ML20072H753
| ML20072H753 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/06/1982 |
| From: | Frederick E METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-05, TASK-1, TASK-2, TASK-3, TASK-5, TASK-GB NUDOCS 8306290719 | |
| Download: ML20072H753 (138) | |
Text
_
up 282 dob UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
__........____x GENERAL PUBLIC UTILITIES CORPORATION, a
h.
JERSEY CENTRAL POWER & LIGHT COMPANY, T
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.,
s Defendants.
.x Continued deposition of METROPOLITAN EDISON COMPANY, by EDWARD R.
FREDERICK, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esgs.,
One Chase Manhattan Plaza, New York, New York, on Thursday, May 6, 1982, at 9:55 o' clock in the forenoon, before JOSEPH R.
DANYO, a Shorthand Reporter and Notary Public within and for the State of New York.
8306290719 820506 PDR ADOCK 05000289 T
PDR t
l DOYLE REPORTING, INC.
(
CERTIFIED STENOTYPE REPORTERS l
369 LaxtNGTON AVENUE l
WALTER SHAPIRO, CJ.R.
New Yong. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
Tsi.spNows 212 - 867-8220
1 283 2
APPe ara n ce at 3
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York By:
RICHARD C.
SELTZER, ESQ.,
6 of Counsel 7
8 g
DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 One Chase Manhattan Plaza New York, New York 11 By:
ROBERT B.
FISKE, ESQ.
12
-and-WILLIAM E.
WURTZ, ESQ.,
of Counsel 14 15 16 KILLIAN & GEPHART, ESQS.
Attorneys for the Witness 17 Box 886 Harrisburg, Pennsylvania 17108 18 By:
JANE G.
PENNY, ESQ.,
19 of Counsel 20 21 22 Also Present:
23 JONATHAN QUINN
,G
\\_)
25
1 284
(~)x
(
2 EDWARD R.
F RED ER I C K,
- resumed, 3
having been previously duly sworn, was examined 4
and testified further as follows:
5 EXAMINATION (Cont'd.)
6 BY MR. FISKE:
7 Q
Yesterday afternoon, we showed you a page 8
from a document that has been previously marked B&W 9
428, and this is a page that contains a figure which is 10 captioned " Physical Arrangement of Relief Valves and 11 Thermocouples."
12 Do you have that in front of you?
()
13 A
Yes.
14 Q
Did you ever see that figure before the 15 accident?
16 A
No, I don't recall having seen this figure.
17 Q
Did you ever see any diagram like that which 18 purported to set forth the location of the pilot 19 Operated relief valves, the code safeties, and the 20 thermocouples relating to each of the valves?
21 A
No.
22 Q
Did you ever ask anyone at Met Ed during 23 the course of your training to show you such a diagram?
24 A
No.
Whenever it was necessary to learn gg
\\A 25 about the physical arrangement of the apparatus, we
1 Frcdorick 285 (V~)
2 could go out in the plant and look at it.
You wouldn't have to request a diagram.
3 4
Q Did you ever go out in the plant and look 5
at the physical apparatus to determine the location 6
of the valves and the thermocouples relating to the 7
valves?
8 MR. SELTZER:
Can we break it down into 9
two questions, valves and thermocouples?
10 MR. FISKE:
Sure, if that is helpful.
11 Q
Let me ask you whether you ever went to 12 the plant to view the physical apparatus to determine "13 the location of either the valves or the thermocouples 14 relating to the valves?
15 A
Yes.
16 Q
When did you do that?
17 A
I wouldn't be able to recall any specific 18 instances when I made the trips into the plant or into 19 the reactor building, but I have been in there on 20 numerous occasions during my training.
21.
Q Was one of the purposes for going in there 22 to find out what the location of the valves was, where 23 the valves were located?
24 A
These particular valves?
'\\
(/
25 Q
Yes, these three.
l 1
Frodorick 286
^T
[d 2
A I would have noted these locations along with the components that I was studying in the entire 3
4 system.
When you make an entry in the reactor building, 5
you try to use your time economically, because some of 6
the entries we made were after the system had been 7
started up and you are not allowed to stand there very 8
long.
9 Q
My question is do you remember any time 10 and any one of these trips when you took the time to 11 stop and determine where the PORV and the two code 12 safeties were located?
')
'13 MR. SELTZER:
In his last answer, J
14 Mr. Frederick said he is sure that on these 15 visits he would have noted the location of the 16 valves.
What more are you searching for now?
17 Q
Is that corr.ect?
18 A
I think I answered that I would have noted 19 the location of these valves along with all the other 20 components that I was trying to identify.,
j 21 Q
At the time you made those trips, did you 22 know then that there were temperature reading devices 1
23 associated with each of these valves?
24 A
I made these examinations, these trips D.
k~
25 during all phases of my training even back to when I
1 Frodorick 287 f')
2 was an auxiliary operator, so whether I was aware of s-the existence of those elements in each one of those 3
4 trips, I don't know, but I think in some of these 5
trips I would have been aware after I had learned about 6
this system.
7 Q
So at least on some of these trips when 8
you made them, you know that there were temperature 9
reading devices associated with these three valves?
10 MR. SELTZER:
Do you have a recollection 11 of that in mind?
12 MR. FISKE:
He just said he did.
13 MR. SELTZER:
He said "I think I would 14 have," which sounds a little bit different from 15 recalling that he definitely did.
16 MR. FISKE:
Read back the last answer.
17 (Record was read back.)
18 Q
When you gave us that answer, were you 19 giving us your best recollection?
20 A
I was giving you a supposition of what I 21 might have known at that time.
22 Q
Are you telling us now that you didn't 23 know?
24 MR. SELTZER:
Can you recall one way or OV 25 the other?
1 Frodorick 288
()
2 A
I don't have a specific recollection of 3
either knowing where these elements were or having on 4
any occasion gone in to search them out or find where 5
.they were.
G 6
Q The immediate question was at the time you 7
made any of these trips, were you aware that such 8
devices existed?
9 MR. SELTZER:
You are talking about 10 temperature detecting devices for the relief 11 valves on the pressurizer?
12 MR. FISKE:
Yes.
1 1
('T 13 A
The system training that I received on the
%J 14 reactor coolant system told me that these devices did 15 exist, so if I made a trip after I received that 16 system training, I would have known that they existed.
17 Q
You were trained on the procedures as part 18 of your cold license training before you received 19 your license, isn't that correct?
20 A
I received procedure training as part of 21 my license training.
22 Q
You understood when you took the license 23 examination that at that point in time you were 24 supposed to be familiar with the emergency procedures,
'~
25 did you not?
1 Frodorick 289 2
A Yes.
3 Q
One of the emergency procedures is an 4
emergency procedure which we were discussing yesterday 5
called pressurizer system failure and symptom A.11 6
refers to a relief valve discharge line temperature.
7 Do you see that?
8 A
Yes.
9 Q
You knew, did you not, that that temperature 10 had to be measured by some kind of temperature reading 11 device?
12 A
Yes.
I' 13 Q
Is it fair to say that at some point after
(_)d 14 you took your examination for license, you made a trip 15 back to the plant?
16 A
After I took my exam for my license?
17 Q
Yes.
18 A
Yes.
19 Q
on the occasion of any trip that you took 20 to the plant after the time when you were taking your 21 examination for license, did you attempt to determine O
22 where each of the temperature reading devices associated 23 with each of the relief valves was located?
24 MR. SELTZER:
Let me ask a foundation I
')
25 question, and I will take your word for it, if
1 Frederick 290 O(~'N 2
you say yes.
3 Are the temperature sensing devices that 4
are on these relief valves ones that are 5
observable from physical observation?
O 6
MR. FISKE:
I would think Mr. Frederick 7
would be able to answer that question better 8
than I could.
9 MR. SELTZER:
I would think it is a 10 foundation to your question before you ask 11 People "Did you go in and attempt to look for 12 them," whether these are temperature sensing "13 devices that are mounted in such a way that 14 somebody just observing with the naked eye 15 could see them.
16 Q
Do you know whether these devices that 17 are designed to measure the temperatures associated 18 with each of the three rolief vslves are physically 19 observable from an inspection?
20 A
I know now that they are not.
I didn't 21 know that at the time.
They are not visible unless G
22 you remove the lagging around the pipe.
23 Q
So tha+. by making a physical inspection 1
l 24 of the plant, you wouldn't be able to find out where I
f)N
(_.
25 the temperature reading devices associated with each l
1 Frodorick 292
(~N 2
valve were located, is that correct?
A That's correct.
In fact, with the case 3
4 of all the instrumentation that we were using in the 5
control room, the location, the physical location was 6
not as important as the location of the instrumentation 7
that was given on the flow diagram which showed you 8
why that instrument was located where it was; like 9
the outlet of the reactor, the temperature in the 10 outlet of the reactor is shown in the diagram as 11 being in the TMI leg, but there was never any necessity 12 to go in and determine exactly where that was on the i
13 P Pe-14 Q
Is it your testimony that you never made 15 any effort to find out where the temperature reading 16 devices associated with each valve were located?
17 MR. SELTZER:
You mean beyond the 18 information that was given to him from the 19 control room position indication?
He just said 20 that there was information in the control room 21 about where temperature sensing devices were 22 located.
23 Q
Did the control room tell you where each 24 of the temperature reading devices for the relief O(_/
25 valves was located?
i i
Frodorick 292
()
2 A
They could be located on diagrams, yes.
3 Q
It could be located on diagrams?
4 A
We have a complete set of construction and flow prints in the control room,.
5 O
6 Q
My question is did you ever look at those 7
flow prints and diagrams to determine where these g
devices were loceted?
A Yes, I can quite readily locate them on 9
10 flow diagrams that we used for system operation.
11 Q
And you did before the accident?
12 A
Yes.
()
13 Q
So the short answer to this entire line 14 of questions is that you did make an effort before 15 the accident to find out both the location of the 16 three valves and the physical location of each of the 17 temperature reading devices associated with those 18 valves?
19 A
No, perhaps you don't understand the flow 20 diagrams.
The flow diagram is a representation of 21 the schematic of the system.
22 Q
I understand.
23 MR. SELTZER:
Are you finished?
l 24 THE WITNESS:
No.
O 25 MR. SELTZER:
Why don't you let him finish.
l l
1
1 Frodorick 293 2
A The diagrams that we used in the operation 3
f the plant were not designed to locate them 4
geographically in the building.
They were located on 5
the diagram in accordance with how the system needed (gg 6
to be operated, how the components were hooked together.
7 Q
Is it your testimony that you understood 8
before the accident that there was no diagram in 9
existence which was available to you which showed the 10 physical location of these devices?
11 MR. SELTZER:
What do you mean by the "P ysical location"?
h 12
()
13 MR. FISKE:
Where'they were placed on the 14 Pipes.
15 A
I said that wc.kad flow diagrams and 16 construction prints which are called isometric 17 diagrams which, if there was a reason for locating 18 any component, for instance, for maintenance, if you 19 wanted to go in and find it quickly, you could use 20 those diagrams to know where to go.
21 Q
Did you do that before the accident?
22 A
I had occasion to use those diagrams 23 frequently, but I don't recall having to use them for 24 these temperature detectors.
l
%.)
25 Q
And you never made a specific effort to
1 Frodorick 294 i
[']
2 use them for the specific purpose of finding out
\\_/
where these detectors were located?
3 4
A I don't recall ever having located these 5
indicators on those prints.
lll 6
Q The pressurizer system failure procedure 7
in symptom A.1 refers to relief valve discharge line 8
temperatures exceeding the ncrmal 130 degrees 9
Fahrenheit.
Do you see that?
10 A
Yes.
11 Q
Did you know before the accident that for 12 some period of time the temperature readings had been 13 in excess of 130 degrees?
14 A
Yes.
15 Q
For how far back before March 28, 1979 16 had the temperatures been in excess of 130 degrees?
17 A
I don't know the exact length of time.
I 18 know it was savoral weeks.
~
Q EowJhigh were those temperatures during 19,
' 20 that period of time?
o s'
t 21 A,, +
r I am afraid I don't recall, but I know we
'c 22 can find it on one of the old logs.
lk
/},.,
i 23. '
Q Could you look at your Keneny deposition 4
1 2k testimony on,the bottom of page 305 and the top of 1
o 7-3 0 5.,, $
' l 25 h:#
page
{/
..z
_/ r
);
s t'<
4 1
J
\\ ~"
a-
1 Frodorick 295 m
)
2 Does reading the testimony on page 306 J
3 help you in any way to recall now what the temperatures 4
were before the accident that you were seeing?
5 A
Yes, I can see here at that time I gg 6
remember the temperatures to be in the 190 to 195 degree 7
range.
I think I would agree with that.
8 Q
Was that for all three temperature g
reading devices?
+
10 A
That they were all reading in that range?
11 Q
Yes.
12 Q
I would say that is approximately correct.
' 13 Q
Didn't you conclude from that that one of 14 the valves was leakino?
f 15 A
In this testimony or as I recall?
16 Q
Forget the testimony for now.
I am asking
)
17 you didn't you before the accident conclude that one l
18 of the three valves was leaking?
1 19 A
Are you asking me did I conclude that l
20 separately and independently based only on those 21 temperatures?
22 Q
No, did you conclude before the accident 23 that one of the valves was leaking?
24 A
I believe that conclusion was arrived at rx
\\)
25 by others, and it was related to me one time when I
l 1
Fredorick 296 l
(O) 2 came on watch as to what the reason for those high 3
temperatures was.
4 Q
You yourself before the accident were aware 5
that one of those valves was leaking, isn't that g
6 correct?
7 A
I was aware that it was the opinion of 8
the operations department that the cause of those high 9
temperatures was a leak.
10 Q
Directing your attention to page 27 of 11 the testimony that you gave in your interview with 12 the President's Commission, Messrs. Hollis, Bland t
(
13 and Dicker.
As you recall, there are two sets of 14 numbers.
It is the first set.
15 Do you have it in front of you?
16 A
Yes.
17 Q
Directing your attention to the middle of 18 the page, the centence that reads, "There was a leak 19 on the electromatic relief valve - designation being 20 RC-RV2."
21 Do you see that sentence?
22 A
Yes, I do.
Is this my answer?
l l
23 Q
This is a transcript of the tape of the 24 interview that you had with Mr. Hollis, Mr. Bland and 25 Ms. Dicker on May 10, 1979.
I think we referred to it
1 Fredorick 297 gN 2
yesterday or the day before.
A I see that sentence that you pointed out 3
4 is there.
It is in part of an explanation that I was 5
giving as to how the pressurizer works.
g 6
Q Right.
Is RC-RV2 what is called the 7
pilot operated relief valve?
Is that the designation 8
for that valve?
9 A
Yes, I recall that as being a designation 10 for the valve, and in this deposition I was explaining 11 what we had concluded after the accident.
12 Q
I'm sorry?
-13 A
I was answering that this sentence that we O
14 are looking at seems to be part of an explanation 15 post-accident as to what I thought was happening.
16 Q
Are you telling us that when you made 17 that statement in that tape, you were not referring to 18 something that you knew before the accident?
19 A
Yes.
20 Q
Let's go on to the next page.
You see 21 the bottom of page 27.
After you finished the answer 22 of which that sentence that I just read you is a part, 23 the next question is, " Question:
Why was this 24 happening?
13
(,)
25
" Answer:
0.K.,
because there was a little
1 Fredorick 298
()
2 leak, whatever size leak, in that relief valve.
3
" Question:
When did that occur?
Were you 4
aware of that at the time?
5
" Answer:
several weeks before.
What I am 6
saying is a leak in the valve, a leak through the valve, 7
the seep was not firmly down on the valve seat. From 8
a distance the seep could not meet it so there was steam 9
escaping through the valve to the reactor core 10 (inaudible).
11
" Question:
Would you characterize that as 12 a malfunction?
(}
13
" Answer:
It was a malfunction that they 14 chose not to work on because it didn't affect the it 15 was not a safety-related valve and in order to fix it, 16 you had to shut down and drain the reactor cooling 17 system or cool it down and take the valve apart and fix 18 it and put it back together and start up.
I hate to 19 say it, it is a very sensitive operation to fix that 20 valve and we could operate without that valve in 21 service.
O.K.,
it meant just once in a while we had 22 to flush out the pressurizer which is not a big deal."
23 Do you see that?
Those questions and those 24 answers from the statements you made on May 10th?
25 A
Yes, I do.
Again, I think I was answering
1 Frederick 299 2
using post-accident analysis of what had happened during the accident.
3 4
Q In other words, when you were asked in the question, "When did that occur? W'ere you aware of 5
ggg 6
that at the time?" and you answered "Several weeks 7
before"?
8 MR. SELTZER:
I guess that shows one of 9
the problems of asking compound questions.
There 10 are two questions there.
When did that-occur 11 and were you aware of that at the time.
12 It is very difficult to tell to which
/~N 13 question the response is.
U 14 Q
Is it your testimony now that you were not 15 aware before the accident that there was a leak in the 16 Pilot operated relief valve?
17 A
It is my testimony that I was not aware 18 which valve was leaking for sure, and the answer to 19 this question that we have been discussing, when did 20 that occur, I was not discussing the leak at all.
I 21 was discussing the boiling process and the flushing 22 Process that had to occur as a result of one of the 23 leaks in the valves, and that in the question, when i
24 did that occur, is referring to the times that we had r
N 25 to flush the pressurizer.
1 Frcdorick 300 2
Q So it is your testimony that you learned v
sometime after the accident that the PORV had been 3
4 leaking before the accident?
5 A
I'm sorry?
ggg 6
MR. SELTZER:
Objection.
What is the 7
foundation for knowing that it was the PORV that 8
had been leaking rather than some other valve on 9
top of the pressurizer?
10 MR. FISKE:
The answer on page 27, "There 11 was a leak on the electromatic relief valve -
12 designationibeing RC-RV2."
13 Q
You just tactified, I believe, that when O
(
I
'/
14 you said that you were talking about something you 15 learned after the accident, not something you knew 16 before the accident, is that your testimony?
17 A
I am testifying that when I made that 18 statement there was a leak in the electromatic relief 19 valve based on conclusions that I had made or had been 20 made aware of by May 10, 1979, and I would like to say 21 that they still haven't determined that it was the O
22 electromatic relief valve that was leaking.
23 (continued on the following page.)
24
(~ )
25 q_
hd1 1
Frederick 302 O(_/
2 MR. FISKE:
We are resuming after a short 3
break, during which Mr. Seltzer made a telephone 4
call.
5 MR. SELTZER:
And why did you feel it was ggg 6
necessary to note that I took a telephone call?
7 MR. FISKE:
I am just saying it is a short 8
break.
9 MR. SELTZER:
Let the record note that we 10 are taking a short break while Mr. Fiske takes i
11 a telephone call.
12 BY MR. FISKE:
(O 13 j
Q Look again at the answer you gave at page 14 28.
15 Do you see the answer, the third answer 16 down the page, where it says, "It was a malfunction 17 that they chose not to-work on because it didn't 18 affect it was not a safety-related valve"?
19 Do you see that answer?
20 A
Yes, I do.
21 Q
What valve were you referring to in that O
22 answer?
23 A
I think I was referring to the electromatic 24 relief valve in that the discussions I heard after the g3
' _]
'x 25 accident, I was giving some of the reasons that it l
l l
l l
2 1
Fredorick 302
)
2 hadn't been worked on.
J 3
Q In other words, you understood that the 4
reason why no work had been done to eliminate the 5
leaking before the accident was because a determination ggg 6
had been made that the leak was coming from the pilot 7
operated relief valve, which was not a safety-related 8
valve?
9 A
No, I don't want to characterize that as 10 something I knew before the accident.
This is one of 11 the reasons that was given me as an explanation after 12 the accident.
/~T 13 Q
I know.
I understand.
I don't think you O
14 listened to my question.
15 (Record read) 16 Q
If I can make that question a little 17 clearer, do I take it that what you were saying was 18 you learned after the accident that the reason no work 19 had been done before the accident to fix the leak was 20 that a determination had been made that the leak was 21 coming from the pilot operated relief valve, which was O
22 not a safety-related valve?
23 MR. SELTZER:
Are you asking him to 24 confirm that the PORV is not a safety-related b
\\~'
25 valve?
3 I
Frodorick 303
{}
2 MR. FISKE:
No.
3 Mr. Seltzer, just let him answer the 4
question.
5 MR. SELTZER:
Is that part of your 6
question, to confirm that the PORV is not a 7
safety-related valve?
8 MR. FISKE:
He already said that when he 9
told the Kemeny Commission that they chose not 10 to work on it because it was not a safety-related 11 valve.
He was referring to the pilot operated 12 relief valve, so I think we already established
'13 that.
{'/S s_
14 I would like to have an answer to the 15 question I just put to Mr. Frederick.
If you 16 would like to hea.- it again, the one that 17 starts in terms of what you knew or learned after 18 the accident.
19 (Reco.-d read) 20 A
No, I was not aware of a determination 21 that had been made prior to the accident that the PORV O
22 was, in fact, the leaking valve.
l 23 Q
When you said it was a malfunction that 24 they chose not to work on, do you see that in your
\\
25 answer?
Do you see that part of your answer?
1 Frodorick 304 2
A Yes.
3 Q
That reflects, does it not, a decision 4
made before the accident, somebody had chosen not to 5
work on it before the accident, isn't that right?
G 6
A Yes, I have to say that in the operations 7
and maintenance supervision, the group which felt that 8
it might be the PORV, it might be leaking as opposed to 9
the code safety valves which some of the others thought 10 might be leaking, a decision in my mind had obviously 11 been made not to work on the valve, because I did not 12 observe any work occurring on the valve.
b) 13 Q
Did you understand the reason that a
%./
14 decision had been made -- did you understand after the 15 accident that the reason that the decision had been 16 made before the accident not to work on it was because 17 the determination had been made that the leak was 18 coming from a valve which was not a safety-related 19 valve?
20 A
No.
21 Q
You are not telling us now, are you, that O
22 you did not make this statement to Mr. Hollis, Mr.
23 Bland, and Ms. Dicker, which I have just been reading 24 from?
O 25 MR. SELTZER:
Is that the same as asking
5 1
Frodorick 305 O
/
2 him whether he recalls making the statement that 3
appears in the middle of page 287 4
Q I am asking you whether you are testifying 5
that you did not make such statements, the statements 6
that I have read to you?
7 A
No, I am not stating that I did not make 8
or give this answer to this question.
What I am 9
saying is this question was completely characterized by 10 my post-accident knowledge, which came between Marc.h 11 28th and May 10, 1979.
12 Q
That is the answer that you would like to 13 leave us with, is that correct?
14 MR. SELTZER:
What are you talking about, 15 leave us with?
That is the testimony he has just 16 given.
17 Q
The emergency procedure pressurizer system 18 failure on Section A, leaking pilot operated relief 19 valve, after it lists cymptoms including relief valve 20 discharge line temperatures, exceeding the normal 130 21 degrees Fahrenheit, it lists in Section A.2 under O
22 "Immediate Actions," as a manual action, "Close the i
23 electromatic relief isolation valve RCV-2."
24 Do you see that?
(
/
v 25 A
Yes.
306 5
1 Fredorick 2
Q Was the electromatic relief isolation 3
valve closed before the accident?
4 A
I don't recall at this time whether the 5
valve was closed for a period of time prior to the g
perhaps it may have been 6
accident in an effort to 7
done in an effort to test whether that, in fact, was 8
the leaking valve, and I am not aware of it.
9 Q
Isn't it a fact that you knew before the 10 accident that the valve had -- the block valve was not 11 shut?
12 MR. SELTZER:
You mean on the morning of
(}
'13 the accident, the valve was not shut?
14 Q
That the valve had not been shut.
15 MR. SELTZER:
Had never been shut in the 16 past?
17 Q
Isn't it a fact that you knew that after 18 the temperatures reached the elevated levels which you 19 have previously described in your testimony this 20 morning, the block valve was not shut?
21 MR. SELTZER:
You are asking him whether 9
22 he is aware that on no shift on any day during 23 the weeks before the accident was the block 24 valve shut?
I 25 MR. FISKE:
Yes.
7 1
Froderick 307
()
2 Q
Isn't it a fact that it was your 3
understanding as of the day of the accident that the 4
block valve had not been shut during the period of 5
time that these elevated temperatures occurred?
6 A
I can only say that I was not aware that 7
it had been shut during that time, but I can't say 8
that lack of my awareness precluded it from having 9
happened.
10 Q
Isn't it a fact that you felt that it 11 should be shut and that you couldn't understand why 12 it wasn't?
f)
13 A
I think I can recall thinking that it N_/
14 might be advantageous to cycle the valve, to see if 15
.the PORV was the leaking valve, if it could be 16 determined, and then I think that I finally went along 17 with the arguments which said that it should remain 18 open.
19 Q
What do you mean by cycling the isolation 20 valve?
21 A
close it and then open it.
O 22 Q
close it long enough to see whether or 23 not the leak was com'ing from the PORV?
24 A
Yes, close it just long enough to make a O
25 determination that it might be one of the contributors
8 1
Frodorick 308
/~h 2
to the leak rate.
_]
3 g
Let me read you some questions and answers 4
from an interview that is dated April 6, 1979, which is 5
an interview captioned "TMI Staff Interview, Ed ggg 6
Frederick, April 6, 1979, Conducted by T.
Van Witbeck, 7
et al."
8 MR. FISKE:
Mark this as B&W Exhibit 655.
9 (Document entitled "TMI Staff Interview, 10 Ed Frederick, April 6,
1979, Conducted by T.
11 Van Witbeck, et al." was marked B&W Exhibit 655 l
12 for identification as of this date.)
("N
'13 BY MR. FISKE:
V 14 Q
I am going to refer you to one question 15 and answer which appears on the fourth page.
16 Were you interviewed by Mr. Van Witbeck 17 and others at the Island on April 6th?
18 A
Mr. Van Witbeck was a contractor, and I 19 saw him on many occasions.
It wasn't an interview like 20 we are having here today.
It was just meetings that 21 we had.
O 22 Q
Reading from page 4 of this transcript, 23 this is dated April 6, 1979, " TEAM: did RCRV-2 ever 24 stick open before?
25 FREDERICK:: av'alv'e has-been leaking for weeks.
3 1
Frederick 309 2
- We had a relief valve, but,we weren't doing 3
anything about it.
It was either one of the two code 4
safety valves or RCRV-2.
Prior to the accident, we g
5 didn't want to cycle the isolation valve RCRV-2, 6
because we were afraid it might stick shut.
It sounds 7
like a screwy ergument to me.
I think they should 8
have shut it anyway to see if they could stop the 9
leaking.
I know for weeks we had to process a 10 lot of water and had difficulty keeping boron 11 concentration equalized in the primary system."
12 Did you give that answer to the team
'13 headed by Mr. Witbeck in this discussion approximately 14 a week after the accident?
15 A
Yes.
16 This was after the accident.
This answer 17 characterizes both my pre-accident knowledge of the 18 situation and my post-accident impression of our 19 actions.
20 Q
My immediate question simply is whether 21 that is an answer that you gave, and if you want to 0
22 MR. SELTZER:
He answered that.
4 23 MR. FISKE:
He added something which is not 24 responsive to the question, which I will move O
25 to strike.
t
1 Frederick 310 2
MR. SELTZER:
I thought it was responsive.
3 Q
Why did you think the position that the 4
block va_ve should not be cycled was screwy?
5 MR. FISKE:
Withdrawn.
ggg 6
Q I take it from this statement that there 7
were people that didn't want to cycle the isolation 8
valve because they were afraid it might stick shut, is 9
that correct?
10 A
Yes.
11 Q
It is correct also that you thought that 12 was a " screwy argument," is that correct?
N
_J 13 MR. SELTZER:
Thought that at what point 14 in time?
15 MR. FISKE:
At the time he made this 16 statement, a week after the accident.
17 A
It seems that a few days after the accident 18 I did have that impression of our actions prior to the 19 accident, yes.
It would have seemed like a simple thing 20 to do after the accident in relationship to the 21 cataclysm that we were going through at that time.
9 22 Q
Your testimony is that when you said it 23 sounds like a " screwy argument" to me, that you didn't 24 think it was a screwy argument before the accident, is
(-
'% /
25 that your testimony?
1 Frodorick 311 2
A Yes.
3 Q
Why did you think it was screwy to think 4
that the block valve might stick shut?
5 MR. SELTZER:
Objection.
No foundation ggg 6
that that is what he thought was screwy.
7 MR. FISKE:
That is exactly what his 8
answer says.
For heaven's sake.
9 MR. SELTZER:
For heaven's sake, yourself.
10 That is not what his answer says.
11 MR. FISKE:
Let me read it, quote, Prior 12 to the accident, we didn't want to cycle the I~
13 isolation valve because we were afraid it might
()D 14 stick shut.
It sounds like a screwy argument 15 to me."
16 MR. SELTZER:
The possibility that the 17 block valve might 18 MR. FISKE:
Please.
You don't have to 19 interject.
i 20 BY MR. FISKE:
l 21 Q
Is it correct that you felt that it was.
22 screwy to think that the block valve might stick shut?
23 A
No.
24 Q
What did you think was screwy?
bo 25 A
By this testimony, I was including myself
1 Frederick 312 O
(_/
2 in the term "we."
Prior to the accident, we didn't 3
want to cycle the isolation valve because we were 4
afraid it might stick shut.
The answer here doesn't 5
show any paragraphing or pausing or how I was trying ggg 6
to separate these thoughts, but I am trying to explain 7
now the separation occurs at the end of that sentence 8
as being my post-accident impressions of what would 9
have seemed at that time to be a small action that 10 might have added some clarification to the situation 11 prior to the accident.
Just Monday morning 12 quarterbacking.
(m) 13 Q
Why did you think it was screwy not to 14 shut the cycle, the block valve?
15 MR. SELTZER:
Asked and answered.
I 16 object.
17 A
I think the term " screwy" here might be 18 drawing more attention than necessary.
In these few 19 days, April 6th, after the accident, we were in the 20 midst of quite a turmoil there and this is probably l
l 21 one of the biggest incidents of my life.
What I am O
22 saying is if you compare all of that activity and all 23 of the turmoil at that time to the relative calm and I
24 peace before the accident, it just seemed odd that we (s
25 hadn't taken that action prior to the accident.
It is
1 Frodorick 313
[')
2 such a small thing to do, but in the light of the V
3 arguments that existed prior to the accident, it seemed 4
quite logical not to cycle it before the accident, but 5
it seems like it should have been something we should gg 6
have considered doing.
7 Q
In other words, you thought that after 8
the accident that the risk of having a block valve 9
stick shut was outweighed by the valve determining 10 whether or not the leak was coming from the PORV, is 11 that correct?
12 A
No, I don't think I said here that cycling
(']
~13 the block valve would have solved the problem of which
'V 14 valve was leaking.
It would have -- it could possibly 15 have eliminated the PORV as a source of the leakage.
16 Q
That is my question.
Isn't it a fact that 17 a week after the accide.nt, you felt that the risk of 18 having a block valve stick was outweighed by the 19 benefit of possibly being able to determine whether the 20 leak was coming from the pilot operated relief valve?
I 21 A
At the time, the discussions were that j
h 22 that outweighing might be present, and it was one of l
23 the impressions I held at that time, but I feel that l
24 as more information was derived from analysis of the 1
l'hJ 25 accident, I think I changed my mind.
I certainly don't
1 Frederick 314 s) 2 feel now that having cycled that valve prior to the 3
accident would have in any way prevented the accident 4
or caused us to take any different actions.
ggg 5
Q Is it your testimony, and if it is we will 6
go on to something else, is it your testimony that it 7
was only after the accident that you concluded that 8
the benefits of being able to determine whether a leak 9
that was coming from the PORV outweighed whatever risk 10 there was that the block valve might stick?
11 A
I think the answer that I gave to the 12 questions just a minute ago answered that pretty good.
()
13 Q
Is the answer yes?
14 A
The answer is what I gave before.
15 Q
I want an answer to that question.
16 A
I think I did answer that before.
17 MR. SELTZER:
Which answer before are you 18 referring to?
19 (Discussion off the recor'd between the 20 witness and his counsel.)
21 (continued on next page)
O 22 l
23 24
(-
x_,
25
1 1
Frodorick 315 2
(Record read back by the reporter.)
A At this point on April 6 after the accident, 3
4 I felt that there was such an outweighing, but as I 1
5 said, later on I went on to change those ideac as I g
6 learned more about the accident.
7 MR. FISKE:
I don't think I understand 8
that answer.
Could you read it back?
9 (Record read back by the reporter.)
10 Q
Are you saying that you changed your mind 11 again at some point after April 6th?
12 MR. SELTZER:
What do you mean by "again"?
~13 MR. FISKE:
Apparently he is saying that 14 he changed his mind as to whether the benefits 15 of learning whether the leak came from the PORV 16 outweighed the risk of having the valve stick, 17 between the view that he held before the 18 accident and a week after the accident. And in 19 the week after the accident, he is apparently 20 testifying he changed his prior opinion.
21 I understood his last answer to suggest 22 that he changed his opinion again at some time 23 after April 6th, and I am trying to find out if 24 that represents a second change of opinion or O(/I whether he was merely confirming the first one.
25
Frodorick 316 1
[]
Q If you would like to hear your answer v
again --
A No.
You are asking me if I had changed my opinion again.
At this point after April 6th?
Q Yes, did you change it again after April 6th?
7 A
I can say that my opinions as to the causes 8
and the events that led up to the accident changed g
quite a few times in the months following the accident 10 as we learned more about it and the industry learned gg m re about it.
12 13 Q
At some time after April 6th, did you g
change your mind again and go back to the view that you g
say -- and go back to a view that closing -- that the risk of having the valves stick outweighed the benefits 16 of g
learning whether the, leak was coming from the PORV?
Is that what you meant by ycur last answer?
18 A
I meant that I changed my mind several 19 times after April 6th.
g Q
On that question?
g A
22 on many questions concerning the accident.
23 Q
I am just asking about this one for the m ment.
Did you change your mind after April 6th on 24 whether or not the risk of having the block valve stick 25
Frodarick 317 1
m outweighs the benefit of learning whether or not the g
2 leak is coming from the PORV7 3
A I can't say that I have specific recollectior.
4 of changing my mind on several occasions concerning this G
incident.
I barely remember the testimony that you have 6
shown me heres the fact that I considered that a few 7
more times after the accident would seem logical to me, but when and if I changed my opinions, we have to check other testimony to find out if I ever talked'about it
- again, Q
What is your opinion right now?
g A
My opinion now is that it would have made O
little difference on the day of the accident whether 14 we had cycled that valve earlier or not.
Q What is your opinion now as to whether the 6
risk of having the block valve stick outweighs the 18 benefits of learning whether the leak is coming from the PORV?
MR. SELTZER:
I think his last answer is perfectly responsive to that.
If there is h
little benefit from cycling it, that answers your question.
A Are you still on the question what is my opinion today?
Frodorick 318 1
I) 2 Q
Yes, on that subject.
I want to know V
whether you changed your opinion again.
3 MR. SELTZER:
Why do you put this pejorative 4
tint on his answer?
ggg 5
6 MR. FISKE:
I am picking up from his last answer.
7 8
MR. SELTZER:
Why don't you state the 9
question so it is clear on the record what the 10 witness is responding to.
11 Q
What is your opinion today as to whether 12 the risk of having the block valve stick outweighs the
{v~')
13 benefits of determining whether the leak is coming from 14 the PORV7 15 A
The risk today is the same as it was prior 16 to the accident.
It might stick and it might not stick, 17 and the reason for shutting it would be only if the 18 leakage was a real problem,and my opinion now would be 19 not to cycle it unless the leakage rate was a problem.
20 Q
By the leakage rate, you mean the amount 21 of accumulated leakage or the rate at which the leakage O
22 is flowing?
23 MR. SELTZER:
Which question are you asking?
24 MR. FISKE:
I think it is the same.
(~h)
I 25 MR. SELTZER:
No, the accumulated flow is I
1 Frodorick
.319
()
2 a lot different from the rate of flow.
3 Q
By rate, you meant flow; is that correct?
4 A
Gallons per minute.
5 Q
Going back to this emergency pressurizer ggg 6
system failure procedure, do you have that in front of 7
you?
8 A
Yes.
9 Q
Do you see where it says symptom number 1,
10 relief valve discharge line temperature exceeding the norma 130 degree alarm on computer 200 degrees Fahrenheit?
11 12 A
Yes.
(}
13 Q
You understood, did you not, that that was 14 a symptom of a leaking pilot operated electromatic 15 relief valve, right?
16 A
As I have said, I would not attribute the 17 130 degrees to any individual valve.
I would think 18 that one of the valves is leaking.
That is what I 19 thought prior to the accident, one of the valves was 20 leaking.
21 Q
Where it says manual action close the O
22 electromatic re. lief isolation valve, do you see that?
23 A
Yes.
24 Q
That doesn't say in that procedure close
}
25 the electromatic relief isolation valve only if you
g Frodorick
~320 m
(
)
2 determine that the flow rate is a probicm, does it?
v A
N but the manual action is referring to 3
4 the conclusion that you made that actually the 5
leak is through the pilot operated relief valve.
6 If you made that conclusion, that action might be 7
called for.
8 Q
Why did you understand it was important to g
close the block valve if there was a leak from the 10 PORV?
11 A
It would only be important to me in my 12 understanding if the leakage was a problem in meeting
('N 13 the leakage specifications which determine whether d
14 plant operation can continue.
15 Q
Is there anything in this procedure that 16 says the only time you have to close the block valve 17 is if the leak rate ir at a certain specified level?
18 A
No, but this procedure is not the only 19 thing governing my actions in the control room.
20 Q
Did you feel free to disregard this 21 emergency procedure simply because you yourself felt 22 that it shouldn't apply unless there was some 23 specified flow rate of leakage?
24 A
Certainly I felt that I could take O
25 advantage of all the information in the control room to
1 1
Frodarick
'321 (D
/
2 make a decision of that nature, including other v
3 procedures, technical specifications, limits and 4
precautions and previous experience.
5 Q
So your answer to my question is yes?
ggg 6
MR. SELTZER:
He answered your question 7
very fully.
8 Q
Did you ever go back to the people that 9
wrote these procedures and say these procedures are 10 confusing, we shouldn't have to close the block valve 11 every time, you should write into those procedures 12 some designated flow rate of leakage before we close
()
13 the block valve, or did you think that could be left 14 to the individual judgment of each operator as to how 15 much of a flow rate he thought was a problem?
16 MR. SELTZER:
Is3that a speech or one
\\
s 17 question?
18 MR. FISKE:
One question.
19 MR. SELTZER:
State your one question.
20 MR. FISKE:
That is it.
21 MR. SELTZER:
Don't answer it.
22 Q
Did you think it should be left to each 23 individual operator to determine what flow rate level 24 was a problem before he decided not to close the block l
\\_/
I 25 valve?
i g
I
~
'r}
I 4
/
Frodorick 322 i
g
[^')
A Yes,,each operator should use the limits 2'
say and prochdures an(I guidelines given to him to operate p.
l,?
, j before ha makes any, decisions like this, yes.
'/
l i,/
y Q
no as'you understood the implementation of a
i
. -')
6 this procedure, the block valve might be closed one
[7 time and it,r.ight not be closed another time, depending on the individual judgment of the particular operator
,8 ' y,
j if#
r-
/
9 as to whether he felt the flow rate was at a level that ha" felt wa s.s p r.ob l eia, is that correct?
! 10 II, h
I doubt that any operator would take s
4 J
q;2'
.indpendent.sction of that nature or make the decision
,.i s
13 without collaborating with his fellow operators.
If x.). c 14 I
there,was some confusion in his mind, he would make an
,e
[
15 attempt to clear it up.
I certainly would.
Ii 13 Q
Did you understand that there were any 17 ot'her unwritten conditions to the implementation of this
,s
^"
18
. ' ' procedure besides an ad hoc judgment on the spot as to
.19 whether the flow rate was a problem?
fg l
MR. SELTZER:
Objection.
No foundation that 21 there wore unwritten conditions.
The witness 22 '
referred,in his prior testimony to limits and 23 L
precautions, other procedures, technical specifications; l~
!n 24 all'of those are written.
i.
25 MR. FISKE:
I am referring to unwritten in I.
i' d
I Frodorick 323 2
this procedure.
A can I hear it again?
3 4
(Record read.)
A What is ad hoc?
g 5
6 Q
on the spot.
7 (Record read.)
8 MR. SELTZER:
What do you mean"besides an 9
on-the-spot judgment?"
10 HR. FISKE:
The kind of judgment he just 11 talked about.
12 MR. SELTZER:
A judgment based on technical O
13 specifications, limits and precautions, other d
14 procedures, and prior operating experience?
Is 15 that what you mean by on the spot?
16 MR. FISKE:
I am talking of the judgment 17 he just referred to in his prior answer.
18 A
I didn't mean to say that the judgments made 19 by the operators are in any way on the spot or made 20 quickly.
They are usually quite deliberative.
21 Q
However they are made, did you understand 22 there were any other conditions to the implementation 23 of this emergency procedure which were not written 28 into the procedure besides the judgment of the operator A
25 as to whether the flow rate was at a sufficient level to be a problem?
1 Frodorick 324 A
Yes, there are many other considerations 2
v that should come into the decision-making other than 3
what is written in this procedure.
4 5
Q Where were some of the other conditions ggg 6
that would limit the application of this emergency 7
procedure that are not written into it besides the 8
judgment an operator reached as to whether or not he felt the flow rate was at a level which was a problem?
9 10 A
I think in previous questions we brought 11 out a few of the concerns, such as the problems which 12 may become compounded by taking this actions that is, 13 having the valve stick shut, what effect did that have gg O
14 on the overall safety of the plant.
That was one 15 consideration.
16 Another might be are we taking the right 17 action based solely on these symptoms.
Shouldn't we 18 before we operate or take this manual action, shouldn't 19 we consider that the source of this high temperature 20 might be some other valve.
21 I am sure a discussion would ensue on, even 22 if we don't cycle the valve at this point, what effect 23 would that have on continued operation in relation to 24 the leakage rate.
/'N
'(.,)
25 All of those things would be discussed
Frodorick 325 g
/' n 2
before this action would be taken.
This is not what V
Iw uld call a quick response emergency situation.
3 4
Q Just to put it in simplest terms, you did nt understand this procedure to mean that if it was ggg 5
6 diagnosed that there was a leaking pilot operated relief 7
valve,that you were required to close the block valve; 8
is that your testimony?
9 A
No, I don't think that I had said that. I said 10 that in the event that we were unsure which valve was 11 causing the leakage, we wouldn't even be in this 12 procedure.
(~
13 Q
I think we understand that.
I have been
(_)/
14 asking you a series of questions based on the 15 application of this procedure, and I think my last 16 question was, and I want to make sure I understand your 17 answer, are you telling us that.it was vour 18 understanding of this procedure before the accident that 19 you did not have to close the block valve even if in 20 applying the symptoms in this procedure, it was 21 determined that there was a leak from the PORV?
22 A
I don't remember having thought prior to 23 the accident that the symptoms in this procedure were 24 capable of making that diagnosic that the PORV was O
25 leaking.
a
g Fr0d0 rick 326 Q
Y u mean y u didn't think these symptoms 2
b were sufficient to help you determine whether the PORV was leaking?
4 A
They were only sufficient to show me that 5
the PORV might be leaking among the other valves.
6 Q
How did you understand before the accident 7
g you could make a determination as to which one of the three valves was leaking?
g 10 MR. SEMZER:
Objection.
No foundation.
Q You can answer that.
gg A
I think it is apparent from my previous 12 testimony and others that you have cited that I didn't 13 know how to determine which one was leaking.
34 15 Q
You did know, though, that one way to 16 determine whether the PORV was leaking would be to close the block valve?
37 A
I can't say that closing the block valve 18 w uld prove conclusively which valve was leaking, cut 19 i
wude mina e ne, yes.
20 Q
You knew before the accident that you could 21 h
determine whether the PORV was leaking by closing the 22 bl ek valve?
23 A
You are asking me again to give you my 24
)
understanding prior to the accident.
25
Frodorick 327 g
2 Q
- Yes, A
Even if y u did 1 se the block valve, if 3
the temperatures didn't change, I knew then that that 4
wouldn't give me any inf rmation saying that the PORV 5
g was not leaking, because the nature of that type of 6
7 gate valve which the block valve is, it could have 8
enough leakage to cause those high temperatures.
9 Closing the valve,I was convinced prior to the accident 10 that closing the valve would be inconclusive.
That is 13 why I didn't push for the argument that it be closed.
12 Q
So was it your understanding that the 13 pressurizer system failure procedure,to the extent that it prescribed closing the block valve as the action 14 15 to cure a leaking PORV,was inadequate?
16 A
It was my understanding that this portion 17 of the procedure was written for an emergency condition, 18 not for a small normal operating unomaly.
Not for 39 something that was just a small problem.
20 Q
That is not my question.
MR. FISKE:
Please put the question again.
21 22 (Record read.)
l I
23 A
No.
l 24 Q
Didn't you just say that you thought that pV 25 even if you closed the block valve, there still might
1 Frodorick 328 I
i e
2 be leakage from the PORV?
i
(
3 MR. SELTZER:
He said it would be 4
inconclusive.
5 A
Yes.
ggg 6
Q Did you understand taat closing the block 7
valve would not be of assistance to you in determining 8
either whether the PORV was leaking or whether the PbRV g
was not leaking?
10 MR. SELTZER:
You are focusing on his 11 pre-accident understanding?
12 MR. FISKE:
Yes.
' 13 A
I felt that it would be inconclusive in the Od 14 condition that we are in.
However, in a larger leak, 15 it would be helpful.
16 Q
Is your answer that you felt it would not 17 be of assistance in that size leak?
18 MR. SELTZER:
What size leak?
19 MR. FISKE:
The size leak that you had at 20 that time.
i 21 A
You are saying that it would not be helpful.
O 22 You are talking,of the manual action or the entire
(
23 procedure?
24 Q
The manual action.
('~N,)
25 A
That is correct.
I felt it would be
Frodorick 329 g
2 inconclusive with such a small leak.
3 Q
After the accident when you gave the 4
statement to Mr. Van Witbeck, did you have a different 5
understanding then as to what the size of the leak g
6 had been before the accident?
7 A
I don't know that I recall even now how 8
big the leak was.
9 Q
You testified that a week after the 10 accident, you felt that the block valve should have 11 been closed, correct, in your statement to Mr. Van 12 Witbeck?
And I take it by that that you felt at
'13 that time that closing the block valve would not have O
\\/
14 been inconclusive in determining whether the leak was 15 coming from the PORV, is that correct?
16 MR. SELTZER:
I think he said, and this 17 question has been asked and answered, that at 18 the time he was responding to Witbeck, he 19 thought it might be advantageous to cycle the block 20 valve to determine if the pilot operated relief 21 valve was leaking.
22 MR. FISKE:
That's right.
23 MR. SELTZER:
So you have that answer.
24 Why do you have to go back and re-ask it?
(~T
(_)
25 MR. FISKE:
Because he he.s said that a week
Frcdorick 330 1
before the accident, he thought it would be inconclusive for a leak of the size that they had, and unless he reached a different opinion J
4 in the next week as to the size of the leak, I I
w uld like to know why he felt a week after the 6
accident that it would not have been conclusive 7
f ra leak of that size to have closed the block 8
valve.
g 10 Q
Having laid out the whole question and the rationale, I hope you can answer it.
33 A
I don't see any difference in my Van 12 Witbeck testimony as to my opinion prior to the
^13 O
- accident, I still felt that it had some 34 15 Possibility of not being conclusive.
I said that it 16 might help.
17 (Recess taken.)
18 (Continued on Page 331) 19 20 21 0
22 23 24 O)
I 35 x_
>/1 1
Frodorick 331 2
Q I take it that you were not aware of any 3
analysis before the accident which had been made and i
4 which had determined that the leak was coming from 3
one of the code safeties, is that correct?
6 A
I don't recall being aware of an analysis.
7 An engineering analysis that determined that one of the 8-valves was leaking?
9 Q
Any kind of analysis that determined that 10 the leak was coming from one of the code safeties and 11 not the PORV.
12 A
I don't recall' that now, no.
13 Q
Did anybody tell you at any time that 14 any effort had been made at Met Ed before the accident 15 to try to determine from which valve the leaking was 16 coming?
17 A
I think I was aware prior to the accident 18 that the engineering department was trying to figure 19 out which valve was leaking.
20 Q
But I take it -- who told you that?
How 21 did you find that out?
22 A
I don't specifically remember, but we --
23 I had discussions with foremen and engineers.
They 24 come in the control room occasionally, and they might x/
25 have mentioned it.
g Frodorick 332
(~T 2
Q Might have or did?
V A
Might have.
3 4
Q I am not asking you for what might have 5
happened.
I am asking you for your be,st present ggg 6
recollection of what you knew before the accident.
7 Just so we all understand each other, let me go back 8
and put the earlier question again.
9 Did you know before the accident of any 10 effort that was being made at Met Ed to determine which 11 of the three valves was leaking?
12 MR. SELTZER:
He said he was aware of an 13 engineering department effort, and you want to 14 find out how he was aware of that?
15 MR. FISKE:
No, I am not clear whether 16 when he gave that answer he was talking about 17 what he knew or what he might have known.
18 I am going back and I want an answer to 19 that question.
20 A
I was aware prior to the accident that an 21 effort was under way by the engineering department.
O 22 whether that only consisted of Met Ed or a combination 23 of Met Ed and contractors and vendors, I don't know.
24 Q
How did you understand they were making A(_)
25 this effort?
How did you understand, what. method did
g Frodorick 333 2
you understand they were using to try to determine which f the valves was leaking?
3 4
MR. SELTZER:
Objection.
No foundation 5
that he knew or had an understanding what they ggg 6
were doing.
7 MR. FISKE:
That is what I am asking.
8 MR. SELTZER:
"What, if any,' understanding did',
9 you have" et "Do you have an understanding," either of 10 those questions elicit foundation. Your question did no 11 Q
Do we understand each other or do you want 12 me to put another question?
I will do it the way
'13 Mr. Seltzer suggested.
gS
(_/
14 Did you have any understanding betore the 15 accident as to the method that was being used by the 16 engineering department to try to determine which of 17 the valves was leaking?,
18 A
I don't recall at this time knowing what 19 method they wdre using.
)
20 Q
Did you ask anybody?
21 A
I don't recall asking anybody what method O
22 they were using.
Did anybody tell you at any time before 23 Q
24 the accident whether or not the engineering department O)
(_
25 had reached any conclusion as to which valve was
1 Frodorick 334
/~h 2
leaking?
()
A Again, I wasn't aware that there was a 3
4 decision made by the group that everyone agreed with of 5
which valve that was carsang the leakage.
G 6
Q I would like to go back to the pressurizer 7
system failure procedure and direct your attention to 8
the second page.
9 Before we get to that, let me direct your 10 attention to Section C of the pressurizer system 11 failure procedure which is captioned " Leaking Code 12 Relief Valve RC-R1A or RC-R1B."
13 Do you have that in front of you?
14 A
Yes, page 4.
15 Q
On the bottom it says, "See Point 3 16 follow-up action."
Do you see that?
17 A
Yes.
18 Q
And No. 3 is " Place code relief discharge 19 line temperatures on analog trend recorder."
Do you l
20 see that?
21 A
Yes.
1 22 Q
What is an analog trend recorder?
23 A
It is a paper recording device which is 1
I 24 capable of displaying a data point ih relation to time.
25 Q
sort of a moving chart?
1 Frodcrick 335
/~T (j
2 A
Yes.
3 Q
Like a cardiogram?
I don't mean that it 4
looks like a cardiogram, I mean it works on the same 5
kind of principle.
ggg 6
A I am sure a cardiogram is misch more 7
sophisticated.
This is just an ink pen tracing over 8
a piece of paper.
9 Q
Which would show temperatures in this 10 case for each of the code relief valves over a period 11 of time?
12 MR. SELTZER:
When you say "each of the,
(
13 code relief valves," do you mean both of them?
14 MR. FISKE:
Yes.
15 MR. SELTZER:
This says the discharge line 16 temperature, not the code relief.
17 MR. FISKE:
Let's go back.
18 Q
No.
3,
" Place code relief discharge line 19 temperatures on analog trend recorder."
What 20 temperatures did you understand that referred to?
21 A
That referred to the temperatures in the O
22 discharge line of the relief valves.
23 Q
And from your prior testimony, the analog 24 trend recorder would then display those temperatures
\\
(~h V
25 over a period of time, is that correct?
g Frodorick 336 2
A Yes, you would need to use more than one O
I trend recorder to get all the information.
3 4
Q Were the code relief discharge line 5
temperatures placed on an analog trend recorder at ggg 6
any time before the accident, any time in the several 7
weeks before the accident?
8 A
I don't recall.
9 Q
Were there still elevated temperatures 10 on the discharge line on the day before the accident?
11 A
Above the temperature that we talked about 12 before?
'13 Q
Yes, above 130.
O 14 A
Yes.
15 Q
were the code relief discharge line 16 temperatures on an analog trend recorder on the day of 17 the accident?
18 A
Again, I don't recall that we were trending 19 any of this information, because we hadn ' t entered into 20 this procedure.
21 Q
By "this procedure," you mean the O
22 pressurizer system failure procedure?
~
23 A
In general, yes, but specifically we are 24 talking of this Part C, the end of the follow-up actions,
()
25 there is one step that says place them on the trend
1 Frodorick 337
(-
2 recorders.
We hLdn't done any of the follow-up actions
(_
3 in this procedure or the beginning of this procedure.
4 Q
Going back to Section B, that refers to an 5
inoperative pilot operated relief valve, does it not?
ggg 6
A Yes, that is the title.
7 Q
B1 contains symptoms of an inoperative 8
PORV7 g
A Yes.
'ystem 10 Q
Symptom No. 2 is" Reactor coolant s
11 p.ressure is below 2,205 psig and RC-R2 fails to close."
12 Do you see that?
p 13 A
Yes.
'd 14 Q
Is it your understanding that the PORV was 15 supposed to clone once the temperature came back down 16 below 2205 poig?
17 A
I think the automatic set point for closure 18 of the valve was based on pressure, and that was 19 2,205 pounds, i
I l
20 Q
The next item is "RC-R2 discharge line 21 temperature is above the 200 degree Fahrenheit alarm."
O 22 RC-R2 refers to.the PORV, does it not?
23 A
In this procedure, that is what they are 24 using to designate the pilot operated relief valve.
\\>
25 The actual system designation is RC-RV2.
1 Frcdorick 338 2
Q But in this procedure
{~'))
s-A Y'8' 3
4 Q
And the discharge line temperature that is 5
referred to is the temperature reading for the ggg 6
instrument associated with the PORV discharge line 7
temperature, is it not?
8 A
Specifically, they want you to use computer 9
point 402.
I don't know what the label is on that 10 point.
It would just have the point number a~nd the 11 title and the number.
12 Q
In other words, that is the computer point r~S 13 that you would look to to determine this temperature, b
14 is that correct?
15 A
Yes.
16 Q
Did you understand that RC-R2 discharge 17 line temperature was a symptom of an open PORV7 18 A
Symptom No. 3?
19 Q
Yes, as opposed to a closed PORV.
20 A
I am trying to recall what I understood 21 prior to the accident.
Looking at it now, we are O
22 talking about any condition in which the pilot operated 23 relief valve is inoperative and that includes closed 24 and open.
This system says you have 200 degrees p
k-25 Fahrenheit and you have to apply that to which of the
g Frodorick 339
[^)
2 first two symptoms you have chosen to follow, whether
'O it is No. 1 or No.
2.
A certain amount of thinking 3
4 has to go into determining whether it is open or closed.
5 Q
That is what my line of questions is gg) 6 getting at.
In going through that line of thinking, 7
when you look at item 3, to see whether the RC-R2 8
discharge line temperature is above the 200 degree 9
Fahrenheit alarn, did you understand that that symptom 10 was supposed to be a symptom of an open PORV or was 11 that supposed to be a symptom of a closed PORV7 12 A
I think I had the understanding that the 13 temperature in excess of 200 degrees would indicate 14 that the valve was either open I don't think I 15 would make the conclusion that meant that the valve 16 was open, no.
I would assume from this symptom that 17 it means that it is in op.er ative in some way.
18 Q
Why did you think an elevated temperature 19 at the discharge line from the PORV was a symptom of 20 anything being wrong with the PORV?
21 A
Again, I didn't make the conclusion that O
22 an elevated temperature downstream of these valves 23 was a symptom of a problem with the PORV.
It was a 1
24 symptom of one of the a problem with one of the 25 valves.
You could see this identical symptom up here
1 Frodorick 340 b('~T 2
in Section A, computer point 200 degrees.
3 MR. SELTZER:
I think we are back at the 4
same point we were at yesterday where symptoms 5
can be a necessary condition but not a sufficient ggg 6
condition to define the occurrence.
7 MR. FISKE:
I agree with that completely.
1 8
MR. SELTZER:
I am saying that for l
l 9
everybody's benefit.
~
10 MR. FISKE:
We will movt along a lot faster 11 if we all understand that.
I am not suggesting 12 any of these symptoms is supposed to be in and e) 13 of itself determinative that it means that l
%)
l 14 condition and no other condition possibly exists.
15 I am using the term " symptom" in exactly 16 the came way the term " symptom" is used in the 17 Met Ed procedures.in the same way we defined it 18 yesterday.
19 Q
I think you understand that.
Don't you?
20 A
Yes, I just found it difficult to answer 21 that question without relating to it somehow.
O 22 Q
Didn't you understand that seeing 23 temperatures at the discharge line from the PORV above 24 200 degrees Fahrenheit above a point when an alarm
[^3
(-)
25 goes off was a symptom that the PORV might be open?
1 Frodorick 341 2
MR. SELTZER:
Just so it is clear, it didn't 3
necessarily mean that the valve was open but it 4
could be an indication that the valve was open?
5 MR. FISKE:
If the word "might" in my gg 6
question means anything other than what 7
Mr. Seltzer just said, then we need a new 8
definition of "might."
9 Q
Do you understand that?
10 A
Yes.
11 Q
Do you understand the question now?
12 A
Yes.
This symptom No. 3 could mean that.
13 Q
You knew as you said before that several 14 weeks before the accident that temperatures at the 15 discharge line indicators had been as high as 190 and 16 I think you even said 200 at one point.
Is that 17 correct?
They were up to or close to 2007 18 MR. SELTZER:
He testified today to 190 19 to 195.
That is pretty close to 200.
What is 20 the question?
21 Q
Did you have any discussions with anyone O
22 at Met Ed about revising i$em 3 in this procedure, 23 particularly the 200 degree Fahrenheit number,in light 24 of the fact that temperatures for several weeks had o-)
25 been at the elevated range that you just described?
11 1
Frodcrick 342 2
A No, I don't recall having done that.
I w uldn't have felt that this symptom was inconsistent 3
j 4
with all of the other information I had to deal with 5
in making a decision of this nature.
9 1
6 Q
Did you feel before the accident that this 7
symptom at No. 3 in B1 was just as good a symptom 8
with temperatures before the accident being at the 9
elevated levels that they ware as the symptom had been 10 before the temperatures reached those levels?
11 MR. SELTZER:
By "j ust as good a symptom,"
12 you mean just as good an indication that the valve 13 was inoperative?
14 MR. FISKE:
Yes.
15 A
It is just as good a symptom in showing 16 that the valve was inoperative as it is that it was 17 leaking in Part A.
It has the same quality.
18 Q
That isn't the question.
19 Section A refers.to a normal relief valve 20 discharge line temperature of 130 degrees, correct?
21 A
And a computer point alarm of 200 degrees.
22 Q
You knew for several weeks before the 23 accident that the temperatures were not 130 degrees.
24 They were significantly above that,as you said, as high
('N
(-
25 as 190 to 195, correct?
A Yes.
hd1 1
Frodorick 343 2
Q My question is, did you consider symptom 3
number 3 under B.1, "RCR-2 discharge line temperature 4
above the 200 degree Fahrenheit alarm" to be just as ggg 5
good a symptom of an open PORV with temneratures at 6
the elevated levels as it had been at the 7
time the temperatures were at their normal levels?
8 A
I don't recall having thought about that.
9 Q
Did you think about that during the day of 10 the accident?
11 MR. SELTZER:
Did he think specifically 12 about what, during the day of the accident?
13 Q
Do you understand the question?
rx 14 A
You are asking me if I thought about this 15 symptom and whether it was a good symptom at the high 16 temperature as well as the low temperature during the 17 accident?
18 Q
Yes.
19 A
No, I don't recall thinking about that.
20 Q
Did you have any discussion with any of 21 the other operators at any time during the first three 9
22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of the accident sequence on the question of 23 whether or not an RC discharge line temperature above 24 200 degrees Fahrenheit was a symptom of an open PORV i
(^N
(-
M that you could use on the day of the accident in trying
{
I 1
Frodorick 344 2
to diagnose what was going on?
3 A
No, I don't recall any discussions like 4
that.
5 Q
Let me read you some questions and answers ggg 6
from your Kemeny deposition, beginning at page 308, 7
line 15.
8
" Question:
Did it occur to anyone here 9
at Three Mile Island to modify this procedure 10 in light of the fact that there had--and what I 11 am referring to by 'this procedure' is Section B.7, 12 Emergency Procedure 2202-1.5 did it occur "13 to anyone to modify procedure number 3 under f3 14
' Symptoms' to account for the fact that you had 15 a leaking valve, and, therefore, you had a base 16 line temperature higher than you would have had 17 if the valve had been working properly?"
18
" Answer:
I don't know that that would be 19 a proper method.
You should change your limits 20 in the procedures to fit a malfunctioning piece 21 of equipment.
You should fix the equipment and O
22 not change the procedure.
I believe it was the 23 intent to repair that valve at the next 24 opportunity, rather than change the requirement p
I (s_/
25 that that temperature be maintained below 200 1
3 1
Frodorick 345
{J
}
2 degrees."
3
" Question:
To repair the valve would 4
require a shutdown?"
5
" Answer:
Yes."
ggg 6
" Question:
In the meantime, you have got 7
a situation where even though you say you should 8
repair the valve, in the meantime you have got a 9
valve which isn't repaired?"
10
" Answer:
Yes."
11
" Question:
You have a base line temperature 12 which is substantially higher?"
13
" Answer Yes."
x/
14
" Question:
Do you know whether there was 15 any notation made on your emergency procedure 16 to alert people to take that into account?"
17
" Answer:
No.
There is no approved method 18 for applying a temperature change to an emergency 19 procedure."
20
" Question:
Because of some equipment 21 variation?"
O 22
" Answer:
Any change in emergency procedure 23 will be made in the body of the procedure.
You 24 do not attach a note or any other type of
[']
(/
25 unapproved parameter to an emergency procedure."
1 Frodorick J46 7-s()
2 were you asked those questions and did 3
you give those answers?
4 A
Yes.
5 Q
I take it there was no change made in 6
the body of the pressurizer system failure procedure 7
to in any way change the temperature reading in symptom 8
number 37 9
(Discussion off the record between the 10 witness and his counsel.)
11 A
I understand your question to be that 12 there had been no changes to these temperatures prior
/~N 13 to the accident.
I wasn't aware of any changes.
14 Q
Was there any change prior to the 15 accident in the 200 degree Fahrenheit temperature that 16 is listed in symptom number 3?
17 A
Yes.
18 Q
There was?
19 A
There appears to have been, yes.
20 Q
What number was substituted in that 21 procedure for 200 degrees Fahrenheit?
GD -
22 A
I don't know.
What I was talking about 23 here is, you can't pencil in a change or attach a note 24 to an emergency procedure; yo have to change the O-2 25 procedure officially.
5 1
Frodorick 347 (m) 2 Q
What I am asking you is,was there such s
3 an official change in the procedure before the 4
accident?
5 A
Yes, there was.
O 6
On page 2 of the procedure, Section B.1, 7
Symptom 3, "RCR-2 discharge line temperatures about 8
200 degrees alarm," there is a vertical line to the 9
right of that symptom signifying that Revision 1 made 10 on June 22, 1977 affected that line, that symptom.
11 What the number was prior to that or how this sentence 12 read is not indicated here.
[V'n 13 Q
But I guess we are not on the same 14 wavelength.
Do you say that the vertical line on the 15 right-hand side opposite that indicates that the 200 16 degree Fahrenheit number had been put in as a result 17 of a revision in June 19777 Is that correct?
18 MR. SELTZER:
Or that there was s on.e 19 change in this?
20 MR. FISKE:
Yes, there was some change in 21 number 3 in June 1977.
O 22 Q
Is that what you just said?
23 A
That is how I interpret those markings, i
24 yes.
p
'V 25 Q
My question was whether or not there was l
6 1
Frodorick 348
()
2 any change in the emergency procedure made in the weeks 3
before the accident when the temperatures were at the 4
elevated levels that you described before to change 5
that 200 degree Fahrenheit number?
ggg 6
A I don't know that an official change was 7
entered.
I don't remember putting in a change, but 8
the change would not show up like it would on you 9
can't put a TCN on an emergency procedure.
You have 10 to wait for the body of the procedure to be changed by 11 a PCR.
There is no indication in the procedure that 12 a change is pending.
13 Q
All I am asking you is whatever the 14 mechanics are of making the change, was there such a 15 change made in the emergency procedure before the 16 accident?
17 A
No.
18 Q
Going back to your Kemeny testimony, 19 page 306, " Question:
Prior to the accident, you were 20 seeing temperatures up to 195, 200, or 205, and 21 I believe what I was saying is that if the 22 relief valve then lifted and starting at a 23 temperature of 195 or so, I would not be 24 surprised to see it go over 200 degrees, which r-)N
\\'
25 would be a 5 degree change."
b 7
I Frodorick 349 2
Do you see that answer?
3 A
Yes.
It seems here that I am talking 4
about higher temperatures than I talked about before, 5
At the top of the page, I said 200 degrees, rather g
6 than 195.
7 Q
In any event, you testified, did you not, 8
that "if the relief valve then 31fted, and starting at 9
a temperature of 195 or so, I would not be surprised 10 to see it go over 200 degrees which would be a 5 11 degree change."
12 You gave that answer, did you not?
13 A
That is part of the answer I gave, yes.
14 Q
And notwithstanding that ' belief on your 15 part, you made no suggestion that the number in symptom 16 3 be changed?
17 A
No, I saw no reason to; change it, because a
18 it would still indicate the same thing that it was 19 intended to indicate.
You would still give the alarm.
20 Q
Would this be just as good a symptom of an 21 open PORV as it was before the temperatures were O
22 elevated?
Is that your testimony?
23 A
No, I think, continuing with this answer s'
24 we were just reading, this tells my opinion of what I I
m 25 l
thought of this symptom.
It says, "Here B&W is
i
+
8 1
Frodorick 350 i
[ />
/
2 obviously stating that a discharge line temperature v
3 above 200 degrees is absolutely conclusive evidence 4
that the relief valve is, in fact, stuck open, and I 5
disagree with them" That was my opinion then and that g
6 is my opinion now.
7 Q
I think we covered that before that 8
nobody is suggesting that any one of these symptoms 9
is, quote, absolutely conclusive evidence, close quote.
10 I think we established that earlier on in this 11 deposition.
12 To the extent your answer is making that f'T 13 point, I don't think we need to spend any time on it.
v/
14 My question is simply whether or not you felt before 15 the accident that notwithstanding the fact that 16 temperatures before the accident had been elevated up 17 as high as 195 or maybe even 200 degrees that symptom 18 number 3, the alarm going off at 200 degrees Fahrenheit, 19 was just as good a symptom that the PORV was open as 20 it had been before those elevated temperatures 21 occurred?
O 22 A
I don't remember stating that I thought 23 that number 3 was a good symptom of the valve being 24 open.
1 25 Q
I believe you did state that it was a
9 1
Frodorick 352 f ')
2 symptom that the valve might be open.
V 3
A In the sense that we discussed symptoms 4
before, I guess I can say yes to that question.
5 Q
I think you also testified before, and if ggg 6
you reaffirm it, we can move on, that you felt it was 7
just as good a symptom with the elevated temperatures 8
as it had been before the temperatures were elevated.
9 MR. SELTZER:
You are asking him if that 10 is a belief that he held before the accident?
11 MR. FISKEr Yes, which I think he already 12 testified to.
(~T 13 MR. SELTZER:
I don't remember whether he U
14 testified to that or not.
15 MR. FISKE:
Then let him answer.
16 A
can I hear what I answered last time?
17 Q
No, I would like to hear your 18 understanding before the accident.
19 A
I think in the sense that we have been 20 speaking, it would be just as good a symptom with the 21 low temperature start or the high temperature start, O
22 because as soon as you hit 200 degrees, you get the 23 alarm, so the fact that the alarm still is going to 24 function means that the symptom is still usable.
[)
\\/
l 25 Q
My question is,the alarm going off would
10 1
Frodorick 352 f~')
2 have the same significance as a symptom in either a
3 case?
4 A
No.
5 Q
Did you feel that the significance of ggg 6
the alarm going off at 200 degrees Fahrenheit as a 7
symptom of an open PORV was less when the temperatures 8
were elevated than it had been before?
9 A
I don't recall thinking about whether the 10 symptom was still valuable or not.
It was closer to 11 the alarm set point, so I don't know, never having 12 thought about it before, how it would have colored my (G~}
13 thinking about which part of the procedure or should I 14 have been in one of these procedures when the alarm 15 went on.
16 Q
Are you saying you simply didn't give this 17 any thought one way or the other before the accident?
18 MR. SELTZER:
Now you are talking about 19 before the accident, not the day of the i
20 accident?
21 MR. FISKE:
Yes, that is exactly what my O
22 question was.
23 A
The question was whether I had given any 1
24 thought or not.
I can't remember whether I had given l
(~h 25 any thought or not.
l l
11 1
Frodorick 353 A()
2 Q
The question is, did you give this matter 3
any thought one way or the other before the accident?
4 A
I can't recall what relevancy I would 5
have placed on the effectiveness or the meaning of the gg 6
alarm based on starting temperature.
7 Q
So is it your testimony that you don't 8
remember now whether you attached any relevance one way 9
or the other to the fact that temperatures had been 10 elevated as high as 195 degrees in terms of the 11 significance of this 200 degree Fahrenheit alarm?
12 MR. SELTZER:
You are asking did he attach I~h 13 any significance to it before 4:00 a.m.
on V
14 March 28, 19797 15 MR. FISKE:
Yes.
He already answered what 16 happened during the accident, so I am not going 17 back to that.
I am talking of the period of 18 time before.
19 A
I can't recall spending any time in a 20 thought process trying to attach any relevance to the 21 effectiveness of this symptom either in the case that O
22 existed or a
case that did not exist prior to the 23 accident.
(
24 Q
Do you know whether anyone at Met Ed
' ~ '
25 gave any thought to that question before the accident?
I
11A 1
Froderick 353A 2
A I don't know whether anyone did or not.
3 (Luncheon recess:
12:40 p.m.)
4 s
O 6
7 8
9 10
'll 12 13 14 15 16 17 18 19 20 21 0
22 23 24 25
354 12 1
[)
2 AFTERNOON S E S S I ON v
3 (Time noted:
2:10 p.m.)
4 EDW A RD R.
FRE D ERI CK, resumed.
S EXAMINATION (CONTINUED)
G 6
BY MR. FISKE:
7 Q
Turning again to pressurizer system 8
failure emergency procedure, I would like to direct 9
you to symptom number 4 on page 2.
It says, "The RC 10 drain tank pressure and temperature are above normal 11 on the control room rad waste disposal control panel 12 8-A."
~N 13 Do you see that?
(d 14 A
Yes.
15 Q
what instrumentation was there on that 16 panel that would reflect the drain tank pressure?
17 A
There is a gauge.
Just a gauge.
18 Q
what instrumentation was there that 19 reflected the drain tank temperature?
20 A
It too -- I shouldn't characterize it as 21 a gauge.
It is actually a meter.
Both the presnure 9
22 and temperature are displayed on meters.
23 g
were there alarms for drain tank pressure?
24 was there an alarm for drain tank pressure?
O>
25 A
I am trying to remember as cecurately as
13 1
Fredorick 355
(
2 possible.
There is either a reactor drain tank trouble 3
alarm or there is a temperature alarm.
I don't recall 4
right now.
5 Q
What do you mean by " trouble alarm"?
ggg 6
A The alarm doesn't say a trouble alarm 7
would just say reactor coolant drain tank trouble, and 8
a light that lights up behind that.
9 Q
What kind of trouble did you understand 10 that light indicated?
11 MR. SELTZER:
You mean if there was a 12 trouble alarm light?
(~T 13 MR. FISKE:
The one he has been talking O
14 about.
15 MR. SELTZER:
I think he said there was 16 either a trouble alarm light or a temperature 17 alarm.
18 Q
Do you remember now which it was?
19
'A I don't think it makes much differenc,e what 20 the actual wording on the annunciator box is.
I am 21 having trouble remembering that.
If it was a trouble O
22 alarm, it would mean to me that you go to the alarm 23 response to find out what the trouble was.
If it is a 24 temperature alarm, it means you reached the temperature U
25 alarm set point.
1 Frodorick 356 2
Q Did you understand that having drain tank 3
pressure and temperature above normal was a symptom of 4
an open PORV or a closed PORV as it is used in this 5
procedure?
g 6
A We are talking now about the -- this is 7
the indications, not the alarm, right?
8 Q
Yes, I am talking of the symptom that is 9
referred to in this Met Ed procedure for inoperative 10 pilot operated relief valve.
11 A
Yes, I understand it as it is listed here.
12 It is a symptom in the context that we discussed 13 symptoms before.
3 Q
14 Q
Symptom of what?
15 A
Inoperative pilot operated relief valve.
16 Q
My question was, did you understand that 17 it was a symptom of an open PORV or a closed PORV?
18 MR. SELTZER:
I object, if your question 19 is implying that those are the only two 20 alternatives.
There is no foundation that 21 those are the only two possibilities if RCDT G
22 pressure and temperature are above normal.
23 Q
I assume that PORV is either open or 24 closed.
O\\
\\/
25 MR. SELTZER:
What about leaking?
1 Froderick 357 Ih 2
MR. FISKE:
I think that would indicate V
3 it wasn't fully closed.
Let's let Mr. Frederick 4
answer.
3 A
You are asking me to apply an g
6 interpretaion to this, saying what I derived from it is 7
an interpretation of this symptom?
8 Q
No, I am asking how you understood this 9
emergency procedure before the accident.
10 A
I am telling you I understood this 11 symptom to mean,since it is listed under Section B, 12 that it is a symptom of an inoperative pilot operated
{%.)
g 13 relief valve.
It is also listed in the other section.
14 Q
Did you understand that,having drain tank 15 pressure and temperature above normal was a symptom 16 that the PORV might be open?
17 A
That is one of the conditions that it 18 could indicate.
19 Q
Going further down the page, under B.2, 20 it refers to automatic action.
21 Do you see that?
O 22 A
Yes.
23 Q
Part 2 under " Automatic Action" lists 24 certain things that, I take it, will occur automatically
\\ ')
25 if there is a failed open PORV, is that correct?
1 Frodorick 358
(
2 A
These are automatic actions that will 3
occur if the pressure set points listed in each one, 4
A, B,
and C are reached.
ggg 5
Q For a failed open pilot operated relief 6
valve, right?
7 A
Yes, again these are more symptoms.
8 Q
So it would be a symptom of a failed 9
open pilot operated relief valve that the reactor 10 would trip at 1900 psig?
11 A
Not in the way that we talked about 12 symptoms before.
These are automatic actions that
(
13 occur if the pressure gets to that set point.
This 14 is an automatic action.
15 Q
You just said a moment ago that the 16 items listed under 2 were symptoms.
All I am saying 17 is, they were symptoms of a failed open PORV. Isn't 18 that what the procedure or what the symptoms quote for 19 a failed open RCV-27 20 A
No, I must have used the wrong terminology 21 there.
I would like to make it clear, these are 9
22 automatic actions that will occur as a result of 23 reaching these pressure set points, and they are not 24 symptoms.
The symptoms are listed higher up on the 25 page.
1 Frodorick 359
~)
2 Q
You understood, did you not, from the (G
immediate action section of this procedure that, quote, 3
4 For a failed open RCV-0, three things would happer.,
5 assuming certain pressures were reached.
Pressurizer g
6 heater banks would come on full below 2105.
Reactors 7
would trip at 1900 psig or variable pressure 8
temperature, and high pressure injection would be actuated at 1600 psig," isn't that correct?
9 10 A
These are automatic actions that could be 11 caused by RCRV-2 failing open along with a number of 12 other causes.
13 (Discussion off the record between the 14 witness and his counsel.)
15 BY MR. FISKE:
16 Q
You received training when you were down 17 at Babcock & Wilcox on the simulator as to how to 18 diagnose an open PORV?
19 A
Again, in trying to answer that in the 20 context of what I knew before the accident, I think I would have to review the training records to know what 21 G
22 transients I ac,tually saw down there, 23 Q
Let me just read you some testimony that 24 Mr. Faust gave, and then I will ask you a question n/
x_
25 after you have had a chance to listen to that testimony.
1 Frederick 360 l
(_)
2 This is from his deposition in this case on August 3
19th of 1981, pages 195 and 196.
This is reading 4
from page 195.
5
" Question:
Did you perform procedures ggg 6
directed at specific transients?"
7
" Answer:
Yes."
8
" Question:
Involving pressurizer 9
malfunction, pressurizer system malfunction?"
10
" Answer Yes."
11
" Question:
Was one of those transients 12 that you experienced on the simulator an open
(
13 pilot operated relief valve?"
14
" Answer:
I believe so."
15
" Question:
Were you instructed as part 16 of the training that if you diagnosed that a 17 pilot operated relief valve was open, you should 18 shut the block valve?"
19
" Answer:
In reference to a failed open 20 pilot operated relief valve, that was*the mode 21 to take to shut the block valve for it."
O 22
" Question:
Were you instructed that you 23 could diagnose whether or not the PORV had 24 failed open by looking for a drop in pressure, 25 by looking at the thermocouples readings on the
1 Frodorick 361
()
2 trunk line, and by looking at the drain tank 3
pressure?"
4
" Answer:
You have the procedure?
I could 5
review it."
ggg 6
" Question:
I am asking you for your 7
recollection."
8
" Answer:
My recollection right now would 9
be towards those parameters, yes, but I don't 10 recall everything in the procedure anymore."
11
" Question:
You would need to see the 12 procedure that was being used at B&W in that 13 course for that transient?"
14
" Answer:
Now?"
15
" Question:
In other words, that is what 16 you are asking?"
17
" Answer:
At this point in time, I would 18 like to look it over to make sure.
It has been 19 a while since I have had the need to remember 20 that."
21
" Question:
Are you saying, I believe you O
22 told us your recollection is that the parameters 23 that I described were the parameters that you 24 were given while you were on the simulator 25 analyzing that transient, isn't that correct?
j
1 Frodorick 362 e-(g) 2 That is your best, present recollection subject 3
to looking at the procedure?"
4
" Answer:
Yes."
5 I ask you whether having listened to that 9
6 testimony from Mr. Faust whether that in any way helps 7
you recall that you received similar training when you 8
were at B&W?
9 MR. SELTZER:
I notice that the examiner 10 of Craig Faust had indicated that B&W's records 11 reflect that he was trained on pressurizer 12 system malfunctions.
13 MR. FISKE:
That is the question involving 14 pressurizer system malfunctions.
15 MR. SELTZER:
Mr. Frederick said that it 16 would help him refresh his recollection if he 17 could look at the records of his training.
Do 18 you have those?
19 MR. FISKE:
I think we marked them as l
20 an exhibit, if I am not mistaken.
21 A
Having looked at the training record that h
22 you gave me a few days ago, I can see that the group 23 that I was with on April 5th through July 9, 1976 24 was exposed to one evolution which was entitled 25
" Leaking Pressurizer Relife Valve, so that-as a member
1 Froderick 362A 2
of that group, I either participated in it or observed 3
it.
4 (continued on next page)
G 5
6 7
8 s
9 10 11 12 O
13 v
14 15 16 17 18 19 20 21 9
22 23 24 25 l
1 1
Frodorick 363 2
Q Doesn't the training sheet for June 6 3
through June 10, 1977 indica?.e that you also 4
participated in the performance of one evolution of that 5
leaking pressurizer relief valve during that period of ggg 6
time?
7 A
I think this record indicates I either 8
participated in or observed it once'during the 9
June 6th visit also.
10 Q
Having added that review of the record to 11 the testimony I just read of Mr. Faust, does that help 12 you remember whether you received training at B&W on jl 13 diagnosing an open PORV?
14 MR. SELTZER:
By opened, do you mean failed 15 open as opposed to leaking?
16 MR. FISKE:
Yes.
17 A
I can say since this is a group record, I 18 don't think I can testify that I actually remember doing 19 that.
It was something I diu with the group.
You want 20 me to say that I did this?
21 Q
No, I don't want you to say anything.
I O
22 am just asking you what is your best memory as you sit 23 here today of the training that you received at B&W, 24 and I am asking you whether you learned on either
(
I
~
25 occasion that you were at B&W that you could diagnose
Frodorick 364 g
)
/
2
- n open PORV by looking for a drop in pressure, by 1
king at increased pressure in the drain tank, and 3
by looking for increased temperatures on the discharge 4
11"*7 lll 5
A I find that difficult to answer 6
because I am not even aware that those indications are 7
8 available at the simulator.
You want me to say -- you want me to answer in light of what we did at the 9
10 simulator in relation to this emergency procedure, and I don't think these indications are available now.
31 12 Q
No.
My question wasn't confined to the
(
13 simulator.
You had classroom training at B&W as well v) as simulator training, did you not?
14 15 A
Yes.
16 Q
My question a moment ago was whether on 17 either occasion that you were at B&W, did you at any 18 point learn at B&W that you could diagnose a open 19 PORV by looking for a drop in pressure, by looking for 20 an increase in pressure in the drain tank and by looking for an increase in temperature on the discharge line?
21 O
22 A
My answer is no, I have no recollection of 23 that, because I don't think those indications are 24 available at the simulator, and they couldn't have 25 taught me about it.
Frodorick 365 1
Q S
y u are saying that you did not learn 2
that even in classroom training at BGW?
Do you have 3
a recollection of that not coming up in classroom 4
- "I"1"92 h
5 A
I have no recollection of it coming up in 6
classroom, and I wouldn't expect it to because the 7
8 specifications would be covered in the simulator, not in the classroom.
9 10 Q
Is your answer that it didn't come up at any time at B&W7 gg A
I don't recall it coming up in classroom 12 13 training.
14 Q
Is it your testimony you received no 15 training at all at B&W on how to diagnose an open PORV?
A No.
16 17 Q
What training did you receive on how to gg diagnose an open PORV?
A I have specific recollection about several 19 of these transients listed here, but I don't have 20 anything specific about that one probably because of the 21 O
22 emphasis that was given.
23 Q
I am just asking you whether -- you just said a moment ago that it was not your testimony that 24 b
25 y u received no training at B&W on how to diagnose an
Frederick 366
{~)3 open PORV.
I am asking you what training did you 2
\\_
receive at B&W7 3
A What training did I receive at B&W on this 4
particular transient?
Q On how to diagnose an open PORV.
6 A
I don't have a recollection of how they 7
trained me or what they told me, because I don't think it was really emphasized.
9 Q
Did you receive training at Met Ed that you could diagnose an open PORV by looking for an 11 increase in temperature at the discharge line, by looking for an increase in drain tank pressure, and by (L,)
looking for a drop in pressure?
14 A
A drop in pressure where?
15 Q
A drop in the reactor coolant system.
A We were trained on this procedure, and all 17 those things are mentioned here in the procedure.
Q So then you did know that?
A Again, I don't have a specific recollection 20 of it.
h Q
Because it wasn't emphasized at Met Ed?
22 A
This procedure received as much emphasis 23 as the other emergency procedures at Met Ed.
24
' k)
Q Is it your testimony that at B&W this 25
367 Frodorick 1
t'%
(
)
2 procedure received less emphasis than other procedures?
s,
A I can testify that it certainly didn't 3
receive as much emphasis as some.
4 lll 5
Q S
is your testimony then that Met Ed 6
placed a greater emphasis on diagnosing an open PORV 7
than they did at BGW?
8 A
No.
9 Q
Y u did learn at Met Ed, didn't you, that 10 if you diagnosed that there was an open PORV, the remedy 11 was to close the block valve?
You did know that on 12 the day of the accident, did you not?
h!
13 A
I can relate that my understanding would s-14 have been that if the valve, the relief valve was open j
15 when it should not have been open, an appropriate action 16 would have been to close the block valve for the 17 relief valve.
18 Q
You said an appropriate action?
19 A
Yes.
As I relatef. before, the actions 20 taken which are stated in this procedure are not the l
21 only ones that govern what I should be doing to correct 22 a situation that is a transient.
23 Q
Just so we understand each other, were you 24 told that there was any situation in which you diagnosed O
25 an open PORV where it would be all right not to close
Frodorick 368 1
5 the block valve?
2 A
It w uld not be all right if the high 3
4 pressore situation continued, I would think.
In other w rds, if it had opened to relieve a high pressure lll 5
1 situation and the high pressure situation had not been 6
terminated, then the valve was doing its job.
You 7
8 wouldn't want to block it then.
9 Q
I meant were you trained that there was any 10 situation in which the PORV was open when it was 11 supposed to be closed, that you should not close the 12 block valve?
O(_)
13 A
I can't say that any of my training would 14 have been in the black and white nature of that type 15 of a decision.
Each one decision made in the plant 16 took into consideration many parameters, not just one.
17 Q
I am asking you before the accident, were 18 you aware of any situation in which you had diagnosed 19 an open PORV that should have been closed,where you 20 understood it would have been an appropriate action 21 for you not to have closed the block valve?
O 22 MR. SELTZER:
Is the pressure in the 23 reactor coolant system below the set point for the 24 PORV to close?
x_/
25 MR. FISKE:
I believe that is built into l
'369 Frodorick 1
my question.
2 A
If I had come to the conclusion that it 3
4 would have been an appropriate action to block the relief valve, I would have no hesitation to carry out lll 5
that action.
6 7
Q I am not sure that completely answers my g
question.
Is that the best answer you can give?
If it is, we will go ahead to the next question.
g 10 MR. SELTZER:
If the valve has failed open and the reactor coolant system pressure is below gg 12 the set point for PORV to close, would you have
( s) 13 understood that the action to take is to close
~
14 the block valve?
15 THE WITNESS:
Yes.
16 Q
This procedure for diagnosing and treating 17 an open PORV is part of an emergency procedure, is it i
18 not?
19 A
You are referring to B2?
1 20 Q
All of Section B.
)
A Section B is a part of this emergency 21 O
i 22 procedure, yes.
i 23 Q
You have said earlier that'you knew that l
one thing that could happen if a PORV failed open was 24
~-)
?
l 25 that there could be a drop in pressure?
l I
l
'370 Frederick 1
O(-
A That is one of the causes of a drop in 2
pressure.
3 4
Q And the procedure indicates that one thing lll that could result from,a failed open PORV is that there 5
6 could be a reactor trip, correct?
A A failed open PORV is not a cause of a 7
8 reactor trip.
The cause of the reactor trip would be one f the RPS signals.
In this case, it is listed 9
10 as the there are two of them here.
The 1900 PSIG or 11 the variable pressure temperature trip.
12 Q
Resulting from an open PORV, correct?
13 A
A's listed here, yes.
14 Q
And you knew that a reactor trip was 15 something that you were supposed to avoid, if possible, 16 when you were operating a reactor, didn't you?
17 A
A reactor trip was one of the safety 18 portions of the system.
It is there to help you.
It 19 is not there to cause a problem for you.
20 Q
If you could operate the plant so that the 21 system recovered before there was a reactor trip, 9
that was more d'esirable than allowing the conditions 22 23 to deteriorate to the point where there was a reactor 24 trip, isn't that right?
J 25 MR. SELTZER:
I object.
I think that
Frodorick 371 O
\\ m,l question is too vague and too global.
There 2
are probably a thousand things that could be 3
going on in the plant.
4 MR. FISKE:
You are confusing this by lll 5
bringing in a lot of variables that I am not 6
talking about in my question.
I am talking about 7
8 simply a drop in pressure resulting from an open PORV leading towards a reactor trip.
9 MR. SELTZER:
You are not giving the witness 10 any indication of what other upset conditions 11 12 might exist in the plant.
MR. FISKE:
That's right.
I don't think 13 that is necessary for the purpose of this question!
14 that I am asking.
15 A
Can I hear the question again?
16 17 Q
Did you understand that in operating the 18 plant, it was desirable, if you could, to correct a 19 condition before it deteriorated to the point where there was a reactor trip?
20 A
I understood that we were to maintain the 21 (pi 22 normal system operating parameters as best we could, 23 and that if the system did begin, the parameters did 24 begin to deteriorate, it was actually my job to trip the reactor before the system tripped itself, and that 25 i
Frodorick 372 g
I should be the one that trips the reactor, not the 2
automatic system.
3 Q
Y u said I believe earlier in this 4
deposition that you knew that a drop in pressure was a lll 5
i 6
symptom of a loss of coolant accident, isn't that I
correct?
7 8
A I think I said it was a symptom of an in perative pilot operated relief valve.
9 l
10 Q
Isn't it also a symptom of a loss of e olant accident?
11 12 A
It is one of the symptoms in that
()
33 procedure, too.
14 Q
I think when I asked you why you said a 15 drop in pressure was a symptom of a loss of coolant 16 accident, you said because a loss or drop in pressure 17 indicated a loss of inventory in the system.
Do you 18 remember giving that answer?
19 A
Yes.
20 Q
Why did you understand that pressure 21 dropped as a result of an open PORV?
O 2a A
Because you are letting -- it is like 23 having a vent on top of the pressurizer.
T 24 Q
A drop in pressure resulted in a loss V
25 of inventory through that accident, did it not?
T Frodorick 373 A
I wa8 8 peaking of water inventory before.
2 This is actually steam.
The top of the pressurizer 3
just has steam in it.
There is no water in it.
4 When the valve opened, it would be allowing steam to h
5 6
g out like at the top of a pressure cooker or something.
(Continued on Page 374) 7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 O
25
l
>/1 1
Frederick 374 l
O,
\\
2 Q
How long did you think the fluid that j
3 escaped through the open PORV would be continued to 4
merely steam?
ggg 5
MR. SELTZER:
You mean what was his 6
understanding before the accident?
7 MR. FISKE:
Yes.
8 A
I don't remember thinking that it would 9
be anyt hing except s t. e am.
10 Q
No matter how long the PORV stayed open?
11 A
I have no experience with what you are 12 characterizing as a long opening of the valve.
(
13 Q
In the course of your training at Met Ed 14 when you were being trained on this procedure, did you
{
l 15 ever ask anyone why is it important to diagnose an 16 open PORV7 17 A
I don't think I would have any trouble 18 diagnosing an open PORV.
I could just look at the 19 light and tell that it was open.
I wouldn't have to l
l 20 ask anybody.
21 Q
We will get to the light in a little while.
O 22 That isn't the question.
23 MR. FISKE:
Would you read it back.
24 3
(Record was read back.)
\\_)
25 A
I don't recall being confused or having a
1 FrCdorick 375
()
2 thought that I might have difficulty diagnosing that the PORV was open because it is a simple matter to 3
4 determine it from the light.
5 Q
That is your answer to the question?
(gg 6
MR. SELTZER:
If you want to clarify your 7
question, why don't you,instead of repeating 8
the same question?
9 MR. FISKE:
Do you think it needs 10 clarification?
11 Q
Did you ever ask anybody why it was 12 important that operators be able to diagnose an open
()
13 PORV?
That is the same question.
I can't make it 14 much simpler.
15 A
No, it wouldn't have been something I 16 would have asked a question about, because I had no 17 confusion about how to determine whether the PORV 18 was open or not.
19 MR. SELTZER:
He is not asking about how 20 to determine whether it is open.
His interrogatory 21 asks why, and did you ever ask anybody why 9
22 spotting an open PORV is anything that is 23 important to do.
24 Q
It goes to the basic issue which we have O
V 25 been through before of your understanding of the system
1 Fredorick 376 (O) 2 and how it worked.
In the course of your training 3
when you were learning how to diagnose an open PORV, 4
did you ever ask anybody, "Why is this important? What lll 5
difference does it make whether we are able to
~
6 diagnose it quickly or whether it takes us a long 7
time to diagnose"?
Did you ever ask that question or 8
a question like that?
9 A
No, because there was never in my mind any 10 Problem with diagnosing whether the valve was open 11 or not.
12 Q
And that is because of the answer that you
()
13 gave three times before that you would just look at i4 the light, correct?
15 A
That would be my primary indication of the 16 Position of the valve, yes.
17 Q
When was that light installed?
18 A
I think it was in 1978.
19 Q
When in '787 20 A
I don't remember.
21 Q
Sometime after the transient where there O
22 was a failed ope'n PORV at Met Ed in March 1978?
23 A
Was there a transient in '78 where it 24 failed open?
fq N-]
25 Q
You don't know that?
d 1
Frodorick
[)/
2 A
I know there was a transient in which the s-valve Pened in response to a loss of power at one 3
4 time.
5 Q
When was that?
ggg 6
A 1978.
7 Q
And the light was installed after that 8
9 A
Sometime after that, yes.
10 Q
Let's talk for a moment about the period of 11 time before that in the five or six years that you were 12 going through training before that light was installed.
(~S 13 Did you have the same feeling then that it
%)
14 wasn't necessary to consider why it was important to 15 diagnose the PORV because you had no doubt about your 16 ability to do it, or did that confidence just come 17 with the light?
18 MR. SELTZER:
Why don't you ask him does 19 he recall in that earlier period asking why it 20 is important?
21 MR. FISKE:
I will stick with my question.
22 Thanks.
23 A
You are asking me when did I have confidence 24 of being able to determine whether the valve was open?
O) 25 Q
Maybe --
1 Frederick 378 2
A Or if I had that confidence before this?
3 Q
I think you are on the right track but 4
listen to the question.
ll) 5 (Record was read back.)
6 A
I think that my term of training was 7
somewhat less than four years, and the period in which 8
I developed confidence in my ability to respond to 9
emergencies was sometime after having passed the 10 examinations required to become a control room operator, 11 and in the period from the time I demonstrated that 12 ability until the time in 1978 that this incident O
L.,)
13 with the power failure occurred, I had confidence in 14 my ability, and I think the March incident where the 15 power failure occurred told a lot of people that we 16 might have been mistaken about our ability to tell if 17 the PORV was open.
18 Q
When you had confidence in your ability 19 during this period of time before the March transient 20 to diagnose an open PORV, how did you understand you 21 would diagnose it?
O 22 MR. SELTZER:
The March transient you mean 23 is the one before the accident, right?
l
(-lg 24 MR. FISKE:
Yes.
\\-
j 25 Q
The period of time before the light was
379 1
Fredorick installed when you said you had confidence in your 3
ability to diagnose an open PORV, what symptoms would 4
you have been looking to at that point that gave you gg) 5 confidence that you would be able to make that diagnosis?
6 A
I am only characterizing my confidence as 7
to my use of all the emergency procedures, and I don't 8
specifically remember how I felt about this one 9
procedure.
10 Q
Is there any emergency procedure for 11 diagnosing an open PORV other than the one we have 12 been talking about?
()
13 A
No, and in the times that the record shows 14 that we used them in our training, I was never corrected 15 or told that I was using them incorrectly, so that 16 told me I was doing it right.
17 Q
You were using the pressurizer system 18 failure procedure right to diagnose the open PORV, 19 is that correct?
Is that what you are saying?
20 A
I am saying that since I was never corrected 21 or I don't remember being corrected by the instructors O
22 as I used them in the simulator, then I don't remember 23 that I,was doing anything wrong at the time.
24 Q
Now, you remember that you were trained on
(-]S l
\\-
25 this procedure at the simulator, is that it?
i l
380 1
Frederick O( )
2 A
No, I said I don't recall being corrected 3
on this procedure, just as I don't recall having it 4
emphasized to me.
I recall some of the corrections lll 5
that the instructor gave me at the simulator. "You are 6
doing this wrong, Mr. Frederick.
You need some extra 7
study in this area" and I responded to those corrections 8
and comments, and I think I would have remembered a g
comment in this area.
10 Q
so your confidence in your ability to 11 diagnose an open PORV based on this pressurizer system 12 failure procedure was based in part on the fact that 13 you received no corrections from anybody at B&W on the 14 use of that procedure, is that it?
15 A
Again, not specifically relating it to this 16 one emergency procedure.
17 Q
That is the one we are talking about.
You 18 said you had confidence in your ability to diagnose an 19 OPen PORV based on the emergency procedures.
I think 20 we have established that there is only one amergency 21 procedure dealing with the diagnosis of an open PORV, 9
22 and that is the-one we have had in front of us for 23 the last three hours.
/'T 24 That is the one I am talking about.
(
l 25 Do you understand that?
l l
l
1 Frodorick 381 2
MR. SELTZER:
I don't think pursuing it 3
is going to make it any clearer than the witness 4
has already made it.
He said he had a generalized ll) 5 confidence in his ability to work with the 6
procedures.
He said also that he couldn't recall 7
any specific focus in his training at B&W on 8
the pressurizer system failure procedure.
9 MR. FISKE:
We all remember what the 10 witness said, and I don't think you have stated 11 it completely.
12 Mr. Frederick has testified that he had
()
13 confidence in his ability to diagnose an open 14 PORV before the time that the light was 15 installed, and that confidence was based upon
~
16 the pressurizer system failure procedure.
17 MR. SELTZER:
I don't think that 18 characterizes his testimony.
19 MR. FISKE:
He said it was based upon 20 emergency procedures.
I 21 Q
I am asking you now,once again, was there O
22 any emergency pr'ocedure for diagnosis of an open PORV 23 other than this one we have been talking about for the 24 last three hours called pressurizer system failure g-
'v 25 procedure?
g Frodorick 382 C
( )h 2
MR. SELTZER:
Let's move on.
He answered 3
that two questions ago, and the answer was yes.
4 MR. FISKE:
Fine, we will move on.
5 Q
I would like to have Mr. Frederick
{gg 6
acknowledge that the answer is yes and we will move on.
o 7
A I am not aware that there was another 8
procedure with this title.
9 Q
So that your confidence that you had the 10 ability to diagnose an open PORV based on the emergency 11 procedures was based on this procedure, the pressurizer 12 system failure procedure which lays out specific
)
13 symptoms for that diagnosis, isn't that correct?
J 14 A
We used either this procedure or a revision 15 of it, yes.
16 Q
And you were confident then before the 17 light was installed that you would be able to diagnose 18 an open PORV based on this procedure?
19 A
I have said that I don't remember thinking 20 specifically about this procedure.
21 Q
What procedure did you have in mind when O
22 you said you had confidence in your ability to diagnose 23 an open PORV based on the emergency procedures?
24 A
I didn't say that.
You did.
(_
25 Q
I believe you said it several times, and
1 Frederick 383
(\\
l s_/
2 Mr. Seltzer reaffirmed it a few minutes ago.
3 A
Is that a question?
4 Q
Are you telling us now that you didn't say (l) 5 just a few minutes ago that you had confidence before 6
the light was installed that you would be able to 7
diagnose an open PORV based on the emergency procedures?
8 A
I am testifying that what you have just 9
said is not a quote of what I said nor is it an accurate 10 paraphrase.
11 Q
We will let the record stand on that.
12 A
Very well.
()
13 (Discussion off the record between the 14 witness and his counsel.)
15 MR. SELTZER:
Rather than leaving the record 16 with your insinuation, why don't you say what 17 was wrong with his characterization of your 18 testimony and repeat what you just said to me.
19 THE WITNESS:
I said that I didn't refer 20 to this procedure in my answer.
I referred to 21 procedures in general the way Mr. Seltzer had 22 characterized it in his comment.
23 Q
Then I think you also testified just a 24 few moments ago,and indeed Mr. Seltzer confirmed that
(~]S
'q.
25 you had so testified, that there was no emergency
1 Frederick 384 10
(-)
2 Procedure for the diagnosis of an open PORV other than this one that we have been talking about for the last 3
4 couple of hours.
Isn't that correct?
A In Unit 2, this is the procedure that (l) 5 6
we were talking about, yes.
7 Q
Did anything that occurred in the March g
1978 transient indicate that any of the symptoms cited g
in this emergency procedure were not a symptom of an 10 oPen PORV?
11 MR. SELTZER:
Objection.
You haven't 12 established as a foundation that Mr. Frederick O
(,/
13 knows what the symptoms were that were observed 14 in the control room during the March 29, 1978 15 transient.
16 Q
Did anything come to your attention at 17 any time after the March'1978 transient which indicated 18 to you that any of the symptoms listed in the 19 pressurizer system failure procedure that we have been 20 just talking about were not valid symptoms of an 21 OPen PORV?
O 22 MR. SELTZER:
Same objection.
If no 23 symptoms came to his attention, it is a rather
(~'
24 vacuous question.
N.))
25 MR. FISKE:
He can answer it.
1 Frederick 385 (3
'~
2 A
I don't know or recall that I even reviewed 3
this procedure after that accident or that incident 4
because the primary focus of studying that incident 5
was on the power failure, not on the PORV.
6 Q
Then is the answer to my question no?
7 A
I said I don't recall having reviewed this 8
procedure.
9 Q
My question was did anything come to your 10 attention that indicated to you that any of the 11 symptoms in that procedure were not valid symptoms of 12 an open PORV?
(~)
\\_/
13 A
I answered if I don't recall reviewing the 14 symptoms, I can't remember if anything came to my 15 attention pertaining to the symptoms.
16 (Recess taken.)
17 BY MR. FIS KE :
18 Q
Just before the break, I believe you said, 19 in substance, that nothing came to your attention as 20 a
result of the March 1978 incident which indicated 21 that any of the symptoms for diagnosing an open PORV 9
22 in the pressurizer system failure procedure were not 23 valid symptoms for that purpose.
24 I would like to ask you, isn't it a fact 25 that what you learned about the March 1978 transient 1
1 Frederick 386 O
2 tended to confirm the value of at least one of those 3
symptoms as a diagnostic tool for an open PORV7 4
MR. SELT3ER:
I object.
No foundation that h
5 today Mr. Frederick recalls what he learned about 6
the March 1978 transient.
7 MR. FISKE:
Let him answer the question.
8 MR. SELTZER:
He can answer the question.
9 I am just stating a factual objection to the form 10 of your question.
11 A
I recall learning mostly about that incident
-12 about how the power failure occurred and how it was 0
1 13 going to be corrected in the future.
I don't 14 specifically remember the training that we might have 15 received on the PORV which was one of the incidents 16 that happened on that day.
17 Q
Isn't it a fact that you learned after 18 that incident and before the Three Mile Island accident 19 that the way the open PORV had been diagnosed was by an 20 increase in the quench tank pressure?
21 MR. SELTZER:
Objection.
No foundation 22 that the 6 pen PORV was diagnosed in the control 23 room during the March 29th incident.
[s) 24 Why do you look so exasperated?
n 25 MR. FISKE:
Because I think, to put it
1 Frederick 387
(
(~)
2 politely, that is an invalid objection.
It is an bjection to the form anyway, so let's go 3
4 ahead.
5 A
I don't recall that right now.
6 Q
I will read you some questions and answers 7
from your testimony in the Kemeny deposition which you 8
gave on the 23rd of July, 1979 under oath to 9
representatives of the Kemeny commission staff.
10 I am reading from page 203.
11 "My question is, though, do you recall 12 whether that information for identifying a failed open 13 PORV from secondary indicators was discussed at the 14 time that the PORV failed open here at TMI-2 in the 15 spring of 1978?
16
" Answer:
It was discussed as far as 17 relating the transient parameters as we saw them.
18 What the operators saw that time that told them that 19 the valve was open.
l 20
" Question:
What did he say finally told 21 him the valve was open?
22
" Answer:
Quench tank pressure, I believe.
23 He went around behind the panel.
This was not the
[)D 24 operator on duty.
It was a different operator.
He 25 just happened to walk around back there and looked at
1 Frederick 388
/
3
%/
2 it.
3
" Question:
At the strip chart?
4
" Answer:
There was no strip chart.
lh 5
" Question:
It was just a gauge?
6
" Answer:
He was looking at the gauge.
He 7
came around and informed the operator on duty that he 8
thought that one of the reliefs was still blowing to 9
the tank.
10
" Question:
So there was a discussion that 11 was the technique that was used on that occasion to 12 identify the fact that it was open?
/~S 13
" Answer:
Yes."
14 Were you asked those questions and did you 15 give those answers?
16 A
Yes, it appears that I was asked these 17 questions and gave these answers, but I' don't know what 18 the time period of the discussions is that we are 19 talking about in these questions and answers.
20 (continued on the following page.)
. (Il 22
(~T o4
\\_)
~
25
309 hd1 1
Frederick
' ')
2 Q
Does it help you in recalling that to 3
look at the first question, quote, My question is 4
though, do you recall whether that information for 5
identifying a failed open PORV from secondary 6
indicators was discussed at the time that the PORV 7
failed open here at TMI-2 in the spring of 1978, close 8
quote?
Does listening to that question help you tell 9
us what time period you were referring to in those 10 answers?
11 A
No, not really.
I think we are talking 12 about two different sets of discussions here, whether 13 it was discussed among the operators that were on duty 14 and later related to me.
It would be two separate 15 discussions.
16 I am saying here it was discussed, but 17 I don't think I am saying that it was discussed with 18 me after that transient.
19 Q
Let's try again.
Let's look at the 20 answer to that question.
21 "It was discussed as far as relating the 22 transient parameters, as we saw them."
l 23 Who do you think the "we" was in that
(~}
24 answer?
Lj 25 A
The Operations Department.
2 1
Frederick 390
(~h L) 2 Q
Including yourself?
i 3
A I include myself in the Operations l
4 Department, but I don't think that implies the entire h
5 Operations Department was present for the discussion.
6 Q
Do you include yourself in the word "we" 7
in that answer?
8 A
Yes.
9 Q
Did anybody tell you at any time after 10 the March 1978 failed open PORV incident that any of 11 the symptoms in the pressurizer system failure procedure 12 were not a valid indication of an open PORV?
)
13 A
I don't recall discussing the symptoms 14 in that procedure after the March 1978 incident.
15 Q
Did Mr. Scheimann, your direct supervisor, 16 ever tell you at any time before the light was 17 installed that all of the symptoms of an open PORV 18 including those referred to in the immediate action 19 section of the procedure would also occur in a normal 20 opening and closing of the PORV?
21 A
Would you say that again?
9 22 (Record read) 23 A
I don't recall anyone telling me that.
f'N I
t.,
)
24 Q
You yourself did not have that 25 understanding, did you, before the accident?
l
i l
l 3
1 Frederick 392
~
2 MR. SBLTZER:
He didn't have what 3
understanding?
4 MR. FISKE:
That all of the symptoms listed 5
in the pressurizer system failure procedure for 6
an open PORV including those listed in the 7
immediate action section would also occur under 8
normal opening and closing of the PORV.
9 A
I don't recall thinking about these 10 automatic actions as symptoms prior to our discussion 11 earlier today.
12 Q
So is the answer to my question, no?
/"
13 A
The answer is, I don't recall thinking of 14 these automatic actions as symptoms prior to our 15 discussion earlier today.
16 MR. SELTZER:
Irrespective of whether you 17 think of them as symptoms, did you know the 18 normal opening of a PORV would cause these 19 things?
20 A
All of these things?
21 Q
Yes.
That is all.
q 22 A
A normal opening and closing of the PORV 23 might cause some of these things.
I wouldn't expect
/~5 l
i 24 it to cause all of these things.
%j 25 Q
Which one of those things did you
1 1
Frederick 392
('~N
(_)
2 understand before the accident a normal opening and 3
closing of the PORV would cause?
4 A
I don't remember thinking about it prior 5
to the accident.
i 6
Q Let's go back to this transient in March 7
1978.
8 Were you on duty when that transient 9
occurred?
10 A
No.
11 Q
Did you come on duty within several hours 12 afterwards?
)
'~'
13 MR. SELTZER:
You mean, was he on the next 14 shift?
15 MR. FISKE:
Yes, let's try that.
16 A
I don't recall that I was on the next 17 shift.
I was on one of the shifts that followed that 18 day.
19 Q
Did you learn about that transient that 20 day?
21 A
I don't recall that I came on shift right 22 after that accident.
I would have heard about it when 23 I came back.
()
l 24 Q
Before the Three Mile Island accident, 25 did you learn of any other open PORV that had been
5 1
Frederick 393 8._)
2 diagnosed by operators looxing at the pressure or 3
temperature on a drain tank?
A No.
4 lh 5
Q Did you know Gary Miller before the 6
Three Mile Island accident?
7 A
Yes.
8 Q
What was his position in the year or so 9
before the accident?
10 A
He had a title like Unit 2 Operation 11 Superintendent or something like that.
12 Q
Did you know a man named James O'Hanlon
'"~
13 before the accident?
14 A
I had met him.
I didn't really know 15 him as well as I knew Mr. Miller.
16 Q
What was Mr. O'Hanlon's position, if you 17 can recall?
18 A
I don't recall his position.
Something to 19
'do with Unit 1.
20 Q
Did either Mr. Miller or Mr. O'Hanlon 21 ever tell you that there had been a failed open PORV 22 or stuck open PORV at Toledo Edison's Davis-Besse 23 plant in September 1977 as a result of which the l
24 rupture disk had blown on the drain tank?
25 A
I don't recall Mr. O'Hanlon or Mr. Miller
l Frodorick 395
[
g O)
(_
2 Q
He was what you referred to in some of Y ur prior testimony as a honcho?
3 A
Yes, he is a honcho.
4 llh 5
0 -
Did Mr. Herbein ever tell you of a transient at Duke Power Company Oconee Station in 6
which the rupture disk had been activated as a result 7
8 of a stuck open pilot operated relief valve?
A Mr. Herbein and Mr. Miller and Mr. O'Hanlon 9
10 and I did not have such conversations.
gg Q
Did anybody at Met Ed in the training 12 department, your superior, Mr. Scheimann,or anybody 13 else, tell you about the transient at Duke Power where 14 the pilot operated relief valve had stuck open and the 15 rupture disk had been actuated?
16 MR. SELTZER:
No foundation that Mr.
- 7 Scheimann knew about that.
I 18 MR. FISKE:
I will stand on the question.
19 Let's let Mr. Frederick answer the question.
20 (Record read.)
A We heard about some transients at other 21 9
22 plants through training and through my superiors, 23 sometimes, but I don't have a specific recollection of gN 24 that one.
(_)
Q In any cf the information that you learned 25
Frodorick 396 1
(h from the training department or from any of your
(_)
2 superiors about transients at any other plants, did 3
4 anyone at Met Ed tell you about any transients in which the pilot operated relief valve had stuck open and llh 5
6 the rupture disk on the drain tank had been actuated?
A I don't recall one.
7 MR. FISKE:
Let's mark the next exhibit, 8
Bsw 656, copy of a letter from L.
C.
- Rogers, 9
10 Manager of Site Services, to Mr.
J.
G.
- Herbein, Manager of Generation Operations Nuclear, 11 12 Metropolitan Edison, dated July 30, 1975; O
\\
13 subject:
preventative maintenance suggestions for,
')
the RCRV-2 pressurizer electromatic relief valve, 14 with carbon copies to Messrs Colitz, Kennedy, 15 16 Coppola and Govers.
17 (Copy of letter dated July 30, 1975, from 18 L.
C.
Rogers to J.
G.
Herbein, marked B&W 19 Exhibit 656 for identification, as of this date.)
20 Q
Did you ever see that letter before today?
A I don't recall having seen this letter 21 22 before.
23 Q
or having received the information, any 7-24 of the information contained in that letter?
()}
25 A
Since this is a letter which suggests I
Frederick 396-A 1
(
preventative maintenance and ideas on monitoring the cleanliness or absence of corrosion products, I 3
wouldn't have expected to receive this type of notes in 4
my training.
(Continued on Page 397) 6 7
8 9
10 11 12 13 14 15 16 17 18 19 l
20 21 l
22 23 l
1
-a l
Fredorick 397 y
[)
u-g 1
Q W uld y u have expected to receive 3
information that would be helpful to you in diagnosing 4
lll whether an open PORV existed?
5 MR. SELTZER:
You mean notwithstanding 6
B&W's focus on maintenance and corrosion?
7 8
MR. FISKE:
I don't see any focus in that letter.
g 10 A
The title of the subject of this letter 11 is preventative maintenance suggestions.
12 Q
Can you answer my question?
Would you 13 have expected to receive information that would be 14 helpful to you in diagnosing an open PORV?
15 MR. SELTZER:
You are talking about 16 July 1975 when he was an AO?
17 MR. FISKE:
Sure.
18 A
I think I always felt that if B&W had some i
39 information they wanted to gi've me that would be 1
20 helpful to me as an operator, they would send it to me.
21 Q
How about if Met Ed had information that 22 would be helpful to you, they would tell you also?
1 j
23 A
Yes.
l
/~)
24 Q
And you would expect that from the people
%.)
25 at Met Ed if they had that kind of information, they
Frodorick 398 3
w uld pass it on to you?
2 MR. SELTZER:
You are referring to what 3
now?
4 MR. FISKE:
Information that would be llh 5
helpful to him or any other operator in 6
diagnosing an open PORV.
7 A
I don't specifically remember thinking g
ab ut that as a problem.
9 10 Q
That is not my question.
A We aie being specific about what I recall 11 12 that I would like to receive information on.
I don't
()
13 recall having thought that I wanted information on that.
14 15 Q
You mean you thought you had all the 16 information you thought you needed?
17 A
This is pretty early in my career here.
18 I don't think I was that cocky.
19 Q
So you would have liked to have this information?
20 MR. SELTZER:
What information?
21 O
MR., FISKE:
Information that'would be helpful 22 23 to him in diagnosing an open PORV.
24 MR. SELTZER:
You mean specifically the rw)
(
25 information that is contained in Rogers' memo on
Fredorick 399 g
t')s.
preventative maintenance?
Y 2
MR. FISKE:
Information when the PORV opens, 8 rupture disk may blow.
4 llh A
I think I had that information.,That is 5
why the rupture. disk was installed.
In case any 6
overpressure condition existed, it would relieve the 7
8 pressure.
Q At.any. time before the accident in 1979, g
10 did y u learn about any transient at TMI Unit 1 where the PORV had stuck open or failed open?
gg 12 MR. SELTZER:
Didn't you ask that about
[)
13 ten minutes ago?
t-j4 MR. FISKE:
I don't believe so.
I asked 15 ab ut other plants, transients at other 16 plants.
I didn't intend by other plants to 37 include TMI-1.
gg If Mr. Frederick understood I did in 19 answer to the question in that context, he can 20 make that clear.
A Other plants is other plants besides TMI-2.
21 22 Q
Without redebating what I was asking 23 before, can you jus,t answer the question I asked now?
,s 24 A
I don't recall being told about incidents L.)
25 at other plants including TMI-1 about stuck open PORVs 4
i Frodorick 400 1
["'i Q
Or failed open PORVa?
\\_)
2 A
Or failed open PORVs.
3 Q
Did you ever learn at any time before the 4
accident about any change that had been made at TMI Unit 1 in the size of the drain tank, the reactor 6
coolant drain tank?
7 A
You are asking me if I recall a change in 8
TMI-1, change in the size of their drain tank?
9 Q
Yes.
10 A
No, I don't recall that.
11 Q
Do you remember learning at any time before 12 the accident about a change in the size of the drain
~}
V tank at TMI Unit 27 14 A
As far as I know, the drain tank is the 15 only one that we always had, the one that was originally 16 installed.
17 Q
Did you learn at any time before the 18 accident about any incident at TMI Unit 1 in which the 19 reactor coo'lant drain tank had been overpressurized?
20 A
No, I don't recall that.
Most of my experience in Unit 1 was as an auxiliary operator.
22
(
Q Your answer is st'ill no, is that right?
23 A
Yes.
24
(~-)g
(-
Q Let me show you a document which has been 25 i
y Frodorick 401
)
marked as B&W Exhibit 180, which is captioned 2
Notification of occurrence of a 30-day reportable event, Unit 2.
The date of this is April 12, 1978.
4 h
Do you have that in front of you?
5 A
xes.
Q Let me show you another document, marked 7
B&W Exhibit 181, which is the Unit 2 licensee event 8
9 report for that same transient.
10 D
you have that in front of you?
A What did you say it is called?
gg 12 Q
Unit 2 LER.
(d' A
Yes, I have that.
13 14 Q
Did you review either one of those 15 documents before the Three Mile Island accident?
16 A
I don't recall seeing any letters in the form of this one, like-No. 180.
This is a letter 37 18 that goes out to somebody else.
19 Q
A fairly large number of people, right?
A Yes.
20 21 Q
Including the training department, is O
that right?
22 l
23 MR. SELTZER:
The document says it goes to the training department.
m 24 f
'~'
25 A
Yes.
1 Frederick 402 V
2 Q
So y ur testimony is you didn't see B&W 1807 A
I don't recall se'eing it, no.
3 4
Q How about the LER which is Exhibit 181?
llh A
I have seen this LER form before, but I 5
6 don't recall seeing this individual one.
I am talking of the second page of this one.
That looks familiar.
7 8
Q But is it your testimony that you have seen LERs but you don't remember whether you have seen 9
10 this one?
11 A
The only place I actually saw LERs was in 12 the LER review that we did in training, and I actually 13 didn't see them.
They were part of a lesson plan.
I 14 didn't get the originals.
15 Q
Didn't they have a set of the LERs in the 16 control room?
17 A
I think the control room clerk kept a file 18 of them.
19 Q
You understood these were available to you 20 for your review, did you not?
21 MR. SELTZER:
You mean it was something he 22 could read if he wanted to?
23 MR. FISKE:
Yes.
(~)s s
t 24 A
I think if I would have asked, I could 25 have seen one of these.
1 Frederick 403 l
2 Q
Didn't you understand it was part of your obligati n as an perator at Met Ed to review LERs 3
4 concerning transients at your own plant?
h A
Yes, and I would review them during 5
6 training.
7 Q
So your testimony is that you did review 8
this LER in training?
A I don't recall reviewing it, but I have no 9
10 reason to doubt that I did.
11 Q
That is Met Ed training, right, training 12 at Met Ed?
O)
(_
13 A
Yes.
14 Q
What training did you receive from 15 Metropolitan Edison about the lessons to be learned 16 from this transient?
17 A
My recollection of the training that we 18 received was focused on the steps that we would take i
loss 'f vital bus and 19 in the future to prevent a o
20 I think that the surveillance procedures that were used 21 which caused the. loss of the vital bus were 22 reviewed, and they may have been given a revision.
I 23 am not quite sure, but I know we were instructed to
/T 24 have in mind caution when we were dealing with these
^
b 25 vital bus to prevent this in the future.
r l
l
1 Frederick 404 a
2 Q
In other words, you were trained on how to avoid causing another such transient, is that 3
4 correct?
A My recollection is that we were just 5
6 trained that the surveillance procedure was either 7
going to be changed or we should use it with a little 8
more caution to make sure that the switch positions g
were correct before we moved from one spot in the 10 surveillance procedure to the next spot.
11 The problem was I believe that a switch 12 was thrown out of sequence, and that caused the loss O'J 13 of power, but that is only my recollection.
14 Q
Did this training take place in some of 15 the classroom lectures you were attending as part 16 of your requalification training program?
17 MR. SELTZER:
As opposed to being part of 18 any other training?
19 A
I have a recollection of what I learned 20 from it, but not how I was trained on it, 21 (continued on Page 405) g 22
~
l 23
('~)
A,/
24 l
25 1
l
405 1
1 Frederick O
(_/
2 Q
In the training department lectores that 3
you attended, was there any discussion about the fact 4
that the PORV had remained open in this transient for 5
a period of time?
(gg 6
A My best recollection is that there was 7
mention that the PORV had operated due to the loss of 8
power but that it had opened and then reclosed when 9
the power was regained.
I don't know that we discussed 10 it any further than that.
11 Q
Were you told that during the period of 12 time that the PORV remained open there had been a O)
(_
13 rapid depressurization of the RCS?
14 A
I think I can only suppose if they trained 15 me on a portion of this, they would have trained me 16 on the whole thing, so that to the best of my 17 recollection, as it says here, the event produced no 18 adverse safety concerns.
Everything functioned as per 19 design, so it was an incident that needed to be reviewed, 20 but I don't remember any in-depth study of it.
21 Q
was there any discussion in the course of 9
22 the training thaIt you received on this transient of 23 what problems an open PORV might cause for the system?
t
N 24 A
Again, there is mention of that in the LER,
-]
25 but I don't remember specifically being trained on this l
1
406 1
Frederick O
2 LER.
3 Q
What were you' told in your training with 4
respect to problems that might result if the PORV lll 5
remained open?
6 MR. SELTZER:
Are you still focusing on 7
the training that keyed on this licensee event 8
report or are you now talking more generally?
9 MR. FISKE:
I will be glad to expand it.
10 MR. SELTZER:
You just choose whatever you 11 want.
I am asking what you mean.
12 MR. FISKE:
I will make the question more f/'T 13 general, but I will key it specifically to the s
14 time period after this event occurred.
15 Q
What training did you receive at Met Ed 16 in the aftermath of this incident as to what problems 17 could be caused in the system if an open PORV was 18 allowed to remain open when it should shut?
19 A
My best recollection of the training 20 following this incident is that it zeroed in on the 21 instrumentation losses due to the loss of the 21V bus 22 and how they could affect your interpretation of the 23 plant operation, and as a result, we went around and
[")
24 labeled all of the instruments as to what their power
%.)
25 supplies were so we.could identify which instrumentation f
1 Frederick 407
\\
2 would be affected by the power supply loss, and that 3
is what I remember being the big deal from this 4
incident.
lll 5
Q Then is the answer to my question none?
6 A
No, the answer is that the primary emphasis 7
on the training was on that and I don't recall being 8
trained on what you are speaking of.
9 Q
In the course of any of the training that 10 went on where this event was being discussed, do you 11 remember anybody at any one of the classroom sessions 12 raising their hand and asking the question, "What rN k/
13 happens if we are not able to diagnose a stuck cpen m
14
'PORV and it stays open longer than it should"?
15 A
I don't want to give you the wrong 16 impression that this was a large classroom of people.
17 It probably would have been just me and Mr. Faust, and 18 if neither of us thought of it, it wouldn't have 19 been asked.
The requalification training is just for 20 the operators on that one shift.
21 Q
so you don't remember anybody at any time 22 at Met Ed asking that question after this transient, 23 is that correct?
(~h 24 A
No, I don't recall that specific question.
L 25 Q
Anyone ask B&W to simulate this transient
408 3
1 Fredorick j
(~%
(-
2 on the simulator?
3 MR. SELTZER:
A bus failure?
4 MR. FISKE:
No, a failed open PORV.
(g) 5 MR. SELTZER:
Davis-Besse did.
6 MR. FISKE:
Yes, they did.
At least for 7
Mr. Faust.
Maybe that is why he didn't ask the 8
question in class.
9 A
The question again, please?
10 Q
After this transient, did anyone ask B&W 11 to simulate it on the simulator?
12 A
I don't know.
13 Q
Did you tell anyone in the training 14 department that you would like to have it simulated 15 at B&W7 16 A
I know that we were asked prior to our 17 simulator trips to make' lists of what we would like l
18 to have simulated on the simulator, and I don't know l
19 that this was one of them.
I 20 Q
You said earlier that after this transient 21 there was a light installed.
I take it that is on O
22 the control panel?
l 23 A
Yes, right near the pressurizer station.
/~'T 24 Q
How did you understand before the accident V
25 that light worked?
.409 1
Frederic.t
(
\\-)
A It comes on when the valve is open and goes 2
ff when the valve is shut.
It is a red light.
3 4
Q Were you told before the accident in your 5
training at Met Ed that this light was a direct lll 6
indication of position of the valve?
A What do you mean by " direct"?
7 8
Q I am using it in the reverse sense of the 9
colloquy we had earlier about what is the meaning of 10 the symptom.
11 MR. SELTZER:
Why don't we approach it 12 more directly.
13 Q
Did you understand that this light was a 14 symptom as we have been using that term before or did 15 you understand that every time the light was off, you 16 could be sure positively that the valve was shut?
17 A
I am using it in that sense of a symptom.
18 It was a primary indication of the position of the 19 valve and unless I had some conflicting information, 20 I would consider it correct.
21 Q
That isn't completely responsive to my 9
22 question.
23 MR. SELTZER:
It sounded very responsive
's 24 to me.
O 25 Q
Did you understand that if the light was
Frederick 410
')
2 off, that meant positively that the valve was shut?
l 3
A I have never been taught that anything in 4
the real world is positive, and it was an indication lll 5
just like a pump light.
If you turned the switch for 6
the pump to start and the light comes on, you assume 7
that the pump is running.
It is the same type of 8
indication.
9 Q
Isn't it a fact that or did you know that 10 before the accident that what this light indicated was 11 whether there was power on or off to the solenoid for 12 this valve?
f~h
(_)
13 A
I have thought about that since the 14 accident, and I don't have a clear recollection of 15 knowing that prior to the accident.
I have been asked 16 before to try and really separate when it was that I 17 learned that, and I have been unable to do that so far.
18 Q
Were you aware that there was a disagreement l'9 within Het Ed prior to the installation of this light 20 as to whether this type of light should be installed 21 or whether a direct indication of the valve position 22 light or whether a light indicating valve position 23 should be installed?
l (~}
24 MR. SELTZER:
Objection.
No foundation LJ 25 that a direct indication can be installed on 1
1 Frederick 411 O}
f 2
the pilot operated relief valve.
3 Can you get inside and put an indicator 4
on the main valve stem?
lll 5
MR. F IS KE :
Let's let him answer the 6
question.
7 A
Can I hear your question again?
8 Q
Were you aware before the Three Mile 9
Island accident that there was a disagreement among 10 People at Met Ed as to the type of light that should 11 be installed in the control room?
12 A
By " type of light," I suppose you mean O)
(-
13 how it was hooked up electrically to indicate the 14 position of the valve.
15 Q
You testified that you knew that there was 16 a light installed, correct?
17 MR. SELTZER:
Yes, he did-testify to that.
18 A
Yes.
19 Q
Did you know before the accident that there 20 were people at Met Ed that felt that instead of that 21 light, some other type of indication should be O
22 installed that would be a better indicator of valve 23 Position?
I) 24 A
I don't recall knowing how the light worked v
25 to begin with, so I don't know that I would have been
1 Frederick 412
(--)
2 able to make a decision as to another one that would 3
have been better.
4 Q
I am not asking you right now whether you lll 5
were called upon to make the decision.
I am asking you 6
whether you were aware of the fact that there was a 7
disagreement within the ranks of Met Ed on the question 8
of what kind of light should be installed?
9 MR. SELTZER:
Objection.
If he didn't know 10 the way in which it was installed, it seems 11 rather hypothetical for him to be asked were you 12 aware there was a debate over different ways of
/' N,
(_)
13 installing it.
14 MR. FISKE:
Maybe the answer is he doesn't 15 know but I think we can get it.
16 A
No.
17 Q
Did you know Jim Floyd before the accident?
18 A
Yes.
19 Q
What was his position in the spring of 20 19787 21 A
He was an off-shift operations personnel, 22 but I don't recall his title.
He was an operations 23 manager of some sort.
(~J) 24 Q
Some sort of a supervisor of operations?
25 MR. SELTZER:
We will stipulate that that is what Floyd was.
id1 1
Frederick 413
~
[U) 2 Q
Did you ever hear Mr. Floyd express the view as supervisor of Operations of Three Mile Island 3
4 Unit 2, that a different light should be installed llh 5
than the one that was installed?
6 A
No, I don't recall him talking to me 7
about that.
8 Q
Did you ever hear from anyone that the 9
supervisor of Operations at Three Mile Island Unit 2 10 felt that a light should be installed which gave a 11 better indication of PORV position than the light that
-12 was installed?
'~#
13 A
No, I don't recall that either.
14 Q
Did anybody in your training till you of 15 the circumstances under which the fact that the light 16 was off might not be an accurate indication that the 17 valve was shut?
18 A
I don't recall being taught that the 19 light for the valve might be an inaccurate indication 20 of its position.
21 Q
Do I understand from that that nobody in 22 Met Ed told you of any circumstances under which the 23 light might not be an accurate indication of position
)
24 of the valve?
25 A
I don't recall being told that it might
2 1
Frederick 414 A
2 be an inaccurate indication.
There is a sign right 3
next to it that says, when the light is on, the valve 4
is open.
That is how I understood it works.
lll 5
Q Did anybody tell you before the accident 6
that even though the light was off, the valve still 7
might be open because of a scored piston ring main 8
valve?
9 A
A piston ring in the relief valve?
10 Q
The main valve.
11 A
Is that different from the electromatic 12 relief valve that we are talking about?
OO 13 Q
I am reading from a Met Ed document.
14 Did anybody tell you that?
15 MR. SELTZER:
Objection.
No foundation 16 that there is a piston ring in the pilot 17 operated relief valve.
18 MR. FISKE:
I will take my chances with 19 that.
20 Q
Did anybody tell you before the accident 21 that even though the light was off, the PORV might 22 still be open because of a scored piston ring main 23 valve?
()
24 A
I don't recall ever having someone refer 25 to the electromatic relief valve as having a piston
3 1
Frederick 415 4 (')
2 ring.
3 Q
so the answer to the question is no?
4 A
I guess so.
llh 5
Q Did anybody tell you before the accident 6
that the PORV could stick open even though the light i
7 was off because of foreign material in the main valve 8
seat?
9 A
SPecifically relating to the PORV, I 10 don't recall that, but I had an understanding that the 11 corrosion products could prevent a valve from properly 12 seating.
Any valve.
(/)
s_
13 Q
That would be true even if the power was 14 off to the solenoid?
15 A
We are talking of corrosion products 16 gathering around the seat of the valve that would keep i
17 it from properly sealing.
It wouldn't be a good seal.
l 18 That would be independent of the light.
l 19 Q
Did anybody tell you before the accident 20 that the PORV could fail to close even though the i
21 light was off because of foreign material in the main 22 valve piston ring?
23 A
I don't recall hearing that before.
/~V}
24,
Q Did anybody tell you that the PORV could 25 fail to close even though the light was off because of
4 1
Frederick 416
(~s
'v 2
a scored guide main valve?
3 A
I don't recall the various failure modes 4
you have been listing as being emphasized in any of my h
5 training.
6 Q
Let me, to save time, read you a list of 7
different items here and ask you whether at any time 8
after this light was installed in the control room 9
anyone at Met Ed told you that the PORV could stick 10 open,even though the light was off, if any of the 11 following things happened:
broken spindle pilot valve,
'12 distorted spindle pilot valve, corroded spindle pilot 7-i 13 valve, scored seat pilot valve, scored disk pilot valve, 14 loose disk pilot valve, foreign material pilot valve 15 seat, foreign material pilot valve spindle, adjustment 16 loose pilot valve, lever jammed pilot valve, gasket 17 leak between pilot base and pilot guide, external leak 18 from pilot valve chamber, solenoid plunger jammed, 19 wiring malfunction solenoid energized, relay contents 20 stuck closed, high pressure switch contents stuck 21 closed, low pressure switch contents stuck closed, high 9
22 pressure switch adjusting screw set wrong, low pressure 23 switch adjusting screw set wrong, control station C)\\
(_
24 switch contents stuck in manual position.
25 MR. SELTZER:
I don't understand those
5 1
Frederick
.417 2
questions.
3 What are the high pressure adjusting 4
screw and the low pressure adjusting screw?
llh 5
MR. FISKE:
Maybe we ought to ask Mr.
6 Frederick.
7 MR. SELTZER:
Do you know what he is 8
referring to when he says the high pressure 9
adjusting screw?
10 A
I can give you a guess as to what I think 11 it is, based on my training on the valve.
-12 Q
I am not really interested in guesses and 13 so forth, unless you are telling me that someone did 14 tell you before the accident that any one of those i
15 things could cause the pilot operated relief valve to 16 stay open even though the light was off.
If your 17 answer to that is yes. then we will pursue whichever j
18 one it is in a little more detail.
19 A
I can't recall being told about any of 20 those specific failures, but since the valve had not 21 exhibited a failure in the past, I wouldn't expect to 22 have them annotated like that.
23 Q
In other words, you wouldn't expect, as O) t.
24 part of your training, to be told of the extent to 25 which the light on the panel might not be an accurate
5 1
Frederick
.418
,.U 2
indication of the position of the PORV?
MR. SELTZER:
I don't think that is what 3
4 he was saying at all.
llh 5
MR. FISKE:
Then I would like to clarify 6
that.
7 A
I think I have said that I don't recall 8
being trained that the valve might be an inaccurate 9
indication of the valve's position.
That does not 10 mean that I couldn't think of, if I had been given the 11 task, some way in which that indication might mislead
.12 me.
O kl 13 My answer to your previous question was 14 I don't remember being told of those specific failures.
15 Q
So you were not told of any one of those 16 26 separate ways in which the valve might remain open, 17 even though the light was off?
18 A
I don't recall being told about any ona 19 of those 26 failures or knowing that anyone even knew 20 that those 26 failures could occur.
21 MR. SELTZER:
What was that you were 22 reading from?
23 (continued on next page)
)
24 s-
~
25
5A 1
Frederick 1.418A O
\\'
2 MR. FISKE:
A GPU document prepared, 3
captioned "This list represents potential 4
failures of the PORV to close."
llh 5
(Time noted:
4:30 p.m.)
6 7
EDWARD R.
FREDERICK 8
9 subscribed and sworn to 10 before me this day 11 of 1982.
12 13 14 15 16 17 18 19 20 21 (B) 22 23 A]
24 L-25
l 7
g 419
)
n j
e CERTIFICATE 2 ji STATE OF NEW YORK
)
3 ll
- ss.:
il COUNTY OF NEW Y'ORK
)
4 I,
JOSEPH R.
DANYo
, a Notary i
Public of the State of New York, do hereby 6
l l
certify that the continued deposition of EDWARD R. REDERICK Was taken before me on Thursday, May 6,
1982 consisting 9
of pages 282 through 418A I further certify that the witness had l
11 i
been previously sworn and that the within k,#I transcript is a true record of said testimony; l
13 That I am not connected by blood or 14 j
marriage with any of the said parties nor 15 l
interested directly or indirectly in the matter l'
in controversy, nor an I in the employ of any i
1,.
i of the counsel.
I 18 l
IN WITNESS WHEREOF, I have hereunto set my l
hand this
[
day of 8//V
,1982.
j 20 }
/
l
{
21 LA / (l.s 23 sdH R. DANYO/
24 l i
25 1
i l
t.
May 0, 1982 420 i
INDEX a
w erf WITNESS PAGE
} h Edward R. Frederick 284 EXHIBITS B&W FOR IDENT.
655 Document entitled "TMI Staff a
Interview, Ed Frederick, April 6,
1979, Conducted by T. Van Witbeck, et al."
308
-)
656 Copy of letter dated July 30, 1975, from L.
C.
Rogers to J.
P G.
Herbein.
396 1
e e e t
.i 4'I t
L
,y
.. ; -. u,......
.* ' _ *{T, 5;' '
y
~
.. ob r
- n Lv.:S r,..
.,Q i*M'. s.
y*. r,
- ) *:.gQ ey. :.
4 9.;'s
- q.,,d.*p
,s.
, jk,).xy;'r:, -..
[
- 'i
..e
.s. a,.
..c
. W3.
i a: 4 ':. Ch' ; p:..':,. i '. :-.
E $'kY[.
'b' Skt,- '.;J
$ yhc.
. N @!*g N
wp-@w
.{.
, ;.g s:J.m.h 3 e c i $N,:g j.. ;
. ~/.o.*c.. M e
t
- 3. 2; n,. c.
, % w < ', a. ' w..
,:.~l :e v..s a.,.,
). f, ' s --,
n
~.s :
..~3
- *s
.s.
g..-l n...
1 F:. pg. e*
..; g 4. j rs?!g...G. g :'.P.*n..-.. : g:.,' ~..
c-.
, v --h:..,.,.G.. tJ-
.1. '. n '
~.c,.H
- ~...
.w:.r. t...m r.,...p.
+%
-? $,;gt.
..e
...,n.,..
- s..
_...