training.
15 Q Were there reactors at either of those 16 places, Windsor or Bainbridge, training reactors?
17 A There is a prototype or training reactor 18 located at Windsor, Connecticut.
l 19 Q Did you have responsibilities aboard the l 20 RAYBURN for actually operating the reactor as opposed g 21 to testing it and initial start-up?
22 A No, the testing and initial start-up here l
23 refers to the entire plant, not just the reactor. Not
()
[h 1
24 just the core.
25 Q So you had the responsibility for testing
1 Frederick 24 O
2 and initial start-up of the entire plant, correct?
3 A specifically, I worked as an electrical 4 operator and was concerned with that portion of the 5 plant.
6 Q Is what you are saying that even in the 7 testing and initial start-up, your duties were as 8 an electrical operator and maintenance supervisor?
. 9 A Yes.
10 Q Just to put it in its simplest terms, 11 did you ever operate the reactor itself?
12 A No.
m
.- 13 Q If this is a comparison that is meaningful, 14 did you perform functions when you were on board the 15 RAYBURN which were comparable to functions performed 16 by an auxiliary operator at Met Ed?
17 A Some of the duties performed by me on the 18 RAYBURN would be similar to those performed as an 19 auxiliary operator.
20 Q That would be to the extent that an g 21 auxiliary operator at Met Ed has responsibility for 22 maintenance or electrical operation; is that correct?
l 23 A The auxiliary operator at Met Ed has no Q
kJ 24 responsibility for maintenance, just operating 25 equipment.
1
1 Frederick 25 l
V 2 Q You left the navy in 1973 and joined 3 Met Ed?
4 A Yes.
5 Q What was your rank in the navy when you 6 left?
7 A E5.
8 Q Is it correct that during the period 1968 9 to 1973 there was a program in effect in the navy 10 whereby someone could start on a course of study 11 which would lead to becoming a navy control room
-12 operator?
O
'- 13 A What was the time period again?
14 Q At the time you were there. There was a 15 designated path that you could start down, at the 16 end of the line becoming a control room operator.
17 A You are particularly referring to me 18 that there was a course I could have taken?
~
19 Q No. There was such a program in 20 existence during that period of time? Some people 21 that went into the navy embarked on a program course 9
22 of study which was designed to at the end qualify them 23 to be a control room operator.
gs 3
xs ) 24 MR. SELTZER: By " control room operator,"
25 do you mean holding an AEC or NRC license?
1 Frederick 26
()
'%)
2 MR. FISKE: Sufficient to operate the 3 reactor on the submarine.
4 MR. SELTZER: I am not sure you need an 5 NRC or an AEC license to operate a reactor on 6 a submarine.
7 MR. FISKE: That's why I didn't tie it to 8 a license.
9 Q Putting it in simplest terms, the navy 10 has nuclear submarines. Submarines are operated by 11 people that run the submarine, whether they have a
'12 license or not. I am simply asking, isn't it a fact O 13 that during this period of time there was a program 14 in the navy where people who joined the navy could 15 start out on a course of study that would lead them 16 to become qualified to operate the nuclear reactor 17 on a submarine. !
. 18 A The course that you may be describing is ;
19 the end point for certain personnel v4 to be 20 qualified as a reactor operator aboard an individual 21 submarine as opposed to all submarines.
gg It was not 22 an elective type course. You were chosen for that 23 early on in your naval career.
( 24 g were you, Mr. Frederick, chosen for that 25 program on the SAM RAYBURN?
1 Frederick 27 (x
i
's 2 A No.
3 Q I think a minute ago we had just finished 4 your navy career and we were starting at Met Ed.
5 That was in November 1973, according to your letter 6 to Mr. Collins.
7 A Yes.
8 Q Again referring to your letter, paragraph 2 9 on page 2, it says, "My experience as an auxiliary 10 operator for A-Nuclear included studying systems 11 and writing operating proceduras and alarm responses.
J12 I also operated systems and equipment for plant 13 start-up and acceptance testing and performed switching 14 and tagging."
15 Then I would refer to the next page, 16 which is enclosure 1, item 1, which is captioned 17 " Auxiliary Operator A-Nuclear Training Program, 18 March 1974 to August 1974."
19 Do you see that?
20 A Yes.
21 Q Do the items listed under paragraph 1 set 22 forth the training that you received as an auxiliary 23 operator?
m
() 24 A I think that is pretty accurate. Rather ,
25 than saying item 1 includes all the training I had l
l l _ -
1 Frederick 28 T'
N.]T 2 received, we have to include this paragraph you read 3 a moment ago, part 2. It would require a bit more 4 clarification to make it more accurate, I think.
5 Q Taking paragraph 2 in the letter plus 6 item 1 in the enclosure, do those two together 7 describe the training that you received as an auxiliary 8 operator?
9 A Again, this paragraph under section 2, it 10 is~not exactly a clear representation of the 11 peripheral duties that I had other than this classroom 12 type training.
O
\2 13 Q Just so we can move ahead, as I understand 14 it, paragraph 1 in the enclosure describes that 15 classroom training that you received; is that correct?
16 A Exc ept item J was in-plant training.
17 Q Your testimony is that in addition to the 18 classroom training and in addition to what is listed 19 in item J, you did some other things?
20 A It says here that we were studying systems.
21 That would be covered under item J, revising operating gg 22 procedures, and alarm responses. What I did was make 23 revisions to draft procedures, and as the systems were f
) 24 installed, we would walk them through to see if they 25 were applicable. Operating systems and plant equipment
1 1
1 Frederick 29 l (s~3 4
2 ,
for start-up was often done under the instruction of 3 engineers during the turnover of plant equipment, 4 performing acceptance tests, again as an entirely G 5 independent action.
6 Q Going back to enclosure 1, there are 7 10 different paragraphs there; is that correct?
8 A Yes.
9 Q Item 2 is captioned " Unit 2 Control Room 10 Operators' Training." That begins in August 1975 and 11 continued through November 1975; is that correct?
'12 MR. SELTZER: You are just asking him to O 13 verify that that is what the document says?
14 MR. FISKE: Yes.
15 MR. SELTZER: We will stipulate to that.
16 Q Is it correct that everything from 17 paragraph 2 to the end of this encicsure refers to 18 control room operators' training?
19 A Yes.
20 Q one thing that is not completely clear g 21 to me, when you talk about auxiliary operator training 22 programs and then you also talk about control room e a 23 I operator training programs, is there a program that
() 24 you start out with in order to become an auxiliary 25 operator and then once you become an auxiliary
1 Frederick 30 b)
\,_
2 operator, you then enter control room operator 3 training, or do you start out right from the beginning 4 as an auxiliary operator and are trained as an 5 auxiliary operator right from the beginning?
6 NR. SELTZER: Objection. That is a 7 compound question.
8 MR. FISKE: I am just trying to find out I am sure it is c o m'p o un d .
9 which of those two.
10 I am trying to find out which of those two 11 works.
~
-12 MR. SELTZER: Can you ask him one
['~
13 question. I don't understand the question.
14 MR. FISKE: Let's put it in terms of 15 Mr. Frederick's experience.
16 Q Item 1 under enclosure 1, March 1974 17 through August 1974, auxiliary operator A-Nuclear 18 training program. Were you in fact an auxiliary 19 operator while you went through that program?
20 A Yes, ggg 21 Q You start March 4th as an auxiliary l 22 operator and when it is all over on August 1974 you i
23 are still an auxiliary operator?
I I^'
l (,j\ 24 A Yes.
l l 25 Q At what point in time do you become a
1 Frederick 32 U("N 2 " control room operator" for the purpose of the headings 3 that are used in this outline?
4 A The progression from auxiliary operator A 5 to control room operator is not a mandatory 6 progression. It is a matter of a job being available 7 in that category, control room operator, and then 8 requesting to fill that vacancy.
9 Q But within the terminology, you can be 10 trained at Met Ed as a control room operator even 11 though you have not yet been licensed by the NRC7 J12 A After having taken the control room 13 operator's j ob, you can then be trained.
14 Q So, in other words, during the period 15 August 1975 through November 1975, which is item 2 on 16 this enclosure, you were going through a Unit 2 17 control room operator's training program, correct, 18 even though you had not yet been licensed?
19 A Yes.
20 Q Is it correct that all of the training that gg) 21 is listed on this enclosure was training that you l
22 had completed prior to the time that you applied to 23 take the application for a license?
h) w./
24 MR. SELTZER: Applied to take the 25 application?
l
l 4
l l
1 Frederick t 32 (3
2 Q Applied for an application for an 3 operator's license examination.
4 A This letter is an application for a 5 reactor operator license examination that was sent 6 in 1977. The courses listed here were either 7 completed or in progress at the time of the application.
8 Q Item 4 on enclosure 1 refers to the Unit 2
, 9 cold license simulator certification training, 10 April 5, 1976 to July 8, 1976.
11 MR. SELTZER: It says July 9th on my 12 copy.
s_ 13 MR. FISKE: I am sorry. July 9th.
14 Q Do you see that?
15 A Yes.
16 Q That refers to an eight-week course 17 conducted by Babcock & Wilcox at Lynchburg?
18 A Yes.
19 Q ' Item 9 refers to a simulator training .
l 20 program, June 6, 1977 to June 10, 1977, which is I ,
i l
21 referred to as a one-week course at Lynchburg, 22 Virginia.
23 Do you see that?
hv 24 A Yes.
25 Q Did you have any training at Lynchburg,
l 1 Frederick 33 j O
V 2 Virginia at any time after June 1977 before the 3 Three Mile Island accident?
4 Putting it simply, was the last time that 5 you were at the simulator before the Three Mile 6 Island accident the week of June 6th to June 10, 19777 7 A I don't recall. I made several trips to a the simulator. Other than the fact that the dates 9 of them are written here, I don't recall when they were 10 or if there was an additional one after this 11 application was sent.
-12 Q You did in fact receive a license, did (l
13 you not?
14 A Yes.
15 Q And you received that license sometime 16 in 19777 17 A Yes.
18 Q My question is at any time after you 19 received that license, did you ever go back to 20 Lynchburg, Virginia for training on the simulator 21 at any time before the Three Mile Island accident?
gg 22 A Again, I don't remember if there was an 23 additional trip in there or not, r
l ID 24 Q Is that a subject that you thought about "V
25 before you came here today, whether you had any
1 Frederick 34 O
\_J 2 simulator training at BC: at ar.y time after you ,
3 received your operator's ~1icense in 19777 4 MR. SELTZER: Did he ever thidt about 5 that?
6 Q In thinking about the testimony that you 7 were going to be asked to give in this deposition, did 8 you think about the question of whether or not before g the accident you had any simulator training at B&W 10 at any time after June of 19777 11 A No, I don't recall trying to remember J12 the dates that I was down there, no.
r)\
t 13 Q So before you came here today, you have 14 not made any effort to try to determine that?
15 MR. SELTZER: You mean in the course of 16 his getting ready to testify?
17 MR. FISKE: Yes.
18 A No.
19 MR. FISKE: Let me show you two documents, 20 one, which we will mark as B&W 646 consisting ggg 21 of two pages, and the other consisting of 22 several pages which will be marked as B&W E47.
23 (Two-page document was marked as B&W
( 24 Exhibit 646 for identification, as of thic 25 date.)
l 1 Frederick 35 O
V 2 (Document consisting of several pages was 3 marked as B&W Exhibit 647 for identification, 4 as of this date.)
k 5 MR. SELTZER: B&W 647 seems to be 6 somebody's assemblage of pages from different 7 documents stapled together. It creates a 8 rather confusing panache.
9 Can you explain what the origin of these 10 pages is?
11 MR. FISKE: The copy that I gave Mr.
12 Frederick was not stapled together. They were O
13 held together by a paper clip. What I was 14 going to ask Mr. Frederick to do is go through 15 the different pages and ask if he can identify 16 any of them. I am not representing to Mr.
17 Frederick that those pages necessarily were all 18 stapled together in any one place or any one 19 time.
20 MR. SELTZER: In fact, they weren't.
gg 21 The numbers are not consecutive. The 22 appearance of the photocopying shows holes at 23 the top on some and holes on the side on the b)
V 24 others.
25 MR. FISKE: So these were not from one i
1 Frederick 36 v
)
2 document.
3 MR. FISKE: I said that. I said what I 4 would like Mr. Frederick to do is ask him whether 5 he can identify any of those pages. I was going 6 to refer to certain material on there and ask 7 him whether or not he could identify the 8 particular document itself.
. 9 MR. SELTZER: Could you indicate what the 10 origin of these documents is, starting with 646 11 which bears no document production numbers on it?
'12 MR. FISKE: I am not even sure myself.
13 MR. SELTZER: Do any of your associates or 14 tssistants know where it came from?
15 MR. WURTZ: I an informed that Exhibit 646 16 comes from the materials provided at Kaye, 17 Scholer on April 14, and we got a Xerox copy hefw-18 w)eh the stamping process or the microfilming 19 process occurred.
20 BY MR. FISKE:
g 21 Q Let me show you a document which we will 22 mark as Exhibit 646-A which is a collection of a number 23 of pages all stapled together, all of which were O)
( 24 produced by your counsel to us on April 14th, and the 25 documents that are part cf Exhibit 646 as well as
1 Frederick 37
/^N NJ 2 the documents that we previously marked as 645 are 3 all part of this collection that was produced stapled 4 together by your counsel.
5 (Collection of documents was marked I
6 as B&W Exhibit 646-A for identification, as 7 of this date.)
8 MR. FISKE: If it helps you to analyze 9 Exhibit 646 by looking at 646-A, you are free l 10 to do so.
11 Q Referring to Exhibit 646, have you ever s J12 seen that document before? I 13 A I have seen documents similar to this one, 14 but I don't recall specifically reviewing this one.
15 Q After you completed the simulator training 16 course at B&W in 1976, did you receive from B&W 17 at some point a list of the evolutions and emergencies 18 in which you had participated and the number of times 19 they were performed?
20 A No.
ggg 21 Q Did you ever see at any time after you 22 completed the simulator training any kind of a record 23 of which particular transients had been simulated
(~h
(_,/ 24 while you were there? Let me withdraw that.
25 Did you at any time after you finished
1 Frederick 38 2 the simulator training receive any written statement 3 f which particular simulated transients you had 4 been trained on?
5 A No.
6 Q Directing your attention to Exhibit 647 7 which is a collection of pages that you have before 8 you, have you had a chance to look through those?
, 9 A Yes.
10 Q Have you ever seen any of those pages 11 before?
-12 A Yes.
13 Q Can you tell us which ones?
14 A There is a sheet in the packet entitled 15 " Simulator Evaluation" which has my name on it, 16 handwritten.
17 Q "Ed Frederick" up in the right-hand corner?
i 18 A Yes.
19 Q Does the number 23083 appear on the 20 bottom?
21 A It appears to be 25083.
! 22 Q It is a document containing handwriting; 23 is that correct?
( 24 MR. SELTZER: That is what he said.
25 Q That is your handwriting?
1 Frederick 39
/s U A 2 Yes.
3 Q Is there any handwriting on that page 4 that is not yours?
5 A There doesn't appear to be.
6 Q can you tell us when you prepared that 7 document?
8 A There is no date on it.
. 9 Q Do you remember whether it was after your 10 first trip to the simulator or your second trip?
11 MR. SELTZER: Objection, no foundation J12 that it has to be one of those two. He said he O
O 13 can't recall whether he had gone more than two 14 times.
15 A I only would be guessing to tell you when 16 I wrote this.
17 MR. FISKE: Why don't we mark that 18 particular page as Exhibit 648.
19 (Document in handwriting of Mr. Frederick l 20 was marked as B&W Exhibit 648 for identification, 21 as of this date.)
ggg 22 Q Are there any other pages in 647 that you 23 recognize?
l s l
(J' 24 A Again, your question is have I ever seen 25 it or do I recognize it? I have seen sheets like this
1 Frederick 40 bD 2 one that say " Plant Operations Training Classroom 3 Schedule," " Control Room Schedule." I have seen 4 schedules like that in the past, but whether or not 5 I have reviewed this particular schedule, I don't 6 remember.
7 Q Any other document in that exhibit that 8 you can identify?
9 A This simulator training summary sheet 10 which is also a part of this group appears to be very 11 similar to the document that you marked 646. Since 7- 12 I said I had seen others like 646, this would be NJ 13 included in that group, I would think.
14 Q Were you aware that at some time in 15 1977-1978-1979, in that time period, a decision was 16 made by Met Ed to send licensed operators to the 17 simulator for training only once every two years 18 instead of every year as had been the practice before?
19 A Just as you mentioned, I do remember that 20 being discussed, but I don't know that it was g 21 initiated.
22 Q Is it your testimony that you don't know 23 whether or not such a decision was made?
t
l
(,)8 24 A I think my testimony is that I recall that 25 decision pending, but I don't know what the outcome l
1 Frederick 41 2 was.
3 Q Is it your testimony that you understood 4 that that question was being considered but that 5 no decision had been made by the time of the 6 accident?
7 A I am not aware that any decision was made.
8 At least, I don't recall it at this time.
9 Q Did you ever express an opinion to anyone 10 in the training department that they should not make 11 such a decision?
'12 A I don't recall making that type of G
V 13 suggestion, no.
14 (Recess taken.)
15 Q Before you actually took the NRC 16 examination to become a licensed control room 17 operator, was there a program at Met Ed where an 18 organization called General Physics came in and 19 conducted oral examinations of the candidates for an 20 operator's license?
l g 21 A Yes.,
22 Q Did you in fact have such an oral 23 examination yourself by representatives of General 24 Physics in the summer of 19777 25 A I had an oral examination by General l
1 Frederick 42 v
2 Physics Corporation. I don't remember the date.
3' Q But it was shortly before you were scheduled 4 to take your NRC examination, was it not?
5 A I remember it being several months, four 6 or five months prior to the examination date.
7 Q Wasn't one of the purposes of this 8 program to be able to determine in advance whether the 9 people who were candidates for the NRC examination 10 would be likely to pass the exam?
11 A It is my understanding that the purpose
<12 of the examination was to discover areas in each O'-~ 13 examinee which would require further study prior to 14 the examination date to concentrate our studies in 15 our weak areas rather than be unaware of them until 16 the exam date.
17 Q And this General Physics exam program was 18 given to all of the people who were at that time 19 considered to be candidates nearing the point where 20 they would be taking their NRC exam?
21 A It was my impression at the time that gg ,
22 everyone who was going to be examined by the NRC had 23 a General Physics exam as well, but I don't know that l
i
( 24 that was the case.
l 25 9 At the time they gave the examination to
l l
l 1 Frederick 43
[
l \vi l 2 you, they were also giving it to a number of other 3 people, were they not?
4 A Yes.
5 Q Did you receive a report from General 6 Physics on the results of that examination?
7 A When the examiner completed the oral 8 examination, he spoke with me about his impressions, 9 but I did not receive a report on the examination.
10 Q Did you learn at any time after you had 11 taken the examination that you had received a grade 12 [fmarginal fail '
t 1 V
M A' Yes.
14 Q Did you ever see any written report that 15 was prepared by General Physics for Met Ed concerning 16 the results of this examination program that they 17 administered in 1977?
18 A Other than the time I mentioned when the 19 oral examiner reviewed his notes with me, I don't 20 recall seeing another report besides that, ggg 21 Q Let me show you a document which will be 22 marked as 649.
23 (Document was marked as B&W Exhibit
(~h.
(_) 24 649 for identification, as of this date.)
25 Q I just ask you whether you ever saw a copy D' A
1 Frederick 44
/T Y
2 of that document in 1977.
3 MR. SELTZER: Is this another part of a 4 document rather than being a complete document?
. 5 MR. WURTZ: It is part of a document.
6 I believe it is complete as far as what it is.
7 MR. SELTZER: For example, the last page 8 of what you handed us ends with "A specific 9 comment is included with each operator." I I
10 don't see any specific comments for any operators 11 here, c12 MR. FISKE: Let me show you two additional Os 13 pages which bear the heading "OralEudit 14 Examination Results, Applicant E. R. Frederick, 15 Examiner, A. Mangine." I will add those 16 two pages to the document that has been marked.
17 If he can answer the question of whether 18 or not he has seen the document that is in front 19 of him, we will move on to the next subject 20 and at a recess we can get you the complete 21 document from which this is taken.
i 22 MR. SELTZER: In other words, from the 1 23 fragments that he has handed you, do you
(("',)
l l 24 recognize any of these fragments? They have not 25 given you the whole document.
l l
I
1 Frederick 46 2 recall seeing a copy of the report that General 3 Physics made to Met Ed concerning this testing program 4 other than the portion of the report which contained h 5 the comments on your own oral exam, and as to that, 6 you are not sure whether you saw the page or whether 7 you simply received oral comments to the effect of 8 what is on the page. If that is your testimony, we can
. 9 move on.
10 A I think that is substantively correct.
11 Q Let me show you the next exhibit, which 12 we will mark as B&W 650, which is a memorandum fron 13 Mr. Tsaggaris td Mr. Lawyer, dated July 18, 1977, 14 subject, " General Physics Audit Exam Results."
15 (Memorandum from Mr. Tsaggaris tc Mr.
16 Lawyer, dated July 18, 1977, subject, " General
.s 17 Physics Audit Exam Results," was, marked as -
18 B&W Exhibit 650 for identification, as of this 19 date.)
20 Q Do you have B&W 650 in front of you?
21 A Yes.
9 22 Q In July 1977, what position did Mr. Tsaggaris 23 hold at GPU?
24 A I don't know what his position or title V(~~T 25 was.
1 Frederick 45 A
U 2 A I don't recall seeing any of these letters 3 or lists or parts of the documents other than the 4 last two pages that you gave me entitled " Oral 5 Audit Examination Results" with my name at the top 6 of the page.
7 Q You did receive that?
8 A I don't remember specifically seeing this 9 results sheet, but I do remember these comments, 10 whether they were read to me or I saw the sheet.
11 .MR. WURTZ: We have here also the
>12 complete document as produced by BPU containing 73 b 13 the evaluations of the other operators, if you 14 are interested in looking at that.
15 , MR . FISKE: I believe that what was produced 16 to you, Mr. Frederick, was the complete document 17 other than individual comments on operators 18 other than yourself. But if you would like to 19 look at the rest of the document consisting of 20 the comments relating to the other operators, gg 21 you are free to do so.
22 THE WITNESS: Are you asking me to state l
23 whether I have seen this portion of it or
\
(. I
\_) 24 that portion of it?
25 Q As I understand your testimony, you do not 1
I l
1 Frederick 47 v) 2 Q Did you know Mr. Tsaggaris in 19777 3 A I knew Mr. .Tsaggaris while he.. worked on the 4 Island but pinning down this time frame might be 5 difficult. He worked on the Island for a time and 6 then he moved off the Island. I knew him while he 7 was there.
8 Q What was his position in the summer 9 of 19777 10 A He had several jobs. I don't know what 11 his position was at this time.
J12 Q Was there any point in time when Mr.
O 13 -Tsaggaris has adything to do with train.ing at Med.Ed?
14 A Yes, he did work in the training department.
15 Q But you don't remember now in what capacity?
16 A No.
17 Q Did you know Mr. L. Lawyer in the summer 18 of 19777 19 A I don't recall having met Mr. Lawyer until 20 after I began working in the training department in gg 21 1979. ,
22 Q Had you heard of Mr. Lawyer in the summer 23 of 19777
/~
(_)N 24 A I think so.
25 Q What did you understand his position was?
1 Frederick 48
~' MR. SELTZER: Objection.
2 No foundation 3 that he had an understanding of his position.
4 A I don't recall whether I had an 5 understanding or was aware of his position in the 6 company at that time.
7 Q Directing your attention to the last page 8 on the bottom, there are four individuals referred to
, 9 there. G. P. Miller, J. Floyd, R. Zechman and D.
10 Goodman.
11 Did you know the position that any of those
.12 individuals held in the summer of 19777 13 A R. Zechman worked in the training 14 department and D. Goodman worked in the training 15 department. Jim Floyd and Gary Miller were in the 16 operations department.
17 Q Did you see a copy of this document in 18 the summer of 19777 19 A I don't recall having seen this document 20 at all.
21 Q I think you said earlier that after the gg 22 Three Mile Island accident in or about June 19, 1979, 23 you became administrator, technical training, for
[~*) 24 Unit 2 --
's_/
25 A Yes.
1 Frederick 49 2 Q --
and as such, you then became part of the 3 Met Ed training department, correct --
4 A Yes.
5 Q --with responsibility for training others?
6 A Yes.
7 Q Let me show you a document that we will 8 mark as Exhibit 651.
. 3 (Memorandum from Mr. Frederick to Mr.
10 Zechman, dated September 7, 1979, was marked 11 as B&W Exhibit 651 for identification, as of 12 this date.)
N/ 13 Q Do you have that document in front of you?
14 A Yes.
15 Q Is that a memorandum that you wrote --
16 A Yes.
17 Q -- on or about September 7, 19797 18 A Yes.
19 Q And that was to Mr. Zechman?
20 A Yes, 21 Q What was his position at that time?
22 A He was a supervisor in the training 23 department.
[%.)') 24 Q Do you still have in front of you a copy l 25 of your letter to Mr. Collins and the enclosure which l
1 Frederick 50 (d 2 summarizes your training?
3 A Yes.
4 Q Part of the training that is listed i'n 5 paragraph 3 of enclosure 1 is reactor theory. Do 6 you see that?
7 A Yes.
8 Q Did you receive training at Met Ed on
. 9 reactor theory?
10 A Yes.
11 Q Did you in the course of that training 12 that you received at Met Ed learn, if you didn't know T
s/ 13 before, how it is that a pressurized water reactor 14 works?
15 MR. SELTZER: I object. That is a 16 compound question, since it is asking whether 17 he had previously learned it, and if he 18 had not previously learned it, did he learn 19 1.t then.
20 (Ccntinued on the next page.)
21 43, 22 23
(~',)
w 24 25
d
/1 1 Frederick 51 O
( I k/ 2 Q By the time you finished the training 3 program that is listed in paragraph 3 of enclosure 1, 4 did you understand how a pressurized water reactor llh 5 works?
6 MR. SELTZER: My guess is there are 7 professors at MIT who teach nuclear physics who 8 don't understand how everything in a nuclear g reactor works.
10 Maybe you want to be precise what elements 11 of PWR technology you are referring to.
.12 Q Do you have trouble with the question?
13 A Yes.
14 Q Did you understand that the purpose of 15 the power generating equipment on which you were being 16 trained was to generate electricity?
17 A Are you still asking about my impressions 18 in this cold license training program?
19 Q No. Mr. Seltzer made an objection to an 20 earlier question, so I rephrased it and I will put it 21 again so there is no question about it.
22 I am talking now,just for the purposes of 23 simplicity in putting this question, about the period
(~ 24 of time after which you had completed the training V) 25 program which is referred to in paragraph 3 of enclosure
1 Frederick 52 2 1 which includes the course on reactor theory. That 3 is the point in time I am asking about for the moment.
4 I am asking you whether at that point in 5 time you understood that the purpose of the unit which 6 you were studying to become licensed to operate was 7 to generate electricity?
8 A I understood at that time that one of the
, 9 goals and part of the purpose of that station was to 10 produce electrical power for the consumer.
11 Q Did you understand that the electrical 12 power was generated by a turbine?
C\
\- 13 MR. SELTZER: As opposed to a generator?
14 A As best I can recall, I think my 15 understanding of the unit would have included the 16 basic understanding that the turbine was involved in 17 the process which produced electricity.
18 Q Did you understand that steam was generated 19 which drove the turbine in order to produce electricity?
20 A Yes.
21 Q Did you understand that that steam was 22 produced by hot water which circulated through pipes 23 into a steam generator which contained water and in the
(; 24 process turned that water into steam?
25 A At this point, I was aware that that is how
1 Frederick 53 b)
\/
2 the Navy-type systems worked. The purpose of this 3 course we were discussing was to give me an introduction 4 to how the commercial plant worked.
k 5 Q Did you understand that that is the way 6 it worked also at THI-27 7 A I don't recall what my understanding was 8 about this particular steam generator at that time.
, 9 It would certainly be colored by my understanding 10 today, and separating the two might be difficult.
11 Q Let's make it real simple. Let's take 12 it to the period of time --
13 (Discussion off the record between the 14 witness and his counsel.)
15 A Let's take it up to the period of time 16 when you were applying for your license, when you were 17 about to take the exam. At that time, did you 18 understand that the way steam was generated at TMI 19 Unit 2 was by hot water that circulated through pipes 20 in the steam generator and turned the water in the 21 steam generator into steam?
22 MR. SELTZER: Yo2 are talking about 23 secondary side water, feedwater?
24 MR. FISKE: Read the question back.
(")S
\m 25 (Record was read back.)
l l
1 Frederick 54 r O)
(_ 2 Q If you have a problem with that question, 3 let me know.
4 MR. SELTZER: Why don't you just explain, khk 5 so we can get this over with, how you understood 6 at the time you were getting ready for your 7 license exam, how steam was generated.
8 MR. FISKE: That would be fine.
9 A The reason.I was having a problem with 10 your question is it seems too simplified and not 11 precise in its description of how the steam plant 12 works. The specifies of the operation of the B&W
() 13 steam generator as we learned in the classrocm and 14 simulator training given to us in the B&W program 15 was the water level in the generator is not actually 16 discernible from the point at which it passes through 17 the orifice point at the base of the steam generator.
18 There is no steam generator level.
19 Q I think you are getting ahead of what is 20 a very simple question. It may be at some point in 21 this deposition you might want to inject that kind of 22 testimony in response to a question to which it may be 23 more responsive. J 24 My question couldn't be more simple. We b(~g 25 are talking about the very basic fundamentals of how 1
l
I 1 Frederick 55 t
2 steam is generated in a pressurized water reactor.
3 That is all I am talking about right now. I am not 4 anywhere near as refined as the answer that you just
.5 gave would suggest. We may get to that sometime down 6 the road, but let's start at the simple part of it.
7 MR. SELTZER: Do you want to say something, 8 Mr. Frederick?
, 9 A The confusion I had with your question is 10 you had asked me isn't this how it operates and isn't 11 this what you understood at the time of your licensing 12 exam, and the explanation I gave was a clarification
(
\_-) 13 of what I understood at the time I gave the exam.
14 Q I am just asking about the process of how 15 the water in the steam generator is turned into steam.
16 Isn't it a fact that that process takes place as a 17 result of water that circulates through the steam 18 generator in what is commonly referred to as the 19 reactor coolant system?
20 A No.
21 Q You are familiar with something called a 9
22 reactor coolant system? Does that phrase mean something 23 to you?
) A
('J
'u-24 Yes.
25 Q In simple terms, that consists, does it
l 1 Frederick 56 v
2 not, of a series of pipes through which water flows 3 essentially in a circle or around and around through 4 the same set of pipes?
llh 5 MR. SELTZER: It is not a circle. I object.
6 It is a circuit or a loop.
7 Q A circuit.
8 A No.
, 9 MR. SELTZER: Why don't we, just to get 10 over this, because I think this is taking up more 11 time than it is probably worth to anybody, why
_s '12 don't you just ask Mr. Frederick if he could 13 explain simply but correctly how he understood 14 steam was generated at or about the time he was 15 preparing for his licensing exam?
16 MR. FISKE: ,Let's put it very simply.
17 Q The reactor is referred to as a pressurized 18 water reactor, correct?
19 A For TMI-2, yes, 20 Q Where is the water that is pressurized?
21 A It is in the reactor coolant system.
22 Q During normal operations of the reactor, 23 at what temperature is the water?
/~
(,)T 24 A There are in various places in the system 25 different temperatures.
1 Frederick 57 2 Q The water is heated, is it not?
3 A Under normal operations. The water which 4 is being pumped to the reactor coolant system is heated.
lll 5 Q What heats the water?
1 6 A The water passes by the hot fuel elements i 7 in the reactor vessel.
8 Q And are the hot fuel elements commonly .
9 called the core?
10 A As a group, they are, yes.
11 Q To what temperature is the water heated 12 in normal operations as it passes through the core?
(~
N' 13 A At 100 percent power, it is heated to 14 approximately 608 degrees.
15 Q After it passes through the core and is 16 heated to the 608 degrees Fahrenheit, it is then 17 in what is often referred to as the hot leg of the 18 reactor coolant system, is it not?
19 A After it leaves the reactor vessel, yes.
20 Q And then it proceeds from there and goes l 21 in the same pipes.through the steam generator, does it 22 not? ,
l 23 A When it reaches the steam generator, it b) s/
24 divides into many, many pipes.
1 25 Q And then passes through the steam generator i lI l
l l
l 1 Frederick 58
/'N k-) 2 still enclosed in those pipes?
3 A Yes.
4 Q And in the process of passing through the h 5 steam generator, it turns water in the steam generator 6 into steam, isn't that correct?
7 MR. SELTZER: Different water, right?
8 MR. FISKE: Yes.
. 9 A water on the outside of the tubes, yes.
10 Q In that process, heat is transferred from 11 the pipes in the reactor coolant system to the water 12 in the steam generator vessel, is that not correct?
g 13 A It returns from the steam generator to the 14 reactor vessel? Is that what you said?
15 Q Yes, after having transferred some heat 16 to the water in the steam generator.
17 MR. SELTZER: To the secondary water in 18 the steam generator?
19 MR. FISKE: Yes.
20 A Again, your characterization of fluid on S 21 the opposite side of the tubes is not in conjunction 22 with my understanding of how it occurs, but the water 23 does leave the steam generator and returns to the Ih 24 reactor vessel.
V 25 Q There is water in the stean generator?
ll 1 Frederick 59
/ ~'s I. )
2 Mr. Seltzer refers to it as secondary water. There is 3 secondary water in the steam generator, correct?
4 A You can refer to it as a fluid, but to lh 5 characterize it as water would be incorrect.
6 Q The water in the primary system goes 7 through that fluid in the primary system pipes, 8 transfers heat and turns the fluid in the steam
, 9 generator into steam, correct?
10 A Yes.
11 Q Then when it leaves the steam generator, 12 the primary system water has been cooled down, has it
(')N
(_ , 13 not, below 608 degrees?
14 A The primary water, yes.
15 Q What temperature is it at at that point 16 in normal operations?
17 A Approximately 556 degrees.
18 Now, at this stage, is it in what is Q
19 commonly referred to as the cold leg?
20 A Yes.
21 Q Then it continues through the pipes and 22 goes back through the core and is heated up once again, 23 is it not?
p/
\_
24 A Yes.
25 Q Then in the process of going through the
i 1 Frederick 60
' core, the water is heated back to 608 degrees and at 2
3 the same time the water serves the function of cooling 4 the core, does it not?
h 5 A Yes.
6 Q At atmospheric pressure, water boils at 7 212 degrees, does it not, Fahrenheit?
8 A It is a fair approximation.
, 9 Q What is it that keeps the water in the 10 primary system from boiling?
11 A The majority of the water in the reactor 12 coolant system other than that water which is trapped
(~h (s,) 13 in the pressurizer is not undergoing boiling because 14 it is under a high pressure.
15 Q And at what pressure is that water kept 16 during normal operations?
17 A 2,155 pounds.
18 Q Is it correct that it is the pressurizer 19 which produces the pressure that keeps the water from 20 boiling?
21 A The pressurizer system does that, yes.
22 Q And you understood, did you not, before i
! 23 the Three Mile Island accident that the purpose of
/~ 24 the pressurizer is to keep the water from boiling?
l N~)T 25 A Yas.
i 1 Frederick 61 I !
2 Q Isn't it a fundamental principle of 3 operating a pressurized water reactor that you should 4 keep the water in the primary system from boiling?
I 5 MR. SELTZER: You are asking whether this 6 was a fundamental principle that Mr. Frederick 7 was aware of before the Three Mile Island 8 accident?
. 9 MR. FISKE: Sure.
10 Q Did you understand before the accident 11 that it was a fundamental principle of operating a
-12 pressurizered water reactor that you should keep the
\
Q 13 water in the primary system from boiling?
14 A I think my understanding could be more 15 clearly characterized by stating that it was my 16 understanding that the system was designed so that 17 under normal and emergency conditions, that systen 18 would normally be kept from boiling.
19 Q And that it was a very important principle 1
20 of operating a reactor that the water should not be 21 allowed to boil?
22 MR. SELTZER: He said the system was 23 designed so that under both normal and emergency
(~)%
( 24 conditions it wouldn't boil. I don't understand 25 how your next question is different.
1 Frederick 62 l
(~)
'~
2 MR. FISKE: Maybe it isn't. Maybe you 3 can tell me.
4 Q Didn't you understand prior to the Three I 5 Mile Island accident that it was important under both 6 normal and emergency conditions to keep the water in 7 the reactor coolant system from boiling?
8 MR. SELTZER: You mean important for the 9 operators to keep it from boiling? Is that 10 what the subject of the question is?
11 MR. FISKE: I don't think the question 12 could be much simpler.
f t
x 13 MR. SELTZER: It is an intransitive 14 sentence. Passive voice sentence. I don't 15 know which. I am trying to find out who is 16 the actor in the sentence, what is the actor 17 that is supposed to keep the plant from boiling?
18 Is it the design that should keep it from boiling 19 or the operators that should keep it from boiling?
20 MR. FISKE: Let's make it real simple.
21 Q Did you understand before the accident 9
l l
22 that it was important that during operation and emergency 23 conditions that the water in the reactor coolant 24 system not boil?
25 A Other than brief remarks made in the i
1 Frederick 63 0 2 description of the design and the original safety 3 analysis, and comments made during the initial B&W 4 training and in the refresher training given at Met h 5 Ed, I don't remember that being emphasized as a point 6 of extreme importance.
7 Q Whether it was emphasized by Met Ed or not, 8 the question is just simply, in your understanding
, 9 of the system at the time of the accident, didn't 10 you understand that it was important that in both 11 operations and in emergency conditions that the water
.12 not be allowed to boil?
13 A I have to state that my understanding was 14 that that was a part of the design of the plant, and I 15 don't recall having fixed any greater importance to 16 it than that.
17 Q Did you understand that in operating the 18 plant, one of the things that you were supposed to do 19 in operating it was not to allow it to boil?
20 A My recollection of the limits and 21 precautions and operating procedures and the 22 demonstrations given during my classroom and simulator 23 training was that that was not pointed out as one of 24 my duties.
(
25 Q Are you telling us that you did not
1 Frederick 64 (sf 2 understand as of the day of the accident that one of 3 your responsibilities as ar. operator during operating 4 or emergency conditions was to keep the water in llh 5 the primary system from boiling?
6 A Yes, I have to say that that was in my 7 mind. I understood that to be part of the design 8 of the plant that that would happen in normal and 9 emergency conditions without any operator action.
10 Q Let's make sure I understand that last 11 answer. You understood that the water would boil 12 in the primary system if pressure fell to a certain 13 level, did you not?
14 MR. SELTZER: What are you assuming 15 about temperature and pressure?
16 Q Let's assume if you want to build that 17 into it, you understood that the water would boil if 18 the pressure / temperature ratio reached what was known 19 as saturation point, did you not?
20 MR. SELTZER: What do you mean by 21 " temperature pressure ratio "? As a fraction 22 with temperature on top and pressure on the 23 bottom?
(~} 24 Q Do you have a problem with that?
U 25 A Can you read it back.
1 Frederick 65 Ok/ 2 Q If you have a problem with that, I will 3 put it again.
4 You understood that at any given temperature <
lh 5 in the plant there was a ratio between temperature and 6 pressure at which if pressure came down to a certain 7 point, the water would start to boil?
8 A We are talking about the water?
, 9 Q In the primary system.
10 A The reactor coolant system water?
11 Q Yes.
.12 A No, I don't believe I had that understanding, 13 Q You mean you never understood before the 14 accident that if the temperature of the water in 15 the primary system stayed at the 606, 55E levels that 16 they were at, and the pressure fell below 2155 and 17 continued to fall, that the pressure would reach a point 18 at which the water in the primary system wou3d start 19 to boil?
20 A I guess I am saying that I don't remember 21 having training or understanding of that type of 9
22 transient at which boiling began or some kind of l
l 23 accident or drop in pressure.
("'1 24 Q That wasn't my question. I am asking a
'd 25 question about your understanding of the system in the
1 Frederick 66
\_/ 2 way it works. That is what we have been asking you 3 about for the last 20 or 25 minutes. I think you 4 testified that the water in the primary system is llh 5 heated at temperatures well above the levels at 6 which water boils at sea level and what keeps the 7 water from boiling is the fact that it is under 8 pressure. My question is really a very simple one.
. 9 Didn't you understand as part of your knowledge of 10 the system that if that pressure that kept the water 11 from boiling was not there, the water would boil?
12 A I think in answer to that question, I did
(~)
i have the theoretical knowledge that the pressure is s_) 13 14 what kept the water from boiling, but I don't at 15 this time recall having an understanding which was 16 derived from training or experience which showed me 17 the application of that theory in any of the procedures 18 or evolutions that I had ever seen so that I could 19 anticipate what you are saying would happen.
20 Q In other words, your testimony is nobody l 21 had told you about a specific transient in which that 22 would happen?
23 MR. FISKE: Could you read back the last 24 answer.
V 25 (Record read.)
1 Frederick 67 m
2 A Your saying I was never taught about a 3 specific transient is probably more detailed than I 4 had testified. I don't remember being told of any llh 5 transients in which that would happen.
6 Q Is the term " voiding" commonly used as a 7 term which means formation of steam?
8 A Is it a currently used term?
9 Q Is it a commonly used term when people 10 talk about voiding in the context of water in the 11 reactor coolant system? Is that a term that is 12 commonly used to refer to the formation of steam?
() 13 MR. SELTZER: Are you talking about 14 commonly used to Mr. Frederick's understanding 15 since the accident or before the accident?
16 MR. FISKE: Before the accident.
17 A It was not a commonly used term prior to 18 the accident.
19 Q Have you used the term since the accident?
20 A Yes.
21 Q what does it mean, as you understand it, as 22 it is used since' the accident?
23 A It is the formation of steam in the reactor g- 24 coolant system.
~
25 Q And is it correct that steam formation
1 Frederick 68
/i k/
2 results from boiling? '
3 9 Yes-4 Q Didn't you know before the accident that h 5 it was possible to have voiding, as you have just 6 defined the term, in the core as a result of a loss-7 of-coolant accident?
8 A I recall that prior to the accident in our 9 safety analysis lectures conducted by engineers and 10 ins.tructorn at B&W and generally endorsed at Met 11 Ed, we talked of a scenario in which there was a large 12 break LOCA and the system volume would be evacuated O
( j 13 from the core and there would be steam in the core 14 the,n. But, again, the term " voiding" was not attached 15 to that.
16 Q And the voiding that you referred to or 17 the formation of steam that you referred to is a 18 condition that is caused by a drop in pressure, is it 19 not?
20 A No, by the evacuation of the inventory 21 system through the leak.
9 22 Q With a drop in pressure?
23 MR. SELTZER: Are you asking him for (N, 24 his understanding before the accident whether
\,J' 25 the loss-of-coolant accident with the dropping
1 Fre de ri c': 69 O) t'"
of inventory created a drop in pressure?
2 3 Q Let me just read you some questions and 4 answers from the deposition that you gave to the I 5 Kemeny Commission. I am reading from page 111.
6 The questions and answers are as follows:
7 " Question: I understand. In what context 8 did you understand about voiding in the core?
9 " Answer: I knew that it was possible in 10 a loss-of-coolant accident.
11 " Question: How would that occur? What
.12 would have to occur first?
b)
(> 13 " Answer: Loss of inventory.
14 " Question: O. K., what other conditions?
15 " Answer: Decrease in pressure and high 16 temperature.
17 " Question: Sattration?
18 " Answer: Yes, saturation or above, yes, 19 it is possible to have superheating, too." !
20 Were you asked those questions and did you 21 give those answers?
22 A I don't have a specific recollection of 23 this testimony, but I would concur that I was
(~'\ 24 answering questions in this deposition.
b 25 (Luncheon recess taken at 12:20 p.m.)
1 70 p)
( 2 AFTERNOON SESSION 3 2:00 p.m. I 4 E DWARD E. FRE DE RI C K, resumed.
k 5 EXAMINATION (continued) 6 BY MR. FISKE:
7 Q In the discussion we were having before 8 lunch, I think you had testified that the water that 9 goes through the core in the reactor coolant system 10 Plays a cooling function in the sense that as it goes 11 through the core, it cools the core.
12 MR. SELTZER: I am just indicating to
) 13 him that there is no question pending.
14 Q Is that correct?
15 A I believe I agree with your characterization.
16 Q Did you understand before the accident that 17 if steam formed in the w'ater as it went through the core, 18 that that made the heat removal more difficult?
19 A No. The understanding I had of the most 20 optimum method of heat transfer involved the formation 21 of steam bubbles.
22 Q That is so-called nucleate boiling?
l 23 A Yes.
t I
- 24 Q That indeed occurs during normal operations, i'^,/
25 does it not?
l l
1 Frederick 71 b
U 2 A Yes, in a small fraction of the core.
I 3 Q could you describe this phenomenon known 4 as " nucleate boiling" in as short a description as llh 5 Possible?
6 A Nucleate boiling is the formation of steam 7 bubbles at nucleation sites through the concentration
. 8. of heat flux in a small area.
9' Q And these are very small bubbles, are
' I 10' tney not?
11 .
MR. SELTZER: What do you mean by "very t
12 small"?
O v) 13 MR, FISKE: Smaller than small.
14 '
HR. SELTZEh What diameter?
M Q Let's ask Mr. Frederick to describe to us 16 the size of the steam bubbles.
ss 17 ' A They are bubbles which in relation to the
, .s .
, 28 entire size of the fuel clad surface are small.
19 Q Did you understand that if steam formed
, 20 l. in the. core beyond the normal nucleate boiling 21 that you described, that the formation of that
- 22 additional steam not present in normal operations could
%, 23 ' s make it more difficult to remove heat from the core? i x '
I en '
24 'A Yes.
\ >i
, 25 Q Did you understand that the presence of
- \ s
1 Frederick 72 g
kJ 2 quantities of steam in the core making it more 3 difficult to remove heat from the core could lead to 4 core damage?
.Ih 5 A I understood that the formation of these 6 large amounts of steam could result in difficulty 7 in removing heat and then damage to the fuel 8 elements, yes.
9 MR. FISKE: Let me mark as Exhibit 652 10 l a collection of pages, and mark as Exhibit 653 11 an excerpt from those pages.
12 (Cc11ection of pages was marked as
) 13 B&W Exhibit 652 for identification, as of this ,
14 date.)
15 (Excerpt from pages marked as B&W Exhibit 16 652 was marked as B&W Exhibit 653 for 17 identification, as of this date.)
18 Q I am only going to be asking you about the 19 pages that are marked Exhibit 653. Those page's 20 are part of a larger collection of pages, all of which 21 have been marked in 652, and you are perfectly free 9 22 to look at the entire 652 but I am only going to be 23 asking you about 653.
~
24 MR. SELTZER: Is this from GPU's files v
25 or B&W's files?
l l
l l
1 Frederick 73
(\ 2 MR. WURTZ: From GPU's files. I 3 MR. SELTZER: Do you have the original 4 from which this exhibit was copied so that the llI 5 writing would be legible? On my copy, I can't 6 read the handwriting.
7 MR. FISKE: There is only one part of 8 the handwriting that I am going to ask Mr.
9 Frederick to look at. Maybe we can all. work 10 cur way through it when we get to it.
11 l MR. SCLTZER: We may be able to work our 12 way through that, but there might be a context O)
(, 13 that is created by adjacent portions which are 14 also illegible. I think it would be better to 15 get the most legible copy if we are going to 16 have testimony from this exhibit and give the 17 witness and his counsel the opportunity to read 18 the document before questions are asked.
19 MR. FISKE:
, Just so we can move along, 20 this Exhibit 653, at least as I understand it, 21 consists of a series of separate questions put 22 to Mr. Frederick in an examination and handwritten 23 answers by Mr. Frederick to those questions. l 24 I only intend to ask him about one discrete (U~')
25 question. I have no objection to at some point
l 1 Frederick 74 f\2 2 before the deposition is over to making 3 available the entire original of the exhibit, 4 assuming you still don't have it.
lll 5 MR. SELTZER: I don't have it with me.
1 6 I certainly didn't anticipate that you were 7 going to ask questions on it. Otherwise, I 8 might have tried to bring the original with me.
9 But to be confronted at 2:05 with this document 10 for the first time and be told that "I can't 7
11 read it" I don't think is very satisfactory.
12 MR. FISKE: I think we are blowing this
{
/~N
'q,)
13 a little bit out of proportion. As I said, there
{
l l
14 is one question and one answer consisting of 15 about five lines that I am going to ask Mr.
16 Frederick about, and we are not going to finish 17 this deposition today. If you want to go back 18 and look at the original before this deposition 19 is over, you are certainly free to do it.
20 MR. SELTZER: Why don't you put the 21 question and then we will see if the 22 illegibility so obscures what it is that you 23 are examining on that we can't proceed.
l O 24 BY MR. FISKE:
O 25 Q I am referring to Exhibit 653 and
1 Frederick 75 h
,_/ 2 specifically to the second page of that document 3 which contains a number of separate questions, all of 4 which are typed.
llh 5 Do you see that page? I 6 A Yes.
l l
7 Q What I would like to do is ask my colleague i 8 Mr. Wurtz, whose eyesight is better than mine, to read 9 into the record the typed question that appears at 10 the bottom of that page.
11 MR. WURTZ: This is question B-5, "The l
12 procedure for loss of all reactor coolant pumps
( 13 requires in the immediate actions that emergency 14 feedwater establish natural circulation cooling."
15 Then sub A under that question is, 16 " Explain emergency feed to OTSG's on loss of 17 all RCP's."
18 Then sub B is, "Why is natural circulation 19 required?"
20 Q Then I would like to direct your attention j 21 to the last page of this document. There is some 22 handwriting at the top of the page.
23 Do you have that in front of you?
i p 24 A Yes.
O 25 Q Do you recognize that handwriting?
1 l Frederick 76 l o
A
- 2 It is most difficult by the copy to verify 3 that it is mine. I suspect that it is mine but it 4 doesn't look like the other sample that you showed me ll) 5 is. -
l 6 Q why don't you go back and look at the page 7 immediately before the one I just showed you. That 8 is an entire page of handwriting, is it not?
9 A Yes.
10 Q Is that your handwriting?
11 A Yes, I think it is.
12 Q Having identified your handwrit 3ng on the
() 13 page immediately preceding, can you now lock at the 14 last page of the document again and tell us whether 15 that is your handwriting?
16 A It looks to be similar to the handwriting 17 on the previous page. A' gain, I would think that was 18 probably mine.
19 Q I will give you an opportunity, if you like, 20 Mr. Frederick, to read that into the record or if you 21 prefer, we can ask Mr. Wurtz to do it.
22 i You can ask Mr. Wurtz to do it. I can't 23 make out some of the words.
(~}
( ,/
24 Q Let's have Mr. Wurtz do it, and as he does 25 it, if you disagree with any particular words that he l
l l
l
1 Prodorick 77
) 2 has read into the record, you let us know.
J 3 MR. WURTZ: This is an answer to the 4 prior question B-5, sub B, and at the top of lll 5 the page are the letters B-5B underlined.
6 Then the answer reads, "Since all reactor 7 coolant pumps are idle, there is no 8 mechanically induced circulation. Natural 9 circulation by heat transfer through the 10 OTSG's is required to remove core decay heat" --
11 MR. SELTZER: " Decay" that word is?
12 MR. WURTZ: Decay.
13 MR. SELTZER:
~) Where do you see the "d"?
J 14 MR. WURTZ: I will read it and --
15 THE WITNESS : I think that phrase is 16 " decay heat" but it is difficult to make cut.
17 MR. WURTZ: " Natural circulation by heat 18 transfer through the OTSG's is required to
.19 remove core decay heat for natural circulation 20 system cooldown. There must be an active means 21 of decay heat removal to prevent steam 22 formation in the core and possible core damage."
23 Q Do you have any disagree:aent with l
24 Mr. Wurtz's reading of your handwriting as it appears l
(~h I
\'
~
25 on that page?
l l
l
1 Frcdarick 78 2 A No, his deciphering of these inscriptions 3 seems to be accurate.
4 MR. SELTZER: May I suggest that in the gg) 5 future we would be willing to provide you with 6 our original of something that is as difficult 7 to read as this so that it would be easier 8 to follow, and I would also suggest that it 9 would have been a lot easier if for this short 10 passage a stenographer had retyped it so we have 11 the adjacent page to follow instead of having 12 to sit and just listen to it orally for the first p 13 time.
O 14 MR. FISKE: Your suggestions are noted.
15 Q When you referred to steam formation in 16 this answer, were you referring to steam formation 17 other than nucleate boiling?
18 A I don't recall writing the answer, nor do 19 I remember what it is I had in mind any further than 20 what is written.
21 Q I think you testified in the beginning of 9 22 the deposition that at one point you had given l
l 23 testimony before the full President's Commission in 24 the course of a public hearing.
O)
(- 25 Do you remember giving that testimony?
1 Frederick 79 2 A Before the President's Commission in 3 washington?
4 Q Yes.
lll 5 A Yes.
6 Q I would like to read to you a question 7 and answer that appears on the bottom of page 199 and 8 the top of 200. It is a question by Commissioner 9 Pickford, "Mr. Frederick, at the time of the 10 accident, were you also aware of the importance that 11 the temperature be kept below the boiling point?
12 "Mr. Frederick: Yes,"
f~)
'v 13 Do you see that question and answer in 14 the transcript?
15 A Yes.
16 Q I take it you were also aware before the 17 accident of the importance that the pressure be kept 18 above the boiling point?
19 A Say that again.
20 Q You told Commissioner Pickford before the 21 accident you were aware of the importance that the s 22 temperature be k'ept below the boiling points correct?
l 23 A Yes.
( _3 24 Q Is it fair to say that you understood by A
25 the same token before the accident that it was
1 Frederick 80 O
(_,/ 2 important that pressure be kept above the point where 3 the water would boil?
4 A Yes, I also saw the maintenance of high pressure as being an important part of the design of ll) 5 6 the plant, yes.
7 Q By " maintenance of high pressure," are 8 you referring to the fact that it was important to 9 maintain high pressure?
10 A By maintenance, I meant tatt the system 11 was designed to do that. That was the job of the 12 pressurizer.
I~'t 13 Q I think you testified earlier that there
%.)
14 was a time when you were interviewed by representatives 15 of the President's Comnission.
16 MR. SELTZER: By members of the 17 President's Commission?
18 Q By staff members of the President's 19 Commission. By the staff of the President's Commission.
20 A This isn't an interview, is that right?
21 Q What you just put your hand on is the 9 22 testimony that you gave to the public before all the 23 members of the President's Commission, i
t l 24 A Yes.
(3
~
l 25 MR. SELTZER: You testified you were l
l
1 Frederick 81 (A) 2 interviewed by the staff, deposed by the staff, 3 and testified before the full Commission. Now 4 he is talking about the interviews by the lll 5 staff.
6 Q specifically, I am asking you about an 7 interview'that you had with a gentleman named Michael
,x
- 8 Hollis, a gentleman named Bill Bland, and a woman 9 named Ruth Dicker of the President's Commission in 10 May 1979.
11 A Again, I don't have a clear recollection 12 of that testimony, but those nanes do soun6 femiliar.
/~ 13 Q I would like to show you a transcript of (s}
14 that interview. I don't think we need to mark this 15 as an exhibit.
16 Maybe we better mark it. Let's mark this 17 transcript as B&W Exhibit 654.
18 (Transcript of interview had by Mr.
19 Frederick with Michael Hollis, Bill Bland and 20 Ruth Dicker was marked as B&W Exhibit 654 for 21 identification, as of this date.)
22 Q on the cover page it says " Interview of 23 Ed Frederick by the President's Commission, Hollis, 24 Dicker, Bland, May 10, 1979."
O 25 Directing your attention to the first page, l
l
1 Frodorick 82
(~ 2 it starts with page No. 12, at the top it says, O) 3 "Pape 3, Side 2."
4 Do you see that?
A Yes.
gg) 5 6 Q Do you remember that when you were 7 interviewed by Mr. Hollis and Mr. Bland and Ms.
8 Dicker, that there was a tape recording of the 9 interview?
10 A Clearly, this document indicates that there 11 was a tape, and there were tape machines present at 1
12 many of the interviews that I had. I would have no 13 reason to doubt. that this was a taped transcript.
14 Q Do you see on the first page the first 15 answer where it says, "I attended Paterson State I 16 Teachers College"?
17 A Yes. -
18 Q And the words "Paterson State" are written 19 in above something that is crossed out?
20 A Yes. ;
1 21 Q Do you know whose handwriting that is?
O 22 A No, I do not.
23 Q Directing your attention to page 18, do ,
1 24 you see the word "bidded" in the sixth line on that r~N (j 25 page?
l
1 Frederick 82-A s
V 2 A Yes.
3 Q Do you know whose handwriting that is?
4 A No, I do not.
g 5 (Continued on the next page.)
6 7
8 9
10
'l I
11 12 13 f
14 15 16 17 18 19 20 21 22 .
23 24 O
25
ll 1 1 Frcdcrick 83 1
l 2 Q I would like to direct your attention to (G~)
3 page 17, and I might indicate that this is the second 4 Page 17. The numbers start all over again. They go g 5 to 29, and then they start again. I am referring 6 to page 17 in the second set.
7 I would like to direct your attention to 8 the answer that you gave beginning on page 17 and 9 continuing over to page 18.
10 Have you had a chance to read that?
11 A Yes.
12 Q I would like t.o read the answer beginning
~
g 13 on page 17 through page 18, part of the answer on d
14 page 18, and I would like to ask you a question.
15 Do you sue where it says "Can I draw you P
16 a little picture" in your anseer on page 177 17 A Yes.
18 Q Then there is written in the margin the 19 word " diagram," and then the transcript reads as 20 follows: "This is the reactor and it is a heat 21 source. It is hot. Then you have a pump and another 9 22 tank, and this tank is divided in half. This is for 23 illustrative purposes. It has a wall down the middle 24 of it. The purpose of this pump is to circulate this 25 hot water in the loop, so that hot water comes out
I 1 Frcdcrick 84 "h 2 of the reactor and goes through this tank, comes back
[O 3 and goes into the reactor. From this side of the wall 4 is water. Now this hot water passing from this side 5 will cause that water to boil on the other side of the ggg 6 wall, and that water will boil, cause steam, go into 7 the turbine and generate electricity. Now, as this P water passes through the steam generator and heats 9 that water up, it becomes cold. So that if this is 10 hot, this is r elatively cold. It is only about 11 50 degrees or so. We are talking 603 degrees on the 12 inlet, and 556 degrees on the outlet, so it is not that 13 much different. This hot to cold is what protects the
("]
\_d
.4 reactor. In other words, as long as you LLve this 15 cooling water ecming in to take the heat away from 16 the reactor, and put it in this tank, then you have 17 the normal sequence. Anything that you can do that 18 would stop this or reduce it in any way will cause 19 the reactor to heat up. O.K.? And all of the i
20 safeguards that we have are designed to prevent an l 21 overheating or a boiling condition in the reactor." )
0 22 Do you remember making that statement to 23 the representatives of the President's Commission on 24 tape?
s/ 25 MR. SELTZER: When you say members of the
I 1 Fredcrick 85
() 2 commission --
3 Q Members of the staff of the President's 4 Commission.
5 A No, I don't specifically remember saying 6 these words. I have no reason to doubt that this is an 7 accurate transcription, but I was often in the position 8 during this testimony of describing to lawyers and 9 other representatives who were not familiar with how 10 the plant worked and trying to explain to the'm what l
11 goes on basically in a nuclear power plant, and this 12 appears to be an attempt to use a simplified diagram
~
13 to explain the design of the system.
14 . Q At the time you were doing that, were you 15 ) trying te do that as accurately as you could?
16 A No, this is a very, very simplified i
17 explanation.
18 Q Were --
19 A It is quite obvious that the steam 20 generator is not divided in half and has a wall and 21 that sort of thing.
22 Q What you were giving to the members of the 23 staff of the President's Commission was sort of a 24 layman's description in simple terms of how the system O)
\
25 works, isn't that correct?
6 I
1 1
1 Fredorick 86
( 2 A I think earlier on in the testimony, I 3 was dealing on a layman's level, and then he asked me 4 to clarify it further, and I had to go even more simple than that.
lll 5 ,He asked me, "Can you tie these two 6 together for us," on page 17. He wanted a further 7 explanation of what I had explained.
8 Q But it was in that context of making it 9 as simple for him as you could that you made the 10 statement I just read?
11 A Yes.
12 i Q Isn't it correct that the reason why it 13 was important before the accident to prevent a situation
(
14 where boiling occurred in the primary system war to 15 prevent the formation of steam in the core which could 16 cause core damage?
17 MR. SELTZER: I object. No foundation 18 that the witness had the understandings that you 19 are implying in your question and that he had 20 those understandings before the accident.
21 MR. FISKE: You can note that objection O 22 for the record if you want. I believ e I have 23 established a sufficient predicate for it.
24 If I am wrong, you can tell me later. Meanwhile, (D
'}
25 I would like to have Mr. Frederick answer.
I 1 Frodorick 87 2 MR. SELTZER: Why do you have to make a
{~/')
w 3 speech? I simply stated the objection.
4 MR. FISKE: I am responding to your 5 statement.
ggg 6 MR. SELTZER: You don't have to argue 7 the motion.
8 MR. FISKE: You stated an objection. I 9 am responding why I am chocsing not to accept it.
10 MR. SELTZER: The deposition would get on ]
l 11 much faster and much rnre constructively if you s!.
12 I would not keep responding to my objections.
(^
\~,'
13 I usually do not bridle and respond to your 14 objections.
15
] i MR. FISKE: It is not a matter of bridling.
16 It is a matter of responding.
17 MR. SELTZER: It would not offend me if you 18 didn't respond to my objections.
19 HR. FISKE: It wouldn't offend me if you 20 didn't make the objection in the first place.
21 MR. SELTZER: It is my duty to make the 9 22 objections if they are warranted.
l 23 Are you asking for his present understanding l
24 of why it is important, or are you asking for an l O
(._ 25 understanding that he had before the accident )
l 1
I i 1 FrGdorick 88 y'~s 2 since you didn't make any time connection in s
m)'
3 your question?
4 MR. FISKE: Read back the question.
(g) 5 (Record was read back.)
6 NR. SELTZER: Are you asking for his )
7 understanding post-accident or pre-accident?
8 MR. FISKE: I will start again.
9 Q The testimony that I have read to you i
10 from the President's commission said that you 11 understood before the accident that it was irportant 12 that the temperature be maintained below the boiling O
D 13 point.
14 In the othe- anawers that you gave earlier, 15 you said that you knew before the accident that if 16 steam formed in the core, other than as a result of 17 nucleate boiling, that could cause core damage.
18 All I am simply trying to do is ask you, 19 putting those two together , didn't you understand 20 before the accident that a reason why it was important 21 not to allow boiling to occur in the primary. coolant 9 22 system was to prevent or to avoid the formation of 23 steam in the core which could cause core damage?
24 MR. SELTZER: I object. There is no
( .
\
25 foundation that he has previously testified that
l 1 Frodorick 89 l
() 2 he had an understanding before the accident that 3 it was important to avoid boiling in the reactor 4 coolant system.
ll) 5 MR. FISKE: I will stand on the record on 6 that. It is just three questionc and answers 7 back.
8 MR. SELTZER: I think that is your 9 synthesis of a lot of different answers and you 10 are entitled to do a su"mation however you want.
I 11 MR. FISKE: I would like an answer to tne 12 question.
13 Q You understand, and I am sure Mr. Seltzer 14 explained before the deposition that simply becausa he l
15 interposes an objection, that doesn't mear that you 16 don't answer the question. He makes the objection and 17 we sort that out later. In the meantime, you and I 18 go on.
19 Would you like to hear the question again?
20 A Didn't you have two questions that you 21 asked me?
O 22 Q one question based upon two prior answers.
23 A I would like to hear that again.
24 (Record was read back.)
( '
)
25 A No. I guess I am having a problem following
l 1 FrGdorick 90
(~N
( ,) 2 through what you said just before you asked the question 3 and then you asked the question. This was a discussion 4 I was having with these people and trying to tell them how the plant worked. Then you asked me didn't (l) 5 I, 6 understand how steam formation was dangerous.
7 Q Is your answer to my last question no?
8 A Yes.
9 Q I will read you the question and answer 10 again that you gave to the President's Commission in 11 public. This is your public testimony before all the 12 members of the commission. Page 199 and 200.
() 13 " Commissioner Pickford: Mr. Frederick, at 14 the time of the accident, were you also aware of the 15 importance that the temperature be kept beicw the 16 boiling point?
17 "r r . Frederick: Yes."
18 A I am talking now --
19 MR. SELTZER: There is no question pending.
20 Q You testified previously that you understood 21 before the accident that boiling could cause steam, 22 correct? -
23 A Yes.
24 Q And you testified before earlier that you 7_s
() 25 knew before the accident that the formation of steam
L 9 1 Frsdorick 91 i l
i f'T D
2 in the core could cause core damage, isn't that 3 correct?
4 MR. SELTZER: Is that something you knew 5 before the accident?
ggg 6 Q Isn't that something you testified to 7 just less than an hour ago,that you knew before the 8 accident that the formation of steam in the core other 9 than nucleate boiling could make it more difficult to 10 remove heat from the core and thereby cause core 11 3 damage?
11 l A Yes, you asked me that question and I
'13 think I clarified it by saying damage to the fuel U(~g 14 elements progressing f rom nucleate boiling.
15 Q And damage to the fuel elements is damage 16 to the core, is it not?
17 A My impression now of what damage to the 18 core is in light of the accident is not what I thought 19 damage to the core was then.
20 Q I am talking about the answer that you 21 gave to this question that we previously read into the O 22 record, 653, where you said, "There must be an active 23 source of decay heat removal to prevent steam formation 24 in the core and possible core damage."
i
()%
(_ 25 MR. SELTZEE: Mr. Frederick previously 1
l 1
i
I 1 Frodorick 92 f')
s_/
2 testified that he didn't recall writing this 3 and couldn't recall what he meant when he wrote 4 this. l I
5 Q In light of the discussion we have been ggg 6 having in the last several questions and answers, let 7 me ask this question:
8 Is it your testimony today that before the 9 accident that you did not understand that one reason 10 i it was important to keep the water in the primary ,
11 system from boiling was to prevent the formation of 12 steam in the core which could cause core damage?
/~ '13 A correct me if I am wrong, but I think I v
11 testified earlier that I thought that was an important 15 part of the design of the plant.
16 Q So your answer is yes, you did have that 17 understanding? -
18 A The answer was I thought it was an important 19 part of the design.
20 Q In other words, you thought that it was an 21 important part of the design of the plant to keep the 9 22 water in the primary system from boiling in order that 23 steam not be created in the core which could cause core 24 damage?
Cs) '~
25 A No, I felt that it was an important part of
1 Frodorick 93
() 2 the design of the plant which was carried out by l 3 the design of the plant, which maintained it as a 4 precsurized water reactor.
(ll 5 g I am not clear what you mean by your 6 answer. You felt what was important?
7 A We were talking about prevention of the 8 water from boiling.
9 Q Right. And that one of the reasons that 10 it was important to keep the water from boiling, 11 whether that was by the design of the plant or by any 12 other means, was to prevent the fornation of steam in J
13 the core which would cause core damage, isn't that 14 0 correct? Didn't you have that understanding?
15 A No, I didn't understand it the way you 16 are stating it now.
17 Q So is it your testimony that before (he 18 accident, you didn't understand that boiling in the 19 primary system could cause the creation of steam?
20 A I understood that boiling would cause 21 steam.
G 22 Q And didn't you understand before the 23 accident that the formation of steam in the core other 24 than nucleate boiling could cause core damage?
25 A No.
1 Frodorick 94
() 2 Q Do you remember being interviewed in the 3 summer of 1979 by members of the staff of the 4 Subcommittee on Nuclear Regulation of the United States ggg 5 Senate Committee on Environment and Public Works?
6 A This is not one of the groups that you 7 mentioned before, is it?
8 Q We referred generally to congressional 9 committees before. I don't think we identified this l
10 i one specifically.
I 11 MR. SELTZER: Who is the lesd public 12 representative on that?
13 Q The people listed as participating in this O(~h 14 l interview are Lrew .Trena, chief counsel, Steven Blush, ,
15 investigator.
16 A I don't have a specific memory of that 17 interview. Mr. Arena's name sounds familiar.
18 Q Let me show you a transcript of that j 19 interview. I would like to direct your attention to 20 page 14. The question by Mr. Blush, "Had you had any 21 experience prior to March 28th with fuel failure?
O 22 "Mr. Frederick: You mean actual operating l 23 experience?
24 "Mr. Blush: Yes, operating experience.
O 25 "Mr. Frederick: No.
1 Frederick 95 (q %) 2 "Mr. Arena: In the course of your 3 training, what are you trained to anticipate as the 4 causes of fuel failure?
lll 5 "Mr. Frederick: I suppose the emphasis 6 is on overheating due to excessive flux peaking at the 7 clad which causes melting or overheating due to the 8 steam blanketing of the fuel that prevents the heat 9 from transferring out of the element and damages the 10 clad."
11 I wouJd like to ask you was it that type 12 1 of core dauage that you were referring to in the
()
I I
13 answer to the exan questions that we showed you 14 I, earlier?
15 A You are referring to the question on this 16 Exhibit 653?
17 Q Yes.
18 A The answer is no. The characterization 19 I am giving here of core damage is post-accident 20 understanding.
21 MR. SELTZER: Maybe it would help, and I O 22 hesitate e'ven to suggest it, but you could ask 23 before the accident what understanding did 24 Mr. Frederick have that steam formation in the 25 core could cause core damage, and I think that
1 FrGdOrick 96
() 2 is different from anything that you have asked 3 and may get at what you are trying to find out.
4 MR. FISKE: I think Mr. Frederick has already answered that question. I think the only (l) 5 6 thing he hasn't answered is the connection 7 between that and boiling.
8 Q Is it your testimony that before the Three 9 Mile Island accident you were not aware that steam 10 l blanketing of the fuel in the core could prevent the
-l 11 1 heat fron transferring out of the core and could cause i
12 damage to the clad?
13 A no, I wau referring to the answer that I
}
14 gave in this United States Senate testimony, and it 15 says here that I understood that it was overheating 16 due to excessive flux peaking at the clad which causes 17 melting or overheating, and due to steam blanketing, 18 and what I am stating is that that characterization of 19 the process is post-accident knowledge.
20 Q Whatever the process was, you did understand l
l 21 before the accident that the formation of steam in the i h
22 core beyond nucleate boiling could cause a reduction 23 in the transfer of heat from the core?
24 A Yes.
25 Q And that that could cause core damage?
1 1 Frodorick 97 (m
%J i 2 A If the definition of core damage remains 3 within the context of my understanding of what core I
4 damage was prior to the accident, I would agree with 1
g 5 that.
6 MR. SELTZER: So the record isn't 7 ambiguous, why don't you state what your 8 understanding is of what core damage is in the 9 sense that you are using it.
10 A Frevious to the accident, core damage, 11 I understood core damage to be you could have a steam i
12 production that would cause damage to the service of
(~% 13 the cled and it would cause tiny fissures in the clad,
%_ l 14 cracks, and since the accident, my idea of core damage 15 would have been greatly altered.
16 What I would characterize as core damage 17 now would coincide with some of the post-accident 18 analyses that have been done on the damage that is 19 supposed to have happened to TMI-2.
20 Q Did you understand the type of core damage 21 that you just described could result in a release of 9 22 fission products to the reactor' core?
t l
l 23 MR. SELTZER: You mean his pre-accident 24 knowledge of what core damage could be?
i A
-' 25 MR. FISKE: The limited definition he just
l 1 FrCdorick 98 s
e-() 2 gave.
3 A Yes.
4 Q Did you understand that was undesirable?
jgg E A I understood that the type of damage that 6 I was referring to existed even to some small degree 7 during normal operations and that the release of fission 8 products due to that damage was within the operating 9 limitations and capabilities of the plant, even 10 though it was undesirable.
11 Q I am not asking now whether there were other 12 backup mechanisms that were designed to deal with the
~'\ 13 problem if it occurred. I am simply asking you isn't (G
14 it a fact that you understood that you were supposed 15 to run the plant so that kind of thing didn't occur?
16 MR. SELTZER: He just said he understood 17 it would occur in' normal operation.
9 18 Q Did you understand that you were supposed 19 to run the plant in such a way that you would not cause
's 20 the kind of core damage that you have just described in s-
., s 21' 4) your answer to Mr. Seltzer? ,
k 1 \
A The plant was to be operated so as not to
- 22. f g (3 cause any more damage of that nature that was present
( 24 during normal operations.
l s"#
25 Q Was it your understanding before the 4.
w
ll 1 Frcdorick 99 (3
() 2 accident that that was the only kind of core damage 3 that could possibly occur to the core under any 4 circumstances?
lll 5 A I was not made aware during my training 6 at B&W or the refresher training at Met Ed what types 7 of damage could occur to the core or the system as a 8 whole as a result of the accidents that they described 9 in the safety analysis.
10 Q That isn't my question. My question was il did you have an understanding before the accident that 12 there was no other kind of core damage that could occur
/~ 13 regardless of the circumstances other than the type D) 14 that you just described to Mr. Seltzer?
15 A Yes.
16 Q Were you familiar before the accident with 17 something called a heatup/cooldown curve?
18 A Yes.
19 Q Were there several different heatup/cooldown 20 curves that had to be found?
21 A There were several curves that had to be O 22 referred to when doing a heatup or cooldown, but they 23 weren't all called the heatup and cooldown curve.
7_
24 Q Were these curves a reflection of various
\'~,)
- 1 25 pressure / temperature relationships? l l
1 Frodorick 100
( 2 A The one that I am thinking of is a pressure 3 versus temperature plot, yes.
4 Q Were you familiar with a phrase before the lll 5 accident called the pressure / temperature envelope?
6 A I know that we use that phrase now in 7 training quite a bit. I can't remember whether that is 8 a pre-accident phrase or not.
9 Q Whether the phrase itself came into 10 existence before or after the accident, is the concept 11 referred to in that phrase one that was known before 12 the accident?
13 A Known to me?
s 14 Q Yes.
15 A I understood the pressure / temperature 16 envelope and I understand it now to be the normal 17 operating range of the pressure and temperature in the 18 plant at full power.
19 Q so is your understanding of the pressure /
20 temperature envelope one fixed pressure and one fixed 21 temperature?
22 A No, it is a range.
23 Q What is at the bottom end of that range?
24 A What I would refer to as the bottom end of O
\')
25 the range would be the lowest pressure that would be
1 Frederick 301
^
(s )N 2 obtained in normal pressurizer operation.
3 Q Let ue show you a document which has been 4 marked as Exhibit 572. Do you recognize that?
lll 5 A This is a portion of the license document 6 for Unit 2. The revision date isn't noted on here, but 7 it is one of the revisions of the license attachment.
8 Q Do you recognize this as the section of 9 the technical specifications dealing with safety limits 10 and limiting safety system settings?
11 A Yes.
12 Q You were trained on this, were you not,
() 13 before the accident at Met Ed?
14 A Yes.
15 Q Directing your attention to page 2-1, the 16 very first item in this technical specification, do 17 you see where it says "2.1 Safety Limits"?
18 A Yes.
19 Q Right under that, it says " Reactor Core."
20 A Yes.
21 Q Then it reads, "2.1.1 The combination of 22 the reactor cool' ant core outlet pressure and outlet 23 temperature shall not exceed the safety limits shown l
,s 24 in Figure 2.1-1."
25 Do you see that?
l 1 Fredcrick 102 O
y/ 2 A Yes.
3 Q Then do you see Figure 2.1-1?
4 A Yes.
lll 5 Q Does that figure set forth this pressure /
6 temperature envelope that you just described?
7 A No.
8 Q Wha't do you understand this figure does 9 set forth?
10 A These are the limiting safety system set 11 points for the reactor protection system.
12 Q This Figure 2.1-1 sets forth various I~ 13 pressure and temperature criteria, does it not?
D) 14 A Yes.
15 Q And do you see the words " Acceptable 16 operation" in the middle of that chart?
17 A Yes.
18 Q Did you understand that the reactor had 19 to be operated within the limits, pressure / temperature 20 limits, covered by the acceptable operations part of 21 this figure?
22 A No .- More specifically, my understanding 23 was that the operation of the reactor could not continue
,_ 24 out of the bounds of these limits shown on this figure.
U 25 The normal operating parameters were much more
1 Frederick 103 2 restrictive than this.
3 Q What did you understand would happen if 4 the reactor was operated outside the limits?
lll 5 . MR. SELTZER: Objection. No foundation.
6 A The operator or the reactor cannot operate 7 outside these limits.
8 Q What would happen if it was operating and 9 either the pressure fell or the temperature rose beyond 10 these limita?
11 A In the case where pressure fell or 12 temperature rose or pressure rose or you met the
() 13 variable pressure and temperature trip, in each one 14 of those cases the reactor protection system would 15 ipsert the control rods in what was termed the reactor 16 trip.
17 Q In other words, the reactor would trip if 18 you went outside thene boundaries?
19 A Yes.
20 Q Why did you understand that these boundaries 21 were ref erred te as a safety limit?
22 .MR. SELTZER: Objection. No foundation.
23 Q I will put another question. Going back l g- 24 to paragraph 2.1.1, under " safety Limits," the " Reactor k- 25 core," it says, "The combination of the reactor coolant
l 1 Frodorick 104 (m
(_) 2 core outlet pressure and outlet temperature shall not 3 exceed the safety limits shown in Figure 2.1-1."
4 Why do you understand that was referred to lll 5 as a safety limit?
6 A The clarification I gave before referred 7 to all these lines here that are labeled high pressure 8 trip, and temperature, and all those others. The 9 safety limits on this curve is the line that is to the 10 right of all those numbers, to the right of that box, 11 and it has an arrow pointing to it that says " Safety 12 limit." We were discussing the other box and the 19 Q
13 operator's envelope.
14 Q Let's talk of the safety limits on the 15 Figure 2.1-1, on the line that is drawn and designated 16 specifically " Safety limit." You understood, did you 17 not, from the tech specs that the operator was not --
18 the reactor was not to be operated outside those 19 safety limits? -
20 MR. SELTZER: Now we are talking about a l 21 technical specification?
22 MR. FISKE: We are talking about the same 1
23 sentence. "The combination of the reactor coolant l 24 outlet pressure and outlet temperature shall not
(~
V) 25 exceed the safety limits shown in Figure 2.1-1."
1 Frodorick 105
/~N t
_) 2 Mr. Frederick pointed out the safety limit on 3 Figure 2.1-1 is a line that proceeds upwards on 4 the right-hand side of the graph.
lll 5 I am asking him why did he understand that 6 was referred to as a safety limit.
7 MR. SELTZER: No foundation. Objection.
8 A I understood that line to be a safety 9 limit because it is referred to under the technical 10 specification heading of " Safety Limits" and has an 11 arrow pointing to it that says " Safety limit."
12 Q Other than the fact that it is in the
() 13 section of the technical specifications referred to as 14 " Safety Limits" and the fact that the line itself is 15 designated " Safety limit" line, did anybody at Met Ed 16 in the course of your training tell you why that line 17 represented a safety limit? Why was it called a safety 18 limit?
19 MR. SELTZER: Which question are you 20 putting?
21 MR. FISKE: The same question.
22 MR. SELTZER: The last one, why was it 23 called a safety limit?
24 Q Did anybody tell you in the course of your
/-s\
\~J 25 training at Met Ed why this was a safety limit?
g Frodorick 106 O
(_) 2 A I believe the first time that I was taught 3 about safety limits was at the cold license training 4 in Lynchburg, and the things on the four pages called lll 5 the " Safety Limits" were designated as safety limits 6 because they related directly to the safety of the 7 plant.
8 Q Why did you understand it to be unsafe 9 for the plant if you went on the wrong side of the 10 safety limit line?
11 A Before the accident, I understood that that 12 line, the " Safety limit" line, represented the point at
() 13 which DNBR would occur.
14 Q Does that stand for departure from nucleate 15 boiling ratio?
16 A Yes.
17 Q What did you understand would happen to the 18 plant if that occurred?
19 A If the plant reached the point of DNB, then 20 some partial film boiling would occur.
21 g What was unsafe about having film boiling 22 occur?
l 23 A The fact that film boiling would occur in !
24 and of itself would not be unsafe in that occasionally
( 3,
%J 25 during transients film boiling does occur, but it would
1 Frederick 207 2 be undesirable because the type of fuel clad damage 3 that I described is likely to occur under partial film 4 boiling or film boiling.
lll 5 Q Did you understand there was no safety 6 problem if DNB was reached?
7 A It was my understanding that simply 8 exceeding that limit would not necessarily cause the 9 type of damage that I described and that the actions 10 that had to be taken were outlined in the paragraph 11 below the one that we were just talking about.
12 Q Before we get to the actions, I would like 13 to stick with your understanding of the significance of 14 adhering to this limit. At any time when you were in 15 any of your training programs at either Met Ed or B&W, 16 did you ever ask anyone why is this line referred to 17 as a safety limit?
18 A As I remember, it was described--the answer 19 to the question is no. As I remember, it was described 20 quite thoroughly in B&W initial training.
21 Q Why did they tell you it was a safety t 22 limit?
23 A Because exceeding that limit and the other
(~T 24 safety limits was the first step in beginning to yl 25 challenge the design of the plants, and I felt that
l 1 Fredorick 308 l')
(_, 2 these were safety limits that the operators might not 3 necessarily conclude that damage had occurred, simply 4 because they gave you quite a bit of time to respond llh 5 to them.
6 Q Directing your attention to Section 2.1 at 7 page B2-1 of the technical specifications, following 8 the word " Note," do you see that?
9 A Yes.
10 Q You see the note on the preceding page, 11 it says, "The summary statements contained in this 12 section provide the bases for the specifications of 13 Section 2.0 and are not considered a part of these 14 technical specifications as provided in 10 CFR 50.36"?
15 A Yes, I see that note.
16 Q We are talking now about a Met Ed 17 docunent, are we not, this technical specification?
18 That refers to Unit 2 of Three Mile Island?
19 A What is a' Met Ed document?
20 Q This is a document governing Three Mile 21 Island Unit 2 which is operated by Metropolitan Edison, 22 the basis upon khich the NFC gave a license to Met Ed 23 to operate this plant. That is what I mean by Met Ed 24 document.
25 A This is a document that we use to govern
1 Frederick 109 T
[/
(_ 2 our actions in control of the plant as opposed to a 3 document that was originated by Met Ed.
4 Q You were trained on this document, were you l
llh 5 not, at Met Ed, these technical specifications?
6 (Discussion off the record between the
{
7 witness and his counsel.)
8 Q Did you understand from your training at 9 Met Ed that the technical specifications for Three Mile 10 Island Unit 2 were the basis upon which the Nuclear 11 Regulatory Commission had granted a license to Met Ed 12 to operate the plant?
() 13 MR. SELTZER: Objection.
14 A Yes.
l 15 Q And this document referring to 2.1.1 on )
16 page B2.1 that you have in front of you reads, under 17 " Safety Limits," referring back to the section I read 18 to you several times already, referring back to Section 19 2.1.1, this says, "The restriction of this safety 20 limit prevents overheating of the fuel cladding and 21 possible cladding perforation which would result in 22 the release of fission products to the reactor core."
23 Do you see that?
24 A Yes.
3 G
25 Q Did you understand before the accident that
\
l 1 Frcdorick 130
() 2 this safety limit as it has been described by Met Ed 3 in its NRC document was designed to prevent overheating 4 of the fuel cladding and possible cladding perforation lll 5 which would result in the release of fission products 6 in the reactor core?
7 (Discussion off the record between the 8 witness and his counsel.)
9 A I think I lost the question. Can I have it 10 read back?
11 (Record was read back.)
12 A No. I understood what you just read there 13 to refer to, as it says there, both of those 14 specifications, No. 1 and No. 2. The paragraphs written 15 in this part of the bases cover the combination of 16 those two safety limits.
17 Q I think you elready said that you understood 18 before the accident that if pressure / temperature ratio 19 was allowed to fall to the right side of the line that 20 is designated as the " Safety limit" on the figure, 21 that that could cause a departure from nucleate boiling?
22 A Yes.
23 Q And you knew, did you not, that a departure 24 from nucleate boiling could produce a potential safety G
25 problem?
1 Frcdorick 23J r~~
' A Yes.
2 3 Q Let me show you a document which has been 4 marked previously as B&W Exhibit 540. Do you have lll 5 that in front of you?
6 A Yes.
7 Q You said earlier, I believe, that the 8 technical specification figure that we have just 9 referred to a moment ago was designed to set forth the 10 limits within which the reactor should be kept while 11 it was operating and that if it went outside those 12 limits, the reactor would trip. Is that correct?
13 A No, I said -- the second part of your f'/h x_
14 question is right. If we went outside the limits, 15 the reactor would trip, but the operator's intention 16 is to keep the operating parameters of the system in 17 a much more restricted snvelope than that.
18 Q I believe that was implicit in my question, ;
1 19 but in any event, the figure that is in the tech specs 20 was designed to cover the limits that should apply 21 during normal power operations? l 22 (Record was read back.) l 23 A No, the limits that apply during normal
' 24 operations are more restrictive than those shown in
(_s s 25 the technical specifications.
l l
1 l
l 1
1 Frederick 132
("%
k- 2 Q You weren't supposed to go outside the 3 limits in the figure during normal power operations?
4 A In fact, it was impossible to operate llh 5 outside those limits.
6 Q Did you also have procedures whereby after 7 a reactor trip and you were no longer in normal power 8 operations, that it was important to maintain certain 9 pressure / temperature ratios within the reactor coolant 10 system?
11 A Upon establishing the prerequisites for 12 technical specification mode 3, after a reactor trip
((_N) 13 or plant transient, then there are procedures which 14 cover what the plant parameters should be.
15 Q Is Exhibit 540 that I just showed you one 16 such procedure?
17 A Yes.
18 That is called Unit cooldown, is it not?
Q 19 A Yes.
20 Q can you turn to the, I believe it is called 21 Figure 1. It is page 16.
22 (Discussion off the record between the 23 witness and his counsel.)
l 24 Q Do you have the figure in front of you,
(^)T
\_
25 page 16?
1 FrCdorick 3J3 2 A Yes.
3 Q Figure 17 4 A Yes.
lll 5 Q That is called a heatup/cooldown curve.
6 Do you see that at the top?
7 A Yes.
8 Q Did you understand that during the course 9 of a cooldown, following a reactor trip, that it was 10 necessary to maintain pressure / temperature relationships l
11 as defined by various of the curves on this figure?
12 A The time to use this procedure is stipulated
() 13 in the prerequisites. When to use this figure is 14 stipulated in the prerequisites of this procedure, and 15 that is when you would refer to this figure.
16 That I understood, yes.
17 (Continued on the following page.) l l
18 19 20 llI 22 23 7- 24 b 25
1 Fredt;ick 334
^
/ )
kl 2 Q Did you understand that within the 3 prerequisites specified in the procedure, that it was 4 necessary to be sure that as the plant cooled down, you llh 5 maintained pressure and temperature in certain ratios 6 as prescribed by this curve?
7 A Yes.
8 Q Take, for example, curve No. 5. Do you see 9 curve No. 5 at the bottom?
10 A Yes.
11 Q What does that curve designate?
12 A The legend on the diagram shows it as 13 being the minimum RC pressure for single pump in a 14 loop NPSH or 1/0, 1/1, 2/1 instrument error plus 50 15 pounds and 12 degrees Fahrenheit.
16 Q Is that sometimes referred to as the 17 net positive suction head?
18 A It is the net positive suction head curve 19 for a particular pump configuration.
20 Q And No. 6 is the net positive suction 21 head curve also?
22 A Again it is a net positive suction head 23 curve for other pump configurations.
(~N, 24 Q During the course of a cooldown being U
25 conducted pursuant to this procedure, did you
1 Frederick 335 O
'\ / 2 understand which side of the curve you were supposed 3 to keep the pressure temperature ratio on?
4 A Yes.
lll 5 Q Which side?
6 A Which side of the curve No. 5 and curve 7 No. 67 8 Q Yes.
9 A The area of the curve which is to the left 10 and above the curve.
11 Q Were you trained on how, during the course 12 of a transient where you were following this cooldown (s,g) 13 procedure, you would be able to tell which side of 14 the curve you were on?
15 A Yes.
16 Q How were you trained to do that?
17 A I recall that the procedure stipulates the 18 instruments to be used to read the parameters on this 19 graph.
20 Q What other parameters on the graph that 21 you have to read?
22 A Reactor coolant pressure and temperature 23 . in degrees Fahrenheit.
24 Temperature of what?
(~')
'x_e Q
, 25 A I don't recall now whether it was average l
l
l l
l 1 Frederick 326 l
<s v) 2 temperature or cold loop temperature. It would say so 3 in the body of the procedure. I could look it up.
4 Q What instrumentation was there in the llh 5 control room that showed what the T-AV and T-C were?
6 A Average temperature and cold leg 7 temperature are displayed several places on the panel.
8 Q And reactor coolant. system pressure is also 9 displayed on the panel?
10 A Yes.
11 Q So do I understand that in the course of 12 conducting a cooldown pursuant to this procedure, that f'h
() 13 the operators were trained to watch the instrumentation 14 for pressure and temperature to be sure that pressure 15 and temperature were maintained to the left and above 16 these curves as the curves became applicable?
17 A The net positive suction head curves?
18 Q Yes.
19 A Yes, those are the only ones or those are 20 the only two that you would have to stay to the left 21 of. Some of these you have to stay to the right of.
22 Q Which ones did you have to stay to the 23 left of and which ones did you have to stay to the r^% 24 right of?
(_ )
25 A The curve which is labeled A, B, C, D, E l
1 Frederick 237
/
k_3) 2 is a line which the operator had to remain to the 3 right of. Since the rest of them are curved lines, 4 they are all to stay to the left of, including lines lll 5 2 and 3, you stay to the left of also.
6 Q Could we talk about lines 2 and 3 for a 7 minute.
8 What are those referring to? What did you 9 understand prior to the accident that those referred 10 to?
11 A Those were minimum pressure guidelines.
12 You had to stay to the left of those. Left and above.
() 13 Q Are those referred to as fuel pin 14 compression curves?
15 A I seem to remember they were called fuel 1G clad compression curves, but it would be essentially 17 the same thing.
18 Q What did you understand before the accident 19 would happen if pressure and temperature was allowed 20 to fall to the right-hand side of the fuel clad 21 compression curves?
22 MR. SELTZER: Objection. No foundation l 23 he had an understanding.
7- 24 A That if you exceeded that temperature at C/
25 that pressure or exceeded to the rate of that curve,
l 1 Frederick JJ8
('))
s.
2 you would not have sufficient pressure on the clad 3 surface to conform with the way it was designed.
4 Q And it was designed to maintain a certain lll 5 pressure on the outside of the surface to balance 6 the pressure from the inside of the surface; isn't 7 that correct?
8 A Yes.
. 9 Q And what did you understand would happen or 10 could happen if the pressure was allowed to drop to the 11 point where the pressure on the outside was less than
.12 the pressure on the inside?
13 A I think that there would be some 14 distortion of the clad surface.
15 Q And potential damage to the clad?
16 A Again, not the same type of damage we were 17 speaking of earlier where you would get little 18 fissures. We were talking about getting ripples along 19 the edge of the clad. Unevenness.
20 Q But you understood if the pressure was 21 allowed to drop to the right-hand side of these curves, i j
22 you could create a situation where clad damage could 23 occur as a result of an imbalance of pressure?
(~ 24 MR. SELTZER: By " clad damage," do you
\~))
25 mean the ripples that the witness has just l
1
_ ________________--__--- - J
1 Frederick .119 n
2 described?
3 MR. FISKE: I mean any kind of damage.
4 MR. SELTZER: You mean any damage other h 5 than what he just described?
6 Q Did you understand that the further the 7 Pressure dropped to the right of this curve, the 8 greater the imbalance there would be between the
, 9 pressure pushing out from inside the clad and the 10 pressure on the outside?
11 MR. SELTZER: Is that anything that you 12 thought about before the accident? If so, 13 answer his question.
14 MR. FISKE: I don't think you need to 15 inject that. I think the question is perfectly 16 clear as to what his understanding was before 17 the accident.
18 MR. SELTZER: If he didn't think about it, 19 then you are just going to be getting his ;
1 20 conclusions today, and you repeatedly instructed !
21 your witnesses not to give me their analyses 22 today and you told the witnesses on the record l l
23 they should only give ne analyses and conclusions 24 they drew before the accident. I am merely 25 making sure that Mr. Frederick understands that
1 Frederick 320 l l
2 the question calling for his understanding 3 pre-accident calls for things that he thought 4 about pre-accident and not for an independent lh 5 . appraisal today.
6 MR. FISKE: Things that he understood 7 before the accident. That is all I asked him.
8 It is a fairly simple question.
g A Can I hear it again?
10 Q Did you understand before the accident 11 that the further the pressure dropped to the right 12 of this curve, the greater the imbalance would be O)
(_ 13 between pressure from the inside of the clad and 14 pressure on the outside?
15 A My understanding -- my answer is no. My 16 understanding is that an item of importance in crossing 17 that line was that you get back as quickly as possible, 18 that the time spent on that side was more important 19 than the differential that you are speaking of. My 20 impression was that, and in fact it was the practice, 21 that we on occasion crossed that line, but as long 22 as we came back quickly, there was not expected to be 1
23 any damage.
I 24 Q Was it your understanding that was true 25 no matter how far below the line you went? I l
1 l
1 Frederick J23 f
(_3) 2 A That if we recovered quickly, there would 3 be no damage, yes.
4 Q Recognizing that the less time you are llh 5 below the curve, the better, and I understand that, 6 my question is, didn't you also understand as a matter 7 of simple logic before the accident that the further 8 you went, the further pressure dropped to the 9 right of the curve, that is, the lower the pressure 10 became, the greater the difference would be between 11 that pressure on the outside and the pressure that 12 was pushing from the inside?
() 13 A No, that which I gave you in my answer 14 previously was the limit of my understanding prior to 15 the accident.
16 Q Why did you understand that it was 17 important to get back on the correct side of the curve 18 quickly?
19 A I am only working on recollection here, 20 but I remember that on several occasions a curve 21 similar to this using Unit 1, it was passed into 22 that region and quickly recovered. We asked B&W I
23 what do we do about that, and they said as long as l r~ 24 you recovered quickly, there should be no problem.
\ N-]T 25 Q What is "quickly"? A few minutes?
l
1 Frederick J22
(~)'\
(_ 2 A A few minutes.
3 Q Did anybody at Met Ed in the training that i
4 you received there discuss with you either the llh 5 question of how short a period of time you should stay 6 on the right of the curve or how far below the curve 7 you should avoid going?
8 A I think my answer indicates there was a 9 discussion at some time.
l 10 Q But other than that, there were none, 11 other than what you already referred to?
12 A I don't want to limit it to only one p)
( 13 discussion on only one occasion. I am only giving you 14 the best of my recollection.
15 Q What did you understand would happen if 16 the pressure was allowed to fall to the right of the 17 net positive suction head curve?
18 A If the operation fell to the right of the 19 No. 6 curve, I think is the one that we normally 20 used, then it would be violating the operating 21 recommendations for the reactor coolant pumps.
22 Q In what respect?
23 A That is where curve No. 6 comes from, s 24 from the operating recommendations for the reactor s-) -
25 coolant pumps, from the vendor.
l
I 1 Frederick J23 Os
\"'# 2 Q Did you understand why it was part of 3 operating recommendations that they told you to l 4 maintain temperature and pressure within a certain h 5 relationship?
6 A Yes, that is why the curve was called the 7 NPSH curve. If you go beyond that curve, then at 8 some point beyond there you would violate the NPSH 9 requirements for that pump.
10 Q In what way?
11 MR. SELTZER: What do you mean?
12 Q What would happen that would cause a
(' \
( 13 violation of the NPSH requirements?
14 MR. SELTZER: I don't understand. This 15 is a temperature / pressure curve, and going 16 beyond the curve means the temperatures and 17 pressures are in a relationship that is defined 18 by the curve. So that is how you have gone 19 beyond the NPSH.
20 Q Why did you understand pressure / temperature 21 ratios had anything to do with operating pumps?
22 A Why did I understand that pressure and 23 temperature had something to do with operating pumps?
24
( Q Why did you undarstand it made any 25 difference as to what the pressure / temperature ratios )
1 Frederick 324 1 (^~\
l k~l 2 were to the operation of the pumps?
3 MR. SELTZER: Do you mean why was there 4 an perating recommendation for the reactor ll) 5 e lant pumps? .
6 Q Why did you understand that the pressure /
7 temperature relationships had anything to do with 8 the operation of the pumps?
g A The relationships shown on this curve are 10 extrapolations of limits given to the proper it operation of the pump so no damage could occur to the 12 pump and it could be expected to last the lifetime b
(_/ of the plant.
13 14 Q Why did you understand that damage could
(
15 occur to the pumps if the pressure / temperature 16 relationships reflected on this curve were not 17 maintained?
18 A Damage would not occur at these 19 relationships. It would occur at some point to the 20 right of that where the actual limit existed.
21 Q Why did you understand that if you didn't 22 follow this curve damage would occur to the pumps?
23 A Because the pump would operate in a
(^ 24 cavitating state.
(_)T 25 Q What does that mean?
1 Frederick 325 2 A It is a condition of the pump in which 3 vibration and poor flow begin to develop.
4 Q What causes the development of the h 5 cavitation, vibracion and poor flow?
6 A As the formation of vapor at the eye of 7 the pump, which is a low pressure point of the pump, 8 and then the subsequent collapse of those vapor
, 9 bubbles at the tips of the impeller, that collapse 10 causes erosion and vibration at the tip of the 11 impeller.
12 Q Is vapor another word for steam?
13 A In this caso, yas.
14 Q In'other words, you understood if 15 pressure was allowed to fall to the right of these 16 curves, that that could cause the formation of steam 17 and damage to the pumps in the way you have described?
18 MR. SELTZER: Steam at the eye of the 19 pump. ,
20 MR. FISKE: Yes, in the way he described 21 it.
22 A My understanding is if the pump were 23 allowed to operace for some tima in that condition, l ( 24 then damage would occur to the pump, yes.
1 25 Q As a result of steam caused at the eye l l
l
\
l
s.A
..z.
( - - - - - - - - - - - - - - - -- - -- - - - - - ^ ~
% p, N v t
.),s N sN(s.
t
, . 3, s.
s ,(. s 1 ,
s Frederick 126 3: .
s N' -
1 2 . o.9 the pump by the drop in pressure?
s ', ,
i 3 -
t
, 3 3' A No, as a result of the collapse of that h
t*'w-p] lateam at the tip of the impeller.
us d ,e i
9 g' Q After it had been formed at the eye by 6 the drop in pressure?
7 A Yes.
s 8
8 9
^-
Edward R. Frederick
, \'s 10 - .
Subscribed and sworn to before me i s 73 '
Y
" this , day of 1982.
12
~ - 13
\' 14 15 s .
, 1 16' ,
17
\
18 19 r
20 21 9 ,e 22 s
9 25 i
i
", s ,
4 ~,
___-~,\.., '
,,i. "-'r *- ' " ~ " ^ ~ - " " " ' ' ' '
Cl4 .127 EEEEI.E1Ed1E 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK )
..h 5 6 I, JOSEPH R. DANYo , a 7 Notary Public within and for the State of New York, 3 do hereby certify that the foregoing deposition 9 of EDWARD R. FREDERICK was taken before 10 Tuesday, May 5, 1982 me on _;
11 That the said witness was duly sworn 12 before the commencement of his testimony and 13 that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 10 counsel.
~
20 IN WITNESS WHEREOF, I have hereunto set
{
21 my hand this [ day of A , 1982.
22 U '
T j ,
MT A. 6 p
v 24 j /Joseph R. Danyo
128, INDEX WITNESS PAGE Edward R. Frederick 4 EXHIB ITS B&W FOR IDENTIFICATION 645 Letter from Mr. Frederick to Mr. Paul Collins at the Nuclear Regulatory Commission, dated July 5, 1977 21 646 Two-page document 34 O 646-A Collection of documents 37 647 Document consisting of several pages 35 648 Document in handwriting of Mr. Frederick 39 649 Document - 43 650 Memorandum from Mr. Zaggers to Mr. Lawyer, dated July 18, 1977, subject, " General Physics Audit Exam Results" 46 651 Memorandum from Mr. Frederick to Mr. Eechman, dated
, September 7, 1979 49
, 652 Collection of pages 72 653 Excerpt from Exhibit 652 72
. 654 Transcript of interview had l y by Mr. Frederick with Michael Wollis, Bill Bland and Ruth I '"
Dioker
.~
, ~
- :. 81
}_._
- . =. sw .
- :, .e - .e a
-.