ML20072H752
| ML20072H752 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/05/1982 |
| From: | Frederick E METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-06, TASK-1, TASK-2, TASK-3, TASK-6, TASK-GB NUDOCS 8306290717 | |
| Download: ML20072H752 (152) | |
Text
D1 129 UNITED STATES DISTRICT COURT v
SOUTHERN DISTRICT OF NEW YORK
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x GENERAL PUBLIC UTILITIES CORPORATION,
,O JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
_against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
Defendants.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x U
Continued deposition of Metropolitan Edison Company, by EDWARD R. FREDERICK, taken by defendants pursuant to adjournment, l
at the offices of Davis Polk & Wardwell, Esqs.,
One Chase Manhattan Plaza, New York, New York, on Wednesday, May 5, 1982, at 9:50 o' clock in the forenoon, before Joseph R.
Danyo, a Notary Public within and for the State of New York.
A 8306290717 820505 PDR ADOCK 05000289 T
{
DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LexlNSTON AVENUE j
WALTER SHAPIRO, C.S.R.
Nrw YOmx. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELEPHONE 212 - 867 8220 l
1 130 i
<m m
2 Appe arance s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York O
5 By:
RICHARD C.
SELTZER, ESQ.
6
-and-ANDREW MacDONALD, ESQ.,
7 of Counsel 8
DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By:
ROBERT B.
FISKE, ES2
-and-12 WILLIAM E.
WURTZ, ESQ,
of Counsel 14 KILLIAN & GEPHART, ESQS.
Attorneys for Edward R.
Frederick 15 Box 886 Harrisburg, Pennsylvania 17108 16 By:
JANE G.
PENNY, ESQ.,
17 of Counsel 18 Also Present:
19 JONATHAN QUINN 20 ERIC ABRAHAMSON 22 23 (m.)
24 25 4
i
1 131 2
EDWARD R.
F RE DE R I C K, having 3
been previously duly sworn, resumed and i
4 testified further as follows:
Ih 5
EXAMINATION (continued) 6 BY MR. FISKE:
7 Q
You realize you continue under oath this 8
morning?
9 A
Yes.
10 Q
In fact all day, you realize that?
11 A
Yes.
12 Q
Yesterday we were at the end of the day O-13 asi.ing you some questions about the heatup/cooldown 14 curve which was part of the procedure that we showed 15 you, the unit cooldown procedures,. marked B&W Exhibit 16 540 Do you recall that discussion at the end of the 17 day?
18 A
yes.
19 Q
Isn't it a fact that at all times in the 20 operation of the plant other than when it was at 21 power operation, normal power operations, you were 22 required to follow the heatup/cooldown curve to the 23 extent that those particular curves became applicable
()
24 in any phase of the plant's operation?
25 MR. SELTZER:
I object.
Isn't that a
1 Frederick 132
,O
\\J 2
tautology the way you finished it, to the extent it is applicable?
3 4
MR. FISKE:
Withdrawn.
Yh 5
Q Let's make it simpler.
We talked yesterday 6
about the provisions of the technical specifications 7
and the figure that you said applied during normal 8
Power operations, and what I am asking you -- we also g
talked yesterday at the end of the day about some 10 curves that were part of a procedure, the unit cooldown 11 Procedure, the so-called heatup/cooldown curve, and 12 there were a number of separate curves that we went
\\J 13 through that were on that particular procedure.
Do 14 you remember that?
15 A
Yes, I remember the discussion of the 16 heatup/cooldown curve.
17 Q
Weren't there separate procedures, 18 Operating or emergency procedures in effect at the time 19 of the accident,that covered different aspects of the 20 Possible conditions in the plant other than normal 21 Operations.?
O 22 MR.' SELTZER:
Could you read back the i
23 question.
[)
(Record read.)
\\s 24 25 MR. FISKE:
I will start again.
1 Frederick 133 S
,]
2 Q
Other than the normal power operations 3
which were governed by the technical specifications 4
that we talked about yesterday, weren't there a number llh 5
of separate operating and emergency procedures in 6
effect at the time of the accident that covered 7
conditions of the plant other than normal power 8
operations?
9 A
You are saying that the technical 10 specifications governed normal power operations and 11 other procedures covered the rest of the operations?
.12 Q
All I am talking about for the moment is
,_sU 13 conditions in the plant other than normal power 14 operations.
I am simply asking you, weren't there a 15 number of separate operating procedures or emergency 16 procedures that were in effect at the time of the 17 accident that covered conditions of the plant other 18 than normal power operations.
19 MR. SELTZER:
In your question, you didn't 20 refer to heatup and cooldown curves.
Is your 21 question divorced from that subject now?
22 MR. FISKE:
This is a preliminary question.
23 I am trying to get to that.
(h
(,)
24 MR. SELTZER:
So you are just asking, did 25 they have procedures that covered nonnormal
1 Frederick 134 L,)
i 2
operation?
3 MR. FISKE:
That is exactly the question, 4
nonnormal power operations.
llh 5
A I am not familiar with that term.
6 Q
Did you have a procedure for unit heatup?
7 A
Yes.
8 Q
We.s that a procedure applicable to normal 9
power operations?
10 A
Yes.
11 Q
Did you have a procedure called unit
'12 startup?
73
\\~]
13 A
Yes.
14 Q
Did you have a procedure called pressurizer 15 Operation?
16 A
Yes.
17 Q
Did you have a procedure called unit 18 shutdown?
19 A
Yes.
20 Q
Did you have a procedure called decay 21 heat removal via the once-through steam generator?
O 22 A
What was that again?
23 Q
Decay heat removal via the once-through A(_)
24 steam generator.
25 A
It is a normal operating procedure.
1 Frederick 135 O
2 Q
There was such a procedure?
3 A
Yes.
4 Q
Did you have a procedure called decay heat lh 5
removal?
6 A
Simply decay heat removal?
7 Q
Yes.
8 A
No.
9 Q
Are you familiar with decay heat removal 10 system?
11 A
Yes.
12 Q
Did you have a procedure called station
~
13 blackout?
14 A
That would have been an emergency procedure.
15 Q
I was referring to both operating and 16 emergency procedures in my questions.
Isn't it a 17 fact that the unit shutdown procedure, the decay heat 18 removal system procedure, the decal heat removal via 19 the steam generator procedure, the unit,cooldown 20 procedure, and the station blackout procedure were all 21 procedures that dealt with conditions of the plant after I
22 there had been a reactor trip?
23 A
No.
()
24 Q
You mean they were not applicable after 25 there had been a reactor trip?
1 Frederick 136 a
2 MR. SELTZER:
All of them?
3 MR. FISKE:
Yes.
4 Q
Which one of those that I read was not lh 5
applicable after there had been a reactor trip?
6 A
My answer was intended to show that the 7
listed procedures that you gave me was neither 8
all-inclusive of the procedures which may be applicable 9
after a reactor trip, nor is it a list of procedures 10 which must be used after every reactor trip, but it 11 may or may not be applicable.
's 12 Q
My question didn't import either one of those
{D 13 two things.
14 MR. SELTZER:
I thought it did.
15 MR. FISKE:
We will straighten it out.
16 Q
The question is, were not each of those 17 procedures that I read applicable to conditions that 18 might occur after a reactor trip.
19 MR. SELTZER:
Does your question imply 20 that they were simultaneously applicable?
21 MR. FISKE:
They could become applicable 22 after a reactor trip.
23 A
As I review that list now, I can understand b)
N/
24 where each of them may have become applicable after a 25 given reactor trip.
1 Frederick 13 7
("'N O
2 Q
Didn't you understand that before the 3
accident, that each of these could be applicable after 4
a reactor trip?
5 A
Given the prerequisites for each of those 6
procedures was met, they could be applicable.
7 Q
Wasn't the same heatup/cooldown curve that 8
we were discussing yesterday that was part of the unit 9
cooldown procedures part of each of these other 10 procedures as well?
11 MR. SELTZER:
You are asking whether he
, 12 can testify from memory that Figure 1 in B&W 13 Exhibit 540 is reproduced in each of the other 14 procedures that you have described?
15 MR. FISKE:
Right.
16 A
I can't say at this time that I remember 17 that that graph was in each one of those procedures.
18 Q
Let me read you the list of procedures again 19 just so we understand what we are talking about and 20 you tell me, as you sit there, if there is any one of 21 these procedures,which does not have a unit G
22 heatup/cooldown curve as part of it.
23 MR. SELTZER:
Before you read the list,
)
\\-./
24 are you asking him whether today he recalls 25 knowing before the accident that this
1 Frederick 138 l
s 2
heatup/cooldown curve was in each procedure as 3
you read it?
4 MR. FISKE:
Yes.
h 5
g Let's put it this way.
You were trained 6
on the operating and emergency procedures in your 7
training prograr at Met Ed, were you not?
8 MR. SELTZER:
Are you asking for just Met 1
9 Ed as opposed to also at B&W Lynchburg?
10 MR. FISKE:
I am talking about Met Ed in 11 this question.
We will take them one at a time.
p
. ~12 A
Yes.
N-)
13 g
You were also trained on them in whatever 14 times you went to training at B&W; isn't that correct?
15 A
Yes, I did that in my initial training on 16 emergency and operating procedures at B&W.
17 Q
The fact of the matter is you were trained 18 on emergency and operating procedures as part of your 19 cold license training program before you got your 20 license; isn't that correct?
21 A
Specifically the cold license training O
22 program at B&W7 23 Q
Yes, take that.
You were trained on them O)
(_
24 at B&W before you obtained your license, were you not?
25 A
Yes.
1 Frederick 139
/~T
(-)
2 Q
And you were also trained on them at Met 3
Ed before you received your license, were you not?
4 A
I do recall that we reviewed our previous llh 5
training at Met Ed, yes.
6 Q
In other words, it was part of the Met 7
Ed part of the cold licensing training program that you 8
would be trained on operating and emergency procedures?
9 Met Ed didn't leave that entirely to B&W, did they?
10 A
The study of procedures was not left 11 entirely to B&W in that we were to review and we had 12 learned at B&W and in the case of emergency procedures (s) t\\~#
13 memorized the actions so that our study at Met Ed 14 was basically review and self-study in an effort 15 to memorize the emergency procedures.
16 Q
After you obtained your license, you went 17 through requalification training at Met Ed, did you not?
18 A
Yes.
19 Q
And as part of that'requalification 20 training program, you were supposed to continually 21 study and be trained on the operating and emergency 22 procedures, were you not?
23 A
You are asking if it was a requirement
/'y
(
)
24 of the training program or if I actually did do the 25 training?
1 Frederick 140 O).
\\-
2 Q
Let's start with the second.
Isn't it a fact -- let me ask you the question.
Did you 3
4 receive any training at Met Ed in the course of Ih 5
requalification training on either operating or 6
emergency procedures?
7 A
Yes, during the course of our 8
requalification training, we reviewed and went over 9
the revisions to procedures.
10 Q
And you understood at the time you 11 received your license and at the time you were going
~12 through this requalification training that you 13 were supposed to know what was in the operating and 14 emergency procedures, did you not?
15 MR. SELTZER:
When you say " supposed to 16 know," do you mean, memorized verbatim?
have it 17 MR. FISKE:
No, I don't mean that.
18 MR. SELTZER:
What do you mean?
19 MR. FISKE:
Be familiar with.
20 A
Can you say the question using that 21 phrase?
O 22 Q
You understood, did you not, both at the 23 time you obtained your license and at the time that O,
k-24 you went through your requalification training at Met 25 Ed that you were supposed to have a working knowledge
1 Frederick 141 2
of the operating and emergency procedures?
A I understood that we were to have a 3
4 familiarity with the operating procedures and to 5
memorize certain portions of the emergency procedures.
l 6
Q Which portions of the emergency procedures
)
7 were you supposed to memorize?
g A
The portions of the emergency procedures which were called the symptoms and the immediate 9
10 manual actions.
11 Q
Let me go back to my earlier question.
fl2 Before the accident, did you know that the unit
\\_ -
13 heatup operating procedure contained as part of the 14 procedure the heatup/cooldown figure which we were 15 discussing yesterday with the six curves?
l 16 A
I think that I would h ave to review the 17 procedure and compare the diagrams to see if they were 18 the same figure at this point.
I-don't recall 19 them as being the identical figure.
20 Q
Do you remember if there were any 21 heatup/cooldown curves as part of the unit's heatup 22 procedure?
23 A
Yes.
24 Q
Were there heatup/cooldown curves as part 25 of the unit startup operating procedure?
1 Frederick 142 2
A That I don't recall.
3 Q
Isn't it a fact that there were 4
heatup/cooldown curves as part of the pressurizer 5
operating precedure?
6 A
I remember that there were curves in that 7
procedure governing the operation of the pressurizer, 8
but whether they included this heatup/cooldown curve, 9
I don't recall.
10 Q
Isn't it a fact that there were heatup/
11 cooldown curves as part of the unit shutdown procedure?
12 A
I don't specifically recall what graphs O
13 are in the back of the procedure.
14 Q
Isn't it a fact that there were heatup/
15 cooldown curves as part of the decay heat removal via 16 the steam generator procedure?
17 A
I don't recall that either.
18 Q
Isn't it a fact there were heatup/cooldown 19 curves as part of the decay heat removal system 20 procedure?
21 A
I know that there were graphs in the back 22 of that procedure governing the operation of the decay 23 heat removal system, and specifically that a portion 24 of the heatup/cooldown curve is in that procedure.
25 Whether the same curve again in the cooldown procedure
[
1 Frederick 143 p,
2 is in that procedure, I don't know.
3 Q
Isn't it a fact that there were heatup/
4 cooldown curves as part of the station blackout 5
procedure?
6 A
I don't recall that either.
7 Q
Is it your testimony that you didn't know 8
that the curves that were attached to the procedures 9
that I just described to you in fact were the same 10 curves in each of those procedures as were on the unit 11 cooldown procedure that we were discussing yeste'rday?
("T 12 MR. SELTZER:
You just asked that question
\\)
13 specifically about these procedures and got 14 answers specifically for each procedure.
15 A
No, my testimony is not that I did not 16 know it at the time.
It is that I do not recall 17 knowing it at this time.
18 Q
You mean your testimony today is you 19 don't know before the accident whether you knew it 20 or not?
21 A
I j us t, don't see the necessity in 22 rephrasing my answer.
I think my answer is clear.
23 Q
I don't think it is.
rh 24 MR. FISKE:
Would you read it back.
25 (Record read.)
1 Frederick 144 C ')
2 MR. SELTZER:
I think Mr. Frederick's 3
answer was complete and responsive and you have 4
gotten the answer twice now to the same question, 5
and I am not going to permit you to harass the 6
witness by pressing for repeated answers to the 7
same question.
8 MR. FISKE:
There is no harassment going 9
on here.
We are just trying to get an ~ answer 10 to the question.
Mr. Frederick said, as I 11 understand his last answer, that he doesn't
'12 know now whether the curves were all the same.
13 My question is, did he know before the accident 14 that they were all the same.
15 MR. SELTZER:
I am telling you that he 16 already answered that question twice.
17 MR. FISKE:
Why don't you tell me what 18 the answer is, yes or no.
What was his answer?
19 If you give it to me, then we will go ahead.
20 MR. SELTZER:
The record is quite clear.
21 I would rather not paraphase his sworn testimony.
22 You-can have the court reporter who has taken 23 it all down verbatim read it back again.
You 0)
\\/
24 can go back to each of the questions where you 25 asked, did you know that it was in unit heatup,
Frederick 145 N-]
2 do you recall that it was in unit startup, do 3
you recall that it was in pressurizer operations.
4 The answers are all there. Then you got a sum-up I
5 answer again.
6 Q
I will put it to you this way.
I want 7
to know and have this record indicate whether or not 8
you can tell us today whether you knew before the 9
accident that the unit heatup/cooldown curves.that 10 were attached to all of the procedures that I just 11 described were the same.
If you think. you have answered
/~N
~12 that question and Mr. Seltzer instructs you not to
(_)
13 answer, obviously, right at this moment, there is 14 nothing I can do to make you answer the question, 15 but this record is going to be part of this case, 16 and I am giving you an opportunity to answer that 17 question now.
18 MR. SELTZER:
Let me say that I think you 19 are a big bully for using the tone of voice that 20 you have just been using and phrasing the same 21 question repeatedly.
I am going to ask Mr.
22 Frederick to please patiently give Mr. Fiske 23 the answer to his question.
O 24 MR. FISKE:
Before you do that, I am going 25 to object to the statement you just made.
My i
1
1 Frederick 146 2
tone of voice was absolutely level.
It didn't 3
change in inflection from one word to the other 4
in the last sentence.
What you are trying to do lh 5
is distort the record by using words like I
6 harassment and making statements about my tone 7
of voice that you know are completely inaccurate 8
and unjustified.
There is no more basis for your D
commenting on my tone of voice in response to 10 the question I just asked Mr. Frederick than 11 there is in commenting on the way I am talking
(~g
'12 to you right now which is in a level, moderate V
13 tone.
14 MR. SELTZER:
I detected a sharp tone in 15 your voice and the type of glare that you were 16 giving the witness,as you were giving him the l
17 question for the third time communicated to me i
18 an attempt to intimidate the witness, and if 19 I put that on the record, it is because that is 20 what I perceived.
21 MR. FISKE:
I think you have an 22 extraordinarily sensitive, thin skin, if you 23 think that every time I look at Mr. Frederick O
24 to try to get an answer, that that is somehow a 25 glare that is intimidating him.
You must not
1 Frederick 147 b)
\\~-
2 have been in this business very long if you think 3
that is intimidation.
We are not going to get 4
anywhere if every time I ask a question and look 5
at him that I get accused of intimidating him 6
or use a tone of voice that is called 7
harassment.
Maybe this is your way of harassing 8
or delaying the deposition.
9 MR. SELTZER:
I think you are the one with 10 the thin skin.
This is the first time in more 11 than a day of this deposition that I have made a
(~x
.~ 12 comment like that, so it is not every time you k
13 ask a question.
14 MR. FISKE:
The question was no different 15 than any of the ones I have been asking up to 16 that point.
That is why I couldn't understand 17 why you made the comment.
18 Let's go ahead.
19 MR. SELTZER:
If you will moderate your 20 behavior, I won't have to make that comment 21 again.
gg l
22 MR. FISKE:
There is no one here that is l
23 judging whether I am right or you are right in O
kJ 24 this colloquy that is taking forth.
25 MR. SELTZER:
Why don't you stop the
l y
Frederick 148 2
colloquy then.
3 MR. FISKE:
Why don't you stop putting 4
adjectives to your objections to the questions.
5 The judge will make his own judgments at that 6
time as to how lawyers conduct themselves.
7 He is not going to depend on what you may try to 8
put in the record in the deposition which I 9
tell you right now is totally unjustified.
Let's 10 go ahead with this examination.
11 MR. SELTZER:
I think that your speech-c12 making on the record is totally uncalled for, 13 that you and your co-counsel in this case make 14 extensive objections without eliciting the kind 15 of response from me that you already see fit 16 to try and put on the record when I am making 17 objections.
I think that you are not only 18 attempting to intimidate the witness at times, 19 but it is a tactic to try to intimidate opposing 20 counsel and deter us from making objections 1
21 that are entirely proper.
22 MR. FISKE:
My style is not intimidation.
23 Anybody knows that, and you know that as 24 well as anybody else.
You have been through 25 enough of these depositions to know that
1 Frederick 149 O
2 yourself.
3 Let's go on.
4 (Record read.)
h 5
A I have to state that in the rereading of 6
the record I did not detect a question.
I detected 7
a statement or a desire on your part to say something 8
clear on the record.
5 Q
You don't have to get in this game, this 10 game of colloquy back and forth.
All you have to do 11 is answer the question.
12 MR. SELTZER:
What is your question?
I O
\\
13 think he is looking for what is your question.
14 Q
Did you know before the accident that the 15 heatup/cooldown curves which were attached to the unit 16 cooldown procedure that we were discussing yesterday 17 that those same curves were part of all of the other 18 procedures that I had been questioning you about this 19 morning?
20 A
I feel I already answered that.
You can go 21 by the answer I gave you before.
22 MR. SELTZER:
Let me ask you, would you tell 23 him one more time.-- I am not going to permit I) 24 him to ask it again -- what your answer to that v
25 question is.
1 150 1
Frederick O'
\\s 2
Q Yes or no?
3 A
My answer to that question is neither yes 4
nor no.
My answer is that the recollection I have at 5
this time is that I do not remember what my knowledge 6
of the placement of those curves in the various 7
Procedures was.
8 Q
I show you this operating procedure decay 9
heat removal via OTSG which has been previously marked 10 as B&W Exhibit 573.
Do you have that in front of you?
11 A
Yes.
-12 Q
l would like to direct your attention to V
13 Page 3.0.
It says " Limits and Precautions, 2.1.1, 14 Reactor coolant temperature, pressure, and cooldown 15 rates shall be maintained within the limits specified 16 in Figure 3.4.2 of T.S.
3.4.9.1 (Refer to Figure 1.5.2 17 attached)."
18 I direct your attention to page 11, 19 Do you see heatup/cooldown curve there, Figure 1.' 5.' 2 ?
20 A
Yes.
21 Q
The figure is captioned "Heatup/Cooldown 22 Curve," is it not?
23 A
Yes.
r~s
(,)
24 Q
Then there are a series of curves on the 25 figures right?
1 Frederick 151
[%/
2 A
Yes.
3 Q
Isn't it a fact that those are the same 4
curves that appear in the unit cooldown procedure that h
5 we were disgussing yesterday?
6 MR. SELTZER:
Are you asking for him to 7
do a comparison today in answer, or are you 8
asking him, did
'.e know before the accident 9
these were identical?
10 Q
I won't ask you to do a comparison today.
11 We can do that ourselves.
Did you understand before
~12 the accident that they were the same?
13 MR. SELTZER:
Asted and answered.
14 Q
What did you understand the decay heat 15 removal via OTSG operating procedure was designed to 16 cover?
What kind of condition?
What kind of 17 circumstances would this procedure become applicable?
18 A
My understanding would closely parallel 19 the prerequisites of this procedure on page 4.
20 Q
For the benefit of those that would like 21 to hear it explained, could you tell us what you 22 understood that to mean?
23 A
In th e event that the prerequisites 24 listed on page 4 on section 3 are met, then you can 25 go on to use this procedure in accordance with
1 Frederick O) 2 Section 4.
3 Q
I am not asking you to walk me dumugh the 4
procedure at this point in terms of how the different 5
sections interrelate to each other.
I am asking you 6
to give us a general description of the type of 7
conditions that would be existing in the plant when i
8 you would be turning to this procedure.
9 A
You use this procedure when the reactor 10 is at hot shutdown, which is mode 3,
and you have 11 obtained hot shutdown in accordance with procedure
(~}
12 No. 2102-3.1, unit shutdown, and that the safety rod
%/
13 groups would be fully withdrawn, that feedwater flow 14 is via the startup feedwater valves, and that decay l
15 heat is being removed by the turbine by pass valves 16 and turbine header pressure is maintained in the 17 normal band of 855 pounds.
18 Q
Is the hot shutcown mode 3,
is that 19 something that occurs after a r,eactor trip?
20 A
It will occur at some time following a 21 reactor trip after having moved through hot standby.
22 Q
so in other words, before you get to hot 23 shutdown, you go through hot standby?
24 A
Yes.
25 Q
So that hot shutdown, the answer to my
1 Frederick 153 O
%J 2
question is, clearly after there has been a reactor 3
trip?
4 A
sometime after there has been a trip, yes.
k 5
Q Indeed, doesn't decay heat itself refer 6
to the heat that is generated after the reactor is 7
no longer critical?
8 A
Decay heat in the technical sense refers 9
to the heat generated by the decay of fission products 10 and is present during all modes of reactor operation.
11 Q
But in the way these terms are used in the
-12 context that these procedures are discussing, isn't s
13 decay heat commonly used to refer to heat that 14 continues to be generated by the core even after the 15 reactor has been shut down?
16 A
That is one sense of the understanding of 17 the term, but I would not accept it as the only 18 generally accepted definition.
19 Q
why did you understand that it was 20 important to remove decay heat after there had been a 21 shutdown of the reactor?
22 MR. SELTZER:
When you say "after there 23 has been a shutdown," you mean probably after f~%
(_)
24 there had been a trip; right?
25 MR. FISKE:
Yes.
l
s 1
Frederick 154 0
2 MR. SELTZER:
The unit would be in shutdown.
3 A
It was necessary to. remove decay heat to 4
be able to maintain the conditions set forth for the 5
shutdown condition in the technical specifications 6
and in the operating procedures.
7 Q
Why was that important?
8 A
You are asking why is it important to 9
maintain parameters within those listed in the 10 procedures?
11 Q
No, I am not asking you why was it 12 important to do what the procedures said.
I understand 7-O 13 you had to follow the procedures.
I am asking, did 14 you-understand the rationale behind the procedure to 15 "
why the procedures were designed to remove decay heat.
16 A
I can say now that I had some understanding 17 of the rationale behind the procedures in that I 18 was given quiEe extensive training on it at the 19 B&W classroom session in my cold license training.
20 Q
What did you understand the rationale was?
21 A
All operating procedures?
22 Q
No, t,he rationale for why it was important 23 to remove decay heat after there had been a. trip.
O
(_,/
24 A
N 'One of the reasons I already stated and 25 that is to remain within the operating parameters of
\\
1 Frederick 155
- V 2
the procedures.
Another, to remain within the limits 3
set forth by the curves and the diagrams in the 4
technical specifications.
5 g
Did part of this procedure apply to' 6
decay heat removal by natural circulation?
7 A
Before I review the procedure, you are 8
asking me if I remember the procedure did that or 9
as I look at it now?
10 Q
I asked you whether you knew that before 11 the accident, and if it would help you to taswer
- 12 that question to look at the procedure, you are free 13 to do it.
14 A
I have found a section entitled " Heat 15 Removal by Natural Circulation" in this procedure 16 we are discussing, 21023.3.
17 Q
I would like to direct your attention to I0 the page 4 of the procedure, the top of the page, 19 Section 2.1.7.
"During decay heat removal by 20 natural circulation, maintain TH 30 degrees Fahrenheit 21 below the saturation temperature corresponding to IN I pressurizer pressure in other to prevent boiling in 23 the hot legs."
U 24 Why did you understand that it was important 25 to prevent boiling in the hot legs?
1 Frederick 156 U) 2 MR. SELTZER:
Objection.
No foundation.
3 A
I don't recall now having attached any 4
significance or importance to the statement you just 5
read.
I don't think that we discussed previously 6
that I thought that this was a significant or important 7
statement.
O Q
Well --
9 A
At the time.
10 Q
You have testified before that you were 11 trained on these procedures both at Met Ed and in the
'12 cold license training program at B&W when you were 13 there and again repeatedly at Met Ed during the course 14 of your requalification training program.
I would 15 like to ask you whether in the course of that training, 16 didn't you receive. training on this particular 17 procedure.
18 MR. SELTZER:
When you say "this particular 19 procedure," you mean generally the decay heat 20 removal via once-through steam generator gg 21 procedure?
22 MR. FISKE:
Yes.
23 A
I don't recall having received training
(~'
l
(_)h 24 on this procedure or the specific portions which i
25 you have pointed out to me so far in my training at the
1 Frederick 157 V
2 B&W simulator or at the classroom.
3 Q
How about at Met Ed in the course of any 4
of the training you went through at Met Ed during the 5
entire time that you received training there, is it 6
your testimony that you received no training on this 7
particular procedure?
8 A
I can only say now that since I don't 9
remember this being emphasized at the simulator or 10 in their classroom training, I also don't remember 11 then the Met Ed training program having attached 12 significance or importance to it since it wasn't 3
13 covered very well there.
14 Q
What do you mean by "there"?
15 A
B&W.
16 Q
Is it your testimony that all the people did 17 at Met Ed was find out what had been taught at B&W 18 and then just go back over that same material again 19 at Met Edi that that was the full extent of the 20 training that was done at Met Ed on operating and 21 emergency procedures?
Is that what you are trying ggg 22 to tell us?
23 A
whether that was the actual program or
(~h
(_)
24 not, I can say that that was my impression.
25 Q
So your impression is you learned nothing
1 Frederick 158
[)
2 at Met Ed about operating or emergency procedures in 3
addition to what you learned on the two occasions you 4
went to B&W7 k
5 A
No, I can't say that review and study and 6
memorization, through that process I would learn 7
nothing.
It might be analogous to the situation of g
a college student who spends one or two hours in a week 9
in classroom and spends four or five hours on his 10 own.
You wouldn 't say that he didn't learn anything 11 on his own.
.12 Q
Is it your testimony that it was your 13 impression that the people that were conducting the 14 training at Met Ed, when they sat down with their 15 own operating and emergency procedures, they were 16 trying to decide what they should teach to their 17 operators, that they would go through the procedures 18 and before they decided whether or not to give any 19 training on a particular paragraph or particular 20 section of a procedure, they would first find out 21 what B&W had trained on that, and if B&W had trained gg 22 on it, then they would give exactly the same training, 23 and if B&W hadn't trained on it, then they would just
(~'h
\\-
24 skip that and not give any training on their own?
25 Is that what you are testifying your impression was
I Frederick 159 hx) v 2
of the Met Ed training program while you were going 3
through it as an operator?
4 MR. SELTZER:
That sounds more like a e
5 speech than a question.
6 MR. FISKE:
It is a question.
7 A
No, I don't think that is what I was 8
trying to relate as my impression.
But I do feel that 9
the priorities given the sections of the Met Ed 10 training were certainly derived from the emphasis 11 given by portions of the training received at B&W.
(~T
.~ 12 Q
How was what B&W emphasized communicated V
13 to the Met Ed training department?
14 MR. SELTZER:
You are asking again for 15 his impressions, because as I understand it, 16 before the accident Ed Frederick was not in the 17 Met Ed training department.
18 MR. FISKE:
Yes.
I will withdraw the 19 question I will go back to this particular l
l 20 section of the procedure.
gg 21 Q
Let's go back to this procedure, the decay 22 heat removal through the steam generator.
23 How did you understand an operator was
\\--
24 supposed to determine whether TH was 30 degrees 25 Fahrenheit below the saturation temperature o
1 Frederick 160 2
corresponding to pressurizer pressure?
3 MR. SELTZER:
Could you establish as a 4
foundation first whether Mr. Frederick recalls O
5 from his knowledge pre-accident this section 6
and how this section was to be applied, and then 7
ask him to interpret particular portions of it.
8 MR. FISKE:
If he wants to say that he 9
didn't have any understanding of this before the 10 accident, he can say that.
11 MR. SELTZER:
I think the question is, 12 does he recall three years later what his 13 understandings were of this section.
All I 14 was suggesting is that it would be proper to 15 find out, does he still have an understanding 16 today of what he knew about this section three 17 years ago, and then to proceed to ask questions I0 about words or phrases within it.
19 (Record read.)
20 A
Having reviewed all of the operating g
procedures prior to the accident, I can say that I 21 22 probably read this section before, but I don't recall 23 now having thought about how one would go about V
24 conforming with this particular atep in the procedure.
25 Q
Going back to the unit cooldown procedure l
A f
l 1
Frederick 161
')
(G 2
that we had out yesterday, I would like to direct your 3
attention to page 14, paragraph 4.31.
Do you have that 4
in front of you?
It starts, " Slowly open the DH 5.
auxiliary spray isolation valve."
6 A
Yes.
7 Q
Directing your attention to the note at 8
the bottom, it says, "The spray adjustment is to 9
prevent pressurizer outsurge into the RC hot leg."
10 Do you see that?
11 A
The note, yes.
I
'12 Q
Why did you understand that it was 13 important not to allow a pressurizer outsurge into the 14 RC hot leg during a cooldown?
J 15 A
I am going to have to read this section.
l l
16 Q
That is o.K.
l 17 A
To answer the question, I would be giving 18 you an analysis of what I believe the procedure is 19 doing based on what I know now.
l 20 Q
No, I would like to know whether you had 21 an understanding before the accident as to why it was g
22 important not to allow an outsurge from the pressurizer 23 into the RC hot leg.
(/
x-24 A
My understanding was that an outsurge is
{
25 a movement of some of the water in the pressurizer
Frederick 162 U) 2 into the RC hot leg, and that moving that hot water 3
into the transition pieces and the wells associated 4
with the surge line could cause some temperature 5
stress where the tip of the surge line is in the 6
pressurizer, and you don't want to be changing the 7
temperature by allowing water to shift from the hot 8
leg in or from the pressurizer out.
9 Q
Who was it that gave you that explanation?
10 A
I don't recall at this time that anyone 11 did give me that explanation.
12 Q
other than possibly causing damage to the 13 surge line itself, did you understand there was any 14 other reason for not allowing hot water from the 15 pressurizer to surge into the RC hot leg?
16 A
Other than the reason I gave you that was 17 temperature stress, my recollection of my understanding 18 is that there was no other reason except temperature 19 stress.
20 Q
Is the phrase " transferring the bubble" 21 a phrase that you ever heard before the accident?
ggg 22 A
The phrase has been used so frequently l
l 23 since the accident, it is difficult for ma to l
(~)/
l
(-
24 separate that recollection at this point.
25 Q
You understand what the phrase means today; l
I Frederick 163 2
right?
3 MR. SELTZER:
You are asking, does he 4
understand today that it refers to the steam 5
space in the pressurizer?
Is that right?
6 MR. FISKE:
I would like Mr. Frederick to tell 7
us what he understands by " transferring the 8
bubble."
9 A
I know what I understand the phrase to 10 mean, but I don't know that it concurs with what you 11 understand it to mean,
'12 g-Q How about the phrase " popping the bubble D
13 in the hot leg"?
14 A
No, I am not familiar with that phrase.
15 Q
What I am talking about is a situation 16 in which the steam bubble in the pressurizer is i
i 17 t.ransferred so that a steam bubble appears in the top
{
18 of the hot leg.
19 MR. SELTZER:
That is a statement.
What 20 is the question?
gg 21 Q
Were you aware of that concept before the 22 accident?
23 A
The concept being that the bubble could 24 be transferred from the pressurizer to the hot leg?
25 Q
Correct.
Frederick 164 pb 2
A I don't recall being aware of that, no.
3 Q
Is it your testimony that you did not 4
understand that one of the reasons why you wanted to O
5 prevent an outsurge from the pressurizer into the RC 6
hot leg was to prevent the creation of a steam bubble 7
in the hot leg?
8 A
I feel in your question there is an 9
implication that I should have known that as a result 10 of some of my cold license training, and I don't know 11 how to answer the question.
12 Q
You don't have to guess what the 13 implication of the question is.
All you have to do 14 is answer it.
So maybe we can read it again and just 15 answer it yes or no or the best you can.
16 (Record read.)
17 A
The testimony I gave you was strictly 18 related to this note in this procedure which you 19 showed me, and the purpose of this hote which I 20 iterated as being protection against temperature g
21 stress.
If you are asking me to expand that 22 understanding to mean something else, no, it only 23 meant temperature stress.
/^%
V 24 Q
Is it your testimony that you did not 25 understand before the accident that an outsurge from
1 Frederick 165 u,_s 2
the pressurizer into the RC hot leg could cause a 3
steam bubble in the hot leg?
4 A
The term "outsurge" did not in any way 5
relate to me the movement of the steam bubble.
We 6
are strictly talking about a transfer of a small 7
amount of water from the pressurizer to the hot leg.
8 (Recess taken.)
1.
9 l
(continued on the following page) 10 11 1
13 14 15 16 I
17 18 l
l 19 20 til 21 22 23 L
24 25
t 1B 1
Frederick 166
/O V
2 Q
Let me show you an exhibit that has been 3
marked as B&W Exhibit 539, which is the operating 4
procedure for Unit 2, the decay heat removel system.
h 5
Do you have that in front of you?
6 A
Yes.
7 Q
I would like to direct your attention to 8
page 38.
Do you see the curves on that page?
9 A
Yes.
10 Q
Those are curves that reflect variour 11 pressure temperature relationships, do they not?
12 A
Yes.
13 Q
I would like to direct your attention to the 14 top.
15 MR. SELTZER:
Can you help us out?
There 16 is some writing that describes the chart on page 38 17 down at the bottom, apparently a legend covering 18 this chart, that is not very readable on our copy.
19 Can you or Mr. Wurtz tell us what it is?
l 20 MR. FISKE:
I don't know that we have any 21 copy that is any better than this one.
As you 9
22 know, these copies were made from originals 23 produced by your client.
/'(,)\\
24 MR. SELTZER:
I am sure that we could get 25 better copies, if you ask us.
1 Frederick 167 G
2 MR. FISKE:
My question to Mr. Frederick 3
relates to the curves, each of which are described.
4 Let me direct your attention, Mr. Frederick, lh 5
to the top curve.
6 BY MR. FISKE:
7 Q
Can you read what it says above that curve?
8 A
The best I can make out, it says " maximum 9
allowable pressure to prevent overpressurization decay 10 heat system, DH system."
11 Q
Which curve are you referring to?
~12 A
It says either "DH system" or "In System."
13 The curve at the top of the page.
14 Q
The curve that you referred to refers to 15 maximum pressure, does it not?
16 MR. SELTZER:
Maximum allowable pressure 17 is what the wor 6s say.
18 MR. FISKE:
Yes.
19 Q
And the three curves at the bottom all refer 20 to minimum pressure, do they not?
21 MR. SELTZER:
I can't read what the middle l
22 curve s ays.
1 23 MR. FISKE:
I am asking Mr. Frederick.
k3j 24 MR. SELTZER:
Are you asking him to confirm
/
25 what the document appears to indicate to him
10 1
Frederick 168
\\
(
2 today?
MR. FISKE:
Lot's start with that.
3 MR. SELTZER:
What is the relevance of what 4
ll it means to him today?
5 6
MR. FISKE:
I will state to you then, at the 7
risk of being corrected if I turn out to be wrong, 8
that the three curves at the bottom all refer to g
" Min" pressure, which I will hazard a guess 10 stands for minimum.
11 MR. SELTZER:
I will stipulate to that.
.12 I am not arguing with what things may mean today.
O N/
I am trying to make sure that we're on equal 13 14 footing in examining on documents and 15 understanding whether we're getting today's 16 unde'rstanding or understanding at the time of the 17 accident.
18 BY MR. FISKE:
19 Q
Referring to the top of those three curves, 20 can you read what it says there?
A At the top of the three curves?
21 22 Q
Y e s.*
23 A
It says " Min pressure to prevent boiling
[/
)
24 in top of either 30 or 36-inch RC pipe."
\\
25 Q
Why did you understand that it was important
1 Frederick 169
(~h Q.)
2 to prevent boiling in the top of the 36-inch RC pipe?
3 A
I don't recall having that understanding.
4 This curve is one that would be used in operation of the h
5 decay heat removal system and using decay heat removal 6
system, temperature versus A loop pressure.
I don't 7
recall having an understanding of the importance of 8
each of these labels.
9 Q
You did understand that if pressure was 10 allowed to fall below that line, that that might cause 11 boiling in the top of the 36-inch RC pipe, isn't that 12 correct?
O 13 MR. SELTZER:
I really object to the 14 witness being examined on this page without our 15 having a clear enough copy to read what the 16 inscription is immediately below the curve and 17 the inscription on the bottom of the page which 18 may explain very clearly what these things mean 19 and may be of assistance in refreshing the 20 witness' recollection.
21 MR. FISRE:
I don't think that is necessary, 22 but Mr. Wurtz will be glad to read from what 23 appears to be a micro film copy of what appears 24 at the bottom if that will help us move along.
25 Do you want us to do that?
l
i Frederick 170 O
2 MR. SELTZER:
Could I see it?
MR. FISKE:
Sure.
3 MR. SELTZER:
I am not going to guess for 4
5 purposes of the record what this says.
6 MR. FISKE:
Then I will ask Mr. Wurtz to read it into the record.
7 g
MR. WURTZ:
The legend at the bottom states,
" Maximum - Minimum RC Pressure during operation g
10 of DHR System with no RC pumps operating." That is what I make it out to say. Mr. 12 Frederick may be able to affirm that. O 13 BY MR. FISKE: 14 Q You are perfectly welcome to look at that, 15 if you want. 16 MR. SELTZER: What is the pending question? 17 (Record read) 18 A I don't recall having that understanding. 19 I would like to add something to'that answer. 20 MR. SELTZER: Sure. Finish your answer, 21 if you weren't fini she d.. 22 MR. FISKE: Obviously, Mr. Seltzer is j 23 telling you to say something. I can't stop you l ( 24 from saying it. All I can do is say that you are 25 not allowed to make a statement that is not l
l l 5 1 Frederick 171 (~h %-) 2 responsive to my question. My question really 3 asked you for your understanding about -- g o 4 ahead, if you want to. I object to it if it is lh 5 not responsive. 6 MR. SELTZER: Why don't you listen to what 6 7 the witness has to say and then make any remark 8 if you feel it is appropriate. 9 A I do not recall having that understanding 10 because these lines would indicate operating limits 11 just like the operating limits on many of the other 12 curves we talked about, and I would not have understood ,s k_ 13 that crossing that line would cause boiling. 14 BY MR. FISKE: 15 Q You mean you didn't understand that when 16 there is a curve which is described as the curve setting 17 forth the minimum pressure to prevent boiling, that if l 18 you went below that pressure, you might have boiling? 19 A That's right. The conservatism built into l i 20 the curve tells you that operating at or near the curve t 21 is probably not a violation of that limit. { G l 22 Q How far did you understand you could go 1 23 below that curve before boiling would start? l f~s (,) 24 A I did not have an understanding about when 25 boiling would occur in the use of this curve. l l
73 1 Frederick 172 2 Q Let me show you another procedure which is an 3 operating procedure for Unit 2 called Pressurizer 4 Operation. It has been previously marked as GPU S Exhibit 350. 6 I would like to direct your attention to 7 page 22 of this pressurizer operation procedure. Do you 8 see the section at the top of the page, 4.3.8.6, that 9 starts "RCS depressurization can continue as follows"? 10 A
- yes, 11 Q
There are two paragraphs under that, '12 correct, 1 and 27 13 A Yes. 14 Q Directing your attention to paragraph 2 and 15 the note that follows it, the note says, "Also insure 16 that approximately 45 psig is indicated on the hot leg 17 RC 3 API indicator to prevent boiling at the top of 18 both loop hot legs." 19 Why did you understand that it was important 20 to prevent boiling at the top of the hot legs in i 21 connection with the use of that procedure? 22 A In response to your question, I can only say l 23 that I don't recall having thought about that prior to O(_/ 24 the accident. I don't remember that note. 25 Q Going back to the basic training that you
1 1 Frederick 173 (D V 2 had at Met Ed on these procedures, I think you testified 3 previously that you received training both in the cold 4 license part of the training and also in the 5 requalification part of the training on both operating 6 procedures and emergency procedures, is that correct? 7 A Yes, but during that time, the only place 8 that I actually had experience using the procedures was 9 at the simulator, and that is where I actually got the 10 experience how to use these. 11 Q I know you inject comments about the 12 simulator in response to practically every questica O 13 about training, and believe me, you will have ample 14 opportunity to discuss what did or did not go on at the 15 simulator. 16 My question was a simple preliminary 17 question, simply designed to confirm,which I understand, 18 the fact that you did receive training at Me t Ed on 19 both operating and emergency procedures, isn't that 20 correct? 21 A We did review operating and emergency 9 22 procedures in our Met Ed training. 23 Q And in the course of the Met Ed training, O) 24 weren't you, as operators, given drafts of procedures ( 25 before they became final and given an opportunity to
i l 1 Frederick 174 0 2 comment on those procedures? 3 MR. SELTZER: I object. Compound question. 4 A We as control room operators did receive 5 procedures to review as a group, and we were to read ggg 6 the ones that were assigned to us and make comments. 7 Q So that in that sense, the operators 8 themselves as a group were made part of the process by 9 which procedures were developed at Met Ed? 10 MR. SELTZER: What do you mean by the 11 operators as a group? 12 MR. FISKE: He just referred to the V 13 operators as a group in his last answer. I was 14 using it in exactly the same context in my 15 question. 16 MR. SELTZER: I think he just described 17 what the routine was. I can't see that your 18 characterization of it adds or subtracts any new 19 facts. 20 (Record read) 21 A We as a group were included in the process O 22 in the development of some of the procedures that were 23 to be used, yes. (~h (_) 24 Q Were the operators excluded from l 25 participating in the development of any particular l I
1 Frederick 175 (N O 2 procedures? 3 MR. SELTZER: Objection. No foundation 4 that this witness is knowledgeable about the 5 development of all procedures at TMI. ggg 6 MR. FISKE: He just described the process 7 that he himself participated in. I want to know 8 while he was participating in that process that 9 there were certain procedures that he wasn't 10 allowed to comment on. Certainly you are not 11 going to refuse to let me ask him that question. 12 MR. SELTZER: The fact that he was shown ("/ \\ \\m, 13 some procedures does not mean that he would 14 necessarily know whether there were other 15 procedures that were not being given to 16 operators to comment on. 17 MR. FISKE: Let's let him answer the 18 question. Let's let Mr. Frederick tell us. That 19 is what we're here for. 20 MR. SELTZER: I hear you respond, and I 21 think I am having deja vu hearing myself when you O 22 have made objections or Bob Wise has made 23 objections or Bill Wurtz, who is sitting next to 24 you has made objections when I have been examining 25 witnesses, and I have to smile at some of the
113 1 Frederick 176 7-2 things th at you are saying now. 3 MR. FISKE: You can make whatever facial 4 expression you want, so long as Mr. Frederick 5 will answer the question. ggg 6 Maybe you ought to hear it again since it 7 has probably faded from your memory at this point. 8 (Record read) 9 A There was no policy that excluded any 10 operator from reading or reviewing any procedure that 11 he wanted to review. However, the process was that of 12 the bulk of procedures that needed to be reviewed, each C/ 13 of us would receive one or two to review and make s-14 comment on them, and perhaps another person would be 15 doing the other procedures. 16 BY MR. FISKE: 17 Q So that as you said earlier, the operators 18 as a group would receive a collection of procedures. 19 You individually would only review one or two of them? 20 A Yes. 21 Q My question is, did you understand that O 22 there were any procedures at Met Ed that the operators 23 as a group were excluded from commenting on? (} 24 A My answer to that question was that there 25 was no policy which excluded operators from reviewing
l D 1 Frederick 177 ('h k-2 any procedure that they wished to make comment on. 3 However, there were procedures that were not 4 operating procedures. There were instrument procedures, 5 maintenance procedures, health physics procedures, and ggg 6 we could read and review as many of those as we liked. 7 Q If my questior wasn't clear, I will clarify 8 it now. My questions were intended to refer only to 9 operating and emergency procedures. Did you understand 10 that when I was asking those questions? 11 A I don't think I had a clear understanding 12 that that is what you were being specific about. ( ) \\_/ 13 we were reviewing procedures in general. 14 Q In the context of operating and emergency 15 procedures, did you understand there were any operating 16 or emergency procedures that the operators as a group 17 were precluded from commenting on? 18 A There were no operating or emergency 19 procedures which we were precluded from commenting on. 20 Q You actually spent part of your time writing 21 procedures, did you not, in the course of your training O 22 at Met Ed? 23 A No, what I would write would be revisions /^ 24 or comments to procedures. b) 25 (Discussion of f the record between the
3D 1 Frederick 178 t\\) 2 witness and his counsel) 3 Q That applied to both operating procedures 4 and emergency procedures, did it not? 5 MR. SELTZER: What applied? ggg 6 MR. FISKE: Mr. Frederick's participation 7 in the writing of procedures as he just described. 8 A My participation in the writing process as 9 a reviewer or editor was part of the entire process 10 which was primarily a job engineer's and PORC, and 11 they were just asking for our comments on the procedures, 12 just before they went into their final form, so that /N (_) 13 they could have a more representative input to the 14 applicability of each procedure. 15 Q They wanted input from the people that 16 were going to have to use the procedures, isn't that 17 what you understood? 18 A Yes. 19 Q Let me read you a question and answer from 20 your Kemeny deposition. This is page 56. Let me read 21 you a question and answer starting at line 4. 9 22 " Question: Did you cover procedures during 23 the study and training period? - f)i 24 " Answer: Yes, and we wrote many of the l 25 procedures based on what the engineers submitted as
14B 1 Frederick 179 OV 2 as preliminary procedures, and then we would refine 3 them. As we started up the system, we would change the 4 order of the steps and put in new parameters. We were 5 very involved in the development of the operating gg 6 procedures for most of the system, the alarm responses 7 and the emergency procedures. 8 " Question: And this was during the period 9 you were studying to become a CRO? 10 " Answer: Yes." 11 Then I would like to read further from 12 page 86 of your Kemeny deposition, starting at the n 13 bottom of 85 and continuing on to 86. 14 " Question: Are there other kinds of 15 occasions which relate to a review of emergency 16 procedure? 17 " Answer: Through operator training, we 18 review all the emergency procedures once a year through 19 our training." 20 I take it in that answer you were referring l 21 to training you received at Met Ed? 22 A No, I was referring to through the yearly 23 operator training, all of the operator training. [O) 24 Q Did you go to B&W once a year? 25 A Yes.
B 1 Frederick 180 , ~N 2 Q You did? 3 A Yes. 4 Q Your testimony is you went to B&W after 5 June of 19777 ggg 6 A I think I stated before that I didn't 7 remember what the dates of the training were, nor is 8 the requal. year coincident with the calendar year. 9 Q Do you remember going to B&W anytime after 10 June 19777 11 MR. SELTZER: That is the same question you 12 asked yesterday. {'/ s 13 MR. FISKE: Yes, but I think he is giving s-14 a little different answer than the one yesterday, 15 so I am pursuing it. 16 MR. SELTZER: I think he gave you the same 17 answer yesterday. 18 MR. FISKE: I think he just said he went 19 to B&W once a year. I would like to pursue that 20 since I don't recall him saying yesterday that he l I 21 had. 22 A I don't recall when the trips were down to 23 Lynchburg. l [ 24 BY MR. FISKE: 25 Q Let's start again then with this question and
1 Frederick 181 j s_/ 2 answer from page 85. 3 " Question: Are there other kinds of 4 occasions which would lead to a review of an emergency 5 procedure? ggg 6 " Answer: Through operator training, we 7 review all of the emergency procedures once a year 8 through our training. 3 " Question: The training department does? 10 " Answer: The training department tasks the 11 operators with waiting and studying them for a cause 12 with the intent of having the operators review them for () 13 context, being current procedures, to see if anything 14 has changed substantially since the last time we used 15 that emergency procedure or the last time we reviewed it. 16 " Question: I am not sure I follow you on 17 that. 18 " Answer: It is a matter of studying the 19 procedures that exist and if you think there should be 20 a change, the group in training would submit a TCN 21 for review. O 22 " Question: How often have you seen a 23 proposal made to change an emergency procedure based on 1 1 ,y 24 a training program or review of it? U 25 " Answer: Often. l
k 't 7B 1 Frederick 182 i 2 " Question: Can you give me the specifics? 3 " Answer: One goes through training once 4 every six weeks and during the training cycles in which Jgg 5 we were sent four or five procedures to review, there 6 are usually at least one change that comes out of it 7 or one suggestion." N s 8 ,Were,you asked those questions and did you s 9 give.those'answera, those two separate portions of your 10 Kemeny deposition that I just read? .11 A I don't recall the specific testimony, but 12 I have no reason to doubt that those are my answers to s/
- 13 those questions.
T 14 Q In your answer, where you said on page 86, 15 "The training department tasks the operators with 1 16 waiting and studying the emergency procedures for a 17 cause with the intent of having the operators review 18 them fc: 6 22n t e n t, being current procedures, to see if 19 arf t 's as ' as changed substantially since the last time 20 we ssed that emergency procedure or the last time we 21 reviewod it," you were referring, were you not, to the k 22 training department at Eat Ed? 23 MR. SELTZER: Mr. Frederick just said he {~} 24 didrc't recall giving this testimony although he v 25 does not dispute ' ti l P h s
18B 1 Frederick 183 (~h () 2 MR. FISKE: Why don't you let him answer 3 the question? 4 MR. SELTZER: Why don't you not interrupt 5 me? g 6 MR. FISKE: I would like him to answer the 7 question, not you telling me that he can't answer 8 it. 9 MR. SELTZER: I am not telling you he 10 can't answer it. I am objecting to the form of 11 the question. 12 MR. FISKE: The form of the question asking (9 13 him what he meant by training department? Is j 14 that your objection to the form? 15 MR. SELUIRt He said that he didn't recall 16 giving this, so now you are asking him what he 17 means when he said something that is in here. If 18 you want to ask him at or ab out the time that you 19 were referring to, was it your understanding that 20 the training department did ask operators to 21 write and study, I have no objection to that. I O 22 think that would be a proper way of getting at 23 his present recollection of the s ame period of 24 time that he was testifying to here, but to ask \\_/ 25 him what he meant by words or phrases that he
1 Frederick 184 V(~h 2 doesn't recall giving seems out of place. 3 MR. FISKE: Why don't I just ask the question 4 and see what Mr. Frederick says. 5 MR. SELTZER: I would also note that your ggg 6 partners and perhaps you have refused to let me 7 ask your witnesses, "What do you mean in this 8 statement that you wrote?" Even when I have got 9 the man's signature on the bottom and I.am asking 10 him what does that word mean, what does that 11 sentence mean, you have said, no, instructing him 12 not to answer because that witness already b \\# 13 testified that he doesn't recall today having 14 written that, even though the witness did not 15 even dispute having written it. Because he 16 couldn't recall having written it, you directed 17 your witnesses not to answer the question. 18 MR. FISKE: Without getting into a long 19 colloquy'on that subject on which there is much 20 more to be said than what you have just said -- 21 MR. SELTZER: I have said the truth and you I 22 know that it is true and you know you directed 23 witnesses not to answer questions like that. ) () 24 MR. FISKE: I am not going to stop now and 25 review the individual circumstances of each b
D 1 Frederick 185 2 objection that was made in each deposition up to 3 now by us or by you. Somehow every time we get 4 into something that -- where we seem to be moving (g) 5 along and making progress, you take the opportunity 6 to relitigate the history of the deposition 7 program in this case, which is all very 8 interesting, but really has nothing to do with 9 what we're trying to accomplish here. 10 MR. SELTZER: If you would not think that 11 it was necessary to castigate me for making 12 objections which you make when you are defending, ) 13 we would move right along. If you would just 14 be businesslike enough to let the objection sit on 15 the record and proceed with your examination, I 16 think we would get along much faster. 17 MR. FISKE: Let's leave it that way and let 18 Mr. Frederick answer the question. 19 THE WITNESS: What is the question? 1 l 20 (R(;.ard read as follows: 21 " Question: In your answer, where you said 9 22 on page 86, 'The training department tasks the 23 operators with waiting and studying the emergency 24 procedures for a cause with the intent of having 25 the operators review them for content, being T
210 1 Frederick 186 (~') \\> 2 current procedures, to see if anything has 3 changed substantially since the last time we 4 used that emergency procedure or the last time ggg 5 we reviewed it,' you were referring, were you not, 6 to the training department at Met Ed?") 7 BY MR. FISKE: 8 Q When you refer to the training department 9 in the answer that begins on line 6, you were referring, 10 were you not, to the training department at Met Ed? 11 MR. SELTZEA: If you recall what you were 12 referring to. O 's y 13 A Since I don't recall having said this, I 14 don't recall what I meant at the time, but in reading 15 the testimony, it seems obvious that I was talking 16 about both B&W and the training department at Met Ed. 17 Q Didthepeo[le at B&W give you operating 18 procedures and ask you to revise them? 19 MR. SELTZER: This says " review them." I 20 don't see the word " revise." Do you see " revise"? 21 Q I am asking a question based on the entire 9 22 answer that you gave here. Is it your testimony that 23 you don't recall now what you were referring to by (-) 24 "the training department"? G/ 25 MR. SELTZER: His answer is what he just
2D 1 Frederick 187 (O _/ 2 said. I think he couldn't have been more clear 3 in responding exactly to your question. 4 Q In other words, the training department gg) 5 refers to both Met Ed and B&W7 6 MR. SELTZER: Let's reread his answer, which 7 I think is unambiguous. 8 (Record read) 9 Q Is it your testimony that when you refer to 10 "the training department," you were referring to both 11 Met Ed and B&W? 12 A My testimony is that I don't recall what I () 13 was referring to, but in reading'the entire answer, not 14 just the first three words, I can see that I was talking 15 about both training departments. 16 Q Even though the answer only refers to one 17 training department? 18 MR. SELTZER: Objection. He said, reading 19 the entire answer, not just the three words, he 20 believes he was referring to both training 21 departments. O 22 MR. FISKE: We'll let your acrJer stand. 23 (Continued on next page) 24 ') a 25 l
1 Frederick 188 2 Q Referring to the answer that you gave at 3 the bottom of the page on page 86, " Question: can 4 you give me the specifies? g 5 " Answer: one goes through training once 6 every six weeks,' and during the training cycles in 7 which we are sent four or five procedures to review, 8 there is usually at least one change that comes out of 9 that or one suggestion." 10 Do you see that answer? 11 A Yes. 12 Q When you were talking in that answer O (,/ 13 about training that you went through once every six 14 weeks, were you talking about training that you 15 received at B&W7 16 A No. 17 Q You were talking about training at Met 18 Ed, were you not? 19 A In that answer, I was talking about the 20 six-week training cycle at Met Ed. 21 Q Going back to the answer that you gave at O 22 page 56 of your Kemeny deposition, the last sentence 23 of the answer that I read before where you said, 24 "We were very involved in the development of the 25 operating procedures for most of the system, the alarm
1 Frederick 189 O 2 responses, and emergency procedures," by "we" in that 3 sentence, were you referring to you and the other 4 Operators? gg) 5 MR. SELTZER: If you can recall. 6 A I don't recall. 7 Q Part of your training at Met Ed was 8 something that has been described as the l l 9 requalification program. 10 A Yes. 11 Q And that was training conducted at Met Ed 12 after you had received your license; isn't that correct? O) (_ 13 A The title "requalification program" { 14 refers to all of the aspects of the training referred 15 to in the Code of Federal Regulations. 16 Q I think we know what is in the Code of 17 Federal Regulations and what is in the FSAR. I am 18 just asking you about the training that you personally 19 received as part of the requalification training i 20 Program, and that program applies, does it not, to a 21 Period of time after you have received a license? O 22 A The requalification training is the 23 training prescribed by the code of Federal Regulations [^)/ 24 that you go through after you obtain your license. C t 25 Q And you obtained your license in the fall I \\ 1
1 Frederick 190 O N.) 2 og 19777 3 A Yes. 4 Q It is a fact, is it not, that the g 5 requalification training that you received from that 6 point on was training that you received at Met Ed? 7 A Part of the requalification program was 8 conducted at Met Ed. 9 Q And part of the requalification training 10 program was a lecture series, was it not? 11 A Yes. 12 Q Involving classroom training? ( 13 A A lecture series and classroom, yes. 14 Q Did you understand that you were supposed 15 to attend those classes? 16 A The requalification program included a 17 requirement to attend or study the material. 18 Q That wasn't my question. 19 MR. SELTZER: I think that was totally 20 responsive. 21 Q Did you understand that you could satisfy O 22 the requirements of the lecture series part of the 23 training program simply by studying the material oct O) 24 of class and never going to class? (., 25 A No.
1 Frederick 191 O V 2 Q You understood you were supposed to go to 3 class; right? 4 MR. SELTZER: Every class? gg) 5 Q You understood that you were supposed to 6 attend as many classes as you could; isn't that correct? 7 Withdrawn. 8 In the classroom training sessions that g you went to, there was training on operating and 10 emergency procedures? l 11 A Are we talking about any of the ~12 requalification training that I ever attended, or are 13 we talking about a specific time period? I 14 Q I am talking about the requalification l 15 training that you received at Met Ed between the time I 16 you obtained your license and the time of the accident. 17 A Did we review operating procedures in that 18 time period? 19 Q Operating or emergency procedures during 20 that time period, yes. 21 A I can't recall the lectures that I actually 9 22 sat through during that time period. 23 Q Is it your testimony that you don't remember (A_) 24 now one way or the other whether you received any 25 such training? i_
1 Frederick 192 O! (_j 2 MR. SELTZER: During the requalification, 3 classroom portion? 4 MR. FISKE: During the approximate year (l) 5 and a half period between the time you obtained 6 your license and the time of the accident. 7 A I remember reviewing and studying operating 8 procedures during that time period, but whether it 9 occurred in the classroom or not is what I don't 10 recall. 11 Q And the same is true of emergency 12 procedures? () 13 A Yes. 14 (Discussion off the record between the 15 witness and his counsel.) 16 Q Did you know during this period of time 17 that it was important thit you understand the procedures 18 and know how to use them? 19 A Yes. 20 Q Did you know that it was important that the 21 procedures -not be confusing or difficult to apply? O 22 MR. SELTZER: Was that something that was 23 important to Mr. Frederick? (- 24 MR. FISKE: Yes. (_) 25 A I think I had an understanding that it was l
1 Frederick 193 [) N- ) 2 good to have procedures that were usable and readable. 3 Q And you understood, did you not, that it l 4 was important that they not be confusing? lll 5 A I don't remember thinking about that. 6 Q You never thought at any time before the 7 accident about whether it made any difference to you 8 whether the procedures were confusing or not? 9 MR. SELTZER: You are asking him, did he 10 formulate that thought before the accident and 11 can he recall it today? Is that right? 12 MR. FISKE: Yes. 13 Q At any time before the accident,'did you 14 think it was important that the procedures not be 15 confusing? 16 MR. SELTZER: I think we can agree today 17 that is a very logical proposition. I think what 18 is relevant is whether he recalls having l 19 thought about that before the accident, and he i 20 already told you, sitting here today, he can't 21 recall having thought about that. Maybe he did, 22 maybe he didn't. What more can be said on the 23 subject? [GD 24 Q Are you going to stand on that answer? 25 A Yes.
1 Frederick 194 (~h U 2 Q Did you understand from your training 3 at Met Ed that if there was something about the 4 procedures that you felt at the time was confusing lll 5 or that you didn't understand, that you had an 6 obligation as an operator to call that to the attention 7 of the other people at Met Ed? 8 A I understood that if I had a question, 9 I could ask for clarification. I think I always had 10 that understanding. If I was confused on a point or 11 didn't understand something, I could always ask for a 12 clarification. I') \\ 13 Q Beyond that, if you felt that something 14 was confusing in the procedure, didn't you understand 15 that it was important that you bring that to the 16 attention of other people at Met Ed so that that 17 confusion could be eliminated for the benefit of 18 other operators as well? 19 A No, I don't think that I would have 20 assumed that my confusion or inability to understand 21 would have been translated to everybody else. If 22 I didn't understand something, I would seek to 23 clarify that for myself rather than initiating a () 24 change. 25 Q Did you understand before the accident
Frederick 195 (~\\ U 2 that if you felt a procedure was wrong, that you had 3 some obligation to tell that to somebody else at 4 Met Ed? lll 5 A If I came to the conclusion that there was 6 a mistake, yes, I would feel that I had to tell it 7 to somebody. 8 Q Did you feel that if you felt that a 9 procedure was inadequate for any reason that you should 10 tell that to somebody at Met Ed? 11 M R. SELTZER: What do you mean by 12 " inadequate"? 13 MR. FISKE: I think it is a term of common 14 usage. I don't think I have to define it. 15 MR. SELTZER: Do you understand what his 16 question means when he refers to a procedure 17 that is inadequate? 18 THE WITNESS: I understand my definition 19 of the word " inadequate" and I can answer in 20 those terms. 21 A I think I had an understanding that if I 22 found a procedure was inadequate or inaccurate, I l I 23 would bring that to someone's attention, probably my [)D l 24 direct supervisor. N, 25 g who was your direct supervisor during this l l
1 Frederick 196 O 2 period of time between the day of your license and 3 the day of your accident? 4 A I had several different supervisors, g) .5 because I had several different shift assignments 6 during that period of time. 7 Q What sort of generic position was held 8 by the person that was your supervisor? 9 A The shift foreman. 10 Q On the day of the accident, that would 11 have been Mr. Scheimann? .12 A Yes. 13 Q For how long had Mr. Scheimann been your 14 direct supervisor? How long before the accident had 15 he been your direct supervisor? 16 A I don't recall the period of time. 17 Q Isn't it correct that the format of the 18 emergency procedures was to set forth certain symptoms 19 of a particular condition and then follow that with 20 actions that the operators should take to correct the 21 particular condition? 22 A No, the symptoms were not symptoms of a 23 particular situation. They were parameters or board /~l 24 indications that might result from a partictlar failure, L) 25 but not limited to that single particular failure.
1 Frederick 197 3(V 2 Q I guess what I am trying to get at is 3 there were a specific number of emergency procedures: 4 correct? h 5 A There were a specific number of emergency 6 procedures? 7 Q Yes. There was a defined number of them. O MR. SELTZER: You mean there couldn't be 9 more than a certain number? 10 Q On the day of the accident, how many 11 emergency procedures we re in effect? 12 A I don't know. 13 Q During this period of time that you were 14 going through this requalification training and 15 studying both operating and emergency procedures, 16 based on the work that you did there, what 17 understanding did you have at the time of the accident 18 as to how many different emergency procedures there 19 were? 20 A I never counted them. There are several 21 dozen. 22 Q Emergency procedures? j 23 A Yes. You have only made a classification 0-/ 24 of operating and emergency procedures, where in 25 actuality there are operating, abnormal and emergency
1 Frederick 198 (V) 2 procedures, and the emergency plan, and those are all 1 3 the operating and emergency procedures I am thinking 4 of. lll 5 Q My questions all the last few minutes 6 have been confined to emergency procedures. 7 A Does that exclude 8 Q You understand the difference between an 9 emergency procedure and an operating procedure? 10 A Yes, I do. 11 Q And the difference between an emergency 12 procedure and an abnormal procedure? O\\_) 13 A I can't say that I ever had a clear 14 understanding what drew the line between an abnormal 15 procedure and an emergency procedure. 16 Q My question is, on the day of the accident, 17 what understanding did you have as to how many different 18 emergency procedures there were? 19 A A few dozen. 20 Q Are you including in that few dozen 21 abnormal procedures, or is that something separate? 22 A I am including abnormal procedures 23 because they were grouped into the binders that we O) 24 call the emergency procedure books, so I kind of ( 25 lumped them all together.
1 Frederick 199 Ob 2 Q What did you understand was the difference 3 between an emergency procedure and an operating 4 procedure? lll 5 A An operating procedure is used to give 6 guidance to the operator during the normal operation 7 of the plant. An emergency procedure is used to give 8 guidance to the operator in a situation which is not 9 covered in the normal operating procedures. 10 Q As of the day of the accident, had you told 11 Mr. Scheimann or anyone else at Met Ed that you felt .12 any of the emergency procedures were confusing or O k-13 difficult to apply? 14 A I don't recall a discussion of that 15 nature with Mr. Scheimann. 16 Q Did you tell that to anyone else at Met Ed? 17 A I don't recall a discussion of that nature, 18 no. 19 Q As of the day of the accident, had you 20 told Mr. Scheimann or anyone else at Met Ed that any 21 of the emergency procedures were either wrong or 22 inadequate? 23 A I may have done that during the review () 24 of the procedures, but I don't recall having a 25 discuss ion like that.
1 Frederick 200 O V 2 Q Do you have a specific recollection of 3 having made a comment to anyone at Met Ed with 4 respect to any particular emergency procedure that lll 5 you thought was wrong or inadequate? 6 A No. 7 Q As of the day of the accident, did you 8 have in your mind the knowledge that you had made 9 such a comment with respect to any emergency 10 procedure which had not been acted on to your 11 satisfaction? 12 A I generally recall having input, making O) (' 13 comments, but I don't specifically recall the 14 comments I made or what procedures I may have 15 commented on. 16 Q I understand you said that before. My 17 question is as of the day of the accident, did you 18 have an understanding at that time that you had made 19 such a comment with respect to any particular emergency 20 procedure which had not been acted upon and resolved 21 to your satisfaction? 22 A I guess that is my difficulty. Since I 23 don't recall making the conments, I don't recall if I () 24 had any outstanding comments. 25 Q Geing back to this discussion that we were
1 Frederick 201 O V 2 having earlier with respect to the organization 3 of the emergency procedures, what did you understand 4 was the pu,rpose generically of that portion of the (l) 5 procedures that described symptoms? 6 A If a parameter or an indication was being 7 presented on the panel which was out of the bounds of 8 the normal operating procedure, the symptoms of the 9 emergency procedures were used to try and identify 10 the failure or the problem which might be causing that 11 particular symptom. .I2 Q So is it a fair sort of general statement p) (_ 13 that a purpose of the symptoms part of the procedures 14 was to help you identify what the problem was? 15 A No, using the symptoms may not help you i 16 decide what the problem is. It may only help you 17 characterize it as treatable using that procedure. 18 Q But before you could treat it, you have to 19 know what it is; correct? 20 A Not in the bounds of the emergency 21 procedures. For instance, if a turbine trip occurred, 9 it would not be "ecessary to identify the cause of 22 n 23 the turbine trip in order to use the emergency 24 procedure. K-25 Q I understand that, but the problem. 3
i 1 Frederick 202 V('% 2 that you are treating with the application of the 3 emergency procedures at that point is the turbine trip 4 itself, not what caused it. lll 5 MR. SELTZER: In other words, you have to 6 identify that you had a turbine trip and then 7 you would apply the turbine trip procedure; right? 8 THE WITNESS: Yes. I thought that the 9 question was, would the emergency procedure 10 help you find the problem, and r.f answer was no. 11 Q You used the word " problem" in an earlier 12 answer, and I thought we were talking about the same O 13 thing when we referred to problem, but I think Mr. 14 Seltzer has been helpful in straightening that out. 15 A Good. 16 Q Going back to where we were before, is 17 it fair to say that the purpose of the symptom part 18 of the procedure was to help you identify what the 19 problem was that would be treated by the action part 20 of the procedure? 21 A The symptoms were used to put a label l 22 on the situation so that it could be treated with a 23 procedure that had been written. That is what they O 24 were for. (_j 25 Q Lets use your word " label". You had a l
1 Frederick 2 G3 O 2 number of different emergency procedures as you have 3 described, each one of which prescribed separate 4 courses of action to be taken to correct various types 5 of problems; isn't that correct? 6 MR. SELTZER: Maybe to correct situations 7 or to respond to situations would be a more 8 generic way to refer to it. 9 A Yes. 10 Q But before you could know which course of 11 action to follow, you had to know what the condition 12 was that you were supposed to be treating; isn't that O 13 correct? 14 A Yes. 15 Q In other words, there were a wide variety 16 of possible transients that could require the 17 application of emergency procedures; isn't that 18 correct? 19 MR. SELTZER: When you say "in other 20 words," are you suggesting that that follows 21 from his prior answer? 22 MR. FISKE: Strike the "in other words." 23 (Record read.) ()\\ 24 A Yes. 25 Q And the prescribed course of action was
1 Frederick 204 [\\> 2 different for different transients, was it not? 3 A I find it difficult to answer that in a 4 general way. Different transients may result in the lll 5 same actions, depending on what transients you are 6 talking about. 7 Q I am not trying to make it any more 8 complicated. I am trying to make it as simple as I 9 can. 10 MR. SELTZER: I think you are 11 oversimplifying it in some cases. .12 Q I am not suggesting that every single Ch (_) 13 transient had a unique prescribed course of action 14 that may have applied to it alone and none of those 15 prescribed actions were applicable in any way to any 16 other transient. I am simply saying that generically 17 the fact is that as of t'he day of the accident, 18 you knew that there were a number of different possible 19 transients which could occur; isn't that right? 20 A Yes. 21 Q And that there were emergency procedures 22 written to deal with those transients; isn't that 23 correct? l /~D 24 A The emergency procedures were written to 'd 1 25 deal with a certain set of transients, not saying that l l
1 Frederick 205 /~T U. 2 there was a procedure for every transient. 3 Q The procedures prescribed particular steps 4 that the operators should take in dealing with the h 5 transient; isn't that correct? 6 A If the transient is identified as 7 applicable to that procedure, then there are steps 8 that the operators should take. 9 Q So that before the operator can know what 10 steps to take, he has to know what transient he is 11 dealing with; isn't that correct? 12 A Yes. 13 Q And was the symptoms part of the procedures 14 designed to help the operators make the diagnosis 15 of what particular transient they were dealing with? 16 A The symptoms were designed to be used as 17 an aid in the process which the operator would go 18 through to put a label on that particular transient 19 in conjunction with the other information available 20 to him. 21 Q And the symptons themselves were contained 22 in the same set of procedures that contained the 23 prescribed course of action; isn't that right? m[b' 24 A There were symptoms and actions in each 25 emergency procedure.
1 Frederick 206 O 'V 2 Q My question is, how did you understand on 3 the day of the accident when a particular set of 4 conditions occurred in the plant you were supposed to ) lll 5 determine which procedure to use? 6 MR. SELTZER: Are you withdrawing that 7 question? 8 MR. FISKE: No, I want to make sure that 9 Mr. Frederick understands what I am asking. 10 Q In the course of the training you had at ~ 11 Met Ed in this period of time going right from the 12 beginning right up to the accident, when you were 13 discussing the use of emergency procedures, what were 14 you told as to how, when you saw a set of conditions, 15 you would determine what procedure you would pull 16 out? 17 A The process would be to observe the panel 18 and the indications and note as many off-normal 19 parameters as possible, and using the knowledge of the 20 systems and the experience gained from using the i 21 procedures in the past, try to identify the procedure 22 by memory which contained the largest number or the l 23 most significant parameters as symptoms for an l (- j 24 emergency procedure, and then make a preliminary () 25 attachment of the label in that emergency procedure i
1 Frederick 207 g 2 to the transient that was ocenrring, waiting as the 3 transient progressed to see if other indications 4 might lead you to believe that another emergency lll 5 procedure might be applicable at the same time. 6 Q I take it that all of these procedures 7 were in the control room at all times; isn't that 8 right? 9 MR. SELTZER: Emergency procedures you 10 are referring to? 11 MR. FISKE: Yes. 12 A Generally speaking, the emergency procedures I 13 were available at all times. 14 Q Didn't you understand that it was very 15 important that the emergency procedures be available 16 at all times in case of an emergency? 17 A Yes. In fact the only time that they were 18 momentarily unavailable was when they were being updated 19 or revised by the secretary who was not allowed in the 20 operating arena. 21 Q And the emergency procedures were all in O 22 the control room on the day of the accident, were 23 they not? () 24 A I would be surprised to find out that one 25 or two were missing, yes.
I Frederick 208 2 MR. SELTZER: It hasn't come to your 3 attention since the accident that any were missing? 4 THE WITNESS: No. llh 5 Q In all the time that you were being trained 6 on these procedures, did you ever express the view 7 to anybody that there ought to be a better system for 8 identifying which procedure to apply than having to 9 memorize the symptoms? 10 A I can remember having the thought while 11 I was trying to memorize the emergency procedures that .12 there might be an easier way to do it, but I don't O(/ 13 ever remember coming up with a better solution. 14 MR. SELTZER: Do you ever remember 15 suggesting to anybody that there ought to be a 16 better procedure, is his question. 17 THE WITNESS: No. 18 (lunch recess taken at 12:30 pm) 19 20 (g> 22 A 24 t i \\m/ 25 1
1 Frederick 209 ~5 (0 2 Q I would like to review with you the 3 training that you had had from the time you started 4 at Met Ed right up to the time of the accident, and llk 5 I would like to have you take a look at enclosure 1 to 6 the letter that you sent to Mr. Collins in support 7 of your application for reactor operator's license 8 examination. 9 Do you have that in front of you? 10 A 645, yes. 11 Q I think you told us before that enclosure 1 12 refers to the training that you had after you became O 13 employed by Met Ed up to the time that you took your 14 examination for operator's license. 15 A Yes, this is a general outline of that 16 training. 17 Q And that covers, does it not, the period 18 of time from March 1974 through August 19777 19 A Yes. 20 Q I would like to go through this exhibit 21 with you briefly. 22 Paragraph No. 1 refers to " Auxiliary i 23 Operator A-Nuclear Training Program. " That is ) 24 March 4, 1974 to August of 1974. 25 Do you see that?
1 Frederick 210 /N 2 A Yes. '3' Q That was conducted at the Island, was it 1 s l 4 not? l h 5 A Yes. 6 Q And that is how many hours? 7 MR. SELTZER: It says 1040. \\ r 8 Q Is that accurate, that you received 1040 g4 hours of training at the Island in the auxiliary 10 operator A-Nuclear training program? 11 A I think so. 12 Q The next paragraph says " Unit 2 Control O h_) 13 Room Operator's Training, August 11, 1975 to s 14 November 28, 1975." The description of that is 15 600 hours of on-site classroom training and 40 hours 16 for instruction and operation of Penn State University 17 reactor. 18 Do you see that? N - e 19 A Yes. 20 Q Is it correct that the 600 hours of t l \\ 1 21 on-site. classroom training referred to in that I O 22 paragraph were conducted at the Island? 23 A Yes, I think so. [ ]N Q The next paragraph is " Unit 2 Cold License 24 Q. l 25 Pre-dimulator Training Program, March 1976 to April s k i b
i t' Y I ll Frederick 221 ()r '1 (_ 2 l 1976," referred to as 80 hours. l 3 Do y u see that? 4 A Yes. I 5 Q Where was that training program conducted? O 6 A It doesn't indicate here where it was, but 7 I think that was at the Island also. 8 Q Paragraph,4 refers to " Unit 2 Cold 9 License Simulator Certification Training," 320 hours 10 during the period April 1976 through July 1976, and 11 it says this eight-week course was conducted by Be.bcock 12 & Wilcox at their Lynchburg, Virginia simulator (O 13 training facility. w) I 14 Is that accurate? i 15 A Yes. i 16 Q So that 120 hours was at Lynchburg, right? 17 A Yes. 18 Q Paragraph 5 says " Unit 2 Cross-Licensing 19 Traisiing," that refers to the period 1976 20 MR. FISKE: Does that say 9/13/76 21 MR. SELTZER: Yes. 22 MR. FISKE: -- through 3/31/767 i 23 MR. SELTZER: Yes. l 24 0 100 hours? 7- \\ '\\j l 25 A Yes. I I
I Frederick 212 (-U 2 Q should that have been 3/31/777 3 A I would think so, yes. 4 Q And that refers to 100 hours of formal lll 5 classroom instruction on Unit 2 systems. Was that 6 formal classroom instruction conducted at the Island? 7 A I think so. 8 Q Paragraph 6 says " Unit 2 OJT Program," 9 December 1, 1976 through August 1, 1977, approximately 10 300 hours. 11 Does OJT stand for "on-the-job training"? 12 A Yes. 13 Q was that 300 hours of on-the-job training 14 conducted at the Island? 15 A I think so. 16 Q Paragraph 7 refers to a turbine controls 17 training course of 20 hours conducted at the Island 18 by Westinghouse stressing operation of the AEH 19 turbine controls and turbine operation. 20 was that 20 hours conducted by Westinghouse 21 at the Isl an d? 22 A Yes. 23 Q Paragraph 8 refers to the Unit 2 /O (,/ 24 standardized toch spec training program, 40 hours, 25 from May 1977 to -- 40 hours in the month of May 1977. l
i l l 213 i Frederick { ') \\'-) 2 Was that course conducted at the Island? 3 A The course including all that under No. 8? 4 Q Yes. h 5 A Yes. 6 Q Paragraph 9 refers to a one-week simulator 7 training program from June 6th to June 10th, 1977 of 8 40 hours at Babcock & Wilcox's facilities in Lynchburg, 9 Virginia. The enclosure says you will have completed 10 those. I take it you did in fact complete that week? 11 A Yes. 12 Q That 40 hours was at Lynchburg? f~% k-13 A Yes. 14 Q And paragraph 10 refers to a pre-simulator 15 review course conducted after the 40 hours of training 16 at Lynchburg from July 18, 1977 to August 12, 1977, 17 an 80 hour program, and it says you will have completed 18 that two-week review course before your testing date. 19 MR. SELTZER: I wonder if that should 20 be post-simulator review course. 21 Q In fact, you did complete this two-week O 22 review course after you came back from Lynchburg, did 23 you not? I) 24 A That is what the dates indicate. I think \\J 25 that is what it was, too.
l 1 Frederick 214 (_ 2 Q Then you discussed before lunch the 3 requalification program that was conducted by Met Ed 4 after you received your license. Can you tell us lll 5 how many hours of requalification training you 6 participated in between October 1977 and the day of 7 the accident? 8 A No, I can't. 9 Q Did you understand that you had to renew 10 your license every two years? 11 A Yes. 12 Q And that it was necessary in order to 13 apply for a renewal of your license that you 14 demonstrate that you had completed a requalification 15 training program? 16 A Yes, and perha,7s I should clarify by saying 17 we completed a requalification program every year 18 rather than just as required every two years. We 19 actual 1y did it every year. 20 Q Part of that requalification program was 21 something called the " Operational Review Lecture 22 Series"? Did you ever hear of that? 23 A I don't recall that title offhand. () 24 Q I am reading to you now from the FSAR 25 filed with the NRC by Met Ed in order to obtain
1 Frederick 215 gU 2 an operating license at Unit 2. 3 MR. SELTZER: It is a description of 4 that course in that FSAR. ll) 5 MR. FISKE: Yes. 6 Q Section 3.2.2.2.1 refers to an operational 7 review lecture series. It says " Lectures shall be B held on a continuing basis and consist of a minimum 9 of 60 scheduled hours per requalification program 10 cycle." 11 Do I understand from your previous -12 testimony that at Met Ed that requalification program 13 cycle was completed every year? 14 A The 60 hours of lecturing? 15 Q Yes. 16 A I know -- what I meant was we took an 17 exam every year. I don't know if we I don't know 18 how many hours of lecture we had each year. 19 Q Did you participate between October 1977 20 and March 1979 in a requalification program lecture 21 series which covered, among other topics, reportable O 22 occurrences, operating history and problems, procedure 23 changes, abnormal and emergency procedure review? O \\ 24 A Yes. %J j 25 Q Did you in fact spend a minimum of 60
1 Frederick 216 (~% (_) 2 hours in that program between October 1977 and March 3 19797 4 A I can say I don't remember being notified gg) 5 that I was not attending enough lectures. I think 6 that I attended the lectures I was supposed to 7 attend. 8 Q And those lectures were conducted on the 9 Island? 10 MR. SELTZER: Could we see the FSAR? 11 MR. FISKE: Sure. 12 A I have a much greater understanding of (,() 13 this type of procedure now in the training department 14 and I know we are allowed to use classroom lectures 15 no matter where we get them from. In counting 16 this 60 hours, I don't know whether we bring in Penn 17 State or other contracto'rs or even use the time 18 down at Lynchburg for some of that time. 19 Q I am asking you for your recollection of 20 what your training was before the accident. I am not 21 asking you what improvements may have been made to O 22 that since the accident. What I am asking you is, 1 23 isn't it a fact that you yourself participated at S 24 the Island in at least 60 hours worth of training \\) 25 under the program that we have just been referring to,
1 Frederick 217 [) 2 this operational lecture series on the various topics 3 that I just read for you? 4 A No. I am not trying to describe an ll) 5 improvement to the training program. I am trying to 6 relate to you the only understanding I have of this 7 minimum 60 hours. 8 Q But I am asking you what you yourself did 9 in that program before the a c e'i de n t. 10 A I think I stated I don't recall how many 11 lectures I attended. The maintenance of the .12 attendance records and the number of hours attended 13 wasn't my job. I only had to report when I was 14 present. Then I would be notified if something was 15 wrong. 16 Q Nobody ever told you you didn't complete 17 that program? 18 A That's right. 19 Q The FSAR also refers in section 20 13.2.2.2.2 to an additional program called the 21 " Fundamentals and System Review (PSR) Program," which i 22 is also described as part of the continuing i 23 requalification program conducted by Met Ed, and the (a') 24 FSAR states that this program may consist of 25 preplanned lectures, self-study assignments, possible
1 Frederick 218 /T N-2 tutorial sessions with designated technical 3 instructors and evaluation quizzes. 4 Do you remember participating in that lll 5 program, that part of the requalification program 6 before the accident? 7 A No, my undarstanding of this program has 8 something to do with the written examination, and 9 the subsequent evaluation of the grades that you 10 obtain in your early evaluation would determine whether 11 or not you had to participate in this program. I 12 don't at this time remember if I participated in this 13 section of the program. 14 Q The next section of the FSAR, 12.2.2.3, 15 refers to on-the-job training and it says during the 16 two-year term of the license, each licensed operator 17 shall participate in on-the-job training, which has 18 the goals listed in the FSAR. 19 Did you participate in that on-the-job 20 training program? 21 A I recall doing some of these things, 22 yes. 23 Q And you did that at the Island, did (~)T ( 24 you not? 25 (continued on the next page.)
1 Frederick 219 (3 k_) 2 A No, I think in looking at part A, I 3 think we did that. I think we either did that at Penn 4 State or at Lynchburg. I remember having to fill out ll) S paper work at Penn State once and I think also at 6 Lynchburg. We had done some evolutions that 7 constituted reactivity manipulations. 8 Q Are you now testifying that you conducted l 9 that kind of computation at Lynchburg at some point 10 after you obtained your license? l 11 A I don't have a recollection of the actual l l l 12 attendance dates at Lynchburg or I think Penn State (_) 13 you showed me when I attended that. My understanding } 14 is that I either attended simulator training or was 15 scheduled to attend in each requalification year from 16 the time I started my training right up until the 17 accident and that is all I am basing my answers on, 18 my recollection. 19 Q But you have no better recollection this 20 afternoon than you did yesterday morning on whether 21 in fact you ever went to the simulator after you 9 22 obtainedyourlibense? 23 A No, I haven't gone back to look at any ,A 24 documents about that. ( ) s-25 (Continued on the next page.)
l 1 1 Frederick 220 q 2 Q Isn't it a fact that out of all the training 3 that you received after you became an employee of Met 4 Ed, only 360 hours of training was conducted at lll 5 Lynchburg and the balance of that training, consisting 6 of significantly more than 1500 hours, was conducted 7 at the Island? 8 MR. MacDONALD: You are asking for his 9 understanding prior to the accident, not just to 10 look at the document and tell you his present 11 understanding? 12 Q I am asking, isn't that a fact, as of today, O(_- 13 that of the training that you had received prior to the 14 accident, only 360 hours of that training had been at 15 Lynchburg, and that significantly more than 1500 hours 16 of training had been conducted by Met Ed at the Island? 17 MR. MacDONALD: Based on your understanding 18 and your recollection of your understanding. 19 A Looking at the totals on these hours on 20 this sheet, that is an approximation of the hours, yes. 21 Q Going back to the subject we were talking 22 about before lunch, we were talking about the i 23 emergency procedures. I think you testified that you f')T 24 understood before the accident that there might be x._ 25 transients for which there was no emergency procedure,
2 1 Frederick 221 C 2 is that correct? 3 MR. MacDONALD: You are asking what his 4 testimony was or are you asking that as a new ll) 5 question? 6 Q Isn't it a fact that you understood before 7 the accident as you were going through training on l 8 procedures that there might be transients for which l l 9 there was no emergency procedure? 1' 10 A I think that I had thought about that prior 11 to the accident. '12 Q What did you understand you were supposed 13 to do if you were confronted with a set of conditions 14 that was not covered by any procedure? 15 MR. SELTZER: Did you say what, if anything? l 16 MR. FISKE: No, I just said what did he l 17 understand he was supposed to do? 18 MR. SELTZER: I object. No foundation that 19 he had an understanding of what he was supposed 20 to do. 21 Q If you want to testify you understood you O 22 were supposed to do nothing, that is fine. 23 MR. SELTZER: I don't think that is the only p) (_ 24 alternative. 25 MR. FISKE: Read back the question. h
l 1 Frederick 222 Ok-) 2 (Record read) 3 A I don't recall having been given specific 4 instructions on how to deal with an unknown casualty lll 5 even in the very intensive training we received on 6 emergencies at the simulator. 7 Q Let me read you a question and answer from 8 your Kemeny deposition, reading from page 321. 9 " Question: Was there much attention or 10 any attention given to that in the training generally 11 in the sense that as a control room operator, you may 12 run into a situation where you don't have an emergency 13 procedure and you will not be able to follow a procedure? 14 " Answer: Yes. That is the underlying reason 15 for the detailed study of all the systems. If you 16 just had to memorize procedures and use them to react 17 to symptoms, then there'wouldn't be any need to 18 understand how the system worked other than how to 19 present it on the control panel. The whole idea is to 20 have a sufficiently detailed knowledge so in the event 21 something occurs that is completely foreign, you can 22 use your knowledge of the intricacy of the system to 23 figure out what is going on." (~] 24 were you asked that question and did you NJ 25 give that answer in the deposition which you gave to
1 Frederick 223 2 the President's Commission? ,g A Yes, I think so. 4 I would like to continue with my answer, ll) 5 if I may. 6 Q The only question is whether you were asked 7 that question and gave that answer. 8 MR. SELTZER: The questions and answers go on 9 to ask,"How would that be done in training 10 specifically? How would that issue of dealing 11 with a situation not covered by procedures be ~12 addressed in the training program? OV 13 " Answer: I don't know that that is 14 specifically addressed." 15 MR. FISKE: That is fine. 16 "I am just saying the basic concept is to 17 know as much as you can in case you get in a 18 situation where you don't know exactly what is 19 going on. 20 " Question: So what you are saying is that 21 the general study, the general familiarization, 9 i 22 general efforts to understand how the system 1 1 l 23 worked is designed in your view to equip you for D. l (,) 24 that eventuality? 25 " Answer: Yes." l
1 Frederick 224 [) (/ 2 BY MR. FISKE: 3 Q Were you asked those additional questions 4 and did you give those answers in the deposition to the lll 5 President's Commission? 6 A I think I missed where you were reading 7 from. 8 Q I was continuing on what Mr. Seltzer started g reading. The next two questions and answers after the 10 ones I read first. 11 Were you asked those questions and did you 12 give those answers? O) (_ 13 A Yes, I was asked those questions and gave 14 those answers. 15 Q I would like to ask you whether in your 16 training with respect to the procedures, did you 17 understand that -- if you want to go on reading your 18 testimony, that is okay. I don't want to ask questions 19 while you are also trying to read. 20 A I can forgo that for now. 21 Q In the training that you had on the O 22 procedures, did you understand that if a set of 23 conditions occurred which were covered by a procedure, {~T 24 that under those circumstances you should follow the ~> 25 procedure?
1 Frederick 225 iV 2 A Yes, I understood that if an occurrence 3 could be identified as having relation to a given 4 procedure, that that procedure should be applicable. lll 5 Q In other words, if symptoms occurred that 6 were covered by a particular procedure, then you were 7 required to take the action prescribed in that procedure? 8 A No. 9 Q Did you feel free to disregard the procedure 10 if you felt like it? 11 MR. SELTZER: You mean under a situation 12 where the situation that was occurring matched (~h \\-) 13 the symptoms in the procedure? 14 MR. FISKE: Yes. 15 Q Did you feel that you could ignore the 16 procedure? 17 MR. SELTZER: In other words, why did you 18 say no to his last question? 19 A The question was if a symptom occurred that 20 was in a procedure, should you use that procedure to 21 deal with the symptom? Is that correct? 22 g
- yes, j
23 A The answer is no. [ )) i 24 MR. SELTZER: Why? c 25 THE WITNESS: The answer is no, because
1 Frederick 226 O) R- \\ 2 that particular symptom or group of symptoms may 3 appear in several procedures. The job is to 4 continue to observe and look for more information lll 5 that will help you to identify or label that 6 particular occurrence as being treatable by an j 7 individual emergency procedure or a group of l 4 emergency procedures. l g BY MR. FISKE: 10 Q Let me put the question, just to make it a l 11 little more clear what I am talking about. 12 Once you saw certain conditions in the plant ) 'd 13 that were set forth as symptoms of a particular 14 condition and there was a procedure identifying those 15 symptoms as symptoms of that condition and also action j 16 that was required, the action to be taken to deal with 17 that condition, did you feel you were free not to 18 apply that procedure? 19 A If I was not sure that those symptoms were i 20 leading me to that action, yes, I felt free not to 21 follow that procedure. 22 (continued on next page) 23 Ix_J 24 l i 25 l
tF 1 Frederick n 227 j 2 Q Is it fair to say that be fore you would 3 make a decision not to follow the procedure, 4 you would have to be convinced that the symptoms ll) 5 we re not indicating the condition covered by that 6 procedure? 7 A I think the negatives, the series of l 8 negatives in that question is confusing me. l 9 Q Let's say you have a procedure that 10 says if conditions A, B and C are symptoms of a 11 condition D; you see symptoms A, B, and C, did you '12 g not take the action prescribed to correct condition d 13 D without being sure that symptoms A, B, and C were 14 attributable to something other than condition D? 15 A I think if all of the symptoms in that 16 procedure being A, B, and C showed up, and there 17 was no confusion that those A, B, and C plus a 18 few others were in another procedure, then if A, B, l 19 and C showed up, then I would feel that would be the 20 right procedure to use if all of them were there. 21 Q Let me show you the station 22 administrative procedure 1001 for Unit 2 which has 23 been previously marked as B&W Exhibit 237. O i) 24 s I would like to direct your attention 25 to paragraph 3.8.3 which appears on page 21.2.
F 1 Frederick 228 \\/ 2 " Procedural Deviation Limitations. 3 "1. Deviations from written procedures 4 may not be made exceot in emergencies. In emergencies," lll 5 underlined, " operations personnel are authorized to 6 depart from approved procedures where necessary to 7 prevent injury to personnel including the public 8 or damage to the facility. Such changes shall be 9 documented, and as appropriat e, incorporated as socn 10 as possible in the next revision of the a f fe cte d 11 p ro c e du re. Documentation shall consist of at least 12 describing the deviation in the control room O k-13 operator's or shift foreman's log book." 14 Were yois aware of that requirement of 15 the administrative procedures for Unit 2 at the 16 time of the accident? 17 MR. SELTZER: You read several 18 requirements. Which one are you talking about 19 in your question? 20 MR. FISKE: The requirements that I just 21 read. 22 MR. SELTZER: All of them. You are 23 asking him if he was aware of 3.8.3 sub 17 24 MR. FISKE: Yes, if he wants 25 MR. SELTZER: I am just asking what your
1 Frederick 229 2 question is. 3 MR. FISKE: The one I asked. 4 A I would like to have the question back. lll 5 g on the day of the accident, were you 6 aware of the requirements of the sta tion 7 administrative procedure that I just reed to you? 8 A Yes. 9 (Discussion off the record between the 10 witness and his counsel.) 11 Q I show you a document which has been 12 marked as B&W Exhibit 272 which is a loss of reactor O) (_ 13 coolant / reactor coolant system pressure emergency 14 procedure for Unit 2. 15 were you f amiliar with that procedure 16 before the accident? 17' A Yes. 18 Q This procedure is divided into Part A 19 and Part B, is it not? l l 20 A Yes. l 21 Q Part A refers on page 1 to a leak or a 22 rupture within capability of system operation, and 23 Part B on page 6 refers to a leak or rupture of (~) 24 cignificant size such that engineered safety I V 25 features are automatically initiated. l Isn't that correct?
1 Frederick 230 0 2 A Yes. 3 Q Directing your attention to Section B, 4 the first part of that is section 1.0, it says, lll 5 " Symptoms." 6 Do you see that? 7 A Yes. 8 Q Then there are eight separate 9 subparagraphs underneath " Symptoms." 10 A Yes. 11 Q Did you understand that those eight 12 paragraphs licted various symptoms of a leak or hi x/ 13 rupture of the type described in heading B7 14 A Yes. 15 Q Did you understand in attempting to 16 diagnose a transient that was in progress that the 17 list of symptoms referred to in this procedure should 18 be re ferred to as an aid to determining whether or 19 not the transient involved was one which met the 20 description in paragraph B? 21 A I understood that these symptoms O 22 were part of the process we used to decide which 23 emergency procedure you were in, yes. ) 24 Q Wasn't it your understanding be fore r 25 the accident that it was not necessary to have all
I Frederick 233 ['\\ U 2 eight of those symptoms in order to make a 3 determination that you did have a leak or rupture 4 of the size described in paragraph B7 lll 5 A No, it was my understanding that if you 6 had a leak or rupture as described in Section B 7 chat eventually all these symptoms would be made 8 evident on the panel. 9 Q As you understood it, you were not 10 allowed to make a diagnosis that you did have such a 11 leak and take the action prescribed to deal with such .12 a leak until you saw all eight of those symptoms? O \\- 13 A No, but I understood that you should 14 see enough of these symptoms to convince you that you 15 should use this procedure before you took any 16 action. 17 Q Going through these symptoms one by one, 18 No. 1.1 re fe rs to a rapid continuing de crease of 19 reactor coolant pressure, and then it refers to a 20 low alarm, a low, low alarm, and then safety 21 injection actuation at 1640. O 22 Why did you understand that a rapid 23 continuing decrease of reactor coolant pressure /~T 24 leading to those alarms and the actuation of HPI () 25 was a symptom of a leak or rupture described in
g Frederick 232 7 2 paragraph B? 3 A I just understood that those symptoms 4 listed there as 1, 2, and 3, under 1.1 would be lll 5 some of the things you would see as a result of a 6 loss of coolant inventory. 7 Q I understand that is what the procedure 8 says. 9 I am asking you what was your 10 understanding going beyond just the phrase of 11 the procedure, going to your understanding of how 12 the system worked, what was it about the fact that O) (_ 13 pressure dropped to the point where HPI came on 14 that would be an indication that there might be 15 a loss of coolant accident? 16 MR. SELTZER: You mean in what way would 17 that symptom be consistent with a loss of 18 coolant accident occurring? 19 Q Why did you understand that that 20 was a symptom of a LOCA other than the fact that 21 the procedure said so? 22 A I did not conclude from these symptoms 23 or from my training that a safety inj e ction ( 24 actuation was a symptom of a LOCA. That it 25 indicated that a LOCA was occurring.
1 Frederick 233 ps d 2 (Diccussion off the record.) 3 BY MR. FISKE: 4 Q In light of the colloquy that you have g 5 been having with Mr. Seltzer, do you want to 6 supplement the answer to the last question or change 7 it? 8 MR. SELTZER: Or hear the question 9 again? 10 MR. FISKE: Sure. 11 (Record read back.) 12 MR. SELTZER: You mean a loss of coolant 13 accident of the type B variety, right? 14 MR. FISKE: Yes. 15 A Other than the fact that the procedure 16 says that it is a symptom, I understood through the 17 workings of the system, the RCS system and the 18 high pressure injection system, that it would come on 19 when you had a severe LOCA. 20 Q Did you understand why that would happen? 21 A The purpose of starting up the safety 22 injaction system on a large rupture like that is 23 to regain the system inventory. OV 24 Q And you understood, did you not, that 25 the HPI would be automatically actuated when i
1 Frederick 234 (~) V 2 pressure dropped to 16407 3 A Yes. 4 Q Going back to my first question, ll) 5 why did you understand that a drop in pressure to 6 the point where it was as low as 1640 was a symptom 7 of a LOCA? 8 MR. SELTZER: Why does pressure drop when 9 there is a LOCA? 10 MR. FISKE: I think that is what I was 11 trying to ask; before the accident. l 12 MR. SELTZER: Mr. Fiske wants to make ((-. 13 it sound more complicated than it is. 14 A The pressure would drop because of a 15 loss of inventory. You are evacuating the 16 water in the system through a big hole. 17 Q Symptom 1.2 is rapid continuing 18 decrease of pressu;::izer level, again, culminating 19 in a low alarm and a low low a la rm. 20 Why did you understand that a decrease 21 in pressurizer level was a symptom of a LOCA? 22 A I understood that because of my training. 23 I learned that pressurizer level indicated how much 24 watar was in the system, and as the water left the 25 system, pre ssurize r level wc uld go down.
1 Frederick 235 O'w) 2 Q Symptom 1.3 refers to high radiation 3 alarm in reactor building. 4 Does that re fer to an alarm which lll 5 would be designed to' detect presence of 6 radiation in the air in the reactor building? 7 A 1.4 does not specify -- I'm sorry. 8 1.3 does not specify which of the reactor building 9 radiation alarms they are re ferring to. It could 10 be high radiation in the air or high radiation, 11 just Gamma type radiation, not necessarily 12 entrained in the air. (D \\/ 13 Q Why would that be an indication of a 14 loss of coolant accident? 15 MR. SELTZER: By " indication," you mean 16 symptom? 17 MR. FISKE: Yes. 18 A It can be listed here as a symptom of a 19 loss of coolant accident because the system was 20 designed to detect radioactive contaminants in the 21 reactor building that wouldn't normally be there, O 22 so something has happened that caused some radiation 23 to get into the building. (m) 24 Q Simply put, the presence of radiation i. 25 in the building is a symptom that there is a LOCA
0 1 Frederick 236 O 2 in progress? 3 A No, there is a procedure specifically l 4 entitled "High Radiation in the Reactor Coolant (g) 5 System," and neither one of them is linked to a 6 LOCA. 7 Q Then why did you understand symptom 1.3 8 contained a high radiation alarm in the reactor 9 building as a symptom of a LOCA? 10 A Because of the situations which could 11 cause a radiation alarm in the reactor building. .12 A LOCA is one of those situations. O 13 MR. SELTZER: I think the two of you are 14 having some problems of dialogue which is not 15 either of your fault, but when I studied 16 I math at Harvard, we talked about whether something 17 was a necessary condition and a sufficient 18 condition, and some of these symptoms I think 19 can be described as necessary but not sufficient 20 to describe a LOCA. 21 Every time you say,11s that identified O 22 with a LOCA, Ed Frederick is thinking that 23 you mean that alone would be sufficient to () 24 describe a LOCA, so he is saying one thing 25 and you are thinking something else. __ l -
1 1 Frederick 237 /~'N N.Y 2 MR. FISKE: I think the distinction that 3 you are drawing is drawn in the procedure 4 itself when we get along further down the page, llg 5 but at the moment I am using the term 6 " symptom" in exactly the same context that 7 I assume Mr. Frederick understood it at the 8 time he was trained on these procedures and 9 studied them before the accident. 10 Q Going back again to symptoms as listed 11 under 1.0 -- 12 MR. SELTZER: What I am suggesting is fm 13 maybe instead of you assuming that Mr. Frederick 14 is applying the same definition that you are, 15 why don't you indicate by " symptom" you mean 16 something that is necessary but not sufficient? 17 MR. FISKE: I thought Mr. Frederick said 18 at the beginning -- all right. 19 Q Did you understand that there might be 20 other explanations besides a LOCA for any of the items 21 listed on 1.0 through 1.8? O 22 A Yes. 23 Q You also und.erstood that a possible A. 24 explanation for each one of the items, 1.0 through ( ) 25 1.8, was a LOCA?
) 2 1 e Frederick 238 bG 2 A Yes. 3 Q In that sense they are symptoms of a 4 LOCA? 1 g 6' A Yes. 6 Q That was your understanding of the ~ 7 word " symptom" in this procedure, is that correct? 8 A Yes. 9 Q Is it your testimony, Mr. Frederick, with 10 respect to 1.3 that there could be situations in 11 which you saw a high radiation alarm in the reactor '12 building when a-LOCA would not be in progress? O 13 A Yes, they would be described in the other + 14 emergency procedure that I mentioned. 15 Q The ane you mentioned earlier? 16 A Yes. -))) 't 17 C' { Item,1.4 refers to reactor building 18 ambient temperatura slarm. i s 19 Way did you understand that a high 20 reactor bui1 ding temperature was a symptom of a 21 LOCA? n O 22 ' ' h A I think at that time I understood that a , } w, 23 e pould be' evacuating high temperature water into h) v 24 .ythe' building sod thr.t 'i,t would eventually raise ? 3-25 the'tanperature;in the' building. 3. '4 m.'
1 1 Frederick 239 2 Q 1.5, high reactor building sump level. 3 Why did you understand that a high 4 reactor building sump level was a symptom of a LOCA? llh. 5 A Because the water coming out of the 6 reactor coolant system would make its way to the 7 reactor building floor where there is a small cavity 8 called the reactor building sump, so it would collect 9 there, and we had an indicator in the auxiliary 10 building which showed that level in that sump. 11 Q Item 1.6 s ays, high reactor building 12 pressure. O 13 Why was high reactor building pressure 14 a symptom of a LOCA? 15 A Because the water coming out of the 16 reactor coolant system would be filling the 17 reactor building, and you would have some vapor 18 production, and that would cause an increase in the 19 pressure, the atmospheric pressure of the building. 20 Q By " vapor" you mean again steam? 21 A Yes. 22 Q 1.7 refers to a rapidly decreasing 23 makeup tank level. ( 24 Why would the makeup tank level decrease 25 in a LOCA?
1 Frederick 240 (~N l ~ 2 A The symptom up above which would be 3 1.2, which said you would have a rapidly 4 decreasing pressurizer level would be linked to lll 5 the makeup system in that the makeup system would 6 try to regain that level by injecting more water into 7 the reactor coolant system to maintain the pressurizer 8 level, and that water would come from the makeup 9 tank, so you would expect that level to decrease. 10 Q What is the process by which that water 11 is put into the system? 12 A It is pumped in. 13 Q By what? 14 A Makeup pump. 15 Q Are makeup pumps also the HPI pumps? 16 A Yes, they are the same pumps. 17 Q Are they automatically actuated under 18 certain circumstances? 19 A, Yes. 20 Q And are they automatically actuated by 21 a drop in pressurizer level? O 22 A In t'he same way that they are actuated 23 for high pressure injection? f) 24 Q No, what actuates high pressure injection i \\~J 25 A The manual signal by the operator or the
I Frederick 241 i 2 automatic signal listed above. 3 Q what automatically activates high 4 pressure injection? g 5 A That would be the injection signal listed 6 up there, at low pressure. 7 Q Item 1.8 refers to both core flood tanks' 8 levels and pressures are decreasing. 9 Why would a decrease in the core flood 10 tanks' levels ahd pressures be a symptom of a LOCA? 11 A Because it was the design of the core 12 flood system to inject water into the reactor core 13 as the water was evacuated in the system through a 14 leak. 15 Q How would that happen? How would that 16 be done? 17 A The water flows in under mode of force 18 of the nitrogen pressure maintained on the tank. 19 That along with gravity flow. 20 Q Does that have to be manually 21 activated or does that go on automatically? 22 A I wouldn't classify it as manual / 23 automatic. It is a passive system. It goes without h 24 operator or mechanical action. l N._/ 25 Q what triggers it?
i 1 Frederick 242 O .G' 2 A The differential pressure between the 3 core flood tank and the reactor vessel. 4 Q Now, there is a note under 1.8 jll 5 which I think goes to the point that Mr. Seltzer 6 may have been addressing earlier. 7 The note says, "The operator may 8 distinguish between a loss of coolan t inside 9 containment, an OTSG tube rupture, and a steam line 10 break by the following symptoms which are unique to 11 the aforementioned accidents." '12 Did you understand that some of the %.) 13 symptoms which are listed in 1.0 through 1.8 were 14 also symptoms of an OTSG tube rupture or a steam line 15 break? 16 A Yes. 17 Q Did you understand that the note was 18 designed to help you decide when you saw some of 19 the symptoms in 1.0 through 1.8 whether you had a 20 loss of coolant accident, a tube rupture, or a steam 21 line break? l 22 A Yes, I understood the note to be an l 23 aid in the struggle to put a label on the casualty, b) ( 24 to clarify the symptoms. 25 Q It refers to certain symptoms, the note l l
1 Frederick 243 Oi V 2 refers to certain symptoms which in the language 3 of the procedure, "Are unique to the aforementioned 4 accidents." llf 5 Do you see that? 6 A Yes. 7 Q No. 1 says, " Loss of coolant inside 8 reactor building - particulate iodine gas monitor 9 alarm on HPR 227 reactor building air sample." 10 Why did you understand that particular 11 alarm was unique to a loss of coolant inside the 12 reactor building? G 13 A It was my understanding that if a 14 loss of coolant inside the reactor building type 15 accident occurred, this additional indication from 16 HPR 227 might aid in deciding that it was a 17 LOCA because chere is some amount of radiation or 18 activity in the reactor coolant as opposed to there is 19 not supposed to be any activity in the steam or in 20 other secondary systems. 21 Q so that your understanding of this O 22 procedure before the accident was that you would not 23 expect to see that alarm if you had a tube rupture O) ( 24 or steam line break? 25 A I think I had the understanding I would i
1 Frederick 244 0 2 not expect to see that alarm as a cause or 3 having been caused by a steam leak in the secondary 4 sy s te m. 5 Q No. 2 rays, " Steam tube rupture," and it 6 refers to a gas monitor alarm on VAR-748. 7 Why did you understand that a gas 8 monitor alarm on VAR-748 was unique to a tube 9 rupture? 10 A Again, due to the presence of some 11 activity in the reactor coolant, the tube rupture .12 in the steam generator would allow some of that O 13 activity to get to the condensor and that VAR-748 14 is a radiation monitor and it should be able to detect 15 that activity. 16 Q That monitor is located near the 17 condensor? 18 A Yes. 19 Q That is part of the so-called secondary 20 system, the condensor? 21 A Yes. 22 Q No. 3 refers to a steam break inside 23 the re actor building. It refers to low condensate 24 storage tank level alarm and/or a low hot well level 25 alarm.
1 Frederick 245 O. U 2 Why did you unders tand that a low 3 condensate storage tank level was a symptom unique 4 to a steam line break? lll 5 A The steam line break would cause a loss 6 of the fluid in the s e conda ry system, and the 7 condensate storage tank is a 250,000 gallon tank 8 or actually 50,000 gallon. No. 250,000 gallons. 9 That water would be used to make up for 10 the loss in the steam line, and af ter some time 11 period, you may receive that low level alarm as a 12 result of the loss of water inventory from the 13 secondary system. The low hot well level alarm 14 was likely to occur for the same reasons, but 15 whether you would receive that alarm first or not 16 would be a toss-up, I think. 17 Q Where is the hot well? 18 A The hot well is actually a part of the 19 condensor. 20 Q Why would the hot well level go down 21 during a steam line break? 22 MR. SELTZER: I think he said it would 23 go down for the same reason you get low level [j 24 in the condensate storage. v 25 Q Is that correct?
1 Frederick 246 b 2 A There are several reasons that you might 3 get a low ho't well level alarm. Linking it 4 specifically to a steam break inside the reactor lll 5 building as we are doing here, the cause could be an 6 inability of the water coming in from the condensate 7 storage tank to maintain the normal level in that 8 the leak is so large that the water is moving at a 9 larger volume than can be made up. 10 g why did you understand that a feedwater 11 latch system actuation was a symptom unique to 12 a steam break inside the reactor building? O \\/ 13 A I don't think I had that understanding. 14 Again, the feedwater latch system 15 actuation I would not have labeled that as a unique 16 indication of a break inside the reactor buiding. 17 Any steam break could have given you, 18 whether it was inside or outside the reactor building, 19 could have given you that particular indication. 20 Q What causes an actuation of the 21 feedwater latch system? 22 A Differential pressure between the 23 feedwater inlet and the steam outlet of the steam () 24 generator. 25 Q so basically a drop in pressure in the a
1 Frederick 247 O 2 steam generator would cause that? 3 A It would have to affect the differential 4 pressure across the steam generator. lll 5 Q The s t e am line break that is what 6 happens, does it not, there is a drop in pressure 7 in the steam generator? 8 A Yes, but the same symptom would be 9 in a feedwater line break. The steam generator 10 pressure would drop, but the steam pressure might be 11 maintained for some time. So you have to look at the 12 differential between the two in order to (a~\\ 13 determine that the actuation was proper. 14 (Recess taken.) 15 (Continued on next page.) 16 17 18 19 20 h 22 I ) 24 25
pk 1 1 Frederick 248 [) \\ %J i 2 Q Continuing on with the loss of reactor 3 coolant / reactor coolant system pressure procedure, I 4 ask you to turn to page 7. You see there the heading, ggg 5 it says "Immediate Action"? 6 A Yes. 7 Q And that of course is immediate action with 8 respect to the type of leak that is described in 9 category B, right? 10 A Yes. 11 Q And then the first part of that is 12 " Automatic Action," right? O) 13 A Yes. 14 Q And the first three items listed under 15 " Automatic Action" are reactor trip, turbine trip, and 16 safety injection initiated at 1600 psig. Do you see 17 that? 18 A Yes. 19 Q You did understand in 'a case involving a 20 leak of the category described in B, you would have 21 safety injection come on automatically? O 22 A Yes. 23 Q Then I would like you to turn to page 9, D(_) 24 which describes follow-up action. Do you see that? 25 A Yes.
1 Frederick 249 iO 2 Q Reading through " Follow-up Action," that 3 whole section, is there any provision in that procedure 4 as you understood it on the day of the accident that lll 5 allows you to terminate high-pressure injection before 6 the point in time when low-pressure injection comes on? 7 MR. SELTZER: This assumes that the operator 8 has identified the sit'tation as a type B loss of 9 coolant accident? 10 MR. FISKE: Yes, under this procedure. 11 A May I ask, by " terminate," do you mean the .12 automatic nature of the actuation be terminated or that O 13 it be bypassed? 14 Q The flow be terminated or reduced. 15 A Yes, there are several places in the i l 16 follow-up actions that would require changing the 17 high-pressure injection' flow. 18 Q Which are those? 19 A Section 3.3.2, which is under section 3.3, 20 "The control room operator continuously monitors the 21 following safety f eatures ' flow rate in each of the h 22 following." No. 2 is the four high-pressure injection 23 lines on MU 23 flow indicators 1, 2, 3 and 4. rs t ) 24 Q So that particular section tells the control 25 room operator to continually monitor the flow rate in
I Frederick 250 f\\- 2 those injection lines, correct? 3 A Yes. In conjunction with that,Section 3.5 4 requires the operator to throttle as required to 5 prevent pump runout. This would be in conjunction gg) 6 with this monitorir.g of the flow through those 7 high-pressure injection lines as mentioned in section 8 3.3.2. 9 Q Under what circumstances would you throttle 10 high-pressure injection flow to prevent pump runout? 11 Let me ask a preliminary question. 12 What pump is referred to in 3.57 13 A The high-pressure injection pump. 14 Q What does pump runout refer to in that 15 context? 16 A Pump runout 13 the action of a pump of 17 this sort to move a volume of water which is greater 18 than its designed capacity, which would result in motor 19 damage. 20 Q So 3.5 essentially says that the operator 21 should throttle the HPI pumps as necessary to prevent 22 damage to the pumps, is that correct? 23 A Yes, that is the reason for the part 1 f~} 24 under " Throttle." The caution tells about a minimum sa 25 flow requirement for the pumps so that you have a
251 4 1 Frederick '(m/ 2 window in which you are allowed to operate the pump. 3 Th t is between 95 gallons per minute per pump up to 4 500 gallons per minute per pump. If you stayed in lll 5 that window, you wouldn't damage the pump. 6 Q This is in the caution under item 37 7 A I am on page 10 at section 3.5. Under that 8 is a 1 where it gives you the zero to 250-gallon-per-9 minute maximum and the caution is right underneath that. 10 The caution says, if the makeup pump flow 11 drops below 95 gallons per minute, trip the excess ~12 makeup pumps. So it's telling you you may have too many \\ 13 pumps on for this situation. 14 Q What does No. 2 mean, low-pressure injection 15 flow on the top of page 10.1? 16 A No. 2 says if the low-pressure injection 17 flow is allowed to be varied between 3,000 and 3,300 18 gallons per pump, and there are two low-pressure 19 injection pumps. i 20 LDiscussion off the record) i 21 A In answer sc the question that we started 1 22 with, there are still other places in the follow-up 23 action that indicate times at which you should throttle O(_, 24 or turn off the pumps, but I think you stipulated until 25 the low-pressure injection flow begins?
1 Frederick 252 7'T 2 Q That's right. I am just trying to deal 3 with these one at a time as you describe them. Let's 4 stick with 3.5. I think you said that the purpose of dlh 5 that is throttle as necessary to prevent pump runout 6 which you described as possibly producing damage to the 7 pump, and then you indicated that there is a 8 recommended range of the flow from 0 to 250 gallons per 9 minute per leg, is that correct? 10 A Yes. 11 Q Under that same section, there is a note 12 that says, high-flow alarms should actuate as a warning tc 13 throttle flowr. TEere were high-flow alarms on the 14 instrument control panel. 15 ?.R. SELTZER: High-flow alarms on what? 16 Q Were there high-flow alarms on the control 17 panel? 18 MR. SELTZER: The flow of what? 19 MR. FISKE: The flow of HPI. 20 A I think I recall there being alarm vindows 21 on the panel. 22 Q Which would indicate --- which wou~d have 23 high-flow alarms for the high-pressure injection? 24 A Yes, I think that is how I remember it. 25 Q You can continue on if there are any other places in the follow-up action that govern possible
1 Frederick 253 ['h v 2 throttling or reducing of HPI flow prior to the time 3 that low-pressure injection comes on. 4 A I want to point out that in the workings lll 5 of the safety features actuation system, the low-pressure 6 injection pumps and the high-pressure injection pumps 7 all start together. The s ame signal starts them all, 8 so there really is no differentiation as to when the 9 bigh-pressure injection pumps are running and when the 10 low-pressure injection pumps are running. It's the 11 actual flow of the waters the low-pressure injection 12 system will occur later unless it is a very large leak. 13 Q Are you saying it is the same pumps, but the 14 flow is controlled by the pressure as to whether it is 15 high pressure or low pressure? 16 MR. SELTZER: I think he said it was the 17 same actuation signal, not the same pumps. 18 (Continued on next page) 19 20 21 0 22 23 ('N 24 %,] 25
1 Frederick 254 0 2 Q Do the low pressure injection pumps start 3 running at 16407 4 A Yes. lll 5 Q Do they start pumping water at 16407 6 A Yes, they have a recirculation path that 7 they pump water through until when the check valves t 8 open. 9 Q When is that? 10 A Whenever the discharge pressure of the 11 pump exceeds the pressure in the reactor coolant system. -12 O What point is that designed to occur in 13 the course of a transient that produces a continuing 14 drop in pressure in the reactor coolant system? l 15 MR. SELTZER: Is that another way of asking 16 what is the discharge pressure of the low 17 pressure injection pumps? 18 MR. FISKE: Possibly. 19 A As best I can remember, somewhere around 20 600 or 650 pounds. 21 Q So, just so we understand each other, 22 the point at which water starts going into the system 23 as a result of the action of the low pressure injection 24 pumps is approximately at the time reactor coolant 25 system pressure would reach the 650 pounds?
1 Frederick 255 Ob 2 A Now that I heard myself say that, it seems 3 like a low pressure. I don't remember the discharge 4 pressure of the pump at this time. It is in that llh 5 neighborhood though. 6 Q with that clarification and recognizing 7 that that is the point in time that I am talking about 8 in the question that I put to you before, go ahead. l 9 MR. SELTZER: I am very confused. What l 10 is the point in time at which what happens? 11 Q The question is, what is there in the 12 section of this procedure entitled " Follow-up Action" O(._/ 13 that allows the operator to throttle back the flow of 14 high pressure injection before the time when the low 15 pressure injection pumps start putting water into the 16 system? 17 A The notes un' der Section 3.7 entitled 18 both LPI strings are operating but indicated flow 19 in each is below 750 gallons per minute. It would 20 indicate a time to me that the low pressure injection 21 is not yet being injected. 3.72 says, "If not already 22 done, throttle HPI strings flow rates back to 500 23 gallons per minute per pump, each using control valves [) 24 MUV 16A, B, C, and D." N.s/ 25 Q 3.7, when it says both LPI strings are
g Frederick m 256 U 2 operating, did you understand that to mean operating 3 in the sense that they were putting water into the 4 system but at a rate less than 750 gallons per minute? lh 5 A No, on the page previously, we already 6 discussed that the low pressure injection flow rate 7 is going to be between 3,000 and 3,300 gallons per 8 minute. This below 750 gallons per minute means we 9 are not having low pressure injection yet. We are at 10 a point less than that. 11 Q But if the flow of the low pressure {^)h 12 injection was indicated at,.let's say, 500 gallons ~ 13 per minute, which is below 750, would that indicate 14 that 500 gallons per minute were going into the 15 reactor coolant system from the low pressure injection 16 pumps? 17 A I think I would understand, of that 500 18 gallons per minute, at least 400 gallons of it 19 would be getting into the reactor coolant system. 20 some of it may be recire flow and some might be getting 21 by the check valve in excess of the recirculation 22 flow. 23 Q why did you understand that when both 24 LPI strings were operating but indicated flow in each 25 was below 750 that the operators should throttle the
1 Frederick 257 tU 2 HPI back to 500 gallons per pump? 3 A This is the same limit we had a few 4 minutes ago to protect from pump runout. 500 gallons h 5 per minute per pump is the same limit as 250 gallons per 6 injection leg, because each pump feeds two injection 7 legs. 8 Q So do I understand you to say that when 9 the low pressure injection flow is at the limits 10 described in 3.52, then the high pressure injection 11 flow should be between 0 and 250, and when the low '12 p pressure injection flow is below 750, then the high 13 pressure injection flow should be cut back to 500 14 gallons per minute? 15 A The high pressure injection flow limit 16 given here is per pump. If you had two pumps running, 17 you would have a thousand gallons per minute. 18 Q I meant per pump. 19 A I am only trying to point out the pla~ces in 20 here wt:- - -t an you don 't have the low pressure 21 in3ection flow, there are notes that tell you when 22 you can throttle or cut back on high pressure 23 injection. {b N i 24 Q Is it a fair overall summary of what we r I have been discussing so far that there are procedures l
1 Frederick 258 2 in here for the throttling back of HPI flow depending 3 on the volume of flow from the low pressure injection 4 pumps? h 5 MR. SELTZER: This is a new line of 6 questioning. Before you were asking him whether 7 there were 8 MR. FISKE: It is the same. 9 MR. SELTZER: I thought the question 10 you had been asking was, are there follow-up 11 actions in here that would permit throttling 12 high pressure injection before low pressure ") 13 injection is adding coolant to the reactor 14 coolant system. Wasn't that the question you 15 had anked? 16 MR. FISKE: That's right. I am trying to 17 get clear in my own mind, based on Mr. 18 Frederick's last answer, whether the procedure 19 described in 3.5, throttling to prevent pump 20 runout, says high pressure injection flow is 0 21 to 250 gallons per minute per leg, and number 22 two, low pressure injection flow, 3,000 to 23 3,300 gallons per minute per leg, is referring A(,) 24 ,l to a point in time at which -- 25 MR. SELTZER: Per pump.
l 1 Frederick 259 O V 2 MR. FISKE: Per pump, is referring to a 3 point in time at which there is flow into the 4 reactor coolant system from the low pressure llk 5 injection pumps. 6 A Section 3.5 gives the limits for the 7 three different sets of pumps that are involved in the 8 safety systems actuation. They are all grouped 9 together under throttle as required to prevent pump 10 runout. Each one is applicable whenever those pumps 11 are running. 12 MR, SELTZER: Are they independent of one O 13 another, each of those thre: conditions? 14 THE WITNESS: Yes. What I pointed out in 15 Section 3.7 is a reiteration of that runout 16 precaution under the section which deals with 17 before you have established the necessary low 18 pressure injection flow. 19 Q Are there any other provisions of this 20 procedure which allow the operators to cut back on 21 high pressure injection flow? 22 A
- Yes, In Section 3.7.3, as the operator 23 is establishing low pressure injection flow, this is
() \\_,/ 24 a special condition here. Open valves DHV7A and B 25 and cross over line from LPI line to suction of HPI
1 Frederick 260 bv 2 pumps. In that condition, where you are using the 3 low pressure injection pumps' discharge to feed the 4 suction of the high pressure injection pumps, you will llh 5 also have to throttle the flow because the 6 introduction of that higher pressure at the suction 7 will cause an increase in the flow. 8 Q Any other part of this procedure that 9 allows throttling back of HPI after it has come on 10 automatically in response to this type of leak? 11 A Again, here is the note on Section 3.7.6 12 in which we just referred to back at the beginning 13 of Section 3.7 where the dividing line again is 14 750 gallons per minute of low pressure injection flow. 15 Once you cross that threshold, then you can begin to 16 consider that you have low pressure injection flow, 17 and the high pressure injection pumps can be shut 18 off at that point. 19 Q I think we have now perhaps reached the 20 terminal point of the situation that I had defined in 21 my first question. 22 A May I continue to read? 23 Q sy all means. [G) 24 A It seems that Section 3.8 is dealing with 25 a high pressure injection actuation, and then a low l
1 Frederick 261 f wJ 2 pressure injection actuation in which one of the low 3 pressure injection strings fails to operate, and it 4 gives special consideration to using the high pressure h 5 injection string in conjunction with the available 6 low pressure injection string, and again in Section 7 3.8.4.1, it gives you the opportunity to control the 8 flow rate through the high pressure injection string 9 by throttling flow rate and maintaining 500 gallons 10 per minute in conjunction with that low pressure 11 injection flow. 12 O q,y (continued on the following page) 13 14 15 16 17 18 19 20 9 22 23 (~/) I \\. 24 l 25 l
1 Frederick 262 %/ 2 Q Just to summarize this, as I understand it, 3 looking at page 10.1, under the word " Situation," 4 correct me if I am wrong with this summary of how llh 5 you have described this procedure. 6 Under " Situation" No. 1 refers to the 7 situation where both LPI strings are operating and 8 indicated flow in each is above 750 gallons per 9 minute. 10 You go to step 3.6, one part of which is 11 in 3.63, to shut off the HPI pumps. That if under 12 " Situation" 2 both LPI strings are operating but b) 13 indicated flow in each is below 750, then you go to 14 step 3.7, which includes the section 3.7.6 I'm 15 sorry, which includes 3.7.2, which tells you how much 16 you need to throttle back HPI until the low pressure 17 flow has reached 750. 18 Is that correct? 19 A Yes. 20 Q Going back to the beginning of this 21 procedure, part A refers to a leak or rupture within i g l w 22 capability of system operation? l 23 A Yes. /~S k. 24 Q Then there are various symptoms listed 25 under 1.07
1 Frederick 263 V 2 A Yes. 3 (Discussion off the record between the 4 witness and his counsel.) llh 5 Q Directing your attention to this part of 6 the procedure, leak or rupture within capability 7 of system operation, 3.0 describes the follow-up 8 action once the situation has been identified as 9 falling within category A, and you see 3.1 refers to 10 safety injection not initiated. 11 A Yes. '12 Q And it tells you then to initiate unit gg b 13 shutdown and cooldown pursuant to other procedures, 14 correct? 15 A Yes. 16 Q And then 3.2 says " Safety injection 17 manually initiated, both high pressure injection and 18 low pressure injection." 19 Do you see that? 20 A Yes. 21 Q Is it correct that the circumstances under 22 which safety injection would be manually initiated 23 pursuant to this procedure would be a situation in 24 which it was apparent that the makeup pumps were not i 25 adequate to maintain the system pressure and inventory?
1 Frederick 264 O 2 MR. SELTZER: When you say "would be 3 manually initiated pursuant to this procedure," 4 are you suggesting that there is somewhere llh 5 in this procedure where it directs manually 6 initiating HPI and LPI? 7 MR. FISKE: Yes. 8 A There is section 3.2 which tells the 9 actions to take if you manually initiate high pressure 10 injection. i 11 Q Right. 12 Turning to section 3.2.5 on page 3, item 1 l 13 says that if pressurizer level can be maintained above 14 the low level alarm point and the RCS pressure above 15 the safety injection actuation point, then proceed 16 to step 3.2.6. 17 Do you see that? 18 A Yes. 19 Q And 3.2.6 is a plant shutdown and 20 cooldown, is it not? 21 A 3.2.6 is part of this procedure which O 22 says that if you are maintaining pressurizer level 23 and RCS pressure within allowable limits, then you (T ) 24 should initiate plant shutdown and cooldown using 25 the other procedures.
1 Frederick 265 O \\_/ 2 Q That is what I meant. In other words, the 3 thrust of this section 3.0 under " Follow-up Action" 4 is under 3.1, if safety injection is not initiated, llh 5 you initiate unit shutdown and cooldown pursuant to 6 other procedures? 7 A Yes. 8 Q If safety injection has been initiated and g under 3.2.5 pressurizer level can be maintained 10 above the low level alarm point and the RCS pressure 11 above the safety injection actuation point, then you 12 proceed to initiate plant shutdown and cooldown O 13 pursuant to these other procedures, right? 14 A No, if you read it in this way, then you 15 skip procedurally step 3.2.6 16 Q That is what I am talking about. 17 A -- which reads, "The pressurizer level and 18 the RCS pressure aire being maintained within allowable 19 limits as opposed to being maintained above the low 20 level alarm point." 21 Q Isn't it correct, as you understcod this 22 procedure, that you don't proceed to 3.2.6 until 23 under 3.2.51 the pressurizer level can be maintained (G , _) 24 above the low level alarm point and the RCS pressure 25 can be maintained above the safety injection actuation
1 9 / e g Frederick 266 0 p int? 2 4 ') A Yes, my understanding was that it would k 4 not proceert to the plant shutdown and cooldown h 5 rr cedores without having met the conditions in f 3.2.5 and 3.2.6. 6 7 Q 3.2.52 says "If pressurizer level cannot 8 be maintained r.bove the low level alarm point, and 9 the RCS 5.ressure above the safety injection actuation 10 point, tr.en 'the plant has suffered a major rupture 33 and ope. rations should continue according to part -12 B, leak or rupture of significant size such that O V engineered safety. features systems are automatically .13 14 initiated."
- Do you see that?
15 <l6 A Yes, I do. l g7 Q Part B is what we have just been talking 18 about earlier today, is it not? gg A' Yos. Again, the same point would be made 20 in that answer that you do not proceed to part B unless 21 y u met the conditions of that paragraph 2. 22 C In other words, you would proceed to 23 part B if pressurizer level could not be maintained f) above the-low level alarm point and the RCS pressure 24 LJ above the safety injection actuation point? 25~
1 Frederick 267 O 2 A Yes. 3 Q So that you understood the plant, under 4 this procedure, would have suffered a major rupture, lll 5 as defined here, if pressurizer level could not be 6 maintained above the low level alarm point and if the 7 RCS pressure could not be maintained above the 1 8 safety injection actuation point; is that correct? j, 9 MR. SELTZER: Your question has as a l l 10 built-in assumption that the operators have 11 already decided that they have got a loss-of-t 12 coolant accident that meets the symptoms of O 'v' 13 part A, right? 14 MR. FISKE: Yes, I am assuming we are 15 following this procedure. 16 MR. SELTZER: That is a big assumption. 17 MR. FISKE: That is what all these 18 questions are about, asking bt, 'ds understanding I I 19 of this procedure, and presumably, if he is 20 following this procedure, it is because he has 21 determined that it is applicable. 22 A I missed the question just above that. 23 Q Wasn't it your understanding that under (G_) 24 this procedure, that the plant has suffered a major 25 rupture as defined in part B unless pressurizer level
1 Frederick 268 O(~% 2 can be maintained above the low level alarm point 3 and pressure can be maintained above the safety 4 injection actuation point? lll 5 A No. That is not my understanding, that 6 I should conclude that there is a major leak or { l 7 rupture. You should move to part B and begin the 1 8 same process of considering the symptoms and the 9 parameters being exhibited and see if they mesh with 10 the symptoms and what is expected of part B of this 11 procedure. I -12 Q But you understood that part B would < s, 13 become applicable under the circumstances I just 14 described in my last question ? 15 A If we had worked through part A and I 16 come to that point, then could not maintain pressurizer 17 level above low level alarm point and the RCS pressure 18 above the safety injection actuation point, then we 19 would go to part B and consider those symptoms. 20 Q Let me show you the Unit 2 emergency 21 procedure for pressurizer system failure, which has 22 been marked previously as B&W Exhibit 305. 23 I would like to show you a diagram, which I t (,) 24 is page 14, figure 2, from a document that has been 25 previously marked as Exhibit 428, which may be
1 Frederick 269 (v 2 helpful in connection with discussion of this 3 procedure. 4 Is it correct that there are three relief lll 5 valves on top of the pressurizer? 6 A According to the diagram you just gave me, 7 three relief valves are connected through piping to 8 the top of the pressurizer, yes. 9 (continued on page 270.) 10 11 12 OO 13 14 15 16 17 18 19 20 h 22 23 O (_) 24 25
k 1 1 Frederick 270 0 2 Q That was your understanding, was it not, 3 prior to the accident, that there were three valves that 4 could reduce pressure in the event that the pressurizer lll 5 became overpressurized? 6 A Yes. 7 Q One of them is referred to as the 8 pilot-operated relief valve? 9 A Yes. 10 Q And there are two others referred to as 11 code safeties? 12 A Again, previous to the accident, exposure -sU 13 to this subject, the valve that you are referring to 14 as the pilot-operated relief valve was called the 15 electromatic rolief valve, and the other two relief 16 valves were called code reliefs. That is the 17 terminology we were using. 18 Q Were you familiar with the structure of the 19 system between the pressurizer and the reactor coolant 20 drain tank prior to the accident? 21 MR. SELTZER: You mean how the valves and O 22 the piping connected to the reactor coolant drain 23 tank? I(,/ 24 MR. FISKE: Yes. 25 A I knew there were piping connections between
1 Frederick 271 (~)'. t 2 the pressurizer and the drain tank, but I don't know 3 how they were physically arranged or directed through 4 the plant. lll Q Did you know that if any one of the valves 6 that you described opened, that the fluid that escaped 7 through those valves would go through pipes directly 8 to the drain tank? 9 A Yes. 10 Q Did you know before the accident that there 11 we re thermocouples designed to measure the temperature 12 of the flow through the piping for each of the three i N/ 13 valves that you just described? 14 A No, I was not aware that they were 15 thermocouples nor that they would give indications of 16 an independent valve's temperature. 17 Q Did you know before the accident tnat there 18 were any thermocouples that would measure the 19 temperature'of the fluid that might flow between the 20 pressurizer and the reactor coolant drain tank? 21 A No, I did not know whether they were 22 thermocouples or RTD's. l 23 Q Do you know whether there was any device [ j') 24 that measured the temperature of flow through the pipes m 25 between the pressurizer and the drain tank?
l 1 Frederick 272 () V 2 A I knew that there were temperature 3 measuring devices somewhere at the discharge of those 4 three valves. lll 5 Q Let's talk about the training that you had 6 at Het Ed with respect to this system which existed at 7 Unit 2. What did people at Met Ed tell you with 6 respect to any devices that there were that would 9 measure temperatures between the pressurizer and the 10 drain tank? 11 MR. SELTZER: What did they tell him about -12 the existence of such? OV 13 MR. FISKE: Yes. 14 A The temperature measuring devices on the 15 discharge of the relief valves was not a part of the 16 nonnuclear instrumentation lecture normally given that 17 I can recall. The training that would have been 18 received on the location and type of instruments would 19 have been acquired through tracing out the system and 20 studying the system, description of the system. 21 Q What training did you have at Met Ed in 22 tracing out the system and studying the system 23 description? A () 24 A I don't recall this particular set of 25 instrumentation being emphasized in any of the training
I Frederick 273 2 that I received at B&W or Met Ed. 3 Q B&W didn't supply this part of the system, 4 did they? lg 5 A I don't know. 6 MR. SELTZER: When you say "this part of 7 the system," the relief valves that would be 8 discharging were part of the B&W scope of supply. 9 I think everybody knows that. 10 Q The part of the system between the 11 pressurizer and the drain tank, including whatever .12 instruments there were to measure temperatures along
- C/
13 that path, this is what I was referring to. 14 A I don't know what B&W was responsible to 15 supply. 16 Q What understanding did you have prior to 17 the accident as to how you would be able -- what 18 understanding did you have prior to the accident as to 19 what devices there were that would be useful in ] 20 determining temperature at the electromatic relief 21 valve? O 22 MR. SELTZER: Objection. No foundation. 23 Q Did you know before the accident whether O(_,) 24 there was a device that would measure temperatures l 25 either of the fluid or of the pipe at the point where
5 I Frederick 274 0 2 fluid left the pilot-operated relief valve and entered 3 the pipe? 4 A No, my understanding at that time was that g 5 there were temperature-indicating devices available 6 somewhere downstream of the valve where there were a 7 group of indicators which would indicate leakage 8 through any one of the three valves. 9 Q Did you understand that the temper.ature-10 measuring devices that would measure temperatures of 11 fluid escaping from the pilot-operated relief valve and .12 from the safety relief valves were all in the same 13 place? 14 A I understood that they were in a common 15 portion of the pipe. I really didn't have any idea 16 what their physical location was. 17 Q I don't understand what you mean by 18 common portion of the pipe. 19 MR. SELTZER: ,Have you established yet 20 whether Mr. Frederick had an understanding about 21 whether there were separate temperature-sensing 9 22 devices for each of the three valves? 23 MR. FISKE: I am trying to find out. 24 MR. SELTZER: Why don't you ask that as a 25 foundation question. 1
I 1 Frederick 275 2 MR. FISKE: I will take that question. 3 A I knew that there were three indicators, 4 but it was my understanding that none of them could be ll) 5 assigned as being an indicator for any particular valve. 6 They would all show an increasing temperature in the 7 lines downstream of the th re e valves because they were 8 all connected together. 9 Q Forget for the moment what you thought was 10 they might show. Did you understand that there was in 11 the system a separate device designed to measure 12 temperature separately for each of the three valves? O 13 A No, I just knew that there were three 14 temperature readouts and they had numbers. 15 Q And you didn't -- 16 A Temperature elements. 17 Q You didn't know that one of the devices was 18 assigned to the electromatic relief valve and each of 19 the other two was assigned to a specific safety relief i 20 valve? 21 A I think when we took readings on them, we 9 22 assigned them, designated them by valve number, rather r l 23 than instrument number. l () 24 Q How did you make that assignment? 25 A I didn't make that assignment. That was on
1 Frederick 276 s 2 the log sheet. 3 Q How did you understand that assignment was 4 made? gg) 5 MR. SELTZER: No foundation. Objection. 6 Q Did you have any understanding as to how 7 that assignment was made? 8 A No. 9 Q Why did they pick one device to assign to 10 one valve, as opposed to another? 11 A I don't remember trying to differentiate 12 them. I just accepted the designations that were (%, (_) 13 given by the engineers. 14 Q So as you understood it before the accident, 15 there was no way to tell by looking at the temperatures 16 of any one of those valves whether a leak was coming 17 from a relief valve as opposed to the electromatic 18 relief valve? Whether the leak was coming from a 19 code safety as opposed to a pilot-operated relief valve? 20 A It was my impression that it was not possible 21 to make the decision as to which valve was causing the 22 rise in temperature strictly by reading the temperatures. 23 Q How did you obtain that understanding? /~T 24 A I don't know how I obtained that '\\-) 25 understanding. We I think I did have that i ~ l
Frederick 277 O 2 understanding. I just don't recall where it came from. 3 Q so I take it your testimony is you were not 4 aware then of the specific location of any one of these h S three measuring devices. 6 A That's correct. 7 Q And you were not aware of the nature of 8 the device itself? 9 A I don't recall knowing which type of 10 l temperature detector that it was. 11 Q Did you know whether it measured temperature 12 of the fluid inside the pipe or temperature of the U 13 pipe itself? 14 A I don't recall knowing that either. 15 Q Going to this pressurizer system failure 16 procedure, do you have that in front of you? 17 A Yes. IO Q Item Section A ssys " leaking pilot 19 operated (electromatic relief valve)." Do you see 20 that? 21 A Yes. 22 Q A.1 lists various symptoms of a leaking 23 PORV, does it not? O) 24 \\ A Yes. 25 Q Using the same understanding of the word l
1 Frederick 278 O 2 " symptoms" that we used earlier in the afternoon, the first symptom is relief valve discharge line 3 4 temperature exceeding the normal 130 degrees lh 5 Fahrenheit. Alarms on computer at 200 degrees 6 Fahrenheit. 7 Why did you understand that a relief 8 valve discharge line temperature exceeding 130 g degrees was a symptom of a leaking pilot operated 10 relief valve. 11 A I think I already stated that I did not 12 have an understanding that a high temperature indicated (~)h k-13 that the valve could be identified as to which one 14 was leaking. 15 Q Item 2 says, " Reactor coolant drain tank 16 Pressure above normal on the control room rad waste 17 disposal control panel and temperature above normal 18 on the local rad waste disposal control panel." 19 where'was the rad waste disposal control 20 Panel? 21 A There are two rad waste disposal control 22 panels mentioned in this portion of the procedure. 23 One is in the control room and one is in the auxiliary n() 24 building. 25 Q Which is which?
1 Frederick 279 2 A The one labeled control room rad waste 3 disposal control panel is in the control room, and the t l 4 one labeled local rad waste disposal control panel is lll 5 in the auxiliary building. 6 Q Under A-2, it says, "Immediate actions." 7 Item B is " Manual actions, close the electromatic 8 isolation valve." 9 Do you see that? 10 A Yes. 11 Q And that is commonly referred to as the 12 block valve? A 13 A You can refer to it as the electromatic 14 relief block valve. 15 Q There is no block valve for either of the 16 code safeties, is there? 17 A No, but there are other block valves in 18 the system, in other systems. 19 Q The only block valve relating to the 20 pressurizer is the one for the pilot operated relief 21 valve? r block valve also. 22 A No, there is e 23 Q But the manu n that is required by Ii 24 this procedure for a leaki. it operated relief (J 25 valve is to close the electromatic relief
1 Frederick 280 0 2 block valves right? j 3 A Yes. I only wanted to make it clear by 4 referring to that one, I would tag that label in front I 5 there, electromatic relief block valve. 6 Q We will keep referring to that one so 7 there won't be any confusion. 8 (Time noted: 4:30 p.m.) 9 10 11 Edward R. Frederick 12 13 Subscribed and sworn to before me 14 this day of 1982. 15 16 17 18 19 20 lh 22 23 I) 24 %.) 25
1 l 1 i 281 l ) CERTIFICATE 26 'i STATE OF NEW YORK ) 3 ji I
- ss.:
COUNTY OF NEW YORK ) 4 i , a Notary I g I, JOSEPH R. DANYO Public of the State of New York, do hereby I certify that the continued deposition of 7 EDWARD R. FREDERICK 8 was taken before l me on May 5, 1982 9 consisting 1 I of pages 129 through 281 I further certify that the witness had I 11 I been previously sworn and that the within transcript is a true record of said testimony; l That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter I 16 in controversy, nor am I in the employ of any I 17 l l of the counsel. i l IN WITNESS WHEREOF, I have hereunto set my l 19 i l hand this [ day of 7/ /f[2 20 / ( Ih 21 l 1 23 %s / p \\ Joseph R. Danyo / I b 24 I v 25 ) I L}}