ML20072H762
| ML20072H762 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/13/1981 |
| From: | Jim Hickey TOLEDO EDISON CO. |
| To: | |
| References | |
| TASK-11, TASK-GB NUDOCS 8306290725 | |
| Download: ML20072H762 (171) | |
Text
_ ____ ______________________ _
'd UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_ _x GENERAL PUBLIC UTILITIES CORPORATION, a
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
(
Defendants.
_x 2
%d Deposition of JAMES M.
HICKEY, taken by Plaintiffs, pursuant to notice, at the offices of Fuller, Henry, Hodge & Snyder, Esgs., 300 Madison Avenue, Toledo, Ohio, on May 13, 1981, at 9:30 a.m.,
before Martie Saphir, Notary Public, in and for the County of Hennepin, State' of Minnesota.
l 8306290725 810513 x.
PDR ADOCK 05006289 T
PDR l
l 9
DOYLE REPORTING. INC.
CERT!FIED STENO TYPE REPORTERS 369 LextNGTON AvzNur
)
WALTER SHAPIRO C.S.R.
NEW Yost N:. N.Y.
10o17
TcLcPHONE 212 - 867-8220 j
F 1
2 2
AP P E A R.A N C E S:
3 4
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs
()
5 425 Park Avenue New York, New York 6
4 BY:
RICHARD C.
SELTZER, ESQ.
7 8
i 9
DAVIS, POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 1575 I Street Northwest Washington, D.
C.
20005 il BY:
DANIEL F.
KO@B, ESQ.
12
-and-(
KAREN WAGNER, ESQ.
14 15 FULLER, HENRY, HODGE & SNYDER, ESQS.
Appearing on behalf of the Witne'ss 1
16 300 Madison Avenue l
P.O.
Box 2088 17 Toledo, Ohio 43603 18 BY:
C.
RANDOLPH LIGHT, ESQ.
19 20 21
(:
22 23
_(s' T,).
24 25
1 3
I 2
IT IS HEREBY STIPULATED AND AGREED by 3
and among the attorneys for the respective parties 4
hereto that the sealing, filing and certification 5
of the within deposition be, and the same hereby 7
6 are, waived; and that the transcript may-be signed 7
before any Notary Public with the same force and 8
effect as if signed before the Court.
9 IT IS FURTHER STIPULATED AND AGREED that t
10 all objections, except as to f o rm', shall be 11 reserved to the time of trial.
12 I -0 9:26 a.m.
Wednesday r
13 May 13, 1981 14 Whereupon,
- 15 JAMES M.
- HICKEY, 1
16 having first been duly sworn, was examined 17 and testified as follows:
~
18 EXAMINATION BY MR. SELTZER:
19 Q
State your name, please.
?
20 A
James M.
Hickey.
('
21-Q By whom are you employed?
22 A,
Toledo Edison.
. Q When did you begin working-for Toledo Edison?
(h L/
- 24 A
-1974.
25 Q
What has been your job responsibility.at S
__.,_.__r,-
-m
,.m,.
..y-y
~...
i 1
Hickey 4
- 73 2
Toledo Edison since 19747 3
A Nuclear training, responsible for the training of 4
the nuclear staff at Davis-Besse including the operators.
5 Q
What job titles have you held since 19747 6
A Training coordinator, training supervisor, 7
training manager.
8 Q
Have you been the highest ranking management 0
person at Toledo Edison with full time responsibility for the training of nuclear operators?
11 A
I havs been, yes.
Q What prior nuclear experience did you have 13 before coming to Toledo Edison?
14 A
Nuclear Navy experience, eight years.
Q Were you involved at all in training of 16 nuclear. operators with the Navy?
17 A
Yes, primarily training.
18 2
Q What training positions did you have with the Navy's nuclear program?
90 A
Instructor and training coordinator.
(.
I Q
In or about September 24, 1977 how many 22 people were on the staff responsible for training nuclear-
)
}
employees at Davis-Besse including yourself?
~I MR. KOLB:
Objection as to form.
95
~
BY MR. SELTZER:
1 Hickey 5
2 Q
You may answer.
3 A
Three.
4 l
MR. SELTZER:
What is the basis of the 5
objection?
6 MR. KOLB:
You said nuclear employees 7
and I take it you probably meant nuclear operators l
8 but you didn't say that.
9 MR. SELTZER:
I meant employees responsible 10 for operating the plant, that's right.
11 BY MR. SELTZER:
("N 12 g,)
Q Is that the sense in which you understood the 13 question?
14 A
Yes.
15 Q
At the time of the famous Three Mile Island 16 accident, how many employees including yourself were 17
~
responsible for the training of nuclear plant operators 18 at Toledo Edison?
19 A
Six or seven, at that particular time.
20 Q
Toledo Edison Company operates one nuclear
[
21 electronic generating station, is that right?
A Right.
23 l
(^g Q
What is the name of that?
5-34 A
Davis-Besse.
25 O
How many nuclear units are at that station?
i a
t Hickey 6
AV 1
o A
One.
One unit, f
3 i
Q Is that called Davis-Besse Unit I?
4 A
That's correct.
5 Q
Which company manufactured the nuclear system 6
for Davis-Besse?
7 A
Babcock & Wilcox.
O Q
Among the various types of Babcock & Wilcox 9
plants, what type of nucidar plant is Davis-Besse?
10 A
It's a 377 element rays lube plant.
11 Q
And is it a 2772 megawatt thermorated plant?
4 A
That's correct.
13 Q
Is it also correct to describe the plant as having an all rods out design?
15 A
That's correct.
I 16 Q
What does all rods out refer to?
17 A
Means that any major shifts in power are-done 18
{
by either dilution or by adding more on to the reactor 19 coolant system.
Minor changes in power are handled by l
l-20 volume.
F
-Q For power-levels above approximately 75 22 percent of full power, is the-normal configuration for
- 3
~ the plant ~ operation with the control rods substantially.
~
s d
og withdrawn from-the core?
95
~
A That is correct.
l
,. _. ~., _. -.,, _.... _,...
. - ~,.. _..,,,,..
1 Hickey 7
gS).
Q And that's what all rods out refers to?
A' That is correct.
4 Q
When was the first criticality achieved on 5
the Davis-Besse unit?
6 A
That would have been in July
'77, our operating 7
license was issued in July, and initial criticality was 8
the same day.
9 Q
Is criticality the moment at which a 10 self-sustaining nuclear reaction is achieved?
11 A
That is correct.
)
Q When was the first synchronization of the i
13 turbine?
14 A
That would have been August 1977, the latter part 15 of the month.
16 Q
At the same time that first-synchronization 17 was achieved was the first electric power generated by 18 the Davis-Besse unit?
19 A
That is correct.
20 Q
When did the plant first go commercial?
If
[
21 you're not sure, it's not important.
22 A
Shortly after.the August 28th date.
23
/"]
Q Had the plants gone commercial prior to N_/
o4
~
September 24, 19777
~5 9
A We had been at 35 percent power prior to September 4
__.___-_-.a
1 Hickey 8
g i
s 9
~
24 and we were declared commercial at 15 percent power.
3 so that's an assumption I would make.
I would have to 4
verify that exact date.
5 MR. LIGHT:
Answer as well as you can.
6 BY MR. SELTZER:
7 Q
In other words you would assume that the 8
plant went commercial before September 24 but you would 9
want to verify that?
g 10
~
A I would want to verify that, yes.
11 Q
From your experience as the person who's been
("T 12
(,)
the head of training for nuclear operators at Davis-Besse 13 since 1974, what, if anything, do you believe principally 14 prepares operators of a nuclear plant for how they should 15 respond to an abnormal event?
16 A
Their total training program of course prepares 17 them for that.
And there is essentially five phases to i
18 the training.
And the actual operations in an emergency 19 situation is done on the simulator.
And that is one of 90 the phases of training.
(.
Q What are the other five phases?
22 A
You have an academic phase.
You have a phase 23
(~5 that is involved in pressurized water technology.
You
\\_.)
o4
~
have an observation training phase where you actually 25 observe the operation of a facility but do not participate
1 Hickey.
9
/'T U
2 in the thing.
You have a phase of training that consists 3
of simulator training and also the pool reactor training.
4 And then you have another phase of training called Phase 5
Five which is usually conducted by the utilities which is 6
systems training on your installed systems.
7 Q
Prior to September 24, 1977 had Toledo O
Edison relied on Babcock & Wilcox to provide part of 9
the training for the operators of the Davis-Besse plant?
t 10 A
That's correct.
11 MR. SELTZER:
I would like to mark I2
(
for identification as GPU Exhibit 1,000, a Babcock 13
& Wilcox description of Training Services, T203 14 Physics Test Orientation for Engineers /E3 dated 15 June 1977.
16 (REPORTER'S NOTE:
GPU Exhibit 1,000 is 17 marked for identification.)
MR. SELTZER:
I would like to mark as 19 GPU Exhibit 1,000 a Babcock & Wilcox description 20 of Training Services T302 entitled NSS Orientation
(
21 for Experienced Engineers and Operators /02, dated 22
-June 1977.
23 (REPORTER'S NOTE:
GPU Exhibit 1,000 is o4
' marked for identification.)
I 25 MR. SELTZER:
I would to mark as GPU
1 1
Hickey 10 0
2 Exhibit 1,002 a Babcock & Wilcox description of 3
Training Services T303 entitled Replacement 4
Operator Training /03, dated June 1977.
(i 5
(. REPORTER'S NOTE:
GPU Exhibit 1,002 is 6
marked for identification.)
7 MR. SELTZER: I would like to mark as GPU 8
Exhibit 1,003 a Babcock & Wilcox description of 9
. Training Services T304 entitled simulator 10 Requalification Training /04 dated' June 1977.
11 REPORTER'S NOTE:
GPU Exhibit 1,003 is 12 marked for identification.)
13 BY MR. SELTZER:
14 Q
Mr. Hickey, have you seen these descriptions 15 of B & W training service programs in the regular course 16 of your business?
17 A
Yes, I have.
18 Q
Do GPU Exhibits 1,000, 1,001, 1,002 and 19 1,003 describe training services programs which in 20 substantial part have been supplied by B & W for Davis-(
21 Besse operators?
22 A
That's correct.
23 l
Q In addition to the programs that are O
24 l
described here, has B & W also supplied other training 25 services?
Hickey 1
OV 2
A They have, yes, 3
Q And what other training services has B & W 4
supplied for Davis-Besse personnel?
5 A
In our early days, early days being
'74,
'75 6
period and even prior to that,.they supplied us with I
pressurized water technology courses which are lengthy 8
- courses, j
9 Q
Did B & W supply any management training?
10 A
Yes, they did.
11 Q
What type of management training did they 12 supply?
13 A
They supplied some indoctrination programs for 14 key personnel.
They supplied a training program for one 15 of our vice-presidents, the vice-president in charge of 16 nuclear at the time, Mr. Grant, and also'some other 17 individuals immediately after the purchase of the plant
~
18 back in the 1970 time frame.
10 Q
Did the Babcock & Wilcox training which was 20 supplied to Davis-Besse personnel include classroom
{
21 instruction?
A Yes, it did.
22 O'"
Q Did the Babcock & Wilcox training of Davis-24 Besse personnel include training on the B & W simulator?
25 A
Yes, it did.
1 Hickey 12 r~N k
2 Q
What, if anything, is the significance of 3
the simulator in the training of nuclear plant operators?
4 MR. KOLB:
Objection as to form.
BY MR. SELTZER:
6 Q
You may answer.
7 A
Simulator training is a key elenent in preparing 8
an operator to handle the plant.
It's a requirement for 9
licensing of operators, what we conside,r cold licensing 10
~
of operators, being that there is no plant to train on, 11 the operator becomes familiar with the normal operations,
(~N, 12
(_,)
the start-ups and shutdowns of the plant and also the 13 emergency operations of the plant through the simulator.
14 Q
In terms of degrees and importance, how 15 l
would you characterize the importance of simulator
{
16 I
training, as a tool for training?
17 A
It's an extremely important portion ~of the 18 training program.
It replaces, as in the Navy program, 19 the Navy had prototype training which was actual plant 20 training.
And in civilian environment on the simulator replaces that prototype training.
And it's extremely 22 difficult to, if not impossible, to train a person 23
("]
i operating a plant without a simulator.
\\ms 34 Q
In your work in training, are you familiar 25 with a concept known as venditioned response?
a
t 1
Hickey 13 2
A Yes.
3 Q
To what extent, if at all, does a simulator 4
build a conditioned response?
5 MR. KOLB:
Objection as to form.
6 THE WITNESS:
The' repetition of event and 7
of say. casualties.has a tendency to have the same 8
'effect as a conditioned response.
People can 9
immediately perform the activity,without having to 10 concentrate on the detail of the activity.
It's 11 not a Pavlovian response by~any~means, but it's-an automatic response'to indication, in some cases.
13.
MR. KOLB Read the answer back, please.
14
.(REPORTER'S NOTE:
Last answer read'back by 15 reporter.)
16 BY MR. SELTZER:
17 Q
In the B & W simulator training program, are 18 the Davis-Besse operators trained on both -normal 19 operating events and abnormal operating events?
20 A
-They are.
e Q
Are they trained on any events which they
~~
haven't seen.or experienced on-their own nuclear reactor?
~
23 A
Yes.
94
~
Q What is the purpose-in doing that, as you 95 understand it?
t 1
Hickey 14 O
V O
~
A To insure that your personnel are aware of the 3
different kinds of transients that may occur, and to 4
assure that the action that they take is appropriate for 5
the symptoms or the cause.
0 Q
Have the Davis-Besse operators received I
simulator training from anyone other than Babcock &
~
8 Wilcox?
A No.
10 Q
If there is anything wrong or incomplete in 11 the simulator training that is given to operators, what
()
effect does that have on the operators?'
13 MR. KOLB:
Objection as to form.
14 THE WITNESS:
Have a tendency to reinforce the discrepancy in training.
16 BY MR, SELTZER:
17 Q
What do you mean by reinforce'the discrepancy?
A If we teach someone something wrong and we 19 demonstrate it on the simulator, we in fact reinforce 90
~
that wrong concept in any other forn of training.
91
(_.
Q Would you take a look, please, at-GPU Exhibit
~
2 J,003, the description of B & W training program T304 93
~
g entitled Simulator Requalification Training.
\\_
94
~
Do you see the second paragraph that begins, 45 "The program -
"?
l' Hickey 15 A
Yes.
2 g
Q It states there, "The program includes a review of recent abnormal occurrences applicable to 4
.B & W plant operations as well as a review of the 5
. utility's abnormal and emergency procedurei."
6 7
As part of the simulator training program 8
that B s W has been supplying to Davis-Besse operators, g
it your understanding that B & W would be including was abnormal occurrenced applicable-to 10 a review of recent B G W plant operations?
gg A
That's correct.
12 13 Q
Do you believe that that is an important part 14 of the training program supplied by B & W7 15 MR. KOLB:
Objection as to f,o rm.
16 THE WITNESS:
It is an important part of a I
17 training program, that is correct.
18 BY MR. SELTZER:
19 Q
Why do you believe it's important.for B & W 20 to supply a review of recent abnormal occurrences
'21 applicable to B & W plant operations?
l A
B & W has access, be it access to the different 22 23 abn rmal occurrences that occur at the plant, and they 0
.\\
are able to get more detail than what I,
being just a 34 25 training manager, would be able to get by contacting m_..
1 Hickey 16 O
2 maybe our counterparts.
They would have also the
=
3 engineering input in some cases into it rather than just 4
the surface material.
{
5 Q
When you say B & W would have access to other 6
l-plants,~what other plants were you referring to?
7 A
Other B & W plants.
Arkansas, SMUD, Crystal River.
'O Q
Those are all names of other B & W nuclear 9
plants?
e 10 A
That's correct.
11 Q
You were ju'st giving those names as examples?
e 12 A
That is correct.
13 Q
Does the description in GPU Exhibit 1,003 14 state what you understood B & W had agreed to supply to I
15 the Davis-Besse operators as of mid 19777-
~
IO A
Yes.
17 Q
Do you believe that B & W was in a better 18 position than Toledo Edison to supply effective training 10-to nuclear plant operators?
20 MR..KOLB:
Objection as to form.
21 THE WITNESS:
The vendor, the person who --
22' or.the group who designed the.NSS system always 23
_has the advantage over other vendors in being O
'4
'able to'present courses that pertain.to the 25 operation and. control--of the NSS system.
1 Hickey 17 V.
2 Q
What is that?
3 A
They have the -- of course they have designed the 4
plant.
Their engineers are available to interface with
-('
5 the training program and they do in fact receive feedback 6
from the other utilities on plant operati.on and abnormal 7
occurrences, other things.
They definitely are the focal point of information for any vendor, vendor utility 0
Q Does the fact-that B & W has a simulator and
(
0 Toledo Edison does not in any way affect --
I A
Oh, definitely.
Q their ability to provide ~ more effective 13 training?
14 A
That's a key element.
MR. KOLB:
Objection as to f o'rm o n tha t 16 question.
^
17 THE WITNESS:
The simulator is definitely a necessary thing.
And the only B & R simulator, 19 until recent times, was the lynchburg simulator.
BY MR. SELTZER:
-Q All of the Babcock & Wilcox training was supplied in addition to other training which Toledo 93
~
Edison obtained for its operators, is that correct?
4
'A That is correct.
95-
~
Q Prior to the Three Mile Island accident', what I. -
1 Hickey ja
'. O
.G' 2
if anything, were the Davis-Besse operators learning from 3
B & W regarding the use of just pressurizer water level 4
as a measure of the amount of water or inventory of 5
water in the reactor coolant system?
6 MR. KoLB:
objection as to form.
7 THE WITNESS:
The operators had drawn a 8
direct correlation between pressurizer water level 9
and plant inventory.
t 10 BY MR. SELTZER:
11 Q
Prior to the Three Mile Island accident, are 12 you aware of any B & W training of operators to 13 anticipate rising pressurizer water level;at the same I4 time ac falling reactor coolant syctem pressure?
15 A
Repeat that one, will you please?
16 Q
Prior to the Three Mile accident, were you 17 aware of any B & W training of Davis-Bess operators to 18 anticipate rising pressurizer water level at the same 19 time as falling reactor coolant system pressure, 20 simulator training?
(
21 A
No.
22 Q
Before September 24, 1977 what, if anything,.
23 is your understanding as to what Davis-Besse operators 3
)
24 learned from B & W regarding terminating high pressure 25 injection'as soon as pressurizer water level was
g Hickey 19 2
restored to its normal band?
3 MR. KOLB:
Objection as to form.
4 THE WITNESS:
One of the indications of 5
discovery from an abnormal occurrence or a 6
casualty was the increase in pressurizer level to 7
within the operating band on the pressurizer was 8
one of the indications that was used to terminate 9
high pressure injection.
10 BY MR, SELTZER:
11 Q
Was that indication stressed?
12 A
Yes.
13 Q
Was that indication stressed over all other 14 indications?
15 A
The learned response was such that,the pressurizer 16 level overrode other kinds of indication.
17 Q
Overrode?
Is that the word y'ou used?
18 A
Not overrode, I shouldn't use that ord.
Was 19 Acted upon, I would say.
Whenever the pressurizer got 20 into the band the operators acted upon that.
Operators 21 were informed that they should monitor all indication 22 but yet the operator would respond to pressurizer level 23 in the operating band as being indicating that the
[d ~
24 transient had been terminated.
25 Q
And you called that the learned response, is
1 Hickey 20
(^3 V.
2 that right?
3 A
Yes.
4 Q
In other words the learned response was to 5
terminate high pressure injection in response to 6
rising pressurizer water level?
7 A
Or throttle back on high pressure injection.
8 Q
So the learned response was to throttle back 9
or terminate high pressure injection in response to e
10 pressurizer water level?
11 MR. KOLB:
Objection as to form.
12 THE WITNESS:
Yes.
13 BY MR. SELTZER:
14 Q
Was throttling back high pressure injection 15 or termination high pressure injection the reinforced 16 or conditioned response that the operators learned from 17 the B & W training?
18 MR. KOLB:
Objection as to form.
19 THE WITNESS:
Throttling back on HPI was a 20 product of the overall training of the group and
{
21 a portion of that training was simulator training.
22 BY MR. SELTZER:
23 Q
And the training you're referring to is-
's_/
24 training by whom?
25 A
The overall training, the training of the individua:
Hickey 21 1
rN
. (I 2
either through atility training or vendor training.
3 Q
Did the Davis-Besse operators learn anything 4
from Babcock & Wilcox about when it was permissible to l
5 take the pressurizer solid?
6 A
In our early days of training in our pressurized 7
water technology courses and similar types of courses, 8
it was emphasized to the operators that there was only 9
one time in which the pressurizer was deliberately taken t
10 solid and that was during the period of' hydrostatic 11 tes, ting of relief valves, and that you should refrain 12
(-}
from letting the pressurizer go solid at all other times.
\\J 13 Q
Hydrostatic testing is a method of testing 14 the physical integrity of the reactor coolant system 15 before fuel is loaded into the reactor?
16 A
That is correct.
That is correct.
17
- Hichey, MR. KOLB:
Excuse me, Mr.
could 18 I ask that you refrain from answering the 19 question before he has completed the question?
20 Because if he doesn't complete the question I 21 don't have an opportunity to object.
22 THE WITNESS:
Okay.
23 BY MR, SELTZER:
.O(_)
24
.Q As you have been using the expression go 25 solid or-take the pressurizer solid, what does it mean e
g Hickey 22 P
2 to take the pressurizer or let the pressurizer go solid?
3 A
That means that the pressurizer normally has a
- 6 4
vapor space above the water in the pressurizer, and by i
5 going solid means collapsing the bubble that exists in 6
the top of the pressurizer and therefore the pressurizer 7
.itself would be full of water, not a vapor space and a 8
water space.
I 9
Q You said that the operators were trained by 10 t
Babcock & Wilcox that except during hydrostatic testing 11 they were not to permit the pressurizer.to go solid.
12 In what ways did Babcock &<Wilcox convery.
13 the rule against letting.the pressurizer go solid or the 14 instruction of letting the pressurizer go' solid?
15 MR. KOLB Objection as.to form.
-- 16 '
THE WITNESS:
The instructors,' simulator 17 instructors, reinforced that during.the 18' simulator training both during the" normal training 19 as-well as during the evaluation phase of-the 20 operator certification.
And this again.was
(
. reinforced by the operators themselves.
~2 9
BY:MR,-SELTZER:
23 Q'
How was it~ reinforced by the-operators
- 24 '
!thems e lve s ? -
25 A
It was considered by the. operators.as'.being
1 Hickey 23.
O 2
something to basically. point fingers at and basically 3
laugh at a person if they took the plant solid on the 4
simulator.
(
5 Q
You mentioned certification in your answer a 6
minute ago.
Did B & W in any way penalize operators 7
when it came to certifications if the operator had 8
permitted the pressurizer to go solid on the simulator?
9 A
Yes.
s.
10 Q
How were they penalized?
x 11
.A In some cases maybe not the sole reason, but in 12 some cases individuals were not certified when, during s
.J 13 their exam, their test, they let the pressurizer go 14
- solid, j'
15 Q
In other words letting the pressurizer go t'
16 solid was a mark against them on their certification?
17 A
Oh, yes.
Yes.
~
18 Q
Hav'e you witnessed training of operators on l
19 the B & W control room simulator?
20 A
Yes, I have.
21 Q
What Davis-Besse operators of what group of 22 operators'have you seen'being trained on the B & W 23 simulator?--
b)
(.
24 A
Our initial cold license group and the initial 5 hot
.25 license group -- we had 23 people in our cold license
_l
'l Hickey 24 (0
2 group.
Of that number approximately half of them had 3
been certified prior to 1974.
We returned them to the 4
simulator for recertification in the
'74,
'75,
'76 time
(
5 frame for a two-week periodi I attended those 6
certifications and we had another group of operators who s,
7 completed that 23 man group who were down for N
8 certification, initial certification.
And I witnessed s
9 the certification of those particular individuals. _And t
10 then the'first groups of the hot license people that n
pil went through, that would be up through probably 1976, '77
-(
- l s.
s 12 Q
Have you witne'ssed any of the training of t).
~
s 13' l
operators from uti'lities other than Toledo Edison at i
x - n s.
14 the(' LynchburgLsimulator o,f B A
h,
& W?
j
\\j.}
only very. casually.E They vould be,at 15 the 16i
^ imulator the same-time we were.there and they might be I
s h
17 there o the morning on'the simul'atorand}wewouldbe
(
t lu there,1 the afternoon in.the classroon,,so just casually, t
x 1
10 Q
On September 24 3.1977+the Davis-Besse' plant
- 1..
20 had an abnormal eveni, is that'right?
'n; s
8 y
21 A
That is correct.
h
?'
i +'
s o
22 thejprincipal' features [of that Q
What were q, _.
s..-
t
.t w 1
23 abnormal event?
What,I'mspecifically-iskingish' hat (O.
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N 24 was! happening to the pla n tVdui-ing thatd, hno'rmal epant? U 4.;5, u,..
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started o,ut that Saturday'at,15 /perc'ent z
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l Hickey 25 G
I power and we had some difficulty with the valve.
So we i
3 took the turbine off the line.
The reactor was abciy t e 9 4
percent power.
And we received a SFRCS half trip which
(
5 affected our feedwater system, isolated the steam 6
generators, affected the feedwater system.
We had some 7
probism with an auxiliary feedwater pump so we were 0
actually feeding one side of the plant with one steam 9
generator isolated.
10 We boiled dry the one stea generator but 11 we did have one steam generator operate.
(
At the same time that occurred within just 13 a few seconds the pressure within the system got up 14 to the lift point of the PORV, and the PORV opened.
15 The reactor of course was :, vill critical at c.h a t 16 PArticular time.
The reactor was tripped and the 17 ruptured disc on the quench tank broke and the 18 operators at that time observed a shift in, pressurizer 10 level.
Pressurizer levei started increasing and it 20 increased to above the scale of indication and the 21 operators did in fact secure high pressure injection.
22 And then we received an alarm on the sump, the building 23 sump, and that in connection with an operator identifying f) v 24 the fact that we had voiding in the system caused the l
25 operator to close the PORV.
,g*
t y,,.
e
,e gr i;
4
.y n
Hickey 26
(-,b,e ' Q' '
s-c
l~,-
,2 s
/Q Close the PORV or close the block valve?
.\\ +
= 2.1 3
A Block valve to the PORV, right.
And then restore 4
the system.-
')
5 Q
You used some initials in your answer.
One
,(-
t-6
]
- was SFRCS.
Does that stand for steam and feedwater.
.\\ E 7
' rupture control system?
4 (A
A That's correct.
9
?
Q Does PORV refer to pilot oqerated relief 10 valve?
' 11 '
h That's correct.
12 Q
Is that sometimes also referred to as an 13 electromatic relief valve?
14 A
That is correct.
15 Q
You said that at one point in'the event the 16 operator secured high pressure injection.
Does that 17 mean they terminated it, shut it off?
18 A
That is correct.
The flow through the high 19 pressure injection lines in the early part of the -
t 90 i
~
incident showed no flow through the lines because they 91
(
shared a common line with their high pressure injection
- of our makeup pumps.
So that was another portion of that 23 C\\
initial incident.
A,)
24 Q
I'm sorry, I don't understand that.
25 A
The operators had looked at the high pressure y
y',-w.
,r e-u-
1 Hickey 27 (3
G 2
injection flow right after the incident started when we 3
got down to 1600 pounds.
And they observed very low 4
flow, if no flow, through those high pressure injection
(
(!
5 lines.
But they share a common line with our makeup 6
pumps which are high head pumps, and the high pressure 7
injection pumps were pumping against the head of the 8
makeup pumps.
9 Q
What was the result?
the makeup puEps were putting 10 A
The net result was i
11 in 140 gallons per minute and the high pressure injection 12 pumps were not putting in water at the initial phase.
O 13 Q
You said that at one point an operator 14 identified voiding.
Is voiding the same as boiling?
15 A
It is.
16 Q
Did the boiling or voiding that was occurring 17 have any effect on pressurizer water level?
18 A
It did.
19 Q
What effect did it have?
20 A
Voiding within the system displaces water in the 1
21 system and the water is displaced to the pressurizer.
!']
22 so therefore the pressurizer level would increase.
23 Q
You say it would increase.
Did it in fact-()
's,,,j 24 increaseyon September 24, 19777 25 A
It did increase.
'I
Hickey 28
T
.b 2
Q How high did it increase in response to the 3
boiling in the reactor coolant system?
-4 A
It increased t.'
the top of the pressurizer.
5 Q
Before the Three Mile Island accident, could 6
the Babcock & Wilcox simulator substantially reproduce
.the Davis-Besse September 24, 1977 transient?
8 A
No.
9 MR. KOLB:
Just, again, Mr. Hickey, please 10 wait until he finishes the questi.on.
11 BY.MR. SELTZER:
12
{)
Q In what ways could the B &,W simulator not 13 substantially reproduce the September 24, 1977 Davis-14 Besse transient?
15 A
The B &.W simulator could not model a mixed phase 16 within the reactor coolant system nor could it model --
17 once_the pressurizer became solid it coulhnotmodel the 18 transient at that particular time.
And the simulator had 19 limitations on being abib to model multiple casualties.
90 Q
When you use the phase could not model, what 21 does that mean?
A It means'that the -- basically'the mathematical 23 model within the computer was not sufficient enough to I
\\/
24 -
cause the simulation to occur.
.Q Is there a computer-that is an essential part m
y 4
rr3,r-e
---w 7
I
'l i
g Hickey 29
/g
(_f 2
of B & W simulator?
{
4 y,,,
3 4
Q And that's the computer you're referring to?
5 3
y,,,
6 Q
You said that the simulator could not reproduce a mixed phase.
What is a mixed phase?
8 A
That would be saturated conditions within the 9
reactor coolant system itself.
The pressurizer of course 10 t
wgs designed -- the pressurizer itself was designed to 11 handle this mixed phase, saturated conditions.
But the e
12 reactor coolant system was modeled as being subcooled or 13 not Saturation conditions within that.
14 Q
Just to try to tie your use of the word 15 saturation to words that you have used previously, when 16 there is a saturation in the reactor coolant system does that produce boiling and voiding?
18 A
Saturation is a condition whereby yo_u have your
{
temperature at which steam and water exist.
And when 20 you have steam and water existing at that particular 21
{
interval, yes, you could have boiling and do have boiling.
~~
Q Does satura, tion refer to the physical effect 23 of. water molecules becoming saturated with or absorbing r
4 enough heat to go from a liquid phase to a steam phase?
25 A
That is correct.
t Hickey 30 O\\
U 2
Q You said that the B & W simulator could not 3
reproduce the condition of a solid pressurizer.
In your 4
experience what happened at the B & W simulator if an 5
operator took it to the point of solid conditions in the 6
' pressurizer?
7 MR. KOLB:
Objection as to form.
8
- BY MR. SELTZER:
9 Q
Let me lay a foundation then.
t 10 were you ever present when the B & W 11 simulator was taken up to the point where the pressurizer 12 became solid?
13 A
I have seen that occur on -- in an examinating 14 atmosphere, yes.
15 Q
what is your understanding of,what happens to 16
- the B & W simulator's ability to continue simulating or 17
-reproducing the transient conditions at the point when 18 the. pressurizer has gone solid?
19 MR. KOLB Ohjection as to form.
20 THE WITNESS:
The indications that are given
. (.
that.particular time have nothing at all to do
/
21 at 22 with plant' conditions.
It's a ramdom generation 23 of indication.
It's a.different thing to identify
. D(_) ?
24-
-all the-indications'that would be involved, but it 25 idoes not simulate the condition nor the parameters f.
.-....,.i
.i_
._.s
...Trg r--
-l1-
I Hickey 31 Iv 2
that are associated with that condition, or did 3
not.
Did not.
4 BY MR. SELTZER:
k 5
Q You're saying that prior to the Three Mile 6
Island accident it did not correctly show the conditions 7
in the plant?
8 A
That's right.
That's right.
l 9
Q You said that the B &' W simulator had t
10 limitations on being able to model multiple casualties.
11 What are multiple casualties?
12 A
A multiple casualty would be when the initiating 13 event is of one type and there is additional casualties' 14 i
that occur after the initiating event.
15 I
Q Was the Davis-Besse September 24, 1977' event I6 a multiple casualty?
18 A
It was.
18 Q
What were the successi've features that made 19 it a multiple casualty?
20 A
We had a steam feedwater-rupture control trip on 21
{
the initial casualty.
We had a loss of feedwater on-one steam generator which would have been another casualty.
23 We had a LOCA, loss of coolant accident because of the CT
\\s) 24 PORV, the power operated relief valve lifting.
So that's i
25 a sequence of at least three that contributed to a
1 Ilicke y 32 (1).
2 multiple accident.
3 Q
You referred to a loss of coolant accident 4
when the PORV lifted.
5 A
railed to open.
6 Q
In your September 24, 1977 event, the 7
pressure in the reactor coolant system rose to the 8
point which the pilot operated relief valve was 9
designed to open, is that right?
i 10 A
That is correct.
11 Q
Then you need the phrase just now of failed 12 open.
In the September 24, 1977 event did there come a 13 point in time when the pilot operated relief valve failed 14 to close when it should have closed?
15 A
That's correct.
IG Q
Is it correct that during the September 24, 17 1977 event there was a complete loss of all main 18 feedwater?
19 A
That is correct.
20 Q
And in addition to the complete loss of all
(
21 main feedwater, there was a partial loss of auxiliary 22 feedwater?
23 A
That is correct.
Ok/
24 Q
And as you have described it, there was a 25 complete loss of auxiliary feedwater to one s t e ata
1 Hickey 33 O
generator, is that correct?
3 A
That is correct.
4 Q
And the second steam generator was being fed 5
with auxiliary feedwater?
6 A
That is correct.
7 Q
You said that there were limitations on the 8
simulator being able to model or reproduce multiple 9
casualties.
What did you mean by limitations?
A-The simulator responded to a casualty, but when 11 that casualty was compounded by additional factors or 12 casualties, then it did not have the capability to put 13 or to relate this new casualty with the other one 14 casualty and to crank forth a logical simulation.
15 Q
What do you mean crank forth?..
16 A
In other words calculate or simulate -- digest'the II
'^
material and produce the effects on the simulator.
18 Q
Before the Three Mile Island accident, to 19 your knowledge, was B & W reproducing any events on its 20 simulator which showed a pilot operated relief valve 21
{
failing to open?
22 g.
.There were not before.-
23 QL Before the Three Mile Island accident, what o~4 is the closest that B & W came to reproducing the.
{
V~
25 september 24 transient on its simulator?
-1
~
Hickey 34
(-
C/
2 MR. KOLB:
Objection as to form.
3 MR. SELTZER:
What is the basis of the 4
objection?
5 MR. KOLB:
You're asking him to tell what 6
happened at simulator sessions he was never at.
7 MR. SELTZER:
I said to the best of his 8
understanding.
9 MR. KOLB:
I understand, but it's obviously
(
10 a question that goes well beyond the state of the 11 knowledge of the witness and inappropriate.
12 BY MR. SELTZER:
13 Q
From all of the simulator training sessions 14 that you observed and that you received reports on, 15 could you tell me what is your understanding as to the 16 closest that B & W ever came before the Three Mile 17 Island accident to simulating any event like the 18 Feptember 24, 1977 Davis-Besse event?
19 A
Probably the loss of feedwater, which was a portion
.20 of our incident, and another simulation that would have
{
21 somewhat the same kind of a playback would be a steam 22 leak.
23 Q
when you say the same kAnd of playback you r
I k
24 mean the same kind of playback as a loss of feedwater 25 event?
l i
Hickey 35 0
2 A
It would have some of the things the indications 3
would track that of our 1977 incident.
4 Q
In the loss of feedwater events that were I
5 simulated on the B & W simulator, what was the system 6
response that the simulator showed the operators?
7 MR. KOLB:
Objection as to form.
O THE WITNESS:
On loss of feedwater?
9 BY MR. SELTZER:
t 10 Q
Yes.
What was the response'to the loss of
.11 feedwater event?
12 MR. KOLB:
Same objection.
13 THE WITNESS:
Loss of feedwater caused a I4 reactor trip and normal reactor trips cause PORVs 15 to operate.
And in some cases safety features 16 actuation would occur.
17 BY MR. SELTZER:
18 Q
What safety features actuation?
19 A
High pressure injection.
20 Q
After the simulator showed reactor trip
{
21 pilot operated relief valve operation and operation of i
22 high pressure injection, would there be any more to the 23 simulated event?
O 5~/
24 A
The normal-sequence would be to reestablish 25 Fressurizer level in the operating band and then that
1 Hickey 36
/]
V.
2 would be the termination of the incident.
~
3 Q
In a steam break is that a break in a steam 4
line?
(
5 A
Yes.
6 Q
Where is that steam line that you're 7
referring to?
9 8
A Any kind of a steam line break would have some 9
feedback that would be useful to the operator in being 10 able to identify other casualties.
Steam line break 11 gives you, depending upon the size, it can give you an 12 overcooling accident which is part of the -- or could be 13 part of an incident like we had at DB where we 14 depressurized.
You can end up depressurizing due to 15 rapid heat removal through the steam generators.
16 Q
When you have more rapid heat removal than J
17 is the desired heat removal for any particular point in 18 time, is that called an overcooling event?
19 A
Yes.
20 Q
And is the overcor ~ Ang an excessive cooling i
21 of the reactor coolant system?
22 A
That is correct. of a portion of the reactor 23 coolant system.
1 O)
(,
24 Q
Does the drop-in temperature produce a drop 25
.in pressure in the reactor coolant system?
g Hickey 37 2
Q Does the drop in temperature produce a drop 3
in pressure in the reactor coolant system?
4 A
In most cases.
5 Q
In most cases then when you have a drop in 0
temperature resulting in a drop of pressure in an 7
overcooling event, can that drop in pressure also cause 0
an actuation of the high pressure injection system?
9 A
It can.
t 10 Q
Has B s w simulated such overcooling 11 transients resulting in high pressure injection systems starting on its simulator?
13 A
.Yes.
l 14 Q
Have you had such overcooling events at-the 15 Davis-Besse plant?
16 3
y,,,
17 Q
when the high pressure injecti.on system 18 automatically initiates during an overcooling event, is 19 it responding in any way to a loss of coolant accident?
20 MR. KOLB:
Could I have that question again, 21 please?
(REPORTER'S NOTE:
Pending question' read 23-back-by reporter.)
w/
24 MR.-KOLB:
I will~ object to that too as to 25 form.
4
t i
Hickey 38 2
BY MR. SELTZER:
-l 3
Q In other words, if I was in any way unclear, 4
I'm asking whether, during an overcooling transient, is
('
l 5
there generally also a loss of coolant accident in i
6 progress?
7 MR. KOLB:
Objecti'on as to form.
8 THE WITNESS:
Not necessarily so.'
9 BY MR, SELTZER:
t 10 Q
Would it be a multiple casualty if you had 11 both an overcooling transient and a loss of coolant 12 g']
accident?
V 13 A
In most cases that would be the case.
14 Q
.Have you had overcooling transients at the 15 Davis-Besse plant that did not involve any loss of 16 coolant accident?
17 A
Yes.
18 Q
Other than the September 24, 1977 event has 19 Davis-Besse plant experienced any other loss of coolant 20 accidents?
21 A
No.
Q In an everco,oling transient that leads to 23 initiation or starting of high pressure in injection,
-A 2I does there come a point in time during that event when 25
}. the operators must manually secure or shut off high I
1 Hickey
(~T 39 V
o pressure injection?
3 A
There is a period of time when that point is l
4 reached, that is correct.
5 j
Q Before the Three Mile Island accident, could 0
the B & W simulator reproduce any condition of boiling 7
in the reactor coolant system?
MR. KOLB:
Would you read that back, please?
(REPORTER'S NOTE:
Pending question read 10 back by reporter.)
THE WITNESS:
Only the pressurizer.
BY MR. SELTZER:
13 Q
Not in any.other part of the reactor coolant 14 system?
15 A
Not in any other portion.
16 Q
You said earlier that in your Davis-Besse 17 September 24, 1977 event, it was the boiling in the 18 main portion of the reactor coolant system,that has 19 forced the water level to rise in the pressurizer.
Is that right?
.(
MR. KOLB:
Objection as to form, oo
- ~
THE WITNESS:
That's correct.
The hot a*3 piping within the reactor coolant system caused C\\
24 an expansion'of the water.
25 BY MR. SELTZER:
Hickey 40 0
2 Q
Before the Three Mile Island accident could 3
the Babco'k & Wilcox simulator reproduce or simulate c
4 boiling in the reactor coolant system main control S
forcing water up into the pressurizer?
6 MR, KOLB:
Objection as to form.
7 THE WITNESS:
It could not.
8 BY MR. SELTZER:
9 Q
Is the inventory of water 1,n the reactor 10 coolant system that exists outside the pressurizer 11 sometimes referred to as the primary control volume?
()
A It's referred to as the primary inventory.
13 Q
Throughout the time that you have been in 14 charge of training of nuclear operators at Davis-Besse, 15 who has been the person at Babcock & Wilcox who has been
{
16 in charge of the B & W training program?'
17 A
Norm'Elliott.
18 Q
Were you at the Davis-Besse plant on the.
19 evening of September 24, 1977 when the transient that day 20 commenced?
/
21
(
A Not at the time that the transient commenced.
22 Q
When did you-first find out that the 23 g~,
Davis-Besse plant had or was into the September 24, 1977 d
24 transient?
25 A
I found:out about it immediately after they had
1 Hickey O
,41
}
made the reactor compartment entry, containment entry.
3 And that was a matter of hours after the incident.
4 Q
Did you return to the plant that day?
5 A
Either that night of the first thing in the 6
morning.
It's difficult for me to remember exactly the I
time frame, but not later than the next morning.
8 Q
What, if any, steps did you take to inform yourself about the September 24 transient?
10 A
I communicated with the operators who were on I
shift, attended the debriefing session of the operators
()
which was held immediately after the incident, talked with our engineering staff, commenced the gathering information that I felt was -- would be needed to identify whether in fact we had training' problems or 16 whether it was strictly a mechanical failure.
17 Q
You testified earlier that after the 18 operators saw the pressurizer water level rising for the 19 first time they terminated the high pressure injection.
90 Did there come a point during the
(,
September 24 event when the operators took any other 21 action to attempt to correct the rising pressurizer water 9~3
,g level?
?
1
\\~/
94 MR. KOLB:
Objection as to form.
THE WITNESS:
Yes, the operators observed I
1 Hickey 73 42
\\
2 the pressurizer level increasing and immediately 3
opened the letdown valve which is used to divert 4
water from the reactor coolant system to either 5
the purification system or storage tanks.
i 6
BY MR. SELTZER:
7 Q
Did they initiate maximum letdown?
i l
8 A
They did.
9 Q
What was the purpose of doing that?
t 10 A
To decrease the pressurizer level'to within the 11 operating band.
12 Q
Where on the reactor coolant system is the 13 letdown valve?
14 A
It comes'off the make.up purification system and it 15 diverts water from the letdown coolers back into the 16 makeup tank or the purification system.
17 Q
Did you form a conclusion as to whether the 18 action of the operators in terminating high pressure 19 injection when the pressurizer water level first rose was 20 consistent or inconsistent with what they had learned
{,
21 from their training with B & W?
22 A
The operators reacted to what they had learned.
23 Q
Did'you form a conclusion as to whether the
-O 24 action by the operators in initiating. maximum letdown 25 was consistent.or inconsistent with what they had learned
1 Hickey 43 from training by B & W7 3
A They reacted as they had learned.
4 Q
How long did it take for the operators to 5
close the block valve behind the stuck open pilot 6
operated relief valve?
'T A
Approximately twenty minutes.
8 Q
Did it concern you that it had taken the 9
operator so long to close the block valve?
t 10 MR. KOLB:
Objection as to form.
11 THE WITNESS:
It concerned me until I
()
analyzed the total incident.
BY MR. SELTZER:
'4 Q
What do you mean until you analyzed the total incident?
16 A
Some of the indications of our particular incident 17 I
were confusing to the operator.
And the fact that we 18 had only one day of power on the core gave-indications 19 that would not necessarily be present if we would have 90
~
had more power, more days of operation of the core.
(,
The trend that existed at that particular time
~
within six seconds after the incident occurred, we had
~3 3-
{
pressure decreasing and also we had temperature
\\)
m '
o4
~
decreasing even though in-certain sections of the 95
~
system, sections that weren't readily monitored within
i Hickey 44 O
2 the reactor coolant system, we did have saturated 3
conditions.
4 So analyzing their particular -- at that time --
(,
5 our operators' response was within the acceptable 6
guidance for that period in time.
7 Q
When you say you had pressure decreasing 8
within six seconds after the onset of the event --
9 A
Yes.
5 10 Q
So pressure was decreasing prior to and at 11 the time that the operators terminated high pressure
()
injection?
13 A
Yes.
Temperature was decreasing also.
Q Under the procedures that you had in effect 5
at the plant at that time, do you know whether it was 16 consistent with the procedures or inconsistent to terminate high pressure injection when pressure was 18 decreasing?
19 A
The guidance that was provided and procedures at "O
that time relied heavily upon training experience of the 2I
(
operator.
And the operator.
And the operator was
. expected to be able to identify the point at which he 93
~
secured high pressure injection.
94 Q
I'm sorry, he was what?
5 A
Due to his training and experience it was up to
1 Hickey 45 fh O
2 the operator to identify the point at which he 3
terminated high pressure injection by the old guidance, 4
procedural guidance.
5 Q
Was there anything in the training or 6
procedures regarding the u: e of pressure?
7 What I'm driving at is in the written 0
procedures -- did you have written procedures at that 0
time?
l 10 A
Yes, we did.
11 Q
Did the written procedure, to your knowledge, 12 make any reference to pressure in the reactor coolant 13 system as being a system measuroment that was supposed to 14 be checked before high pressure injection was terminated?
15 MR. KOLB:
Would you read the question back?
IO (REPORTER'S NOTE:
Pending question read back 17 by reporter.)
~
18 THE WITNESS:
At the time of the incident 10 that was not one of the items that was in the 20 procedure.
(,
21 BY MR. SELTZER:
22 Q
You said that it took approximately twenty 23 minutes before the operators closed the block valve.
Is 24 that approximately twenty minutes between the time that 25 the pilot operated relief valve fa'iled in its open
f I
g Hickey 46 O
2 position and the time that the block valve behind the 3
pilot operated relief valve was closed?
4 A
Yes, that is correct.
5 Q
During thosr twenty minutes the loss of 0
coolant accident occurred?
I A
That is correct.
Q Was it your desire that in the future you O
wanted Davis-Besse operators to be able to respond more
,i 10 quickly to events such as you had seen on September 24?
A That is correct.
Q Did you ever tell anyone from B & W that you wanted B & W's assistance in training the operators so 14 that they would be able to respond more quickly to events 15 such as had occurred on September 247 10 A
I requested training on the September 24th 17 incident.
18 Q
To whom did you make that request?
A Norm Elliott.
"O Q
When is the'first time that you spoke to tiorm 21 Elliott about that?
A Within a few days after our incident.
23 Q
Where did you have the discussion with Norm O
,4 Elliott-about this?
25 A
At the plant site, fifth floor of the site.
l h_..
_ _ _ = -
i Hickey 47 O
2 Q
What was your understanding as to why Norm 3
Elliott was at the Davis-Besse plant shortly after the 4
September 24 event?
5 A
We were discussing the schedule for the next year.
6 simulator schedule and services that we were expecting
)
to get from B & W for the next interval of time.
8 i
Q For approximately how long did you meet with 0
Norm Elliott?
t A
A portion of the day.
A few hours.
I Q
Did you discuss the September 24th abnormal I
("}'
event with Norm Elliott?
A We did.
I4 Q
What did you tell Norm Elliott about the 15 event that had occurred on September 247 16 A
We ran through the scenario that had been prepared 17 for us and discussed the events that were within the 18
- scenario, 19 Q
Just so that the' record is clear, what were 90
~
the principal events that you described to Norm Elliott
.(~
.as part of the scenario?
.A-The initiating event, the operator actions that
! were taken, the sticking open of the PORV, the loss of o4 coolant and the apparent discrepancy in pressure levels o5
~
that the operators witnessed.
1 Hickey 48 2
Q What do you mean by apparent discrepancies?
l 3
A Well, apparent being that the operators were more 4
or less surprised that it would have -- the indication 5
would have been that way.
They were able to recall other 6
incidents that had occurred at similar kinds of things 7
but they were at that particular time trying to draw 0
directly upon training or training events and it did 9
track with their minds, t
10 Q
Had you become aware at the time or shortly 11 after the September 24th transient, that pressurizer 12 water level was rising at a time when reactor coolant 13 system pressure was falling?
14 A
Would you repeat that?
15 (REPORTER' S NOTE:
Pending question read back 16 by reporter.)
'II THE WITNESS:
Yes.
10 BY MR. SELTZER:
19 Q
Did you discuss that with Norm Elliott?
20 A
We discussed that phenomenon, yes.
(-
21 Q
When you said you discussed with Norm Elliott 22 the operator actions taken, what operator actions were 23 you referring to?
~
~
24 A
The length of time that it took to identify the 25 cause of the incident and the-termination of high
1 Hickey 78 49 2
pressure injection.
3 Q
Did you also -- I'm sorry, were you going 4
to say something else?
5 A
And the termination of high pressure injection was 6
more in the context of the fact that high pressure 7
injection was terminated while there was still a leak 0
occurring, more than anything else.
9 Q
Did you discuss with Norm Elliott what your t
10 understanding was as to what had induced the operators 11 to terminate high pressure injection at that time?
In l
12 other words what indications the operators were acting 13 upon?
I4 A
We discussed the indications that the, operators 15 responded to but we did not discuss the root cause of why 16 they responded to it.
17 Q
Among the operators actions that you 18 described to Norm Elliott, did you also describe that the 19 operators had initiated maximum letdown?
20 A
Without being able to reproduce the initial
(
21 scenario I would not be able to respond to that.
If it 22 were in the original scenario, yes, we discussed it.
U L R E P O R T E. S NOTE:
Brief recess taken'at
^f 3\\
\\
,4 13:00 a.m.)
~
25 (Resumed at 11:16 a.m.)
. - -.~. - -.
1-Hickey Sr
- O.
2 (Off the record d'iscussion held.)
3 THE WITNESS:
The first commercial date 4
j was at 40 percent rather than 15 percent, and 5
that occurred in December of 1977.
And the 75 0
percent commercial date was in January of 1978.
7-BY MR. SELTZER:
8
_. Q Just before the break you were describing a 9
meeting.which you had with Norm Elliott shortly after L
10 the September 24, 1977 event at Davis-Besse plant.
11 You testified that.you described the scenario of the September 24th event.
You testified tihat you let 13 Norm Elliott know that you were concerned about how the P
- 14 operators had responded and that it had taken them 20' 15 minutes' to close the block valve.
16 Did you make any request of. Norm-Elliott?
17 g
I.made a' request in the form of sim lator training.
I I wanted to be able to provide our operators with the 19 experience of going throt$gh our - particular incident on 20 the simulator.
h 2I' Q
When you.say "our particularl event" you.
22 mean the September 24th event?
..A
'The Septemb'er 24th event, that-is correct.
1 24 h
Q.
-would that include-showing.the operators the 25
.effect"of a stuck;open pilot operat'ed relief valve'?
~
5._
_~
l 1
Hickey 51 v
2 A
It would include the stuck open pilot operated 3
relief valve, the phenomenon with the pressurizer and 4
the pressurizer level.
Everything with the exception of
(
5 the initiating event.
The initiating event itself was 6
on a system that was not at all modeled on the Lynchburg 7
reactor.
It was a TECO, Toledo Edison SFRCS system.
8 So the initiation would have to be different but the 9
scenario from that point on -- we wanted to simulate that e
10 Q
You mean you wanted to simulate it from the 11
.6 loss of main water main feedwater, loss of partial O
12 g
13 A
And -- yes, initiation of high pressure injection, 14 termination of high pressure injection.
Both the 15 incident and the correct way to handle the incident.
16 Q
You said that you wanted B & W to include the 17 phenomenon with the pressurizer and pressurizer level.
Whak,were~youreferring 18 to?
19 A
The increase in pressurizer level with 20 corresponding decrease-in pressure within the reactor k
21 coolant system.
22 Q
Why did you want that training added to the 23 fg training that B & W was supplying on the simulator for D
24 your operators?
l 25 A-We had some real data at that particular pc^.nt.
o
r
' w --
s n-
'u
't s.
J
{
-/
+
1 Hickey o
,7~sx 52 L C/.
i 2
We had an incident.that'we had collected 3"
significant gmount of data, add I felt as though that s
l v;
4"
(
was one of the first opportunities for our plant, at Q
i -
s, l
5 L least, th)t we would be able to show a series of l
1 t
i s,
6,.
7 sincidents that'were Davis-Besse specific.
And people 7
would be able to re, late better to,that particular thing e'
w.
8 End be able to uhdsrstand that partic'ular_ occurrence
- s s
N 9
and better be equipped to handle future Kinds of t
/
10 incidente.
u_.
sIk was something that basically we had not II f
j
[ 12 discussed before as far as -- that I was aware of, that 13
,we had discussed before in any ob our training programs.
l 14 And it seemed appropriate that that should'be added as a 15 s,
module within our training.
o I6 Q
When you say " sit hadn't been discussed in any 17 of our training programs" do you mean all-five of the 18 areas of training that you described at the outset of 19, the deposition?
20 A
That is correct, that integ5ated -- that
(,
integrated kind of activity had never been discussed 21 22 in any of the five phases.
23 gS Q
What was Norm Elliott's response to your l
\\g --
24 request that the September 24th event be included in 25 B& W's training?
-1 Hickey
-O 53 2
A The response basically was the fact that the 3
simulator was limited in being able to do this 4
particular kind of incident, 'and that they could not 5
program it at that point, or were not willing to program, 6
one or the other, the simulator to do that particular 7-incident.
8 Q
How quickly did Norm Elliott respond to the 9
request that you had made?
10 A
In a relatively short period of ime.
I think 11 the final determination of that was not arrived at until 12 after he returned to Lynchburg, but there is indication 13 that it was not as simple as I might think it wourd be 14 at the same day of the meeting.
15 Q
You mean Norm Elliott told you'that 16 incorporating the September 24th transient into the l
17 B & W simulator.was not as simple as you might have 18 thought it was?
I2 A
Yes.
Yes.
20 Q
Did you ever make another request to B & W
(-
21 to include the_ September 24th Davis-Besse event in the 22 B & W simulator?
23
- 3 y,,,
v Q
Could you tell'me about that?
25 A
That was just a followup. just to touch bases
1 Hickey
/~N 54 b
2 again on the thing to more or less verify what I thought 3
I understood in the first communications.
4 And I contacted someone at the Lynchburg 5
simulator and discussed the incident and whether we O
could simulate the incident.
7 Q
What response did you get to that request, 8
your second request?
O A
The second request was the same, that the simulator couldn't do that particular thing.
11 Q
Do you know if anyone else from Toledo
,,(
Edison ever requested Babcock & Wilcox'to include the 13 September 24, 1977 Davis-Besse event in the simulator 14 training program?
15 g
7,,,
10 Q
Who made that request?
II A
Mike Derivan.
18 Q
When did he make the request?
19 A
He made the request when he arrived at the i
20 Lynchburg site for his requalification training.
('
21 Q
In what year?
A 1978.
93
~
.N
.Q What was Mike Derivan's position at Toledo Edison in 1978?
25 A
Mike Derivan had
I Hickey 55
,s k_
~
Q Let me back up.
3 Do you know what Mike Derivan's position was 4
in September 1977?
5 A
Yes.
6 Q
What was it?
A He was the relative position of operation 8
supervisor.
He was the acting operations engineer at 0
that particular time.
t 10 Q
Do you know what position he held in 1978 11 when he was going for requalification training?
()
A In 1978 he was either on my staff as the 13 requalifications instructor or still the acting 14 operations engineer.
It was within a month -- it was in 15 the transition phase of acting operations engineer to
^
16 requalification instructor.
Q What did' Mike Derivan request of B & W7 18 A
Basically a rerun of the September 1977 incident.
19 By rerun I mean to provide the simulation of that 20 particular incident.
(_
Q How did you learn that Mike Derivan of Toledo Edison had made that request of B & W?
0'3 gg A
Direct communication with Mike on that subject.
(s 94 Q
Was your communication with Mike a.
~ 25 conversation that you had with him in the regular course
Ol 1
Hickey 56 2
of business?
I 3
A Yes, it was.
4 Q
Toledo Edison had experienced the September 5
24, J977 transient and had done its own analysis of the O
sequence of events, is that right?
I A
That is correct.
8 Q
And you also had assistance from B & W in 9
analyzing the event and the sequence of events, right?
A That is correct.
11 Q
Why did you want to Davis-Besse operators
()
12 trained on.the simulator with regard to that event if 3
3 you had all this oth'er information on the event?
I4 A
The difference is between being able to read 5
either a scenarioaor a sequence of events'or being able 16 to live and experience that.
You would say that it's probably similar to-reading a book about flying an 18 airplane and then being able to get in the airplane and 19 handle the controls.
You need the feel.for the control.
20 You need the visual indication as a stimulus in order to
(
21 better understand the event.
If you read it on a piece
'~~
-of paper and the scenario becomes quite lengthy, the 23-r-
words become lengthy and all of this activity is
\\'
9~4
-occurring simultaneously'so you get a-different feel.
25 for-what is happening.
Whereby if you are discussing
I Hickey 57 2
temperatures and pressures and you're talking about 3
events that are happening a second apart for the operator, he's seeing that all at one time on the 5
i simulator.
He's not seeing it at the top of the page 6
And then again at the bottom of a page.
You get a much better -- much more comprehensive feel for an incident 8
on a simulator than you can by reading books or scenarios 0
or whatever, whatever the activity is.
So it's from that perspective.
Q In terms of what you have just been
.(~h 12 (j
describing, reading about it versus experiencing it, how 13 useful is it to hear somebody tell you about an event?
14 MR. KOLB:
Read it back, please.
15 LREPOP.TER'S NOTE:
Question read back by 16 reporter,1 17 BY MR. SELTZER:
18 Q
What I'm asking is, is hearing somebody tell 19 you about it like reading-it or is it like experiencing 0
it yourself on a simulator?
J MR. KOLB:
Objection as to form.
THE WITNESW:
To have someone read or 23
(~N discuss the incident is superior'to reading it, but
\\-
94 inferior-to simulation.
95~
~
BY MR. SELTZER:
l t
y.,..
1 Hickey 58 2
Q Was it normal for Toledo Edison employees to 3
make oral requests of Babcock & Wilcox for the inclusion 4
of specific items in the training of operators?
l 5
A Yes.
6 Q
Do you know whether Norm Elliott met with 7
any other Toledo Edison staff during the visit shortly 8
after the Davis-Besse September 1977 event?
9 A
I have no direct information on that.
I 10 Q
To your knowledge did Norm Elliott speak to 11 any of the operators or other Toledo Edison personnel 12 who had been in.the control room during the September 13 24th event?
14 A
I have no direct information on that either.
15 Q
If Norm Elliott had asked for' permission to 16 speak to the operators who had been in the control room 17 on September 24, would you have given him-that 18 permission?
19 MR. KOLB:
Objection as to form.
That's a 20 hypothetical question.
I think this witness ought l
(
21 to be asked fact questions.
22 BY MR. SELTZER:
23 Q
You may answer.
\\^')
24 A
Yes.
25
-Q If he had asked to see any other personnel who
t Hickey 59 O
2 had been in the control room during the September 24 3
transient, would you have given him that permission?
4 MR. KOLB:
Same objection.
5 THE WITNESS:
Yes.
6 BY MR. SELTZER:
I Q
Did. Norm Elliott ask to look at any data 0
that had been collected at the plant during the September 9
24th event?
I 10 MR. KOLB:
Objection as to form.
11 THE WITNESS:
We reviewed data that I had
[)
12 available at that particular time.
To my knowledge
%./
13 no additional requests were made.
14 BY MR. SELTZER:
15 Q
If he had asked for permissio'n to see other
(
16 data collected at the plant regarding the September 24 17 transient, would you have given him permission?
t' 18 MR. KOLB:
Objection as to form.
O THE WITNESS:
The B & W assisted us in 20 evaluating the incident, therefore it was already
(
21
- in B &.W's hands.
22 BY MR. SELTZER:
23 Q
All right.
Do you know.whether Norm met with 24 any other B & W staff at or'near the. Davis-Besse plant 25 when he came to visit in September 19777
i Hickey 60 bo 2
A He was escorted from a B & W trailer to the place 3
of.our meeting.
4 Q
Were the B & W employees in the trailer, to 5
the best of your knowledge or understanding?
6 A
There would have been someone in the trailer'for 7
security purposes.
8 Q
Who was the B & W site representative in late 9
September 19777 t
10 A
Fred Faist.
11 Q
You testified earlier that you gathered 12 information about the September 24 event by talking with 13 operators and by attending one or more~ meetings after 14 the event at which the operators and other personnel from 15 the plant discussed the event.
16 Did you determine why it took the operators 17 20 minutes to discover that the pilot operated relief 18 valve had failed in the open position?
19
.A Yes.
20 Q
What did you learn?
(
21 A
Learned that one of the causes for the delay was 22 that the indication that we had on valve position was 23 different than what we had assumed.
.The indicating
~
t
)
's~~/.
24 light was_a' light that told us basically that power was' 4
25 -
available to the particular pilot operated solenoid, had
1 Hickey 61 kJ 2
nothing to do with really the position of the pilot valve 3
for the PORV.
4 Q
You say that was different than what we had 5
assumed.
What had been assumed on the day of the 6
accident?
7 A
on the day of the accident the assumption was that 4
8 the indication was indication of the position of the 9
pilot valve not the signal to the pilot valve.
(
10 Q
Who had made the assumption'on the day of the 11 September 24 event.that the light indicated the position 12 of the pilot operated rel5Lef valve?
13 A
All the operators in the control' room.
14 Q
What did that light indicate to the 15 operators at the point at which the pilot operated relief 16 valve had failed in its open position on September 247 17 A
That the valve had in fact -- the operators 18 assumed the valve had shut because the signal was there 19 for the valve to be shut.
20 Q
To your knowledge, during any Babcock &
{
21 Wilcox training subsequent-to the September 24 transient 22 or abnormal event, and before the Three Mile Island 22 accident, did any B.&'W engineers _ address the Toledo g -lg
- ,~ ~ '
24 Edison operators about the' September 24 event?
25 A
Repeat that.
62 1
Hickey 2
Q Okay.
I want you to limit yourself to the 3
time period between the Toledo Edison event on September 4
24, 1977-and the Three Mile Island accident.
A Okay.
6 Q
And I'm asking you, during that time period 7
did any Babcock & Wilcox engineers, as part of B & W's 8
training program, ever address Davis-Besse operators 9
about the implications of the Septembeq 24 transient?
10 A
Not to my knowledge.
11 Q
Did they ever address,them about anything relating to the September 24 transient, to your 13 knowledge?
14
.A Not to my knowledge.
15 Q
Did any B & W instructors ever discuss the 16 September 24 transient with any Davis-Besse operators 17 during that same time period?
18 A
Not to my knowledge.
19 Q
I would like to show you a copy of what has 20 previously been marked GPU Exhibit 53 for identification.
(
21 A
It'is a description of post TMI plant. staff training prepared by Babcock & Wilcox^for a Nuclear Operating 23
(~}
Experience Conference apparently held in March 1980.
-f' 24 would you.take a look at the page that's 25 numbered 2 of.GPU Exhibit 53?- Do you see the heading at 1
1 l
l 1
Hickey 63 s
V 2
the top of the left-hand column, "Requalification 3
l Training"?
l A
Yes.
5 Q
Would you look, please, at the third 6
paragraph beginning with the words "Of particular I
importance -"
dc you see that?
1 8
A Yes, I do.
Q B & W states there, "Of pajticular 10 importance is inclusion of the small break, loss of i
11 I
coolant accident which produces plant responses similar (O
12 j
to Three Mile Island (E. G. pressurizer level going up 13 while pressure is going down and stable temperature and 14 pressure, but with reactor coolant system saturation 15 conditions.)"
16 To what extent, if any, are.the items that are described in that paragraph as being of particular 18 importance, items which you and Mike Derivan had been 19 asking B & W to include in.the training program prior 20 to the Three Mile Island accident?
(,
21 A
Well, I was happy to see that of course'that that oo I
was being included as part of the training program, 93
~
73-because I had placed a significant amount of importance N~j oz
~
on being able to do those particular things.
I felt, just t
95
~
looking from Toledo Edison's point of view, that we
1 Hickey 64 2
needed a capability in order to ensure that the lessons 3
that we had learned in 1977 would continue to be learned 4
by our operators as new operators replaced the old 5
operators and time went on.
.And I considered it a very 6
important part of our long-term training.
Q Were the items that are listed in the 8
paragraph that I read items that you had asked B & W to 9~
include in the training program after your September 24 10 transient?
11 i
A The September 24th incident that we had would have
(
incorporated each of those items, that'is correct.
I 13 Q
At the bottom of page two in the right-hand 14 column there is a simulator -- heading " Simulator."
15 Under that B & W states, along with the changes to 16 programs, "the performance of the B & W nuclear-power 17~
~
plant simulator has been improved."
18 The first full paragraph on page three it 19 i
states, "The first major simulator modification was the-20 inclusion of two phase conditions in the primary. control
(-
volume.
While saturation is not required to be 22 the classical loss of coolant accident, demonstrated on 23 j'N-the consideration of the small break demands that that.
- <.]
ng
~
condition be demonstrated to all operators."
95
~
Does that paragraph describe conditions which y
e
,w
+
-e
~-
1 Hickey 65 O
N~s'\\
2 you had asked B & W to incorporate in its training 3
program on the simulator prior to the Three Mile Island 4
accident?
5 A
The September 24th incident did have those 6
conditions existing.
7 Q
And did you ask B & W to include these 8
conditions in its reprogramming of the simulator before 9
the Three Mile Island accident occurred?
(
A We asked them to include as part of their training for Toledo Edison, a replay or a simulation of our
(^T 12
(,/
particular incident.
And that would have included those items.
14 '
Q The reference to two phase conditions in the primary control volume refers to including the 16 phenomenon of boiling or saturation in.the reactor 17 coolant system outside the pressurizer.
.I s that right?
18 A
That is correct.
19 Q
Would you look at the third full paragraph 90 on page three beginning with, "One of the most
(,
significant -" it states there, "One of the most significant modifications to the B & W simulator was on 23
.(-]
the pressurizer.
The pressurizer model had to be
\\s>
94
~
redesigned to allor the primary system to go solid and 95
~
recover, be completely voided, refilled, regain
i i
1 IIickey b(~N 66 2
temperature and draw a bubble."
3 What do you understand the expression " draw 4
a bubble" means?
5 A
Draw a bubble is to reestablish the pressure 6
control mechanism within the pressurizer itself.
In 7
other words increase the pressurizer to above the 8
temperature of the reactor coolant system, thereby 9
increasing the pressure of the reactor coolant system
(
10 above saturation.
'll Q
Does it also refer to establishing a two-12 phase condition within the pressurizer-with water on the 13 bottom of the pressurizer and a steam space on top?
I4 A
There would be two phases present, not a mixed 15 phase but two phases present.
16 Q
With wdter on the bottom and steam on top?
17 A
Yes.
18 Q
Were the modifications describ,ed in that 19 third paragraph changes in the B & W simulator which 20 Davis-Besse personnel had repeatedly asked B & W to
(
21 make prior to the Three Mile Island accident?
'22 A
The limitation on pressurizer modeling was not a 23 well understood thing by Toledo Edison nor its operators.
O
/
\\
24 We found out in the course of our requests that that was 25 a limitation.
But prior to that time we did not know
i Hickey 67
.O J
2 that was a limitation.
3 Q
I didn't speak clearly.
I think you 4
misunderstood me.
5 Were you asking B & W to make changes to its 6
simulator so that it could show a pressurizer behaving 7
in the ways that are described in this paragraph?
8 A
The requests that we had made on this September the 9
f24th incident would have provided, if we were able to t
10 simulate that incident, would have prov'ided that, those 11 changes in the pressurizer.
12 Q
How soon after the Three Mile Island accident l
13 did you learn that B & W had made the changes in its 14 simulator that are described in Exhibit 53 and which you 15 had requested after your september 24th event?
16 A
In a relatively short period of tine I a
(
17 surprisingly short period of time, I can'y tell you the 18 days that were involved, but we it occu_rred so fast 19 that we couldn't get commercial flights for people to 20 Lynchburg. And we chartered flights to get them down there
(
21 for the training.
22 Q
You said it was a surprisingly short period 23 of' time.
In what way was it surprising?
~
24 A
well, when someone tells me something is extremely 25 difficult to do, I just automatically attach some time
i 1
Hickey 68 O
2 frame to that and it exceeded the time frame that I had 3
established exceeded the actual time frame that was necessary in order for B & W to do that change.
5 Q
In other words it surprised you that they 6
were able to do it so much more quickly than you thought they had indicated previously?
8 A
Yes, due to what I had assumed the difficulty to be 9
Q And you were assuming the difficulty based
(
10 on what Norm Elliott and others had told you?
A Right.
I had assumed there was a significant 1
] )
amount of work.that would have to be done in order to do i
13 i
that.
14 Q
When you said that the change had been made 1
so quickly after the Three Mile Island accident that you 16 had to charter a plane to get your people down there, is 17
~
it your recollection that it was within a-matter of a 18 few weeks after the Three Mile Island accident that the 19 reprogramming took place?
90
~
A Ch, yes.
Definitely.
Within a matter of weeks.
(
Q Less than a month?-
99
~~
A Oh, yes.
(~(
Q In the training that'is given'to Davis-Besse s
24 operators today, let me ask you the following questions.
25 -
If the events of September 24, 1977 were to
(_
1 Hickey 69 (3
V 2
happen again are the operators trained that they should 3
or should not initiate maximum letdown?
4 A
It should not.
5 Q
If the September 24, 1977 events were to 6
occur again today, are the operators trained that they 7
should or should not terminate high pressure injection 8
on the initial rise in pressurizer water level?
9 A
They should not.
t 10 the' operator action Q
In your view today, was I
11 on September 24, 1977 in initiating maximum letdown and l ("}
shutting off high pressure injection proper and timely?
12
'v 13 A
The operators responded to what they learned and 14 within the guidance that was provided both procedurally 15 and otherwise.
IG Q
Today you would not have the operators 17 respond the same way, is that right?
18 A
Th'at is correct.
19 Q
In describing appropriate operator response 20 today, would you characterize what was done in response i
-(
to the. September 24th events as being proper and timely?
21
{
22 MR. KOLB:
Objection as to form.
l 23 BY MR. SELTZER:
' t' h
\\'"/
l 24 -
l Q
What I'm trying to say is not based on the f
l 25 training and-procedures that were in place then, but
1 Hickey 70
(
v based on what it is now your understanding is proper 3
plant operation, do you believe that the operators' 4
action in initiating maximum letdown and terminating 5
high pressure injection was proper and timely action?
6 MR. KOLB:
Objection as to form.
7 THE WITNESC:
In light of the new guidance 8
that we have on subcooling and other procedural 9
modifications and training changes, no, what was done
(
before would not be acceptable practice at this time.
11 BY MR. SELTZER:
Q It would not be proper and' timely?
13 A
It would not be.
14 Q
Is it correct that Toledo Edison prepared a licensee event report and a supplement li'censee event 16 report for the September 24, 1977 event?-
l A
That is correct.
l 18 Q
Did you prepare any portion of that?
19 A
Did not prepare any portion of it.
20 Q
Why?
Were you asked to review and approve
(
21 either of those documents before they were submitted to 2~9 the NRC?.
23 r~
A No formal review or approval was done by myself, i./
9~4 Q
On September 24, 1977 did the operators at 95
~
Davis-Besse plant have an~ emergency procedure for loss
1 Hickey 71 2
of reactor coolant and reactor coolant pressure?
3 A
They did, 4
MR. SELTZER:
I would like to mark for identification as GPU Exhibit 1,004, Davis-Besse 6 l l
Nuclear Power Station Emergency Procedure EP1202.06 7
LOSS OF REACTOR COOLANT AND REACTOR COOLANT 8
PRESSURE, together with revisions one through four.
9 (REPORTER'S NOTE:
GPU Exhi. bit 1,004 is marked 10 for identification.)
11 BY MR. SELTZER:
Q Is GPU Exhibit 1,004 a copf of Davis-Besse 13 emergency procedure EP1202.06, revisions one through 14 four?
15 A
Yes, sir.
16 Q
Can you state which revision of this procedure was in effect on the day of the' September 24, 18 1977 transient?
19 A
Revision one.
20 1
l Q
Were the subsequent revisions made after the l
(
21 L
September 24 transient?
22 A
Yes.
23 Q
Do you.know who prepared the original J
24 1 procedure?
25 MR. KOLB:
Objection as to form.
i L-
- - ~ - -
1 Hickey 72 O
BY MR. SELTZER:
3 g
nee.me ask you, what is your understanding 4
as to how this procedure was prepared?
I 5
A Procedures are normally prepared through draft 0
procedures supplied by the vendor and the station 7
engineers, and the station staff take the draft 8
procedure and modify and customizr, if you want to use O
that word, the procedure to fit the particular plant.
I 10 Q
When you say " prepared by the vendor" in II this case who is the vendor?
A The draft procedure would have been prepared by 13 B &
W.
Q Would you take a look at revision two, the 15 fourth page of that revision?
16 A
The fourth page?
Q Maybe I have done you a disservice by 18 stapling it that way.
It makes it harder _to find.
19 Do you see the note in the middle of that "O
page?
(, ;
21 A
Yes.
Q To the left of it there is a vertical line 93 and the number two is written to the left of the vertical 24 line.
Does that indicate that the text which appears 95 next to that line is the text that was changed as part
M 1
Hickey 73
/Q./ -
2 of revision two?
3 A
That is correct, that two would signify the 4
revision of that particular paragraph.
('
5 Q
That paragraph states, " Note: Prior to 6
securing high pressure injection, insure that a leak 7
does not exist in the pressurizer such as a safety valve 8
or an electromatic relief valve stuck open."
9 The electromatic relief valve is the pilot t
10 operated relief valve?
1 11 A
That is correct.
12 Q
Do you know why this revision was made in the 13 emergency procedure?
14 A
It was made due to the incident that we had had in
-15 1977, September 24th incident.
16 Q
Were you aware in or about December, 1978 that-17 that revision was being made in the DavishBesse 18 procedures?
19 A
-Yes, sir.
20' Q
Did-you think at the time that the time
(
21 change was a necessary change in the procedures?
22 MR. KOLB:
Objection as to form.
23 THE WITNESS:
The inclusion of that into our 24 procedures provided additional guidance to the 25 operator, therefore it was a good addition to the
1 Hickey 74 2
pr.ocedure, 3
Q Let me shift gears a little and ask you 4
how did you first hear about the accident at Three Mile k
5 Island?
6 A
The first indication or the first words of that 7
particular incident came to me very early in the sense 8
that I'm a -- while getting to work every morning I 9
usually listen to the morning news.
And there was just 10 a very small thing on the morning news that there had 11 been a problem at Three Mile Island.
Then of course when I arrived at work during the day we kept getting a 13 little bit of information but not very much information 14 throughout that day, Not enough at all to arrive at any 15 sort of conclusions as to what was occurring at Three 16 Mile Island in actuality.
17 Q
Shortly after March 28, 1979 did you hear 18 that the pilot operated relief valve had failed to open 19 at Three Mile Island?
20 A
Yes.
(
21
(
Q Did you hear that the operators had oo
~~
terminated high pressure injection in response to 23 9
rising pressure water level?
24 A
- Yes, 25 Q
Did you hear that they had initiated
1 Hickey 75 O
maximum letdown in response to rising pressurizer level?
3 MR, KOLB:
Just note my objection as to 4
form as to that question and the prior question.
f 5
THE WITNESS:
We understood that those things did occur, yes.
BY MR. SELTZER:
0 Q
At the time that you heard these things had 0
happened at Three Mile Island or shortly thereafter, t
10 did you draw any conclusion about any s'imiliarity between I
ll the events at Three Mile Island and the September 24, I
1977 Davis-Besse event?
13 MR. KOLB:
Objection as to form.
THE WITNESS:
We immediately drew those 5
y parallels.
Just the basic scenario, not the 1
16 l
I initiating event, but things past.the initiating l
17
~
event did in fact track our incident.
i BY MR. SELTZER:
l 19 Q
What do you mean "did track"?
"O A
In other words the lifting of the PORV, the 21
(
indication of pressurizer level, the termination of HPI all were things;that were incorporated in our LER as 23 being what we had occur at Davis-Sesse.
94-Q What was your reaction, if any, when you
- 9~5 heard that the-Three Mile Island operators had
I Hickey 76 2
terminated high pressure injection in response to 3
rising pressurizer water level?
4 l_
jr,
A It was a little harder for me to understand at I
\\
5 that point because we had had an experience ourselves.
6 And I guess I just had assumed that everyone had learned 7
something from that particular experience.
8 Q
As you talked with others did you form any 9
other reaction?
10
^
A Not immediately.
11 Q
Did you eventually?
A Yes.
13 Q
Did you learn at any point in time that the 14 Three Mile Island operators believed that they were 15 I
acting in terminating high pressure injection and in 16 initiating maximum letdown to-avoid letting the 17 pressurizer go solid?
18 A
That was my understanding.
19 Q
What was your reaction
- o that?
20 A
I knew that we did not have that concern at
(
21 Davis-Besse.
And without knowing in detail their system 22 and other things, I could not judge that.
But knowing 93
' 'i
~
/' )
i.
the Davis-Besse plant and the way that it's designed and
\\
24 the capacity of its components, it was not-the right 25 thing to'do at Davis-Besse.
I 1
Hickey 77 2
Q Did you discuss with any of the Davis-Besse 3
operators what preconceived notions or training they 4
had regarding letting a pressurizer go solid?
5 MR. KOLB:
Objegtion as to form.
6 THE WITNESS:
Our operators' response to the 7
second incident, the March incident was basically 8
the' fact that the from their viewpoint, the 9
operators responded'to the way that they had i
learned.
So --
BY MR. SELTZER:
1
/~
% }i Q
When you say the second incident, the March 13 incident, you're referring to the Three Mile Island 14 accident?
15 A
Three Mile Island accident.
16 Q
And when you say the operators had reacted the way they had learned --
A Yes.
19 Q
What operators are you referring to?
00
~
A That our Davis-Besse operators said of that
- 1
(
particular incident that the Three Mile Island operators
~
e,
~~
acted-in a fashion that they, the Davis-Besse operators' 03
~
~had learned originally.
\\q
' -)
94
~
Q Learned from whom?
05 A
Through their training programs.
1 Hickey
'Q 78 O
2 Q
All of their training programs?
3 A
Prior to the 1977 incident, yes.
4 Q
Do you believe that the training which 5
Toledo Edison asked Babcock & Wilcox to add to its 6
program after the September 24, 1977 event would have 7
helped the Davis-Besse operators safely handle an event 8
like the Three Mile Island accident?
9 A
Yes.
t 10 Q
How important do you believ'e simulator-11 supported training by B & W is in preparing operators to Y
l'I handle an event like the Three Mile Island accident on
.)
13 March 28, 19797
~
14 A
It's extremely important.
15 Q
In preparing Davis-Besse operators to handle 16 an event like the Three Mile Island accident, do you 17 think that such training on the B & W simulator is 18 extremely important for operators who experienced the 19 Davis-Besse September.24, 1977 event?
20
_MR.
KOLB:
Objection as to form.
{
21 THE WITNESS:
The September 1977 event was 22 an event that occurred in a frame of time that is 23 j_
extremely confusing to the operators.
Each 1
)-
\\
/
24 individual operator is seeing something different 25 be caus e. tue is paying attention to different l-1 i
79 1
Hickey
.(~)
v 2
parameters and looking at different things.
So if 3
you had five people in the control room and you ask 4
all five people to say what they saw, each one 5
would have something slightly different.
So 6
therefore, no single operator in the control room 7
could reconstruct the total event.
Therefore, in 0
order to train a person to handle the situation, 9
you're going to have to simulate the thing and have t
10 him be in a controlled environmen't whereby the 11 incident is played, forward for him and the simulation would be for the individual and the 13 simulation would be for the individual in I4 training.
MR. KOLB:
Read the' question and answer back.
16 (REPORTER' S NOTE :
Last question and answer read back by reporter.)
18 BY MR. SELTZER:
0 Q
I would like to show you what has previously 20-been marked GPU Exhibit 76 for identification.
It is 21 a memorandum from Mr.
J.
J.
Kelly of Babcock & Wilcox dated November 1,
1977, subject Customer Guidance on
~~
(
High Pressure Injection Operation.
,4 I would like you to take a moment to look at
~
25 it and then I would like you.to focus your attention on 1
?
1 Hickey 80 2
the two guidelines that are set forth at the bottom of l
3 Exhibit 76, 4
In your opinion, if the Davis-Besse operators I
5 had followed instructions along the lines contained in 6
Kelly's memorandum GPU Ex.hibit 76, would they have 7
maintained high pressure injection until the stuck open 8
pilot operated relief valve would have been discovered?
9 MR. KOLB:
Objection as to form.
t 10 THE WITNESS:
The guidance 'that's provided 11 there would have provided the operator with the
(
12 knowledge to maintain high pressure injection until 13 the LOCA condition had been terminated.
14 BY MR. SELTZER:
15 Q
LOCA is loss of coolant accident?
16 A
Yes.
17 Q
And the LOCA condition you were referring to 18
.is the stuck open pilot operated relief valve?
19 A
Yes, it is.
20 Q
I would like to show you what has previously
(,
21 been marked as GPU Exhibit 79.
It's a memorandum from 22 Bert Dunn to Jim Taylor.
23 MR. LIGHT:
What was the number of this O
24 prior exhibit?
25 MR. SELTZER:
Seventy-six.
.. ~.
7,,. -.
,-r,
,-~,m y
1 1
Hickey 81 BY MR, SELTZER:
3 g
Exhibit 79 is dated February 16, 1978.
It's 4
subject is Operator Interruption of High Pressure i
5 Injection.
6 Would you take a minute to review that, 7
please?
i 8
j In your opinion, if the Davis-Besse operators 9
had consulted a procedure worded like Dunn's recommended t
10 procedures in GPU Exhibit 79, would they have maintained r
11 high pressure injection until the stuck open pilot 1
(
operated relief valve'had been discover ~ed on September-13 24, 19777 I4 MR. KOLB:
Objection.
15 THE WITNESS:
The' February 16' memorandum 16 provides proper guidance, additional guidance for 17 the operator.
Therefore the operator would not havo 18 secured high pressure injection.
20 Q
He wouldn't have secured it until-the loss
(.
21 of coolant accident had been arrested, is that right?
A Until at least the loss of coolant accident had 4
23 been arrested and unti1~the temperature conditions, the 24 l
subcooling conditions had been reached in the reactor 1
25 coolant system, w-9--,
y--e
,---w,,w w <r-vwm.,:,,w,-w
.,,,,g--er%eyw---,y-,,.w++
=eg-w-ww-=,-
-y...yTv' em-
+e w'wN-+y+'F-e s -e ve=S---e c+-ev w we
+vt 5=--e-M<ee-v'wer**
r-p-'P-+-
r*--'y r--
)
l i
1 Hickey C>y 82 rn 2
Q When you say until the subcooling conditions 3
had been reached --
4 A
Yes.
5 Q
Is it correct that GPU Exhibit 79, Bert 6
Dunn's recommended procedures, require that the 7
temperature and pressure in the reactor coolant s3 stem 8
be 50 degrees below the temperature at which boiling can 9
occur in the reactor coolant system before high pressure i
10 injection can be terminated?
11 A
That is correct.
I~'\\
12 Q
Has Davis-Besse plant ever received
'% )
13 procedures like those described in GPU Exhibit 79, Bert 14 Dunn's memorandum from B & W7 15 A
We received draft statenents for procedures to be 16 incorporated from B &
W.
17 Q
Draft statements for procedures along the 18 lines contained in GPU Exhibit 797 19 A
That is correct.
20 Q
When for the first time did B & W give such
(
21 draft procedures to Davis-Besse?
22 A
Post Three Mile Island.
23 Q
Was it very shortly after the Three Mile
\\/
24 Island accident?
25 MR, KOLB Objection as to form.
-.m y
y,,,,r_,
yy m.
,-,,v r
w.,
4 i
Hickey S3 rN h
v 2
THE WITNESS:
Prior to our restart after 3
Three Mile Island, yes.
4 BY MR. SELTZER:
5 Q
Does that mean that you received it within a 6
matter of days or weeks?
I A
Within a matter of weeks, yes.
~
0 Q
Returning for a minute to GPU Exhibit 1,004 9
which is the loss of coolant, loss of gressure proeddure, 10 do you consider this procedure an important procedure to 11 plant safety?
("}
12 A
This is a safety-related procedur'e, yes.
I do V
13 consider it to be very important for plant safety.
14 Q
Do you know whether Toledo Edison ever 15 reported or otherwise made the NRC aware of the fact that 16 this procedure was being revised after the September 24 17 event in the manner in which this shows it was revised?
18 MR. KOLB:
Objection as to form.
Would you 19 repeat that?
20 BY MR. SELTZER:
(
21 Q
Let me try and restate it more cogently.
Do you know whether the NRC was informed or 23
- otherwise given information that Toledo Edison had x-o4 revised this procedure after the September 24th event in 25
.the way in which GPU Exhibit 3,004 shows it was revised
)
1 Hickey 84
(\\
2 after the 3
September 24th event?
4 A
Yes, I am aware.
5 Q
Did the NRC conduct any audit of Davis-Besse 6
to assure itself that changes had been made in the I
procedures to reflect the September 24th transient?
O A
They did.
9 Q
Do you know whether B &
W, the Babock &
10 Wilcox Company, has ever seen the revisions of this 11 emergency procedure which were made after the Davis-12 Besse September 24, 1977 event?
13 A
It would be strictly an assumption.
B & W 14 representatives are on the site and we work very 15 closely with those representatives on all matters that 16 pertain to the NSS system.
17 Q
Based on your understanding of now the 10 Davis-Besse site staff of Toledo Edison operates and 19 the way that Babcock & Wilcox site representatives at 20 Davis-Besse plant operated at or about the time that f
k 21 revision two was being made, is it your understanding 22 that Babcock & Wilcox personnel would have seen the 23 revision that was being made to this emergency procedure?
o 24 MR. KOLB:
Objection as to form.
25 THE WITNESS:
Yes.
I L_
1 Hickey 85
/"'g b
LREPORTER'S NOTE:
Off the record discussion 3
held.)
4 BY MR. SELTZER:
5 Q
Shortly after the september 24, 1977 6
transient, are you aware of whether the operators and I
station supervisory personnel requested some modifications to be made in the design or instrumentation >
0 of the plant in order to respond to what had happened on 10 September 24?
11 A
Yes, we made several requests.
(
Q What were those requests?
13 A
The first request that we wanted was modifications 14 to provide us with better indication of PORV position.
The second request was that we would like' to have an 16 interlock between the block valve and pressure such that 17 when the pressure in the reactor coolant system got to 18 less than 2100 pounds, that the block valve would shut.
19 And the third request was that we would like to 90 investigate the possibility of installing a trip signal
(,
21 from SFRCS system to trip the reactor when we received
~~
SFRCS actuation.,
93 Q
Did you concur in the desire to get the first
~
two items changed or installed?
25 A
I felt strongly that the operator needed to know j
l 1
Hickey 86 O
the status of that particular valve, and that the more information he had on the valve the better off he would 4
be and more positive the indication and the better off 5
he would be.
6 Q
The valve you're referring to is the pilot operated relief valve?
8 A
Pilot operated relief valve.
9 On the second one when we were discussing interlock 10 the installation of an interlock to shut a block valves 11 as far as I was concerned at the time, I thought it
()
needed further investigation and depended upon how good 13 the instrumentation was on the PORV.
And the normal 14 process to do those evaluations occur in the form of 15 FCR's, and that's what is normally generated in order to
^
16 get engineering input on these things.
17 Q
Was the interlock that was proposed an 18 interlock that would shut the block valve if the pilot 19 operated relief valve had failed in an open position?
00
~
A It would not discriminate on the pilot operated
(,
relief valve.
The interlock that was proposed would be anytime that the FCR pressure drops below 2100 pounds.
23 i
i the block valve would shut without discriminating to gg
%-)
og whethEr it was caused by the PORV or other.
l
~5 9
Q What, if anything, did Toledo Edison
1 Hickey 87 2
subsequently do on either of the first two requests?
3 A
Prior to startup, and I believe it was October of 4
1977 or during October of 1977, we installed a new 5
indicating light to give us a little better indication 6
of. pilot valve positions, the pilot valve or the PORV.
7 And it was, triggered by relay and a position relay, that-8 since the actual position of the pilot valve gave us 9
somewhat better indication of position of PORV.
t 10 Q
That modification still did not give the 11 Davis-Besse operators a positive indication of the
-12 position of the pilot operated relief valve, did it?
13 A
That is correct.
It did nqt.
14 Q
Have you subsequently installed at Davis-15 Besse plant a device which gives positive-indication of 16 the position of the pilot operated relief valve?
17 MR. KOLB:
Objection as to fo'rm.
18 THE WITNESS:
We have installed at the 19 Davis-Besse plant, a device that measures flow 20 through what we consider the tail pipe of the
{
21 relief valve.
22 BY MR. SELTZER:
23 Q
That's the pipe immediate ly behind the O
24 l'
A The relief -- the pilot operated relief valve.
25 And thels particular device measures the amount of
1 Hickey 88 e
i v
2 flow that's going through that particular piece of 3
piping.
4 Q
If gny one of the relief valves to the 5
pressurizer is in an open position or partially open 6
position, does this measuring device detect that flow?
7 A
That is correct.
8 Q
When was that device installed relative to the Three Mile Island accident?
t 10 A
Post Three Mile Island at our refueling outage.
11 Q
Is it something that you had been designing
/~N 12
(
l before the Three Mile Island accident?' By you I mean uJ 13 Toledo Edison and its suppliers.
14 A
Toledo Edison had been requesting a better 15 indicating device prior to our installation, of course.
16 Q
Did any representative of Babcock & Wilcox 17 ever tell Toledo Edison, to your knowledge, that an 18 automatic interlock to close the block valve had been 19 designed by B & W for its other plant?
00
~
A Not to my knowledge.
Q Prior to the Three Mile Islanf accident, had B & W ever given any training to Davis-Besse operators 23 on the simulator on any event which caused pressurizer g-
'V o4 level to rise at the same time that reactor coolant 5
system fell?
1
~.
~
i l
i t
Hickey 89 O;
s_
[
2 MR, KOLB:
Objection as to form.
l 3
l THE WITNESS:
None of the training that I l
4 witnessed, 5
BY MR. SELTZER:
i 6
Q Did you ever hear of any training supplied 7
by B & W that included that?
4 8
A No.
9 Q
You discussed the training that your 10 operators have received with them from time to time.
11 A
Definitely.
(
Q Do you discuss with them tr'aining sessions a.
that you have not personally witnessed?
d 14 A
Definitely.
Q After the September _24, 1977 bavis-Besse 16 transient, was Toledo Edison training its operators on the actions to take during a loss of coolant accident j
18 when the pressurizer level was going in one direction and 19 the reactor coolant system pressure was going in the t
i j
"O opposite direction?
(,
2I A
What interval of time did you ask?
~~
I Q
.After your September 24, 1977 event.
23 4 h MR. KOLB:
Objection as to form.
d 24 MR. SELTZER:
What should I clear up,-Dan?
25 MR. KOLB You can clear up whether that's i
)
i 1
Hickey f
/~N -
90 2
after the event but before TMI or just after the 3
event.
4 BY MR. SELTZER:
5 g
Okay, let me ask that for the interval after 6
September 24, 1977 and before the Three Mile Island 7
catastrophe.
8 MR. KOLB:
Objection as to form.
i 9
BY MR. SELTZER:
1 10 Q
During that period was Toledo Edison training
~
11-its operators on the actions that they should take during 12 a loss of coolant accident when the loss of coolant level 13 was-going up and reactor coolant pressure was going down?
14 !
A Toledo Edison operators were being trained that the I
15 condition could exist whereby the pressurizer level was 16 not indicative of the inventory in the reactor coolant 17 system prior to the Three Mile Island, yes.
18 Q
Was that instruction, instruction that was 19 stressed after the September 24, 1977 event at Davis -
20 Besse?
(
21 A
It was stressed in training in two different areas.
s 22 One was a cool down.
When you were performing a cool l
23 down in the reactor coolant system, conditions whereby l O)
\\-
24 you could get a rise in pressure, and it could occur at 25 that particular time.
And it was also looked at as the
i i
4 1
Hickey 91 O
2 i
September 24th incident with our operators during future 3
training.
4 Q
As a result of the September 24, 1977 5
i transient was additional stress placed on how the i
6 operators should react to rising pressurizer water leve17 7
A Yes.
8 Q
After the September 24, 1977 event at Davis-9 Besse and before the Three Mile Island fiasco --
t 10 MR. KOL3:
Objection as to form.
11 BY MR. SELTZER:
1 12 I
Q Was Toledo Edison teaching'its operators I
13 that saturation in the reactor coolant system, primarily i
14 volume, was a symptom of a loss of coolant accident?
I 15 j
A Toledo Edison operators were being. taught'that 16
,4 saturation conditions could occur as a result of a loss
~
i 17 of coolant accident, but not necessarily directed toward i
18 a symptom of.
19 Q
Was the fact that saturation or boiling could 1
20 occur as a result of a loss of coolant accident something that was given greater stress in the Toledo Edison
}
i 22 training l
t 23 4
A Yes.
?
24 i
l Q-You say yes.
Was it given greater stress 25 after the September 24, 1977 event and because of the 1
4 m.
..m.
m+
l 1
Hickey 92
/NU 2
September 24, J977 event?
4 O
MR. KOLB:
Objection as to form.
4 THE WITNESS:
Yes.
~
5 BY MR, SELTZER:
0 Q
You're responding yes to both parts of that I
question?
A Yes.
O Q
After September 24, 3977 and before the
=.
O Three Mile Island accident, was Toledo Edison placing 11 stress in its training of operators on the fact that the
()
operators should n,ot terminate high pre.ssure injection-based only on a reading of pressurizer water level?
1 14 A
That is correct.
15 Q
Was greater stress placed on'that after 16 September 24, J977 because of your September 24th event?
17 A
That is correct.
18 MR. SELTZER:
I have no further questions.
19 LREPORTER ' S NOTE :
Lunch recess was taken at 0
12:48 p.m.1
(
21 2:37 p.m.
no
~~
EXAMINATION BY MR. KOLB:
43
~
j Q
Mr. Hickey, would you tell us again for how 94 i
l long you were responsible for the training of operators
~
o-at Davis-Besse?
1 Hickey 93 2
A Yes, I came to Toledo Edison in 1974 and l
3 immediately started working with the operators at 4
Davis-Besse.
And started the first major programs -- we 5
started within.the Phase Five training programs which, 6
for the initial group of operators, first cold license 7
group was what we would call Phase Five, the final phase 8
of that training.
9 Q
During the time that you were responsible for 10 training and up until the time of the Three Mile Island
~
11 accident, can you tell me did you have occasion to visit 12 the simulator facility and the training facilities at 13 Lynchburg?
14 A
Yes, I did.
15 Q
Could you tell us how many times you visited?
16 MR. SELTZER:
I'm sorry, is_this over the 17 complete time from 1974 through today?
18 BY MR. KOLB:
19 Q
No, up to t.he time of the Three Mile Island 20 accident.
{
21 A
I can give some relative times on what that was.
22 Q
Just do the best you can.
23 A
okay.
We had, as I was stating before, O
i 24 I
approximately twenty-three people in the cold license i
25 group of which maybe twelve of them had already been
i 1
Hickey 94 O
%-)-
1 1
y
~
certified.
Our normal training sessions are three i
operators at the simulator at a time.
So that would 4
have meant at least four sessions for that first group 5
of cold people, i
6 The next group of people would involve again maybe 7
another four groups, and those four groups of people were 8
at the simulator for eight weeks, ten weeks.
9 Q
All told?
(
10 A
Between eight or ten weeks.
11 Q
When you say they were there you mean
()
altogether?
13 A
Altogether.
So that was broken down into again three or four groups.
i 15 Now I was at the simulator approximately once every 16 two weeks with each of those groups.
At the time I would 17 go to the simulator I would split my time-between the 18 classroom and the simulator phase.
If I --we had a group 19 of people in the classroom, I would of course be in the 20 classroom with them.
If we had a group of people in the (a
simulator I would be with them at that particular time.
99
~~
Not all classes that were present while I was there did If 23 g
attend nor did I attend all the simulator sessions but L) o
~~g fselectedones.
I saw each one of our operators when they were certified, in other words taking their certifying L.
1 1
Hickey 95 2
I exag and witnessed different training of the or 3
training of the individuals of the -- or training of the 4
individuals prior to their certification.
5 Q
You said there were 23 individuals.
6 A
In the cold license group.
7 Q
And are you indicating you went then to 23 8
sessions on recertification?
9 A
I witnessed a recertifications of those individuals.
10 yes, those 23 odd individuals.
11 Q,
And you also attended training, simulator 12
(
instruction periods in addition to the 23, is that 13 correct?
14 A
That's correct.
Excuse me.
they may have occurred.
15 on the same day or within the same week while being in the 16 simulator.
17 Now there is a hot license group that falls into I
f 18 j
the same category, And the initial hot license group l
10 I was down at intervals also to observe their training 20 and to listen to whatever complaints they may have to
(,
21 make their training fit the needs of the individual.
Q Did you go to all of'the sessions, the "3
simulator sessions that they participated in?
i i
fA l
24 Not all.
Not all the sessions, no.
I 25 Q
Okay.
Now can you tell me during your time
1 Hickey 96 2
as head of training, between the time that you started 3
and the Tnree Mile Island accident, how many times you 4
are observing a simulator instruction period or a
(
5 recertification in which pressurizer level was involved 6
as one of the events?
7 MR. SELTZER:
, hat do you mean as an event?
W O
MR. KOLB:
Or as a parameter that was 9
similar to the simulator instruction.
j t
10
'on't understand.
MR. SELTZER:
I object.
I d
11 MR. KOLB:
What is the basis?
I
[}
MR. SELTZER:
Ambiquity.
Because I think v
13 pressurizer -- levels of pressure are constantly I4 on display whenever the simulator is on.
15 BY MR. KOLB:
16 Q
Let me try to rephase it so it's as clear as 17 it can be.
1 18 Were there instances, Mr. Hickey, during 19 the period that we have discussed when the pressurizer 20 levels rising was an event that was part of the
(
21 instruction as you viewed it?
22 A
Yes.
23 Q
Could you tell us as an estimate, about how
(~]%
i 24 many times do you remember that happening out of the 25 total number of experiences you had?
, _ _ -. ~ _ _
1 Hickey 97 O
2 A
That would be total conjecture.from the point of 3
view that pressurizer level or variations in pressurizer 4
level occur on just about every casualty that you would 5
have on the simulator.
And any recovery from a 6
simulator casualty there would be variations in the 7
pressurizer level.
8 So if you're really sitting through the emergency 9
procedures section of the simulator training, you would 10 be bombarded with changes in pressurize'r level all the 11 time.
12 Q
Did all of those changes, as you recall,
)
13 involve situations where you might be going solid?
14 A
No.
15 Q
How many situations do you remember?
16 A
There is only a few situations whereby I had ever 17 seen anyone let the pressurizer get out of control.
18 Q
could you estimate, out of the. total number 19 of experiences you had, how many of those there were?
20 A
Very very few.
Again it would be conjecture.
{
21 As a minor portion, very very few people.
22 Q
You indicated, I believe in your testimony 23 i
this morning, that the simulator instruction you o1 observed from time to time tended to leave an impression 25 with operators'as to the reaction they should have'if they
~-.,,
l' i
Hickey 98 O
2 saw pressurizer level rising and getting out of control, 3
is that correct?
4 A
Rising, increasing.
Yes.
5 Q
Okay.
6 A
Not necessarily the response -- was not necessarily I
out of control.
The response was if they saw 0
pressurizer level increasing within or above the 9
operating band, but not necessarily out of control.
t 10 Q
And could you tell me -- I 'b e l i e v e y o u s a i d 11 that there was an instance where actually some operator 12 made a mistake in the sense that he let the pressurizer 13 go solid and people laughed.
Do you remember that?
14 A
That is correct.
15 Q
How many times did that happen?
16 A
The one time that I personally witnessed.
17 theway$inwhich, Q
Now am I correct that as 18 you observed it, the way in which the simulator 19 instruction was carried on, that each operator had 20 different experiences, that the simulator played out 21 different sequences for different operators?
22 MR. SELTZER:
Objection.
There is no 23 foundation that no two operators saw the same b
24 sequence.
25 l
MR. KOLB:
I'm asking him whether it was his
1 Hickey 99 2
observation that different operators observed 3
different sequences.
He apparently attended a 4
number of different sessions.
That's all I'm 5
asking.
6 THE WITNESS:
If a person were to go back 7
through and observe and look at the documentation 8
provided by B & W on the different transients, you 9
would find that t.here would be very little 10 difference between the number of transients that j
11 one operator -- or the kind of transients one 12 operator would see above another'one.
It was 13 basically an established program.
A person would 14 see.if they had problems in a particular area or on 15 a particular transient, he may see inore of that 16 same transient.
But if he was not having problems II and someone else was not having problems, if you 18 laid their documentation sheets side by side you 19 probably would not note a difference between the two.
20 BY MR. KOLB:
{
21 Q
You're talking about the training instruction 22 now, right?
23 3
7.m talking training instruction, right.
24 U
Q You're not talking about recertification?
i 25 MR. SELTZER:
That is part of training.
'l i
~
Hickey 100 f')
(m/
2 BY MR. KOLB:
3 Q
You indicated earlier that you had observed 4
some recertification sessions on the simulator.
5 A
Yes, the recertification sessions were conducted 6
primarily due to the fact that it had been so long that 7
our people had been to the simulator so they were 8
recertified prior to us sending them up for licensing, 9
that,'s correct.
E 10 Q
You had also observed perhaps ' sessions that 11 were for training purposes, not necessarily for
(~
12
\\_)}
recertification, is that correct?
13 A
That is correct.
14 Q
Now my question is to the recertification 15 sessions.
Am I correct that the various ' operators' were 16 shown, as far as you know, different sequences?
17' MR. SELTZER:
Objection.
No foundation.
18 BY MR. KOLB:
O Q
Go ahead and answer.
20 A
Especially during the recertification sessions,
(
especially during those sessions, the recertification 21 22 sessions stressed very heavily -- they were start-up 23 ; certifications, very heavy emphasic on start-up activities
(")h j
s 24 and therefore they did look almost identical in those 25 recertifications,
1 101 Hickey 2
Q In what sense identical?
3 A
certain number of heat ups, you did a certain 4
number of cool downs.
You did a certain number of this 5
and that.
And then when the exam was given, the exam 6
itself, you usually expected to have a leak, a 7
temperature element fail.
The operator himself, if they 1
8 were to talk with the person who had preceded him, would 0
probably be able to tell not necessarily the sequence L
0 that these would occur but the type of ' things that he 11 would be undergoing.
Q All right. There were similar types of sequences?
14 A
Yes.
1 Q
Right?
That's what you're saying?
MR. SELTZER:
He said they looked almost identical.
18 MR. KOLB:
If you don't mind, _M r. Seltzer, 10 I'll ask the questions and we will proceed.
0 MR. SELTZER:
Don't get upset at my 21 intrusions, I didn't get upset at yours.
MR. KOLB:
I'm not the least bit upset.
23
_7,m calm as could be.
(~N I
' ')
\\
24 l
MR. SELTZER:
I just object to your
- 5 mischaracterizing what the witness has already
i i
1 Hickey 102 l
2 testified.
3 MR. KOLB:
Well, I don't think I did. I take 4
it there were types of sequences that were similar
()
5 from operator to operator; leaks, temperature, 6
the elemental fails, is that what you said?
Give l
7 me the list again.
8 MR. SELTZER:
Let's have the reporter read it 1
9
- back, e
10 (REPORTER'S NOTE:
Pending answer read back 11 by reporter.)
12 BY MR. KOLB:
%J 13 Q
Now you have heard that answer back but I'm 14 going to ask you the question again.
What is the list 15 of types of sequences that you recall?
J.ust tell us 16 again.
And if you can add to the list you have given 17 us before, please do so.
~
18 MR. SELTZER:
You say the type of sequences?
~
19 I think the word sequence to mean -- you would not
[
20 know in what sequence these transients would be 21 given 22 MR. KOLB:
That he did say but I'm not 23 asking him what types of transients.
We're talking L.
24 about and he can use his own words, but I want i
25 him to tell me what the types were so we can take
1 Hickey 103 2
it from there.
3 MR. SELTZER:
And do you mean in addition 4
to the four types that he has already listed?
5 BY MR. KOLB:
6 Q
Just for clarity, I would like him to 7
include the ones he has already listed.
8 A
Okay.
We talked about LOCA conditions, steam leaks 9
temperature element failures, turbine trips, reactor
(
10 trips.
Usually the LOCA conditions were either small or 11 large breaks, small or large steam leak, that kind of 12 thing.
O l
13 Q
Just to take an example, when the operators 14 received their recertification simulator instruction did 15 they at that point all see the same sequence for steam 16 leaks?
17 MR. SELTZER:
When you saysepuencedoyou 18 mean transient?
19 BY MR. KOLB:
20 Q
The same thing played out on the 1
{
21 simulator?
22 A
They saw -- when you say the same thing, now not 23 the same thing.
They saw a steam leak.
{'
\\/
24 Q
But there are different types, aren't there?
25 A
Sure.
There could have been a steam leak in
I 1
Hickey 104 2
different locations, but the end result is basically the 3
4 Q
Is the same true that they saw different 5
(
A Different locations of LOCAs, yes.
Q And'the same would be true of other items 8
you listed?
There would be different sequences or 9
different displays on the simulator even though they r
10 would all have the common feature of being of the same type?'
1
(
A Yes, usually there is certain limitations to that.
13 A failure of a temperature element was a failure of a 14 temperature element.
There is no degrading, it just 15 failed.
So that everyone would see the same failure in 16 that case, Those are hard to change, hard to modify.
~
17 Q
Is that-the only exception you can list?
18 A
No, there are others.
19 Q
Can you list them?
20 A
Offhand I can't.
k, Q
Did the operators, that is your operators, I
~~
when they were not put through their recertification 03
~
training, did they always have the same instructor?
\\w-l
,4
~
l A
There were certain instructors that were supplied 25 by the engineering group of B & W and they would not
1 Hickey 105 f~g 2
necessarily have the same instructor nor would they have 3
the same lecturers in all cases.
If the lecture was 4
being supplied by the instructors that are associated a
5 with the simulator -- there were certain instructors 6
assigned to Toledo Edison personnel, in those days 7
certain ones that we had requested to be assigned to our 8
people.
And then in that case our people would interface 9
with the same instructor from class to class to class.
t 10 Q
okay.
Are you in a position to know who the 11 instructors would have been for the operators from Met (g
12
(,)_
ED or any other GPU subsidiary?
13 i
'A No, I would not.
14 Q
Did you ever attend any sessions where any 15 Met ED operator was being instructed?
16 A
No.
17
~
Q Did you ever attend any classroom or lecture 18 where any Met ED operator was being instructed?
19 A
I did not.
20 Q
I believe you said this morning that there
(
21
(
were some limitations on simulators that you had 22 observed, and I believe one of them was that you l
23 observed that it wouldn't model a mixed phase, is that 24 l
4 j
correct?
25 A
That's correct.
a 1
Hickey 106 O
2 Q
Could you just tell us briefly what that 3
means?
u 4
A Well, the conditions the simulator was designed for J
)
5 was for a subcool fluid or liquid in the reactor coolant 6
system itself and into the reactor itself.
And by mixed 7
phase we mean that basically if you end up with a O
saturated condition in say the candy cane or in the top 9
cf the steam generator, using that as an example, that 10 the model was not complste enough to t anslate that into 11 a performance package or[a operating package or 12 simulation.
13 Q
When you watched the simulator was it obvious that it had that limitation?
Obvious to you?
A It was not obvisous to me.
We discovered that only 16 after discussions on how to do certain things.
1
.Q How did those discussions take place?
MR. SELTZER:
Could we fi:: a point in time?
BY MR. KOLB:
20 Q
That will be fine in a minute but let me just 21 ask how they took place then we will get to the time.
~~
A Okay.
The discussions evolved around requests-for
- 3
~
the simulation of our September _24th incident..And at
~
( '1
,4 i
that particular time these kinds of -- this kind of 25 information came into light.
__ ~
1 Hickey 1
(~h 107 V
Q What kinds of displays -- what kinds of 3
programs could be run on the simulator if it was capable 4
of modeling a mixed phase?
5 A
Our September 24th incident would be an example of 6
something that could be true.
7 Q
Any other examples you could give of the kinds of things that could be done if the simulator was 1
9 capable of modeling a mixed phase?
10 A
.Any sort of a casualty that involved the reduction 11 of the subcooling margin, things that were not l~o
(
necessarily to the forefront of peoples' minds before 13 our September 24th incident.
14 Q
When you say not at the forefront of peoples' 15 minds, what do you mean?
16 A
I mean it wasn't something that a that was felt 17
~
to be likely to happen or possible to happen, that kind 18 of thing.
19 Q
When you say peoples' minds, what people are 90
~
you talking about?
(
A
- People, Just -- either the operators or our own 22 engineering staff.
23 Q
Okay.
Had you ever seen such an incident on
,f-}
(/
24 the simulator?
25 A~
As our September 24th?
k-
.. ~
1 Hickey 108 s
2 Q
- Yes, 3
A No, I had not.
4 Q
Were you ever, prior to the Septemberb24th
('
5 incident, conscious of the fact that such events were not 6
being displayed on the simulator?
I' A
No, I had not.
O Q
I believe you said that the -- you observed 9
that the simulator couldn't model multiple ~ casualties.
(
0 Is that your observation?
11 A
Yes, that's correct.
Q Where did you get that impression?
MR. SELTZER:
I object.
Th'at really 14 mischaracterizes his prior testimony.
He said it 15 had certain limitations on its ability to model 10 multiple casualties, not that it could not model 17 them at all.
18 THE WITNESS:
That is correct.
'BY MR. KOLB; 20 Q
Which is correct?
That you observed there 21 were limitations?
A There were limitations.
23 Q
What limitations?
- p)
's-24 A
Well, as an example, the example we could use is 25 an example where you have a leak compounded by a
_ _. ~ _ __,
t 1
Hickey 109 O
~
2 condition in the reactor coolant system of -- let me 3
think how I want to word this.
4 We started out with an SFRCS casualty.
We ended
(
5 up with a second casualty, a LOCA, our second casualty.
O The third casualty or third portion of this thing was 4
7 the shut down of high pressure injection.
We had 0
initiated high pressure injection.
That was a third 9
- sequence, And by shutting down high pressure injection 0
we had changed the characteristics of the plant and had 11 saturating conditions in the system.
That's another 12
- casualty,
.That's another incident.
s 13 So you put all of those one on top of the other 14 and you can't -- you couldn't digest all that material 15 and come out with a logical simulation.
i 16 Q
Did you know that?
17 A
Not until we requested that particular item.
And 10 I did not know --
19 Q
You never observed any such event or multiple 20 casualty display on the simulator, did you?
21 MR, SELTZER:
Objection.
He has already 22 testified that the simulator was not able to 23 display that.
AV 24 THE WITNESS:
We never saw any displays 25 because it'just couldn't do it.
. ~.
1 Hickey 110 (3V 2
BY MR. KOLB:
3
-Q Just wasn't there?
4 A
And that's the state of the art afterwards that I
{,
5 assume that simulation was.
6 Q
I'm not sure I understand.
What do you mean?
7 A
I assumed at the time that they told us it couldn't 8
~
simulate multiple casualties, that that was the state 9
.of the art of the simulator.
10 Q
I believe another limitation you mentioned 11 this morning was in the area of going solid where the 12 simulator could actually reflect what happened when one 13 went solid.
14 A
Yes.
15 Q
What did happen when the simulator reached 16 the point where it was to the point of going solid?
17 What occurred?
18 A
Okay.
You had erroneous indication of pressuri'zer 19 level, and the model ceased to give you reasonable 20 displays of the actual plant conditions at that point.
21 Q
Did you know at that point when you 22 observed that that the model could go no further?
23 A
I believe we understood that there was a problem
'rs
( )_
24 at that point because we had seen that kind.of activity 25 at the top end of the scale.
1 Hickey 111 0
2 Q
I take it you observed that before the 3
September 24, 1977 Davis-Besse incident?
4 A
Yes, I had seen that.
(
5 Q
I believe another limitation you mentioned 0
was simulation of open PORVs.
Do you recall was that I
something that you observed before September 24, 19777 0
A Simulator -- we never observed power operated 9
relief valves on the simulator.
0 Q
You just never saw that?
11 A
To my knowledge it was never simulated.
12
-s Q
Are.you saying that was a deficiency of the 13 simulator?
14 A
I'm saying that it was not simulated.
15 Q
And the final one you listed,was the 10 reproduction of the boiling in the SFRCS outside the 17 pressurizer.
I believe you indicated that was a IO simulation on the simulator?
I9 A
Repeat that.
20 Q
That you had not seen reproduction of 21 boiling in the SFRCS outside of the pressurizer?
22 A
I had not seen that on the simulator, that is 23 correct.
b')
V 24 Q
Is it your understanding that was a 25 limitation on the simulator?
l
112 1
Hickey I%J 2
MR. SELTZER:
Are you implying in your 3
question that that's something different than the 4
simulator's not being able to reproduce a mixed (n
5 phase?
0 MR. KOLB:
It's something different than that certainly.
MR. SELTZER:
I don't know.
I don't think 9
there is anything different.
I think you're 10 t
confusing the witness.
11 THE WITNESS:
I don't see the difference.
4 BY MR. KOLB:
('~)g 13 Q
You think those are equivalent?-
14 A
Yes.
15 Q
So your answer would be the same for both?
16 A
Yes.
I had seen -- we had seen that occur before II but not at the simulator.
Q Where had you seen it occur?
19 A
During hot functional testing on our plant before 20 the fuel was loaded.
21 Q
You saw it on the actual plant itself?
22 A
That is correct.
23 Q
Okay.
Just while we're on that subject, who
(~)N,
(
24 observed that?
25 A
The operators including Mike Derivan who happened i
,-----------,-.n.-
->-e.
.-s.
s
1 Hickey 113 0
2 to be in the control room at the time of September 24.
3 Q
Tell me.
You testified this morning that you 4
went to or you talked to Mr. Elliott and asked if the (i
5 simulator could reproduce the incident of September 24, 6
1977, correct?'
7 MR. SELTZER:
Objection.
He didn't say he 1
8 went to see Mr. Elliott, he testified Mr. Elliott 9
came to see him.
10 THE WITNESS:
And I made a! request.
11
'BY'MR. 'KOLB:
12 Q
That's fine.
I agree it was conversation a
13 with Mr. Elliott.
14 A
And I made a request of Norm to provide that 15 simulation as part of our training package'.
16 Q
I understand.
And I apologize.
I understand 17 it was the other way around.
Did you ask-him to do 18 anything-'else with respect to training?
19 A
We were in -- just general discussion of.the 20 schedule'and the scheduled activities of that particular 21 time.
22 Q
Did you ask him to make any other-changes in 23 the training?
()'
24 A
No, I did not.
25 Q
Just to run that-single incident?
?
1 Hickey 114 O
2 A
We wers looking at running the incident and 3
providing that as part of the training.
And we had 4
discussed what had occurred in the incident and that was
(
5 part of what we were requesting that Norm do for us.
6 Q
But there were no other requests made by you as to changes in training?
E A
There were always requests made whenever I would 9
meet with Norm or any of the other people on changes to 10 be made in training.
There were always requests because 11 there is always room for improvement and there is always 12 things that you don't like or you feel as though could 13 be done better.
14 Q
Okay.
15 A
so I will not say that I didnot ask. for any other 16 requests.
l 17 Q
could you give me an example or give me an 18 indication of what other requests you did make?
19 MR. SELTZER:
Objection.
He testified this 20 morning that they met for two hours discussing 21 what Toledo Edison wanted in the training program.
22 What do you want, a computerized list?
Are you 23 asking him to regurgitate two hours of session with o
24 Mr. Elliott?
25 MR. KOLB:
No,-I'm asking a specific question;
1 Hickey 115
(~V) 2 if he can tell me what other requests he made, if 3
any.
4 THE WITNESS:
I could not say that.
But it
(.
5 would have been around such things as who was 6
going to our simulator training, who our 7
instructors were going to be, what kind of lectures 8
you're going to have for people,' what kind of 9
engineers are going to participate in those 10 lectures.
And that would be the(kind of things, 11 and suggestions on either the quality or the type 12 of lecture that we wanted for people to be supplied,
'~'N 13 And that would have been general topics of 14 discussion during that session.
15 BY MR. KOLB:
~
16 Q
Do you recall anything else?
17 A
No, I don't.
18 Q
Now, Mr. Hickey, based on the observation you 19 made of B & W training, could you tell me whether you 20 would have considered it a natural, immediate operator 21 response if an operator observed that the pressure was 22 falling and that the quench tank rupture disc had 23 -
broken, would you have considered it to.be such an I
[)
24 operator response at that point to assume that the PORV
%)
25 was open?
1 Hickey 126 2
A Yes.
3 MR. SELTZER:
Let me just'ask for a 4
clarification.
I didn't object before he answered
(
5 because I didn't want to interrupt your question 6
and answer. But are you asking him whether this is 7
his judgment today or whether that was his judgment 8
on September 24, 1977 when his operaters terminated 9
high pressure injection after those events had 10 taken place?
E 11 MR. KOLB:
Well, I'll break it down.
d 12 BY MR. KOLB:
O
\\/
13 Q
First of all, Mr. Hickey, we're talking about 14 your observation of B & W training.
And it's B & W 15 training before Three Mile Island, the Three Mile Island 16 accident.
17 MR. SELTZER:
What is the question?
There is 18 no question.
19 MR. KOLB:
Well, he was going to say 20 something.
Go ahead, Mr. Hickey.
21 MR. SELTZER:
I would object and I would 22 suggest it's not proper for him just to make 23 speeches.
Why don't you ask him a question?
(m 24 MR. KOLB:
I'm prepared to do that.
I
\\-
25 thought he was trying to say something and I didn't
1 Hickey 217 O
2 want to suppress him.
3 MR. SELTZER:
This isn't a seminar, it's a 4
deposition, Why don't you proceed.
5 BY MR. KOLB:
6 Mr. Hickey, is there something you want to 7
tell us?
8 A
I'll wait for the question.
9 Q
Before the Three Mile Island accident, you 10 t
hAd observed B & W training.
Am I correct?
11 3
y,,,
1~9
(^3 Q
And my question is, at that point in time U
before the Three Mile Island accident, was it your 14 impression that B & W training that it would be a 15 normal operator response if the operator observed the 10 pressure was falling and the quench tank ~ rupture dise l
was open, that the PORV was open?
18 MR. SELTZER:
You mean the normal -- you 19 mean trained responce?
Are you asking him if B 20
& W was training people that those two events taken 21 together indicated the pilot operated relief valve 22 was open?
23 MR. KOLB:
Based on the training as he
/^
k_)%
24 understood it, what was the response he would 25 expect.
And that's basically what I'm asking him.
i
1 Hickey 118 ss
~
U 2
MR. SELTZER:
And you're limiting it to B &
3 W training?
4 MR. KOLB:
Well at the moment, that's right.
({
S MR. SELTZER:
All right.
6 THE WITNESS:
I can't limit it to B & W 4
7 training.
I have to speak of the training of our 8
personnel as being an overall training program.
9 B & W training was one section of the program and, 10 yes, our operators would in facttrecognize, as 11 they did on the September 24, 1977 incident, they 12 would recognize it as -- one of the indicators O
k-13 of being able to recognize it was when they 14,
detected that the ruptured disc had failed.
And 15 the indication there was, in connection with other 16 kinds of indication, was the level alarm in the 17 normal sump.
And so the answer in connection to 18 that would be yes, due to the overall training that
~,
19 the people had received.
1 20 Q
And when you say overall training you're 21 including both your training and B & W's?
L 22 A
Yes.
23 Q
And based on the training that you had I
l
[]
24 observed at B &
W, would you have considered it to be m,
l 25 the to be appropriate for an operator to turn off a t
I l
1 Hickey 119 I
yn k_
2 safety system and'to leave it off if he did not believe 1
3 he knew what the condition of the plant was?
4 MR. SELTZER:
Objection.
What safety system
((
5 were you talking about?
What point in time are 6
you referring to?
7 MR. KOLB:
I'm questioning as to any safety 8
system.
For the moment I'm asking him a general 9
question.
As far as time is concerned, we're 10 always talking about the training before the 11 Three Mile Island accident.
12 MR. SELTZER:
I'm sorry, could you please
(~h
\\-
13 read back what he said?
14 (REPORTER'S NOTE:
Pending question read 15 back by reporter.)
16 MR. SELTZER:
I object.
I think any safety 17 system is too broad.
Probably scores of safety 18 systems in the plant, each of which may have a 19 different procedure for operation.
20 BY MR. KOLB:
21 Q
Let me ask another question so we don't have L
22 any problems with the answer.
23 Mr. Hickey, was it-the general training that
(
24 if an operator didn't know what the condition of the plant 25 was that he was to let the plant run and not do anything m.
-. - - ~ -
1 Hickey 120 2
until he had determined what was wrong?
Is that the i
3 general training that was given?
I 4
A As in our September the 24th incident, the idea l
({
5 of thinking that you know what is going on affects the 6
question you asked me in the sense that yes, a person 7
should make sure that he understands what the conditions 8
are prior to securing a system.
But if you think that 9
it is something else and you go ahead and secure it, 10 then that statement that I made prior in the question a
11 loses its value, as far as my answer goes.
12 Q
If I understand you correctly, you're saying 13 that if the operator thinks he knows, even though he may 14 not be right, he may act not withstanding the general 15~
adm nition that he is not to act unless he knows?
16 A
That's right.
17 Q
All right.
Now suppose he' acts and he 18 turns off a safety system and he determibes after doing 19 that'that he still doesn't know what the c'o'ndition of 20 the plant is, that his initial assumptions appear to 21 have not been correct.What is the general training then?
k.
22 MR. SELTZER:
Objection.
There-is no 23 foundation that there is any general - training on
'h 24 that.
%Le i
25 BY MR. KOLB:
. ~.
_ _, ~ - -
1 Hickey 121 2
Q Go ahead, Mr. Hickey.
3 A
Okay.
Our people at Davis-Besse would restore 4
the safety system to operation.
(
5 Q
In accordance with the training they 6
received?
7 A
In accordance with the Davis-Besse training program, 8
Q All the training they received or just the 9
Davis-Besse training?
10 A
Well, the total --
11 MR. SELTZER:
Are you asking him 12 specifically about O
13 MR. KOLB:
Mr. Seltzer --
14 MR. SELTZER:
No, no, no.
I'm entitled to 15 an objection before he answers a question.
That's 16 the Kolb rule, remember?
Do you have any problem 17 with my objecting before he answers a question?
18 MR. KOLB:
Please don't get upset.
19 MR. SELTZER:
Well, we were saying don't 20 interfere, let him answer the question.
21 MR. KOLB:
It's too late now.
Go ahead and 22' state whatever you want to say.
23 MR. SELTZER:
Were you asking him whether b)'
(,
24 this was a specific part of the training rendered 25 by B & W to Davis-Besse employees to his knowledge?
s t
w s-
1 Hickey 122 2
MR. KOLB:
Well, I think we ought to read 3
the question back if you would like to hear it 4
again because I think that's clear from the (i
5 question.
Would you like to have it read back?
6 MR. SELTZER:
It's your question.
I don't 7
need to hear it read back.
O MR. KOLB:
All right.
I think the question 9
speaks for itself is my answer.
And I think he 10 did answer it.
11 THE WITNESS:
I don't remember the question.
12 MR. KOLB:
That's all right, Mr. Hickey.
f.)
V 13 The problem is not here with you, it's just a 14 difference between Mr. Seltzer and myself on the 15 matter.
16 BY MR. KOLB:
17 Q
Mr. Hickey, based on the training that your 18 operators received from both B & W and Davis-Besse, if 19 the condition of a plant was that the temperature was 20 high, above normal; the pressure was below normal and the 21 reactor coolant pumps were vibrating, what would the 22 training, as you understood it, and this is a l.1 before 23 Three Mile Island, indicate as-to the condition in the O
24 plant?
25 A
To the operator.-- the operator would think that he
..;. :. a.
1 Hickey 123 2
had mixed phase at the suction of the pump.
And by that 3
I mean he would be flashing water to steam on the 4
section of the pump, and the reason, that the suction of the pump is the lowest pressure area within the system.
6 Q
And under those conditions what would the 7
training indicate should be his action?
8 MR. SELTZER:
Objection.
Whose training?
9 MR. KOLB:
Again both Davis-Besse and B & W 10 taken together.
~
11 MR. SELTZER:
I object.
That's a compound.
12 g3 question and I object to it on the basis of form.
\\~
13 MR. KOLB:
Compound in what sense?
14 MR. SELTZER:
You're asking him simultaneously 15 about Davis-Besse training coming from Toledo Edison 16 and Babcock & Wilcox training.
And since the two 17 were conducted in separate locations at separate 18 times, I think the question is an unfair compound 19 question.
20 MR, KOLB:
I'll stand on the question.
Go' ahead, Mr. Hickey.
22 THE_ WITNESS:
The operator would realize that-23 i
he had an overheating kind of a situation and he in I
94
(_)'
~
would be looking at reducing the temperature within 4
-the reactor coolant system.
1 Hickey 124 2
BY MR. KOLB:
3 Q
And what steps would you expect?
4 A
Without knowing the other conditions it's hard to say.
6 Q
Okay.
But something to reduce the 7-temperature?
8 A
Yes, sir.
9 Q
Would you consider it under those 10 circumstances to be an appropriate operator response to 11 turn off all of the reactor coolant pumps?
12
(~
MR. SELTZER:
Objection.
You said that
\\'
13 there was vibration on the pumps but you didn't 14 say whether the vibration was above or below 15 the maximum stated in the B & W limits and 16 precautions.
I think the question is difficult to 17 he knows whether the vibration is answer unless 18 above or below the limits and precau.t, ions ceiling.
19 MR. KOLB:
Why don't we let him answer 20 whichever way he should given the fact that that
(
may be a determinate.
22 THE WITNESS:
The operator would be 23 observing the limitations on the pump, the pump r
vibration.
And he would not secure pumps or a 25 pump until such time as it looked as though the
1 Hickey 225 pump would be out of the spec.
Then the next 3
action that would transpire would be that the 4
operator, knowing the conditions within a system
(
5 and looking at ways to increase the pressure at 6
the eye of the pump, if there is two pumps 7
we're talking operating, each loop of course 8
about a reactor that has tripped.
He would then 9
reduce the flow to maybe one pump per loop.
10
\\
BY MR. KOLB:
11 Q
Would he turn them all off?
12
("}
A Probably not.
13 e
MR. SELTZER:
Objection.
When you say 14 wouldn't turn them all off do you mean with 15 vibration above.or below the maximum specified in 16 the specifications?
17 MR. KOLB:
His answer I think' covered the 18 various elements as he would understand them.
I 19 don't think I can be of any fairer than I have been I
90 l
~
in letting him explain that.
And I think he did j
explain that as part of his answer.
2 THE WITNESS:
I could qualify that.
23 A
okay?
(D k/
In our plant we do need reactor coolant flow in 05
~
order to do a normal cooldown of a plant and that is 1
l
i 1
Hickey 126
[
2 foremost in our operator's mind is that flow is required 3
to cool the plant down to do a normal cooldown coming 4
off the line.
So a lot of consideration is given to
(
5 reactor coolant pumps and maintaining flow of those 6
reactor coolant pumps, we of course were speaking of 7
post Three Mile Island.
8 MR. SELTZER:
Oh, I think 9
MR. KOLB:
No.
All the questions I was 10 trying to avoid repeating that ail the time.
I'm i
11 asking the questions before Three Mile Island.
12 THE WITNESS:
Okay.
That' what I meant, O
13 prior to Three Mile Island, conditions on the 14 reactor pump have changed since Three Mile Island.
15 BY MR.- KOLB:
16 Q
You answered the question as to the time 17 before 18 A
Prior, yes.
19 Q
That's what I understood.
20 A
But I did not want it to mean that that's what we 21 would do at the present time.
22 Q
No, and I wasn't'asking about that.
23 A
Okay.
()
24 Q
Mr. Hickey, I believe you testified this-25 morning as to the conditions that normally exist when
1 Hickey 127 O
2 there is an overcooling transient.
Do you recall that?
3 A
I remember discussing it.
4 Q
Yes.
Could you tell us again what the
((
5 conditions are?
6 A
condition can exist whereby you would introduce 7
say excessive feedwater.into a steam generator causing 8
a decrease in reactor coolant pressure, and of course at 9
the same time a decrease in temperature.
10 Q
If the temperature is increasing, based on 11 your understanding of the training of Davis-Besse and 12 B &
W, would that indicate to an operator something other O
13 than an overcooling transient?
Temperature's increasing 14 not decreasing.
15 A
An increase in temperature would not necessarily 16 be associated with an overcooling transient, that is 17 correct.
18 Q
- Okay, In fact the increase i te'mperature i
19 is inconsistent with an overcooling transient, isn't it?
20 A
On the front end of the transient that is correct.
l 21 Q
That's what I'm talking about.
L 22 A
Yes.
23 '
Q I believe you indicated this morning that in
()
. 24 addition to Mr. Elliott you spoke to a simulator.
- 25 ~
instructor concerning the possibility of running the J
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1 Hickey 128 2
September 24, 1977 incident on the B & W simulator.
3 Am I right?
4 A
.That's correct.
(
5 Q
Are you able to remember the name of the 6
individnal?
7 A
No, I'm not.
I know my normal contact at B & W l
and who that individual would be, but to definitely say 9
that's the individual I discussed it with, I could not 10 say that.
11 Q
Who was your normal contact?
12 A
Walt Perks was the normal contact, bV 13 Q
Do you have any other contact besides Mr.
14 Elliott?
15 h
Well,.other than who picks up the phone and is 16 willing to talk to me on the other end of the line, no.
17 Q
No one you recognize by name at this point?
A Well, I know just -- or did at that time, I knew 19 all the instructors.
So it would not have been normal 90 for me to necessarily go to just one of the instructors 21 and ask such a request.
22 Q
Is there anybody else besides those 23 instructors who you would not normally go to, and Mr.
D\\
Q.
24 Perks, who it might have been?
25 A
other than Norm Elliott, no.
______-_----_-------A
1
' Hickey 129 2
Q Oh, Norm Elliott or Walt Perks?
3 A
But I don't think that I would have gone to just 4
any of the instructors.
(
')
5 Q
Okay.
6 A
B & W has changed,the instructors quite frequently 7
down there so it's sometimes difficult to know who is on 8
first.
9 Q
No;r do you recall that this morning you 10 testified that you had a conversation 6,r conversations 11 with some Davis-Besse operators following the Three Mile a
12 Island accident in which I believe you said they 13 indicated that they thought that the T I operators s
14 during the accident had acted in the incident as the 15 Davis-Besse operators had been taught prior to their t
16 September 24, 1977 incident.
17 There are quite a few things in there but I 18 think I got all of the things you spoke about.
Is that 19 right?
20 A
That's correct.
21 Q
now when you were referring to that 22 conversation and referring to comments by those operators 23 at Davis-Besse about the similarity in the conduct of.the
\\
24 Three Mile Island operators, was the conversation you (d -
25 were telling us about one in which the Davis-Besse-f r.,
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I 1
Hickey 230 O(~\\.
2 operators were speaking of the termination of HPI?
3 A
They were talking about the sequence of events 4
including the shift in pressurizer level, the increase
(;
5 in the pressurizer level and the action of the operator 6
in securing HPI due to that increase in level -- that 7
was some of their primary statements.
8 Q
Was their comment, the one you recorded about 9
how the action of the TMI operators was similar to theirs 10 E
was it confined to that sequence where the pressurizer 11 level was going up, the pressure's going down and the
's termination of HPI occurred or were they talking about 13 other events that they understood occurred in the Three 14 Mile Island accident?
15 A
They -- our operators were relating to the basic 16 responses that the operators did on the front end of the 17 incident, the Three Mile Island incident.
-And relating 18 to primarily the fact that the recognition of a LOCA was 19 normally assumed to be a decrease in pressurizer level.
00 And that is what they had recommended, th't they had a
bean taught and that the Three Mile Island operators 22 had also seen an incident whereby they were encountering 9*3 an increase in pressurizer level which did not fit in
- A 4
with their basic training.
25 Q
That was the similarity they were pointing
i 1
Hickey 131 q
to, a,s you understood it?
3 A
Yes.
4 Q
And they were not, as I understand it,
{
pointing to other events in the Three Mile Island 5
8 accident beyond the ones you just described, as you understood their statements?
8 MR. SELTZER:
You're asking him for what he 9
can recall today?
10 BY MR. KOLB:
11 Q
Of what they said to him because you asked 12 him what they said to him.
e A
Yes, because I can recall now, that was the gist l
14 of the comparison, i
15 Q
Now let me ask you, Mr. Hickey, I believe 16 you testified this morning in just a question or two 17 about the Nuclear Regulatory Commission audit of Davis-Besse following the incident of September 24,
.2977, O
A Right.
21 Q
Do you recall that?
MR. SELTZER:
He is referring to an audit 23 of the procedures that had been revised after the 4
September 24 transient.
BY-MR. KOLB:
b J
1 332 Hickey
[v) 2 Q
That's what I was referring to.
That was 3
going to be my next question, could he just tell us 4
briefly what the audit was about.
But you have taken
({
5 care of it, Mr. Seltzer.
That's the audit I'm referring 6
to.
Please let me ask the question.
7 The question is, what was the source of your 8
information with respect to that audit?
9 MR. SELTZER:
You mean the fact that he did 10 such an audit?
11 BY MR. KOLB:
I 12 Q
Anything about the audit.
How did you come O
N/
13 to know anything about the audit?
14 A
During the post for almost a full year post 15 September 24_,
1977, the NRC was actively at the station 16 talking to'the different people who were involved in s
17 either the incident or the modification of procedures 18 and that whole sequence.
That issue more or less 19 culminated in the 1978 revision of our procedure which 20 the NCR was interested in at that time, that revision 21 they were interested in seeing in our procedures at that 22 time.
23 Q
Well now that's what you recall about the A()
24 audit?
25 A
Yes.
I Hickey 133 2
- Q But now my question is what was your source 3
of information about the audit?
4 MR. SELTZER:
You mean how did he know the
(
5 audit was taking place?
6 gy gg, gong 7
Q How did he know the audit was taking place, 0
just to what extent?
How did you get the information?
1 9
A By attending morning meetings, the conversations 10 I had with the different engineers in kharge of the 11 different groups.
The test session primarily was the d
12 focal point of that.
f.
(-
~.
13 Q
These are all people --
14 A
These are all people that I had daily communication 15 with.
16 Q
Oh, Davis-Besse employees?
17 A
Yes.
18 MR. SELTZER:
Are you excluding NRC testing 19 people on the Davis-Besse plant site?
20 MR. KOLB:
I'm asking how he got the 21 information.
I'm allowing him to tell me whoever 22 it was.
I'm not excluding 23 MR. SELTZER:
Did he ever see NRC people on 24 the plant site participating in the plant site?
25 MR. KOLB:
I think my question covered it,
1 Hickey 334 O
2 but if Mr. Hickey wants to add anybody from the 3
NRC he is certainly able to do that.
4 THE WITNESS:
NRC was on the plant site
{
5 communicating with the different people who were 6
associ,ated with this particular subject.
And their 7
presence on the site I knew -- I attended some of 8
the exit meetings that were associated with NRC 9
meetings personally, the ones pertaining to 10 training.
We were i ierviewed at,NRC inspection 11 audits on training and training activities'that 12 had transpired post Eeptember 24.
0-13 BY MR. KOLB:
14 Q
But all that information came from people at 15 Davis-Besse, right?
16 A
Right.
17 MR. SELTZER:
Objection.
I think he 18 testified he saw these people he attended exit 19 meetings.
This isn't information that he's got 20 secondhand.
21 MR. KOLB:
Mr. Seltzer, I get the 22 impression that he does in fact have the 23 information secondhand in the sense that he didn't
(
24 get it from NRC.
25 MR. SELTZER:
I'm afraid that's a 4
-w
1 l
f 33$
1 Hickey
' -O p
2 gisconception. 'Rather than getting it. secondhand 3
from NRC I'm afraid that's a misconception.
4 That's your impression.
5 BY MR, KOLB:
6 Q
The question is not whether you physically 7
observed people from NRC -- my question was -- I was 8
trying to leave it open, You got something from Davis-Besse, you got something from somebody you told me and 10 I'm prepar,ed to go around again if you would like
't o 11 tell us.
,e 12
~'
audited in. draining -- on A
A As I said be^ fore, we were N) 13 4
tha training we were provided, we were audited by f,th e
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sf
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NRC'on that kind of training. r,Other people were also
,./
- 35 2
audited on other functions that". were taking place, at' that e
I
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16
< time, e
r When you,weje'.4andit.ed byf he NRC as to 17 t
Q 18
I training, did you personally talk to sortebody from. the
'j /
19 s
/
NRC7
/-
/
I
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~*0 A
Yes.
'-/
+
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21 Q
All f,ight.
That's what I meant by sou'rces of C
s
-29
/ ' ",' r f-i e
l information.
?
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4 23 i
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Yes.
t,
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24 '
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O Now wh n you hav'"information, i'f youigh, e.
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1 Hickey 136 Ob 2
where does that information come from?
3 MR. SELTZER:
Objection.
It's not clear 4
that the audit of procedures is different from the
({
5 audit of training.
There may have been questions 6
in the training audit that related to revised s
7 procedures.
g BY MR. KOLB:
9 Q
If you want to clarify, Mr. Hickey, you go 10 right ahead.-
(
4 11 A
We're talking about a wliole span of almost a year 12 in there from -- a little over a year from the t i m e o f-13 our incident until actual modifications and so forth.
14 Emergency procedure's are part of the to'tal package and 15 personnel mu's't be tralned on emergency procedures.
When 16 you modify pricedures the people have to be trained on
~
17 the insertions that were put in the procedures.
We were
^
m, 18 audited on those insertions by the NRC, the statements 19 that were put in:to' ensure that our people were cognizant s
s 20 of the fact that those were in fact covered.
t 21 Q
I'm not debating with,you what happened.
(.
22 That's not the point of the question.
The point of the 23 question is to f i n'd out what the source of information
[~%)
24 is that you have about the-audit or the sources when I w:
25 take it there is probably more than one.
_ i 1
- -... ~
r
1 Hickey 337 Now let me ask you a couple of questions 2
3 which may help because I think that for one reason or 4
another there seems to be some confusion and I don't want
(
5 there to be.
6 First of all, I take it that there was an 7
audit of the training group or department, your group, 8
is that correct?
9 A
There was a portion of the overall audits.
The 10 numbers of audits that took place during,that one year 11 period of time did affect training, did affect our 12 immediate training that we performed after the September O'
13 24 incident.
Future audits did include. modifications in 14 procedures that we made due to these changes.
And, yes, 15 that was directly into our area, the NRC examiners asked e
16
.us and we produced the evidence for them of that training.
17 MR. SELTZER:
When you say our area and 18 pointing to yourself --
19 THE WITNESS:
Training.
Training.
i 20 BY MR.~
KOLB:
21 Q
okay.
'You're including within an audit or 22 a portion of an audit devoted to training the auditing i
23 of the procedures?
(
)
24 A-I'm includingnthe auditing of certain insertions 25 in the procedures, not the total procedure'necessarily but 1
i-
-~,, - -
- ~ - - -
" ~ ' ~ - ' ""
1 Hickey 138 remodified procedures.
We did amend to -- or revision
~
3 to of the procedure at someone's request.
And when we 4
inserted that statement within the procedure there is all l
5 sorts of people that were interested to know whether our 6
operators knew that that had been inserted in the 7
procedure.
And that was verified.
8 g
7,m asking a limited question and I'm by no 9
means trying to confine your observations here, but I 10
(
would like you to just answer the limited question because I think it would clarify --
12 g-MR. SELTZER:
Let me state I think he has
(_/
13 been answering your questions very well.
I'm having 14 difficulty understanding exactly what you're driving 15 at.
4 MR. KOLB:
I don't understand why, Mr.
17 Seltzer, you would have anydifficulpyunderstanding 18 that.
You know perfectly well what the evidentiary 19 problem is here and I think you know perfectly well 20 what I'm driving at here.
21 MR. SELTZER:
If you're going at a question 92
~
of hearsay and source of knowledge, I think to use 93 the word source with a lay witness may be confusing
- p)
(_
24 because he may be assuming that source means 25 somebody other than himself, whereas, from what he's
i 1
Hickey 139 i
O b
2 been testifying, it sounds like he may be a 3
firsthand eyewitness to a great deal of the audit.
4 And if that's a fact, he is a primary source for
(
5 knowledge about the NRC audit, particularly if they 6
were auditing his training section and the 7
procedure changes incorporated in training.
O MR. KOLB:
Now obviously you're trying to 9
tell him what to say.
10 MR. SELTZER:
No, I'm not.E 11 THE WITNESS:
That's what I said.
12 MR. SELTZER:
Thank you.
Because I think lh.e 13 said it.
He said it more clearly than I just 14 have.
I think you're trying to befuddle and confuse 15 the witness by suggesting that he has not already 16 said this.
17 MR. KOLB:
No, I don't think I'm trying to 18 befuddle and confuse the witness, Mr. Seltzer.
19 I think the questions are fair, obviously 20 intended to be fair.
And my point about telling 21 him what to say is we're obviously not dealing with 22 just one s.ubject training, we're dealing with 23 procedures as well.
And I want to ask the witness
/~N tj 24 specific questions.
I have no criticism of'the 25 witness.
I want to be specific here.
I think
i 1
Hickey 140 2
there are elements important to bring up and no 3
confusion is intended.
4 BY MR. KOLB:
()
5 Q
Mr. Hickey, the question I'm trying to get 6
- _at, and let me ex' lain it so you can understand, is I take p
7 it that to some extent the NRC did work with respect to 8
training as such and that to some extent they did work as 9
to procedures.
And I'm trying to find out what the 10 extent of your information is as to the ' procedures part s
11 of that and where you got it.
And if you got it from a 12 person, you got it from your own personal observations or O
13 participation I want to know that.
That's what I'm
]
14 trying to clarify.
You have been very cle'r about the a
15 training part but I'm still not clear myself as to what 16 exactly -- where you stood on the procedures.
I'm not 17 talking about the company as a whole, I'm just talking 18 about you personally.
19 MR. SELTZER:
All right.
Ask him a question.
20 MR. KOLB I just want him to tell me, if 21 he can, whet his role was in connection with 22 procedures, if any, and where he got the 23 information, if any.
)
24 MR. LIGHT:
Maybe I can interject, Dan.
25 What do you mean by procedures?
There may be some i
l
[
. ~. - - - - -
. ~ - - -. -
- - - - < ~ - -----
1 Hickey 141 V
2 misunderstanding on that.
You mean just training 3
procedures or are you thinking 4
MR. KOLB:
No, emergency procedures, that
{i 5
kind of procedure.
6 MR. LIGHT:
Or something beyond just 7
procedural changes in training?
8 MR. KOLB:
One of the problems we have in 9
this case is you begin to use terms understanding 10 what they all mean and Mr. Hicke,of course is not 11 a general participant in the case.
If I have used 12 a term that in any way confused him, I'm sorry.
13 BY MR. KOLB:
14 Q
Mr. Hickey, what I would like to know now, 15 the question.is, and let's take them in parts because I 16 think it's easier to do it that way.
Simply, first of 17 all what connection, if any, did you have personally with 18 the audit of the emergency or other procedures after the 19 September 24, 1977 incident at Davis-Besse?
20 MR. SELTZER:
Including the extent-to which 21 those procedures were incorporated in training and C
22 were audited by the NRC as part of their audit of 23 training?
/
\\
% ))
24 MR. KOLB:
Including anything.
(
25 MR. SELTZER:
All right.
Hickey 142 G'
2 THE WITNESS:
We were audited against 3
emergency procedures and our' actions involving 4
emergency procedures, the kinds of training we l.
5 had provided with people on emergency procedures, 6
the procedures were modified.
I did not modify 7
the procedures.
But certain statements were put 8
into those procedures that pertained not only to 9
operator action but also training that should be 10 supplied to the operator prior t6,him picking up 11 the procedure.
And we were audited on that 12 particular aspect of it, whether we had in fact 13 informed our people of the changes that had 14 been made in the procedure and th at' our people were 1
15 conversant with those changes.
16 BY MR. KOLB:
17 Q
I'm going to ask you again what was your role.
18 A
I was audited.
19 Q
What did you do?
What did you do personally, 20 not what did the company do as a whole, but what did you 21 do personally?
You told us one thing you didn't do, but 22 what did you do, if anything?
23 MR. SELTZER:
How did you respond to the
[ ))
n NRC auditor?
~4 BY MR. KOLB:
i l
)
1 Hickey 143
/.Q-2 Q
If you responded at all.
We haven't even 3
established you talked to them about this subject.
We 4
certainly established you. talked to them about something
(
5 else, but I'm trying to find out what you personally did 6
with respect to the changes of procedures.
7 A
I have totally lost track of where you're going 8
on this question and I can't answer the question the way 9
you have broken it up.
It's impossible for me to answer.
f 10 g
we'll do it another way.
(
11 when is the first time in the audit that 12 we're talking about, the one following the September 24, 13 1977 incident, that you met with or spoke with anybody 14 from the Nuclear Regulatory Commission?
15 A
You're asking me something that when the NRC 16 comes to the site I probably talked to those people every 17 single day on different matters and have for years 'over 18 this period of time.
I can't tell you the time of day 19 when I would be talking to an individual on the matter.
20 It's just a matter of course that if something goes wrong 21 with the plant the first place that they go to after 22 finding out what happened, they go to the training 23 department.
They have to decide what kind of training O)
(
24 was provided for that particular thing.
If we have 25 committed to do additional training they find out what
1 4
Hickey (D
u) 2 that additional training is.
They audit us against it to
+
3 make sure that we fulfill that commitment that we have 4
committed to.
Now to identify a day, a period of time or 5
an interval of time in that whole year and a quarter and tell you who I talked to, that's impossible.
7 Q
Do you know where, if at all, you got 8
information concerning the audit of the procedures, 0
emergency procedures?
Do you know?
10 t
MR. SELTZER:
Dan, excuse me.
But I think 11 he's told you five or six times already that he 12
(~N was personally involved.
Nobody had to tell him.
\\.)
I 13 He said that he would see the NRC people daily.
4 j
It sounds like he's the source.
He has firsthand g
5 eyewitness knowledge of what he has been told.
16 Why do you keep -- it's like asking somebody who's ippacted, who sitting in a car when his car was 18 told you about the accident?
19 MR. KOLB:
I'm sure you understand, Mr.
O seltzer.
He has not said in so many words that 21 he remembers conversations -- as the source of his 09
~~
information he hasn't said he recalls doing it 23 himself in connection with the procedures.
He (D
YJ 24 has just not said.
And now I'm asking him 95 another, what I think is a fair question, and
~
i
1 Hickey 145 y
(G 2
that he is is it that you just don't remember 3
exactly where you got your information as to the 4
audit of the procedures?
(
5 MR. SELTZER:
Why don't you ask him a 6
straightforward simple question.
Did you 7
participate personally in the NRC audit?
8 MR. KOLB:
I tried that.
9 MR. SELTZER:
I don't recall that.
I think 10 you're beating around the bush and I think you're 11 trying to confuse him.
Why don't you just ask him 12 that simple question first.
13 MR. KOLB:
I really must say Mr. Seltzer, 14 I think we could just proceed simply if you would 15 just quit interjecting.
I have tried it every 16 conceivable way.
I have asked the question how he 17 got the information 18 MR. SELTZER:
If you would have'been direct--
~
19 why don't you proceed by asking if he personally 20 participated in this.
You have the devious intent 21 of implying what he is trying to testify to is 22 hearsay.
23 MR. KOLB:
What he is testifying to is
,f'N
(_)
24 hearsay.
25 MR. SELTZER:
You wish it were and you're
1 Hickey 146 7s
. s
\\
2 trying to avoid asking him the frontal question, 4
3 which I will ask him in redirect if you don't ask 4
him, and that is were you personally involved in t
l 5
the audit.
6 BY MR. KOLB:
7 Q
I take it you were involved personally in 8
the audit to some extent.
You have already said that.
9 A
That is correct.
i 10 Q
Do I understand there were' corrections made 11 in the procedures, changes?
12 A
There were revisions made to procedures.
()
l 13 Q
Did you personally become involved in the i
14 revisions?
15 A
In the drafting of the revisions, no.
16 Q
Where did you get the information that you 17 got about the drafting of the procedures? -
18 A
The procedures are distributed as a normal course 1
19
,even if I had never talked to any of my other -- the 20 People that I associate with daily.
When procedures go 21 through the SRB they are distributed to my office to my 22
. desk for my review and for my distribution for required 23 reading and other. training.
24 Q
Okay.
What is the SRB, just for the record?
25 A
Station Review Board.
.~,,
. ~..
1 247 Hickey 2
Q Aside from that form of circulation of 3
materials within the company, do you remember any other 4
source of information you have about the drafting of-the
({
5 procedures?
,6 MR. SELTZER:
Including morning meetings?
7 BY MR. KOLB:
8 Q
Anything.
9 A
Of course I talked to our technical engineer.
I 10 talked to oar nuclear engineer.
t 11 MR. SELTZER:
Don't hold up your hand, 12 Counsel.
That's a cute way to indicate for him to s/
13 stop.
You're holding your hand up in front of j
14 him.
15 MR. KOLB:
Let's go on with the examination.
16 I'm indicating to the man to be complete in his 17 answering.
Go ahead, Mr. Hickey.
18 THE WITNESS:
I have completed my answer.
19 BY MR. KOLB:
20 Q
Do you recall any other person you spoke to, i
21 any other material you received, any other source of 22 information about the drafting of procedures?
23 A
No.
(
24 Q
Okay.
Now I take it that you have learned, 25
.either from personal knowledge or from somewhere else, s
a
1 Hickey 34g n
2 that the Nuclear Regulatory Commission was involved, to 3
some extent, with the drafting of the procedures.
Is 4
that right?
({
5 A
Yes.
You told me the other day.
6 g
Any other source of information?
7 A
No.
I have been puzzled primarily where that 8
came from and you cleared that up for me the other day.
9 MR. SELTZER:
By you you mean Mr. Dan 10 Kolb?
11 THE WITNESS:
Yes.
12 BY MR. KOLB:
O 13 g
Aside from those people I have listed, do 14 you remember any other conversations on that subject?
15 A
I can remember a lot of conversations around that 16 subject but not that was a lengthy kind of discussion, 17 went on for months.
18 Q
Do you remember any conversation with anybody 19 from the Nuclear Regulatory Commission?
20 A
on those particular --
21 Q
on that particular subject.
L 22 A
No.
23 g
okay, thank you.
0) 24
(
Mr. Hickey, let me show you two-documents 25 which have been marked GPU Exhibit 153 and the other of
i l
1 Hickey 349 2
which has been marked GPU Exhibit 154.
153 is a document 3
which, among other things, on its front cover carries the 4
title " Reportable Occurrence MP-32-76-16, Davis-Besse 5
Nuclear Power Station Unit I,
date of occurrence September
(
6 24, 1977."
7 MR. SELTZER:
What is the transmittal date, 8
if it has one in the upper left-hand corner?
4 g
MR. KOLB:
October 1977, 10 BY MR. KOLB:
(
11 Q
GPU Exhibit 154 carries the date November 12 14, 1977 and is entitled, " Supplement to Reportable 13 Occurrence MP-32-77-16 Davis-Besse Nuclear Power Station 14 Unit I,
date of occurrence September 24, 1977."
I will 15 show you those two documents.
16 MR. SELTZER:
You might focus the witness's 17 attention, if you told him what particular portion 18 of the 60 page GPU Exhibit 154 you t'hought was 19 going to be pertinent to any further questions.
~
20 MR. KOLB:
If I thought that would be 21 helpful, Mr. Seltzer, I would do it.
And in some 22 cases in the future it will be helpful and I will 23 do it, but in this instance, as you will see, I
(~N 24 don't think it will be.necessary.
25 MR. SELTZER:
I just wanted to reflect when
i 1
Hickey 150 2
you were being helpful and when you weren't being 3
helpful.
4 BY MR. KOLB:
(i 5
Q Mr. Hickey, from the opportunity you have 6
had to look over those documents, are you able to tell us 7
what they are?
~
~
8 A
These are the LER's, the-first one is the LER from 9
our september 24th incident and a sheet containing the 10 supplemental information.
And then thak would bc dated 11 October
'77.
And then that wo61d be dated October
'77.
12 And then there was an additional study, an expansion of
/O U
13 that particular incident, and a supplement was generated 14 and sent to the NRC on November 14.
15 Q
Did you ever have occasion to review those 16 at or before the time they were sent to the NRC?
17 MR. SELTZER:
What do you mean by review?
18 MR. KOLB:
Look them over, read them.
4 19 THE WITNESS:
For informational purposes, 20 I had seen DVR's or.the original DVR which is the 21 document that generates the LER.
I had seen that.
22 And then in that fashion I would say I had seen 23 what was going to the NRC.
pI t, J 24 BY MR. KOLB:
,~
25 Q
When you say DVR, would you tell us what that
~
i i
1 Hickey 351 t (~)
2 is?
3 A
It's a deviation report and it's generated when 4
-you identify a problem and then it goes from there to i
{
5 the LER stage and it's typed in the LER format.
6 Q
Is the text of the DVR in the ordinary course 7
the same as the text of the LER?
8 A
Basically the same kind of information.
9 Q
When you say you looked at the DVR, are you 10 l talking about the DVR for the original LER or are you i
11 talking about both DVR's for the supplement and the 12 A
The DVR, eicher in the form of an original document 13 or the information that was generated that would provide I
14 this, yes, I had seen that.
There should have been a 15 DVR associated with it.
It's an in-house document.
16 Q
Excuse me for going over this again, I think 17 we may have had a problem with the record..
18 The original LER, the first one is GPU 19 Exhibit 153.
Am I right?
20 A
That is correct.
21 Q
And is it your recollection the DVR preceded L
22 that document?
23 A
Yes, I believe it did.
24 Q
There is a DVR, to your knowledge, for the 25 second one which is 154, the supplement?
Hickey 152
("~')
\\~
2 A
Not that I know of.
3 g
And did y u see anything in the way of a 4
document or a draft before the supplement was disseminated?
(
5 A
well, the supplement itself consists of documents 6
that were available to us in the form of the different 7
graphs and charts and things like,that.
And, yes, I had 8
seen those before and I was familiar with those and quite 9
familiar with those.
10 Q
Would you just tell us, istthe text in the 11 second document Exhibit GPU 154 f
There is text material in that particular document, 12 O
\\-
13 yes.
14 Q
Did you have occasion to see the drafts of 15 the text before the document was sent out?
1 16 A
I cannot recall actually seeing the text before it
~
17 went out.
18 Q
Do you recall reading the doc ment after they 19 were sent to the NRC7 20 A
Read them many times.
21 Q
Did you read them at or about the time they 22 were sent?
23 A
Yes.
Yes, I did.
f) 24 Q
Now as to the DVR with respect to 153-or any v
25 draft you might have - seen, if you did, with respect to
I 153 Hickey
/~h 2
154, do you recall talking to anyone about those drafts 3
or the DVR?
4 A
Yes, I would have talked to someone on those
(,
5 particular ones.
The reason being is in the 153, GPU 6
153 document, a lot of emphasis was placed on the 7
SFRCS trip.
And the training that we provided to-our 8
people immediately after the September 24th incident t
9 contained information that we had gathared from the trip, i
10 l and these documents, and had one segment of the training I
b based on SFRCS.
11 12 Q
Are you Nole to recall who you would have
('T
\\_./
13 talked to?
14 A
Larry Stalter whc was the person whc drafted the 15 first LER.
16 Q
How do you spell his last name?
17 A
S-t-a-1-t-e-r.
18 Q
Anyone else you would have spoken to?
19 A
I would have had discussions on these same matters 20 with our operations people and other people in the 21 technical section,.primarily I can lock in on Larry 22 Stalter because Larry was asked to assist us in 23 delivering the lecture that was acaociated with steam
[^T 24 feedwater rupture control?
25 Q
Are you able to remember any other names,
1 Hickey 154
[u 2
any other specific people?
3 A
Ch, the actual discussion of the LER, probably not.
4 I can't think.
I know I discussed this with hundreds of
(
people but I can't pull out a name for you.
5 6
Q Do you recall any discussions with respect to 7
any draftor as to the original of the supplement which is 8
GPU 1547 0
A I had enumerable discussions with people on the 10
(
material that is associated with this document here.
All 11 of the curves, the charts, the graphs, the diffarent 12 f-things like that.
The actual verbage I can't say that I (w
I 13 l was familiar with each paragraph and the way each paragraph is typed in its present form, but most of the 15 information was available at that time.
I talked to 16 people within our own company.
Part of the i? formation 17 that is in this I shared with other people ~ fram outside I
18 the company as just a matter of course by inquiry or what 19 have you.
So I'm familiar with the contents of both of-20 those.
2I Q
Just focusing on Exhibit GPU 153, do you
(.
l' 2
recall making any suggestions to anyone who participated 93
~
in the preparation of that document as to changes that
[))
24
(,
should be made?
05
~
MR. SELTZER:
Changes which should be made
~-
~
1 Hickey 255
! ~
\\'
2 in the document?
3 BY MR. KOLB:
4 Q
Yes, just generally first, if you' remember
()
5 any.
6 A
On the LER itself, the LER was directed toward the 7
root cause of the trip and the' root cause of the 8
incident.
And I did not at that particu'lar point ask'any 9
changes to be made at that time.
I 10 I
Q
'I would have the same question now with i
11 respect to the supplement.
Did you ask that anybody make 12 any chara g e r in that?
{~}/
i s-13 A
The supplement was, at that particular time, was 14 fairly complete.
15 MR. SELTZER:
I'm going to object.
Are you 16 asking him whether he made any suggestions for 17 changes before it was sent to the NRC?
18 M R '. KOLB:
That was my intent.
19 MR. SELTZER:
I object.
There is no 20 foundation that he saw it before it was sent to 21 the NRC.
22 BY MR. KOLB:
23 Q
If that's the case, that's fair.
f~A N
24 A
I had seen only the internal documents.
25 Q
Meaning those charts and graphs?
1 Hickey 156
(~)
~
%_J -
2 A
The charts and things like that, and the charts 3
and things like that were sufficient so'I would not have 4
input, like I testified, I had not seen this portion of l
5 it.
So I wouldn't have had any input.
6 Q
When I asked my question I was asking about 7
charts and graphs but Mr. Seltzer is quite right, I
l 8
didn't mean to go further than what you already said.
O Do you recall as to GPU 154, whether after l
10 the document was sent to the NRC and you reviewed it, 11 anything caught your eye as needing to be changed?
12 A
There was a difference between needing to be O
13 changed and what I would perceive to be. actions that I 14 should take in connection with the document.
15 Q
Well, I'm not asking about actions at this 4
16 point that you might take having reviewed it, I'm just 17 asking whether there was anything in there-that you saw 18 that caused you to go to someone and say we should change 19 that or amplify it or anything like that.
20 A
No.
No.
21 Q
Okay.
Based on what you just said, Mr.
22 Hickey, am I correct that when you read the supplement you 23 did not think it necessary to suggest that any additional
()
24 information be put in as to the response of the operators 25 during the Davis'Besse incident on September 24, 19777
1 Hickey 157 O
N"'
2 A
As I indicated in earlier statements, is that 3
the concern that I had on the length of time that it took our operators to respond'to the actions that were taken 5
when you analyzed the conditions that existed at our particular incident, those concerns decreased, fed by 7
other reports that were coming in at the time whereby 8
the Nuclear Regulatory Commission had agreed that the 0
operators responded well to the condition.
I felt though 10 E
there is no need to make any further expansion upon those 11
- items, 1
Q And so as a result you didn't makc any 13 suggest'ons?
I4 A
I didn't, that's correct.
15 Q
Is the same thing true -- would you have the 16 same answer as to 153 that you made no changes with 17 respect to suggestions with respect to th a't document?
18 A
I may have had some input on the second expansion 19 of the document, but no direct written input or anything 20 like that, but just a few suggestions about what we 21 might include in the supplement.
2 Q
Now I'm asking about 153 which is the 93
~
original LER.
4 A
Okay.
5 9
Q And my question is am I correct, based on g
~e,,-,--.-n
1 Hickey 358 A
N.J 2
what you just said a moment ago, that you didn't make 3
any suggestions as to any increase in information about 4
the operator response as to LER, the LER which is 153?
Ie 5
A No.
6 Q
You thought it was a satisfactory document 7
as to its description?
8 A
I felt as though the document addressed the root and the
~9 cause of the incident and the root cause was 10 incident was defined, as in all documents, was defined 11 as a depressurization of the system.
And the root cause 1
12 of the depressurizarion was thought at that time to be l
the steam feedwater rupture control system, And that the 13 14
-- by addressing that particular concern we would in fact 15 decrease any probability of such a reoccurrence.
And I had 16 no additional comments to make on it at that time.
17 Q
Okay.
Mr. Hickey, you testified this morning 18 conversation you had with Mr. Elliott concerning a 19 following the September 24th incident.
i l
20 A
Yes.
21 Q
Are you able to recall in full the discussiont 22
.had during that meeting?
23 MR. SELTZER:
Now I object.
This has been i
[')
(-)
24 asked and answered, asked and answered two or 25 three times already.
You asked him in your
1 Hickey 139 (v~)
~
2 cross-examination what else he cov.1d recall.
He 3
described the different subjects that they 4
discussed, the types of instructors they wanted, l}
5 the content of the training programs, the 6
engineers that they wanted to address them.
7 What more do you want now?
How is this 8
question different from earlier questions?
9 MR. KOLBi Actually I tuink the other 10 questions were timed at particula.r subjects.
What 11 I'm trying to find out is if the witness can 12 remember anything as a predicato to asking him the
/~N a
13 next question which you will see.will make good 14 sense.
15 BY MR. KOLB:
4 16 Q
Do you remember what else you discussed with 17 Mr. Elliott?
18 MR. SELTZER:
You mean does he have a 19 computerized list?
20 MR. KOLB No, I don't mean that.
I mean 21 in substance can you remember.
22 THE WITNESS:
I would be foolish to make a 1
23 statement that I could.
/"'s
(
)
24 BY MR. KOLB:
xs 25 Q
Do you remember whether during the meeting
1 Hickey 160 O
V 2
you had any documents that formed the basis for ths 3
conversation?
4 MR. SELTZER:
I think he testified this
)
5 morning that they were reviewing sequence of 6
events from documents.
7 MR. KOLB:
Mr. Seltzer, please don't try 8
to testify for him.
Let him answer the questions.
9 MP. SELTZER:
He has testified already.
t 10 MR. KOLB:
He is perfectly free to testify 11 again under my cross-examination.
It's a 12 perfectly fair question.
It's not necessary for C)
\\'
13 you to interrupt.
It just prolongs the 14 deposition.
15 THE WITNESS:
We did have documents.
We had 16 sequence of events.
We had other kinds of notes 17 that had been taken of the incident ~that we had.
~
18 BY MR. KOLB:
19 Q
Do you remember why those documents had been 20 prepared?
21 A
Definitely.
We had a condition that was abnormal 22 at our plant.
And one of the first things that happens i
23 when you have something abnormal, your engineers swarm
(~T t
g
)
24 down on top of you and we start generating documents.
And v
j l
25 those documents are funneled back through training for
1 Hickey 161 p)
\\
2 training to see what benefit they can derive from them.
3 Q
Were the documents used as a basis of the 4
preparation for the LER?
5 A
I cannot answer that because I did not prepare 6
the LER.
7 Q
You don't know one way or the other?
8 A
I would assume that they would have been.
9 Q
Okay.
Mr. Hickey, as part of your role as 10 head of training, looking at the period before the Three 11 Mile Island accident, did either you or someone else 12 reporting to you take steps to try to get information that 13 was avsilable cencerning other transients?
14 A
As a normal course of action, I received prior 15 to Three Mile Island, all LER's that were sent out by the 16 NRC in their typical packages of extremely large volume 17 of material.
And I took that responsibility personally 18 to try to digest them as well as I could and to identify 19 LER's that may be or may affect operation or have some 20 connection with the operation, yes.
21 Q
Why did you do that?
22 A
There is a requirement that we keep abreast of 23 operating conditions and that was one of my methods of r ()
24 doing it.
And trying to keep our operators informed of 25 what was happening, consumer power or what have you.
1 Hickey 162 0
2 Q
Did you think that was an important thing to 3
do?
4 A
I considered it probably more important than my
(
-5 operators considered it.
There was such a volume of 6
material that what I perceived-in my own mind to be an 7
important document may or may not have been perceive'd by 8
our operators to be of as much significance.
9 Q
But you personally thought it was an 10 important function?
E 11 A
I did.
+
12 Q
Something that in your role you thought you n
N/
13 should do?
14 A
I felt as though someone had to 'o it and no one d
15 else was doing it.
16 Q
Now did you review any other material that
~
17 came in reporting on transients?
e 18, A
Oh, the normal documents, the abnormal occurrence 19 reports that are generated by the Federal Government.
The 20 large-sheets where they give a listing of all LER's by 21 the station, the unit and also the other information 22 associated with the at,omic,--I can't remember the sheet.
23 Everyone's familiar with them.
It was the long 100 page
[)
24 thing.
I did that review as a normal course.
.Q),
25 Q
Did you do that for the same reason that.you i
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fI Hickey 63
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2 reviewed the LER's?
f, I
i<-
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3
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3' A ^'I did.
r-
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I i
l
..'_Q Did you thinksit'was an important thing to:
4[A
. C/.
f i
e 5,
~do because' cf 'the jpb function you had?
f<
(,
6 A
Pers'enally I took it as being a significant thing I'
7 to occur.
I didn't do it fut of enjoyment.
i
/ _,
I
/
8 (REPORTER'S NOTE:
Brief re c e s s ', take n. )
t y-1
/
\\
9 MR. SELTZER:,Any further,questi$ns?
7[
/
10 MR..KOLB ' No.
11 REDIRECT EXAMINATION ~3Y
)
p 12 MR. SELTZER-(d')
13 O
On cross-examinationfyou testified that 14 prior to September 2 4,-- 1 9 7 7 it was your understanding that
/-.-
15 the block of theI. quench tank rupture disc and a drop in 16 reactor coolant system prensure indicated that the pilot 17 operator relief valve was open.
t 18 was that which you have just described 19 something'that was specifically included, to your 20 knowledge, in Babcock &,Wilcox training prior to September 21 24, 1977?
22 A
No.
23 Q
(1s that someth'ing that was specifically
(%'
j 24 included in any other training, to your knowledge, v
25 training given to the Davis-Besse operators?
d
~
1
-.r---
r, r
y n
v-9
1 Hickey 164 (G'
2 A
The discussions, in-house discussions on the 3
pressure relief system on the Davis-Besse unit, the 4
purposes of the ruptured disc and what might occur were
(
5 discussed with our operators during their Phase Five 6
training.
7 Q
You testified on cross-examination with 8
respect to what operators had been trained to do if they 9
had terminated certain safety features.
And then I i
10 believe after the termination that they still had not 11 found the cause of the upset, you said that you believed 12 they should reinitiate the safety features that had f%
13 previously been terminated.
Have you ever had a transient
~
14 occur at the Davis-Besse plant where the operators 15 terminated an emergency safety feature then recognized 16 that they had not determined the cause of the transient 17 and then reinitiated the safety features?
18 A
Yes.
19 Q
When?
20 A,
We have had some, a couple of instances where we 21 have had undercooling or overcooling kinds of situations 22 where an overfeed of a steam generator would cause an l
l 23 incident and then the operator would choose to restart F
( )N 24 high pressure inj ection pumps.
Nothing of any magnitude i
25 as far as an incident at the plant, but just'taking a
J 1
Hickey 165 2
a different course of action than what the person had 3
started to take.
4 Q
You said that you would understand that if 5
you had rising reactor coolant system pressure, falling 0
temperature and vibration on the reactor coolant pumps, 7
that that indicates a mixed phase at the suction side of 8
the reactor coolant pump.
8 A
I said that could, yes.
10 i
Q Prior to the Three Mile Is1'and accident do 11 you know for a. fact whether B & W i.ncluded any training 12 of the Davis-Besse operators that would,.have taught them 13 that specific fact?
A I do not.
Q This next point I was asking.you about during 16 the break just after Mr. Kolb's cross-examination.
17
~
You testified regarding when you believed 18 the operators would have secured or shut off the high 19 pressure injection pumps prior to any revised 20 instructions that they received following the Three Mile 21 Island accident.
Directing your attention still to the 22 period before the Three Mile Island accident, if the 23 operators had one reactor coolant pump operating'on each 24 loop and observed vibration on the frame and the shaft 25 of those pumps which exceeded the B & W limits and-l
-. ~
1 Hickey 106 2
precautions, do you know whether the operators, as 3
their trained response, would have shut off the reactor 4
coolant pumps?
(1 5
A I hypothesized that they would but in fact I 6
could not state that would be the total thing, with a group of operators you may have gotten a variation of 8
responses to that.
But I would have thought that what I 9
had stated before was true.
10 Q
That they would shut them off?
11 A
That they would try to hold on to the reactor 12 coolant pumps as long as possible.
And..that whatever
-s g 13 that point is, that's where my testimony breaks down.
14 It's then up to the individual what his response may have 15 been at that point, 16 Q
And you would just be speculating?
17 A
I would be speculating.
}
18 Q
Revision two to emergency procedure 1202.06 19 requires the operators to check for any open relief 20 valve or pilot operated relief valve on the top of the
(
pressurizer before terminating high pressure injection.
oo
~~
Am I right?
23 MR. KOLB:
Why don't we take the document l,
t 24 f~
A out?
"5
~
MR. SELTZER:
That's GPU Exhibit 1,004.
1 1
Hickey 167 C)
\\' 'J 2
MR. KOLB:
If we've got it do you want to 3
read it again?
4 THE WITNESS:
" Prior to securing HPI, ensure
()
5 that a leak does not exist in the, pressurizer such 6
as a safety valve or electromagnetic relief stuck 7
open."
8 BY MR. SELTZER:
9 Q
On September 24, 1977 the operators did not 10 do that before they secured or shut off'high pressure 11 injection, did they?
12 A
They did in the sense that they checked their 7-s
(_
13 instrumentation, and the instrumentation they thought 14 told them that the valve was shut.
In that sense they did, 15
.But in the sense of not knowing what that instrumentation 16 actually meant, they did not they tried to do that.
17 g
Do you know whether it's a fact that the 18 rupture disc had blown just prior to the operators 19 terminating high pressure injection?-
20 A
The indication of actual ruptured disc, as.far 21 as the operator was concerned, probably tracked what our 22 reactimer tracked.
The operator was made aware of the 23 rupture disc cracking, blowing, whatever the term may be,
[~))
24 by a rise in level of the normal sump.
And that was when l
25 the operctor realized that.
Now the pressure trend or 1
~
c
__y.-
_.._y.,
1 Hickey 68
(~h
(_)
2 other indication that maybe was being taken on the reactimeter may have shown that the rupture disc went 4
before the high pressure injection.
()
5 Q
In fact, subsequent knowledge of what was 6
actugily happening in the system showed that there was a 7
leak from the pressurizer at the time that the operator secured high pressure injection, isn't that right?
9 A
That is correct.
L 10 Q
What do you understand, if*anything, is the 11 purpose of submitting LER's or lice'nsee event reports?
i 12 A
I understand -- this is my understanding of it.
v' 13 My understanding was that.it's to inform the NRC of 14
. ~...
events that happened, either violations of text or 15 abnormal ~ occurrences,that occur at the plant.
And in so 16 doing, due to the distribution of the LER's, that they 17 were available for other entities, whether they be plants 18 or whatever.
They are public documents at.that point.
19 MR. SELTZER:
I have no further questions.
20 MR. KOLB: We don't have any further questions.
21 Whereupon the deposition was concluded at 22 5:15 p.m.
23
~s v
l 25 I
t
__~
4 169 1
O 2
1 3
CERTIFICATE 4
1 5
I have read the foregoing transcript on 6
and it is true and correct to the best 7
of my knowledge with the exception of the changes, 8
(if any.) that have been made by me on the 9
attached correction sheet.
(
10 I
4 11 4
1~0 JAMES M.
HICKEY O-13 14 Subscribed and sworn to before me 15 this day of 1981.
16 17 Notary Public 18 19 20 21
{.
22 23 24 25 l
-.-..--~, _.-- _.-._._
=
1 171 2
SUMMARY
INDEX 4
3 SUBJECT PAGE NO,
'4 Examination
(
5 4.
By Mr. Seltzer 3,
168 6
By Mr. Kolb 95 7
8 Exhibits Marked GPU g
Exhibit 3,000 9
i G7une '77 Training Services T203) 10 8
GPU Exhibit 3, dO3 9
11 GTune '77 Training Services T302) 12 GPU Exhibit J,.0.0 2 10 G7une '77 Training Services T303) 13 GPU Exhibit 3,003 10 14 G7une '77 Training Serviers T304) 15 GPU Exhibit 1,004 73
(. Emergency Procedure EP1202.06) e 16 17 18 19 20 o
I 22 23 lo 24 25
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