ML20072H765
| ML20072H765 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/19/1982 |
| From: | Floy J, Floyd J METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-06, TASK-07, TASK-1, TASK-2, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290727 | |
| Download: ML20072H765 (134) | |
Text
.
160 UNITED STATES DISTRICT COURT
~
SOUTHERN DISTRICT OF NEW YORK V
x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, f
cb Plaintiffs,
-against-
- 80 CIV 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
Defendants.
x Continued deposition of METROPOLITAN EDISON COMPANY, by JAMES R.
FLOYD, taken p
by J;efendants, pursuant to adj ournmen t,
L at the offices of Davis Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, February 19, 1982, at 9:30 o' clock in the forenoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
Ih 8306290727 820219 PDR ADOCK 05000289 T
PDR P)
DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTENS 369 La n t N GTO N AVENUE WALTER SH APIRO. C.S.R.
NEW Y O m st. N.Y.
loot?
CH ARLES SH APIRO. C.S.R.
TELEPMON: 212 - 867 8220
i 1
161 2
Appe aran ce s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York
- g 5
By:
RICHARD C.
SELTZER, ESQ.
6
-and-MYRON KIRSCHBAUM, ESQ.,
7 of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 One Chase Manhattan Plaza New York, New York 11 By:
KAREN E.
WAGNER, ESQ.,
12 of Counsel o
14 LeBOEUF, LAMB, LEIBY & MacRAE, ESQS.
Attorneys for Witness 15 1333 New Hampshire Avenue, N.W.
Washington, D.
C.
20036 16 By:
MICHAEL F.
McBRIDE, ESQ.,
17 of Counsel 18 19 Also Present:
20 SUSAN HANSON 21 O
23 24 25
1 162 2
JAMES R.
FLOY D,
having been r
3 previously duly sworn, was examined and 4
testified further as follows:
5 EXAMINATION (continued) gg 6
BY MS. WAGNER:
7 Q
Are you aware you are still under oath 8
today?
9 A
Yes.
10 Q
Do you still have a license on a nuclear 11 reactor?
12 A
No.
13 Q
When did you stop having a license?
14 A
I believe it was November 1981.
15 Q
Was the license that expired a cross-16 license for TMI-1 an d 2 7 17 A
No.
18 Q
What was it?
19 A
It was a license on Unit 2 for cold 20 shutdown only.
21 Q
When did your cross-license for operation 9
22 of the units expire?
23 A
Right after the accident, March 28, 1979, i
24 we split personnel between the two units and I was Ok/
25 assigned to Unit 2.
At that time, we gave up the
.. 1
1 Flcyd 163 2
cross-license.
3 Q
At some point in your training, at any 4
tine, did you come to understand how a nuclear
]ll 5
reactor works?
6 MR. SELTZER:
What training are you 7
talking about?
8 MS. WAGNER:
Any training.
9 MR. SELTZER:
Navy training included?
10 MS. WAGNER:
Absolutely anything.
11 A
As a previous holder of a senior reactor 12 operator's license, I must answer yes.
13 Q
Do you still know how the nuclear 14 reactor work s?
15 MR. SELTZER:
Let me object.
That 16 question is overly broad.
I think it is 17 unfair since there are infinite degrees to how 18 well one can understand how a reactor works.
19 There is no way anybody can understand your 20 question, to what degree, you are asking, does 21 he unde stana i.cw a reactor works.
O 22 Q
Do you have a general understanding of 23 how it is that a nuclear reactor produces electricity?
24 A
Yes.
25 Q
How does it do it?
I mean generally.
1 Floyd 164 2
I don't want to know every single valve.
3 A
The reactor is merely a heat source to 4
generate steam to turn the turbine, which is a prime 5
mover, to produce relative motion metwee6 the
]g) 6 current carrying conductor and the magnetic field 7
in the main generator.
8 Q
Is it correct that a B&W nuclear rea'ctor 9
is designed to have both a closed system, called the 10 primary 'ystem, and a secondary system, which is s
11 not the same thing as the primary system?
12 A
Yes.
13 Q
Is it correct that the heat from the 14 nuclear core is circulated through the primary system?
15 A
Yes.
16 Q
Is it correct that at some stage in 17 the process, the heat is transferred to the secondary 18 side?
19 A
Yes.
20 Q
Do you know where it was that you learned 21 these things?
O 22 A
No.
23 Q
Do you think you knew them before the 24 accident?
l
\\
25 A
Yes.
I i
1 Floyd 165 2
Q At TMI-2, do you know what was the 3
normal operating average temperature of the primary 4
system?
]lh 5
A Above 15 percent power, it was 581 6
degrees Fahrenheit.
7 Q
Do you know what was the normal pressure 8
at which the system operated above 15 percent power?
9 A
2200 pounds per square inch.
10 Q
Did you understand at that time what the 11 boiling temperature of water was at atmospheric 12 pressure?
13 A
Would you define "at that time"?
14 Q
Prior to the accident.
15 A
Restate the question.
16 (Question read back.)
17 A
Yes.
18 Q
What was it?
19 MR. SELTZER:
At what elevation?
20 MS. WAGNER:
At sea level.
21 A
212 degrees Fahrenheit.
22 Q
In that case, why was it that the water in 23 the primary system was not boiling when it was at 24 581 degrees Fahrenheit?
~'
' (J
)
1 25 A
The overpressure on the system created
-2.
~
c y
1 Floyd 166 2
by the pressure in the pressurizer prevents boiling 3
until you reach saturation temperature.
4 Q
Was it your understanding that a lll 5
pressurized water reactor was not intended to operate 6
at saturation temperature in a primary system 7
outside of the pressurizer?
8 All my questions relate to your 9
understanding prior to the accident.
10 A
Do you mean all temperatures of the water 11 in the reactor coolant system should be below 12 saturation temperature?
13 Q
I mean that water should not be in a bulk 14 boiling mede.
15 A
Yes, I knew that before the accident.
16 Q
Do you know where you learned that?
17 A
No.
18 Q
Do you have any understanding of what 19 would happen in the primary system of a pressurized 20 water reactor if the water had recched a 21 bulk boiling stage in the primary system outside of 9
22 the pressurizer?
l 23 A
Yes.
24 Q
What was your understanding would be the 25 results?
1 Floyd 167 l
2 A
Net steam formation.
3 Q
pid you have any understanding as to 4
what effect that not steam formation would have on ll) 5 the reactor coolant system, if any?
6 A
Yes.
7 Q
What was that understanding?
8 A
As the size of the new steam bubble grew, 9
the pressurizer level would increase.
10 Q
Where would the new stean bubble grow?
11 At dif ferent places or in any particular place?
12 A
As long as the reactor coolant pumps are 13 in service, I don't think you wind up with a discrete 14 interface between steam and liquid but in fact 15 the steam will be entrained in the reactor coolant 16 system flow.
17 Q
Do you recall where you learned about 18 steam formation in the reactor coolant system?
19 A
No.
That is too long agd.
20 Q
Did you know prior to the accident what the 21 saturation temperature was for water which was at O
22 2200 pound pressure?
23 A
Yes.
l 24 Q
What was it?
25 A
Approximately 647 degrees Fahrenheit.
1 Floyd 168 2
Q Did you know what saturation pressure was 3
for water which was at 581 degrees temperature?
4 A
No.
lll 5
Q Did you believe while you were supervisor 6
of operations for Unit 2 that the operators at Unit 2 7
had an understanding of the system similar to what 8
you have just described to me?
9 MR. SELTZER:
You mean evqry detail 10 that he just de s cr,1be d?
11 MS. WAGNER:
Yes.
12 A
No, I do not believe they had that 13 knowledge prior to the accident.
l
- O 14 Q
What is your lack of belief based upon?
15 A
I don't believe they had as deep an 16 understanding of bulk boiling as I had.
17 Q
Do you have any understanding as to why 18 you had a greater understanding than they did?
19 A
I had --
20 MR. SELTZER:
I object.
There is no 21 foundation that this witness interviewed or 9
22 examined the operators to know why their 23 knowledge was not identical with his.
24 MS. WAGNER:
I asked him if he had sny 25-basis for his understanding which he has given
.... ~
1 Floyd 169
(~
2 already.
If he does not have a basis, he can V) 3 say so.
4 MR. SELTZER:
He may know why he knows ll 5
things, but I am objecting to your asking him 6
why he knows why others didn't have the 7
knowledge.
8 MS. WAGNER:
If he knows why, he can tell 9
me.
If he doesn't know why, he can tell me.
10 (The record was read back.)
11 A
My background was of greater diversity 12 and longer in time than the operators, and therefore, 13 I had more time to think about systems.
14 Q
Prior to the accident while you were 15 supervisor of operations for either unit, did you 16 think it was important that operators understand 17 what you have testified you understood about the 18 system and the effect of bulk boiling in the reactor 19 coolant system outside the pressurizer?
20 MR. SELTZER:
When you say "the effect 21 of bulk boiling," are you referring to his 22 testimony that es a new steam bubble grew, 23 pressurizer water level would rise?
24 MS. WAGNER:
Yes, I am.
25 THE WITNESS:
Would you reread her
1 Floyd 170 O]
2 question.
3 (Question read back.)
4 A
No.
ll 5
Q Was there any reason why you didn't 6
think it was important?
7 MR. SELTZER:
Are you asking him whethor 8
he discussed this with anybody or put it in 9
writing at all before the accident?
10 MS. WAGNER:
No, I am asking him if he 11 has any reason why he didn't think it was 12 important, whether it is in writing or not.
O 13 MR. SELTZER:
You are into an area where 14 your partners have precluded our examination 15 of B&W witnesses.
Your partners have 16 frequently lectured me that to ask somebody 17 about their thoughts previously unexpressed 18 in writing or orally is improper examination.
19 Are you saying now that you think this is a 20 proper area of inquiry?
21 MS. WAGNER:
First of all, I don't 22 believe that my partners have taken the position i
l 23 that an unexpressed opinion had prior to the 24 accident is an unf air ground for examination.
25 However, whatever their position is, it is also l
l
1 Floyd 171 2
my understanding that any objection that you have 3
to these questions has been waived on your behalf 4
by your associate, Myron Kirschbaum, who did 5
so at a deposition that I was taking of Mr.
6 Potts, so I had understood that his waiver would 7
apply to these kinds of questions regardless 8
of what the position of my partners might be 9
in depositions.
10 MR. KIRSCHBAUM:
Since it has been 11 mentioned that I allegedly made a waiver, I 12 would like to respond to that.
At the deposition 13 of Mr. Potts, what I did was I withdrew an 14 objection that I had made to questions that had 15 been asked of Mr. Potts.
I did not make any 16 waiver of objections either for the future 17 nor did I waive any objections that may have 18 been made in the past.
In addition, I believe 19 that I made my position at that time clear that 20 it was based on the fact that we were hoping 21 that in response to the action I was taking of 9
22 withdrawing an objection as to present belief, 23 that we would have a reciprocal withdrawing of 24 objections on the other side, which has not 25 occurred.
4 e
3 s
J s
1 Floyd 172 4
.(,
s
, 3 2
,'e MS. WAGNER:
I believe I told you I was l'
E 3
not offering any reciprocal withdrawing of s
objections, but nevertheless you went ahead and 4'
5 withdrew your objection.
'6 First of all, I don't think you 7
accurately reflected the position of my n,
e" 8
partners, and secondly, I believe this objection
.3g has been waived.
10 MR. SELTZER:
I am very pleased if you s ti f
11 think that I misstated the position of your 12 partners, because it would certainly open up J r.
13 areas of inquiry that had previously been 14 blocked, and I look forward to that.
J 15 Go ahead with your question.
16 MS. WAGNER:
For the record, let me state 17 that I, too, may misunderstand my partners'
- /
18 position, and as you may understand, my partners l
19 have the authority to tell me what to do j
20 which I do not have over them; 'however, I s'
21 believe that my statement is correct.
22-Let's reread the question.
23 (Question read back.)
.24 A
While I was supervisor of operations for f%
25 Units 1 and 2, I don't recall that thought ever q
.' s. s
~0 '
'-T
)
\\1
,s
.y 1
1 Floyd 173 O
2 entering my conscious mind.
l 3
Q The thought of whether it was important 4
or not?
ggg 5
A The phenomena I described about bulk 6
boiling and pressurizer level.
7 Q
You didn't have a thought as to whether 8
that was an important thing to tell the operators or 9
not?
10 A
No, just I didn't have the thought enter 11 my conscious mind while I was working at Three Mile 12 Island.
13 Q
I am not sure what thought you are talking O
14 about now.
15 A
The thought about bulk boiling causing 16 expansion of the reactor coolant system volume and a 17 consequent rise in pressuriser level.
18 Q
Am I misremembering your prior testimony?
19 Didn't you testify earlier today that you dip enow 20 that?
21 A
I knew that before the accident at Three 9
22 Mile Island Unit 2.
23 Q
Did you know prior to the accident at 24 Three Mile Island that operators at TMI used 25 pressurizer level as at least one indicator of system
1 Floyd 174 2
inventory?
3 A
It was the primary indicator of system 4
inventory I think it would be safe to say.
Jgg 5
Q Isn't it correct, however, that if the 6
result of bulk boiling in the reactor coolant system 7
was to lead to high pressurizer level, that 8
pressurizer level would not in such a situation be 1
9 an accurate indicator of inventory?
10 MR. SELTZER:
Are you asking him if that 11 was something that came into his mind while he 12 was at Three Mile Island before the accident?
13 MS. WAGNER:
First of all, I would like to 14 ask him if he agrees now with that statement.
15 MR. SELTZER:
I think even under your 16 interpretation of the Davis Polk & Wardwell 17 rule, that would not be a permissible area of f
18 inquiry.
19 MS. WAGNER:
I think it would be since 20 you waived your objection.
However, why don't 21 we start with whether he thought that prior to O
22 the accident.
23 (Record read.)
24 Q
Did you ever know prior to the accident 25 that when the reactor coolant system was in a bulk
1 Floyd 175 2
boiling mode the pressurizer level was not an accurate 3
indicator of system inventory?
4 MR. SELTZER:
Are you asking him did Jgg 5
this come into his mind while he was at Met Ed?
6 MS. WAGNER:
Yes.
7 A
The answer to that would have to be no.
8 Q
Whether or not you recall having a specific 9
thought to that effect, is that something you knew 10 just as you knew what you have previously testified 11 that the result of boiling in the reactor coolant 12 system would be a rise in pressurizer level?
13 A
Yes.
14 Q
Do you know what during normal operations 15 is the normal pressure of the steam generator at the 16 reactor at TMI-27 17 A
Primary or secondary side?
18 Q
steam generator pressure.
19 A
Main system pressure?
20 Q
Yes.
21 A
It is variable with power level from O
22 about 900 to 925 pounds per square inch.
23 Q
what was the normal operating temperature i
24 of the steam generator at TMI-27 25 A
592 degrees Fahrenheit.
,-m
1 Floyd 176
()
2 Q
Did the steam generator during normal 3
operations operate in a saturated mode?
4 A
Portions of it did.
lll 5
Q Do you recall what was the normal operating 6
pressure of the pressurizer at TMI-27 7
A In the B&W supplied system, there is no 8
indicator of pressurizer pressure supplied.
9 Q
Whether or not there is en indication 10 of it, do you know what the normal operating pressure 11 in the pressurizer was?
i 12 A
Only from what I have been told by B&W.
13 Q
What did they tell you?
14 A
It is effectively the same pressure as 15 loop pressure, which is hot leg pressure.
16 Q
Am I correct that you previously testified 17 that was 2200 psig in normal operation?
18 A
Yes.
19 Q
Do you know what the normal temperature 20 was in the pressurizer during normal operations?
21 A
I already testified to that question, too, 22 this morning, 647 degrees Fahrenheit.
23 Q
That was the temperature in the pressurizer?
24 A
Yes.
AU 25 Q
Did the pressurizer normally operate in a
1 Floyd 177
(
2 saturated mode?
3 A
Normally, yes.
4 Q
Do you know if the operators at TMI-2 lll 5
while you were supervisor of operations had any 6
knowledge as to under what conditions a bubble could 7
he transferred out of the pressurizer and into 8
some other portion of the reactor coolant system?
9 MR. SELTZER:
You are asking him whether 10 before the accident he knew whether they knew 11 what you have just a$ked?
12 MS. WAGNER:
That's right.
13 A
I don't know.
14 Q
Before the accident, did you have any 15 belief as to whether it was important or not important 16 that they know this, that they know the conditions 17 under which the bubble could be transferred?
18 A
To the best of my recollection, B&W never 19 spoke about transferring bubbles out of pressurizers, 20 and, therefore, it was not a highlight of the training 21 program.
22 Q
Regardless of whether it was a highlight 23 of a B&W training program, did you have any understanding 24 or opinion as to whether it was an important thing for O
25 operators to know?
1 Floyd 178 I
("%_)
2 MR. SELTZER:
Isn't that the same question 3
you asked him seven or eight minutes ago about 4
whether a phenomenon had ever entered his h
5 mind?
6 MS. WAGNER:
I believe that we have had 7
testimony that there are at least two ways of 8
transferring a Bubble, and I think his prior 9
testimony today related to only one such fashion.
10 I believe he gave testimony yesterday about another 11 circumstance.
12 A
Your question centered on my knowledge or I~D 13 understanding as I remember the que s tion, so I respond V
14 to my understanding of the question..
15 Q
The question is did you think prior to 16 the accident that it was important for the operators 17 to know under what conditions a bubble would shift 18 from the pressurizer to some other portion of the 19 reactor coolant system?
20 A
Prior to the accident at Three Mile 21 Island, the question was never phrased that explicitly.
22 Therefore, I cannot testify to what I thought about 23 that question before the fact.
24 Q
Just so the record is clear, I believe 3
L 25 that yesterday you testified about a situation in which
1 Floyd 179
[a]
2 as a result of overfeed in the secondary side, 3
primary side would cool down,and if you allowed it 4
to cool down beyond a certain point, the pressurizer lh 5
would empty and the steam space would go into the l
Regardless of what you 7
testified yesterday, is that an accurate statement 8
of an understanding you had prior to the accident?
9 A
Yes.
10 Q
When I asked you previously whether you 11 knew whether operators knew about the shifting of the 12 bubble phenomenon, were you addressing both what you 13 have described this morning and what I just described, 14 or were you only addressing the previous situation?
1 15 MR. SELTZER:
I don't understand.
What is 16 the previous and what is the current situation?
j 17 Q
were you addressing both situations?
t 18 MR. SELTZER:
Why don't you ask about i
19 each situation separately and then the record 20 will be clear, instead of making it a compound t
l 21 question?
h i
l 22 Q
Did you have any knowledge prior to the 23 accident as to whether or not operators knew that in 24 an overcooling situation the bubble could leave the pG 25 pressurizer because the pressurizer emptied?
1 Floyd 180 2
A I do not know if that was part of the
(
3 operator's knowledge or not, other than my own.
4 Q
Did you think it important that they know ill 5
about that phenomenon?
6 A
Had it been asked as explicitly as you are J
7 asking it this morning, I am sure it would have been 8
emphasized.
9 Q
Had you ever encountered in real life 10 any instance of that phenomenon?
11 MR. SELTZER:
You mean had he ever been 12 working on a reactor system that had drained the 13 pressurizer dry and pushed the bubble out of 14 the pressurizer?
15 Ms. WAGNER:
Had he ever heard of that 16 happening someplace in a real nuclear reactor 1
17 whether or not he was actually present?
18 A
There was some concern that that might 19 have happened at TMI-2 in one of our transients, i
20 but an analysis by D&W showed that it did not take 21 place.
22 Q
Why was there concern about it?
23 A
The concern was at the engineering l
24 level, not at the operator level, because at the 25 engineering level I think we understood some of the l
1 Floyd 181
()
2 ramifications of that.
3 Q
Do you know if the control room at TMI-2 4
contained steam tables, prior to the accident?
I
- lh 5
A It is my belief that a set of steam 6
tables was kept in the control room before the accident.
7 Q
Did you know prior to the accident how 8
to use steam tables?
9 A
Yes.
10 Q
Did you know whether or not the TMI-2 11 operators knew how to use steam tables?
12 A
It was instructed by the training department.
(
13 Whether the instruction was effective or not, I don't 14 know.
15 Q
Were you familiar prior to the accident 16 with the high pressure injection system at TMI-27 17 A
Yes.
18 Q
Is it correct that high pressure injection 19 would be automatically actuated at an RCS pressure 20 of 1640 psig?
21 A
And decreasing, yes.
22 Q
Is there any other actuation set point for 23 automatic actuation of HPI?
24 A
Four pounds reactor building pressure rising.
25 Q
Do you know or did you know prior to the 1
e
.w
1 Floyd 182
()
2 accident why there was a set point based on reactor 3
building pressure?
4 A
I have a belief.
I don't know that it lh 5
is knowledge, but it was my belief that it was to 6
provide redundancy.
7 Q
Do you have any understanding of how it 8
would provide redundancy?
9 A
on either a loss of coolant accident or 10 a main steam system break inside the reactor building, 11 it may either be the first signal or an immediate 12 backup signal to trip the reactor.
(
13 Q
when you say "the signal," do you mean the 14 reactor building pressure signal?
15 A
Yes.
16 Q
Is that because on a loss of coolant or 17 steam leak inside the reactor building, inventory a
18 will go into the reactor building and increase its 19 pressure?
20 A
The increasing reactor building pressure 21 is not a function of increase in reactor inventory as 22 it is with energy.
23 Q
Why does energy increase in the reactor 24 building?
25 A
The air is being heated by the hot steam.
1 Floyd 183 2
Q Were you aware of any discussion at 3
either Metropolitan Edison or General Public Utilities 4
prior to the accident with regard to elimination of llh 5
the 1640 psig HPI 4ctuation set point?
6 A
I was not aware of any such discussions.
7 Q
Did you have any understanding prior to 8
the accident at Three Mile Island as to whether the 9
TMI-2 operators knew that a B&W pressurized water 10 reactor during normal operations was not supposed to be 11 run in a saturated fashion? And when I say " saturated 12 fashion," I mean did they know that the reactor
()
13 coolant system in the primary system outside the 14 pressurizer was not intended during normal operations 15 to be in a bulk b&iling mode?
16 MR. SELTZER:
You are asking him did he 17 know whether the operators knew this?
18 MS. WAGNER:
Yes.
19 MR, SELTZER:
I object.
No foundation 20 that the operators and he discussed this.
21 MS. WAGNER:
If he doesn't know, he 22 doesn't know.
23 A
In the normal operating mode, I believe t
24 the operators understood that the reactor protection 25 system prevented the condition that you describe.
.,,m,-
4 4
1 Floyd 184 i
(
2 Q
Did you have an understanding prior to i
3 the accident of why the reactor protection system t
4 would prevent such operation or did prevent such lll 5
operation?
l 6
A Yes.
2 7
Q What was that understanding?
8 A
It comes back to the bulk boiling i
9 question.
i l
10 Q
Can you be more specific?
11 A
It is also tied to the large LOCA where 12 the core does become at least partially uncovered and
. ()
13 the need to quench a Zirc water reaction, which may 14 take place.
i 15 Q
Is it your tes timony that the reactor i
16 protection system prevented operating in a saturated 17 mode because of the problems associated with bulk 18 boiling in the reactor coolant system?
I i
19 A
That is at least part of my answer, yes.
i l
20 Q
What was your understanding of the l
~
21 problems of operating in such a mode?
t l
22 MR. SELTZER:
You are talking about 23 probleas of normal operation generating electric 24 power?
25 Ms. WAGNER:
I am talking about the
1 Floyd 185
()
2 problemduring mormal operation having 3
p system operated in the bulk boiling 4
fashion.
illl 5
MR. SELTZER:
You are asking for his 6
understanding before the Three Mile Island
'i accident?
8 MS. WAGNER:
Yes.
9 A
That condition is routinely tolerated in 10 the boiling water reactors, and, therefore, I don't 11 think I can briefly explain why it is not allowed in 12 pressurized water reactors.
(
13 Q
can you explain it at some length?
14 MR. SELTZER:
I don't think it is 15 appropriate to get into a lecture on the 16 mechanics of a system.
If you have a more 17 specific question, maybe that would be more 18 to the point.
19 Q
My question is did you know prior to the 20 accident why you weren't supposed to run a B&W 21 reactor with boiling in the RCS.
22 A
I must quibble with yo - tse of the 23 word " boiling."
24 Q
I am referring to bu ing.
O 25 A
Thank you.
The conditio.. of no net 1
1 Floyd 186
(
2 steam generation f ron the core exit which is a i
3 condition that precludes bulk boiling was established 4
to limit clad temperatures and hence center line fuel
- hh 5
temperatures.
6 Q
Did you have an understanding prior to the 7
accident of why the system was designed to limit the 8
temperature on the fuel cladding?
9 A
Yes.
10 Q
what was your understanding?
11 A
It is a duel concern.
The heat removal 12 from the surface of the cladding is done much less
(
13 efficiently with steam as a heat sink than water 14 as a heat sink, and hence the cladding itself if it 15 gets too hot, it could possibly fail, and at the same 16 time the cladding temperature is rising, the center 17 line fuel temperature and all other fuel temperatures 18 as well will also be rising and could lead to center 19 line melting of the fuel.
20 Q
Were you aware prior to the accident that 21 the B&W reactor was designed to trip on a variable 22 temperature pressure curve?
23 A
Yes.
I 24 Q
Did you have an understanding prior to l
25 the accident of why the variable temperature-pre.ssure
~
1 Floyd 187 f
l 2
trip was available?
3 A
Yes.
i i
j 4
Q What was your understanding?
h 5
A To limit the departure from nucleate 6
boiling or prevent the departure from nucleate 1
7 boiling.
8 (Continued on following page.)
l l
8 10 J
j 11 4
3 l
12 13 i
14 15 i
16 a
h 17 I
18 l
l 19 l
20 l
21 l
22 23 l
[
24 O
25 i
1 Floyd 188 2
Q In the reactor coolant system?
A Y***
3 Q
Prior to the accident, were you familiar 4
with the low pressure injection system?
th 5
A Yes.
6 Q
What was the purpose of the low pressure 7
8 injection system?
A To deliver a large volume of cold water to g
10 keep the core covered with a large reactor coolant 11 system break.
12 Q
Was there any relationship, did you under-13 stand prior to the accident that there was any relation-14 ship between the purpose of the low pressure injection 15 system and the purpose of the high pressure injection 16 system?
A Yes.
17 18 Q
What was your understanding?
19 A
Those two systems coupled with the core flooding tanks theoretically, but not in reality, 20
'i protected us from a spectrum of break sizes, and that is 9
so stated in the FSAR.
22 23 Q
Why do you say theoretically but not l
24 actually or not in reality?
O 25 A
After the unit was in operation and we i
l l
l
1 Floyd 189 2
Operators, and I include myself with all licensed
/~D) perators on TMI-2 at this point, thought we were 3
4 protected by the transient analysis provided by 5
Babcock & Wilcox until they came out with their
-lh 6
modifications for the small break LOCA.
At that point in time we recognized that we 7
8 had been vulnerable and we had not had the protection 9
that had been insured by the vendor.
10 Q
Which guidelines for small break LOCA are 11 you referring to?
12 A
The ones that we incorporated into our LOCA 13 procedure, the administrative controls which involved 14 cross-connection of HPI discharge.
15 Q
Did you have an understanding when you 16 discovered or heard about the new small break 17 instructions of what were the conditions for which you 18 had not previously been protected?
19 A
Yes.
20 Q
What were those* conditions?
21 A
It was a break of limited size with a 22 failure of one of the two high pressure injection pumps 23 to deliver water to the reactor coolant system for l
24 whatever reason.
25 Q
In some break of limited size, one HPI pump
1 Floyd 190 2
was not going to be sufficient?
Is that what was discovered?
3 4
A Yes.
5 Q
Did you have an understanding as to why in ll>
6 such situations the lack of pro :ection would not be i
7 compensated for by the low pressure injection system?
8 A
The vulnerability was not to all break sizes 9
but only to certain break sizes.
Had the break gotten 10 bigger, then the low pressure injection system could i
11 have. protected us, but it was a very limited range of l
12 break sizes for which we were not protected.
13 Q
Is that because for that limited range of 14 break sizes, the system would not depressurize to the 15 point of low pressure injection?
16 A
Yes.
17 Q
Did you have any understanding of why the 18 system would not depressurize to that point?
19 A
The break was not big enough to allow the 20 system to depressurize.
21 Q
Wouldn't it be true that any size break, t
22 if you just let it go, all the water would go out 23 eventually?
24 A
If you are not feeding it.
25 Q
so why wouldn't the system depressurize?
c
1 Floyd 1.91 1
1 2
A It would, if you are not feeding, but if i
3 you have one HPI pump running, you are feeding the leak.
4 Q
But I take it you understood that in that lh 5
situation you weren't feeding the leak enough, because 6
if you were, then you wouldn't be unprotected, isn't 7
that correct?
8 MR. SELTZER:
In other words, you are asking 9
before they got the instruction from B&W to 10 cross-connect the high pressure injection lines, 11 did he have an understanding that there wasn't 12 enough HPI fed in to cover the leak?
{}
13 MS. WAGNER:
That's right.
14 A
I have lost my train of thought.
~
15 Q
I believe 16 MR. SELTZER:
I think it is going to take 17 probably more than a few questions to finish 18 this off.
Do you want to take a short recess?
19 MS. WAGNER:
Let me try to do it in a couple 20 of questions.
21 Q
I believe it is your testimony that there l
22 is a certain range of break sizes for which one HPI pump 23 would not provide sufficient water to provide you 24 protection.
Is that correct?
O 25 x
y.
i 4
1 Ficyd
-192
(
2 Q
If one HPI pump would not provide suffi ient invent ry, why would the system not 3
4 depressurize to the low pressure injection set point?
lhh MR. SELTZER:
Do you mean why wouldn't it 5
6 depressurize before the core had uncovered and there was fuel damage?
7 g
MS. WAGNER:
No.
Why wouldn't it 9
depressurize to the set point of low pressure 10 injection?
11 MR. SELTZER:
Ever?
Before the end of time?
12 MS. WAGNER:
The witness has testified that
()
13 the system would not so depressurize, and I am 14 asking him why.
15 A
You are forcing me to a conclusion which 16 seems logical but I am not sure it is applicable, and 17 that is to get me to saturation in the reactor coolant 18 system.
19 MR. SELTZER:
I wouldn't assume what she is 20 trying to get you to.
I didn't hear her suggest 21 that.
22 A
I do not believe that was my understanding 23 of the reasons for the small break LOCA change.
1 24 Q
Can you tell me what was your understanding?
O 25 A
No.
4
Flovd 193 1
()
2 Q
Because you don't recall it or because y u didn't have one?
3 A
.Because I don't recall it.
4 (Recess taken.)
- h 5
6 BY MS. WAGNER:
7 Q
Do you recall during the time you were 8
supervisor of operations for either unit at TMI, whether there was training administered to reactor 9
10 operators of one unit concerning events which occurred 11 at the other unit?
12 A
Are you now leaving the small break LOCA 13 issue?
14 Q
Yes.
15 A
I would like to add to one of my previous 16 answers before we leave that area to make the record 17 complete.
That is, on the answer where I referred to 18 the fact that the FSAR said we were protected from all 19 breaks until the small break LOCA came along, we then 20 assumed we were protected in all breaks again, but we i
were still deceived by B&W in that we were not protected f
21 22 from small breaks at the top of the pressurizer and the 23 indications that would result from that break.
I think that would make my previous answer 24 O
25 complete.
Floyd 194 g
O Q
Are you testifying that if a break occurred at the top of the pressurizer, the system was not 3
designed to withstand that break?
A If you include in your definition of system the procedures, then that is true.
That combined system of hardware plus paper was not designed to handle that break because the LCCA procedures supplied by B&W gave misleading symptoms for that break.
Q What was it about the procedure that would result in the system being unprotected in the event of 11 a break at the top of the pressurizer?
A The operator was told, instructed through the procedure to expect a decreasing pressurizer level when in fact it was an increasing pressurizer level, so he would get into the wrong procedure for that break.
Q How, if he got into the wrong procedure, was the system not protected in the event of that break?
g A
Depending on which procedure he then g
thought he was in, he could do something that was detrimental to the system.
21 i
Q What procedure would he be in?
22 A
I don't know.
l Q
Was it your understanding prior to the 24 1
accident that the system was protected against small 1
1 Floyd 195 2
breaks even if operators deliberately turned off all 3
redundant HPI trains?
)
4 MR. SELTZER:
Turned it off at what point?
h 5
MS. WAGNER:
At the time of the break.
6 A
The operators had no procedures which would 7
allow them to do that.
0 Q
Was it your understanding that the system 9
would be protected if in the event of a small break for 10 some reason the HPI system was disabled because it fell 11 apart or a bomb hit it or something?
12 A
It is my belief that the first line of 13 defense in a nuclear plant control room is the reactor 14 plant operators, and they operate by properly approved 15 procedures, and as such, I would not expect the plant 16 to be designed against sabotage or whatever you are 17 referring to.
18 Q
So is it. correct that it was your 19 understanding prior to the accident that if for some 20 reason no HPI was available, the system would not 21 necessarily be protected in the event of a small break?
22 A
That is true.
3 Q
Do you recall whether prior to the accident, 24 operators in one unit were ever given training in 95 occurrences, reportable occurrences, at the other unit?
---s
., = -
Floyd 196 1
A For those of us who were cross-licensed, it 2
was mandat ry that we be trained on both units, so your 3
question only has relevance if applied to the people 4
who were not cross-licensed, but it is my belief that ih i
5 all licensed people at TMI were cross-fertilized in 6
the other unit.
7 8
Q Were you aware in 1977 of a proposal that TMI-2 operators be given an hour's worth of training I
9 10 in previous reportable occurrences at TMI-17 A
I don't recall that instance.
11 12 Q
I would like to show you a document which has been previously marked as B&W 72.
I would like to 13 14 show you at the same time a memorandum which has been 15 Previously marked B&W 73, which relates to the same 16 subject as B&W 72.
17 Have you seen B&W 72 before?
18 A
I don't recall having seen B&W 72 before.
19 Q
Do you recall having seen B&W 73 before?
A No.
20 21 Q
I will note for the record that your name O
22 Appears on both as a recipient of a carbon copy.
t B&W 72, the subject of B&W 72 is 23 24
" Incorporation of Unit 1 and other plant operating 25 experience into the Unit 2 training effort."
1 Floyd 197 0
In the second paragraph of the document, 2
there is a question asked, "In other words, could you 3
4 devote maybe one hour of training or less to talking llk about some of the significant. things that happen 5
6 industrywide as they might be relative to Unit 2 in the 7
training program?"
8 Do you recall ever having discussions with anybody concerning training of one hour or less about 9
10 significant industrywide things?
11 MR. SELTZER:
Do you mean in addition to 12 what he said earlier about Unit 2 people being 13 trained on Unit 1 occurrences?
(}
$S. WAGNER:
That's right.
14 15 A
It is my recollection that during some of 16 my requal training, I heard such lectures being given, 17 and they were not limited to one hour or less.
If there 18 was enough material, the self-study time was reduced 19 to the extent that it impinged on the discussions which 20 were applicable.
21 Q
B&W 73 says, "A minimum one-hour training 22 program is being prepared covering industry experience, 23 Unit 1 experience, and reportable occurrences from j
l 24 similar units."
'~'
25 Do you remember the training described here I
(
1 Floyd 198 2
or is it what you described in your previous answer?
A I think I described both at once.
3 4
Q The paragraph indicates that Nelson Brown
.h will conduct the course on certain dates.
Do you know 5
6 who Nelson Brown is?
A He was a Met Ed or GPU employee in the 7
8 training department.
9 Q
Do you recall his giving lectures on this 10 subject?
11 A
No.
12 Q
During the time you were supervisor of 13 operations for either unit, did you ever see documents 14 entitled technical data reports?
15 A
Yes, because it rings a bell.
I recall 16 TDR's, and it seems to fit.
17 Q
Do you recall what TDR's were?
18 A
No.
19 Q
Do you recall how often you used to see i
20 them?
21 A
No.
22 Q
Do you recall what their subject was?
23 A
Their title is fairly suggestive but I i
24 don'.t recall.
25 Q
Do you ever recall receiving training
Ficyd 199
}
concerning a TDR?
(
2 A
I have no recall of'such a thing.
3 4
Q Do you recall knowing what topical reports
<gg were?
3 A
res.
7 Q
What are topical reports?
8 A
The ones I remember were issued by B&W in the 1-WW-0-XX serie s.
g 10 Q
What is a topical report?
11 A
It was usually used as a tool to convey 12 technical information and data to the Nuclear Regulatory 13 commission.
(
14 Q
Under what circumstances would you see such 15 a report?
16 A
I learned about their existence fairly early 17 on in my training program with B&W.
I recognized their 18 value and sought them out.
19 Q
What was their value?
20 A
It was an in-depth analyis as opposed to a 21 condensation or summary of that analysis which is what 22 would normally appear in the FSAR or in fact the whole 23 dccument could have been incorporated in the FSAR by 94 reference.
25 Q
Where did you go to get them?
f 1
'Floyd 200 A
We kept a file of them in the central office 2
under that title, and so I knew which file drawer to go 3
to to find them.
4 4
5 Q
Is this the central office at Three Mile 6
Island?
A Yes.
7 g
Q Is that in a building or in a trailer?
Did it move?
9 10 A
It moved also.
11 Q
Do you ever recall seeing safety department 12 summaries?
13 A
No, I do not.
14 Q
Do you recall knowing what they are?
15 A
No.
16 Q
Did you ever, while you were supervisor of 17 operations for either unit, review on a periodic basis 18 documents which concerned reportable events at other 4
19 plants?
20 MR. SELTZER:
Is this different from the
. r..
21 questions yesterday about LER's?
- e'l.
22 MS. WAGNER:
Yes, documents other than 1
}'
7,//^
23
'LER's.
i
'F
- d;;; O;"
},
24-A Your use of the word "ever" and " periodic" l
Q -"
25 in one' question leads me to great consternation.
L, i
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,s.
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Floyd 201 1
f) 2 Q
Was it part of your job routine as a V
8upervisor of operations to review such documents?
3 MR. SELTZER:
You mean documents otFPr than 4
LER's or summaries of LER's?
!lh 5
MS. WAGNER:
Documents other than LER's 6
because I don't believe we discussed summaries of 7
8 LER's yesterday.
A I don't believe it was part of my job g
10 description to do so, but it was part of my personal 11 desire to stay abreast of the industry to read what I 12 could get my hands on.
[~h 13 Q
What could you get your hands on?
U 14 A
It varied from day to day.
15 Q
Can you give me any idea of the things you 16 got your hands on more frequently than other things?
17 A
No, I don't recall.
18 Q
Do you ever recall seeing a publication 19 entitled " Current Events - Power Reactors"?
20 A
Yes.
21 Q
Is that a document which you saw regularly?
22 A
No.
23 Q
How often do you think you saw it; once a 24 year, ten times a year?
25 A
I can't remember.
Floyd 202 Q
Did you ever see a document entitled 2
(
Nuclear Power Experience?
3 l
A Yes.
4 Q
Do you know how often you saw that?
9 A
No.
6 Q
What was it?
A It was a summary generated by someone about experience at nuclear power plants.
Q Do you recall that it would have descriptions l
in it or did have descriptions in it of transients at 11 other plants?
l A
13 My memory of it is not that accurate.
Q Do you recall that Current Events - Power Reactors discussed transients at other plants?
A My mem ry is n t that detailed.
6 Q
When you were reviewing these documents, was g
it part of your purpose to gain information about gg 19 A
I cannot recall if that was my desire.
Q 21 Do you recall, what was your purpose in reviewing these documents?
22 A
Personal information.
g Q
Did you ever tell anybody else about something that you read in one of these reports?
1 Floyd 203 A
I have no specific recall of any such 2
c mmunication, but if it applied to us, I would have 3
discussed it with the operators.
4 lh-5 Q
When you say "if it applied to us," do 6
you mean if it concerned the TMI plants or if it was 7
something that could be relevant to the TMI plants?
g A
Something that could be relevant to the TMI 9
plants.
10' Q
Do you ever recall seeing an Atomic 11 Energy Clearing House document?
12 A
Yes.
13 Q
What was that?
14 A
It was one of the thicker reports that came 15 around, as I remember, and it was usually routed to us 16 at least for periods of time for department heads to 17 read and initial.
18 Q
Do you recall if that document ever containec 19 information about transients at other plants?
e 20 A
I cannot recall any specific examples, but 21 I believe it did.
22 Q
Prior to the accident, were you familiar 23 with meetings known as users' group meetings?.
24 A
Not from firsthand knowledge, but I knew 25 they were taking place.
t
i Floyd 204
(
g Q
What were users' group meetings?
A It was my understanding that the utilities 3
who had purchased B&W reactors had formed this group 4
h as an exchange of information center.
5 6
Q Do you recall who, if anybody, from Three Mile Island attended these meetings?
7 g
A Normally the station superintendent or, in 9
his absence, a unit superintendent.
10 Q
During the time you were superviser of 11 operations for Unit 2, who was the station 12 superintendent?
IS A
I can't keep the years straight when Mr.
(
14 Herbein left and when Mr. Miller became station 15 superintendent.
16 Q
Was Mr. Miller station superintendent until 17 the time of the accident?
l 18 A
He may have had a title change before the 19 accident, but I don't recall when that would have taken 20 place either.
21 Q
Who was the unit superintendent for Unit 2 22 while you were operations supervisor?
23 A
I think initially it was Gary Miller, and 24 then it was Jim Seelinger in an acting capacity, and 25 then it was Joe Logan.
Floyd 205 1
2 Q
Did you ever discuss with any of these
()
P80P e users' group meetings?
l 3
A The normal flow of information was that the 4
5 Person who was at the meeting would write some notes 4lk 6
and circulate them for our use.
Whether any of those notes stimulated discuscion, I don't recall.
7 g
Q Do you recall seeing such notes?
A Yes.
9 10 Q
Did you read them?
11 A
Yes.
12 Q
Do you recall ever having any questions about'.
' f; 13 them?
%/
14 A
I have no specific recall.
15 Q
Do you recall ever speaking with anybody 16 at another plant about a transient which occurred at 17 that plant?
18 A
I can recall no specific cwnversations that 19 would meet those conditions.
20 Q
Do you recall generally that this is 21 something you did on occasion?
22 A
I was on occasion in contact with people 23 at other plants, usually counterparts of my own title, 24 and the subjects were not restricted to transients or l
25 anything else but just how are things going there, how l
1 l
i
g Floyd 206
'(
are things going here, type of things.
2 Q
Did you have regular meetings with people 3
who were supervisor of operations at other plants?
4 h
A 5
6 9
Did you know prior to the accident of an entity called the Owners' Group?
7 8
A I don't recall such a group.
9 Q
I take it then you were not a participant 10 in such a group, as best you can recall?
A No.
gg 12 (Continued on Page 207)
C:)
23 14 15 16 17 18 19 20 91 I
22 23 24 O.
5 1
1 Floyd 207
-(
2 Q
Do you ever recall any change in procedures 3
at TMI-2 based upon a transient occurring at another
'4 plant, prior to the accident?
lh 5
A I understand " prior to the accident."
It 6
is "ever recall."
Now I am trying to recall a recall, 7
and it gets very difficult.
No, I do not.
8 Q
Do you recall that after procedures were 9
put in place for either one of the units any changes 10 ever being made in them?
11 A
Yes.
12 Q
Do you recall if there was any type of 13 information which would generally motivate such
(
14 changes?
15 A
I don't think I can limit it to any one 16 category of things that prompted changes.
17 Q
I believe that you tes tified yesterday 18 that you were involved to some extent in the 19 promulgation of procedures for TMI Unit 1,
is that 20 correct?
21 A
Yes.
22 Q
what was your role in that effort?
l l
23 A
I was a member of PORC and as such in i
24 Unit 1 I reviewed almost all of the procedures as a
()
25 PORC member.
Some of the people working for me were 1
I
1 Floyd 208
()
2 tasked with preparing balance of plant procedures, 3
review and possible revision of B&W draft procedures 4
on the nuclear steam supply system, and so the lh 5
administration of that work was also part of my 6
responsibility in Unit 1.
7 Q
Do you recall ever writing any procedure 8
yourself?
9 A
Yes.
10 Q
Do you remember which ones or one you 11 wrote?
12 A
I think I was the first author of AP-1012,
(}
13 which was shift relief and log entries.
I imagine 14 I was the author of many revisions to many procedures, 15 but I can't tell you specifically which ones.
16 Q
Did you have any procedure by which you 17 would author revisions to procedures?
18 A
Yes, in order'to change an approved 19 procedure, there were two possible routes.
A temporary 20 change notice called a TCN and a permanent change 21 review, PCR.
The normal mode, the preferred mode, 22 was to make a permanent change in the procedure.
There 23 was a form invented for doing this.
Instructions 24 were promulgated on how to fill out the form, and the 25 flow of the paper through the completed updated
209 1
Floyd
(~m
(
2 procedure.
The need arose to change procedures in a 3
much more expeditious fashion, and so the temporary 4
change notice was invented which accomplished the ll 5
same steps in a more expeditious manner and was 6
subject to more thorough review after the fact within 7
the next seven days, and again instructions were 8
promulgated on how to fill out that piece of paper 9
and the flow path e' that piece of paper and how to 10 implement the change on a temporary basis until the 11 procedure could be retyped.
12 Q
Do you ever recall being aware that a 13 temporary change notice to a procedure was put into
()
14 effect?
15 A
Yes.
16 Q
Under what circumstances would the need 17 for speed be such that you would use the temporary 18 change notice as opposed to the permanent change 19 review?
20 A
It could be something as simple as a 21 typographical error in the final product and we are 22 out in the field trying to conduct this procedure, 23 and it needs to be changed before we can proceed.
24 Q
I would like to refer you to the testimony gx b
25 which you gave before the President's Commission
g 1
Floyd 210 2
which was identified yesterday, specifically to page 3
20 and line 20, actually line 18.
There was a 4
question.
d lh 5
" Question:
Who on site would have been 6
involved in that review?"
And I believe that. review 7
refers to review of procedures.
8 And the answer is, "The plant operations 9
review committee has that responsibility.
There 10 may have been several of the emergency procedures that 11 I personally wrote."
12 Do you recall being asked that question
()
13 and giving that answer?
14 A
No, I do not.
15 Q
Would there be any method today of 16 ascertaining whether you had personally written an 17 emergency procedure?
18 MR. SELTZER:
When you say " personally 19 written," do you mean written from scratch 20 as opposed to reviewed and revised something 21 that B&W had initially drafted?
9 22 MS. WAGNER:
I am referring to the witness' 23 prior testimony.
1 24 M R '. SELTZER:
That doesn't help a great
\\
l 25 deal if the witness says he doesn't recall giving
1 Floyd 211 l
2 it.
I am asking you since you have made it 3
your question whether you are talking about his 4
writing from scratch or working from something lll 5
that B&W has first written?
6 MS. WAGNER:
I would like to read in in 7
response to your comment a previous question 8
and answer.
The question is, "Who drafted the 9
initial operating and emergency procedures for 10 Unit 17 11
" Answer:
Those that were in B&W's scope 12 of supply would have had the firs t draf t written
(~T 13 by B&W and then massaged rather severely by V
14 our staff.
Those outside the B&W scope of 15 supply would have been drafted by our people 16 initially."
17 BY MS. WAGNER:
18 Q
Do you recall being asked that question 19 and giving that answer?
20 A
No, I do not.
21 Q
The testimony would indicate that B&W l
22 provided draft procedures and that then they were 23 massaged severely.
24 Do you recall that happening?
(~T R-)
25 A
No, I do not.
1 Floyd 212
(
2 Q
Do you have any reason to believe that 3
y u did nt give the testimony I have read into the 4
record?
lll 5
A No, I do not.
6 Q
Do you have any reason to believe that the 7
testimony when you gave it was not truthful?
8 A
My choice of words was probably dictated 9
by the mental state which I was in in a first time 10 under oath situation with twelve rather formidable 11 people facing me, and with hindsight was probably a 12 poor choice of words, but those are the words on that 13 record, but I would like to change them and they 14 should probably be changed.
15 Q
I take it when you were responding to that 16 question, you were to the best of your understanding 17 responding truthfully?
18 A
Yes.
19 Q.
I believe I asked you a question if there 20 were any procedures, emergency procedures, which you 21 personally wrote, could one ascertain now which ones 22 those were, and I will start out asking the question, 23 if you had written any from scratch, could one 24 ascertain that.information?
O 25 A
While this statement that you referred to
1 Floyd 213
'~
\\
(,h 2
on line 22, the emergency procedures that' I personally 4
j 3
wrote,was probably and to the best of my recollection 4
was accurate on the day I gave it, there is much h
5 in this testimony that in hindsight and with additional 6
facts that have come to light, I would like to change 7
and go on the record and now say that that was just 8
plum wrong, but at the time I gave it, it was to the 9
best of my ability.
10 I have no recollection now that I ever 11 personally wrote an emergency procedure, and it would 12 be very difficult, the historical file maintained
()
13 on all procedures in the plant are the final approved 14 copy, and we can go back in time to the files that are 15 available at TMI, and we can say this procedure was 16 changed on this date in this way and that these are 17 the people who reviewed that change, but we could not 18 find out who the author of that change was, unless 19 we could have the PCR or the TCN attached to it, in 20 which case, the author would be known.
21 on initial draftings, there were not PCR's 22 or TCN's, so for changes you could identify the author 23 but for what we consider our initial draft, I don't j
24 believe it identified the author.
g-V 25 Q
I believe you testified previously that
_I
1 Floyd 214-l )
2 you think you were the author of AP-1012, is that 3
correct?
4 A
Yes, I remember that to the best of my lhk 5
recollection today.
6 Q
To the best of your recollection, when 7
you authored that procedure, did you sign it in any 8
fashion?
Put your name on it so someone would know 9
that you had authored it?
10 A
No.
11 Q
Is there any information which has come 12 to your attention since the time when you gave the
(/)
13 testimony to the President's Commission based upon
\\_
14 which you no longer believe your answer concerning 15 your authoring emergency procedures is correct?
16 A
I don't know that I even said that it was 17 incorrect here.
I just said that I have no recall 18 that would allow me to substantiate that statement.
19 Q
And, therefore, you don't have any 20 information presently indicating that it is not 21 correct?
22 MR. SELTZER:
I don't think it should be 23 stretched out of recognition with what his 24 original words were.
He says there may have
~
25 been several emergency procedures that he
)
215 4
1 Floyd
()
2 personally wrote in.
He didn't say there were any emergency procedures that he wrote.
3 MS. WAGNER:
I am asking if he has any 4
information now to indicate that what he said
- h 5
6 previously was incorrect.
MR. SELTZER:
"May" includes both the 7
8 possibility that he did write them and that he didn't write them, so it is hard to imagine a g
state of facts that would be inconsistent d
10 1
11 with that statement.
12 MS. WAGNER:
If he now knows that he 13 didn't write them, that state of facts would
()
14 be inconsistent with the statement he gave 1
4 l
15 pr ev' iou sly.
If he now knows that, I would like 16 to know if he has information about that.
17 A
I do not have such information.
18 Q
I would like to refer to page 21 of your testimony before the President's Commission to line
]
19 f
20 9.
The question is, "The drafts that B&W sent you, like were they actually drafts of procedures or more 21 22 outlines?
23
" Answer:
Some people may consider them
]
24 procedures.
They have the necessary steps which had 25 to be accomplished, the 'how to' accomplish this s
-_ - _ - ~ - _ _
,,.-,,..~..s___~
,-~.---,..r.--..,m.
,,,--v----
1 Floyd 216
()
2 step was probably not in sufficient detail to satisfy 3
us, so we would go through and add the proper valve 4
numbers on the
't w to' end of it to make it workable
,tll 5
and readable for the operator to take into the field and 6
actually do it.
And this was true of operating 7
procedures as well as emergency procedures."
8 Do you remember being asked that question 9
and giving that answer?
10 A
No, I do not.
11 Q
Do you recall the process which is 12 described in that answer?
13 A
Yes.
14 Q
Do you recall whether the Nuclear Regulatory 15 Commission was in any way involved in review of the 16 procedures for TMI-17 17 A
The Nuclear Regulatory Commission at the 18 King of Prussia level had to make a declaration to 19 the NRC Washington-Bethesda level that our procedures 20 were adequate to operate the plant prior to the 21 issuance of an operating license.
In order for them 22 to make that statement, they came into the field and 23 at least made a spot check of some procedures, if 24 not all, and the statement by the NRC people in King 25 of Prussia to the NRC in Washington is a tacit approval i
~.
1 Floyd 217
()
2 of all those procedures since they think the plant 3
can be safely operated by the use of those procedures.
4 Q
And you recall that process occurring llk 5
with respect to the TMI-1 procedures?
6 A
Yes.
7 Q
Although the government agency was 8
probably the AEC at that point?
9 A
Yes.
10 Q
For the TMI-1 procedures after a B&W draft 11 was received, what were the various -- who were the 12 various groups of people or who were the various persons 13 who worked on those procedures?
14 A
I don't remember.
15 Q
Do you recall to whom the draft would 16 initially go?
17 A
It was probably forwarded, but it is a 18 probably.
I don 't know.
19 Q
I am asking you for a position rather 20 than a specific person, if that helps at all.
21 A
I vaguely recall that the procedures were 22 sent from B&W to the plant superintendent.
23 Q
Do you recall ever seeing a B&W draft?
24 A
Yes.
[\\
\\.)
\\
i 25 Q
Do you recall where you got it from?
1 Ficyd 218 2
A No.
3 Q
Do you recall what you did with it?
4 A
Probably reviewed it.
jh 5
Q
.Do you recall ever making any changes 6
on any such draft?
7 A
This testimony which I gave in front of 8
the President's Commission about adding valve numbers 9
and pump numbers and names and clarification of 10 terminology from what might have been Bsw terminology 11 to our terminology was traditionally accomplished, and 12 I am sure I had a hand in that at some point along 13 the line.
But if you are talking about substantive 14 changes, then that is a different story.
15 Q
Did you give substantive review to any 16 draft procedures from B&W7 17 A
To the best of my ability, yes, but I did
[
18 not have an independent safety analysis to work from 19 on the emergency procedures.
20 Q
How did you give it a substantive review?
21 A
-By knowing what I could learn about the 22 transient analysis that supported that procedure to 23 see that the mitigating circumstances were taking 24 place in the procedure.
O 25 Q
And you believe you did that on occasion?
l 1
Floyd 219 2
A Yes.
3 Q
Did y u ever have occasion to speak with 4
engineers at General Public Utilities about review of llll 5
these procedures?
6 A
In Unit 1,
General Public Utilities 7
engineers aid not take a very large measure of 8
activity in the review of procedures.
It was primarily 9
a Met Ed evolution.
10 Q
I would like to show you what has been 11 previously marked as B&W 418, which is a draft of a 12 loss of coolant procedure.
13 Do you ever recall seeing B&W 418 before?
14 A
No, I have no such recollection.
15 Q
Do you recall being aware at any dime prior 16 to the accident at Three Mile Island that it was 17 possible for the initial symptoms of a transient to 18 resemble more than one transient and, therefore, 1r initially it would be difficult to tell which of 20 two transients you had?
21 A
Yes.
O 22 Q
Do you recall any specific instances of 23 such a situation?
24 A
We trained diligently on differentiating 25 between a loss of coolant accident, a steam line r - -
- - =,
l(
1 Floyd 220 2
break inside the reactor building, and a dropped 3
control rod since all lead to decreasing reactor 4
coolant system pressure and level as we thought of' h
5 in those days.
6 (Continued on following page.)
7 8
9 10 11 12 13 14 15 16 17 l
18 19 t
20 21 22 23 l
I 24 O
25 l
~
k 1 1
Floyd 221 2
Q So you thought it was possible the operators could get confused by the initial symptoms?
3 A
There were unique symptoms for each, but 4
th there were also two redundant symptoms for each, so we 5
6 trained on the differences.
7 Q
I would like to refer you to the third 8
page of B&W 418 under the section entitled g
" Description."
There is a sentence at the end of the 10 rsecond paragraph which says, "However, the operator 11 should assume the cause of the symptoms described 12 above is a system rupture or leak unless another cause 13 can be immediately established."
14 Do you recall ever being aware that this 15 sentence was in the draft B&W procedure for a loss of 16 coolant?
17 MR. SELTZER:
I thought he said he didn't 18 recall ever seeing this draft procedure.
19 MS. WAGNER:
I am asking was he ever aware 20 this was in the draft procedure, whether he saw 21 it or not.
22 MR. SELTZER:
The second question is 23 subsumed in the first.
l 24 MS. WAGNER:
No, someone could have told u
25 him about it.
l
2 1
Floyd 222
(
2 A
I have no recollection of this sentence 3
being in this draft.
4 Q
Do you have any recollection as to why this llI 5
sentence was removed from the procedure which was 6
eventually put into operation at TMI-1?
7 MR. SELTZER:
Objection.
No foundation.
8 MS. WAGNER:
You direct him not to answer?
9 MR. SELTZER:
I didn't hear me say that.
10 Q
Would you answer it, please?
11 A
I have no such recollection.
12 Q
Do you recall that that sentence is not
(
13 or was not in the procedure for. operation of TMI-1 14 prior to the accident at Three Mile Island?
15 A
No, I was not aware of the omission.
16 Q
Do you recall ever being given any training 17 by Metropolitan Edison to the effect that if you do 18 not know which of the three things you had, a reactor 19 coolant leak, a steam break, or a dropped rod, that 20 you should assume that it was a leak?
21 A
I have no recollection that said the 22 operator wouldn't know.
I think we worked on the
)
23 premise that we could tell.
24 Q
What was the unique symptom or what,were the O
25 unique symptoms for a loss of coolant?
l
1 Floyd 223 2
A Radiation in the reactor building.
3 Q
How vas the operator to determine 4
radiation in the reactor building?
A Either of several methods.
5 6
Q Can you describe them for me?
A Basically, a GM detector in the dome of the 7
g reactor building, and we also had a particulate iodine 9
~ and gaseous radiation monitor on the atmosphere of the 10 reactor building.
11 Q
Do you recall having an understanding with 12 respect to the unique symptoms of the loss of coolant 13 as to at what time in the development of a loss of 14 coolant event these monitors were supposed to alarm?
15 A
I don't recall a time or time delay being 16 stressed.
17 Q
Do you recall understanding that the 18 monitors would immediately alarm if there was a loss 19 of coolant?
j l
A I don't recall the immediacy of the 20 21 radiation alarms.
22 Q
W as it your understanding then of the list 23 of symptoms for a loss of coolant, all of the symptoms 24 did not have to occur simultanerously in order for O
25 there to exist a loss of coolant?
I 1
Floyd 224 O
MR. SELTZER:
I Gbject.
We don't have in
()
2 front of us the loss of coolant accident 3
4 procedure that you are talking about.
I don't know if you are talking about one procedure in (hk 5
6 1971, Unit 2's procedure on the day of the accident or Unit 1's on the day of the accident.
7 8
Therefore, it is very unclear what symptoms and 9
what procedures you are talking about.
10 MS. WAGNER:
I am talking about Mr. Floyd's understanding of how procedures were written.
11 12 Was it necessary as far as he understood it for 13 a particular procedure to apply that all of the
()
14 symptoms in that procedure occur simultaneously.
15 MR. SELTZER:
I object.
If you are talking 16 about all the procedures, there must be 50 or 17 a hundred procedures.
18 MS. WAGNER:
I am talking of emergency 19 procedures.
20 MR. SELTZER:
All the emergency procedures?
91 MS. WAGNER:
Yes.
22 MR. SELTZER:
I object, as vague and 23 ambig uo us.
I don't want you to answer a question 24 that is that vague and ambiguous.
.O 25 If you want to talk about a specific
5 1
Floyd 225 j
2 procedure, I think it is fair to ask the witness ab ut that, but not ab out all emergency 3
4 procedures.
llk 5
BY MS. WAGNER:
6 Q
Did you have any understanding as to the 7
philosophical basis for listing of symptoms in 8
emergency procedures?
9 MR. SELTZER:
What do you mean by 10 philosophical basis?
11 Q
Did you'have any understanding as to why 12 some symptoms would be listed and others wouldn't?
13 MR. SELTZER:
I object.
There is no
{
14 foundation that a symptom that would exist for 15 an accident or a transient would not be listed.
16 Q
Do you believe it would be a symptom of a 17 loss of coolant accident for the core to melt down?
18 MR. SELTZER:
Does he believe today?
19 MS. WAGNER:
Yes.
20 MR. SELTZER:
What do you mean by the word i
21
" symptom"?
k 22 Q
Do you know what the word " symptom" means?
23 MR. SELTZER:
It is your question.
24 Here is the problem.
A core melt seems more 25 like an effect rather than a symptom as I l
ve
. ~.
6 1
F1cyd 226
^h
[b 2
normally understand the word " symptom," but if 3
y u have a different meaning.
4 MS. WAGNER:
My understanding of " symptom,"
lhk 5
which I understand is a fairly common word in 6
the English language, is that it is an indication 7
of something having occurred or in the process of 8
occurring.
9 MR. KIRSCHBAUM:
I don't believe that is a 10 correct definition.
11 MS. WAGNER:
In any case, that is my i
12 definition.
(
~
Based on that definition, I would like the 13 14 witness to answer the question.
If he saw a 15 meltdown occur, would he think that maybe a 16 loss of coolant accident was in process.
17 A
I am not sure that I would know how to 18 recognize a meltdown, and the re fore, I would be 19 hypothesizing as to how I would respond to those 20 symptoms.
21 Q
Have you ever heard that core melt is an 22 indication of a loss of coolant?
23 MR. SELTZER:
When you say "is an 24 indication," you mean that operators should look n\\
25 for core melt as a signal that they have a loss I
i l
7 1
Ficyd 227 2
of coolant?
MS. WAGNER:
No, I am asking if one had 3
4 a meltdown, would that be such a signal, whether i
lll 5
or not they should look for it.
6 A
I thought I just responded to that question.
7 BY MS. WAGNER:
8 Q.
Has anybody ever told you, that is my 9
question.
10 A
I don't recall ever hearing that statement 11 before.
12 Q
Do you ever recall seeing that statement 13 in any procedure for a loss of coolant?
14 A
I don't recall seeing that statement.
15 Q
can you think of any reason why it is not 16 in a loss of coolant procedure?
17 MR. SELTZER:
I object.
The witness has 18 already said it is a hypothetical.
.s 19 MS. WAGNER:
The witness says it is not in 3
20 the" procedure.
I,am asking why it is not.
That i
21 is not hypothetical.
IIP 22 A
I would.like to, set the record straight.
The' witness did not say it does not appear 3
23 i
i 1
24 sin a procedure'.
I said I haven't heard or seen it.
(~
\\
25 I did not deny 'it existed in a procedure.
t;
\\
b 4-
~
M
/
C,l,3 ': /, 0, 4,
1 Floyd 228 1 :r
' :q
( m /'[
J 2
Q Based on the fact that you have neither s *;
?
seen it nor heard it being in a procedure, do you have n',
. y, f -
3 14, a
+
ic 4
'any knowledge as to why it is not in a procedure?
i l)'
5 MR. SELTZER:
He just told you he doesn't A
J
'[, 6, know whether it is in or not, so to ask him why s
</
'7
. it is not rests on a lack of foundation.
7; ;/
r
~
t j "
/,f.
8 MS. WAGNER:
He says he has never heard J
,v t
i'
,fd that it is in it.
I am asking whether he has 9
- )
. l 'I t
,1 '
10 ever heard of a reason why.
j p' j d.J /
/
11 MR. KIRSCHBAUM:
He hasn't heard that it (i /
l/, Li;r'f 12 isn't there.
He just hasn't heard that it is I
' ),..
l
^ (~'f 13 there.
1 u, v.
14 MS. WAGNER:
Has he h-aard any reason why it
\\t 1
c there?
' ',7 15 isn't
.j'
,c n
/
16 A
No, I have not.
W.\\ f s *
~ /
17 BY'MS. WAGNER:
18 Q
Did you have any involvement in the t
/
M '
19 drafting of procedures for Unit 27
(
{ {' r _
20 A
I had some involvement in drafting of
\\"(
?
[
- /
21 procedures for Unit 2.
)1 k hb :'""
I'
~
22 Q
I show you a transcript of testimony or an
+
.),'t
!!.i
/
23 interview of James.
R.
Floyd before the United States
.3 7
2'4 Senate and ask you if you recall that interview.
4
\\2 6 ,
25 A
I don't remember this particular interview.
E
'N, r
n
,. =
9 i
Ficyd 229
("')
2 Q
Do you remember any interview with the L/
United States Senate or some representatives thereof?
3 4
A I have a vague recollection of having talked to the Hart Committee.
I don't know if this is lh 5
6 the same document or not.
7 Q
I would like to refer you to the last page 8
of this transcript, which is called " Certificate,"
9 and it says, "I certify that I have reviewed the 10 attached transcript of my interview with the staff 11 of the Senate TMI investigation and I have made such 12 corrections necessary as to make it an accurate 13 verbatim record of said interview."
d(~S, 14 The page appears to be signed by James R.
15 Floyd on November 30, 1979.
i 16 Do you recall having signed that 17 certificate?
18 A
No, but it is my signature.
19 Q
I refer you to page 36 of that testimony, 20 to a question which starts on line 13, and the answer 21 that follows:
\\,
23 b
"Ms.
Giannelli:
Do you know who I guess l
\\
23 put together the operating procedures for Unit 2?
I I
24 "Mr.
Floyd I have to have a very vital A
i
's /
25 hand in that.
It really, I guess, was the PORC
1 Floyd 230
/~~'N 2
responsibility, Plant Operations Review Committee.
b But as a member of that group and as the operations 3
4 supervisor and as the man with the most years of nuclear ll) 5 operating experience, why, the operating procedures
/ l 6
were very much in my domain." l# I 7
Do you recall being asked that question 8
and giving that answer?
9 A
No.
10 Q
Do you have any reason to believe that that 11 is not your answer?
12 MR. SELTZER:
He said he doesn't recall 13 giving it.
LJ 14 MS. WAGNER:
I am asking if he has any 15 reason to believe that what is written here is 16 not truthful.
17 MR. SELTZER:
That is another question.
18 MS. WAGNER:
I will ask that question.
19 MR. SELTZER:
You are withdrawing the first 20 question?
l 21 MS. WAGNER:
For the moment, he can answer 22 the second question.
I l
23 MR. SELTZER:
You are asking based on his i
l 24 p re s e n t recollection, is what you just read i
D' 25 accurate?
i
11 1
Floyd 231 2
MS. WAGNER:
I am not asking if my reading s/
was accurate.
I am asking if he, as far as he 3
4 knows, gave that testimony.
ll) 5 MR. SELTZER:
If he were asked that question 6
today, would he give that answer?
Is that a 7
fair way to phrase it?
8 MS. WAGNER:
That is one question.
9 MR. McBRIDE:
Why don't you answer Mr.
10 Seltzer's question.
11 BY MS. WAGNER:
12 Q
The question is, if you were asked the 13 question today, would you give the same answer?
14 A
I would give substantially the same answer.
15 Q
Can you describe for me what it was that 16 you did with respect to promulgation of Unit 2 17 procedures, emergency and operating procedures?
18 A
No, I cannot.
I don't remember.
19 Q
Do you remember generally what your role 20 was?
21 A
To schedule the preparation of the 22 procedures in the order of priority in which we needed them and to see that that schedule was followed and 23 24 met.
I3 25 Q
Do you recall ever being involved in any O
9
-c, y
s 1
Floyd 232
[]
2 substantive review of procedures for Unit 27
%j 3
A I have no specific remembrances, but it is 4
something I certainly did.
l[
5 Q
Do you remember what was used as the raw 6
material for Unit 2 emergency procedures?
7 A
Not in every case, no.
8 Q
Generally?
9 A
Generally, I believe they were B&W draft 10 procedures on the NSS scope of supply.
11 Q
What did you do with those draft procedures, 12 to your recollection?
~
13 A
I don't recall.
14 Q
The only thing you recall about the whole 15 process is that they involved a B&W draft?
16 A
And that I was intimately involved in the 17 handling of them after we got the drafts, and I have 18 no specific recall as to what we did with them to 19 convert them into approved procedures for use in the 20 plant.
21 Q
Is there any way I could find out what you 22 did to them?
23 A
Recreating what went on before Rev.0 l
24 i
would be difficult in a detailed step-by-step basis.
O l
\\#
25 If you could find from your records an original copy
233 3
1 Ficyd 2
of the draft that was fi rs t sent, such as you produced
()
here on DP 51202-6, and you could say this is what 3
we offer them and this is what their Rev. O came out 4
looking like, you could then reconstruct two end
]h 5
6 points, a beginning point and a final point, and from 7
that final point forward, then it would not be hard 8
to trace the record of what happened to the procedure 9
o'ver the years in our r'evision process, but there i s' 10 that hole in the-. front end before it became Rev. 0, 11 Three Mile Island didr. 't keep a re cord of it.
12 Q
Do you recall who was involved in working 13 on those procedures for Unit 27
(
14 A
Writing the procedures for a nuclear power 15 plant is a major effort and many, many people are 16 involved.
I believe we had some people who were 17 dedicated solely to that function, but I don't know 18 who all participated in it.
19 MS. WAGNER:
I would like to have marked l
20 as B&W 467 a three-page document entitled 21 "TMI station, Brief overview of Unit 2 Procedure 22 History," dated May 25, 1979.
I l
23 (Three-page document entitled "TMI station,
(
Brief Overview of Unit 2 Procedure History,"
i 24 l
25 dated May 25, 1979, was marked B&W Exhibit 467
14 1
Floyd 234
()
for identification, as of this date.)
2 3
Q Have you ever seen B&W 467 before?
4 A
No.
5 Q
on the front page of the exhibit there is
]g, 6
a paragraph, " Note,it should be noted that some of 7
the draft procedures originally expected from S&W 8
were subsequently deferred.
This was due to the fact that what would have been given to MEC/GPU from B&W 9
10 would have been almost identical to those obtained for 11 Unit 1.
Therefore, MEC/GPU utilized the Unit 1 12 procedures, which allowed B&W to pursue other tasks."
13 Do you recall whether or not Unit 1
(
14 procedures were used in some instances as the drafts 15 for Unit 2 procedures?
16 A
No, I do not recall that.
17 Q
You don't recall one way or the other?
18 A
I don't recall one way or the other.
19 Q
The next paragraph describes the review 20 that was giv'en to Unit 2 procedures and indicates,"1, 21 procedure written 2, procedure received NUC O
22 independent reviews 3, procedure reviewed by PORC (or 23 staff if not NUC safety related), and 4, procedure 1
24 reviewed by unit superintendent."
O 25 Do you recall that process of review for
15 1
Floyd 235 lh 2
Unit 2 procedures?
'%)
A I d n't recall that specifically, but I 3
4 believe that is the way it was done.
i h
5 HR. SELTZER:
It is also part of the 6
description of procedure review, "It should also 7
be noted that B&W attended PORC meetings as 8
was determined necessary by the PORC ch ai rman,
9 unit superintendent or respective B&W person on 10 site (B&W would request they be notified for 11 certain procedures when they were PORC'd."
12 MS. WAGNER:
I object to your reading in 13 anything in the record at this point and move 14 that it be stricken.
15 MR. SELTZER:
If the Court agrees to 16 strike everything, Bob Fiske reads into the 17 record, I will stipulate to that.
18 MS. WAGNER:
If you can make a deal with 19 the Court, good for you.
20 BY MS. WAGNER:
21 Q
There is a section here entitled 22
" Procedure Verification," and it describes a program 1
23 called " Procedure verification / red line program."
Do 24 you remember that?
m.
25 A
Yes.
d i
16 1
F1Cyd 236 2
Q can you describe,it?
A The red line program was the first use of 3
4 the procedure in the field, and at that one instance 5
we were able to merely mark up the copy of the procedure g
6 in our hands and go ahead and proceed as though we 7
had an approved procedure in our hands, and it was 8
then returned to the PORC for incorporation as a 9
revision to the procedure, but that was only done on 10 some system operating procedures.
It could not be done 11 on things like plant start-up, initial criticality, 12 and emergency procedures.
13 Q
To the best of your recollection, was there 14 no red line procedure for emergency procedures?
15 A
That is true.
Those were*all formally 16 reviewed before being implemented.
17 Q
How were they reviewed?
18 A
Usually had a quorum in the control room, 19 a PORC quorum.
20 Q
With the PORC quorum in the control room, 21 what happened?
O 22 A
The necessity for change and the mechanics 23 of the change could be discussed by the cognizant 24 review body and approved before being iaplemented.
25 Q
would the PORC quorum in the control room
I 7
Floyd 237 2
run through the procedure somehow?
How was it that 3
the verification process worked?
4 A
The PORC had already reviewed that
'h 5
procedure, the draft that was trying to be implemented, 6
se they were not unfamiliar with what the intent of 7
the procedure was, and the reason for the desired 8
change as well as the mechanics of the desired change 9
when discussed could then be approved and implemented.
10 (Discussion between the witness and his 11 counsel) 12 Q
Just so I understand your testimony, is 13 what you just described a process which was gone 14 through for the purpose of verifying.or red lining 15 emergency procedures?
16 A
No, I guess I am saying we could not red 17 line emergency procedures.
In lieu of that, changes 18 had to be approved by PORC before they could be 19
- implemented.
20 Q
Aside from changes, how did the original f
21 procedure get approved?
22 A
The original procedure was dry-runned, if 23 you will.
We walked through it in the control room, i
I 24 and assuming you had these indications, you would want
! O 25 to start this pump and look at that flow meter.
That j
l
1 Floyd 238
(~h
(,)
2 does not alw ays lead you to a successful procedure, but it is the best you can do rather than imposing 3
4 accidents on your plant to see if your procedures work.
5 Q
A paragraph further down on page 2 of B&W lh 6
467 says, "It should be noted the NRC performed an 7
in-depth review of TMI-2 procedures from June 20 to 8
July 8.
This review (314 hours0.00363 days <br />0.0872 hours <br />5.191799e-4 weeks <br />1.19477e-4 months <br /> by six inspectors) resulted in a few minor comments and corrections."
9 10 Do you recall the NRC in-depth review 3
11 described in that paragraph 7 12 A
No, I do not.
()
13 Q
Do you recall any NRC review?
14 MR. KIRSCHBAUM:
Of TMI-2 procedure?
15 MS. WAGNER:
Yes.
16 A
No, I do not.
17 MR..McBRIDE:
I assume your question was 18 limited to prior to the accident.
l 19 MS. WAGNER:
Yes, all my questions are prior 20 to the accident unless so stated.
s 21 (Lunch recess taken at 12:00 noon.)
22 l
3 25
1 239 r~
I 2
AFTERNOON SESSION 3
1:30 p.m.
4 JAMES R.
FL0Y D,
resumed.
ll) 5 EXAMINATION (continued) 6 BY MS. WAGNER:
7 Q
I would like to refer you to your 8
President's Commission testimony again to page 32 9
to a question and answer which begin on line 21.
10 Actually, two questions and answers.
11 The first questior. is, "And at that point 12 were you involved in the drafting of procedures for 13 Unit 27 14
" ANSWER:
Yes, ma'm.
15
" QUESTION:
Could you explain that process?
16
" ANSWER:
Well, there we pretty much relied 17 heavily on Unit 1's procedures.
We had invested a 18 tremendous amount of time and effort into the Unit 1 19 procedures at that point in time I think they were 20 being held up by the NRC as an industry standard:
21
'This is the way procedures ought to look in a nuclear S
22 power plan t' since they were telling o'aer stations 23 this, it seemed reasonable that we in Unit 2 would 7-24 use our own expertise that we had developed in Unit 1's 25 procedures, and basically just modified the procedures
1 floyd 240
}
2 where possible from Unit 1 to Unit 2, and used 3
effectively the same procedure."
4 Do you recall being asked those questions lh 5
and giving those answers?
6 A
No, I do not.
7 Q
Do you recall at this time the NRC holding 1
8 up Unit l's procedures as an industry standard?
i 9
A No, I do not.
10 MS. WAGNER:
I would like to have narked l
l 11 as Bsw 460 a seven-page document which is entitled 12 "NRC Inspection 77-04" dated February 3, 1977.
13 (Seven-page document entitled 14 "NRC Inspection 77-04," dated February 3, 15 1977, was marked as B&W Exhibit 468 for 16 identification, as of this date.)
17 Q
Have you ever seen this document before?
18 A
Not that I remember.
19 Q
Do you know whose handwriting it is in?
20 A
No, I do not. It is not mine.
21 Q
I refer you to the second page of the 22 document in which it has written a question, "How 23 do changes to procedures get reviewed by operations?
24 Revision review book not yet implemented for Unit 2.
25 NRC wants a date."
1 Floyd 241 gN 2
Do you recall at any time when you were b
3 Supervisor of operations for Unit 2 the NRC querying 4
you as to how changes to procedures get reviewed lh-5 by operations?
6 A
No, I do not.
7 Q
Further down on the page there is a 8
reference to standing orders, and the document says, g
"JRF resolved with GPM."
10 Do you recall whether there were any 11 standing orders for Unit 27 12 MR. SELTZER:
Standing orders regarding 13 what?
14 MS. WAGNER:
I don't know what.
15 MR. SELTZER:
If you don't know what, 16 how can you ask the question?
17 MS. WAGNER:
I just did ask the question.
18 MR. SELTZER:
But standing orders regarding 19 fire drills MS. WAGNER:
Regarding anything at all.
20 - l 21 MR. SELTZER:
how to run the air 9
22 conditioning in the control room?
23 MS. WAGNER:
Anything.
24 MR. SELTZER:
What do you mean by a
)
25 standing order?
I n
I Floyd 242
)
l 2
MS. WAGNER:
Whatever this document 4
3 means by it.
4 MR. SELTZER:
The witness says he lh 5
doesn't recall ever seeing this document.
6 BY MS. WAGNER:
7 Q
Have you ever heard of something called 8
a standing order?
9 A
In Unit 1,
I did.
10 Q
Did you ever hear of any in Unit 27 11 A
I don't recall ever having issued any 12 standing orders in Unit 2.
()
13 Q
Do you recall whether there were any in 14 Unit 2, whether or not you issued them?
15 A
I don't recall any standing orders in 16 Unit 2.
17 Q
Do you rem'emher having any conversations 18 with Gary Miller about Unit 2's standing orders?
19 A
No, I do not.
20 Q
The next page of the document under a 21 paragraph numbered II, Section A, No.
1, there is a 22 statement, " Responsibility of operators not clearly 23 defined (i.e., who is responsible for authorizing 24 return to rated power).
After a run-back occurs, 25 where do we delineate operators' responsibility to
1 Floyd 243 1
2 follow procedure believe ir.dicAtions."
3 Do you recall during the time you were t
4 supervisor of operations for Unit 2 any discussion lh.
5 about whether or not the responsibility of operators 6
for authorizing return to rated power after run-back 7
was clearly defined?
8 A
No, I have no such recollection.
~
Q Where for the operation of Unit 2 was 9
10 delineated the operators' responsibility to follow 11 procedures?
12 MR. SELTZER:
Follow procedures for what?
13 MS. WAGNER:
For running the plant.
14 A
It would appear as though the writer of 15 thi$ memo thought it appeared in administrative 16 procedure 1009.
17 Q
Do you have any independent recollection 1
18 of whether it appeared in administrative procedure 19 10097 20 A
No, I do not.
21 Q
Do you recall what the subject matter l
22 of administrative procedure 1009 was?
23 A
No, I do not.
l Q
Do you know where for the operation of 24
(
25 Unit 2 was delineated the operators' responsibility 8
0
. ~ -,
-v
+
i 1
Ficyd
.244
(}
2 to believe indications?
3 A
I know it was delineated but I cannot 4
reference the document.
lh 5
Q Do you know generally what type of 6
document it was delineated in?
7 A
It was delineated in one of the 8
administrative procedures,but which one I can't put 9
my finger on at this point in time.
10 Q
Do you recall ever hearing of a TCN log 11 associated with Unit 27 12 A
Yes.
~
13 Q
what is or was the TCN log?
14 A
Going back to the discussion we had 15 earlier on the record, TCN's were meant to be 16 implemented in short order, and there was an urgent 17 need to put them into practice, and so the shift 18 foreman was assigned the responsibility to maintain 19 a record of all TCN's that were currently in effec't 20 in the plant.
21 Q
Was there any responsibility on the part 22 of the control room operatorsfor reviewing the TCN's 23 on a periodic basis?
24 A
What they were supposed to review on a 25 periodic basis was delineated in an administrative l
l
1 Floyd 245 2
procedure, and I believe it was 1012, and I don't i
3 recall if TCN's were part of that listing of 4
things they were supposed to review or not.
l(p 5
Q Do you recall whether the emergency 6
procedures for Unit 2 were indexed?
7 A
Yes, the emergency procedures for Unit 2 8
were indexed.
9 Q
Do you recall how the index was set up?
10 A
2200 or 2300 series of numbers, and 11 it was broken into two subsections, one labeled 12
" Emergency" and one labeled " Abnormal Procedures."
()
13 Q
Was the index simply a numerical list of 14 procedures or were they categorized in some fashion 15 other than what you just described?
16 A
I know of no further characterization 17 beyond what I have already described.
18 Q
Is it correct that in 1977 you were 19 assigned responsibility for generating the standard 20 technical specifications for Unit 27 21 A
I have no recall of ever having had such 22 a broad mandate as that but I was active in the i
23 development of the technical specifications for i
24 Unit 2.
25 Q
I show you a document which has been i
l
g Floyd 246 gy
(
)
N/
2 Previously marked as B&W 297 and ask you if you have 3
ever seen that document before.
4 A
Yes, I have seen this document.
lh?
5 Q
Do you recall --
l l
l 6
MR. SELTZER:
Is this the complete 1
7 exhibit?
It says at the top it is Attachment 1 8
and it doesn't have the reporter's stamp on it.
9 MS. WAGNER:
I think it is the complete 1
10 exhibit.
This is obviously not a copy of the 11 exhibit that was stamped.
We will check that 12 and change the record if necessary.:.
(~)h
(_
13 Q
Do you believe you received this document 14 in the ordinary course of your business as supervisor 15 of operations for Unit 27 16 MR. SELTZER:
You asked him if he recalls 17 receiving it in the regular course of business?
18 MS. WAGNER:
Yes.
19 A
I don't recall receiving it.
20 Q
But you recall having seen it?
21 A
Yes.
22 MR. SELTZER:
Can we clarify something?
23 (Discussion off the record between the i
f)
24 witness and his counsel.)
l 25 MR. SELTZER:
I assume when you asked
1 Floyd 247 2
"Do you recall seeing it," you didn't mean 3
does he recall seeing from having seen it in 4
the last week in preparation for this i
l5 5
deposition?
6 MS. WAGNER:
You are right.
I meant 7
seeing it at or about the time it is dated.
8 A
I don't recall seeing it at or about the 9
time it was dated.
10 Q
when do you recall seeing it?
11 A
several days ago.
12 Q
For the first time?
()
13 A
That is the only time I can recall.
14 Q
Paragraph 1 of the document says, 15 "J.
R.
Floyd, be.the Unit ~2 detailed technical 16 specification individaal."
17 Do you recall being so designated?
18 A
No, I do not.
19 Q
Do you recall any discussions with Gary 20 Miller about technical specifications?
21 A
There were many discussions with Gary 22 Miller on technical specifications aad I recall none 23 of them in de. tail.
24 Q
what generally were they about?
25 A
Technical specifications.
n
1 Floyd 248
()
2 Q
What about the technical specifications?
N/
3 A
Are they getting written, are they getting 4
approved, are they being implemented, are the l(;
5 procedures.being written to support them.
Any number 6
of things that could have been, but I recall none of 7
them.
8 Q
Do you recall ever having any discussion 9
about the substance of the technical specifications?
10 MR. SELTZER:
Do you mean at or about the 11 time the tech specs were being written?
l 12 MS. WAGNER:
At any time prior to the
(~]
13 accident.
V 14 MR. SELTZER:
With anyone?
15 MS. WAGNER:
With Gary Miller.
16 MR. SELTZER:
I don't understand.
Are 17 you asking him does he recall ever discussing 18 any tech spec at any time before the accident 19 with Gary Miller?
20 MS. WAGNER:
He already told me that he 21 has had many discussions with Gary Miller 22 about the tech specs, and he described the 23 procedural discussions he had.
i 24 l
I want to know if he ever discussed the 7_
(
)#
25 substance of any technical specification with A
1 Ficyd 249 2
Gary Miller.
3 A
I can recall no specific discussion of 4
technical matter on the tech spec with Gary Miller, lh 5
but I would put it into the same category as the 6
other items I listed for you.
7 Q
Do you recall any discussion of the 8
substance of any technical specification with any 9
other individual?
10 A
Not spe ci fi c ally, but there are many 11 other individuals involved.
12 Q
Were you aware that Mr. Seelinger had 13 been instructed to assign an engineer to call both O
14 Davis-Besse and Crystal River to obtain a current 15 copy of their technical specifications?
16 A
I don't recall that.
17 Q
Do you recall being assigned to that task 18 yourself?
19 A
No, I do not.
20 Q
Do you recall any discussions with 21 Mr. Seelinger about the technical specifications of e
22 Davis-Besse?
23 A
No specific examples.
24 Q
Do you recall generally such discussions?
25 A
Yes.
~_.
1 Floyd 250
()
2 Q
Do you recall discussions generally with 3
Mr. Seelinger about the technical specifications 4
of Crystal River?
lh, 5
A Yes.
6 Q
Do you have any understanding as to why 7
Mr. Seelinger was asked to obtain technical
.8 specifications from Davis-Besse or Crystal River?
9 A
No, I do nat.
10 Q
Subparagraph 3 of this document, B&W 297, 11 says "J.
R.
Floyd to interface / interact with 12 procedure writers, the NRC, B&W, BER, and other
(}
13 utilities.
This means that I expect calls to be 14 made to Davis-Besse, Crystal River and the NRC 15 around once a week to determine changes and items I
16 of interest in the program.
J.
R.
Floyd to 17 promptly review changes to the STS as they come in 18 for their effect in corporation into our program, 19 any immediate actions and requirements for interfacing I
20 at that time."
l 21 Do you recall interfacing with procedure 22 writers during the time you were supervisor of 23 operations for Unit 27 24 MR. SELTZER:
You mean any interface O
25 at all with procedure writers?
1 Floyd 251
()
2 MS. WAGNER:
Any interface.
MR. SELTZER:
Not just on the STS or 3
4 tech specs?
5 MS. WAGNER:
On any basis.
]ll A
I generally remember interfacing wich 6
7 procedure writers on Unit 2.
8 Q
On what basis?
9 A
To check on the status of the work and 10 possibly to add to the work product.
11 Q
Do you recall making calls around once a 12 week to Davis-Besse concerning items of interest
(
13 to the STS program?
14 A
I do not so recall.
15 Q
Do you recall making euch calls +o 16 Crystal River?
17 A
No, I do not.
18 Q
Do you recall making such calls to the 19 NRC7 20 A
No, I do not.
21 Q
Regardless of whether you specifically 9
22 remember any specific calls, do you recall generally 23 that this was a part of your job responsibility in 24 19777 O
25 A
I do not recall that it was generally
1 Floyd 252 m
(J) 2 part of ny job responsibility in 1977.
3 Q
Do you ever recall hearing anything about 4
the STS at Dsvis-Besse?
l{
5 A
This memo has refreshed my memory to the 6
effect that I believe someone in our staff, and 7
from this memo it leads me to believe it is Jim 8
Seelinger, acquired copies of those two sets of 9
technical specifications and laid them out beside 10 ours and went through a page-by-page, line-by-line 11 comparison to see where they differed.
12 Q
What was the purpose of that comparison?
(V~}
13 A
To see how standard a standard tech spec 14 was.
15 Q
How standard is a standard tech spec?
16 A
I don't recall the results of that review.
17 Q
Do you recall if any of your technical 18 specifications were changed as a result of this 19 comparison?
20 A
I have no specific remembrance of any 21 changes as a result of that comparison.
O 22 Q
Do you have any general recollection?
23 A
No.
24 o
Paragraph 4 of this docu.ent says, i
25 "J.
R.
Floyd to provide a training 1 a-am to the
1 Floyd 253 t >)
2 shift supervisors, shift f or emen," and I believe it
(
3 s ay s" CRO 's. "
4 Do you recall setting up a training 5
program for personnel concerning the STS?
lh 6
A I recall talking to the supervisor of 7
training and agreeing with him to schedule various 8
sections of the STS into the normal requal 9
training program until all sections of the STS had 10 been covered in the requal week.
11 Q
How did the STS differ from the technical 12 specifications in Unit 1 in general?
-~
[G h
13 MR. SELTZER:
Objection.
No foundation.
14 Q
Were they different?
15 A
Yes.
16 Q
How were they different?
17 A
Primarily in format, not in substance.
18 Q
Do you know who somebody called M.
B.
Basila is?
g 20 A
Yes, that would be Mark Basila.
21 Q
Who was he?
22 A
A young engineer on our staff employed by 23 Metropolitan Edison.
24 Q
Do you recall any discussions with Gary
,r 3 25 Miller, Mr. Seelinger, and Mr. Basila concerning
1 Floyd 254
(
2 the technical specifications of Davis-Besse?
3 A
I have no specific or general recollection i
i' 4
of such meetings, although I would believe they took 5
place.
gg) 6 Q
Do you recall ever seeing procedures 7
from Davis-Besse other than the technical specifications?
8 A
No.
9 Q
Do you recall seeing procedures from 10 crystal River other than the technical specifications?
I 11 A
No.
12 MS. WAGNER:
I would like to have 13 marked as B&W 469 a five-page document dated 14 3/14/77, a memo from Gary Miller to, among other 15 people, Mr. Floyd.
16 (Five-page memo from Gary Miller to Mr.
17 Floyd and others dated 3/14/77 marked B&W 18 Exhibit 469 for identification, as of this 19 d at e. )
20 BY MS. WAGNER:
21 Q
Do you recall first of all seeing the G
22 document before?
23 A
No, I do not.
24 Q
I would like to ref er you to page 4 to 25 the bottom to the sentence numbered 11 which says, I
i
\\
1 Floyd 255 s
(
2
" Interface and contach program with other utilities t
3 and N?C J.
R._Fioyd: responsibility - JGH/GPM memo 4
along)vith J.
L.
Scelinger."
((}
5 I take it you don't recall seeing that 6
section of the memo either?
7 A
No, I do not.
8 Q
Does this refresh your recollection 9 i concerning any contact with utilities about their e
10 procedures as opposed to just their STS's?
'l l A
No, it does not.
12 Q
Do'you recall while you-were' supervisor
^T 13 of operations foi Unit 2 ever attending any' meetings (0
14 of the GORB7 i
15 A
I was-not a member of the GORB, but I did 16 make seme presentations to them when they were in 17 session.
N 18
'Q Did you make presentations about any 19 particular subjects?
.s 20<
A Only operations.
\\
'~
~
21 Q
t Do you recall how frequently you made III 22 such presentations?
23 A
No, I do not.
I, don't know their meeting i
r 24 frequency.
(
O 25 Q
-Do you believe'you made presentations l
f Dpel 3
5 1
Floyd 256
- } ' '.I
,r' [
[
' / _.f,.
2 more than once a year?
q.-
1 l' 3
A I believe I made presentations whenever 4
they met.
'/
5 MS. WAGNER:
I would like to have marked 6
as B&W 470 a two-page document on the letterhead 7
of Metropolitan Edison Company entitled " Proposed 8
Agenda for the October 12 to 13 TMI-2 GORB 9
Briefing."
10 (Two-page document on letterhead of 11 Metropolitan Edison Company entitled " Proposed 12 Agenda for the October 12 to 13 TMI-2 GORB 13 Bfiefing" marked B&W Exhibit 470 for identification,
14 as of this date.)
15 BY MS. WAGNER:
16 Q
Have you seen B&W' 4 70 before?
17 A
Not to my recollection.
18 Q
Referring to subparagraph II on page 1,
it 19 is entitled " System Turnover and Operational Status l
20 J.
R.
Floyd."
Subparagraph B is "Significant Problems."
l 21 Do you recall any significant problems O
22 with system turnover in or about September 19777 23 A
I have no such recall.
l 24 Q
Do you recall any significant problems s
25 concerning operational status at or about that time?
1 Floyd 257
- Q 2
A No.
'w) 3 Q
Do you recall making a presentation at 4
or about that time to the GORB7 5
A No.
g 6
Q Did you ever keep notes of proceedings 7
before the GORB7 8
A No.
9 Q
When you made presentations before the 10 GORB, would you sit through an entire meeting with 11 them, or just come in and make a presentation and 12 leave?
,e g
13 A
The reason for this agenda being published NY 14 was so we would have some idea of when we would need 15 to be there.
We presenters were not normally tied 16 up for the whole meeting.
17 Q
Subsection V is entitled " Standard 18 Technical Specifications Status," and subsection B 19 refers to "Significant LCO Problems."
20 Do you know what LCO problems are?
21 A
In the context of the standard technical O
22 specification, it refers to a limiting condition of 23 operation.
24 Q
Do you recall any problems at or about (n
i i
\\>
25 this time with respect to a limiting condition of
1 Floyd 258 1
[~h I
i 2
operation?
'w) 3 A
None specifically.
4 Q
Do you recall any generally?
lh 5
A No.
6 Q
Do you recall whether during the 7
time you were supervisor of operations for TMI-2 the 8
operators of that unit were given training with respect 9
to emergency procedures?
10 M'R. SELTZER:
During what time period?
11 MS. WAGNER:
During the time he was 12 supervisor of operations for Unit 2 before the Ih 13 accident.
O 14 A
I had a general recall of that.
No 15 specific detail.
16 Q
Do you generally recall hcw the training 17 was administered?
18 A
Two types of training took place.
One 19 was lecture by the training department in the 20 training classroom.
The other one <as where the 21 man would take the procedure in his hand and walk it 22 through so he knew where the controls were located to j
23 implement that emergency procedure.
1 24 Q
Do you know if prior to the accident the
,3
(
)
RJ 25 operators were trained that there was a procedure, an I
1 Floyd 259 2
emergency procedure, applicable to every conceivable s'-)
3 type of emergency which could occur at TMI-27 4
MR. SELTZER:
When you say cor.ceivable, 5
do you mean credible or do you mean g
6 MS. WAGNER:
I mean conceivable.
7 MR. SELTZER:
That the imagination of mind 8
could conceive?
9 MS. WAGNER:
That's correct.
10 A
I don't think the operators had that 11 impression nor were they taught to have that i
12 impression.
13 Q
Do you know if they were given any training s
14 as to what they were supposed to do if a situation 15 came up for which they could not figure out that there 16 was any applicable emergency procedure or other 17 procedure?
18 MR. SELTZER:
Objection.
No foundation 19 that there was any credible accident which the 20 operators conceived of for which there was no 21 drafted procedure.
O 22 Q
You can answer the question, j
23 A
I have no recall of such training.
24 Q
'Do you understand your counsel's
('s
(_)
25 distinction between credible and conceivable?
l
1 Floyd 260 2
A Yes.
3 Q
What is the difference?
4 A
Credible in the nuclear industry is fairly 5
well determined by the Nuclear Regulatory Commission, g
6 and it's bounded, although not very credibly.
7 Q
what are the-bounds?
8 A
They are not necessarily centinuous, and 9
that is why they are hard to describe, one condition 10 that is traditionally imposed is one active failure 1
11 may take place during any accident, and the reactor 12 core must be maintained in a safe condition.
i 13 (Continued on following page.)
14 16 16 17 18 19 20 21 9
22 23 24 25
1 1
Floyd 261
)
2 Q
Did you have any understanding prior to the 3
accident of what kind of events were included in the 4
term " active failure"?
lh 5
A Yes.
6 Q
What were they?
7 A
A valve that fails to move that is commanded 8
to move, a pump failing to start that is called upon to 9
start, or any other piece of machinery that was demanded 10 to function and did not function.
Check valves I think 11 might have been excluded from that definition, because 12 they are opened by system pressure.
(
13 Q
Did the NRC analysis include failures of 14 any piece of equipment in a nuclear plant as a defined 15 active failure?
16 A
No, I don't think so.
17 Q
Do you recall what, if any, limitation there 18 was?
19 A
They were only interested in nuclear safety 20 related items.
21 Q
So was it your understanding that an 22 accident was considered incredible by these NRC 23 definitions if it involved two active failures of 24 safety-related equipment in the nuclear steam system?
25 A
No, I do not think they would consider that
1 Ficyd 262 (A) 2 incredible, because the first failure could have been
\\_/
the initiating event.
After the initiating event, you 3
4 had to be protected against one active failure.
lh 5
Q so if you had an initiating event of two 6
active failures, that would be without the bounds of this definition?
7 8
A I will not so restrict the NRC's definition but that might be an accurate representation of what I g
10 believed their definition to be.
11 Q
That was my question, what you understood 12 that definition to be.
That is what your understanding f'}
13 was, is that correct?
\\_/
14 A
Not necessarily incredible but not necessary 15 to be protected against.
16 Q
Did you personally have an understanding of 17 an incredible accident which was different from the NRC't 18 definition?
19 MR. SELTZER:
I don't understand.
What are i
20 you asking?
21 MS. WAGNER: I believe the witness just dB!
og indicated that an event which involved a failure 23 and two active failures would be incredible he l
ex 24 understood by the NRC definition, but not
(
)
i
~
necessarily by what he thought.
I am wondering 25
m i
Floyd 263
)
if he had an understanding which was different 2
fr a the NRC's.
3 MR. SELTZER:
I hope you and Mr. Floyd and 4
lh whoever reads the record understands that 5
6
" incredible accident" is a term of art, and what PeoP e may say is incredible to them is not l
7 8
necessarily inconsistent with what the NRC would 9
say, but it might be inconsistent with what the 10 term of art embraces.
11 MS. WAGNER:
I understand that the term of 12 art embraces something that the NRC has defined.
()
13 BY MS. WAGNER:
14 Q
Is that not correct?
15 A
It has been the intention of my answers in 16 this series of questions to tell you that I don't know 17 what the NRC's definition of incredible is.
I know 18 they have such a definition.
I have tried to explain to 19 you some of my definitions of what is incredible, but I 20 am not suggesting that my definition of incredible is 21 either concurrent with or is to be imposed upon the 22 NRC.
23 MR. SELTZER:
Did you mean congruent 24 instead of concurrent?
25 THE WITNESS:
Yes, that would be a better i
n -.
-. ~ -,.,---.
g Floyd 2G4
()
word.
2 MS. WAGNER:
I object to your changing the 3
witness' testimony.
4 lh MR. SELTZER:
I just wanted to make his 5
6 testimony congruent with what he is trying to 7
express.
8 BY MS. WAGNER:
9 Q
Did you ever receive any training concerning 10 the NRC's requirements for the design of a nuclear 11 reactor?
12 A
No.
/~N.
13 Q
Did you ever read, prior to the accident, U
14 10 CFR Part 507 15 A
Yes.
16 Q
Under what circumstances did you read it?
17 A
I don't recall.
18 Q
Do you recall what it is about?
19 A
Generally, yes.
20 Q
What is the subject matter of 10 CFR 21 Part 507 22 A
I remember on the record yesterday as having 23 answered that question.
I 24 Q
Could you give a brief answer today?
O
( )%
25 MR. McBRIDE:
Are you asking the current
Floyd
.265 1
status of Part 50 or pre-accident?
2 MS. WAGNER:
Pre-accident.
3 4
Q If I asked it yesterday, I apologize.
A It is my understanding that 10 CFR Part 50 jh 5
6 is a Federal regulation which governs the design, 7
construction, operation and testing of nuclear power 8
Plants.
(Recess taken.)
9 10 BY MS. WAGNER:
11 Q
Prior to the accident, do you know if 12 the operators at TMI-2 were taught that a procedure 13 might be applicable to a situation even if not 14 every one of the symptoms listed in the procedure was 15 Present?
16 A
Yes.
17 (Continued on following page) 18 19 1
20 ll 22 23 24 25 i
1 1
Floyd 266
)
2 Q
When they were taught to follow procedures, 3
do you know if they were taught to follow each step 4
in the procedure, eliminating none of them?
h 5
MR. SELTZER:
This is for each and every 6
procedure?
7 MS. WAGNER:
Yes.
8 A
Both operating and emergency procedures 9
ware meant to be followed step by step in 10 chronological order--in numeric order -- excuse me 11 and not to go to step 5 before you completed step 4.
12 Q
Once an operator had determined that a
()
13 particular procedure was applicable, do you know if he V
14 was ever taught that he could use his own judgment to 15 decide not to follow the procedure?
16 A
Only if he decided that it was no longer i
17 applicable and then some other procedure was more 18 applicable.
19 Q
Could he stop following a procedure in the 20 middle of it in such a situation?
l 21 MR. SELTZER:
You mean in such a situation 22 being where he decides that a procedure is 23 nonapplicable?
I gg 24 MS. WAGNER:
Where he starts following 25 procedure A and concludes somewhere in the middle
~
2 1
Floyd 267
[ )'
2 of following it that it is not applicable any V
3 longer.
4 A
As I remember, your question started out
~
lh 5
with could an operator, and he was probably not so 6
instructed, but he probably could.
7 Q
I meant, do you know if he was instructed 8
that that was an appropriate course of proceeding?
9 A
I don't believe such instruction took place.
10 Q
Do you know if ever 6perators were taught 11 whether in the event of a conflict between an emergency 12 procedure and an operating procedure, one was to take 13 priority over the other?
(
14 A
It is my belief they were instructed that 15 emergency procedures took priority over operating 16 procedures.
17 Q
I would like to show you a document which 18 has been previously marked B&W 305 and ask you if 19 you have seen that document before.
20 A
I have not seen this particular document, 21 which is a reduced size of the emergency procedure on 22 TMI-2, but I am familiar with TMI-2 procedure.
23.
Q Can you tell me where in the procedure are 24 listed the symptoms of a failed open PORV, if O
25 anyplace?
3 1
Floyd 268 2
A I believe Section B on page 2 would be 3
applicable.
4 MR. McBRIDE:
Do you mean page 2 of the I
lh 5
document or numbered page 2.07 l
6 THE WITNESS:
Numbered 2.0 on the actual 7
procedure itself, as opposed to the document.
8 Q
And you are referring to Section B-1 or B-27 9
A B-1 and B-2 are not mutually exclusive.
10 Q
Could you tell me what symptoms here 11 relate to a failed open PORV?
12 A
Under Section B-1 entitled " Symptoms," item 13 2,
reactor coolant system pressure is below 2205 psig 14 and RC-R2 fails to close.
15 Q
Are those the only two symptoms?
16 A
Symptom No. 3 also appears to apply, RC-R2 17 discharge line temperature is above the 200 degree 18 Fahrenheit alarm on the computer point 204, and symptom 19 No. 4 also appears to apply, the RC drain tank 20 temperature and pressure are above normal on the 21 control room rad waste disposal control panel 8-A.
22 Q
Is there anything else that appears to be 23 designated as a symptom for a failed open PORV?
l 24 A
Not under this heading entitled " Symptoms."
.O 25 Q
Is RC-R2 the PORV on Unit 27
1 Floyd 269 2
A Yes.
3 Q
The item numbered 3 under " symptoms," is 4
the number 402 in that line a reference to a specific lll 5
C aputer point?
6 A
Yes.
7 Q
Item No. 4 refers to RC drain tank pressure 8
and temperature above normal.
Do you know what was 9
considered the normal RC drain tank pressure?
10 A
within two or two and a half pounds gauge 11 pressure for the temperature.
12 Q
And what was the normal temperature, if 13 you can recall?
14 A
I cannot recall normal temperature on the i
15 tank.
It would probably be ambient in the reactor 16 building.
17 Q
Is it correct that the procedure does not 18 refer to pressurizer level activity as a symptom of 19 an open PORV?
1 20 A
It is true.
It does not.
j c
21 Q
Under B-2, Immediate Action, Section 2, are 22 the actions listed under A, B and C therein actions i
i l
23 which would be taken automatically by the system in i
24 the event of an open PORV and would not require 25 operator action?
l L
1 Floyd 270 t(_)
2 A
That is true.
They are automatic.
. aN Q
Did you know prior to the accident why the 4
reactor system was designed so that in the event of a lh' 5
f ailed open PORV all pressurizer heater banks come on 6
fully below 2105 psig?
7 A
They were not designed to come on full 8
because the electromatic relief valve was stuck open.
9 They are normally controlled to come on at 2105 10 with a decreasing pressure.
11 Q
Do you know why, and this is before the 12 accident, did you know why one of the automatic actions 13 in the event of a failed open PORV was HPI actuation 14 at 1600 psig?
15 A
Again, the logic on setting the high-16 pressure injection set point was to protect the plant 17 from any down pressure transient, no matter what it 18 was caused by, and the fact that in this procedure we 19 are talking about a PORV does not mean that it was the 20 PORV failure that dictated the set point.
21 (Continued on next page) 22 23
(~}
24
\\.J 25
b/l 1
Floyd 271 2
Q To the best of your recollection, did 3
operators at TMI-2 receive instruction on this 4
procedure?
ll) 5 A
I have no specific recollection of 6
instruction on this procedure, but I have a general 7
recollection that they were trainad in all emergency 8
procedures.
9 Q
Prior to the accident in 1979, had you 10 ever heard of a PORV failing open in a real life 11 situation?
12 A
Yes.
13 Q
More than once?
Not more than once had O
14 you heard it but had it happened more than once, to 15 the best of your recollection?
16 A
I believe it happened more than once, to 17 the best of my recollection.
18 Q
Do you recall how many times?
19 A
A multiplicity of times.
20 Q
Do you recall any of them specifically?
21 A
Yes.
22 Q
Can you tell me whatever you recall 23 specifically.
24 A
On TMI Unit 2, and I can't give you the 25 date, but we had a failure of the inverter feeding
1 Floyd 272 vital bus 2-IV which is the power supp1y to this 2
.a1.e,
.nd on 1oss o, th.t,o.er s.,,1,,
th..a1 e 4
failed open.
5 Q
Do you recall any other incidents
(
6 specifically?
MR. SELTZER:
These are incidents that he 7
8 recalls knowing about before the Three Mi1e Island 9
catastrophe?
10 MS. WAGNER:
That's right.
A I cannot be specific but it seems to me gg 12 that it had been an industry problem, and it goes 13 fairly far back in time.
Ten years as opposed to ten months.
14 15 Q
Prior to the accident, was it your 16 understanding that a failed open PORV constituted a loss of coolant?
17 18 A
Yes.
19 Q
In the TMI-2 contro1 room, was there inf rmation available to the operators about prersure 20 i
21 and temperature in the reactor coolant drain tank?
O A
This procedure says it is on panel 8A which 22 is in the Unit 2 control room.
23 24 Q
Is it correct that that is a panel which did not face into the control room?
25 t
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1 Floyd 373 D
[V 2
A It did not face into the normally occupied area of the control room, but it was visible if you 3
4 walked around and looked at it.
lh 5
Q Prior to the accident, were you satisfied 6
with that placement of the temperature and pressure 7
indication of the reactor coolant drain tank?
8 MR. SELTZER:
You mean did he ever express 9
in words any dissatisfaction with its placement?
10 MS. WAGNER:
My question is was he 11 dissatisfied,whether he expressed it or not.
12 MR.
M cBRIDE :
I thought your question was
(
13 was he satisfied.
14 Q
At this point, were you satisfied,whether 15 you expressed it or not? Were you satisfied with the 16 Placement of the reactor coolant drain tank information 17 whether or not you expressed that satisfaction to anybody?
18 MR. SELTZER:
Objection.
No foundation 19 that the witness had formulated a state of mind 20 about the location of the pressure and temperature 21 readings for the reactor coolant drain tank.
22 Q
You can answer the question.
23 A
I have a vague recollection that we once 24 Proposed moving it before it was installed even, 25 Placing it where it would be more visible to the
1 Floyd 274
(
2 operator.
3 Q
Were you a proponent of that notion that 4
it should be placed in a different position?
/
5 A
Yes.
6 Q
Did you express that view to somebody?
7 A
That is about as specific as I can get, 8
somebody.
9 Q
Were you given any reason for why your 10 position was not adopted?
11 A
I do not recall.
12 Q
Do you know why your position was not 13 adopted, whether or not somebody told you?
14 A
No, I do not.
15 Q
Aside from the indication on the rad waste 16 panel, 8A, was there any other method by which the 17 operators could determine reactor coolant drain tank 18 pressure and temperature?
19 A
I do not recall if reactor coolant drain 20 tank temperature and pressure fed into the 855 computer 21 or if they were on the multipoint recorders associated 22 with that computer.
23 Q
I believe you indicated yesterday that 24 the drain tank level you thought was not on the computer O
25 because it had to be manually fed into the computer,
1 Floyd 275 2
is that correct?
A It was manually inputted for the purpose 3
4 of leak rates, which indicates to me that it was not lh 5
inputted as a normal parameter.
6 Q
Were you aware that in 1978 a change was 7
made so that it was the normal input into the computer?
g It became a normal input into the computer?
9 MR. SELTZER:
When?
10 Ms. WAGNER:
Sometime in 1978.
11 MR. SELTZER:
So you are asking him whether 12 your just stating it now is going to refresh 13 his recollection even though that is contrary to 0
14 what he just testified?
15 MS. WAGNER:
That's right.
16 A
No, I do not so recall.
17 Q
Prior to the accident, did you believe 18 that your operators, the operators at TMI-2, were able 19 to identify a failed open PORV?
20 A
Yes.
21 Q
What did you base that belief on?
22 A
The fact that they had been trained in 23 the emergency procedures and were considered proficient 24 in their use.
O
\\_,/
25 Q
I would like to show you a document which
3 Ficyd 276 2
has been previously marked as B&W Exhibit 272, and it is a py of the loss of coolant procedure for TMI-2.
3 4
Have you seen that procedure before?
h A
I don't know that I have seen it, this 5
6 ann tated copy that is marked 272, and I don't know that I have looked at Revision 11 specifically, but 7
g it is not an unfamiliar procedure to me.
9 Q
I would like to refer you to the page 10 numbered 1.0 of the procedure. The first Section A 11 concerns leak or rupture within capability of system 12 operation.
Is it correct that the items under Symptoms 13 are symptoms of a loss of coolant within the capability O'
14 of system operation?
15 MR. SELTZER:
Are you asking him to verify 16 that today he would consider these to be the 17 appropriate symptoms or just to say --
18 Q
Were these the symptoms the operators of 19 TMI-2 prior to the accident understood were symptoms of this event, according to their training?
20 MR. SELTZER:
I object.
There is no 21 O
22 foundation that he knows what the operators 23 understood.
A If this revision were in effect, then these 24 25 are the symptoms they would be familiar with.
1 Floyd 277 2
Q Was it your understanding prior to the accident that all of the symptoms listed herein, 3
1.121.6, were necessary in order to make this procedure 4
l 5
applicable?
6 A
No.
7 Q
Which ones were not necessary?
8 A
Generically, symptoms were listed as possible 9
indications and not all of them had to be present to 10 fully describe the situation.
This was merely a 11 compilation of some of the more important symptoms that 12 may be present, not meant to be exhaustive, nor 13 all-inclusive.
14 Q
Whatever symptoms did occur in order to 15 clue the operator in that some procedure was applicable, 16 were they all supposed to occur simultaneously?
17 A
No.
18 Q
Was there any limit to the time period 19 within which they could occur?
20 A
I have no recollection of knowing any time j
l 21 limit associated with the occurrence of symptoms.
22 Q
The procedure indicates that one unique i
23 symptom of.a loss of coolant inside reactor building l
is " particulate iodine and gas monitor alarm on 24 25 HP-R-227' reactor building air sample.'"
i i
1 Floyd 278 2
Is that a single monitor or three monitors being referred to?
3 4
A It is a single pump passing air past three different radiation detectors.
5 6
Q Did the three detectors detect radiation in 7
different items?
Was there a particulate detector g
and an iodine detector and a gas detector?
9 A
Yes.
10 Q
Was the intent of the procedure, to the 11 best of your recollection, that if any ons of those 12 monitors alarmed, it was a symptom of loss of coolant?
(
13 A
I don't have a recollection to that effect.
14 Q
Do you recall whether you knew prior to 15 the accident how the monitors worked?
16 A
Yes.
17 Q
Was it possible for one of them to alarm 18 without the other ones alarming?
19 A
Yes.
20 Q
Do you know if there was any procedure in 21 effect for insuring that these monitors were accurately 22 calibrated?
23 A
There was a surveillance program as required j
24 by the technical specification which required periodic O
25 testing and calibration of this radiation monitor.
--r
1 Ficyd 279 2
Q Do you know who -- and by "who" I mean 3
what title, what position -- was responsible for 4
insuring accurate calibration?
lh 5
A Accurate calibration would be a function 6
of the instrument and control shop.
7 Q
Do you remember what the procedure called 8
for as the test for accurate calibration?
9 A
No, I do not.
10 Q
Do you recall the frequency required for 11 testing?
12 A
No, I do not.
13 Q
Does this procedure address the conditions O
14 under which you may terminate high pressure injection 15 after it has automatically actuated?
16 A
This Section A of the procedure, the 17 follow-up action does bring on safety injection 18 manually, but I do not believe it refers to automatic 19 initiation of safety injection.
20 Q
Does part B address automatic actuation?
21 A
Yes, that is one of the sy mp toms.
O I
l 22 Q
Does part B address circumstances or l
l 1
23 conditions under which HPI may be terminated after it 24 has automatically actuated?
25 A
on page 10 of the procedure, under step O
Floyd 280 1
i 3.5, it gives you permission to throttle the high
(-
2 NJ l
pressure injection flow, and on page 10.2, step 3.6.3
.I 3
reads shut off HPI pumps.
4 Q
What conditions have to be in effect for 5
k.
6 Section 3.6.3 to be applicable?
j A
LPI has to be in service with a flow rate 7
g above 750 gallons per minute each.
9 Q
I would like to refer you now to page 7.0 10 of that procedure to section 2.2.2, the small break 11 LOCA response.
Is this the addition to the procedure l
12 which you were testifying about earlier which came as
(~
13 a result of,the small break LOCA guidelines and the V) 14 cross-connecting of HPI?
15 A
This is the start of that section, yes, 16 Q
Section 2.2.2.1 indicates that certain
}7 actions must be taken "within two minutes of the LOCA."
18 Do you know where that time requirement came from?
A I think it came from B&W, but I cannot 19 l
f be sure of that.
20 21 Q
Did that require recognition of a LOCA 22 within two minutes of its initiation, to the best of
'i 23 your recollection?
(~
24 A
It required recognition of a small break NJ l
25 l
LOCA within two minutes.
l l
a I
I 1 -
1 Floyd 281 2
Q Prior to the accident at Three Mile Island in march
,,7,.
.ere,ou g.nera11y
...re o, ho. th.
reactor coolant pumps worked?
4 e
A Tes.
3 6
Q Had you eve-encountered the concept of cavitation?
7 g
MR. SELTZER:
What do you mean by "ene untered"?
9 10 Q
Had it ever come to your attention?
11 A
The thought or the actual action?
12 Q
The though..
Did someone tell you what 13 cavitatior. meant?
14 A
Now you have gotten two questions here 15 mixed up in my mind.
cavitation in a pump, cavitation 16 in a reactor coolant pumps which do you prefer to 17 address?
18 Q
When did you first hear about cavitation in 19 a pump?
l 20 A
Years ago.
21 Q
What is cavitation in a pump?
22 A
The formation of vapor phase bubbles in the 23 impellsr of the pump and the subsequent collapse of 24 those bubbles.
O 25 Q
That whole process is called cavitation?
-m
1 Floyd 282 l
1 A
I don't know if the collapse is part of the p
2 definition of cavitation or not.
3 Q
Had you ever heard that cavitation could occur in a reactor coolant pump?
A Yes.
6 Q
Did you have an understanding as to what the condition of the reactor coolant system would have to be in order to result in cavitation in a reactor 9
coolant pump?
A The NPSH curve is transmitted to us by B&W, and NPSH is net positive suction head, and it is designed to prevent cavitation.
It was our guideline for pump operation.
14 Q
What is net positive suction head?
A The pressure required to prevent cavitation.
Q Is that a variable pressure depending upon temperature?
g A
In a water system, yes.
g Q
Is that why the NPSH curve'is a curve?
A Yes.
21 O
Q Because it differs, depending on the temperatures and pressure?
A
'Yes.
Q Do you know whether M I-2 operators 25
---r.-
,7
,-m r--4.,---
yer v3-,,
,3
-..-------.e-
i Floyd 283 2
received instruction concerning the NPSH curve?
A It was part of the reactor coolant pump 3
4 operating procedure, and as such they would have received h
5 instruction in it.
6 (Recess taken.)
7 Q
Do you recall whether prior to the accident, 8
operators were taught to do something if they were 9
exceeding the NPSH curve?
10 A
By exceeding it', you mean operating below 11 it?
12 Q
Yes.
13 A
I believe the limit and precaution talks 14 about not going below the NPSH curve.
I don't recall 15 if there is a procedure on what to do if you find 16 yourself below the NPSH curve.
17 Q,
Do you recall ever hearing of one thing you 18 might do in that circumstance is increase pressure in 19 your reactor coolant system?
20 MR. SELTZER:
When ydu say one thing you 21 might do t
22 Q
One thing you should do.
)
23 A
It seems reasonable.
24 MR. SELTZER:
Just tell her if you recall 25 that is what was taught.
1 Floyd 284 2
A I withdraw my answer.
MS. WAGNER:
I object to your instructing 3
4 him to withdraw an answer which makes perfectly h
5 g od sense to me and I am sure was taught.
6 Q
Do you recall one thing you might do in the event you were operating below the NPSH curve, or 7
8 should do, was try to increase pressure?
9 A
Yes.
10 Q
Do you recall how an operator might go about 11 increasing the pressure?
What were the options 12 available to him?
13 A
Turn on the pressurizer heaters.
14 Q
Did he have any other options?
15 MR. SELTZER:
Other options that he was 16 taught?
17 MS. WAGNER:
Other options that Mr. Floyd 18 knew about prior to the accident.
19 A
Other ways to increase plant pressure?
20 Q
Yes.
21 MR. SELTZER:
If the operator found out he 22 was below the net positive suction head curve?
23 MS. WAGNER:
Yes.
24 A
I know of no other way he could increase 25 plant pressure.
Floyd 285 i
(~N 2
Q Was another thing that he should do,1f he O
f und himself below the net positive suction head curve, 3
is reduce temperature?
4 A
It would be another way to get back on the lh 5
6 safe side of the curve.
7 Q
Do you recall what the options available 8
to him were which would result in a reduction in 9
temperature?
10 A
Depending on what mode of heat removal he 11 had in effect at the time, whether he was steaming 12 the steam generators,he could increase his feed and 13 steaming rate to the steam generators.
O 14 If he was on decay heat, he could increase 15 the flow in the decay heat system or in the decay heat 16 closed cooling water system to effect greater cooling.
17 Q
Can you think of any other method?
18 A
Those are the two normal methods of cooling.
19 Q
If the operators discovered they were below 20 the net positive suction head curve, would the use of 21 HPI result in either lower temperature or higher pressure 22 in the reactor coolant system?
23 MR. SELTZER:
Objection.
24 Are you asking him to give you the results O)
\\,
25 of thought processes he had on this subject l
l l
l
1 Floyd 236
()
2 before the accident?
.S.
WAe...:
Y.s.
4 MR. SELTZER:
You don't want him to figure lh-5 out the answer today?
6 MS. WAGNER:
No.
I want to knov what he knew 7
before the accident.
8 A
Before the accident, I believe that the use a
9 of HPI could have raised plant pressure and might have 10 aided the cooling.
11 Q
Did you ever hear of the concept of going 12 solid in a reactor coolant system?
()
13 A
Yes.
14 Q
What to. your understanding, prior to the 15 accident, was meant by that term?
16 A
Going solid was meant to be operating without 17 a steam bubble in the reactor coolant system.
~
18 Q
Was that considered a good thing or a bad 19 thing for normal operation of the system prior to the 20 accident?
21 A
Undesirable.
22 Q
Did you understand why it was undesirable?
23 A
Yes.
24 Q
Why was it undesirable?
25 A
If the system is liquid full, there is no
g Floyd 287 mpressible fluid available in the system to act as a 2
shock absorber, and therefore any slight change in temperature will effect a large change in pressure.
4 h
Q Was y ur un ers an ng prior to de 5
accident that if the reactor coolant system had a 6
bubble not in the pressurizer but someplace else, that it.
7 g
could be described as a solid system?
MR. SELTZER:
In other words, the 9
10 pressurizer is full to the roof and there is a bubble someplace else?
11 12 MS. WAGNER:
Right.
A W uld I bef re the accident have described 13 that as a solid system?
Is that the question?
14 15 Q
Yes.
16 A
No, I would not have described that as a 17 solid sysrem.
ig Q
Do you know if the operators at TMI-2 were 19 trained prior to the accident as to what they would see 20 if a system went solid?
A The only experience, and hence I think 21 9
22 training that the operators at TMI-2 had on solid 23 operation was for hydrostatic testing.
24 Q
During hydrostatic testing, did the system 25 exhibit the sensitivity to pressure changes that you
1 Floyd 288 2
described previously when it was solid?
A The pressure changes I described previously 3
4 were induced by temperature changes, and during the lll 5
hydrostatic test heat is neither added to it nor 6
removed from the system, therefore you are not 7
susceptible to those type pressure changes.
8 Q
While you were in the Navy, did you ever see 9
a system operated as a solid system, a re:setor coolant 10 system operated as a solid system?
11 A
No.
1 12 Q
Did you know that the reactors in the Navy 13 could be operated in a solid mode?
O 14 A
No, they could not.
It was what they call 15 the semi-solid mode.
16 Q
What did semi-solid mean?
17 A
To me, semi-solid meant that you were adding 18 water to the reactor coolant system at the same time 19 you were removing water from the reactor coolant system, 20 and hence your pressure was controlled by the rate of 21 addition and removal of water.
Hence, the system was not G
22 truly solid.
23 Q
Did such a semi-solid system exhibit 24 sensitivity to pressure and temperature such as you 25 described previously?
1 Ficyd 289 2
A Yes.
O Q
W8r* Y u familiar prior to the accident 3
4 with a procedure --
ll A
May I clarify my last answer?
5 6
Q sure.
A While my previous description of pressure 7
g sensitivity to temperature changes Was not quantified, 9
in the semi-solid system of operation, if reactor 10 coolant system pressure started increasing, the amount 11 of let-down was automatically increased because of the 12 increased driving head of the pressure in the system, 13 so the pressure tended to be self-limiting in the semi-14 solid mode,wh'ile in the actual solid mode it would not 15 be so self-limiting, so semi-solid is safer than solid.
16 Q
Were you familiar prior to the accident 17 with a procedure which came into effect after a LOCA I
18 and was for the purpose of boron control?
19 A
I do not have a clear memory of such a 20 procedure.
21 Q
I refer you to your President's Commission 9
22 testimony, pages 146 to 147.
The testimony appears to 23 be about a procedure for post-LOCA boron control.
24 I would like you to read the testimony, 25 please, on pages 146 and 147 and tell me if that
Floyd 290 refreshes your recollection at all with respect to the existence of such a procedure.
3 A
I have completed reading the testimony on pages 146 and 147.
Q Does it refresh your recollection with respect to a procedure for post-LOCA boron control?
MR. SELTZER:
He said there he is not sure g
"whether or not that ever found its way into our procedure or not.
I can't say until I go back 4
and check procedures in both units to see if I
an find a number for you."
2 Q
Do you recall checking the procedures?
13 A
No, I have not.
t g
Q Do you recall today whether any such i
procedure existed at TMI?
g A
No, I do not recall that today, but I do g7 recollect from just reading this testimony, it is yg 19 very n using and I was in a very confused state of mind when I said those things.
Like very much of my prior testimony, it could have been an error, l
9 In this case I left enough if's and maybe's and when's to not have testified wrong, but in fact I g
think I was in a confused state of mind when I gave that g
O tesumonx.
,s
v Ficyd 291 1
2 Q
I take it when you gave this testimony, you 8
O believed it was truthful as far as you knew?
3 A
Yes, at the time I gave it, I believed it 4
to be the truth.
ll 5
6 Q
And you have no recollection now as to what that you believed might have existed?
7 Procedure it was g
A I also said it might have been in a B&W 9
topical report, and I have not searched those for it 10 either, and it could very well be in there but I have not 11 made a record search to substantiate this statement one 12 way or the other.
i 13 Q
Right now you have no recollection one way 14 or the other of the existence of such a procedure, is 15 that correct?
16 A
I cannot recall such a procedure.
17 MS. WAGNER:
That is all for today.
18 (Time noted:
3:50 p.m.)
19 20 JAMES R.
FLOYD i
l lll Subscribed and sworn to before me i
22 this day of 1982.
23 1
24 O
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1 292 i
CERTIFICATE O
2h b
STATE OF NEW YORK
)
3 :!
- ss.:
ji COUNTY OF NEW YORK
)
JOSEPH R.
DANYO I,
, a Notary Public of the State of New York, do hereby certify.that the continued deposition of 7
I' JAMES R.
FLOYD was taken before 1
8 Feb nan 19, 1982 me on consisting 9
160 291 of paSes through 10 I further certify that the witness had l
11 been previously sworn and that the within transcript is a true record of said testimony; O
j That I am not connected by blood or 14 marriage with any of the said parties nor l
1 a
interested directly or indirectly in the matter I
16 u.
i' j
l in controversy, nor am I in the employ of any 4
17 l of the counsel.
16h l
IN WITNESS WHEREOF, I have hereunto set my 19 :
i hand this h day of h tvNy' /7f8 i
20 ji l
g 21
~
O& /.On 23 l
/
'JoS.,
4a YO
,a i
25 i
t i
.____.._._.__.___..._..._._-._,,.....___...__..__..._-._._...._m._,_.____.._.
293 i
IN DEX WITNESS PAGE James R.
Floyd 162 EXH IB IT S B&W FOR IDENTIFICATION 467 Three-page document entitled "TMI Station, Brief Overview of Unit 2 Procedure History,"
dated May 25, 1979 233 468 Seven-page document entitled "NRC Inspection 77-04", dated February 3,
1977 240 469 Five-page memo from Gary s
Miller to Mr. Floyd and others, s) dated 3/14/77 254 470 Two-page document on letterhead of Metropolitan Edison Company, entitled " Proposed Agenda for the October 12 to 13 TMI-2 GORB Briefing" 256 oOo l
l (2)
f4 o,
/
.s_.
La e C
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DOYLE REPORTING. INC.
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369 LExiNGTON AvtNUE
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.p NEw TOWst. N Y 10017 (212t 667 8220 Listte A ocvLE Wagtte suas.ac u o r,,; g, py,,,e C= ests S=ameno June 20, 10P2 I
I OA"I9 POLK & VAP.7'ILI,, ESOS.
One Chase vanhattan Plaza New Ycrk, New York ATT:
Ms. Karen Wa ner Lear Karen:
Enc 1csed clease find the cricinal and one e
cecy of page 220 of the Tetruary 1c, Ic 2 sessien of the Ja.es P. Flevd dercsitien trans crict, ccrrectlin line 7 fret E I to L'I.
This ccrrection was made eer the discussien between all tarties, after tv stenograchic nctes were checked te confir-the correction.
A cery has also been sent to Kaye Scholer.
- Yours trulv,
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s 4 SEPH.. DANY0
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'PD/JW cc: Richard C. Seltzer, Esq.
Kave Scheler Tier an Have & Handler, Esgs, or p o s.v.o-o as eit e atio~ e evoca-o oce
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