ML20072H761
| ML20072H761 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/07/1982 |
| From: | Beers M GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-06, TASK-10, TASK-6, TASK-GB NUDOCS 8306290724 | |
| Download: ML20072H761 (151) | |
Text
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BK 1
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
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-__________3 GENERAL PUBLIC UTILITIES CORPORATION, t
JERSEY CENTRAL POWER & LIGHT COMPANY,
(,-
METROPOLITAG EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-80 Civ. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.
Defendants.
1,
--x l
Deposition of Plaintiff GENERAL O
PUBLIC UTILITIES CORPORATION, by MARSHALL L.
t l
BEERS, taken by Defendants pursuant to 1
agreement at the offices of Davis Polk &
Wardwell, Esqs., 1 Chase Manhattan Plaza, t
New York, New York, on Wednesday, July 7,
1982 at 10:00 a.m.,
before Nancy A.
l Rudolph, a Shorthand Reporter and 1otary 1
~for the State of New York.
Public within and h
O T
l DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 LuxlNGToN AVENUE l
WALTER SH APIRO, C.S.R.
New Yons. N.Y.
10017 CHARLES SH APIRO, C.S.R.
Tgs.spNoNs 212 - 867-8220 l
I i
2 i
O 2
Appea ra nc as 3
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQSs Attorneys for Plaintiffs 4
425 Park Avenue New York, New York BY:
STEVEN J.
GLASSMAN, ESQg 6
and-7 JULIE NEISSER, ESQ.,
(A.M. Session) 8 of counsel 9
10 DAVIS POLK & WARDWELL, ESQS.
t Attorneys for Defendants 11 One Chase Manhattan Plaza
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.12 BY:
ROBERT B.
FISKE, ESQ.
-and-14 KAREN E.
WAGNER, ESQ.,
15 of counsel.
16 4
17
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18
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19 Also Present:
20 SUSAN HANSON
-21 22
_oco.
23 24 25 i
)
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(_)
2 IT IS HEREBY STIPULATED AND AGREED by 3
and among the attorneys for the respective 4
parties hereto that the sealing, filing and
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5 certification of the transcript of the within 6
deposition be, and the same hereby are waived 7
that said transcript may be signed before any 8
^
Notary Public with the same force and effect 9
as if signed before the Courts and that all 10 objections except as to the form,of the 11 question, are reserved to the time of trial of
'12 this action.
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13 14 15 16
-o00-17 18 19 MARSHALL L.
- BEERS, having 20 been first duly sworn by a Notary Public, 21 testified as follows:
22 EXAMINATION BY MR. FISKE:
23 Q
Please state your name for the record.
24 A
Marshall L.
Beers.
25 Q
Where do you live?
I
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1 Beers 4
rn 2
- A 313 Mine Road, R.D.
- 5, Lebanon, 3
4 Q
Mr. Beers, how are you enployed right now?
({,
5 A
At the present time I am employed by GPU 6
in the quality assurance departmont as an op.erations 7
quality assurance monitoring supervisor.
8 Q
How long have you held that position?
9 A
Since early 1980, February, I believe.
10 Q
What was your position before that?
11 A
Prior to that time I was group
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12 supervisor of licensing training.
13 Q
And you held that positio'n beginning 14 when?
15 A
July of '78 to February of
'80.
16 Q
Can you tell us briefly what your 17 responsibilities are in your presant position?
18 A
In my present position I am responsible 19 for supervising four people who monitor activites
.J in the operations area and RAD CON and chemistry 21 area radioa'ctive waste shipping.
22 Q
Where are you physically located?
23 A
I am physically located in a trailer b(^^
24 complex towards the north end of the Island,
~ i5' immediately north of the Unit.1 service building.
2
1 1
Beers 5
0 2
Q And who do you report ta?
3 A
I report to John Fornicola.
4 Q
What is his title?
(
Operations qual'ity assurance manager.
5 A
6 Q
You said that one of your responsibilites 7
is to supervise four people who are monitoring 8
activities in the operations area, did I understand 9
that correctly?
l 10 A
That's correct.
11 Q
What kinds of activities in the 12 operations area are these people monitoring?
()
13 A
Any activities that are classified as 14 important to safety activities.
15 Q
Does that position that you are in now 16 have'any responsibility for the training of 17 operators?
18 A
Licensed operators?
19 Q
Yes.
20 A
No, it does not.
21 Q
Do you have any responsibility for training
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1 22 unlicensed operators?
2a A
We have a section training program 24 within our section, and I have provided some training 25 in the operations area to our own people.
1 Beers 6
(~~
2
- Q But is it correct that you were not part 3
of the training department at Met Ed?
4 A
No, we are not related to the training
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5 department at all now.
We do not report to the 6
training department or in any way are we related to 7
the training department.
8 Q
At any time before you came here to 9
, testify, Mr. Beers, had you received notice that the 10 defendants in this case had requested the production 11 of certain documents from your files and from the
' 12 company files?
13 A
Yes.
14 Q
And have you or had-you made a search 15 of your files to comply with that request?
16 A
Yes, I did.
17 Q
And have you turned over to~your 18 attorneys all the documents that were called for by 19 that request?
20 A
Yes.
21 Q
Where did you keep your files relating to 22 your duties prior to the Three Mile Island accident?
23 A
Mr. Fiske, could you be more specific?
(Q
's 24 Prior to the Three Mile Island accident, during the 25 period of time that I was training supervisor, is i-
i 1
Beers 7
2 that what you are referring to?
3 Q
I guess I am going back even before that.
4 A
Would you like me to tell you --
(
5 Q
Why don't we do this, Mr. Beers, just to 6
save timo:
Let me mark your resume as the next B&W 7
exhibit.
8 (copy."o f '" Synopsis pf Resume pf 9
Marshall L. Beers" *was marked B&W Exhibit 889 10 for identification.)
11 Q
Do you have B&W 889 in_ front of you, 12 Mr. Beers?
13 A
Is the resume established as 8897 14 Q
Yes.
15 A
Yes, I have the B&W Exhibit 889 in front 16 of me.
17 Q
And that's captioned " Synopsis of Resume
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18 of Marshall L.
Beers"?
19 A
That's correct.
20 Q
Can you tell us the circumstances under 21 which that' document was prepared?
(.
22 A
Yes, I can.
23 I was asked to make a deposition for 24 the -- I am not'sure of t'he proper terminology, the
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25 Y.emony Commission, I believe, and prior to being
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i seers a
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2 deposed we were asked to write up a resume.
3 Q
And did you prepare this document?
4 A
Yes, I did.
(>
5 Q
It was accurate as of the time you 6
prepared it?
7 A
Yes.
8 Q
This document indicates that as you said 9
earlier, from July '78 to sometime after the Three 10 Mile Island accident you held a position of group 11 supervisor in the training department, correct?
12 A
That's correct.
~h*
13 Q
It also indicates from June '73 to June 14
'78 you were a shift supervisor for Metropolitan 15 Edison, correct?
I 16 A
That's correct.
17 Q
And from November '70 to May '73 you 18 were Unit 2 shift foreman and Unit 1 shift foreman 19 at Metropolitan Edison?
20 A
That is correct.
21 Q
Now, my question about the documents, 22 Mr. Beers, covers the period of time from November 23 1970 right up through the time of the accident, and I
24 my question was where did you keep the files that
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25 you maintained during that period of time?
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1 Beers 9
f')
V.
- A Let's start when I first.came to 2
3 Metropolitan Edison in 1970 We were located in the 4
administration building toward the center of the
(
5 Island in the Unit 2 area, and we were in a small 6
office'and I maintained a file cabinet in the office 7
that I was in.
We moved several times. I just don't 8
recall the sequence of events of where I was at 9
different times on the Island, but in any case each 10 time that I moved I had a file cabinet,that was 11 assigned to me that I kept my documents in or in 12 the desk that I was assigned to.
~
. ( >)
13 When I went to be -- when I moved to 14 Unit 1 as a shift foreman we had an office immediately 15
, adjacent to the control room, each person had a desk 16 and a file cabinet assigned to him, and that's w'here 17 the documents were kept.
~
18 That covers the period of time from 1970 19 to 1973 as best as I can recall.
20 Q
How about from 1973 to 19787 21 A
From 1973 to 1978 the same room 22 immediately adjacent to the control room sometimes 23 called the shift supervisor's office, I had a desk 24 assigned to me there and a file cabinet.
()
25 Q
And how about during the period of time i
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1 Beers 10 2
when you were in the training department?
3 A
When I was in the training department I 4
had my own office and I had a bookcase and one, 5
5-drawer file cabinet in my desk, and in those
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6 receptacles is.where I kept all the documents.
7 Q
When you became group supervisor in the 8
training department, did you bring with you the 9
documents that you had accumulated during your prior 10 positions?
11 A
Would you repeat the question when I 12 became group supervisor of training?
O
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13 Q
Yes.
14 You set up business in your own office, 15 did you bring into that office documents that you had 16 collected in your files during the time you were 17 shift supervisor or shift foreman?
18 A
I don't recall that I -- I may have 19 brought a few materials.
Most of the materials I 20 just left there for the shift supervisor that 21 replaced me.
L 22 Q
In Yebruary 1980 when you assumed the l
23 position that yciu have now you said you were located
'~N 24 in a trailer at the north end of the Island?
U 25'
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A That's correct.
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I Beers 11 2
- Q What did you do with the. documents that 3
you had collected during the time you were group 4
supervisor in the training department?
5 A
I left them there in that office because
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6 I was going out of the training area completely so 7
I left all documents that were related to training,
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8 I left them in that office for the person that was 9
. to replace me.
10 Q
When you received this document request 11 in this case, did you go back to the files that you 12 had kept when you were in the training department O
\\/I 13 and make a search of those files?
14 A
No, I did not because I made the 15 assumption that those files'were no longer mine,
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16 they' belonged to the person that was now supervisor l
17 of training, licensed training.
18 Q
And who was that?
-19 A
Sam Newton.
20 Q
Did you go back and search the files 21 that you had maintained during the time you were a 22 shift supervisor or shift foreman?
23 A
No, I did not.
24 MR. GLASSMAN:
I assume these questions, 25 Mr. Fiske, are directed to whether Mr. Beers
_=..-,,.,
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Beers 12 O
k l-2 personally made such a search?.
3 MR. FISKE:
Yes I will ask the same 4
questions, though, since Mr. Glassman has
((
5 brought this issue up.
6 Q
Did you direct anyone to search those 7
files, that is, the files that you had maintained in 8
the training department or the files that you had 4
9 maintained as a shift supervisor or shift foreman?
10 A
No, I did not direct that. I was aware 11 that this type of document request had gone out to 12 practically everyone on the Island.
13 Q
Did you at any time prior to the Three 14 Mile Island accident maintain any files that you 15 kept at home?
16 A
I may have taken training materials home 17 just for the short period of time to study, but I 18 always brought them back to the Island.
19 Q
so is it correct, Mr. Beers, that the 20 only files that you personally searched in response 21 to the document request were the files that you were 22 maintaining in your position that you held beginning i
23 February 1980?
24
.A That's correct.
25 Q
Did you actually produce any documents l
i
l Beers 13
~
2 for review by counsel?
3 A
Yes, I submitted a whole list of 4
documents and a box of documents.
(
5 MR. FISKE:
Let me show you a document t
6 which we will mark as Exhibit 890, 7
(copy of multi-page document entitled 8
" Selection, Training, Qualification, and 9
Licensing of Three Mile Island Reactor 10 Operating Personnel," by Ronald Eytchison 11 was marked B&W Exhibit 890 for identification.)
12 Q
Do you have Exhibit 890 in front of you, 13 Mr. Beers?
14 A
I have Exhibit 890 in front of me.
15 Q
Let me direct your attention to page 2 16 of that document which has the printed number 55901 17 down at the bottom.
18 Is that your handwriting on that page?
19 A
Yes, I believe that's my handwriting.
20 Q
And did you have this document in your 21 files at some point after the Three Mile Island 22 accident?
23 A
Yes.
24 Q
can you tell us what this document is, h,
y
~ '
~ ~ ~ Mr. Beers?
25
1 Beers 14 (9
V
- A The author of this document, Ronald 2
3 Eytchison, was part of the Kemeny Commission Task 4
Force.
He was the technical advisor to the people
(
5 that were giving the deposition, the Kemeny 6
deposition, and Mr. Eytchison produced this document 7
following the -- all the depositions that were given 8
as part of the Kemeny investigation.
g Q
Did you understand that Mr. Eytchison 10 had reviewed the evidence that had been submitted to 11 the Kemeny Commission and from that had prepared this 12 report?
1
'/
13 A
I don't recall. I recall that this report 14 came out after all the depositions, and I believe 15 that I made the assumption that he had written the 16 report based on the depositions.
17 Q
How did you get this report?
t 18 A
I don't recall.
19 Q
Well, were you asked by someone at Met 20 Ed to review this report and make comments on it?
21 A
Yes, I was.
To the best of my 22 recollection, Mr. Zechman asked me to review and 23 comment on this report.
24 Q
And in what form did your comments take?
()
25 A
Just as you see them here. I reviewed
1 Beers 15 2
the report and annotated them in red. pen.
3 Q
Then what did you do with the annotated 4
report after you had completed your review?
(
5 A
I don't recall.
6
.Q Did you give it to Mr. Zechman?
7 A
well, as I said earlier, Mr. Zechman had 8
asked me to review it.and comment on it.
And I 9
always complied with Mr. Zechman's wishes.
10 Q
Does that answer mean that.you did give 11 your comments to Mr. Zechman?
12 A
I just don't recall positively that I 13 gave the report to him.
14 Q
Now, you gave a deposition, did you not, 15
.to the representatives of the Kemeny Commission?
16 A
Yes, I did.
17 Q
And did you also give testimony before 18 representatives of the inspection and enforcement 19 section of the Nuclear Regulator Commission in the 20 company of Mr. Baldson, Mr. Brown and Mr. Zechman?
21 A
The reason I hesitate in answering that, 22 Mr Fiske, is I recall the deposition but I am not s
23 quite sure what section of the Nuclear Regulatory
()
24 Commission that it was.
l l
25 Q
They were representatives from the NRC?
1 Beers 16 o
2
- A Yes, they were representatives from the 3
NRC, but I don't recall whether it was I & E.
I 4
don't recall what branch it was from.
(
5 Q
other than those two occasions did you 6
give testimony before any other group after the 7
Three Mile Island accident?
8 A
Yes, I did.
I would not say testimony.
9 I was interviewed by some other groups.
10 Q
can you tell us by whom you were 11 interviewed?
12 A
The two that comes to mind, I was O
13 interviewed by representatives from INPO. I was 14 interviewed by a representative from -- I don't 15 recall the exact title of the organization, Nuclear
^
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16 Insurers.
That's all I recall.
17 Q
Well, what is INPO?
18 A
It stands for Institute of Nuclear Powcr 19 operations. It's an organization -- it's based in 20 Atlanta, Georgia. It's an organization that was 21 established following the Three Mile Island accident, k
22 and it's made up of representatives from the Nuclear 23 Utilities. It's sort of an evaluation organization.
24 Q
Where did that interview take place?
) )
A In the training department.
25
1 Beers 17 2
- Q Well, did you ever see a. transcript of 3
that interview?
4 A
No, the two interviews that I spoke of
(
5 were just rather informal interviews and I don't 6
recall notes being taken or I never saw a transcript 7
of either one of those interviews.
8 Q
And you said you were also interviewe'd 9
by the Nuclear Insurers?
10 A
Yes.
11 Q
What is the subject of that interview?
12 A
I just don't recall.
13 Q
Were you interviewed by anyone within the 14 Met Ed or GPU organization after the accident?
r 15 A
I don't recall that I was.
16 Q
Were you aware that after the accide'nt 17 Met Ed or GPU had commissioned the engine.ering, 18 nuclear engineering department at Penn State to 19 conduct a review of the training program in Met Ed?
20 A
Mr. Zechman when that occurred.
21 Q
Were you interviewed by any representative 22 of the Penn State group?
23 A
No, I was not.
24 Q
Going back to your resume for a minute,
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25 Mr. Beers, going back to the years 1946, 1947 the
1 Beers 1C
(
2 resume indicates that you spent a year at Penn State 3
in electrical engineering?
4 A
Yes, I did.
5 Q
I take it you did not complete that course?
(
6 A
...No, I had to leave college after a year 7
because of family problems and monetary -- lack of 8
money.
9 Q
Your resume indicates that in 1950 you 10 entered the U.S.
Army?
11 A
Yes.
12 Q
Could you tell us what you did between i
13 1947 and 19507 14 A
Yes, I moved to Pittsburgh and started 15 going to Drafting Tool & Die Design School part time f
16 and working at the school.
17 Q
And that's what you did for-those three 18 years?
19 A
That's correct.
/
20 Q
I take it you were discharged from the 21 Army sometine in 19527 22 A
That's correct.
I 23 Q
And then your resume indicates that in 24 1956 you went to work for Westinghouse, is that right?
(
l 25 A
That's correct.
i
=
1 Beers 13
(^N l V, 2
- Q Could you tell us what you did between 3
1952 and 19567 4
A Following my return from the service I l
1
(
5 secured a job in Pittsburgh as an electrical 6
draftsman for an audio installation company.
7 Q
And how long did you keep that job?
8 A
Until I vent to work for Westinghouse in 9
1956.
10 Q
Your resume again indicates from '56 to 11
'61 you worked as an electronics technician for 12 Westinghouse, is that right?
O 13 A
Yes, from 1956 to 1961 I worked as 14 electronics technician for Westinghouse.
15 Q
And that was still in Pittsburgh, right?
16 A
Yes, that was at the Bettis Laborato'ry.
17 Q
In Pittsburgh?
(
18 A
Well, it's not in Pittsburgh' proper,.but l
l 19 it's the suburbs of Pittsburgh.
20 Q
Is it correct that from 1961 to 1970 you 21 were at the Naval Reactors Facility in Westinghouse 22 in Idaho Falls?
23 A
That's correct.
(V\\
/
24 Q
Could you tell us what the function of
~~
_ the Naval Reactors Facility in Idaho Falls was?
25 i
1 Beers 20 O'
2
- A The Naval Reactors Facility of the National Reactor Testing Station was actually three 3
4 facilities.
There was two prototypes, a submarine 5
prototype and an aircraft carrier prototype and an
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6 aXpended core facility there.
These three 7
facilities --
8 Q
What was the third one?
9 A
Expended core facility.
10 Q
Go ahead.
11 A
-- provide research for the Naval reactors 12 program, research and development and the prototypes "h*
13 provided training for Naval -- Navy reactor operators and other rates of Navy people that were required 14 15 to run the prototypes.
16 Q
Were you an instructor in that train'ing 17 program?
18 A
During the period of time from 1966 to 19 1970 I provided oral checkouts to the Navy reactor 20 Operator trainees as they came through the program.
I was not a classroom instructor per se.
The orals 21 22 sometimes developed into a seminar-type oral such 23 that you would provide some instruction.
24 I also during that period of time, I 25 functioned as a chairman of the qualification board r
[
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g seers 21 2
for'the reactor operator traineos.
3 Q
What were your duties in that position?
4 A
I would like to describe to you one of
(
5 these oral boards, if I may, and in that way I could 6
better describe to you my responsibility, if that's 7
all right with you?
j 8
Q Eure.
9 A
Those oral boards were given around a 10 table such as we are sitting at here with a chairman, 11 a civilian chairman such as myself and then the rest i
12 of the people were Navy people.
There would be 13 leading rates in each of the different disciplines 14 that were represented at the plant, for example, 15 an electronics technician, a mechanic, an electrical 4
16 person and a Navy officer.
l l
17 The normal procedure for giving the oral 18 board was for each person to ask the trainee 19 questions in their particular area, following.-
l 20 going around the table.
21 As each person was asking questions it 22 was everyone's responsibility to grade the trainees' 23 answers and following the completion of going around 24 the table and asking the trainees ques,tions in all 25 areas the trainee was asked to leave the rooms a
I I
Beers 22 2
caucus was held as to the grading and qualification 3
of the trainee.
It was my final decision as the 4
chairman of that board to determine the qualification
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5 or the disqualification of the trainee.
6 32.
- And if you found the trainee was 7
qualified, what did that mean?
8 A
That meant th at. the reactor operator 9
trainee was qualified to operate the reactors for 10 which he had been certified.
And from there he left e
11 the station and perhaps went to the fleet or 12 went on to some other school.
("%
i i
13 Q
Was it your responsibility to determine
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14 the content of the courses which were given to the 15 trainees?
16 A
No, it was not.
There was a separat'e 17 training organization at the prototype whose 18 responsibility that was and those were bo'th Navy.and 19 civilian people.
20 Q
Did you yourself have an understanding 21 as to what'you felt the qualifications of the 22 trainees should be before they were permitted to 23 operate the reactors?
tm()
24 A
Well, as you will see from my resume, 25 prior to my having this position as reactor engineer
' ~ ~ ~
1 Beers 23 0
2 g,,'n t through the Navy training procjram myself there 3
at the site and in that manner became qualified to 4
operate the reactors, and in that role I became very 5
familiar with the content of the training that was 6
provided to the Navy reactor operator trainee.
7 Q
At the time you were doing this, you were 8
an employee of Westinghouse?
O
~
A Yes, I was.
0 Q
Being paid by Westinghouse?.
11
~
We A
Yes, we were paid by Westinghouse.
12 were, I guess, you would call it subcontracted to the Navy, part of Adm. Rickover's Naval program.
14 Q
The three prototypes that you had at Idaho Falls IO A
Two prototypes and one expended core.
17 Q
The two prototypes were one for submarine and one for aircraft carrier, correct?
19 A
That's correct.
20 Q
Those were prototypes of the type of 21 reactor that was then in use on submarines on the one 22 hand and aircraft carriers on the other?
23 A
That's correct.
O 24 (j
Q I take it no part of this training 25 involved training on a Westinghouse commercial
1 Beers 24 2
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reactor, is that right?
3 A
No, these were not commercial Westinghousereactorsh.theseweraNavalreactors 4
s 5
Q Did you yourself at any time that you 6
were with Westinghouse receive any training from 7
Westinghouse on the operation of a Westinghouse 8
commercial reactor?
9 A
Let me understand you, Mr. Fiske: -What 10 you mean by Westinghouse commercial red,ctor.
You 11 speaking of a commercial reactor that generates are 12 electricity and supplies electricity out on to some 13 grid, is that what you mean by that?
14 Q
Yes.
15 A
No, I did not receive any specific 16 training in that area when I worked for Westinghouse.
17 Q
The training that you yourself received I0 at Idaho Falls as part of the Navy reactor operator 19 training was given to you by Navy people?
20 A
It was a combination of Navy people and 21 civilian people. It was an integrated program.
Some 22 classes were taught by Navy peopler some classes were 23 taught by civilian people.
24 Q
Did the civilian people come from 25 Westinghouse?
)
I Beers 25 0
2
- A Yes, they did.
3 Q
In the interests of saving time if you 4
could answer this question in the form I am about to
(
5 ask it, it would be helpful.
If not, I would try to 6
be more specific but were there any specific 7
differences between the prototype for the submarine 8
reactor and the prototype for the aircraft carrier i
9
- reactor?
10 A
The principle of operation.they were both 11 pressurized water reactors and the basic principles 12 of operations were the same, but they were O
13 significantly different in size and design.
14 Q
They both had a pressurizer?
15 A
Yes, they did.
16 Q
Did they both have high-pressure 17 injection?
i 18 A
I can only talk about the aircraft l
l 19 carrier prototypes because that's the one-I was 20 qualified on and to answer your question, Mr. Fiske, 21 we did not'have a system called high-pressure
.k 22 injection.
There was a system that provided a core 23 cooling function.
O) 24
-Q Was that a system that was designed to
(_
25 come on automatically when it was needed?
~~~
i 1
Beers 26 Ci U
- A I don't recall the initiating parameter 2
3 for that system other than I recall that you could 4
initiate it manually.
(
5 Q
Did the pressurizer have safety valves 6
on the top?
7 A
The pressurizer had safety valves. I 8
don't recall whether they were on top of the,
9
. pressurizer or whether they were downstream from the 10 pressurizer.
11 Q
What do you mean by " downstream"?
12 A
Well, I don't recall whether they were 1
\\~/.
13 attached directly to the top of the pressurizer or 14 whether there was piping that came off the top of the 15 pressurizer and went some d'istance and then had a safety 16 valve installed on the piping.
17 Q
But there were valves that were designed 18 to open and allow steam to escape in the' event of an 19 overpressurization?
20 A
There were valves installed as 21 overpressure protection for the reactor coolant 22 system on the pressurizer.
23 Q
I guess my question is were they located 24 in such a place that when they opened the first thing
(
25 that would go out was steam?
. ~.
i i
i 1
Beers 27
(]
/
~ A It came off the top of the pressurizer, 2
3 the piping came off the top of the pressurizer.
4 Steam is in the top of the pressurizer.
The valves
(
5 had a water seal on them, between the valves and the 6
pressurizer, as I recall, a loop seal.
Did you receive any training out at 7
Q 8
Idaho Falls on how the operators should diagnose 9
- the existence of a struck open safety valve?
10 A
I don't recall.
It's too 1ong.
11 Q
Did you receive training in the Navy on 12 loss-of-coolant accidents?
O 13 A
Part of the safety analysis for Navy 14 plants covered loss-of-coolant accidents and 15 therefore we received training on the safety analysis 16 and associated loss-of-coolant accidents, i
17 Q
Did you receive training in the Navy on 18 the criteria for terminating the emergency core 19 cooling system?
20 A
I don't recall.
21 Q
Now, your resume indicates, Mr. Beers, 22 that you came to Metropolitan Edison in November, 1970 23 as a shift foreman?
()
24
'A Yes, I did.
25 Q
You received a reactors license on
i l
Beers 28
~
2 Unit-17 3
A some period thereafter.
4 Q
And did you also at some point receive a
(
5 license on Unit 27 6
A, Yes, I did.
Let's go back to your 7
question.
8 What kinds of license did you ask me that 9
I had?
10 Q
Reactors operators license.
11 A
No, I never had a reactors license on 12 Unit 2.
I had a senior reactors operator on Unit 2.
h.
s/
13 Q
What kind of license did you have on 14 Unit 17 15 A
I had both.
First I had a reactor
~
16 operators license and then a senior reactor operators-17 lincense.
18 Q
Now, this document which is Exhibit 889 19 has a portion of it which is called, " Amplified 20 Resume."
21 Do you see that?
22 A
Yes.
23 Q
Directing your attention to the bottom
(
24 of the first page, it says:
"10/70 to 6/73:
Shift 25 ' '~ foreman, Metropolitan Edison. Company."
It says,
I L
seers 29
[
~
V 2
"This position included the following. activities:
3 Ga)
Preparation of test specifications and 4
procedures."
(
5 Do you see that?
6 A
Yes, I do.
7 Q
Were you involved in the preparation of 8
operating procedures for Unit 17 9
A For Unit 17 10 Q
Yes.
11 A
Not during this period-of time.
During 12 this period of time I was assigned -- most of this
/ 'T
\\~'
13 period of time I was assigned as Unit 2 shift foreman 14 until I started participation in the Unit 1 15 preoperational test program'.
16 Q
So during this period of time from 17 November '70 to May '73 you were a shift foreman at 18 both Unit 2 and Unit 1,
right?
19 A
I realize, Mr. Fiske, that's not very i
20 clear in looking at the resume. I am trying to recall 21 the time frames.
When I was hired in November of L
22 1970, I was hired as Unit 2 shift foreman and I worked 23 at Unit 2 until sometime early in 1973 and at that (Os,_.e) 24 time I was requested to transfer to Unit 1 to 25 participate in a Unit 1 test program and license on
l i
seers 30 0
2 Unit-1.
3 Does that clear it up for you now?
4 Q
I think so.
Yes, it does.
Your resume
(
5 says from June '73 to June '78 you were a shift 6
supervisor?
7 A
Yes.
8 Q
What unit was that in?
9 A
once again, there is a period of time 10 there where I was shift supervisor of Unit 1 only --
11 let me direct your attention to the last page, the 4
12 page where it says " Licenses and Qualifications."
.O kl 13 You see in 1977 my license was amended to 14 include both units so I was shift supervisor of 15
. Unit 1 up until sometime prior to 1977.there, when 16 I went into a cross licensing program to be licensed 17 on both units.
I don't know exactly the tine frame.
18 that you would say I was now assigned as -- called a 1
19 shift supervisor on both units, 20 Q
Do you understand from this that 21 sometime in early 1973 until sometime before you N.
22 received your senior operators license on Unit 2, you 23 were working primarily on Unit 17
()
24
.A That's correct.
25 Q
Your resume indicates, Mr. Beers, that i
,,-.c.
.,.. ~... _ -. -.,
1 Seers 31 O
G 2
were' shift supervisor from June '73 to June
'78, do 3
you ase that on the first page?
4 A
Yes.
5 Q
And then at the top of the page it says
(
6 from July '78 to sometime after the accident you 7
were in the training department?
8 A
That's correct.
I transferred to the 9
training department June 50th, and then July 1st I 10 started being a group supervisor.
11 Q
You went directly from being a shift 12 supervisor to being a group supervisor?
13 A
Yes, I did.
That's not clear, but I did.
14 Q
Had you had any responsibility at the 15 training department a t Met Ed before July 1,
19787 16 A
Do you meon, Mr. Fiske, did I work for i
17 the training dapartment or did I go to the training 18 department?
19 Q
You were not part of the training 20 department at any time until July 19787 a
21 A
That's correct.
22 Q
What were the circumstances under which 23 you were transferred from being a shift supervisor 24 to becoming group supervisor in the training
(
]
25 department?
(
Beers 32 1
A Basically I be ame aware that the 2
~
~
position was open in the training department and I 3
was very anxious to get off of shift work as it was 4
impacting on my home' life and I just wanted to get 5
off shift work mainly.'
6
~
^^' ~
~
~
Q So you applied for the vacancy?
7 C
A I did'.
8 Q
Was there some sort of competition for it?
9 A
Yes.
We had some sort of -- I don't recall 10
(
how I became aware that the, position was'open, but 1\\
an interview p\\
11 there was rocedure and there were 12 other pet ple interviewed for the job besides myself.
13 t
i gQ How would.that v.acancy become created?
14 A
The man that was in the position was being i
15 sister (compa'ny in western Pennsylvania, transferred to the 16
'.i Q
Was that Mr. Goodman?
17 R
Yes.
18 Q
Was Mr.iZechman head of the training depart-s 19 'z h
ment wt the time you applied for this vacancy?
20 A
No, he,wrts, not.
f 21
(
Q.
Who was in charge of the training 22 department at Met Ed atithat time?
23 A
Mr. Tsaggaris.
24 Q
And where was Mr. Tsaggaris located?
25 s
s
I Beers 33 2
' A I don't recall for sure. - I was 3
interviewed at the training department.
I am 4
relatively sure that he was at the training department
(
5 at that time physically.
6 Q
There was a time when Mr. Tsaggaris went 7
to Reading, wasn't there?
8 A
yes.
9 Q
And that was sometime in 19787 10 A
I just don't recall the time frame.
11 Q
Was Mr. Zechman one of the ones that 12 interviewed you for this position?
3 v
13 A
No, it was just Mr. Tsaggaris.
I talked 14 to Mr. Miller about it because at that time I worked 15 for Mr. Miller and he, of course, had to be aware that 16 I was interested in the position even prior to my 17 going to be interviewed by Mr. Tsaggaris.
18 Q
You became group supervisor for licensed l
19 personnel, correct?
20 A
Yes, that's correct.
21 Q
And in that capacity you reported to i
22 Mr. Zechman?
23 A
I can't recall exactly whether when I
)
24 first came to the training department whether
~
25 Mr. Tsaggaris was still there or whether he had left i
l
1 Beers 34 0
2 and I was now reporting to Mr. Zechman.
I just can't 3
quite recall the time frame there.
4 Q
Let me show you a document which was
(
5 marked previously as B&W 555 which is a document that 6
was produced to us by GPU, do you have that in front 7
of you, Mr. Beers?
8 A
Yes, I do.
g Q
Do you see the three dates at the top, 10 March 1,
1976, March 1,
1978 and then March 28, 19797 11 A
Yes.
12 Q
March 1,
1976 it lists A.
Tsaggaris As
(~1 13 supervisor of training, do you see that?
'~
14 A
Yes, I do.
15 Q
As of March 1,
1978 it lists a Mr. Zechman 16 as acting supervisor of training and as of March 28, 17 1979 it lists Mr. Zechman as supervisor of training.
18 Do you see that?
i 19 A
Yes.
20 Q
Now, you came into the training department 21 sometime after March 1,
1978, did you not?
22 A
Yes, I did, 3
23 Q
At that time when this chart would 24 indicate that Mr. Zechman had replaced Mr. Tsaggaris k5
~~
acting supervisor of training?
as
.. ~ _. -
35 L
Beers g
Ns' MR. GLASSMAN:
Are you asking him for 2
his own recollection or from looking at this 3
4 chart?
MR. FISKE:
I am asking Mr, Beers whether
(
5 6
looking at this chart refreshes his recollection at the time he came into the training department 7
8 Mr. Zechman was the acting supervisor of 9
training?
10 A
As I told you before, Mr. Fiske, I just 11 don't recollect the exact circumstances when I came 12 down to the training department.
Mr. Tsaggaris, was still back 13 after he physically moved to Reading, 14 and forth to the training department quite frequently 15 so I just don't recall the exact chain of command when I moved to the training department.'
16 17 Q
Well, in the organization of the training 18 department the position immediately above yours was a
it not?
19 position of supervisor training, was 20 A
Yes.
21 Q
And it is correct, isn't it, that 22 Mr. Zechman held that position either in an acting 23 capacity or as supervisor at all times after you 24 joined the department?
25 A
I have told you, Mr. Fiske, to the best
1 3eers 36 (a) 2 of my recollection what the situation was when I went 3
to the training department.
4 Q
Well, are you telling us, Mr. Beers, that
(
5 you don't remember now who you were supposed to report 6
to at the time you became supervisor of licensed 7
training?
8 MR. GLhSSMAN:
Objection, he told you 9
whatever is on the record.
You have got two 10 different lines of questioning here.
He 11 answered q'uestions in terms of his recollection 12 in terms of the persons he reported to, and the 13 positions they held.
You seem now to be asking 14 different kinds of questions.
15 MR. FISKE:
It's the same question.
Why 16 don't you read the question back?
l 17 (Question read. )
18 A
I have, told you, Mr. Fiske, that the 19 person who interviewed me for the job was-20 Mr. Tsaggaris, 21 Q
That isn't my question, Mr. Beers.
22 A
I am trying to get your question, 23 Mr. Fiske.
And the day that I transferred to the l
Ot,/
24 training department I do not recollect who the 25 supervisor was that day.
)
I 1
Deers 37 o
2
- Q Was there any period of time prior to the 3
Three Mile Island accident when you reported to 4
Mr. Zechman?
(
5 A
certainly.
6 Q
When did that start?
7 A
If I.can't recollect who was the 8
supervisor on 7/1/78 I can' t recollect the exact date 9
that I started reporting to Mr. Zechman, 10 Q
Well, is it fair to say you started 11 reporting to Mr. Zechman whenever he became acting 12 supervisor of training?
O 13 A
That's correct.
14 Q
Now, did you yourself, Mr. Beers, go 15 through any part of the Met Ed training program in 16 the course of qualifying for your licenses on Unit 1 17 and Unit 27 18 A
Yes, I had extensive training prior to 19 receiving my license on Unit 1 in the requalification 20 program subsequent to receiving my licenses on Unit 1,
21 a cross licensing program for -- prior to receiving 22.
my cross license on Unit 2.
23 Q
In the course of the training you
)
24 received, did you have occasion to go to Babcock &
25 Wilcox at Lynchburg, Virginia?
1 Beers 38
(~3, 2
^ A Yes, I was at the Babcock & Wilcox Lynchburg simulator for the first time in 1973, as I recall; 3
4 and attended the simulator many times subsequent to
(
5 that first visit.
6 Q
When was the last time you went there 7
before the accident?
8 A
I don't know the exact date. I believe I 9
was there in 1979 prior to the accident.
10 Q
When you went the first time in 1973, was 11 that in the course of qualification for your Unit 1 12 license?
\\ l-13 A
Yes, it was.
14 Q
Did you participate at all in the review 15 of operating or emergency procedures for Unit 1 in 16 the course of their preparation?
17 MR. GLASSMAN: I am a bit confused, are 18 we now talking about what happened'at the 19 simulator or are we now switching tb a different 20 subject?
MR. FISKE:
I am asking Mr. Beers whether 21 at Met Ed he participated in any way in the 22 23 Preparation of the emergency procedures for
[)
24 Unit 1.
ss 25 A
I don't recall participating in the
1
-Beers 39 a
2 preparation of the emergency procedures in Unit 1.
3 As you recall, when I was talking about the sequence 4
of how I moved from Unit 2 to Unit 1, when I moved 5
to Unit 1 procedures were pretty well written at that
(
6 time, and I started concentrating very heavily on 7
preparation for licens%ng.
8 (Recess taken.)_
9 Q
When you went to the simulator in 1973 10 for the first time had the procedures for TMI 1,
11 Unit 1 been finalized by Met Ed?
12 A
I don't recall.
13 Q
on any of the occasions when you were at 14 the simulator, did you receive training on the 15
. simulator procedure that was in use at old Forest 16 Road?
17 A
After our unit procedures were finalized, 18 we were asked to use our own units, specifically 19 procedures where possible, but since the simulator 20 was not an exact simulation of Three Mile Island 21 there were some cases where we had to rely on old 22 Forest Road procedures.
23 Q
Well, you had a procedure, did you not O)
(_
24 at both Unit 1 and Unit 2 called loss-of-reactor 25 coolant / reactor coolant pressure?
1 Beers 40
/~T O
~
2
- A Yes, we had a procedure like that.
3 Q
And during the period of time that those 4
procedures were in effect at Unit 1 and Unit 2,
did
(,
5 you use those procedures or did you use the B&W 6
stimulator procedures?
7 MR. GLASSMAN:
To where, are you talking 8
about anytime?
9 MR. FISKE:
Fair enough.
10 Q
on those occasions when you went to 11 Lynchburg to the simulator after the Unit 1 emergency 12 procedures had been finalized, did you use the Unit 1 C#
13 LOCA procedure while you were receiving simulator 14 training?
15 A
I just don't recall, Mr. Fiske, other than 16 what I have told you, that we were trained at the 17 simulator.
The simulator instructors impressed on 18 us frequently to use our plant specific p'rocedures 19 as much as possible, and we received training at the 20 simulator on our own plant procedures periodically.
21 Q
And you were supposed to bring those 22 with you, were you not?
23 A
Well, they have a copy of our procedures.
O I
24 The simulator has a copy of our procedure.
NJ Q
For both Unit 1 and Unit 27 25
~
1 Beers 41 J
2
- A Yes.
3 Q
And you understood that under the 4
arrangement that Met Ed had with B&W Met Ed was
(
5 supposed to supply those procedures to B&W and keep 6
them current, isn't that correct?
7 A
I don't know what the arrangement was 8
for the update of the procedures.
9 Q
Well, during the period of time that you group supervisor for licensed training, did you 10 were 11 think it was important that when Met Ed people went 12 down to the simulator at B&W they were trained on 13 the current version of the Met Ed procedures?
14 A
To the best of my knowledge we were 15 trained on the current revision of the procedures.
16 Q
And do you know whether there were 17 procedures in effect at Met Ed to supply B&W 18 Lynchburg with the revised procedures as' revisions j
19 were made?
l 20 A
As 1 just said, Mr. Fiske, I dor,'t know 21 what the arrangement was to supply the simulator 22 with the most current revision.
23 Q
Let me show you a document which has been 24 Previously marked. It's part of GPU 58.
And I will f
)
25 direct your attention to the page that has the stamp
. ~
1 Seers 42 O
2 at the bottom 0090, which is the B&W. simulator 3
procedure loss-of-reactor coolant / reactor coolant 4
system pressure,
](
5 Do you have that in front of you?
6 A --. Yes, I do.
7 Q
Would you just look at the first page of 8
that document?
Have.you had a chance to read that 9
page, Mr. Beers?
10 A
Yes, I read this page.
11 Q
Having read that page, _I would like to 12 ask you whether at any time when you were at B&W on N
a 13 the simulator you used the loss-of-reactor coolant, 14 reactor coolant system pressure simulator procedure 15
.that you are now looking at?
16 A
I don't recall. I don't know what the 17 vintage of this procedure is.
18 Q
Just so I understand your answer, is it 19 your testimony that as you sit here today you don't 20 remember one way or the other whether on any of the 21 occasions that you were in Lynchburg you ever used 22 this procedure?
23 MR. GLASSMAN:
We are talking now about 24 the particular page in front of the witness
()
25 now at this point?
1 Beers 43 Os
~
)
MR. FISKE:
No, I am talking about the 2
whole procedure, the loss-of-reactor coolant, 3
4 reactor coolant system pressure.
(
MR. GLASSMAN:
Just so the question is 5
6 clear, are we talking about a set of pages in 7
this document now or the procedure generally?
8 MR. FISKE:
I am talking about the entire 9
simulator procedure which is in the exhibit 10 before you'.
If you want to take,a look through 11 the whole thing, you are welcome to do that.
I 12 think it's a total of eight pages, starting fb
\\/
13 with page 0090, Mr. Beers.
MR. GLASSMAN:
Just so the question is 14 15 clear, is the question directed to the particular pages you identified as'they appear 16 17 in this particular document, GPU 587 18 MR. FISKE:
Just so the record is 19 clear, I believe GPU 58 is a collection of a 20 large variety of different simulator procedures i
21 and I am referring now specifically to the loss-of-reactor coolant / reactor coolant 22 23 system procedure.
(O 24 Q
And the question'is after taking as
_)
25 much time as you want to to. review the eight pages
~
44 I
Bears 2
in this procedure, can you tell us one way or the 3
other whether or not on any occasions you went to the 4
simulator you used this procedure?
(
5 A
After reviewing this procedure, Mr. Fiske, 6
I just don't recall one way or the other whether I 7
aver used this procedure at the simulator or not.
8 Q
Can you tell us, having looking at it 9
whether you ever saw that procedure at any time 10 before the Three Mile Island accident?.
11 A
I don't recall.
12 Q
Let me show you a document which has O
~ V been marked B&W Exhibit 418 which is a draft, a 13 14 preliminary draft procedure, loss-of-reactor 15 coolant / reactor coolant pressure for Unit 1,
and that 16 again I will ask you whether or not you saw i
document at any time before the Three Mile Island 17 18 accident?
19 A
No, I don't recall seeing this document 20 Prior to the accident.
21 Q
You were aware before the Three' Mile k.
i l
Island accident, were you not, Mr. Beers, that a 22 23 loss-of-coolant accident could cause a sharp drop 24 in pressure in the reactor coolant system?
25 A
A loss-of-coolant accident is one cause av
.-u
--r.--,-.. - - - - -,
.,,.-,-a--
-.,.,-w
- - -, -.. ~, - -.
1 Beers 45 Q
U 2
of the drop in pressure in the reactor coolant 3
system --
4 Q
And did you understand --
(
5 A
--with corresponding drop in pressurizer 6
level-7 Q
Did you understand before the Three Mile 8
Island accident that there were other events that 9
could also cause a decrease in pressure in pressurizer 10 level?
11 A
Yes, I understood that-and we were 12 trained on that both at the Island and at the
(~'s
\\>
13 simulator.
14 Q
Now, directing your attention to the 15
.first page of the simulator procedure which is part 16 of Exhibit GPU 58, and also to.the first page of the 17 draft LOCA procedure for Unit 1 which is Exhibit 418, 18 in each there appears the statement "The~ operators 19 should assume the cause of the symptoms described 20 above is a~n RC leak or rupture unless another cause 21 can be immediately established."
22 I would like to ask you, Mr. Beers, 23 whether or not at any time before the accident at
()
24 anytime you were at the simulator or at Met Ed 25 anyone ever told you that in the event that you saw i
1 Beers 46 (O
v 2
symptoms which could be attributed to a 3
loss-of-coolant accident, but also could be 4
attributed to some other type of event that you
(
5 should assume that the cause of those symptoms was a 6
loss-of-coolant accident unless another cause could 7
he immediately established?
8 MR. GLASSMAN:
Objection as to form.
g Mr.-Fiske, you have also just read apparently 10 from pages of documents which the witness does 11 not recall seeing, and it is improper to ask 12 a question of that sort, and then relate it to
(),
13 some generalized question.
14 MR. FISKE:
I will stand on the question.
15 Do you understand the question, Mr. Beers?
16 If not I would be happy to have it reread.
17 THE WITNESS:
I would like to have that 18 question reread again?
19 (Question read) 20 A
I don't recall anyone telling me that.
21 Q
Now, you knew, did you not, Mr. Beers, 22 before the Three Mile Island accident that if 23 pressure dropped to a certain point in the course of
{)
24 a transient,high-pressure injection would be
\\.,
' ~ ~ ~
25 automatically initiated?
1 Beers 47 i
/"N 2
A That's one of the initiating events for 3
high-pressure injection, yes.
4 Q
And the other initiating event was an
(
5 increase in building pressure, was it not?
6 A
That's another initiating event.
7 Q
And you knew that one initiating event for 8
high-pressure injection would be a loss-of-coolant 9
accident, isn't that correct?
10 A
Initiating event for high-pressure 11 injection, is that what you are referring to, 12 Mr. Fiske?
b.
O 13 Q
Yes.
14 A
I don't believe that you can irrevocably 15 say that a loss-of-coolant accident will automatically 16 initiate high-pressure injection.
17 Q
I understand that there are certain 18 categories of loss-of-coolant accident wh'ich might 19 not automatically initiate HPI.
20 My question is, isn't it a fact that a 21 drop in pressure below the actuation point of HPI was 22 one of the symptoms of a loss-of-coolant accident?
23 A
As I have said before, Mr. Fiske, a f
.24 drop in pressure with an associated drop in (a
25 pressurizer level is one sympton or indication of a
l 1
Beers 48 2
loss-of-reactor coolant casualty, but there are other 3
casualties that you could have the same indication.
4 Q
And one of those is a so-called
(-
5 overcooling transient, is it not?
6 A
Yes.
7 Q
That would also produce a drop in 8
pressure and a drop in pressurizer level, isn't that 9
- correct, as you understood it before the Three Mile 10 Island accident?
11 A
That's correct.
12 Q
Putting aside a loss-of-coolant accident, 13 Mr. Beers, isn' t it correct that bef ore March 28, 14 1979 you did not know of a single type of transient 15
.that could produce a drop in pressure that wouldn't 16 also produce a drop in pressurizer level?
17 A
It's difficult for me to separate out 18 in my mind what I knew prior to March 28/ 1979 and 19 what I knew afterwards.
20 Q
You know today, do you not, that in the 21 case of a loss-of-coolant accident which involves 22 an open pilot operated relief valve you can have a 23 drop in pressure with an increase in pressurizer 24 level?
25 A
From the reports that I have read about
)
1 Beers 49 O
2 the Three Mile Island accident on March 28 and 3
subsequent training that was received both at Three 4
Mile Island and at the simulator shortly following
(
5 the accident, I now understand that you can have a 6
rise in pressurizer level when there is a rupture in 7
the pressurizer itself.
8 Q
And do you know today, Mr. Beers, of 9
any transient other than the one we have just 10 described which will produce a drop in pressure and t
11 a rise in pressurizer level?
I 12 A
I can't think of any.
13 Q
I take it that you didn' t know of any 14 before the Three Mile Island accident, though, 15 either?
16 A
All the training that we had prior to 17 the Three Mile Island accident both at the Island 18 and at the simulator taught us that pressurizer 19 level was the primary means for determining reactor 20 coolant system inventory.
And if you had a break in 21 the reactor coolant system you would have a drop in 22 pressurizer icvel and corresponding drop in pressure, 23 but you had to evaluate those symptoms along with (O,/
24 other symptoms that would be manifested on different
~
25
_ instruments.
u
i Beers 50
(~h V)
- Q You understood, did you not, Mr. Beers, V
2 3
that once high-pressure injection had come on in 4
response to a loss-of-coolant accident that it was
(
5 necessary to leave the high-pressure injection on in 6
order to protect the core?
7 A
No, I didn't understand that.
If we left 8
the high-pressure injection on in accordance with 9
the emergency procedures until reactor coolant system 10 inventory was reestablished by indication on the 11 pressurizer level, per the procedure, 12 Q
We will get into specifically what the
~/
13 p ro cedure said in terms of terminating HPI on 14 pressure and pressurizer level in just a minute.
15 I am asking you'now about more what 16 was in the procedure, what your understanding was l
17 of the purpose of having high-pressure injection
~
18 come on when you had a loss-of-coolant accident, 19 and didn't you understand that the purpos in having 20 high-pressure injection come on in the course of a 21 loss-of-coolant accident among other things was to 22 replace the water that was escaping?
23 A
Yes, I understood that the purpose of
()
24 having a high-pressure injection come on at the 25 initiation point was to supply water for the lost i
1 Beers 51 2
inventory in the reactor coolant system.
3 Q
And didn't you understand that if the 4
system was not allowed to perform that function and
(
5 replace the water that was escaping, there was a 6
risk that the core could become uncovered?
7 A
I am sorry, Mr. Fiske, I don't see the 8
relationship between the two questions.
9 Q
Did you understand before the accident 10 that high-pressure injection had anyth ng to do with 11 keeping the core covered?
12 A
As you have just stated, Mr. Fiske, it is 13 my understan(.ing that the reason high-pressure 14 injection comes on first is a high-pressure pump, 15
.its purpose is to replace the inventory that is lost 16 as a result of a break in the reactor coolant system.
17 I'm sorry, I still just don't understand 18 what you are asking me on the other portion of the 19 question.
20 Q
Well, the question is pretty simple.
21 Did you understand at any time before the 22 Three Mile Island accident that it was important 23 that HPI be allowed to perform its intended function
[')
24 in order in part to keep the core covered?
'% J 25 A
I think our training did not develop i
1 Beers 52 O-
~
2 specifically on the HPI system by itself.
We talked 3
about the whole emergency safeguard system as one 4
system.
If you talk about that whole system the l
5 most important function of that whole system is to 6
keep the core covered during a loss-of-coolant 7
accident.
8 When I talk about the whole system, I 9
am talking about HPI, the core flood tanks, LPI and 10 so on.
11 Q
Well, you knew before the accident, 12 didn't you, that the LPI pumps, the low-pressure
\\#
13 injection pumps would not start putting water into 14 the system until pressure reaches a level somewhere 15 around 500, 600 pounds psig?
16 A
I understood that the LPI pumps would 17 start putting water into the break somewhere around j
18 300 pounds.
19 Q
And that once pressure had dropped below r
20 1640 until the pressure went down as far as 300 21 pounds, high-pressure injection was the only vehicle
(.
22 for replacing the inventory that was being lost in a 23 loss-of-coolant accident, isn't that correct?
()
24 A
No, Mr. Fiske, that's not correct.
~~~
Q Well, what else was available to replace 25 I
1 Beers 53 i
i 2
the coolant?
A At 600 pounds the core flood tanks would 3
4 start discharging their volume of fluid into the
(
6
.Q
.I will amend my previous question to ask 7
you, isn't it a fact that you understood before the 8
accident that once pressure had dropped below 164'O 9
, until it got down to 600 pounds psig, that 10 high-pressure injection was the only source of water 11 to replace the coolant that was escaping?
12 A
If I had established that we were indeed
/
13 in a loss-of-coolant casualty high-pressure injection m-14 pumps are the source of water pressure to replace the 15 lost reactor coolant system inventory.
16 Q
And you understood, did you not, that 17 it was important not to turn off the high-pressure 18 injection system in the course of the 19 loss-of-coolant accident once it had come-on automatically until pressure had dropped at a point 20 21 where the core flood tanks or the low-pressure 22 injection were putting water into the system?
23 MR. GLASSMAN:
Could I have that read 24
.back?
(Question read) 25 1
y
,-,m-,e.----y
--m
,c q
--.y.
.y
. - - - - - - - + -
y.e.,,
-e,s9
1 seers 54
^t 3
~
kJ MR. GLASSMAN:
Just so I. understand:
2 There seems to be a bit of confusion, are you 3
4 asking the question in a theoretical basis or
(
5 in terms of operating approach?
6 MR. FISKE:
I don' t think this is 7
theoretical.
8 MR. GLASSMAN:
You seem to use the word 9
" understanding," and I am not sure what the 10 question is focusing on for now..
11 MR. FISKE: I will stand on the question.
12 I think it is pretty clear.
13 A
I just don't recall, Mr. Fiske, what my 14 understanding of the procedure was prior to March 28 15
.in this area.
16 Q
In the course of the training that went 17 on out at Idaho Falls either that you received or 18 that you were familiar that others were receiving, anything said about possible problems-associated 19 was 20 with going solid?
21 A
As I recall, some Navy training in that 22 area warranted that you should not operate with a 23 solid system. I am trying to recall an axiom that ID 24 oftentimes was pointed out to us, A 1 degree rise
%)
25 in temperature in a solid system will raise the
's
I 1
Baers 55
().
~
2 pressure 100 pounds. I seem to recall something like 3
that.
This was just, I guess you'd call it, a rule 4
of thumb that was taught to the Navy people to stress 5
the importance of how quickly the pressure could rise
(
6 in a solid system situation.
7 Q
Was that same rule of thumb communicated 8
to you or others in the course of training at Met Ed?
9 A
I don't recall that being specifically 10 in the training, but we did have a number of ex-Navy 11 people as operators at the Island. -
12 g
well, I guess my question is beyond what O
13 you may have learned at Idaho Falls.
Was this same 14 sort of concept, this rough rule of thumb, was that 15 part of the sort of folklore, if you want to call it 16 that, that was communicated at Met Ed?
17 A
I don't recall it being stressed one way 18 or the other. I just don't recall one way'or the 19 other.
20 Q
It is correct, isn't it, Mr. Beers, that 21 in the time's that you were at the simulator in 22 Lynchburg this' question of going solid was not 23 specifically addressed?
24 MR. GLASSMAN: Which question of going
(
~
solid are you now talking about?
Are you now 25
l I
1 Beers 56 2
- talking about the general concept or the 3
Particular 1 degree, 100'psig.
4 Q
Isn't it correct, Mr. Beers, that in the
(
5 times you were at the simulator in Lynchb rg, they 6
did not specifically address the not going solid 7
concept?
8 A
No, I don't think you can say that, 9
Mr. Fiske.
Some of the things that were reviewed at 10 the simulator were limits and precautions.
We were i
l 11 trained on technical specifications both at the i
12 simulator and at Three Mile Island.
13 Q
Well, let me read you a question and 14 answer, Mr. Beers, a question that you were asked i
15 and an answer that you gave in a deposition conducted 16 by the representatives of the Kemeny Commission.
17 I will ask you whether that wa.s 18 accurate.
This is reading from page 113'and the top 19 of page 114; 20 "Q
You mentioned some procedures.
Let 21 me go to this area first.
What has B&W had to say 22 about maintenance of control of the pressurizer level 23 in the experience that you have had with B&W
()
24 training?
25 "A
Well, the limits and pracautions
_ - ~ _ _ _ _
1 Seers 57
)
2 that'I spoke of, in no,t allowing the -pressurizer to 3
go solid, come from B&W.
4 "Q
What about their training programs
(
5 specifically?
6 "A
I don't think it was ever addressed.
7 Not to my knowledge did they ever specifically say, 0
'You must not let the pressurizer go solid.
You must 9
- maintain pressurizer levels within such-and-such a band' other than what it says in the limits and 10 11 precautions,"
' 12 Were you asked those questions and did
(/
13 you give those answers, Mr. Beers, to the Kemeny 14 Commission representatives?
15 A
I would like to look at the document?
Q sure, fair enough.
It starts at line 17 16 on page 113 and you can look at those questions and 17 18 and any others before or after.'
answers,
19 Mr. Fiske, what I think I - '
A-20 Q
Well, first of all, Mr. Beers, just so 21 we understand each other what I asked you simply was 22 were you asked those questions and did you give those 22 answers?
24
'A That's what I see that I said after 25 reviewing the record, yes.
)
1 Beers 58
~
2
- Q And when you testified before the 3
representatives of the Kemeny commission that was 4
under oath, wasn't it?
(h 5
A Yes, it was.
6 Q
And you were doing your best at that time 7
to tell the truth?
8 A
Yes.
9 Q
And were the answers that you gave to the 10 questions I just read the truth as you, understood it 11 at that time?
12 A
To my understanding at that time, yes.
O 13 Q
Now, Mr. Beers, i.: going back to Unit 1 14 for a moment during the period of time that you were 15 active there in 1973 and though 197a, were you aware 16 of any incidents which involved a pilot operated 17 relief valve that had stayed open longer than it was 18 supposed to?
19 A
In Unit 17 20 Q
Yes.
21 A
No, I don't recall the specific incident 22 you are referring to, Mr. Fiske.
23 Q
At any time before the Three Mile Island 24 accident, did it come to your attention that the
()
lI5' " ~~ rupture disk on the drain tank at Unit 1 had blown?
l 1
Seers 39 2
- A Yes, I was aware that the rupture disk 3
had blown.
4 Q
What did you understand was the reason
(
5 why the rupture disk had blown?
6 A
I think it was a number of things that 7
caused the rupture disk to blow.
8 Q
Did any of those things involve a pil'to 9
operated relief valve?
10 A
I just don't recall the specific incident.
11 Q'
Did you become aware at any time before 12 the accident that the design of the drain tank at
(%
\\'
13 Unit 2 was different than the design o'f the drain 14 tank at Unit 1?
15 A
In my tours of the reactor building and 16 tracing systems, things of that nature as part of my 17 own self-training in that area I was certainly aware 18 that the physical size of the drain tank'was greater 19 than the Unit 1 drain tank.
20 Q
And isn't it a fact that you understood I
21 before the accident, Mr. Beers, that the drain tank f
(m i
22 at Unit 2 had been designed with a greater size so 23 that the rupture disk would not blow with the same
[)
24 frequency that it had on Unit 17 x_-
25 A
No, Mr. Fiske, I was not aware as to the 1
t Beers 60 i
i t
\\
~
I
<w
?
~
2 reason that the drain tank at Unit 1.w a s larger than 3
it was at Unit 1 4
Q In the training program, Mr. Beers, was
(
5 any instruction given to the operators on Unit 1 and 6
Unit 2 as to the differences between the drain tanks 7
and particularly as it might relate to the type of 8
incident which might cause the rupture disk to blow?
l 9
A I don't recall any particular emphasis 10 on the training program being put on the differences 11 between the two d rain tanks.
12 Q
There was a light in the control room at
[
\\/
13 Unit 1, was there not, which was supposed to help 14 the operators determine whether or not the pilot s
15 operated relief valve was open?
16 A
Yes.
17 Q
And at'some point in 1978 a light was 18 installed for the same purpose in the control room in 3
s 19 Unit 7, isn't that cc.:r ec t?
20 A
Yes.
21 Q
And as it has been explained in earlier 22 testimony, the mechanism for activating the light in 23 the Unit 2 control room was when power went on to the
,m
)
24 solenoid?
25 MR. GL5SMAN:
Could I have that read i
1 Beers 61 2
- back.
3 (Question read) 4 MR. GLASSMAN:
Objection.
The witness
(
5 can't possibly understand what was explained 6
.in prior testimony.
7 Q
Did you understand before the Three Mile 8
Island accident, Mr. Beers, that there was a light 9
in the control room at Unit 2 relating to the pilot 10 operated relief valve?
11 A
At some point in time prior to the 12 accident there was a light installed on the panel i
13 that was indicative of the position of the pilot 14 operated relief valve.
15 Q
You understood before the accident, did 16 you not, that the light went on when power was 17 flowing to the solenoid?
18 MR. GLASSMAN:
Which of the l'ights are 19 we now talking about, you vary between Units 1 r
20 and 27 21 MR. FISKE:
I am taking them one at a 22 time.
This is Unit 2.
23 A
I don't recall, Mr. Fiske, whether I
\\_)
I 24 understood prior to March 28 the exact circuitry for 25
~ ~ ~that light on the panel.
I understood that that
1 Beers 62 2
light was indicative of the motion of the pilot 3
operated relief valve.
4 Q
Well, you understand today, Mr. Beers, that the mechanism by which that light went on at
(
5 6
Unit 2 was the power flowing to the solenoid?
7 A
In reports that I have read following the
.8 accident that has been mentioned and I understand 9
that.
10 Q
Now, is it correct, that the light at 11 Unit 1 was also activated by power.. flowing to the 12 solenoid?
13 MR. GLASSMAN:
You want the witness' V
14 current understanding?
15 MR. FISKE:
Y e s',
I am just trying to find 16 out in as simplest terms as possible whether there 17 was any difference between those two lights, the 18 way they work.
19 A
Yes, there is a difference.
My 20 understanding today, there is a difference. If you 21 get right down to the wiring and the circuitry, there 22 is some slight difference between the two circuits 23 but they are both assumed by the operator to indicate 24 a condition of the pilot operated relief valve.
(
25 g
well, I am not asking you, Mr. Beers,
1 Beers 63 O
I 2
yet,-what the operators may or may not have assumed 3
the light meant.
We will get to that later.
I am
(
simply now trying to find out how in fact the light
(
5 worked, and I am trying to find out if you had 6
Personal knowledge whether there is any difference 7
between the way the light worked at Unit 1 and the 8
way the light worked at Unit 2.
That's all I am 9
really trying to find out right now.
10 A
Well, let me explain a little more to you, 11 Mr. Fiske.
In Unit 1
. 12 Q
Let me ask it in this sense, Mr. Becrc, A
k s[
13 if this is helpful.
Based on your understanding today s
14 of the way the two lights worked before the Three 15 Mile Island accident did Unit 1 provide any better 16 indication of the position of the pilot operated 17 relief valve than Unit 2 did?
18 MR. GLASSMAN:
Do you want the witness 19 to sit here today and make a comparison?
j 20 MR. FISKE:
- Yes, 21 MR. GLASSMAN:
He is not here to be an l
22 expert on what's better and what is worse.
If I
l 23 you want to ask him whether he had any l
24
. understanding of the differences between them I'
25 in the first place and to describe the
)
I 1
Beers 64 2
differences that's fine, but be is not here to make an evaluation of that sort for the first 3
4 time.
l 5
MR. FISKE:
Well, if you want to stand 6
--on that objection, I am not going to press the 7
ultimate question. I thought it might save an 8
awful lot of time. We can go through in 9
elaborate detail what the wiring was and so 10 forth.
t 11 MR. GLASSMAN: I don't want to set any 12 precedent, but all I know is it won't make a N
13 huge amount of difference.
I don' t want this 14 witness to give you an opinion of things he is 15 thinking about now.
16 MR. FISKE: I can assure you at this' late 17 stage of the game you don't have to worry about 18 setting precedents. I am just interested in 19 trying to move this thing along.
20 BY MR. FISYC:
21 Q
Let me read to you, Mr. Beers, and 22 maybe this will be helpful, from a portion of the 23 interview with those people from the NRC that you 24 referred to earlier, and'I am reading now from
(
25 p age 37 and I am reading from a statement by 4
....-.,___,,,m.-.
1 Beers 65 3
.)
2 Mr. Brown, but this is part of a joint interview at 3
which you were present.
I will let you look at it in 4
just a minute.
(
5 A fellow named Kirpatrick says, "I
6 discussed this area with you before.
You listed a 7
series of differences between Unit 1 and Unit 2 that 8
you believe would have led to -- had they existed on 9
Unit 2, as they do on Unit 1,
may have mitigated this 10 problem.
11 "Mr.
Brown:
One of the lists.
12 "Mr.
Kirpatrick:
Make notes.
p ksI 13 "Mr.
Brown:
I will try, I' don't know if 14 I can remember all or not. One of the things 15 is the electromatic rslief valve.
In Unit 2, 16 there is a status light on the console that was 17 added after they had lost a power supply o6e 18 timer and the only thing that this light does in 19 Unit 2 is give you an indication of -what kind of 20 command signal is being sent to the solenoid 21 valve for this electromatic relief valve.
22 "In Unit 1,
it's a limit switch on the 23 valve that will tell you whether that valve is
()
24 open or closed."
25 MR. GLASSMAN:
Is there a question?
1 Beers 66 O
U
- Q Is it your understanding, Mr. Beers, that 2
3 the distinction that Mr. Brown made in that answer is 4
correct?
(
5 MR. GLASSMAN:
By "the distinction," you 6
are talking about the technical circuitry?
7 MR. FISKE:
Yes, the difference between a 8
command signal and a limit switch.
9 A
It is my opinion --
10 MR. GLASSMAN:
The question was focused 11 not on the opinion of Mr. Brown and whether you 12 agree or disagree with that.
The question is 13 whether Mr. Brown's understanding that the 14 circuitry was different is the same as your 15 understanding.
16 Q
It's a very simple question, Mr. Beers.
17 All I am asking you: Is it correct that on Unit 2 the 18 light was activated by a command signal with the 19 solenoid and in Unit 1 there was a limit switch?
20 A
No, that's not correct.
21 Q
So is it your testimony that Mr. Brown is 22 wrong in his description of the way th e two signals 23 worked?
()
24 MR. GLASSMAN:
Objection.
Let's not 25 talk about whether Mr. Brown is right or wrong,
1 Beers 67
,O
^
2
- just whether he has a different recollection.
~
3 g
You can answer it the way Mr. Glassman 4
suggests. I am not trying to criticize Mr. Brown, I
([
5 am just trying to find out 6
A I don't have the same understanding of 7
the difference between the two light circuitries as 8
Mr. Brown does.
9 M P.. FISKE: I am going to make a 10 suggestion which might save an awful lot of 11 time.
If we can get some sort of a written 12 statement as to what was the way the Unit 1 s/
13 light worked which we can stipulate to, we will 14 save a lot of time.
We can serve an 15 interrogatory.
We can look through all sorts 16 of formal procedures, but we have had thre~e or 17 four different witnesses tell us different I
18 things, and we would just like to get this 19 straightened out.
20 MR. GLASSMAN: I will consider that and 21 get back to you.
L 22 M R.' FISKE:
Fine.
l 23 (At 12: 30 p.m.
a luncheon recess
()
24 was taken.)
= _-___. _
1 Beers 68 t
O 2
- AFTERNOON
$ E S,S ION 1:50 p.m.
3 Marshall L.
- Beers, resumed 4
EXAMINATION BY
(
5 MR. FISKE:
(Continued) 6 Q
Mr. Beers, I take it from one of your 7
answers this morning that sometime in 1977 you became 8
involved again with Unit 27 9
A Yes, sometime in 1977 the shift 10 supervisors were directed to include in their 11 responsibility supervision of Unit _2.
12 Q
And you did that?
13 A
Yes, I did.
14 Q
Did you function as a shift supervisor 15 for both Unit 1 and Unit 2 from that point on?
16 A
From that point until I transferred to 17 the training department, yes.
l 18 Q
And when was it in 1977 that that change 19 took place?
20 A
I don't recall the exact time frame.
l 21 Q
The first half of the year?
I%
22 A
I just don't recall.
23 Q
As a shift supervisor, did you do a l
24 regular shift on duty in the control room at Unit 1 25 and Unit 2 both?
I-
1 Beers 69 2 g
- A The shift supervisor was.not required to 3
stay in the control room at all times.
The shift 4
supervisor was free to roam anywhere within the
(>
5 confines of either Unit 1 or Unit 2.
But part of 6
those duties included being in both control rooms.
7 Q
You did a regular eight-hour shift, is 8
that correct?
9 A
That's correct, unless I was working i
10 overtime.
11 Q
And how would it be determined on a given 12 day whether you were working on Unit 1 or Unit 27 b)
\\-
13 A
We went to both units in the same shift.
14 We just went back and forth between the two units.
15 Q
on a regular eight-hour shift, let's take 16 Unit'2 for a moment, you had two control room 17 operators, right, on duty?
18 A
A minimum of two.
There may have been
~
19 more than two.
20 Q
And you had a shift foreman?
21 A
That's correct.
22 Q
And those three people stayed on duty at 23 the particular unit, right?
()
24 A
They were only licensed on that 25 particular unit if it was during the period of time
1 Beers 70 Q(~h 2
when it was required to be licensed.
3 Q
And if you were on duty on Unit 2 as 4
shift supervisor and then you left to go over to f(
5 Unit 1 I presume the shift foreman would be in charge 6
when you were working, is that the way it worked?
7 A
He was in charge anytime I was not 8
physically there.
There were various means of 9
communication that he could contact me anytime that 10 he felt it necessary.
11 Q
Well, from this period.of time in 1977 12 when you started working at both units up to the I
\\_/
13 time of your entry into the training d$partment, can 14 you tell us approximately what percentage of your 15 time you spent at Unit 1 and what percentage at 16 Unit 27 17 A
A large percentage of the time was spent 18 at Unit 2.
19 Q
More than half?
20 A
More than half 21 Q
More than two-thirds?
22 A
I would think more than two-thirds.
23 Q
You were on duty, were you not, en
()
24 March 29, 1978 at Unit 27
~
25 A
Yes, I was.
I I
1 Beers 71 O
2'
- Q And during the time you were on duty there was a transient involving a failed open pilot 3
4 operated relief valve?
(
5 Is that correct?
6 A
That was not the initiating event.
As a 7
result of another initiating event the pilot operated 8
relief valve did fail to open.
l 9
Q And as a result of that pilot operated 10 relief valve failing to open there was a 11 depressurization which led to actuation of the 12 high-pressure injection system, is that correct?
~
13 MR. GLASSMAN:
Are you now asking for 14 the witness' understanding on the day of the 15 incident or at some time later on.or today?
16 MR. FISKE:
Let's take it as of the day 17 of the incident.
18 Q
You knew during the course of'the 19 transient, did you not, that high-pressure injection i
20 had come on automatically as a result of a ' -
21 depressurization?
k s
22 A
No, Mr. Fiske, I was aware that 23 high-pressure injection came on, but at the time of 24 the incident I did not know the reason that it came on.
()
25 Q
That was the first time, was it not, f
.--.---+-r
,,,_-..__y_
---,--y7--
.-.sy,,
v..
_,,_--tm, y,,-w.,-.m
--,_r--.
I I
Beers 72 2
that' high-pressure injection had come on automatically 3
1at Unit 27 4
A Well, I don' t recall.
(
5 Q
Do you know of another incident involving 6
automatic actuation of high-pressure injection at 7
Unit 2 before March 29, 19787 8
A Automatic. actuation you said?
9 Q
Yes.
10 A
Exclusive of the test program?
11 Q
For the moment, yes s
12 A
I know of no other automatic initiation O
13 of HPI.
14 Q
Were there events in the test program 15 where HPI was automatically actuated?
16 A
All safety systems are tested per their 17 design criteria as part of the test program.
I feel 18 quite sure that automatic initiation of the emergency 19 system would have been one of them in the-test 20 program.
21 Q
In other words, a situation was created
,k 22 in a test program where pressure dropped below the 23 setpoint in order to determine whether or not HPI 24 would come on, is that correct?
25 MR. GLASSMAN:
Could I have that read
i Beers 73 2
- back.
(Question read.)
3 4
MR. GLASSMAN:
Are you asking the witness whether he had that full understanding 4
5 6
.. as to HPI and the way it was initiated as well?
7 It's a combined question.
8 MR. FISKE:
Yes, well, that's exactly what 9
I am asking him.
10 Q
Was there a test run in which a situation t
11 was created in which pressure dropped below the 12 actuation point to see if HPI would come on G
\\ s/
13 automatically?
~
14 A
I believe that a -- shall we call it a 15 dummy single -- was injected to simulate the low 16 pressure to initiate the emergency safeguard system.
[
17 Q
When was the first time after this 18 transient started that you learned that there had i
19 been a failed open PORV?
20 A
Sometime following the point where power 21 was reapplied to the bus that was lost as part of
,(
22 the incident.
23 Q
And how did you learn that the PORV had
()
24 been open?
~'55
~
A I don't recall whether someone told me,
i l
Beers 74 1 l 2
whether I determined it -- or I determined it myself.
3 I don't recall.
4 Q
Were you in the control room when
(
5 high-pressure injection came on in that event?
6 A
I was in the shift supervisor's office.
7 Q
And did you make any effort to determine 8
at that point what it was that had caused the 9
depressurization?
10 MR. GLASSMAN:
Objection, lack of
(
11 foundation. I don't know that it's been 12 established that he learned at that point 13 about depressurization.
I think there has been 14 testimony about HPI initiation.
15 MR. FISKE:
Let's make it real simple, 16 Mr. Beers.
17 Q
After you learned that HPI had come on f
18 automatically, did you make any effort to find out 19 whether there had been a drop in pressure.below the l
20 HPI setpoint?
21 A
Part of the incident was a loss of k
22 21V bus; The loss of 21V bus caused the loss of a 23 major part of the control room panel instrumentation.
24 The pressure indicators that the licensed operators
)
25 had been using prior to the incident were lost
I 1
Boers 75
~T inc. dent.
We had.no indication i
2 as a result of the 3
following the initiation of the incident what the 4
pressure was in the reactor coolant system.
(
5 Q
Until power was restored?
6 A
I'm sorry, I didn't hear you.
7 Q
I said you had no indication of when 8
pressure was restored?
9 A
That's correct.
10 Q
And when power was restored, did you 11 have any instrumentation that indicated to you what 12 the pressure had been during the time that power was 13 off?
14 A
The control room panel recorders during 15
.the time that power was lost just went down to the 16 lower ends of their band and when power came back it 17 rose up to the pressure that was present in the l
l 18 reactor coolant system at that time.
l 19 Q
Did you learn at some point after power
\\
20 had been restored that the reason the HPI had come 21 on was because there had been a drop in pressure 22 below the actuation point?
23 A
Well, following the restoration of the 24 plant.to a stable condition it is my recollection 25 that we had a critique of the incident and at that i
y
.... ~
1 Beers 76 2
time the supervisor of operations was there.
I seem to 3
recall an electrical / electric engineer was theres 4
and I recollect that it was at that time that we
('
5 reconstructed all the events that happened as a result 6
of the loss of 21V.
7 Q
And how long after the incident was this 8
critique?
9 A
I don't recall the absolute time. It 10 would have been certainly that afterno n.
11 Q
And from what instrumentation did you 12 reconstruct the events that had occurred?
bi
\\/
13 MR. GLASSMAN:
Are you talking about 14 Mr. Beers personally?
15 Q
From what instrumentation did you 16 understand this reconstruction was being developed?
17 A
Well, there are certain parameters 18 available out of the computer and one of'the things 19 that is done following a reactor trip is you ask the l
20 computer for sequence of events review.
21 And when the sequence of events is printed 22 out this may give an indication to yoit what some 23 parameters were doing.
4 24
.Q Was it your understanding that the computer i
J 25'
~~~was able to produce information as to what the
~
1 Beers 77 O
2 Parameters were during the period of. time that the 3
Power was off.
4 THE WITNESS:
Would you read the question
(
5 back to me, please.
6 MR. FISKE:
I will put it again.
7 Q
It is correct, is it not, that the 8
computer was able to produce the parameters as they 9
existed during the period of tine that the power was t
10 off?
t 11 MR. OLASSMAN:
Which parame'.ers are we 12 now talking about?
O~
\\/
13 MR. FISKE:
The parameters that were being 14 discussed by Mr. Floyd and the others.
15 A
Well, there is more than ont channel of
~
16 Pressure indication available.
Some of the pressure I
17 channels that were not available on the console were l
18 available at the computer.
l 19 As a result of the sequence of events 1
20 review, those channels could give you a trend as to 21 what happened to the pressure during the time that the
(
22 21V bus was lost.
23 Q
Are you familiar with something called
(~N 24 the memory trip review?
25 A
Yes, that is similar to the sequence of I
1 Beers 78
(~'t
\\J 2
events review.
There were two different things that 3
were available out of the computer.
4 Q
And it is a fact, isn't it, that the
(
5 memory trip review also was able to provide 6
information as to pressurizer level during the period 7
of time that the power was off?
8 A
I don't recall what all -- what all 9
parameters are in the memory trip review.
10 Q
Was it brought to your attention after 11 the period of time that the PORV failed to open that 12 pressurizer level increased while pressure was 13 decreasing?
14 A
No, it was not brought to my attention.
15 Q
Did you yourself at any time including 16 the time that you became a group supervisor in 17 charge of licensed training review the movement of 18 pressure and pressurizer level, temperature or any 19 of the other parameters of the March 29, -1978 20 transient?
21 A
No, I don't recall any such review.
22 Q
Was high-pressure injection terminated 23 after it had como on automatically in this transiont?
24 MR. GLASSMAN:
Are you asking for the
(
25 witness' understanding?
1 Beers 79 2
MR. FISKE:
Yes, based on what he saw 3
happening around him on the day of the incident.
4 A
I don't recall it being terminated.
(
5 Q
You mean at no time during this transient 6
was.high-pressure injection terminated?
7 MR. GLASSMAN:
Are you asking for this 8
witness' recollection?
He told you where he was located during the incident.
9 10 MR. FISKE:
Let me put it this way, 11 Mr. Beers.
12 Q
You were in charge, weren't you, on that 13 day, the shift supervisor when this happened?
14 A
I was the senior representative in the 15 control room at the time of the incident, yes.
16 Q
And the ECCS cystem came on automatically 17 as we already established after this transient 18 started, is that right?
19 A
That's right.
20 Q
And that's the first time that had 21 happened with Unit 2; isn't that correct?
22 A
Yes.
23 Q
Now, the decision whether or not to 24 manually terminate a safety system that has come on
()
25 automatically is an important decision, is it not?
~~~
,,,r- -, -
.-----p,
.w_-p
1 Beers 80 O(
~ A The shift supervisor faces a lot of 2
3 important decisions during the course of his day, 4
From a priority standpoint I wouldn't know where to
(
5 put that priority.
6
-- Q Well, wherever you put it in terms of 7
priority, what is your testimony as to whether or not 8
high-pressure injection was manually terminated in 9
the course of that transient after it had come on 10 automatically?
g 11 A
lt's my recollection that following 12 restoration of power to 21V the shift foreman, the O.
k/
13 operators and myself looked at precsurizer level, 14 looked at nakeup tank level and controlled those two 15 parameters in accordance with established procedures, 16 Q
Where was pressure at the time you 17 terminated the HPI on that occasion?
18 A
Mr. Fiske, I didn't say that I terminated 19 HPI.
20 Q
I'm sorry.
You say you controlled it?
21 A
Yes, sir.
22 Q
Do I assume from that that you mean the 23 flow was reduced?
()
24
.A If the pressurizer level was rising 25 towards the upper limits, the valves would have been
1 Beers 81 3(G 2
throttled to reduce the flow and control the 3
pressurizer level.
4 Q
Well, I am not asking you, Mr. Beers,
(
5 for some hypothetical situation.
I am asking you 6
what your recollection is of what the parameters 7
actually were at the time HPI flow was reduced on 8
that day.
9 A
The only parameter that sticks in my 10 mind very vividly as of that day was I recall very 11 vividly when power came back we only had 18 inches 12 in the makeup tank.
13 Q
And what is the significance of that in 14 terms of controlling high-pressure injection or what 15
.was the significance of that?
16 A
Well, the nakeup tank supplies under 17 normal conditions when HPI is not running, the makeup 18 tank supplies -- let me rephrase that.
19 The makeup tank is the source-of water 20 for the makeup pumps.
21 Q
But my question was what significance 22 did an 18-inch level in the makeup tank have in teras 23 of controlling high-pressure injection flow during
()
24 that transient?
25 A
Well, the loss-of-reactor coolant,
I I
1 Beers 82 b(K 2
reactor coolant procedure to the best of my 3
recollection, if you have an automatic initiation of 4
the safety system one of the actions that the
(
5 operators are supposed to do is to close the outlet 6
valve from the makeup tank.
7 You must remember, Mr. Fiske, that one 8
of the indications that we lost was the makeup tank 9
level so until we restored power we weren't really 10 aware of what the level was in that tank.
t 11 So the point I am trying to make is that 12 the tank was so low and I wanted the operator to close
(~h
's I 13 that valve as quickly as possible.
14 Q
The procedure requires that the valve be 15 closed as soon as high-pressure injection comes on 16 automatically?
17 A
That's my recollection.
18 Q
And did the loss of power prevent that 19 valve from being closed at that time?
20 A
I don't recall.
21 Q
But, was the valve closed in' accordance 22 with the procedure right after HPI came on?
23 A
I don't recall that either.
24 Q
I still don't think I understand what
()
25
~~ was the significance of the fact that level in the
1 Beers 83
[^)
~'
2 makeup tank was 18 inches after power came back in relation to controlling HPI flow.
3 4
Did that mean you should leave the HPI
(
5 on at flow, did it mean you should turn it off, what 6
did it mean?
7 MR. GLASSMAN:
Are you asking for an 8
interpretation now?
g MR. FISKE:
No, I am asking him for his 10 understanding of what he did on the day of that 11 incident.
12 A
Well, the way the piping is out there,
(~N s/
13 Mr. Fiske, if you have an automatic initiation of the 14 HPI system, you don't want two sources of water coming 15 into the makeup pumps simultaneously.
You want the 16 source of water to be from the BWST as opposed to 17 from the makeup tank.
18 Q
And in closing the outlet valve from the 19 makeup tank is supposed to accomplish that, is that 20 right?
21 A
That's correct.
k.
22 Q
Did the 18-inch level in the makeup 23 tank indicate to you that the outlet valve had not
()
24 been closed?
25 A
No, it was more of an indication to me l
i
l Beers 84 2
that-we had lost inventory in the reactor coolant 3
system, or that we had had a significant amount of 4
shrinkage somehow in the reactor coolant system.
(
5 Q
And I take it that at that particular 6
moment in time you didn't know which of those two 7
events had occurred, is that correct?
8 A
That's correct because of oy lack of g
instrumentation available.
10 Q
Prior to the time that HPI flow was t
i 11 reduced had you reached a determination as to which 12 of those two events had occurred?
13 MR. GLASSMAN:
Objection, lack of 14 foundation.
15 MR. FISKE:
I will stick with the
~
16 question.
i 17 A
No, I hadn't made a determination at that 18 time.
19 Q
Before you took action to reduce the flow i
20 of high-pressure infection, did you look to see what i
21 the pressure and pressurizer level were?
l C.
22 A
I don't recall.
l l
23 MR. FISKE:
Let me show you a document I
which we will mark as Exhibit 891.
V[
i 24 25 (copy of document entitled, I
~,
1 Seers 85
,/ ~ N..
t V
- " Superintendent's Event Reports" dated 3/29/78, 2
was marked B&W Exhibit 891 for identification.)
3 4
Q Do you have Exhibit 891 in front of you,
(
5 Mr. Beers?
6 A
Yes, I do.
copy of a " superintendent's 7
Q Is this a 8
Event Report," for the March 29, 1978 transient?
9 A
Yes, I believe this is the preliminary 10
" Superintendent's Event Report."
11 Q
Is that your signature on page 37 12 A
Yes, it is.
O 13 Q
Can you tell us what tho e attachments 14 to this report are?
15 A
The first attachment is a plot of
^
16 react'or coolant pressure; the second is $ rom the' 17 computer, sequence of events review. I think that's 18 what all the rest is, a sequence of events review.
19 Q
Who prepared this graph that reflects 20 the movement of pressure?
21 A
To the best of my recollection, it was L-22 Mr. Floyd.
23 Q
Do you recognize Mr. Floyd's handwriting?
24 A
I believe it's Mr. Floyd's handwriting.
().
~' ~
~~~
Q Is this your handwriting, Mr. Beers, on 25
86 3eers 1
O.
2 the'first page of this document?
3 A
Yes, that's my handwriting on the first 4
page.
(
5 Q
And in fact is all of the handwriting 6
on this, on the first three pages of this document 7
yours other than Mr. Floyd's signature?
8 A
That's correct.
9 Q
Let me show you a document which has been 10 marked as Exhibit 170 which I ask if y9u recognize 11 that as the special report filed by Met Ed with the 12 NRC concerning this transient and the LER?
O k/
13 Do you recognize Exhibit 170 as the 14 special report concerning the TMI 2 ECCS actuation 15 on March 29, 1978, and the LER for the same event?
16 MR. GLASSMAN:
What do you mean by 17
" recognize" it?
Did he just look at it and 18 read it or does he recall having seen this 19 before?
20 MR. FISKE:
The latter.
21 A
Let me review the entire document.
-L 22 Q
Fine, there are actually two documents 23 and to put it in Mr. Glassman's words did you see I\\
24 either one of these documents at any time.before the O
25 Three Mile Island accident?
1 Beers 37 (v
- A I recall the LER as with,all LER's they 2
3 were routed to the shift supervisor for review with 4
their crew.
I don't recall the first document, the
(
5 document that actually went to Mr. Grier.
6 Q
Did you understand that a special report 7
had to be filed with the NRC every time there was 8
an automatic actuation of the ECCS system?
9 A
I don' t recall my understanding at.the 10 time.
We were extremely familiar with,the tech specs 11 and I just don't recall whether that's a tech spec 12 requirement or not.
O 13 MR. FISKE:
Let me show you a" document 14 which we will mark'as B&W Exhibit 892.
15 (copy of multipage handwritten document 16 entitled, " Synopsis of Event," was marked B&W l
17 Exhibit 892 for identification.)
1 18 Q
The first two pages of this document which f
i 19 are in handwriting are captioned " Synopsis of Event."
20 Do you see that?
l 21 A
Yes, sir.
I 22 Q
Do you recognize the handwriting those 23 two pages are in?
l ()
24 A
No, I don't.
l l
25 Q
Look at the third page, it says " Sequence i
T 1
seers 88 O
2 of Events," do you recognize the handwriting in that 4.
section of this document?
3 s
s 4
A' I" think that's thtesamehandwriting.
I
(
5 don' t reco'gnize that.
'\\
3s s
6 Q
- (Do you recognize the handwriting. on the N'
7 next three orifour pagec?
' ' il 8
A No, I?m sdrry,}
r.
Fiske, I don',t
\\
recognize that ha$dvriting.
9 10 Q
Look at the pa'fe'that is, marked, t
i 11 "APPondices," whicN is near the end.-
Do you recogniAe'the handwriting on that 12 D
U 13 page?
14 A
No, I don't.
15 Q
Turningtkopa'gesahead, which appears to 16 be the --
i 17 A
You nean towards the front?
~
s
-s 18'
'Q
.No, I tr e an further toward the back,
'l 19 which apears t'o be a' printout from the computer, do 20 you see the handwriting lon the right-hand side, it
~
5 J
)
21:
says, "14:37 something ortother.g
^
~
t
)
2if A
Yes, I see th a t.
+
, ll
[.
23 Q
Do y'ou recognize that writing?
s t
21 A
Not positively.
(
e t
if
~
Q Can you give us an educated gdess, 3.
e s
i I
f, t___
1 Beers 89 I
O G
2 without holding you to it?
3 A
I'm sorry, Mr. Fiske, I am not a 4
handwriting expert. I don't know.
(
5 Q
And how about the last three pages of 6
this document, do you recognize any of that 7
handwriting?
8 A
I can't positively say, I don't know.
9 Q
Did you see any of the pages of that 10 document, Exhibit 892 anytime before the Three Mile t
11 Island accident?
12 A
I recall some of these attachments back (O
'/
13 here.
Whatever it is, the memory review or the 14 sequence of events review or whatever it is, I recall 15 that but I don't recall this front portion.
This 16 looks to be a preliminary report or something like 17 that.
18 Q
Well, looking at the computer printouts 19 that constitute the last six pages of this exhibit, 20 is it your best recollection that you did see those l
(
l 21 P ag e s ?
k.
l 22 MR. GLASSMAN:
Just so the question is l
l~
23 clear, are you referring to the computer l
24 printouts per se, or the computer printouts J
25 with the handwriting as it appears on these
1 Beers 90 O) j 2
.pages?
1 3
Q Is it your best recollection that you did 4
see the six -- the computer printouts which are the
(
5 last six pages of this exhibit with or without the 6
handwriting?
7 A
Well, I recall seeing these printouts the 8
day o f the incident.
That was part of the critique.
9 We asked the computer for these printouts and we were 10 trying to evaluate in the critique exactly what 11 happened, but at that time I don't recall any 12 annotation on the printouts.
N/
13 Q
Who was involved in this critique as you 14 described it, apart from yourself and Mr. Floyd and 15
.some electrical / electronics engineer that you 16 mentioned before?
17 A
And the shift foreman that was in charge 18 that day; and the operators that were on duty; and 19 the operator that was performing the surveillance 20 that initiated the whole event.
21 Q
Who was the shift foreman that was on 22 duty that day?
23 A
Richard Hutchinson.
[)
24 Q
Is he still at Met Ed7 v
25 A
No, sir, he is not.
1 Beers 91 F'%
r(j 2
- Q Where is he?
3 A
I don't really know. I believe he is in 4
(
5 Q
Who were the operators who were on duty 6
that day?
7 A
The operator at the Penelec to the best 8
of my recollection was Dennis Olsen.
This was not 9
my normal crew that day and I just can't recall who 10 else was involved.
11 Q
Who was the surveillance operator?
12 A
I don't recall who that was.
13 Q
Were any of the shift test engineers 14 involved in this critique?
15 A
Yes, I believe one of the shift test 16 engineers was involved in the critique.
I recall 17 hhn being in the control room at the time of the 18 incident.
19 Q
Was that Mr. Dominguez?
20 A
No, I don't recall his being there.
21 Q
Mr. McMullin?
22 A
Noi sir.
23 Q
Mr. Ulrich?
()
24 A
No, sir.
25 Q
Was there more than one shift test
-~
~~~
l L
m
- ~.,... -.
1 Beers 92
/~N iJ
~
2 engineer on duty during that transient?
3 A
I just don't recall.
4 Q
Do you remember now what the name of the
(
5 shift test engineer that did participate in this 6
critique was?
7 A
I recall the name of the shift test 8
engineer that provided some assistance to me during 9
the incident.
10 Q
Who was that?
11 A
A shift test engineer by the name of 12 Steve Poje.
O 13 Q
How do you spell that?
14 A
I am not sure. P-o=j-e, I believe.
15 Q
And was he the one that was present during 16 the critique?
17 A
Yes.
18 Q
Do you have any positive recollection l
19 that Mr. Ulrich was not at the critique?, -
i 20 A
I don' t recall one way or the other.
l 21 Q
Now, after this incident occurred, 22 Mr. Beers, did the training department or anyone else 23 at Met Ed to your knowledge give consideration to 24 what potential problems could result for the plant
()
25 in the event of a failed open FORV7
1 Seers 93
'~#'
2
- A Are you asking me, Mr. Fiske, what my 3
reaction is as of that time or are you asking me 4
what I have been refreshed since I read some of these
(
5 documents?
6
-Q No, my question is as you sit hero today 7
thinking back to the time period between March 29, 8
1978 and March 28, 1979, was consideration given at 9
Met Ed to evaluating what the probleme could be for 10 the plant in the event that a pilot operated relief 11 valve stuck open or failed open and was not properly 1
12 diagnosed?
\\--
13 A
Well, I recall that shortly after this 14 incident a light was installed on the center console 15
.to give indication of the condition of the pilot 16 operated relief valve.
Prior to that time there'was 17 no console indication as to the condition of the 18 pilot operated relief valve.
4 19 Q
Why did you understand it was-important i
20 to diagnose an open pilot operated relief valve?
21 MR. GLASSMAN:
What time frame are we l
22 now talking about?
23 MR. FISKE:
About a year between March 28 24 and March 29.
25 A
If the pilot operated relief valve was
1 Beers 94 0
2 open-for any reason, you have lost integrity of the 3
4 Q
What do you mean by losing integrity?
(
5 A
It's not a closed system.
6 Q
Anu what were tne adverse consequences 7
of losing the integrity of the RCS?
8 A
You have a loss of inventory in the 9
reactor coolant system, from the reactor coolant 10 system.
11 Q
You understood, did you not, during this 12 time period that an open pilot operated relief valve N/
13 could produce a loss-of-coolant accident?
14 A
I don't recall what my understanding of 15 an open pilot operated relief valve was in that time 16 frame.
17 Q
Did you make any effort in the post 18 accident analysis of this event to determine how 19 much inventory had been lost as a result of the open 20 pilot operated relief valve?
21 A
I don't recall that I did.
22 Q
Did anybody at Met Ed to your knowledge?
23 A
I don't recall.
~
24 Q
Did anybody make an effort at Met Ed to
(
25 '
~~ determine whether during the. period of time that the
~
I l
1 1.
Boers 95 O
2 pilo't operated relief valve was open. water as 3
opposed to steam had escaped through the open valve?
4 A
I don't know, Mr. Fiske, whether that
(
5 consideration was given or not.
6 Q
At anytime between March 29, 1978 and the 7
day of the accident including the period of time that 8
you were group supervisor in charge of the licensed 9
training, did you or anyone else at Met Ed make any 10 effort to determine what the movement had been of i
11 pressurizer level during the course of this transient?
12 A
No.
O N/
13 Q
Did you think that it was important 14 during the period of time that you were group 15 supervisor in charge of licensed training to have an 16 analysis made of what the system response was in the 17 case of a stuck open or failed open pilot operated 18 relief valve?
19 MR. GLASSMAN:
Just so the record is 20 clear, you are now talking about stuck open 21 pilo-operated relief valves generally or are 22 you taAking about the particular event f
23 involving a loss of power?
24 MR. FISKE:
No, I am not talking, 25 Mr. Beers, about what it was that had caused i
l
1 Beers 96 (G_)
2 the pilot operated relief valve to fail open 3
in this particular case.
That's not my 4
question. I think maybe you understood that.
(
5 Q
My question is at anytime after the 6
incident including the period of time that you were 7
group supervisor in charge of licensed training, did 8
you think it was important that an analysis be made 9
to determine what the system response would look like 10 in the case of an open pilot operated relief valve?
11 A
No, I don't recall thinking about it in 12 that sense.
13 Q
Did you ever hear anyone at Met Ed in the 14 training department or anywhere.alse.say_that they 15
. thought that that would be something that was 16 desirable?
17 A
No.
I 18 Q
Did you ever hear anyone at Met Ed say 19 after this transient that it would be desirable to 20 ask B&W to make an analysis of what the system 21 response would look like in the event of an open
.k 22 PORV?
23 A
I don't recall.
We did have training on 24 various casualties at the simulator. I cannot recall
)
25 whether this was one of the casualties that was l
1 Beers 97 13 kJ 2
imposed on us or not.
3 Q
Well, after the liarch 29, 1978 transient 4
'was there any discussion that you participated in or
(
5 were aware of at Met Ed to the effect that B&W should 6
be asked to simulate an open pilot operated relief 7
valve on the simulator?
8 Let me withdraw that and put it, hopefully, 9
in a little clearer way.
10 Did you ever ask B&W to simulate an open 11 pilot operated relief valve on the_ simulator?
12 A
Not that I recall.
13 Q
Are you aware of anyone else at Met Ed 14 asking B&W after this 1978 incident to simulate an 15 open pilot operated relief valve on the simulator?
16 A
I am not aware of any request for that.
l l
17 I don't believe that that could be simulated at the l
18 simulator.
19 Q
Is that an understanding that-you had l
20 before the Three Mile Island accident?
21 A
I am trying to recall the list of
(.
22 casualties that could be imposed on us down there, 1
I 23 and I can't separate out whether I had that 24 understanding prior to the accident or after.
~
()
~ ~ " ~
Q Putting it very simply,,Mr. Beers, at 25 l
i I
1 Beers 98
/
G 2
anytime before the Three Mile Island. accident, did 3
you conclude that it was important to have an open 4
pilot operated relief. valve simulated on the
(
5 simulator and express that view to someone else and 6
then be told that the simulator could not simulate 7
an open pilot operated relief valve?
8 MR.-GLASSMAN:
That's not such a simple 9
question.
There are a number of steps in it, 10 but if the witness understands it he can say 11 whether or not he understands it.
12 THE WITNESS:
I would like you to reread s
A/
13 the whole question to me.
14 Q
There are three parts.
15 At anytime before the accident, did you 16 conclude that it was desirable to have an open pilot 17 operated relief valve simulated on the simulator and 18 express that view to someone else, and then be told j
l l
19 that the simulator was not capable of simulating an
{
20 open pilot operated relief valve?
21 A
No, I don't recall expressing to anyone L
22 the importance of having that simulated on the i
i1.
23 simulator.
j
/
24
.Q Before March 29, 1978 had you been aware O
25 of any other situations at Unit 1 or Unit 2 where l
1 Beers 99 2
the pilot operated relief valve had stayed open 3
longer than it was supposed to?
4 MR. GLASSMAN:
Objection to the form of
(
5 the question.
No foundation for the issue of 6
longer than supposed to.
7 MR. FISKE:
I will stay with the 8
question.
You.can answer it, Mr. Beers.
9 A
Well, you asked me a similar question 10 this morning, Mr. Fiske, and what I re ollect in that 11
- area, during the first cycle of Unit 1 operation the 12 rupture disk on the reactor coolant drain tank was A'
13 blown.
14 As to the cause of that rupture, I can't 15
. exactly recall whether it was as a result of electromatic or a problem with the code v'alves.
16 17 Q
How about Unit 2, were you aware prior 18 to March '78 of any situation at Unit 2 where the 19 pilot operated relief valve had stayed open longer 20 than it was supposed to?
21 MR. GLASSMAN:
I have the same objection.
22 THE WITNESS:
What was the date again, 23 Mr. Fiske?
24 MR. FISKE:
March 29, 1978.
l ()
25 A
No, I was not aware of any rupture disk i
1
,.-n--
1 Beers 100
)
~
2 at that time.
3 Q
I am not asking about the rupture disk, 4
although they may be the same thing.
I am asking about
(
5 the pilot operated relief valve.
6 A
Oh, I'm sorry.
7 Q
And the question is simply before 8
March 29, 1978 were you aware of any incident at 9
Unit 2 where the pilot operated relief valve had 10 stayed open longer than it was supposed to?
(
11 A
No.
12 Q
At anytime up to the Three Mile Island
().
\\_/
13 accident including the time that you became group 14 supervisor in charge of licensing in the training 15 department, did youmake an effort to determine 16 whether there had been other incidents at Unit 1 or 17 Unit 2 where the pilot operated relief valve had 18 stayed open longer than it was supposed to?
[
19 MR. GLASSMAN:
I have the same objection 20 as to other incidents where the pilot operated 21 relief valve may have stayed open longer than it 22 was supposed to.
We have not established in any 23 manner what the pilot operated relief valve 24
.was supposed to or not supposed to do.
And we
(
'[~
have had testimony with a particular event
~ ~ ~ ~
2
1 Beers 101
~
2
- dealing with a loss of power..
3 MR. FISKE:
We have heard that objection 4
before, and we are taking our chances with it,
(
5 so if you still remember the question, 6
Mr. Beers, you are free to answer.
I can 7
repeat it if you would like to hear it again.
8 You have three choices You can answer 9
it, you can have the court reporter reread it 10 or I can repeat it.
11 THE WITNESS:
I would like you to repeat 12 it, Mr. Fiske.
13 Q
The question is at anytime after the 14 March '78 incident up to the time of the accident 15 including the time that you'were group supervisor 16 in charge of license training, did you make an effort 17 to go back and find out whether there had been other 18 situations at either Unit 1 or Unit 2 in which the 19 pilot operated relief valve had stayed open longer 20 than it was supposed to?
21 A
No, I did not make any investigation.
If 22 you refer to the " Superintendent's Event Report," you 23 will see that I made some recommendations in that 24 report to preclude deenergizing or opening the PORV
(
25 as a result of this same surveillance procedure.
1 Beers 102 OV 2
- Q In other words, you made.a recommendation 3
that some sort of reviring be done so that in the 4
event of another failure of this particular bus the
(
5 PORV would not open, right?
6 A.
Yes, I made a recommendation in changing 7
the way the surveillance procedure was done.
8 Q
I think that's useful information, but my 9
question is broader than that.
10 Did you make any effort to,go back and 11 find out whether the pilot operated relief valve had 12 stayed open longer than it was supposed to for
\\#.
reasons other than the failure of this particular 13 14 bus?
15 MR. GLASSMAN: It's already been asked and 16 answered.
17 Q
Well, is the answer no?
18 MR. GLASSMAN: I thought he told you what 19 he did.
20 A
Well, Mr. Fiske, it gets back to the same 21 basic question as I don' t know what longer than 22
" supposed to" is.
It depends on the incident that 23 actuated the pilot operated relief valve.
(
24
-Q Are you telling us, Mr. Beers, that 25 during this period of time that you were a shift
i Beers 103 t'
t 2
supervisor on both units and in charge of licensed 3
training for the training department, you didn't know 4
how long the pilot operated relief valve was supposed
(
5 to stay open after it opened?
6 A
I think the length of time could vary 7
depending on power level, decay heat, power history, g
initiating events, things of that nature.
9 Q
There was a particular event which.was 10 supposed to result in the closing of the PORV once it it had opened, isn't that correct? -
12 A
When the pressure got to a certain value 13 the PORV was to close.
14 Q
And what was that value?
About.22057 15 2105'?
16 A
Somewhere above the normal operating 17 pressure.
18 Q
And it's correct, is it not, 'that on the 19 day of the March '78 transient, the PORV had stayed 20 open even after pressure had dropped below that 21 setpoint?
22 A
But, Mr. Fiske 23 Q
Isn't that correct?
21 A
The reason that it stayed open was because
~[
~ it was a power problem there..
2
1 Beers 104 O
O
- Q I am not disputing that,-Mr. Beers, I 2
3 am just trying to establish for Mr. Glassman's 4
satisfaction, if no one else's,what is meant by the
(
5 phrase " staying open longer than it was supposed to,"
6 and it is correct, is it not, that the PORV is 7
supposed to close when pressure reaches a certain 8
setpoint?
9 A
If the PORV is operating as designed to 4
10 the best of my recollection it is to open at 2255 11 psig and to reclose at 2205 psig. -
12 Q
And in the March 29, 1978 incident the O
13 POF/ remained open even after pressure had fallen 14 below 2205, isn't that correct?
15 A
Yes.
16 Q
Did you make any investigation at any 17 time up to the Three Mile Island accident to 18 determine whether at any time other than'on March 29, 19 1978 the pilot operated relief valve at elther Unit i 20 or Unit 2 had failed to close after pressure had 21 dropped below the setpoint?
22 MR. GLASSMAN:
You are talking about 23 whether that was the cause and effect or are
[>
24 you talking about whether power had been
~-
25 turned off at some other event. It's just
1 Beers 105 2
- unclear.
1 3
Q I think I would hope, Mr. Beers, you would 4
understand the question.
It is simply whether did
(
5 you make an investigation to determine whether there 6
had been any other situation for any reason in the 7
world where the pilot operated relief valve had 8
opened and then stayed open even after pressure had 9
dropped below its closing setpoint?
10 A
I did not conduct any investigation into 11 that, it was clear to me as evidenced by my 12
" Superintendent's Event Report" I felt quite positive C%
k-sI-13 in knowing the reason that the PORV was open for 14 such a long period of time.
15 Q
And you are referring now to the March 7 16 incident?
17 A
Yes, sir.
18 Q
And did it ever occur to you while you in charge of training for licensed personnel 19 were 20 that it would be important to know whether pilot 21 operated relief valves might stay open for reasons k
I 22 other than the particular reason which had caused 23 the March '78 problem?
24
.A I had no indication of a history of
)
25 malfunctions of the pilot operated relief valves.
i
1 Beers 106 D
(J
- Q No one had told you that.in August of 2
3 1977 a pilot operated relief valve had stuck open 4
at Unit 2 because of mechanical problems?
l(
5 A
I don't recall that incident?
6 Q
Did anyone tell you at any time prior to 7
the Three Mile Island accident that the pilot operated 8
relief valve had failed open or stuck open at Toledo 9
Edison's Davis-Besse plant?
10 A
No, no one told me that.
t 11 Q
Did anybody tell you at anytime prior to 12 the accident that a pilot operated relief valve had
~/
13 stuck open at other plants because of corrosion?
14 A
I just told you, Mr. Fiske, that I don't 15 recall a history of malfunctions of the pilot operated 16 relief valves.
17 Q
Is it your testimony, Mr. Beers, that 18 up to the time of the Three Mile Island accident.you 19 were not aware of any pilot operated relief valve 20 sticking open or failing open on any plant anywhere 21 in the country including Unit 1 and Unit 2 other than 22 the March 29, 1978 incident?
23 A
I am telling you that today I don't 24 recall that.
25'
~~
Q Just so that I understand your answer,
1 Beers 107 2
is it your testimony that today you don't recall 3
knowing of any such incident before the Three Mile 4
Island accident?
([
5 A
Yes.
6 Q
As group supervisor in charge of licensed 7
training in the training department is that the kind
~
8 of information that you would have expected people in 9
the Met Ed organization to bring to your attention?
10 MR. GLASSMAN:
Are you asking the 11 witness to now speculate about what he might have 12 expected at sometime or are you asking him if n
x-13 he ever thought about that?
14 MR. FISKE:
I am asking him what was 15 important to him to try to do his job as 16 group supervisor in charge of licensed training.
17 MR. GLASSMAN: I think that the question 18 as posed was confusing.
I f you are asking him 19 whether that was something that he considered 20 in those terms, I guess he can answer it but it 21
'.s unclear the way it is phrased.
22 MR. FISKE:
Why don't we let Mr. Beers 23 answer it.
24 A
During the period of time that I was
(
l 25 shift supervisor and group supervisor of licensed v--
e e
w=W g W vs
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-+
re-f,yy-te,*-e--'i y
u, 7w ma w-
-- ew
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--r-
1 Beers 108 2
training, our management people went.to user group 3
meetings, B&W user group meetings and copies of notes 4
from those user group meetings were routed to the
(
5 shift supervisors and were used in training for 6
incorporation into training lesson plans.
7 To answer your question specifically, it 8
is difficult for me to make an evaluation of the 9
importance of an open PORV inasmuch as I can only 10 recall the one specific incident.
11 (Recess taken.)
12 Q
At the time you became group supervisor n
13 of licensed training in July of 1978, Mr. Zechman did 14 not have a license on either Unit 1 or Unit 2, did he?
15 A
That's correct.
16 Q
And were you aware at the time you 17 became group supervisor that Mr. Zechman was spending 18 part of his time studying and being trained in order 19 to try to obtain a license?
20 A
I don't recall one way or the other 21 whether I was aware of that or not.
,L 22 Q
At any point before the Three Mile' Island 23 accident, did it come to your attention that I) 24 Mr. Zechman was spending some of his time studying LJ 25 being trained in order to try to obtain a license?
1 Beers 109 l
(~h
%.)
- A well, certainly shortly after I became 2
3 group supervisor of training Mr. Zechman, 4
Mr. McCormick and myself sat down in a meeting
(
5 together as we often did, and Mr. Zechman discussed 6
with me that he wanted to go into a full-time status 7
and pursue getting a license on Unit 1.
8 Q
And there came a time, did there not, 9
when Mr. Zechman did go on such a full-time status 10 studying and training to try to get a license?
11 A
Yes, that's correct.
12 Q
And that was in or about September of f'#
13 19787 14 A
I don't recall the exact date. It was 15 shortly after I became group supervisor of training.
16 Q
And at or about the time that he started 17 devoting full time to his own personal training, he l
18 was given the position of supervisor, was he not, 19 of training of Met Ed?
20 A
I don't recall whether those two i
21 coincided or not.
22 Q
Well, if I told you that Mr. Zechman L
23 had testified that he did', would that refresh your l ()
24 recollection?
~_
25 A
No, sir.
l
_ ~.
1 Beers 110
' O
~
~
2 Q.
At or about the time that Mr. Zechman 3
started devoting his full time to his own personal 4
training, did anyone in the Met Ed training
(
5 organization have any discussions with you about you 6
assuming some of the responsibilities that Mr. Zechman 7
had had before?
8 A
Mr. Zechman did.
9 Q
And did he tell you in substance that he 10 expected you to do his job while he was spending full 11 time studying?
12 A
Well, as I said just a few minutes ago f~%
(sI 13 when Mr. Zechman, Mr. McCormick and myself sat down 14 together when he initially apprised us of the fact 15 that he was going into full-time license training, 16 it was understood that Mr. Zechman's supervisory 17 duties would be distributed between Mr. McCormick 18 and myself.
19 Q
So you had that part of Mr. Zechman's 20 supervisory duties which related to licensed training?
I 21 A
I am not sure whether you can
,k 22 categorize it that closely or not.
23 Q
But in substance is that the way it
' ()
24 worked out?
25 A
Yes.
s.
.,-e,,
,.-n-.-.,.
,.,..n..
- -, ~.,,.
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1 Beers 111
/~T
(,)
~
2
- Q Now, you understood that.part of the 3
responsibility of the training department was to 4
conduct training on the emergency procedures?
(
5 A
certainly.
6
..... Q one of the. emergency procedures was the 7
pressurizer system failure procedure, was it not?
8 A
There was.an emergency procedure by that 9
name.
10 Q
At anytime betwcen the time you came in 11 to the training department and the -Three Mile Island 12 accident was any training given to any of the i
O k/
13 operators on Unit 2 on the pressurizer system failure 14 procedure?
15 A
I don't recall.
16 MR. GLASSMAN:
Mr. Fiske, just so th'e 17 questions are clear. I notice you are about to 18 show the witness a number of.he procedures.
19 It would be helpful if you could make clear 20 whether you are asking about whether Mr. Beers 21 personally did the training or whether it had 22 occurred somewhere else or what it was.
It 23 might not be too clear.
1 f~d) 24 Q
I am showing you, Mr. Beers, a document 25 that has been marked B&W Exhibit 305, which is the
1 Beers 342 O
v 2
pressurizer system f ailure proceduro.for Unit 2s I
3 take it you were f amiliar with this procedure before 4
you became part of the training department?
(
5 A
well, I see, Mr. Fiske, that this is 6
Revision 3 to the proceduro when I was shift 7
supervisor on Unit 2.
It may not have been this 8
revision of the procedure, but I am familiar with 9
the pressurizer system failure procedure for Unit 2 10 Q
And directing your attention to Section B 11 which appears on page 2, that is Revision 1 as of 12 June 22, 1977, isn't that correct?
-/
13 A
For that page, yes.
14 Q
At the top of this page it says, "Section 15 B Inoperative Pilot Operated Relief Valve."
16 Do you see that?
17 A
Yes, sir.
1
~
of 18 Q
Did you understand that the purpose j
i 19 this procedure was to enable the operators to diagnose 20 the existence of a pilot operated relief valve that 21 was staying open longer than it was supposed to?
22 A
The title of the procedure is " Inoperative 23 Pilot Operated Relief Valve "
When I read that title
()
24 it seems to me that that could either be staying 25 open or failing to open.
L Beers 113
(^)
\\#
2
- Q I think my question is:.Didn't you 3
understand that one of the purposes of this procedure 4
was to enable the operators to be able to diagnose a
([
5 pilot operated relief valve that was staying open 6
longer than it was supposed to?
7 A
Yes, that's one of the purposes of this 8
procedure.
9 Q
And you understood, didn't you, that it 10 was important that the operators be able to tell the t
11 difference between a pilot operated relief valve that 12 had opened and closed the way it was to in f)\\
(_
13 accordance with the setpoints and a pilot operated 14 relief valve that had opened but had failed to close 15 when it was supposed to?
16 A
Yes, I believe I understood that.
17 Q
And looking at this procedure, Mr. Beers, 18 can you tell me what in this procedure enables the 19 operators to tell the difference between a pilot 20 operated relief valve that is stuck open-and a pilot 21 operated relief valve that opened and closed when it L
22 was supposed to?
23 Putting it another way, Mr. Beers, how 24 did you understand before the Three Mile Island 25 accident the operators using this procedure were
1 Beers 114 2
supposed to tell the difference between a pilot operated relief valve that was stuck open and a pilot 3
4 operated relief valve that had opened and closed the
(
5 w ay _t was supposed to?
6 A
I think the operator would have to 7
evaluate all of these symptoms and you couldn't just 8
focus on one particular symptom and say "Ah, ha that 9
tells me that the pilot operated relief valve has 10 failed to close."
11 This is the way the operators were 12 trained in all procedures, all the emergency G
13 procedures.
14 Q
Look at all of the symptoms or automatic 15
. actions or whatever that you want to in this
~
16 procedure and after you have reviewed them all with 17 your recollection refreshed, tell me how you 18 understood as a shift supervisor that the operators 19 were supposed to tell the difference between a stuck 20 open pilot operated relief valve and a normal 21 opening and closing of a PORV?
22 Let me put it another way, Mr. Beers, 23 just so we can move along:
Under " Symptoms," do you 24 see paragraph 3 which says RC-R2 discharge line 25 temperature is abouve 2000F alarm"?
J
I 4
i Beers 115 b)
~
2
- A Yes.
3 Q
You understood, did you not, that that was l
4 a symptom of a PORV that had failed to close?
(
5 A
That is a symptom that the PORV had failed 6
to close, but there are other situations that could
'7 give you that same symptom.
8 Q
What were the other possibilities?
9 A
If you had a code safety leaking it's 10 conceivable that you would also have that alarm.
11 Q
Did you ever receive any guidance.from 12 anyone at Met Ed as to how using the discharge line 13 temperatures you could determine whether the PORV was 14 opened as opposed to code safeties?
15 A
I don't recall any specific training in 16 that area.
17 Q
Did you have any understanding as to any 18 other event that could cause a discharge-line 19 temperature for the PORV above the 200 degree l
20 Fahrenheit alarm?
l I
21' A
It's certainly conceivable that you could 22 have an instrument malfunction.
1 23 Q
Anything else?
24 A
I can't think' of anything.
(
5'
~~~
Q The next symptom is "The reactor coolant
i
,*p
'J
l
\\
. Beers 116 f
f ' I, l
i
~
2 drain tank pressure aand temperature are above normal
- i 3
on the control..roon radwaste alisposal control panel l
4 8A."
(
5 Do yov,see that?
,{8 r.
1 A
'Yesi sir.
t 7
Q
) And you understood that d' rain tank 8
tes.p e ratu re and press.ure above ncrmal were symptoms of a PORV that had' failed to close?
9 10 A
onec again tha0 is a symptom, but this 11 could also be a symptom of*a' code valve leaking.
i 12 MR. GLASSMAN: I would like to have a b
~
for just a
'd 13 little conference with the witness 14 moment.
15 MR. FISKE:
Mr. Glassman, I don't see any 16 reason to have a conference with Mr. Beers right 17 in the middle of a question.
I think the record 18 should indicate that this conference consists 19 of Mr. Glassman whispering to Mr. Beers while 20 we are sitting here.
(Witness confers with counsel.)
21 MR. FISKE:
I think the record should 22 23 indicate that almost a minute has gone by 24 during which Mr. Glassman is talking to Mr.
25 seers and I really object to that, Mr. Glassman.
l l
i I
i
.)
--..- ~, - - - ~ -, - -
t Beers 117 2
I see absolutely no reason for you to interrupt my questioning and have a monologue 3
4 with Mr. Beers while I am right in the middle of a line of questioning.
I don't think there is
(
5 6
any purpose for that other than you telling 7
Mr. Beers what you expect him to say in response 8
to questions that are going to follow.
Mr. Beers didn't ask to consult you.
You 9
10 just asked, "I wanted to have a, conference with 11 Mr. Beers," and then you started whispering to 12 him for a time period that lasted almost a O I
\\ ~/
13 minute.
That's totally out of order.
14 MR. GLASSMAN:
Mr. Fiske, you made your 15 speech and I'm sorry that you felt compelled to' 16 try to put something on the record'that 17 mischaracterizes what just happened.
18 You asked a questf31 The witness 19 answered the question.
I cid not interrupt the 20 question.
This is the first conference, 21 indeed, I have had with the witness all day where I have asked for a brief conference.
It 22 23 was very brief, whether it was seconds or more 24 than ten seconds or 50 seconds, I don't know,
(
25 I didn't keep a stopwatch.
~
1 Beers tjg O
It is certainly not the kind of thing you 2
characterized and any unwarranted implications, i
3 4
and it's just unfounded.
5 I stand on that.
Why don't you just
(
6 continue. I am not stopping your questions.
MR. FISKE:
Well, I certainly will 7
8 continue.
BY MR. FISKE:
g 10 Q
You understood, didn' t you, Mr. Beers, 11 from this procedure that in the " Manual Action" 12 section that the prescribed action for a f ailed open
\\-[
13 pilot operated relief valve was to close the block 14 V"1V87 15 A
Are you referring to section a(2) (al?
16 Q
B (2) (a), yes, sir.
17 A
If you were positively sure that you had 18 a failed open RC-R2 and there was not extenuating 19 circumstances that would override you closing the 20 block valve then you would close the block valve.
21 Q
Do you see any reference in this 22 emergency procedure to extenuating circumstances 23 overriding the closing of the bicek valve?
['l 24
,A Yes, I am ref erring to B (3), the follow-up, 25 specifically B (3).(2).
l 119 Beers 1
O Q
Which says " Reduce ICS rate of change to
\\-'
2 less than 1 percent per minute".?
3 4
A Yes, sir s 5
Q
" lex cep t for runbacks) " ?
(
6 A
Yes, sir.
7 Q
Can you explain to us why that is 8
possible extenuating circumstances overriding the 9
closing of the block valve?
10 A
In the closing of the block valve you
(
11 have now lost the capability of the pilot operated 12 relief valve to function as it was originally
/~%.
(_)
13 designed as a pressure relief source during transient 14 operation, 15 Q
Well, what does that have to do with 16 reducing the ICS rate of change to 1 css than 1 17 percent per minute?
18 A
Well, the ICS rate of change, that is 19 a module in the integrated control systen that sets 20 how fast you could change the power 1= vel of the P ant and it is normally set at a much higher rate l
21 L
22 than 1 percent per minute.
23 Q
Well, I don't think I still understand
"'N 24 what that has to do with closing the block valve.
{J 25 A
By closing the block val'?e we have i
1 Beers 120 0
2 reduced the normal maneuvering capabilities of the 3
Plant, as the total system was designed.
4 Q
Is it correct that the maneuvering 5
capability of the plant to the extent that it was
(
6 affected by a closed block valve could be alleviated 7
by reopening the block valve as necessary?
8 A
The operators who were licensed on Unit 1 g
were rather reluctant to open and close the block 10 valve of the PORV at will because one time in Unit 1 11 we had some malfunction with the PORV and an operator 12 closed the block valve and could not get the block r.,
k--[
13 valve back open again when he wanted the block valve 14 to be opened.
15 Q
So you would not have wanted to have a 16 mechanism at Three Mile Island where the block valve 17 automatically closed every time pressure dropped 18 below the 2105 sotpoint?
Are you asking.the witness whether he ever considered that?
You 20 21 are not asking him now to reconstruct what he k.
would or would not have wanted sometime in the 22 23 Past, if he ever thought about that?
i 24 MR. FISKE:
Let's have Mr. Beers answer
()
~-.
the question.
25 i
i l
l Beers 121 O
k-2
- A Mr. Fiske, I never thought about that 3
design capability.
I can think of no instance in any 4
system where we automatically block valves. I am just 5
saying that due to the malfunction that we had on
{
6 Unit 1 there may have been some reluctance on an 7
operator's part to close the block valve for the 8
PORV unless he was getting into a -- unless he was 9
approaching the violation of tech specs lir.it.
10 Q
You understood, didn't you, Mr. Beers, t
11 that in the case of the stuck open -pilo't operated 12 relief valve one of the automatic actions that
/~N.
(_)
13 would occur was that there would be high-pressure
~
fell 14 injection actuated automatically when pressure 15 to 1600 psig?
16 I am referring now to Section B.2A2C.
17 A
B.2.C7 i
18 Q
It's on page 2.0 where it says, 19
" Automatic Action for a Failed Open RC-R2: Item C 20 High-pressure injection is actuated at 1600 psig."
21 A
I think we have already established, 22 Mr. Fiske, that should the reactor coolant pressure 23 he reduced by any mechanism to 1600 psig that the l
i
(~}
24 high-pressure injection system will come on, v
25 Q
Now, you knew, didn't you that the pilot l
l
1 Beers 122 l
2 operated relief valve or one of the code safeties 3
was open that that would result in a loss of inventory?
3 4
Isn't that correct from your earlier
(
5 testimony?
6 A
That's correct.
7 Q
And a loss of inventory is another word 8
for a loss of coolant, accident, isn't that correct?
9 A
No, I don't like to think of those two as 10 being synonymous.
(
11 Q
Did you have any understanding before 12 the Three Mile Island accident as to what could
(_)'
13 happen to the system if a code asafety stayed open 14 or a pilot operated relief valve stayed open and 15
. inventory continued to flow out through the top?
16 MR. GLASSMAN:
Could I have that read 17 back?
18 (Question read )
19 MR. GLASSMAN:
Are you asking.whether 20 that was ever considered?
21 MR. FISKE:
Yes, I am asking him whether L
22 he ever considered that, particularly after the 23 March '78 transient.
24 MR. GLASSMAN:
But before the March '79 25 accident?
1 Beers 123 0
2 MR. FISKE:
Yes.
L 3
A I don't recall any particular training on 4
that exact type of failure.
5 Q
Did you make any evaluation, Mr. Beers,
(
6 either as a shift supervisor or as the person that 7
had assumed Mr. Zechman's responsibilities as 8
supervisor of training for licensed personnel as to 9
the relative risk to the plant between allowing 10 inventory to continue to escape through an open 11 valve at the top of the system as opposed to the 12 possible risk of losing maneuvering capability of the U-13 plant by reason of a sticking block valve?
14 MR. GLASSMAN:
Objection.
The witness has 15 testified a few moments ago that he had never 16 oven considered the first half of your que'stion 17 so I don' t see how you can have him testify to 18 a comparison.
~
l 19 MR. FISKE:
I think Mr. Beers can answer 20 that question.
^
21 A
well, I believe.I testified earlier, 22 Mr. Fiske, that should you be approaching the tech 23 spec limit of leakage and you were positively sure 24 that the leakage source was the pilot operated relief 25 valve, the operater would certainly close the pilot
(
\\
t Baera 124 0
2 operated relief valve, block valve.
3 Q
I know you said that before, Mr. Beers, 4
but I would like an answer to my last question.
5 THE WITNESS:
Would you please restate
](
6 the question?
7 MR. FISKE:
Do you want to read it back --
8 I will put it again s 9
Q In trying to give guidance to the 10 operators as to when they should close the block 11 valve, did you make any evaluation as to the relative 12 risk to the plant of a continued loss of inventory 13 through the code safeties or the pilot' operated relief 14 valve as opposed to a possible reduction of the 15 maneuvering capability of the plant that might result that was closed and then stuck?
16 in a block valve 17 MR. GLASSMAN:
Objection to the question as
~
18 Previously worded. It applies here --I think the 19 witness testified he did not consider the first 20 half of the question, so I don't see how he 21 could be asked to testify as to whether he made k
22 such a comparison.
He can answer if he 23 understands the question.
24 A
I don't recall making any evaluation.
()
l 25 Q
Is it your testimony, Mr. Beers, that in
1 Bears 125
/~T U
2 allowing a situation to axist where operatora might not 3
close the block valve because of a concern that it 4
might stick and it might reduce maneuvering capability
(
5 of the plant that..in taking that action the operators 6
mi~ght allow inventory to continue to escape through 7
an open pilot operated relief valve?
That's not been his 9
testimonys His testimony was it is It's on s
10 the record-t 11 d
Do you understand /the question, Mr. Beers?
12 A
Well, Mr. Fiske, you are making an awful O
13 lot of suppositions there.
14 Q
I am not making any suppositions. I am 15 just asking a question.
16 A
I believe in the question you used th'e 17 term "might" several times.
~
18 Q
Well, did you have an understanding that 19 the block valve would stick every time that it was 20 closed?
21 A
I have testified, Mr. Fiske, that there 22 was a reluctance on the part of the senior operators 23 from Unit 1 who had experience with sticking block
(
24 valves.
It's difficult for me to answer your 25 question without knowing the total circumstances.
i
326 t
Beers 2
If there were a certain amount of leakage 3
you may tako a certain action.
If the leakage was 4
larger than that chances are the operator would close
(
5 the block valve, 6
Q How much leakage did you understand would 7
result from a pilot operated relief valve that had 8
stayed open for fifteen minutes?
9 A
Is the valve fully open or is it that the valve 10 just didn't reseat properly?
11 Q
How much leakage did you understan(. would 12 result from a situation in which enough flow had gone (Q*
x/
13 through the pilot operated relief valve to rupture 14 the disk on the drain tank?
15 MR. GLASSMAN:
You aren't asking the 16
' witness to guess that.
You are ask'ing him'to l
I 17 consider that.
18 MR. FISKE:
Based on his understanding of 19 the system before the accident in the various 20 supervisory positions that he held.
i l
21
'MR.
GLASSMAN:
You are not asking him to l
C i
22 make calculations here today.
Ycu are asking for 23 his recollection if he has one.
()
24 Q
Let's put it really simply, Mr. Beers,
~'
25 without a lot of dancing arounda Did you have an l
l l
f l
Seers 127 A
2 understanding before the accident that the tech spec 3
limits on leakage would be violated by an amount of 4
flow through the pilot operated relief valve that was 5
sufficient to rupture the disk on the drain tank?
(
6 A
Yes.
7 Q
Were the operators trained in that 8
situation where there was a flow in excess of the tech 9
specs leakage limit during the course of a transient, 10 and the operators were unable to determine whether 11 the flow was coming from the code safeties or the 12 pilot operated relief valve, that they s1 uld close 13 the block valve?
14 MR. GLASSMAN:
Could I have that read back?
15 Q
Were the operators trained before the i
16 accident that if there was a flow in excess of the 17 tech specs leakage limit sufficient so that if it was 18 coming from the pilot operated relief valve the block 19 valve should be closed, the operators were-unable to 20 determine whether it was coming from the block valve 21 or the code safeties, were they trained in that
(
22 situation that they should close the block valve?
23 A
I don't recall, Mr. Fiske, whether they specifically trained, but it's my understanding
[)
24 were o
25 from my own experience as a shift supervisor that I
1 Beers 128 O
2 would have directed the block valve to be closed in that situation as a method for making a determination 3
4 whether it was the code valves that were leaking or
(
5 the pilot operated relief valve.
6 Q
There were actual situations, were there 7
not, at Met Ed Unit 1 prior to the Three Mile Island 8
accident where the pilot operated relief valve had 9
opened and closed the way it was supposed to?
10 A
We are talking now exclusively of the 11 March 29, 1978 incident?
12 Q
Yes, I think by definition, but yes.
O
\\s/
13 A
You asked me about an August 1977 14 accident and I don't recall that incident.
15 Q
No, I am not asking you about situations 16 where'it didn't close the way it was supposed to.
I 17 am asking you now, isn't it a fact that there were 18 situations before the Three Mile Island accident at 19 Unit 2 where the pilot operated relief valve had in 20 fact opened and closed the way it was supposed to?
In 21 other words, normal opening and closing of the pilot 22 operated relief valve.
23 A
It's my recollection that between
[~}
24 March 29, 1978 that there were some reactor trips in
\\_/
25 that period of time where the pilot operated relief
1 Beers 123 0
2 valve ~may have opened and closed normally.
3 Q
And was any effort made by the training 4
department or anyone else at Met Ed to communicate 5
to the operators what the temperatures were at the
(
6 discharge line from the pilot operated relief valve 7
during the period of time that the valve was open 8
and for some period of time after it had closed so 9
that they could see how rapidly the temperature 10 dropped after the PORV had closed?
11 A
I don't recall any specific training in 12 that area.
O #
13 Q
Was any effort made to determine what the 14 temperatures had been at the thermocouples for the 15 pilot operated relief valve in the March 29, 1978 16 transient during the period of time that it was open?
17 MR. GLASSMAN:
Could I hear that back 18 again?
19 (Question read.)
20 A
Going back to th at day, Mr. Fiske, I 21 slightly recall having my attention drawn to a
~
22 recorder that's ~in the cone- - room that displays 23 tailpipe temperatures f ilot operated relief 1
24 valve, the code valves at ther of other
[))
25 temperatures.
I don't recali. absolute values, l
l
1 Beers 130 2
anything of that nature, 3
Q Did the thought ever occur to you, 4
Mr. Beers, at anytime before the Three Mile Island
(
5 accident that it would be useful to the operators 6
in applying symptom B.13 of the pressurizer system 7
failure procedure to know the difference in tailpipe 8
temperatures between a normal opening and closing of
. the PORV and a situation involving a stuck open PORV7 9
10 A
I don't recall any consideration being 11 given to the importance of a plot of these 12 temperatures for use in training or any other purpose.
Os 13 Q
Did you recognize before the accident that 14 there would be a different increase in drain tank 15 pressure and temperature for~a normal opening and 16 closing of the PORV than there would be for a POR'V 17 that was stuck open?
18 A
Once again, Mr. Fiske, we get'into an area 19 where we are almost into engineering calculations. It 20 would depend, of course, on whether the pilot 21 operated relief valve was stuck open fully or whether 22 it had just f ailed to reseat and was leaking slightly 23 into the drain tank. It really depended on the amount 24 of BTU's that were discharged into the drain tank.
25 g
I am talking about two different
l l
1 Beers 131 0
2 situations, Mr. Beers.
One is where the pilot operated relief ~ valve opens and closes completely the 3
4 way it's supposed to, and another situation where the 5
Pilot operated relief valve opens and then when the
(
6 Pressure reaches the prescribed setpoint,does not close completely and stays either wholly open or 7
8 Partially open.
And my question is you recognized, 9
10 didn't you, that in the latter situation there would M1 be a greater increase in drain tank-pressure and 12 temperature than there would be in the former?
[lh.
\\-
13 A
No, I don't understand that"at all, 14 Mr. Fiske. I believe that you could have a normal 15 opening as you describe and a valve that opened, 16 reseated but did not reseat completely an'd it is 17 conceivable to me that the cooling system that cools 18 the water in the drain tank could handle that leakage, and would preclude blowing the rupture disk.
19 20 Q
Did you think before the accident that 21 there was no meaningful way to distinguish between 22 increases in drain tank pressure and temperature from 23 a normal PORV opening and a situation in which the 24 PORV had failed to close as it was supposed to?
()
THE WITNESS:
Would you read the question 25
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L Beers 132 0
2
-back to me, please?
(Question read.1 3
4 A
I don't think that I thought about the two
(
situations in that contexts 5
6 Q
Were you aware, Mr. Beers, before the accident that there had been leakage from one of the 7
8 valves, one or more of the valves at the top of the Pressurizer for several weeks prior to March 287.
9 10 A
Are you speaking now about ynit 27 11 Q
Yes.
12 A
I was aware that there was leakage into 13 the drain tank from one or more of the valves associated with the pressurizer.
14 15 Q
Did you know before the accident that the 16 temperatures at all three of the valves h'ad been close 17 to 200 degrees for a period of time before the 18 accident?
19 A
I did not personally look at those f
indications during the period of time the,t you are 20 referencing'.
21 I
22 Q
But did it come to your attention that as 23 a result of this leakage there had been elevated 24 temperatures at the thermocouples for the three valves?
~
A I don't recall thinking about it.
25
. =
1 Beers 133 0
2
~Q So I understand your answer, does that mean that you didn't know that?
3 A
I don't recall looking at the temperatures 4
(
5 in some manner and I just didn't think about it.
6 Q
I take it that you were not aware prior to 7
the accident of any investigation that had been 8
conducted to determine which of the three valves was g
leaking?
10 A
No, I was not aware of any nvestigation 11 in that area.
12 Q
Prior to the Three Milo Island accident O-13 were you aware of any other situation besidos 14 March 29, 1978 in which high-pressure injection had been automatically actuated in Unit 27 15 16 A
Yes, I believe that there were one or more 17 incidents of automatic initiation of high-pressure 18 injection.
19 Q
can you tell us what were the-causes of the actuation of high-pressure injection in those 20 21 cases?
22 A
Well, the one that I can recall, Mr. Fiske, 23 it was a malfunction of the steam safety valves which
()
24 Provided an overcooling event.
25 Q
That was sometime in April 19787
s 1
Beers 134 U).
f 2
- A I don't recall the date..
3 Q
Can you tell us of any other situation in 4
which HPI was automatically actuated that you were
('
aware of before the Three Mile Island accident?
5 6
A That's the only one that comes to my mind 7
specifically right now.
8 Q
Did you learn in connection with this 9
April 23 transient that the steam safety valves had 10 stuck open?
11 MR. GLASSMAN:
Can I have that question 12 read back?
[k (question read)
\\#
I think the witness had testified that he 13 1-4 did not recall a particular date and whether the 15 event he remembers was or was not in April.
16 MR. FISKE:
I didn't ask him about the 17 date.
18 MR. GLASSMAN:
Maybe I misunderstood the 19 question.
20 Q
Did you understand that the HPI actuation 21 that you just referred to a moment ago had resulted 22 from a transient in which the steam relief valves had 23 stuck open?
24 A
Yes, it was my understanding that it was
()
25 an overcooling event caused by the malfunction of the
1 Beers 135 OU 2
steam safety valves.
3 Q
And the malfunction of the steam safety 4
valves was that they had opened and had not closed the
(
5 way they were supposed to?
6 A
A safety valve doesn't operate the way that 7
the pilot operated relief valve does.
There is what 8
they call a blow down range on the valve.
The safety 9
valves are operated against a spring and they will 10 blow down, the pressure will blow down below the point 11 at which the valve originally lifted, and they can 12 set that blow down rango: and it was my understanding O.
\\/
13 that this blow down range was not set properly or this 14 was the area of the valve that was not operating 15 correctly; which allowed the pressure to decrease 16 below the point at which it should have.
I 17 Q
In other words, when the pressure reaches 18 a certain point the valve is supposed to close, l
19 correct?
20 A
That's correct, Mr. Fiske.
I don't recall l
l 21 the actual number of valves or these are secondary L
22 valves and they were set at various setpoints.
They 23 didn't all open at the same time and then all close at 24 the same time.
They opened and closed at slightly
()
I 55' ~ ~ ~different values.
So when you look at that overall
_m i
Beers 136 0
2 range you could turn into a rather wide range.
~
3 Q
Did you understand that any of the valves 4
had failed to close because of a mechanical problem with
(
5 the valve?
6 A
That's what I was trying to explain to 7
you in explaining the blow down of the valve.
8 Q
Now, you said that after the March '78 9
transient there was a light installed in the control 10 room in Unit 27 11 A
A light installed --
12 Q
Relative to the position of the pilot 13 operated relief valve?
14 A
Yes, there was a light installed on the 15 center console subsequent to'the March 29, 1978 16 incident to aid the operator in determining the 17 position of the pilot operated relief valve.
18 Q
Did you give any training to the 19 operators at Unit 2 on that light?
20 A
Did I personally give any training or are 21 you saying as my responsibility of supervisor of 22 licensing training?
23 Q
Yes, I really meant to include both, 24 Did the training department under your 25 supervision give any training to the operators in i
i 1
1 Beers 137 2
Unit 1 on that'use of that light?
(Recess taken.)
3 4
A Yes, I believe the training department 5
did give training on the fact that that light was an
(
6 indication of the pilot operated relief valve position.
7 Q
Did you tell the operators that the light 8
was a direct indication of the position of the valve?
A I don' t recall the exact training on that.
9 10 I believe that it would have been taugh in the 11 category called " Instrumentation and Control" where 12 sometimes Mr. Brown would give a simplified sketch
(_).
13 to emphasize and instill in the operator's mind how 14 the circuitry worked.
15 Q
so your understanding is that Mr. Brown 16 did make clear to the operators the mechanism by which 17 the light was turned on or off?
18 A
I don't recall the specifics, whether he 19 had a simplified circuit for that or not. -
20 Q
Well, I don't think I understand your 21 testimony up to now.
Can you tell us what the L
22 operators were told about the significance of this 23 light?
[)
24 MR. GLASSMAN: I think you have got two m
25 different questions now, Mr. Fiske. I mean he
's
~ _ _
1 Beers 138
~
2 did answer your questions before as to what the light indicated, but I think now you have been 3
4 focusing on whether they were taught about the 5
particular electrical circuitry, if I understand
(
6 you.
7 Q
Let's put it this way, Mr. Beers:
There 8
is no big mystery about this.
Were the operators told 9
that there were circumstances under which the light 10 could be off but that the valve could still be open?
11 A
I don't recall the specific precaution in 12 this area.
The operators were taught to believe the Os ~
13 indication.
There were cases on the console -- that
~l 14 t'h e indication on' the console is not a direct indication of what that component is doing but what is in the console 15 16 is what the operator has in front of him to see, to be 17 able to determine what's going on out there in that 18 plant.
19 MR. FISKE:
Could I hear that answer back, i
20 please.
21 (Answer read.)
22 Q
Well, as far as the console itself is 23 concerned, there was a light that was either on or f~%
i
)
24 off, right?
y, 25 A
In Unit 2, yes.
1 Beers 139 O
2
-Q And isn't it a fact that there was a labei next to the light that said if the light is on, the 3
4 valve is open.
If the light is off, the valve is
(
5 closed?
6 A
I don't recall the label.
7 Q
Well, _ you knew, didn't you, Mr. Beers, 8
that the way the thing worked, the light came on w' hen 9
power was on to the solenoid, right?
10 A
I think I have already testified to that.
11 Q
Now, it is correct, isn't it, that the way the pilot operated relief valve worked is that when the power 12
(~.
13 was on to the solenoid that activated a' plunger which 14 went down and pressed on a lever which in turn opened 15 the pilot valve, which in turn allowed the main valve
~
f 16 to open?
17 MR. GLASSMAN:
Are you asking for the 18 witness' understanding today?
19 MR. FISKE:
I am asking for his understanding of the way this valve worked 20 21 before the accident.
L 22 MR. GLASSMAN: I am still confused.
Are 23 you asking for his understanding today of the 24 way the valve worked before the accident or are
()
25 you asking for his understanding before the
1 Bears 140 V
2 accident of how the valve worked?
MR. FISKE:
I am asking for his 3
4 understanding before the accident of the way
(
5 the valve worked.
6 MR. GLASSMAN:
I will allow him to answer 7
the question, but you are now talking about how 8
the valve worked.; before you were talking about 9
how the indicator light worked.
I am very 10 confused.
11 MR. FISKE:
Believe me,-Mr. Glassman, they 12 are very closely related.
O k>
13 MR. GLASSMAN:
You can answer the question 14 if you understood it.
15 A
Well, prior to the Three Mile Island
^
16 accident I don't recall a lot of emphasis anywhere, 17 training, on shift, at the simulator, anywhere as to 18 the mechanical construction of the pilot operated 19 relief valve.
20 Q
Well, I am talking now, Mr. Beers, about 21 what was done in the Met Ed training department after 22 Met Ed installed this light in the control room to 23 educate the operators on the significance of that 24 light as it related to the opening or closing of the
()
25 pilot operated relief valves and I think we have
-i
- - ~ - - -,.
-. _ _.. ~, -.
~ -,
t Beers 141 l\\
i 2
established that you understood that when the light 3
was on Power was flowing to the solenoid and when the 4
light was off power had stopped flowing to the
(
5 solenoid, right?
6 You are nodding your head.
7 A
I agree to that.
8 Q
Now, I am trying to develop how that 9
knowledge was related to the way the valve worked so 10 that the operators could be told about possible ways 11 in which the valve might remain open even though power 12 was no longer flowing to the solenoid.
That's the Q-13 purpose of my question just so there is no great 14 mystery about this.
15 MR. GLASSMAN:
Now, do you have a question 16 pending?
17 MR. FISKE:
I don't know. I hope to put 18 one against that background, and we'can move i
19 along.
~
20 Q
I think I will go back to the question I asked a moment ago, which I don't think you really 21
(
l-22 fully answered which is whether you personally, 23 Mr. Beers, after this light was installed, made an 24 effort-to determine in your capacity as supervisor 2
of training for licensed personnel how the valve l
1 Beers 142
()
C/
2 worke'd so that you would be able to understand the 3
significance of the fact that the light on meant power 4
to the solenoid and the light off meant no power to
(
5 the solenoid?
8 MR. GLASSMAN:
I would like to hear that 7
back.
8 (Question re=d. )
9 MR. GLASSMAN: Objection as to form.
It 10 seems to be a lot of combinations.--
11 MR. FISKE:
Please, don't distract the 12 witness.
You made the objection to the form.
I
/~ N.
13 think that's good.
14 Do you understand the question, Mr. Beers?
15 THE WITNESS:
I am not sure.
16 A
I don't recall any research into the area 17 of the relationship between the solenoid activating 18 the valve and what happens to the valve after the 19 solenoid was activated.
20 Q
Well, was it important to you, Mr. Eeors, 21 in your capacity as either shift supervicor or head k
22 of licensed training at Met Ed to determine the extent 23 to which there might be conditions that would cause D
24 the valve to remain open even though the light was
[J
~
25 off?
I Seers 143
- O
~
2 I will withdraw that question.
4 3
was.it important to you, Mr. Beers, as 4
either shift supervisor or head of the training for
(
5 licensed personnel to determine the extent to which the 1
6 light might be a misleading indicator of the position 7
of the valve?
1 1
Objection, lack of f
9 foundation.
It's hard to ask someone what's 10 important to them unless they even answer a 11 basic question as to whether this was ever 12 considered.
- O-13 A
I just don't recall thinking about the 14 fact that the signal could have bean removed from the 15 valve and the valve not close.
16 Q
Did you make any effort to learn the 17 mechanism by which the valve operated so you would be l
18 able to make some informed judgment as to whether or 19 not there were conditions that could cause'the valve 20 to stay open even though power was off to the solenoid?
t j
l 21 MR. GLASSMAN:
That's just been asked 22 and answered a few moments ago, Mr. Fiske.
23 MR. FISKE:
I don't think so, Mr. Glassman.
()
24 MR. GLASSMAN:
We had a bit of a 25 colloquy where I objected to a question and
)
-.. ~...
}
s 1
Beers 144 2
you said I had my objection on the record, and we should go on.
3 4
I let you go on, and now we are coming
(
5 back to it again.
6 MR. FISKE:
No, this is a different 7
question, but you may have lost it in the 8
colloquy, particularly this late in the 9
afternoon, so maybe you could raad it one.more 10 time?
y 11 (Question read. )
12 A
I don't recall giving any consideration O.
~
\\"2 13 to that.
I was certainly familiar with the physical 14 location of the valve.
I had been on top of.the 15 Pressurizer'a number of times, but I don't recall 16 giving any consid'eration to it.
17 Q
Well, putting it one other way, Mr. Beers, 18 just so I understand, did you give any consideration
~
l 19 to trying to determine whether there were" conditions t
20 that could cause the valve to stick open even though l
21 the light was off as. part of your training
~
k 22 responsibil1 ties?
- 23 HR. GLASSMANs Objection as to form.
s
/
,b",
j 24 A
fg td.re you* aware of.any discussion at or 25 - u
~
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p e
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~
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- - l! _ ____ __ _ y y _,
' )- n d.: ! ?,1 z, y ~
1 Beers 145 P d 2 about the time this light was installed on the subject of whether or not a better indicatio-of valve position 3 4 could be installed than this light? 5 A No, I was not aware of any discussion of ( 6 that nature. 7 Q Did it ever come to your attention at any timo before the Three Mile Island accident that people at Met 1:d g had recommended that a better indication of valve g 10 position be installed than this light? ( 11 A No, it didn't come to my attention. The 12 normal sequence of events on anything that was related P. 13 to the nuclear steam supply system would be that a 14 problem report would be generated and it would -- as 15 I recall it would go two ways. It would go up l 16 through the Met Ed engineering people and it also wdnt i 17 to Babcock & Wilcox. i 18 MR. FISKE: I guess I will move to strike 19 the last part of that answer as not~being 20 responsive to my question. 21 Q Let me show you a document -- 22 MR. GLASSMAN: I think the record will 23 try to reflect that the witness tried to [) 24 answer as best he could. \\s 25 Q I show you an exhibit which has been
1 Beers 146 O 2 marked as B&W Exhibit 767 which is, I.believe, a collection of documents generated by various people 3 4 within the Met Ed organization, and ask you concerning ( 5 a different kind of indication for a position of the 6 Pilot operated relief valve whether or not you saw i 7 any of these documents at any time before the Three r 8 Mile Island accident? 9 A Would you give me a moment to review the 10 documents? g 11 Q Sure. 12 A I have reviewed the documents. O-13 Q Did you see any of these documents before 14 the Three Mile Island accident? 15 A I don't recall seeing any of these 16 documents prior to today. 17 Q Did anyone consult you, Mr.' Beers, as 18 supervisor of licensed training before making the [ l I 19 recommendation that the open light for the~PORV l 20 should be connected to the limit switch? MR. GLASSMAN: Objection, lack of 21 22 foundation. 23 Q You can answer the question. () 24 MR. GLASSMAN: There has been no 25, testimony as to what was recommended or what
- n
Beers 147 t ~ would happen to any recommendation or anything 2 of that sort. I object to it. 3 MR. FISKE: I understand the basis for 4 your objection which I disagree withs but you ( 5 6 can answer, Mr. Beers. A I don't recall being queried on this 7 8 Particular modification. It didn't follow under my responsibility, change modification recommendations. 9 10 Q Well, did anyone ask your advice as to 11 whether or not it would be desirable to have a better indication of PORV position before the recommendations 12 contained in these documents were made? '~ 13 MR. GLASSMAN: Objection, lack of 14 foundation. The particular document which you 15 have placed before the witness and w'hich he says. 16 he does not recall seeing simply says 17 18 there was a recommendation made which was not a better indication of PORV indication. 19 MR. FISKE: Well, that isn't what it says 20 at all, Mr. Glassman. 21 There was a document in September 1979 22 23 after the accident. MR. GLASSMAN: There is a particular page () 24 W38018 which says "Not a better indication of 25 l ~. -
1 Beers 148 2 valve position than the present. demand indication." 3 4 Without regard to the date, I don't know that there is anything in this document that ( 5 6 suggests or justifies the comments made by f counsel. 8 MR. FISKE: Well, let's avoid a lot of debate about this. I think it's a simple 9 10 question, Mr. Beers. 11 ~BY MR. FISKE: 12 Q Did anybody consult you for advice before ~ 13 they made a recommendation for what they may have 14 considered to be a better indication of PORV position? 15 A No. 16 Q Did anybody bring to your attention, l l 17 Mr. Beers, at any tine before the Three Mile Island ~ I 18 accident the fact that there had been an event at 19 Unit 2 in October 1978 where pressure had'gone 20 up above the setpoint for the opening of the PORV and l l 21 the light had gone on, but the PORV had remained 22 closed? I 23 A At Unit 27 24 Q Yes. 25 A What was the date on this again?
i t Beers 149 2 Q October 1978, 3 MR, GLASSMAN: Are you asking for the 4 date or are you asking for the event? ,f 5 MR. FISKE: I am asking for the event. 6 A Today I don't recall being aware of that. 7 Q Were you informed at any time before the 8 Three Mile Island' accident of any situation other than 9 the October 1978 situation in which the light proved 10 to be a misleading indicator of position of the valve? 11 A I don't recall any situation of that I2 nature. i
- CE)-
13 LTime noted: 5:15 p.m.) 14 15 MARSHALL L. BEERS 16 17 subscribed and sworn to IO before me this 19 day of 1982. 20 21 L 22 23 () 24 25 w,---- a ,~,-,,m,,--w -..,,..m-,-._,.-,,-,,-----n-w-,.a m- - -
I acers 150 (~) ~ l \\~/ 2 CERTIFICATE 3 STATE OF NEW YORK )
- SS.:
4 COUNTY OF NEW YORK ) f: 6 I, NANCY A. RUDoLPH a. 7 Notary Public within and for the State of New York, 8 do hereby certify that the foregoing deposition 9 of Marshall L. Beers Was taken before 10 me on wednesday, July 7, 1982 11 That the said witness was duly sworn 12 (:). before the commencement of his testimony and 13 that the within transcript is a true reco'rd of said 14 testimony; 15 That I am not connected by blood or l 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of any of the 19 counsel. 20 IN WITNESS WHEREOF, I have hereunto set 21 myhandthisM/ day of_ b /fd 4 22 / f7' i 23 Q W no w
- yfNCYA,
~ RUDoLPH 25 -r s.-- -m-
7/7/82 151 () I N D E X l-WITNESS: PAGE .) MARSHALL L. BEERS 3 EXHI B IT S B&W FOR INDENTIFICATION 889 Copy of " Synopsis of Resume of 7 Marshall L. Beers." 890 Copy ofimultipage document entitled 13 ? Selection; Training, Qualification, and Licensing of Three Mile Island i Reactor Operating Personnel " by Ronald Eytchison. r 891 " Superintendent's Event Report," 84 dated 3/29/78 j ~ 892 Copy of multipage handwritten 87 document entitled " Synopsis of Event." -oCo-J' ./ O ~ w.e is. ~ n- ,,.}}