ML20072H767
| ML20072H767 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 08/10/1982 |
| From: | Illjes T GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-04, TASK-1, TASK-10, TASK-11, TASK-4, TASK-GB NUDOCS 8306290729 | |
| Download: ML20072H767 (157) | |
Text
hd g UNITED STATES DISTRICT COURT
,'Q SOUTHERN DISTRICT OF NEW YORK
-- - - - - - - - - - - - - - - - - - - -x GENERAL PUBLIC UTILITIES CORPORATION, e
'; JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAt{ EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. :
(
-- - - - - - - - - - - - - - - - - - - -x Deposition of GENERAL PUBLIC UTILITIES
%)
COMPANY 'by THEODORE F. ILLJES, taken by Defendants pursuant to agreement, at the offices of Davis Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York on Tuesday, August 10, 1982, at 9:15 o' clock in the forenoon, befo'e r Nancy A. Rudolph, a Shorthand Reporter and Notary Public within and for the State of New York.
8306290729 820810
. PDR ADOCK 05000289 T PDR O DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 LsxlNGTON AVENUE WALTER SHAPIRO, C.S.R. New Yonx. N.Y. loo 17 CHARLES SH APIRO, C.S.R.
TELEPNoNr 212 - 867 8220
1 2 O
2 Appe a ranc e s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue New York, New York By: ANDREW MacDONALD, ESQ.,
G of. Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York
(
11 By: ANN MCDONALD, ESQ.,
12 of Counsel 13 14 KILLIAN & GEPHART, ESQS.
Attorneys for, Theordouw F 15 Illjes Box 886 16 Harrisburg, Pennsylvania 17108 17 By: JANE G. PENNY, ESQ.,
18 - of Counsel 19 .
20 Also Present:
21 EDWARD HILL
(' 22 .
23 * *
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t 2 IT IS HEREBY STIPULATED AND AGREED by 3 and among the attorneys for the respective 4 parties hereto that the sealing, filing and
( 5 certification of the within deposition be, 6 and the same hereby are, waived; and that 7 the transcript may be signed before any Notary 8 Public with the same force and effect as if 9 signed before the Court.
10 IT IS FURTHER STIPULATED AND t AGREED that 11 all objections, except as to the form of the 1
12 question, are reserved to the time of trial.
13 14 * *
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t 1 4 O^ 2 THE O D0RE F. I L LJ E S, 3 having been first duly sworn by the Notary 4 Public, was examined and testified as follows:
(' 5 EXAMINATION BY MS. MCDONALD:
6 Q Mr. Illjes, would you give us your address, 7 please?
8 A Box 135-A, RD #1, Hershey, Pennsylvania 9 17033.
10 Q By whom are you employed att the present 11 time?
12 A GPU Nuclear.
A/ 13 Q What is your job for them a the present 14 time?
15 A I am a shift foreman, nue, lear.
16 Q On Three Mile Island?
17 A At Three Mile Island. .,
18 Q Which unit at Three Mile I s'la[d ?
19 A Unit 2.
20 Q How.long have you held that job?
. 21 A That particular job started in December of 22 '79, 23 Q What job did you hold before that?
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v 24 A Control room operator, Unit 2.
25 Q How long did you hold that job?
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2 A Since 1975.
3 Q So you were a control room operator, I 4 take it, from 1975 through December of 1979
() 5 approximately?
6 A Approximately, yes.
4 7 Q Prior to being a control room operator, .
8 did you have any other job at GPU Nuclear or Met 9 Ed?
10 A I was an auxiliary operaton on Unit 1.
11 Q Unit 1 on Three Mile Island?
12 A correct.
( 13 Q How long were you an auxiliary operator?
I 14 A Since 1971. -
15 Q when did you become employed by GPU?
16 A 1971. It was Metropolitan Edison then.
17 Q Could you give us an idea of your formal 18 '
educational background?
19 A High school graduate, two year's of
-20 college. I did not graduate.
21 -Q .What college?
22 A Colorado State University. !
l 23 Q What courses did you take in Colorado?
(~ 24 A I was majoring in forestry, so it was V}
25 biological, biology, some math, _some physics, l l
l l
, _ . . _ . , - --. , , , , , , - - ~ ~
1 Illjes 6 O- 2 chemistry.
3 Q Any courses in nuclear engineering?
4 A No.
(i 5 G Any courses in engineering?
6 A No.
I 7 Q How long a physics course did you take?
8 A Cross off the physics course. I am 9 going back to my high school course there. I had 10 chemistry and math courses in college.(
i 11 Q You had some physics in high school?
12 A Yes. .
O- 13 Q Have you taken any postgraduate courses?
14 In other words, since college , have you taken courses in 15 anything?
16 A Not a credit --
no credit courses.
17 Q Have you taken courses other than at your 18 job, whatever job you might have held?
19 A Like a correspondence course? -
. 1 20 Q Yes.
21 What courses did you-take?
22 A Mostly for personal. I took a pesticide 23 license course in Pennsylvania.
.(]
"N 24 Q Anything else?
25 A I don't recall any others, no.
1 Illjes 7 f^'\
2 Q What did you do when you got out of 3 colorado State? .
4 A I worked for the Forestry Service.
How long did you work for the Forestry
( 5 Q 6 Service?
7 A It would have been from June '63 till 8 about somewhere around November.
9 Q of '637 10 A '63. g 11 Q Then did you go in the Navy?
12 A correct.
i
(~'/
\s- 13 Q What responsibilities did you have in the 14 Navy? .'
15 A I went from no responsibilities to 16 responsibility as an engineering -- leadibg engineering 17 lab technician. That was the last position I held 18 '
before I got out of the Navy.
19 Q How long were you in the Navy?-
20 A Seven years, three months.
21 Q Did you hold other positions in between 22 having no responsibilities and being a leading 23 engineering lab technician?
24 A Yes.
25 Q What jobs were those?
1 1
1 Illjes 8 O 2 A Do you want to start from the beginning?
3 Squad leader in boot camp, or something like that.
4 Q Let me ask you, were you involved in the
( 5 nucle'r a navy?
6 A Yes.
7 Q What responsibilities did you have while 8 you were in the nuclear navy?
9 A Starting out with schooling in Bainbridge, 10 Maryland, Nuclear Power School. From tpere I went to 11 West Milton, New York. A prototype was at West Milton, l 12 New York, SG3(3C), or something like that.
13 Q Then what?
j 14 A That was a qualification process there 15 before you left to qualify on that particular power 1
t 16 plant. I
, 17 Q Did you receive some sort of certification? ,
18 A You have an examination and th'ere was an 19 oral examination that you had to pass. '
20 .Q What did passing that examination qualify 21 you to do? , j 22 A I was a mechanical operator on that 1
23 particular plant.
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v 24 ,
Q What plant was that?
25 A SG3.
1 Illjes 9 l\ ~
U 2 Q Was this some sort of nuclear plant?
3 A Correct.
4 Q What kind?
( 5 A Pressurized water reactor.
6 Q Did you ever work in a nuclear-powered 7 vessel?
8 A Nuclear powered vessel?
9 Q Boat, ship.
10 A Yes, that was a vessel, if you want to 11 term that a vessel.
12 What ship did you work on?
Q , ,
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L/ 13 A USS Robert E. Lee and the USS Bergall.
14 Q Were you an operator on that ship?
15 A I was a mechanical operator and 16 engineering lab technician on both submarines.
17 By " mechanical operator," what did you do?
Q 18 I am not sure what you mean by mechanical operator.
19 A Well, there are three different types of 20 operators. I was a mechanical operator which had to 21 do with operation of a steam plant from a mechanical 22 situation, operation of valves, operating turbines, 23 lubricating systems, cooling systems. .
n)
(V 24 Q While in the Navy, did you ever manipulate 25 the controls of the primary system of any nuclear ship l
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2 or prototype?
3 A We were given basic training on manipulating 4 the controls, but that was not my job.
How long a period were you in training in
( 5 Q 6 the Navy?
7 A Always.
8 Q Was there a period of time while you were 9 in the Navy when you were being trained and you did not 10 have any responsibilities other than be ng trained?
11 A No. There was always some other 12 responsibilities to go along with it.
O 13 Q Did you receive any books ir materials in 14 the course of your training in the Navy? .'
15 A Yes.
16 Q Do you still have those today?
17 A No, not that I know of.
18 Q When you went to GPU/ Met Ed, did you receive l
19 any training? -
20 A Yes.
21 Q What training was that?
22 A Let's see --
23 Q shall we call it Met Ed?
(~' 23 A It was Met Ed back then. Not until
(
25 recently were we termed GPU Nuclear. I went to work.
1 Illjes 11 l (N '\ '
for Met Ed, I started a 42-week training program as 2
3 an auxiliary operator. I don't know if it was 42 l
4 weeks or not. It was somewhere around that length
( 5 of time.
6 Q Do you recall any of the courses or areas 7 of study that you took during those first 42 weeks?
8 A I started out with a math review, went into 9 physics review, went to reactor physics, reactor J
10 principles, reactor operation, all usua,lly, I think 11 it was, at the latter half, and then we got into 12 systems training. We had some health physics
( 13 training, some chemistry; radiological %ontrols.
14 Q Did any of this training inc16de learning i
15 anything about thermodynamics?
16 A I believe we had one short period in 17 there which we had a short course on thermodynamics 18 and fluid flow.
19 Q How about heat transfer? -
20 A That was included in that.
21 Q Was that a lecture-type thing?
22 A Yes, it was a lecture-type thing.
23 Q Do you remember who gave that lecture j or those lectures?
~
24 25 A Yes, he was Greek.
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i 1 Illjes 12
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k 2 Q Was this a Met Ed employee?
3 A Yes, he was a Met Ed employee. He was 4 very hard to understand. I am trying to think of
(
5 his name. It was George --
6 Q Tsaggaris?
7 A No. You are thinking of Lex Tsaggaris.
8 He was in the training department. George Millis.
9 Q How would you spell that name?
10 A Millis, however that is in reek.
11 Q He was a Met Ed employee?
12 A It was a Met Ed engineer. _
13 Q After the first 42-week tra'ining period, 14 did you receive any further training at Met Ed? Let's 15 take it while you were an auxiliary operator.
16 A We received on-the-job training. There 17 was a period of self-study and then also we had the 18 Unit 1 control room operators to help us o'u t there.
19 Q Did they give you lectures? -
20 MR. MacDONALD: I don't know if he was 21 finished.
22 MS. MCDONALD: I'm sorry. I didn't mean to 23 cut you off.
~T 24 A We also had some formal lectures from --
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25 I am getting Unit 1 and Unit 2 mixed up there -- when
I l
? 1 Illjes 13 l
t8 2 we came out of the 42-w. x training program, we went 3 into a startup program, and we had -- were pulled off 4 shift and that was where we got into either a five or
( 5 six week rotation process and one week out of the five 6 or six weeks, we were pulled off shift and went into 7 formal classroom training.
8 Q This was throughout the time that you were 9 an auxiliary operators one week out of five or six 10 was devoted to training, as far as you now?
11 A I'm not sure the date that started, but 12 that happened somewhere in the early phases of Unit 1.
13 Q When you became a control ioom operator, 14 did you have to go through any further training in 15 order to get that position?
16 A You are going on to Unit 2 now?
17 Q Whenever you became a CRO.
18 MR. MacDONALD: You are talking about when 19 he became a licensed c'RO or when he entered the 20 CRO program?
21 Q Did there come a time when you bid on the 22 CRO job?
23 A Correct.
- [') 24 Q After that, did you, in order to go into V
25 the program, did you have to go through training?
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1 Illjes 14
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2 A Yes.
3 Q What training was that?
4 A We started with a classroom training ,
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( 5 program.
6 Q How long did that go on for?
'7 A I don't remember the exact length of 8 time. I think it was about 12, 15 weeks. Then we 9 spent eight weeks in Lynchburg, Virginia at the B&W 10 simulator, which was classroom and simu[ator training.
11 Q I take it the first 12-to-15 weeks were 12 at Met Ed?
~
13 A That was at Met Ed.
14 Q At the Island?
15 A correct.
16 Q Prior to entering the CRO program, had you 17 ever been trained in Lynchburg before?
~
18 A No.
19 Do you want to finish up on training there?
20 Q Sure; I'm sorry.
l l
21 A When we came back from Lynchburg, then we 1 22 went back into a classroom training for -- I forget 23 how long it was. Then we went on shift, which we 24 received on-the-job training and we were responsible 25 for~1 earning the systems.
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\/ 2 We also at the time had the expertise of 3
Pe0P l e who were working for Burns & Roe in the startup 4 Program;as they tested different systems, we could
( 5 learn from them. And in that period of time also, we 6 were taken out of class or taken off shift and into a 7 classroom situation, once every five or six weeks. I 8 think it was every six weeks then. One week out of 9 every six weeks.
10 Q Again, that one week out of every six
(
11 weeks that you just described was training done by 12 Mat Ed, correct?
(_, 13 A We did receive some trainiig from outside 14 organizations. I remember one week Westinghouse came 15 up and went over their turbine generating system. I 16 can't recall any other outside organizations.
17 Q In the course of your career, this training 18 that you just described in the CRO program, were you 19 also taught s,omething about thermodynamics. fluid flow 20 and heat transfer?
21 A I believe that was part of our training, 22 but I can't remember any specific time period or --
23 Q Do you remember any of the people that
(~N 24 taught that?
h 25 A No.
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2 Q You do recall learning something about 3 that, however, earlier when you were an auxiliary l
4 operator,1 correct, from George Millis? i A Yes, some basic formulas and things like
( 5 6 that.
7 Q Did there come a time when you received 8 a CRO license?
9 A Yes.
10 Q When was that?
t 11 A That was around the summer of 1976.
12 Q Did you take any exams to get that license?
O s_/ .13 A Lots of them.
14 Q Some of them were NRC exams? ,'
15 A Yes.
16 Q Do you have any other licenses today?
17 A Yes.
18 Q What license? -
19 A SRO. -
When did you get' your SRO?
20 Q
, 21 A That was 1980.
L Do you recall when you took the SRO exam?
22 Q 23 h Early 1980.
("] 24 g Did you receive any books or handouts in
\_./
25 the course of your training at Metropolitan Edison?
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1 Illjes 17 O
P 2 A Yes.
3 Q Do you still have those today?
4 A I have them, but they are not in my
( 5 possession.
G Q After the Three Mile Island accident, 7 were you ever asked to search for whatever materials, 8 documents, handouts you might have by lawyers?
9 A Yes.
10 Q When were you asked to do that search?
11 A At the beginning of -- there was a suit 12 filed by Met Ed against B&W and we were asked to 13 gather all our material and make an inventory of it 14 and hand this inventory in to the proper people. I 15 forget who it went to. I think it was John Wilson or 16 somebody like that.
17 Q so it was in connection with this litigation 18 that you did that search? '
19 A correct. -
20 Q Whsn did you turn over this material? Was 21 it back around the time when you were asked to turn it
(
22 over?
t 23 -A No, it was never called for by them.
(~N 24 Q Explain when you turned it over.
V 25 A I turned it over after I received their y -
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1 Illjes 18 request to come up here for this here -- what do you 2
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3 want to call,it?
4 Q Deposition.
( 5 A --
deposition.
6 Q Had you prepared an inventory of what you 7 had back in 19797 8 A Yes, but it was real brief, and I don't 9 remember what is in it.
10 Q Do you know whether you turned over 11 everything that you had listed on the inventory to the 12 lawyers who asked you to turn over documents in -
s/ 13 connection with this deposition?
14 A I don't know that. .'
15 MS. MCDONALD: Off the record.
16 (Discussion off the record.)
17 BY MS. MCDONALD:
18 Q Mr. Illjes, I would like to hdve you take 19 a look at these three boxes full of documehts and 20 notebooks and ask you if you can identify these, not 21 each and.every one, but the three boxes full of 22 documents. Take a look at them, if you want to.
23 A Yes, they are my training information i - 24 prior to the accident, to the best of my knowledge.
25 g Did you turn these over to your lawyers in
1 Illjes 19 O 2 connection with this deposition?
3 A Yes. ~
4 Q Those are documents which you maintained in the course of your employment at Metropolitan
([ 5
'6 Edison in connection with your training, is that 7 correct?
8 A You say " maintained." I had them stored.
9 Q You received them in the course of your 10 training at Metropolitan Edison, is tha right?
11 A Yes. l l
12 Q Did ou use them in the course of your 13 training?
14 A Yes, some of them. l 15 Q Prior to being involved in the nuclear 16 business, did you ever hear that water un' der l 17 atmospheric pressure boils at 212 degrees Fahrenheit?
18 A Yes. -
19 Q Did you hear about that in high scho,o1 or 20 even before?
21 A I can safely say that I heard that before.
22 Q Did you learn in your training or anywhere 23 else that water in the primary system'of a pressurized 24 water reactor is often kept at temperatures
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25 substantially in excess of 212 degrees Fahrenheit?
i
1 Illjes 20
(~h U. 2 A Yes.
3 Q ,
Now, either in the Navy or in your training 4 at Met Ed, were you told why it was that the water in the primary system which was substantially over,at
( 5 6 times, 212 degrees did not boil?
7 A The water was kept at a pressure to prevent 8 boiling.
9 Q Where did you learn that, in the Navy?
10 A I don't recall where I learned that.
t 11 Q How in a pressurized water reactor,were 12 you told in your training, was that pressure applied?
) 13 A How I was told, I don't remember, but I 14 remember the pressure was applied by a pr'essurizer.
, 15 Q The reason I am asking you were you told 16 is because I want your knowledge. I don't want any 17 kncwledge you gained after the Three Mile Island 18 accident, O.K.? Just to explain to you when I ask you 19 questions I want your knowledge before the Three Mile 20 Island accident. Do'you understand?
21 A That is difficult.
22 Q Is there any doubt that you knew before 23 the accident that water didn't boil because it was
('] 24 kept under pressure in the primary system of the PWR7
'J 25 A The pressurizer kept the reactor coolant r
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1 .
Illjes .21 l
O~ 2 system under pressure to prevent boiling.
3 Q Undar normal.eperation of'a pressurized 4 water reactor, it is desirable, is it not, that the
( 5 water remain in a liquid state?
6 A Except.--
7 Q Except for nucleati'ooilinc? - '
t 8 A In the presnurizer, yes.
9 Q In your training were you made aware that 10 it was necessary to keep a s te am' bubble. at the top of 11 the pressuriner in order for the pressurizer to perform 12 its function of preventing boiling in the primary .
[~~\ .-
\d 13 system?
s 14 A~ By keeping'a steam bubble in the pressurizer 15 and the level.in the pressurizer, we prevented boiling 4.
16 in the RCS. '
17 Q Just so I undarstand what you,are saying, 18 was it, based on your understanding beforc'the.a'ccident,- ,
19 was.it possible for the' pressurizer to con' trol pressure 20 in a primary plant of a PWR,if,there was no bubbl6 at
~~
21 the top of a pressurizer?
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22 A It wasIimpossible, or anything is possible,
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23 but I don't remember controlling the pressurizer
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24 controlling the RCS pressure while the pressurizer --
25 you said full o^f water, right?'
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(_ 2 Q Yes.
3 A O.K., we never operated that way.
4 Q If there was a bubble at the top of the pressurizer, based on your understanding at the time of
( 5 6 the accident, would the pressure in the pressurizer be 7 the same as the pressure in the rest of the,RCS?
8 A Approximately.
9 Q In the course of your training, did you 10 ever hear the term " saturation"?
11 A I can't remember anyplace in the course of 12 my training that I heard of saturation, but I remember 13 we probably went over it and I don't remember at what 14 instance.
15 Q What was your understanding before the
> 16 accident what is meant by saturation?
17 A I don't recall what my understanding was.
18 Q Has your understanding changed since the 19 accident as to the definition of saturation?
20 A Well, I have a much more awareness of it.
21 Q I just asked has your definition of what
'22 it means changed?
23 A I never thought of the definition. I don't
() 24 think of it as a definition. Ask it another way.
25 Q What does saturation mean, Mr. Illjes?
1 Illjes 23 7-
~# 2 A It is the point,the pressure, at which a 3 liquid will boil.
4 Q Have you ever testified under oath before?
( 5 A Yes.
6 Q Where?
7 A Harrisburg, Pennsylvania.
8 Q ~ Was that in connection with a deposition 9 taken by some people from the NRC?
10 A I am not sure if I was under oath then.
11 Q I will come back to that.
s 12 Can.we pin down -- what were you testify'ing
~
s 13 about in Harrisburg, Pennsylvania when you were under-14 cath?
15 A I don't believe I am supposed to say. What 16 is that?
17 (Witness confers with counsel.)
18 (Question read) i 19 MS. MCDONALD: Strike that question.
20 BY MS. MCDONALD:
21 Q Mr. Illjes, have you ever testified before 22 a grand jury?
23 A Yes.
/~N 24 Q Was that the testimony to which you were N_]
25 referring that took place in Harrisburg, Pennsylvania
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"1 Illjes 24 b
o 2 under oath?
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3 A Yes.
~
4 Q Was that testimony in connection with the
( 5 Three Mile Island accident?
6 A Yes.
7 Q Prior to testifying there, were you asked 8 to turn over any documents?
l 9 MR. MacDONALD: Just a second. Prior to 10 testifying where? t 11 MS. MCDONALD: At the grand jury; whatever 12 this grand jury was that was in connection with O
N- 13 the TMI accident.
14 MR. MacDONALD: I think we are just going i_ 15 to, at this point.in time, cover only the ,
i 16 question that you are entitled to, khat he has 17 testified before a grand jury under; oath, and 18 that is as far as we are going to gd with this -
19 line of questioning.
20 You don't have to answer this question.
21 MS. MCDONALD: I don't necessarily agree 22 with that, but I will drop the subject now.
23 BY MS. MCDONALD:
l 24 Q Have you ever testified under oath other f~)d u
25 than that time that you recall?
1 Illjes 25
(% -
2 A Oh, I think in my younger days, I testified 3 for somebody in a slugging contest, but other than 4 that --
I don't think we have to inquire into
{ ~5 Q 6 that.
7 Have you had any interviews with anyone 8 about the Three Mile Island accident, not necessarily 9 under oath?
10 A Yes. (
11 Q Who?-
The NRC.
12 A 13 Q Do you happen to remember the dates?
14 A No.
15 Q How many such interviews did you have with 16 the NRC?
17 A There were two.
18 Q Was there a court reporter at'either one of 19 them, somebody taking down what you were saying?
20 A Not that I recall.
21 Q Was there tape? Were you being recorded 22 on a tape?
23 A I believe so, yes.
24 Q At both of those NRC interviews?
[~}.-
ks 25 A I'm not sure if there was one at one of
1 Illjes 26
}
\~/- 2 them, but I think it was ti.e-second one there was a 3 tape. I was led to the understanding that they were 4 taping.
5 Q Have you ever seen transcripts of those
({
6 interviews or listened to a tape of either one of 7 these interviews?
8 A I was given a transcript. But I never 9 read it from cover to cover.
10 Q You were given a transcript of one of 11 them or both of them?
12 A I don't remember a transcript from one, but 13 the second one I was given a transcripi.
14 Q Can you tell me the second one that you 15 say that you got a transcript of, what was the topic 16 that you were being interviewed about?
17 A That was information pertaining to the
~
18 accident at TMI.
19 Q Hav e fou retained the transcript that you 20 were given? Do you still have it?
21 A I have it.
22 Q Did ycu take notes at either one of these 23 interviews?
("% 24 A Not that I recall.
25 Q Do you recall whether any of the interviewers
__ _.. _ _ .~.___ __ __. _ . . - _ . _ _ _ . _ _ _ , _
l 1 Illjes 27 i'
2 took notes?
3 A I don't recall.
4 Q Referring to the interview for which you 5
(' 5 say you still have a transcript, were you represented 6 by counsel at that interview?
7 A No.
8 Q Were you represented by counsel at the 9 other interview?
10 A No, we had a -- no. t 11 Q Have you ever had an interview with the 12 NRC at which Mr. McBride was present? .
[~)
(_/ 13 A Yes.
14 Q Who is Mr. McBride?
i 15 A He is a lawyer that represents the firm that 16 is associated with Ms. Penny Jane Penny 17 g was he there representing you?
~
18 A yes.
19 Q Was this a third interview? I'am trying
, 20 to straighten out --
21 A I am trying to get in my mind that there's 22 two interviews, and then there was --
I don't know if 23 you call it a -- there was a trip down to the facility l
["T 24 that the NRC had down at the Island, and we had
- \-)
i 25 discussion there, and I don't recall exactly what l !
i
1 Illjes 28
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D 2 transpired, so that was not an interview.
3 Q Have you ever been interviewed by anyone 4 from the Essex Corporation, by a person named David
( 5 Eike, along with Mr. Kidwell?
6 A The Essex Corporation rings a bell, but 7 you will have to refresh my memory.
8 Q Were you ever interviewed by anyone at 9 GPU or Met Ed in the aftermath of the Three Mile 4
10 Island accident? t 11 A I don't recall.
12 Q Have you ever heard of something called i
O ,
13 the Keaten Task Force cr the Broughton Task Force that 14 was doing some investigations about the accident?
15 A That rings a bell. I remember a telephone 16 conversation. I am not sure if it was -- that's all I 17 remember, a telephone conversation with somebody. They 18 set up an interview on a telephone converdation and 10 that was for -- this associated with Senat'or -- who 20 was the senator that did the investigation for --
l 21 that started the investigation? l 22 Q Are you referring to Senator Hart?
23 A No, it was the Hart Commission or something 24 like that?
25 Q The Hart Committee?
. _ . _ _ _ , . _ . . . _ . -_ ~ - _. _. __ ___ ,
1 Illjes 29
[ l
(/ '
2 A Yes, it had something to do with it. I 3 don't recall what the conversation was.
4 Q Was the conversation with somebody from C 5 Hart's group or was it with so'mebody from GPU or Met 6 Ed or both?
7 A I know I had -- I don't recall. I don't 8 recall who was there.
9 Q Do you recall when this phone conversation 10 was approximately? t W
11 A After the accident. It was a good while 12 after the accident. It was probably a year or so.
' 13 Q Did you take notes of this conversation?
14 A No. '
, 15 Q Do you know if anybody else did?
16 A I believe it was recorded, because there 17 was a thing on the telephone, but I don't. remember 18 what it was about.
19 Q Was it recorded as far as you knew by 20 tape? -
21 A Well, it had a --
there was a beep on the 22 telephone and they told me that they were going to 23 record it.
O) t 24 Q Was anyone else in the room with you at 25 your end of the phone?
1 1
1 1 Illjes 30 (h
U' 2 A Yes, but I don't remember who.
3 Q Did you ever receive a copy of the tape 4 or a transcript?
No, not that I recall.
( 5 A 6 Q Have you reviewed any of the transcripts 7 of any of the depositions taken in this case?
8 A 7n this case?
9 Q In this cases other people's transcripts.
10 A No. t 11 Q Have you reviewed any of the tapes or 12 transcripts of statements of anyone other than (N -
(- 13 yourself taken by the NRC or anyone in connection with 14 the Three Mile Island accident?
15 A I haven't seen any transcripts of other n-16 people's transcripts, no.
17 Q Have you had any converstaions with anyone 18 at GPU or Met Ed about their statements or' testimony 19 in connection with the Three Mile Island accident?
20 A No, it's a general consensus that
. 21 information that each of us give is private information 22 and that you would be infringing on somebody else if 23 that information was passed on, so we are pretty good 24 about not talking to each other about that sort of 25 thing.
1 Illjes 31 A
> 4
'% ) 2 Did you have any conversations with Q
3 anyone before coming here today, just about the fact 4 that you were going to be deposed? .
( 5 MR. MacDONALD: Are you talking now aside 4
6 from counsel?
7 MS. MCDONALD: Yes.
s 8 MR. MacDONALD: Whatever you discussed 9 with counsel is privileged communication.
10 MS. MCDONALD: Don't tell me anything you 4 11 discussed with counsel.
12 A I had to make arrangements, so I had to N/ 13 take care of that. They knew where I was going.
14 Q You didn't have any discussions with 15 anyone about what you would say today?
16 A No, they didn't ask me.
17 Q In the course of your duties at Met Ed, 18 were you ever required to fill out any kin'd of logs?
1
~
19 A Yes.
20 Q What logs?
,. 21 A Well, every watt station, or do you want 22 to call it a watt station, or there's different areas 23 of responsibility that have logs to fill out.
l i
() 24 Q Did you fill out logs while you were an t 25 auxiliary operator?
l l
i
,----g- ,-9, - -
e we e ve.,--- - - - - , --m--wwarw ww - - v-er*
1 Illjes 32 0 2 A Yes.
3 Q Is there something called the auxiliary 4 operators' log?
A There are several, depending on where your
( 5 6 responsibility is that night.or day.
7 Q Is there something called a control room 8 operators' log?
9 A Yes.
10 Q While you were a CRO, as fa as you knew, 11 was it the ordinary course of business for Met Ed to 12 prepare and maintain control room operators' logs?
- 13 A That was one of our re sp on s'ibili tie s that 14 we tried to maintain that log. ,'
15 Q While you were a CRO, you filled out logs 16 in the ordinary course of your business?
17 A Yes.
18 Q CRO logs?
19 ,
A Yes, CRO logs. -
1 20 Q Was there a procedure for how to fill out )
21 the CRO log prior to the accident?
22 A I believe there was.
23 g Were you familiar with that procedure?
24 A I would assume I am.
25 _g Were you required to review the log entries
_ _ _ _ _ _ _ -. _ _ _ _ _ . _ _ _ _ _ _ . . _ . . - , _ ._. _,_ _ _ _ - , _ . _ _ _ . . _ _ _ _ _ . ~ _ _ _ _ _
1 Illjes 33
>O k/ 2 since your last entry when you came on shift again?
l 1
3 Do you understand the question? 1 4 A Yes, I understand. We reviewed the logs.
( 5 The person who was signing into the CRO log, he reviewed 6 the logs prior to signing on the shift.
7 Q How far back did he review the log?
8 A It would be until the last time he had the 9 shift.
10 Q You did that too, is that c rrect?
11 A Yes.
12 Q Were you supposed to record any unusual
[~)'i
(, 13 events that occurred in the plant in th'e log?
14 A Yes.
15 Q Were you required, prior to assuming the
~
16 shift, to make yourself aware of the plant parameters 17 and the events that had taken place on shifts other 18 than your own'to acquaint yourself with the status of 19 the plant? -
20 A If the'information was available.
, 21 Q Did you personally make it a practice to 22 consult with the people that you were relieving and 23 discuss with them what was going on in the plant before 24 you took over the shift?
(~}/
25 A We had a period of approximately 15 minutes
1 Illjes 34 n '2 in which information was given, questions asked.
3 Q Was it your practice to accurately record 4 what went on during a shift when you made out the log,
( 5 to the best of your ability?
6 A To the best of my ability, I would say 7 though there were times when things were missed.
8 Q Did you ever record something that you 9 knew to be false?
l 10 A Not to my knowledge. t 11 Q Do you know whether anyone else recorded
{
12 anything he or she knew to be false?
O- 13 MR. MacDONALD: Do you mean has he ever heard j
14 of that happening?
15 MS. MCDONALD: Yes.
16 Q Have you ever heard that that happened?
17 A No. .,
~
18 Q Do you know of your own personal knowledge 19 that that ever happened?
- 20 A No.
21 Q Have you ever heard of people at Met Ed L.
22 called shift test engineers?
23 A Yes.
24 Q Who were the shift test engineers?
25 MR. MacDONALD: Who were they in job
l i
i 1 Illjes. 35
%' 2 i responsibility or personnel?
3 Q What did they do?
4 A Well, they were in charge of the startup
( 5 and testing program.
6 Q Did you know that they also maintained a 7 . log?
8 A They had a room which they kept their 9 information and records in. Whether they had a log --
10 I think every so often you would see on,e with a book, 11 but I wasn't aware of a log.
12 Q You didn't review it?
() 13 A No.
14 Q During the startup phase of the plant, on 15 occasion the shift test engineers would also be in the 4
16 control room, is that correct?
17 A Yes.
18 Q We talked before about when you were
~
19 relieving the shift, you would have a brief conversation-20 with the people who had been on the shift before you.
21 Did that sometimes include the shift test 22 engineers, that conversation?
23 A Sometimes, it would.
T 24 Q Are you familiar with something called an
-a l 25 unusual occurrence report? Have you heard of that kind
i l
1 Illjes 36 O 2 of a document?
3 A Unusual event report.
4 Q What was your understanding that that was
( 5 used for?
6 A something that transpired that was not in 7 the normal operating agenda of the plant.
8 Q Did you ever fill out an unusual event 9 report?
10 A Not prior to the accident. g 11 (Recess) 12 BY MS.' MCDONALD:
O 13 Q Mr. Illjes, were you aware before the Three 14 Mile Island accident that there were limits with respect 15 to the maximum acceptable unidentified leak rate that 16 vas allowed in the plant?
17 A Yes.
18 Q Were you aware that there was'a technical 19 specification called reactor coolant system operational 20 leakage which discussed that topic, namely unidentified 21 and identified leakage?
22 A Yes.
23 Q Let me show you what has been previously 24 marked as B&W Exhibit 251 and ask you if you recognize
(
25 that document.
1 Illjes 37 k '
2 A This is our tech specs, technical 3 specifications.
4 Q You were familiar with this document before
.( 5 the accident?
6 A Yes.
7 Q Were you aware that Exhibit 251 required 8 that with any reactor coolant system leakage greater 9 than one gallon per minute unidentified leakage, that 10 that leakage must be reduced to within+the proper 11 limits within four hours or the plant had to be in 12 at least hot standby in the next six hours and in cold
(~
\~)h 13 shutdown in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />? I am referring in 14 my question to Section 3.1.6.2. Do you see that 15 section,?
16 A Yes.
17 Q Were you aware of that requirement before 18 the Three Mile Island accident?
19 A Yes.
4 20 Q Referring to Section 4.4.6.2D of that 21 tech spec, which reads, " Performance of a reactor 22 coolant system water inventory balance at least once l
l 23 per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during steady state operations," were you f~)
%J 24 aware of that requirement before the accident?
l
! 25 A Yes.
-- . , ,,--v -- , , . ,- r .-,--,-,v,,, , , - . r -- -
p
l l' l 1 38 Illjes A'
U. 2 I am showing you now what was previously Q
3 marked as B&W Exhibit 252 and ask you if you can 4
4 ' identify that document.
( 5 A That is labeled as " Surveillance Procedure 6 2301-3D1RCS Inventory."
7 Is it correct that the purpose of that Q
0 surveillance procedure, Exhibit 252, was to meet the 9 requirements of tech spec section 3.4.4.6 and section 10 3.4.6.2 and section 4.4.6.27 (
11 The sections that are in MR. MacDONALD:
2 251? '
4 U[~h 13 MS. MCDONALD: Right.
14 Do you understand the questio ?
Q 15 Are you askiag him whether MR. MacDONALD:
16 this procedure related to the tech pec 17 requirements? .
18 Q I just want to know, was B&W 252 the 19 surveillance procedure that showed you how to comply 20 with the tech spec that is B&W 251?
21 A Yes,.we used this procedure to comply with this.
23 Before the Three Mile Island accident, did Q
4 I 3'
-( j 24 you ever make use of B&W 252, the surveillance 25 procedure?
s ,,.,v w - - - , -- '- - , - - - ' --
-v --v--
I l
l 1
Illjes 39
~
2 A Yes, we followed this procedure.
3 Q Before the accident, did you ever personally 4 perform a leak rate test?
( 5 A Yes.
6 Q Do you recall using this particular 7 procedure or one of its prior revisions?
8 A I believe we used a procedure similar to 9 this, yes, or one of its prior revisions. I don't 10 remember specifically actually taking the procedure out 11 of the drawer and following the procedure step by step, 12 but this procedure relates to the leak rate ,
{s'-
13 specification.
14 Q I take it before the a c c i d e n t ,' you were 15 familiar with how to do a leak rate test?
9 16 A correct.
17 Q Did you do leak rate tests numerous times 18 before the accident?
19 A Yes.
20 Q Have you ever supervised the performance
(
, 21 of a leak rate test done by others before the accident?
22 A No.
23 Q can you try to explain in terms as simple
/~T 24 as possible how this procedure allows you to calculate
_(_/
25 leakage in the plant?
1 Illjes 40 O
V 2 A We actually don't do the calculation. We 3 use a computer to do the calculation, and if your 4 computer is programmed to do the calculation,by ;
( 5 pressing a letter or two on the computer, automatically 6 it calculates the leak rate for you.
7 Q Is it correct that;the procedure, B&W 252 8 and its attached data sheets, in essence define 9 inventory lost from the makeup tank as total leakage?
- 10 MR. MacDONALD
- Are you ask ng him now for 11 his recollection?
- 12 .. MS. MCDONALD
- Yes.
^
- . 13 A Part of the leak rate had to do with level 14 in the makeup. tank. ,'
i 15 Q To obtain the unidentified leakage in the 16 plant, did the process require that invenbory in the 17 reactor coolant drain tank be subtracted from inventory 18 lost from the makeup tank?
19 A I don't recall the calculation', how we
. 20 manually calculated.
21 Q Was the leak rate test, however, affected 22 by how much water the computer thought was in the makeup 23 tank?
24 MR. MacDONALD: Can I have that again?
E 25 (Question read)
-m r -
,--,s s= w -tw ---=-w-=w-++*-+tr&--**wn te - w++=-w-ww-e-t~-w -*---T v-e-w'T- --m +-w-r9-~m----M-wt-*e- ~-----tr'w're *-
1 Illjes 41 s
\
2 A Yes.
3 Q Is it correct that the results of the leak 4 rate test would be affected by both temperature and
( 5 Pressure in the makeup tank?
6 MR. MacDONALD: Are you asking him now 7 whether the computer took that into account and 8 computed those calculations prior to the 9 accident?
10 MS. MCDONALD: I will accept that.
11 A I don't recall taking that into account.
12 Q You don't recall that both the figures l
- 13 for the makeup tank and the figures for the reactor 14 coolant drain tank had to be adjusted so that they 15 were measured in equivalent reactor coolant gallons?
16 In other words, taking account of the tem erature and 17 pressure of the water in those tanks in order to obtain
~
18 a correct leak rate? -
19 A I remember the computer taking'into account 20 the level in the make.up tank. Other data that the
. 21 computer took, as far as you are saying pressure and 22 temperature, I don't remember the computer taking that 23 into account.
/~ 24 g Did you ever perform any leak rate test in !
k_)h !
25 which you did not use a computer? In other words, did
- r -, , - , , ,- - -- - n< e= , - - - -,..-,--~e,- w, - , , ,
L 1 Illjes 42 l
' (O
~#' 2 you ever do it b.y hand?
l l 3 A I believe I have done it maybe once or i
4 twice, but I don't recall specifically.
] 5 Q Referring to Exhibit 252, do you see at 6 the end of that procedure, the last two or three pages, 7 there are some tables of numbers? Do you see what I 8 am referring to? It is pages 30, 31, 32, that 9 procedure.
10 A Yes. ,
11 Q can you tell me what those tables are?
12 A I can barely read them.
/~}
(/ 13 Q Are they steam tables, Mr.'I11jes?
14 A It is listed as " Saturation Pressure" on 15 page 31, and there is pressure --
those could be steam 16 tables, yes.
17 Q Are they steam tables?
18 A Yes, those are steam tables or parts of it.
19 Q Do you know why those steam tables were 20 attached to this procedure?
. 21 A I believe it had to do with calculation of km I 22 a leak rate.
23 Q Does seeing these steam tables at the back
- 24. of this procedure refresh your recollection in any way 25 regarding whether temperature and pressure of the
- , , , m , -- ,n-- w n
1 Illjes 43 t')
J 2 water in the makeup tank or the reactor coolant drain 3 tank had to be taken into account in calculating a 4 leak rate?
I '
5 A No.
6 Q Are you aware of any time when a leak rate 7 calculation was made which produced a leak rate for 8 either identified or unidentified leaks which was in 9 excess of the tech spec limit?
10 A Yes. t 11 Q Did you obtain any of those results yourself 12 in your own performance of a leak rate test?
[(/')
13 A Yes.
14 Q Did you also observe other leak rate tests 15 performed by others that were outside the tech spec 16 limit, observe in the sense of see the results?
17 A Yes, usually this was attributed to an 18 oscillation in the plant and then another' leak rate was 19 calculated or the computer was set up to chlculate 20 another leak rate, and we then got a leak rate that 21 was within the leak rate specification within the time 22 period.
23 Q What time period was that?
t l
() 24 A Reduced the leak rate within the four-hour 25 period; it is in the four-hour period. I don't remember l l
. _ _ . _ _ . _ . - - - _ _ _ _ _ _ ~ . . _ , _ . _ . _ _.- .
l l
l 1 Illjes 44 i
(' '
I' 2 the time period without'looking at the document.
l 3 .Q Is it your recollection that in every case 4 that you recall with a leak rate calculation that resulted in a leak rate outside the tech spec limit, l 5 6 in every case a leak rate within the tech spec limit 7 was then obtained within the four hours at TMI?
8 A The leak rate was ever required --
9 required every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and as long as we had a good 10 leak rate within the 72-hour period, we satisfied the 11 requirements of the tech spec.
12 Q Mr. Illjes, going back to Exhibit 251, on
(_/ 13 the first page, do you see the " action" ~ statement 14 there, section B?
15 A Yes.
16 Q Doesn't that say that you must reduce the 17 leakage rate to within limits within four hours or 18 at least be in hot standby within the next' eight hours 19 and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />?
20 MR. MacDONALD: Answer to your recollection.
21 Q That is what it says is that right, just 22 reading the document.
23 MR. MacDONALD: Everybody can read the 24 document.
25 A That is what the document says, yes.
I 1 Illjes 45
( ~s Y/ 2 Q So let me ask you a different question 1
3 then. ,
4 Every time that you recall getting or
( 5 observing a leak rate which was in excess of the tech 6 spec limits, was it your understanding or do you recall 7 that the plant went into hot standby within four hours?
8 A No, that was not a requirement; insofar as 9 I can recall,the requirement was that we had a 10 performance surveillance every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />;, and as long 11 as we were able to get a leak rate within that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 12 then we met, satisfied, the requirement of the tech p
~
\ 13 spec.
14 Q Well, what was your understanding of the
, 15 meaning of this section B in the action statement?
16 A Well, at the end of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, you weren't 17 able to get a leak rate within those four hours, then 18 we went into that action statement. You e'ntered the 19 action statement. ~
20 Q Do you recall any occasion when the
, 21 operators were unable to obtain an acceptable leak l 22 rate within the 72-hour period?
23 A The computer calculated the leak rate and 24 there were many things in the plant which could change 25 a small amount, which would have an effect on the leak l
T 1 Illjes 46 2 rate. A valve or a controller could cycle, and it 3 could. change.the calculation of the l'eak rate and, 4 therefore, you would have a leak rate either high or l 5 lower. Sometimes, se even went into negative leak 6 rates, and so when we -- we made it a practice of 7 once a shift taking a leak rate whether or not it 8 was satisfied within -- you always took a leak-rate t
9 once a shift, and within that period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> we 10 managed or we got satisfactory leak rate which 11 satisfied the requirement of the tech spec within a j 12 72-hour surveillance period.
4 k 13 Q So it was your practice when you were on 14 shift or your understanding anyway was that each 15 shift took a leak rate until an acceptable one was 16 obtained, is that correct?
17 MR. MacDONALD: Or until the leakage was
~
18 identified.
19 A Right.
20 MS. McDO,NALD: Thank you, Counsel.
i 21 Q That's right?
22 A That's correct, or until the leakage was 23 identified.
What do you recall doing with the data
) 24 Q 25 sheets upon which were recorded the unacceeptable leak
l' Illjes 47 2 rates that you said you personally obtained?
3 A I.f we weren't required a leak rate-and it 4 was not a leak rate within the limit of the tech spec, C. 5 then we didn't keep it.
6 Q You threw it out?
7 A I take it that is where it ended up, yes.
8 Q Did you ever throw one out?
9 A Yes.
10 Q Did you ever discuss with apyone at Three 11 Mile Island the practice of throwing out leak rates i
12 -which came out unacceptable?
O 13 A well, you consider them unacceptable.
~
It's 14 difficult for a plant to get in a situation where you 15 can get a good leak rate. That was our idea, the way ,
I 16 we were made to understand it, so if thehlantwas l
(
l 17 slightly unstable or can cause some sort of 18 perturbation in the control system we just~ -- and - the 19 papar work came back with, say, a higher than.one 20 GPM leak rate and it was unidentified, then we didn't 21 keep it. We weren't required to keep it.
22 Q Did you record anywhere the fact that a 23 leak rate test had been done'if the results were above 24 the tech spec limit?
(
25 A It was recorded on the computer printout.
_s. u _ - - _ _ _ - _ _ _ _ _ - - -- ----J
1 Illjes 48
'# 2 Q Were those computer printouts retained?
3 A some of them were. The good ones were 4 retained.
l 5 Q And the bad ones you would throw out?
6 A Maybe not right away. They were looked at 7 by other people before they were thrown out.
8 Q Were you aware of any requirement to record 9 in the control room log the fact that a leak rate test 10 had been performed regardless of how it came out?
11 A I recall some method of record retention.
12 I don't know if it was in the log or not. We had a 13 procedure or something that it would be passed on 14 whether or not we were within the 72-hour I requirement 15 of our surveillance to get a good leak rate. It was e-16 passed on from one shift to the next. I don't know 17 where it was written down,in the control room operator 18 log or a turnover sheet or --
19 Q I am not sure I understand you'r answer.
20 Do I take it that there was some pe.rmanent 21 record made of every leak rate test that was attempted 22 whether or not it came out under the tech spec?
23 A No, I don't know of any permanent record !
l i
24 that was kept of every time we pushed it or requested L
25 a leak rate from the computer.
l
'1 1 1 Illjes 497
-,9 tS 2 Q If I acked you to go and look ,for thats s
3 today, where would you look?
, s' ,
_ 4 MR. MacDONALD: Look for what?
-( 5 ' MS . MCDONALD: He said he didn't know 6 whether there was any permanent record, so I am r
7 just wondering what the possibilities are.
8 A You said if there were any records kept.
9 You didn't say did we keep all records.
10 ,
Q I see, t
, 11 I take it that if the leak rate test did 12 not.come out properly, the turnover sheet would also
('s ,
13 be thrown out', is that correct?
14 MR. MacDONALD: I am going to-object to~
15 the tern " proper."
16 MS. MCDONALD: Under the tech spec.
17 A. I am not aware.of keeping. turnover sheets 3 ,
~
18 l that we used back then or not.
i 19 Q You said b'efoke that getting lea,k rates 20 over the requirements of the tech specs was often
/
, 21 attributed to oscillation in the plant. -
- + q 22 2 What did you mean by that?
23 A The computer has inputs from different
[) 24~ sensing mechanisms of equipment in the plant, and for l
~- .
r' 25 various reasons they are due to a component making a- _;
. l
- - .6
~~
- s. -
m 1 Illjes
, 50 2 correction for a setpoints in other words, a particular 1
3 temperature that something is supposed to operate at 4 that component turns on and changes the temperature in
( 5 the period of the leak rate calculation that is 6 transpiring, O.K.? Now, when that component changes,it i
7 also will change the input going into the computer, so 8 it is difficult for the computer to see everything in 9 a stable condition when something like that happens, 10 and that is why it is difficult to get a good leak 11 rates one of the reasons.
12 Q Was Met Ed management aware of the practi,ce 1 1
(_) 13 of repeatedly taking leak rate tests until one of them 14 came out under the tech spec limit? '
15 A Yes.
16 Q Did you ever discuss tifis practice with Mr.
17 Floyd?
- 18 A Not to my recollection.
19 Mr. Seelinger?
Q 20 A Not to my recollection.
21 Q Mr. Miller?
22 A Not to my recollection.
23 Q Any shift supervisors?
\ 24 A There was a shift supervisor on shift at (V .
25 the time taking those leak rates.
l
1 I11jes 5.1 0 2 Q Do you remember his name?
3 A I believe it was Joseph Chwastyk.
4 Q Did anyone tell you that it was appropriate
( 5 or acceptable pursuant to this procedure, Bsw 252, to 6 repeatedly take leak rate tests until the rate came 7 within the tech spec limit?
8 A Did anybody from --
9 Q Did anyone at Met Ed tell you that it was an 10 acceptable interpretation of these procedures to 11 repeated 1y take leak rate tests until the rate came 12 withdn the tech spec?
O 13 MR. MacDONALD:
Within the 72' hours?
14 MS. MCDONALD: Yes. '
15 MR. MacDONALD: Regardless of whatever else 16 may have been done to correct leakage?
17 MS. MCDONALD: Right. .,
18 A Well, the shift foreman was id charge of 19 the plant and he was cognizant of what was' going on, 20 so he usually got the leak rates signed and laid on his 21 desk.
?"
Q What shift foreman are you referring to?
23 A I don't remember who was my shift foreman.
() 24 Let's see, we went through a few.
25 g The way you answered that, I thought you
^
1 Illjes 52
~
(~T l' 2 were referring to one in particular. I'm sorry if I 3 misunderstood you.
4 A No.
l 5 Q can you recall who your shift foreman was, l 6 say, in 1978, '797 7 A I can recall Bill Conaway, and another prior
! 8 shift foreman was Dave Newman, but I don't believe he 9 was there when we were operating. There might be 10 another one in there, but I don't recalJ because I 11 switched shifts too somewhere in there.
12 +
Q Are you aware of any instance in which leak O. 13 rate results were recorded incorrectly?
14 A The results were recorded by the computer, 15 so I don't recall recording or no results recorded 16 incorrectly to my knowledge.
17 g When leak rates within the tech spec limits ,
- 18 were obtained, were they not recorded in s'o m e log 19 other than the computer? '
20 A It might have been recorded in the CRO log 21 that we satisfied the intended technical surveillance 22 requirement.
23 Q Do you ever recall either observing or 24 hearing that anyone had added. water to the makeup tank 25 in order to affect the leak rate calculation?
1 Illjes 53 2 MR.. MacDONALD: Are you talking about 3 intentionally affecting leak rate calculations?
4 MS. MCDONALD: Yes.
~( 5 A No, not intentionally.
6 Q Did you ever hear, observe that someone 7 added water to the makeup tank in order to affect the 8 leak rate not intentionally?
9 MR. MacDONALD: By mistake, you mean?
10 MS. MCDONALD: I don't know<. You threw in 11 " intentionally."
12 MR. MacDONALD: I'didn't know what the C. 13 question was geared at.
14 MS. MCDONALD: He said not intentionally, 15 so I am picking up on his answer. I want to 16 know what he does know about it.
17 A It is possible the control room operator-
~
18 that was signed into the book was in charge of the 19 panel area and the one or other two CRO's would be
. 20 taking care of paper work such as he could calculate
)
21 the leak rate or the normal practice of the same --
22 there is a leak rate which is a period of approximately 23 of an hour to however long you want to make the leak
( 24 rate calculation; in other words, you can make it 1
25 longer than an hour. I believe it was normally an- l
1 Illjes 54 O.
(_f ,
- hour or two, or something like that. It's possible that 3 it would depend on the makeup tank for control function 4 of our control rods by diluting waterrif the control
( 5 rods reach the upper limit, the control room operator 6 would have to add water into the makeup tank, to cause 7 the control rods to drive back in, and he could have 8 been into this evolution while the leak rate was ongoing 9 or he had to make up to the makeup tank, and the other 10 operator didn't notify him that a leak rate was in J
11 progress. It could be other situations too, where he 12 would possibly change the level in the makeup tank unintentionally.
14 And changing the level in the' makeup tank Q
15 in the course of doing a leak rate calculation would 16 affect that leak rate calculation, would it not?
17 A The leak rate calculation was,part of the 18 makeup -- it took makeup tank level into [ffect.
19 Adding water to the makeup tank would tend Q
20 to make the leak rate seem less, is that correct, 21 rather than more?
L 22 MR. MacDONALD: . Objection for a minute. I 23 just want a clarification now. Are we talking 24
()_ about an inadvertent addition of water, not 25 somebody intentionally adding water?
_.~ .-. _ - - , . _ _ . _ , _ _ _ _ . _ - - - _ _ . , _ , , _ , _ . _ __ . . . _ _ . .
i i
l 1 Illjes 55 i
~
2 MS. MCDONALD: That is what I am talking i
3 about.
4 A Usually if somebody added water to the
(' 5 makeup tank, it showed right up on the computer 6 because it ended up negative. It was, you know, that 7 wasn't a -- you knew it right away, and you would say 8 " Hey, buddy, you added water to the makeup tank."
9 What I am saying is, we didn't add water 10 to the makeup tank to affect the leak rpte intentionally.
11 Q I understand you said that, but what I 12 would like to know, and I guess maybe you have (w/
N- 13 answered it, for whatever reason the wa',er t was put into 14 the makeup tank the leak rate would end up being lower 15 than it really was in real life, correct?
16 MR. MacDONALD: All other thi gs being 17 equal, that is what you are saying? -
18 MS. MCDONALD: Yes.
19 A It could go lower or it could go negative.
20 If you added water to the makeup tank, the computer
_ 21 didn't -- it sensed it could go below zero. We know 22 that that is -- O.K.
23 Q It is impossible for the leak rate to be 24 negative in real life, is that what you are saying?
(
25 A No, it is just measuring how much water
l
/
1 Illjes 56
' ' ~ Negative was in; 2 you are putting into the system.
3 positive was out, I believe.
4 Q Were you aware that this procedure,
( 5 Exhibit 252, said that adding water to the makeup 6 tank should be avoided during a leak rate test?
7 A That's correct, but there are other things 8 which would have taken precedence, like control rod 9 manipulation,or reactivity manipulations would have 10 taken precedence over something like that.
11 Q Had you ever had a conversation with Mr.
- 12 Hartman regarding leak rate results for Three Mile s 13 Island?
14 A Not that I recall.
15 Q Were you ever aware of anyone deliberately 16 adding hydrogen to the makeup tank in order to affect 17 the leak rate? .
18 A Not that I recall.
19 Q Was it your understanding that the addition 20 of hydrogen to the makeup tank in the course of a leak, 21 rate, whether or not it was done deliberately, would 22 affect the 'Aeak rate result?
23 A I am not sure when that knowledge came to
. (m) 24 me, whether it was before or after the accident, but 25 now I know that the level instrument is sensitive to j
l l
l 1 Illjes 57 2 pressure. I don't remember when that knowledge came 3 to me.
4 Q You mentioned before oscillation in the
( 5 plant that you said might affect the leak rate.
6 A correct.
7 Q Were there what might be described as 8 peaks and valleys?
9 A It could be plus or minus a half a degree, 10 which are sometimes just tolerances of the 11 instrumentation.
12 Q Were you aware before the accident of C' 13 operators attempting to take leak rate calculations at 14 a time when they thought the plant was in:a condition 15 so that the leak rate calculation would.come out 1G right?
17 A You tried to take the calculation when the 18 plant was as stable as possible. And inst'rumentation 19 accuracy, you know, there is a percentage. Some of 20 it is plus o'r minus.4, 10 percent, and that all --
all 21 that type of instrumentation was fed into the computer 22 to calculate the leak rate.
23 Q You mentioned before the addition of water
[J i 24 to the makeup tank for.some purpose involving the 25 control rod drives.
1 1 Illjes 59 2 in there.
3 Q Were there any procedures'while you were 4 on shift to make sure that or to try to see that I
5 people didn't add water to the makeup tank during the 6 course of a leak rate test?
7 A The one you mentioned was on the leak rate 8 calculation.
I 9 Q You are referring to the procedure that 10 requires you not to -- t 11 A That you should --
12 MR. MacDONALD: I object to the form.
O 13 What is the question?
14 Q --
required you to avoid adding water to 15 the makeup tank. Is that what you are referring to?
16 MR. MacDONALD: I am still go ng to object 17 to the form of the question. ,
18 A If you are not locked into a l'eak rate 19 calculation. In other words, you could stop that 20 procedure in the middle of a leak rate if something 21 else took precedence.
22 Q Did it ever come to your attention before 1
23 the accident that a leak rate calculation would be in
() 24 - progress, someone would mistakenly add water to the 1
25 makeup tank, and yet that leak rate calculation would i
i I
. 'j l
1 Illjes 58 n/
\- 2 When that k.ind of an addition was done, was 3 it normally done all at once? In other words, that X 4 gallons of water would be put into the makeup tank to fulfill that function at a given time?
( 5 6 A That's something that -- it depends on the 7 situation. Why are you moving the control rods? Are 8 you moving the control rods in preparation for-shutdown 9 or are you moving the control rods in preparation for 10 power change or due to the control rods,being out of the i
11 operating band?
12 Q Well, was it your understanding that the 1
O 13
~
additions to the makeup tank in order to move control 14 rods would characteristically be an addition of, say, 15 20 gallons, wait 15 minutes and then 20 more gallons,.
16 and wait 15 minutes, that kind of thing, or was it a 17 much larger addition? I am trying to get a feel of
~
18 what kind of addition this was.
19 'A It could be that situation. If you just 20 wanted to make a small adjustment and see what the
, 21 result would be after the water, if you were adding or 22 diluting your boron concentration, you might want to b
23 wait to see what the effect was going ta be before you 24 put in another -- but 20 gallons is a very small amount.
[)'T 25 Normally, it was 30-some gallons per inch or something
1 Illjes 60 a 2 not be performed again, those results would be
! 3 accepted with everybody knowing that water had been 4 added to the makeup tank?
( 5 A I'm sure the possibility exists that 6 water got into the makeup tank and that it affected 7 the leak rate, and possibly it came out within 8 requirements and somebody didn't catch it. I will 9 say that that possibility exists.
10 Q Did you personally ever turn in'a leak 11 rate result which you knew had been affected by the 12 addition of water to the makeup tank during the test?
\m- 13 A I was made aware of that afker the 14 accident. I did not intentionally do that. In other 15 words, I told you before that that was not done 16 intentionally. It was done, I believe a leak rate 17 was taken and water got into the makeup tank through ,
18 control rod maaipulation or something like' that, and 19 I was made aware of that after the accident.
20 Q How were you made aware of that?
, 21 A I believe it was in NRC testimony; not 22 testimony, but interview.
23 You were interviewed by the NRC about leak l
Q 24 rate results?
L 25 A Yes.
I l
?. , _
1 i
l 1 Illjes 61 l -
2 Q Do you remember when that was?
3 A After the accident. '
4 Q Do you remember whether it was '79 or '80
([ 5 or '817 6 A can I talk with Andy?
j 7 MS. MCDONALD: Sure.
(Witness confers with counsel.)
8 9 A I don't remember which interview that was
?
10 brought up as far as when the NRC was cpncerned.
11 Q Had you ever testified about leak rate 12 tests or calculations anywhere else other than to the
~~
4 13 NRC?
14 A Now, you are saying testify --
15 MR. MacDONALD: We talked about questions
~
16 related to the testimony before the grand jury, 17 and this is aside from the grand jury testimony.
18 MS. MCDONALD: No, it is not.'
19 My question stands. -
20 Are you instructing him not to answer on ,
21 some ground?
22 MR. MacDONALD: Yes, he is instructed not 23 to answer regarding what the substance of the 24 grand jury testimony may be. The grand jury is 25 ' still sitting.
.. .- - =. . _ - - .-.
1 Illjes 62 O(~h 2 When you testified before the grand jury, Q
3 were your answers truthful to the best of your 4 knowledge?
k 5 A Yes.
6 Q 'Did you answer all questions put to you?
7 MR. MacDONALD: Again, he is instructed 8 not to answer.
9 Ms. MCDONALD: I am not asking about the 10 substance of his testimony; I just want to know 11 did he answer the questions that were put to him.
12 MR. MacDONALD: He is instructed not to
/~N '
- 13 answer. The grand jury is not the subject of 14 this case. That is a separate proceeding and 15 what is happening before the grand jury in its 16 ongoing investigations is something we are.not 17 going to delve into in this or.any other 18 deposition in the case at this point.
19 MS. MCDONALD: Mr. MacDonald, 5 am not going 20 to try to ask him about the substance of his 21 grand jury testimony, and I have no interest in
(
(.
22 delving into what the grand jury may be 23 investigating. However, I do think it is fair to
() 24 ask him whether he answered all of the questions .
25 put to him.
I 1 Illjes 63 O~ 2 MR. MacDONALD: I just told you my position.
3 BY MS. MCDONALD:
4 Q Have you ever asserted your rights under the
~
( 5 Fifth Amendment to refuse to answer on the grounds that 6 it might incriminate you?
- 7 MR. MacDONALD: Again, I instruct him not 8 to answer. You are going into the substance of 9 the grand jury testimony at this time. I don't 10 think it is proper to go into it at this point.
11 Q Mr. Illjes, have you ever been given 12 impunity from prosecution by any governmental body in
(~
^
\-)/ 13 connection with Three Mile Island?
14 MR. MacDONALD: The same instruction. You 15 are entitled to ask him any and all questions 16 that you want to ask him about leak rates; what 17 his recollection is, what took place,, and be 18 able to obtain all the information fou want about 19 leak rates, but no questions that relate to the 20 grand jury in an ongoing investigation.
, 21 MS. MCDONALD: I disagree with you, but k 22 we will just go on for now.
23 BY MS. MCDONALD:
24 Mr. Illjes, were you ever aware that during
( Q 25 the calculation of a leak rate, water was added to the e ~ m -y w
1 I
I 1 Illjes 64 2 makeup tank and the person adding that water 3 deliberately wrote down that he had added less water 4 than, in fact, he had? Did that ever come to your
( 5 attention?
6 So you understand my question, let's say an 7 operator added a hundred gallons of water, just 8 hypothetically. Did it ever come to your attention 9 that the operator deliberately wrote down either in the 10 log or told the computer that he had really added 50 e.
11 gallons, or something like that?
12 MR. MacDONALD: I object. I think it is (h a hypothetical question.
(.,) 13 I will'let him answer 14 it.
15 MS. MCDONALD: ,
I only gave him the
~
16 hypothetical as an example.
17 Q My question is, did it ever come to your 18 attention that an operator had misstated how much 19 water he added to the makeup tank in order-to affect 20 a leak rate test?
. 21 A I don't recall.
22 Q Did it ever come to your attention that 23 an operator added hydrogen to the makeup tank and l
24 i deliberately did not record the fact that that had 25 been done in order to affect a leak rate test?
l I
l l
l 1 Illjes 65 O' 2 A I don't recall.
3 Q You are saying that could have happened, I
4 but you don't recall?
( .
5 MR. MacDONALD: I object.
6 A To my knowledge, no one has added hydrogen 7 to affect the leak rate in the makeup tank.
8 MR. MacDONALD: Just so we are clear, when
- 9 he responded "I don't recall" in the prior answer, 10 I take it --
and we can inquire qn cross if you 11 want -- but to clear it up now, I take it the 12 answer "I don't recall" refers to no one to his g~g -
(_ 13 knowledge. That is what I want $o clear up.
14 Q That is my question. I lji Do you mean no one to your knowledge did 16 that? -
17 A Your question was did anybody add, for 18 example, a hundred gallons to the makeup tank and put 19 50 gallons in the leak rate or something llke that.
~
20 I don't recall that happening. To my knowledge, that
_ 21 was never done intentionally. i k.
22 Q Did it ever come to your attention that 23 any operator made it a practice to start a leak rate 24 . test using one level o f transmitter for the makeup 25 tank and then in the middle of the test switch to using
1 Illjes 66 2 a different level transmitter in the makeup tank in 3 order to affect the leak rate test deliberately?
4 A Not deliberately to affect the leak rate.
5 Did it come to your attention that that
( Q 6 might have happened even if it was not deliberately 7 to affect the leak rate ' test?
8 A It's very possible that that could have 9 happened. It's a matter of taking the logs and the 10 log, I believe, might have on it the different 11 channels of the makeup tank level or if somebody wanted 12 a level put on a computer, I could switch levels on
\ 13 the makeup tank level instrument channe'l.
14 (Recess) 15 BY MS. MCDONALD:
16 Q Mr. Illjes, up until the time of the 17 accident, am I correct in thinking that it was the 18 practice to attempt a leak rate test appro'ximately
~
19 once every shift?
20 A Approximately.
21 Q Just so I understand what you said before, t 22 approximately?
23 A Approximately.
MS. MCDONALD:
(/)
\--
24 I would like to mark as tci%d ;ci;r.1 'c3 25 B&W Exhibit 903 a portion of .the conteol room log.
l
67 1 Illjes 67
[) -
2 and Mr. MacDonald, if you prefer that I mark 3 the entire log of that book, I will certainly do 4 so.
( 5 MR. MacDONALD: Let me see what you are 6 going to mark.
7 MS. MCDONALD: What I would lik'e to mark, 8 unless you have some objection, is pages 1 9 through 97 of control room log going from 10 February 14, '79 until September , 1979.
11 If you prefer that I mark the entire log 12 from February to September, I certainly will.
N/ 13 Just for convenience, I wou'ld like to mark _
14 just the portion I have handed to you, pages 1 15 through 97.
16 (Pages 1 through 98 of the co troiroom log
)
17 from February 14, 1979 through September 3, 1979 18 were marked B&W Exhibit 903 for identification 19 as of this date.)
20 MS. MCDONALD: We have marked as B&W 903 21 pages 1 through 98 of the control room log 22 beginning on February 14, 1979.
23 BY MS.. MCDONALD:
l/~~) 24 Q Let me show you that, Mr. Illjes.
%_/
25 Do you recognize that as a portion of a
- n. . ., .. . .
l l 1 Illjes 68 2 control room log?
3 A Yes.
4 Q Was that control room log kept in the l 5 ordinary course of Met Ed's business?
6 A It was kept as per what transpired in the 7 control room.
8 Q Was it the regular course of business for 9 Met Ed to maintain these logs? Was it the normal 10 practice to keep these logs at Met Ed ip the course of 11 its business?
. 12 A Right.
13 Q Now, Mr. Illjes, would you turn to page 14 79.of that log?
15 Do you see the numbers at the top right-hand 16 and left-hand corners? I apologize for tbis copy. It 17 is difficult to read, and we have requested better
~
18 copies, but haven't received them yet.
19 Now, do you see an entry made by you on page 20 79?
21 A Several.
22 Q I believe the entry is for March 25, is .
23 i that correct? Can you tell?
(1 24 A Yes, that would be March 25th.
%)
25 Q The 3:00 to 11:00 shift, is that correct?
l
1 l
l l
i i Illjes 69
/ 2 A That's correct.
3 Q Do you see opposite 15/5 hours, "Added 4 300 gallons from reactor..." --
from "B reactor bleed 5 tank to makeup tank 1"?
((
6 A Yes.
7 Q Do you see 1540 hours0.0178 days <br />0.428 hours <br />0.00255 weeks <br />5.8597e-4 months <br />, "Added 300 gallons 8 from B reactor coolant bleed tank to makeup tank 1"?
9 A Yes.
10 "Added..."
Q Do you see at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> --
I 11 believe it is "300..." -- is that how you read it --
12
,~
" gallons from A reactor bleed tank to makeup tank 1"?,
k_ 13 A Yes.
14 Do you see at 1915, "
Added 600 gallons from Q
15 B reactor bleed tank to makeup. tank 1"?
16 A Yes.
17 Do you see at 2115 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.047575e-4 months <br />, "Added 600 gallons Q
I0 from B reactor coolant bleed tank to makeu'p tank 1"?
19 y,,,
3 20 Do you see at 2255 hours0.0261 days <br />0.626 hours <br />0.00373 weeks <br />8.580275e-4 months <br />, "Added 600 gallons Q
21 from B reactor coolant bleed tank to makeup tank 1"?
2 A Yes.
2 Q Am I correct in thinking that comes out to 24
( 2700 gallons on that shift added'to the makeup tank?
25 Ms. MCDONALD: Strike that question.
, , - < - - - y .-- -- ,-- w
1 Illjes 70 O
' ~
2 Q Can you recall, Mr. Illjes, why all this 3 water was being added to the makeup tank approximately 4 three days prior to the Three Mile Island accident?
5 A I believe during this time we had identified
(( s 6 one of the relief valves, a leaking one, or maybe two, 7 leaking into the -- well, one of the relief valves on 8 the pressurizer had a leak.
9 Q How did that relate to adding water to the 10 . makeup tank? t 11 A. Water would be made up to compensate for 12 that leakage.
13 Q As far as you remember, we r'e the numbers 14 of gallons that you wrote down here in this log the 15 numbers of gallons that you added to the makeup tank?
16 A I believe if I wrote it down there, to the 17 best of my knowledge. ,,
18 Q A leak rate test calculation das performed 19 on this shift too, wasn't it, according to- the practice?
20 A I don't recall, but it was the practice to 21 perform a leak rate once a shift.
? 22 Q Do you recall whether you took account of l 23 the water you were adding to the makeup . tank in i
24 performing the leak rate test?
[a')
l 25 MR. MacDONALD: He said he doesn't recall-
1 Illjes 71 2 specifically. There is no basis for the 3 foundation of your question.
4 MS. MCDONALD: You may still answer.
Could you repeat the question?
( 5 THE WITNESS:
6 (Question read) 7 A I don't recall this circumstance. I mean -
8 I can read the information out of the log, but I am 9 not --
I don't recall the situation.
10 Q Mr. Illjes, I would like to go back and 11 correct something. I think we identified this page 12 79 as being March 25, 1979. I believe if you compare ,,
13 page 76 to page 79, in fact that reads Narch 23rd, am 14 I correct, just so the record is clear? >
15 A Which page do you want?-
16 Q I want to make clear what date page 79 is.
17 can you determine that from your review of
~
18 the log?
19 A' It is 3/23/79.
20 Q March 23rd?
21 A No, 3/25/79. If you go to the next page, L 22 on page 80 it is clearly marked.
23 MS. MCDONALD: Off the record.
24 (Discussion off the record.) '
25 BY MS. MCDONALD:
l
. l
1 Illjes 72 2 Q It is, in fact, March 25, 1979, Mr. Illjes, 3 as far as you can see?
4 A Correct.
would you turn to page 75 of this log?
(( 5 Q 6 Do you see an entry written by you on that 7 page?
8 A Correct.
9 Q Once again, do you see several items 10 listed in this entry where you are adding water to the l 11 makeup tank? I don't want to have to go through every 12 one of them, but do you see geveral entries of that m -
(_ 13 nature?
~~
14 A Six.
15 Q Do you see on that page 2031 hours0.0235 days <br />0.564 hours <br />0.00336 weeks <br />7.727955e-4 months <br />, "Added 16 H2 to makeup tank"?
17 A Correct.
18 Q Do you recall why you added hydrogen to 19 the makeup tank on this date? -
20 A Hydrogen was used to blanket the makeup 21 tank and in order to scavenge oxygen in the atmosphere 22 above the makeup tank or in the water. It absorbs or 23 chemically reacts in an oxidizing field.
/~N 24 Q Is it your recollection that that is why
(_
25 you were adding hydrogen to the makeup tank on this
1 Illjes 73 2 entry on this day?
3 A To my recollection, that was our practice.
4 When the pressure got to a certain point, we added 5 hydrogen to raise the pressure back up again.
{i 6 Q I note that on some of these entries, for 7 instance 1532, " Add SCO gallons batch to makeup tank 8 1," what does that mean, " batch"?
9 A The makeup tank has a controller which will 10 automatically shut down at the end of a specific volume 11 which will program into what we call the batch 12 controller, and a batch would be that volume which was 7-- ,
13 programmed into --
in other words, it was put in in one 14 instance or you can consider a batch, you can stop it 15 in between, and then consider a batch but there was 16 one 500 gallon calculation. You usually alculated 17 how far you want to move the rods in or how many ppm 18 you wanted to change the boron concentration in the 19 RCS.
20 g During these additions to the makeup tank 21 in March of '79, was it your purpose to increase or 22 decrease the boron concentration,~ generally?
t 23 A A log indicates that during power, you have 24 fuel burnup, so the practice here would be to it
-[/)
I
\_ l
. 25 looks like either maintaining the boron concentration l i
py ,_y, y , . - - p w - -
1 I11jes 74 b 2 the same or decreasing it.
3 Q Mr. Illjes, can you tell me, does water 4 that comes through the reactor coolant bleed tank,
( 5 does tha't have low-rated water in it?
6 A It could be. It doesn't have to be.
7 Q Without going through all of the other 8 entries where water may or may not have been added 9 to the makeup tank -- of course, we can go through 10 them if you prefer -- do you have a general recollection 11 that in, say, February and March of 1979 a good deal of 12 water was being added to the makeup tank during most o'f 13 the shifts?
14 If you prefer to go through all of the 15 log, we can certainly do that.
16 MR. MacDONALD: He can testifh to his 17 recollection and his awareness of something, 18 but he is not going to testify as td the 19 validity of what may or may not be occurring 20 at.another shift if he wasn't there.
21 MS. MCDONALD: 0.K., I will limit it to his L 22 shifts.
23 Q Do you recall in those months, February 24 and March of 1979, on most of your own shifts you were 25 adding fairly large amounts of water to the makeup
l l
l 1 Illjes 75 l 2 tank?
3 A we were adding water to the makeup tank, 4 yes.
g You mentioned before that there was some
( 5 6 sort of valve leaking.
7 Can you tell me what you remember about 8 that?
9 A We were adding water to compensate for 10 the identified leakage which was coming out of one of 11 the relief valves in the top of the pressurizer, 12 entering into -- to compensate for that leakage.
T'
\_)T 13 g Isn't it a fact, Mr. Ill j e s', that prior 14 to the accident, it was your belief, as far as your 15 review of the information available, that the 16 electromatic relief valve at the top of t$e 17 pressurizer was the one that was leaking?
18 MR. MacDONALD: I am going to' object to 1$ the question. -
20 You can answer it. I just think we have 21 gotten far afield from the agreed upon areas, 22 which were precursor events and surveillance.
23 A To my knowledge, I recall it was either the 24 electromatic or another relief valve that had a leak.
(/h G
25 Now, we are saying information before the accident.
1 Illjes 76 C
k 2 Q Have you completed your answer?
3 A Yes.
4 MS. McD,0NALD: Could I have the last
~
5 question and answer read back?
((
6 (Record read) 7 Q Mr. Illjes, I would like to show you what 8 appears to be a transcript of a tape recorded 9 conversation between you and two gentlemen from the 1
10 NRC.
t 11 MS. MCDONALD: Let's have it marked as 12 B&W Exhibit 904.
13 (Transcript of a tape recor'ded conversation 14 between Mr. Illjes and two gentlemen from the 15 NRC was marked B&W Exhibit 904 for identification 16 as of this date.)
j 17 BY MS. MCDONALD:
18 Q Mr. Illjes, is this the transcript that 19 you have in your possession that you mentioned earlier 20 this morning?
21 A I believe so, yes.
22 Q First of all, do you recall having this 23 interview with Mr. Fasano and Mr. Resner from the NRC?
24 A I remember having an interview. There 25 were two people. I don't remember Resner's name. I
i . .
~
1 Illjes -
77
(%
\' 2 remember Tony Fasano.
3 '
Q Do you recall there was a tape recording 4 what was going on?
5 A Y e t; .
{
~
6 Q On page 21, Mr. "FASANO: You did look 7 at these tempergtures and-it appeared to you 8 that it was the electromatig,7 Thc 'electromatic
}
l -
9 was the one as far as your revie,w of the 10 information available, was the 1e,aking valve?"
11 "ILLJES: As far as I... Y e'r . That was 12 the week...as far... At what period?"
13 "FASANO: Weil, how long has this been 14 leaking? How long hic'the pressurizer been '
15 ,' leaking?"
16 "ILLJES: I believe it started on a trip, 17 l I can't remember exactly."
( -
1' 18 "FASANO: One north? Two months? Three 19 , months?" -
20 , "ILLJES: Three, t'our months, I'd say."
21 "FASANO: To the bestnof your knowledge, it C 22 ' was always the electromati: that was the one 23 with some suspicion,.possisly J of others?" <;
24 l -"ILLJES: Uh, ,some suspicion of the others.
25 It is a possibility'the others could have been m
. j ,_ _ - ,,,, , . .. - - - . - , ....- ,..n
~
1 Illjes 78 I
. \/ 2 leaking also. You noticed some temperature 3 change."
4 Does that refresh your recollection as to whether you, at least, believed'at some point it was s
l 5 6 Probably the electromatic relief valve that was 7 leaking as opposed to other valves on the pressurizer 8 before the accident?
9 A That just backs up what I said prior, that 10 it was either the electromatic or one o the other 11 valves leaking before the accident. I said that already.
12 Q You, in any event, had no information prior n)
\m 13 to the accident which caused you to be' positive that it 14 was not the electromatic relief valve that was leaking?
15 A I can't recall any information to make a 16 positive determination of which valve was' leaking.
17 Q Mr. Illjes, I would like to show you a 18 po- tom of a control room log, which has previously 19 see marked as B&W Exhibit 785, and, in addition, a f
20 copy of the shift test engineer's log, which has been 21 Previously marked as Exhibit 174; the control room 22 operators' log, page numbers -- begins 362 and 363.
23 The shift test engineer's log pages are stamped C,) 24 WO6038 through 06040.
L/
25 I would.like to refer --
t
=
1 Illjes 79 O' 2 MR. MacDONALD: Just before you start, is 3 this a complete exhibit?
4 MS. MCDONALD: They are portions o f the exhibiu 5
( I know they are portions 5 MR. MacDONALD:
6 of logs, but are they complete exhibits? B&W 7 785 and 174, were they these two pages or were I
8 they the whole log? l l
9 MS. MCDONALD: The who.le log. B&W 785 10 was the control room operators' 1pg from April 11 2, 1977 to October 21, 1977. B&W 174 is the 12 shift test engineer's log from March 2, 1976 to 13 September 4, 1977.
14 MR. MacDONALD: Thank you.
15 BY MS. MCDONALD: '#'
16 Q Now, would you look at page 385 of the 17 shift test engineer's log?
18 A 285? -
19 Q Yes, 285. Excuse m'e. -
20 Now, do you see an entry in the middle of 21 that page, " Raised RCS pressure and attempted to lift 22 RC-R2 with no success. Opened RL-V2 at 2200 psig and 23 RC-R2 was open thus decreasing RCS pressure to 2110
[~)-
V 24 psig before RC-V2 could be shut again. Checkedsetpoints 25 on RC-2PS8 which controls RC-R2. They were a little
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ - - 1
1 Illjes 80 t
2 low. Reset them"?
3 Do you see that? Do you recall this 4 incident?
( 5 MR. MacDONALD: The portion that you read?
6 Q Do you recall an incident on or about I 7 August 28, 1977 in which ac-HV2 failed to reseat?
l 8 A I don't recall that specifically happening 9 from between one incident and another incident.
10 Q Looking at the control roo:a log, do you 11 see entries concerning RC-RV2 on that log? And I 12 will read them, the ones I am referring to, "Placed
~
13 heaters incressurizer in manual and spray in manual 14 to raise pressure to 2255 pounds to test RC-RV2 15 (shift test engineer Ulrich's direction)."
~
16 Do you see that?
17 A Yes.
18 Q RC-RV2 is the pilot operated relief valve l
19 on the pressurizer, is that right? - '
20 A Yes.
21 Q The next entry reads, "RC- RV 2 failed to 22 lift at 2255 pounds. The relay , but
)
23 the valve did not open."
24 And then, later on, at 234, "Placed heaters 25 and spray in manual to test RC-RV2 Opened RC-RVLnder
1 l
1 Illjes 81 pm
(_) 2 direction of shift test engineer and shift supervisor, 3 similar foreman."
4 Do you see that entry?
5 A I see that.
{
6 Q Is RC-V2 the block valve for the pilot 7 operated relief valve?
8 A Yes.
9 Q The next entry, " Shut RC-V2 It appears 10 that 'Rc-Rv2 lifted at some pressure less than 2255 t.
11 pounce 6.-cause pressure began decreasing as soon as 12 RC-V2 was opened."
13 Do any of those entries refresh your 14 recollection regarding this incident that appears to 15 have occurred on, August 28, 1977?
16 A It was our practice to review' incidents 17 similar to this because I don't have the details in 18 my mind as to the e xa c t-- j us t specifics of the 19 incident. . .
20 Q 'o you see that this entry, the one I just 21 read from the control room log, appears or it bears 22 the signature or what appears to be the signature 23 of Mr. Frederick, his name appears at the top of the 24 entry also?
("]
b 25 A I see.
1 Illjes 82 l
/~
(~)h 2 Q Do you remember having any conversations 3
with Mr. Frederick at any time prior to the accident 4 about either stuck open or stuck closed pilot 5 Operated relief valves?
(
6 A I don't recall any. But, like I say, 7 these were reviewed in a report afterwards, either on 8 shift or in a training program. An incident similar 9 to this in which we had an abnormal condition and the 10 condition was placed in a -- some sort of format and t
11 reviewed in either on-shift or off-shift.
12 Q The reviews that you are referring to took P)
(_ 13 place before the accident?
14 A Yes, we had reviews like thislbefore the j 15 accident.
i 16 Q Do you recall that in at leas't one or more 17 of those reviews, some incident regarding abnormal 18 behavior of the pilot operated relief valve was 19 reviewed? I don't mean to tie you to this- incident ,
20 but any incident regarding the'PORV.
21 A Another incident concerning loss of power. !
(. 22 to the relief valve.
23 Q Do you recall that that incident was
(~N 24 reviewed in some training review?
L]
25 A I believe that was reviewed in some
, , , + . ., ..v
I 1 Illjes 83
[ I can't remember the specifics, but I am 2 training. l 3 sure we went,over that particular incident.
4 Q The incident that you just referred to 5 that there was a loss of power to the relief valve,
, (
6 do you recall that that incident took place in March, 7 approximately, of 1978? I will make it the spring of 8 1978, if that is easier.
9 A Yes, it was in approximately 1978, to my 10 recollection. t 11 Q What do you recall that you were told 12 regarding that incident in your review of it?
13 A I don't remember the specifics of the 14 review, but I can probably give you some general 15 information.
16 Q What general information can you give me?
17 MR. MacDONALD: Are you talking about his 18 understanding prior to the accident 7 19 MS. MCDONALD: Yes, we were talking about 20 discussing reviews that occurred prior to the 21 accident as I understand it.
22 MR. MacDONALD: The question is what, 23 genarally, did he understand about that?
24 MS. MCDONALD: What does he remember being
[\_)~)
25 told about the incident which he brought up, loss
. ~ .- _ . _ _ . ___. . . . _ . _. .. .-
I l
l 1 Illjes 84 I"'s -
^( /
_ 2 of power to the pilot operated relief valve 3 which occurred in 1978.
4 A The loss of pcwer to that relief valve, 5 let's see, we had loss of power to an inverter and 6 that relief valve opened due to loss of power to 7 that inverter or sensing equipmen't, along with loss 8 of power to quite a bit of indication. I am not sures 9 we probably had a trip.
10 g You don't remember anything else that you i
11 heard about that incident before the ac ident, is that 12 right?
J
() 13 A well, at that point, we did'not have 14 indication on relief valve. And, let's see, after 15 this incident, we resulted in putting in an 16 indication on the relief valve to where you could 17 tell whether it was opened or closed.
18 g You mentioned installing indication on 19 the PORV after this incident. .
20 Did that take the form of some kind of 21 light in the control room?
22 A Yes.
l 23 g You knew, did you not, that that light i f' 24 indicated whether or not an electrical signal was
(.
25 being sent to that valve? You knew that that is what l
1 Illjes. 85 A
A- 2 the light showed?
3 A The light went to a solenoid that caused 4 the valve to open and that is what we used as our 5 indication for the position to be open, you know. It
{
6 had -- when you energized or when that solenoid was 7 energized, we accepted that the valve -- when the red 8 light would come on, the valve would be open. When 9 the red light would be off, the valve would be closed.
10 Q Mr. Illjes, isn't it a fact that you knew 11 prior to the Three Mile Island accident that the
~
.. 12 solenoid could be actuated giving you a red light O ~
( ,) 13 signal, but that the valve could nevertheless be 14 mechanically stuck shut, and didn't you also know 15 that the light could be out indicating no power to the 16 solenoid and the valve still be open, mechanically 17 sticking open?
18 A The valve before the accident,' you 19 mentioned that one incident, but other than that it.
20 was accepted as being fairly reliable, and when the 21 light came on the valve was open and when the light 22 went off the valve was closed.
23 g You said I mentioned that one incident
. (~} 24 What one did you mean?
N. sl 25 A The one covered that was on Ed Frederick's l c -,+-w -- m ,m <---% , y +-v>+
~
1 Illjes 86
.(_
f')) 2 shift.
3 Q This situation is August 28th. You looked 4 back at the control room log and there was an entry "RC-RV2 failed to lift at 2255 pounds. The relay
{ 5 6 actuated but the valve did not open.'"
7 Now, is that an indication there that 8 whereas the valve was signaled electronically to open, 9 it nevertheless did not open?
10 MR. MacDONALD: I object to the form.
t 11 If he testifies to his recollection, 12 fine. I am not going to have him sit here today 13 and have him interpret what someone.else wrote 14 in the control room log.
15 MS. MCDONALD: He said, other than the 16 incident I mentioned. I would like' to know what 17 that meant.
18 A You stated to me that the log here stated 19 that the relief valve failed to open, but I said I 20 didn't recall this particular incident, and you know I 21 would have to make a judgment from this situation here 22 that, you know, was it -- 0.K.
l l 23 Q Do you have any idea what the relay that l
is being referred to here is?
(~} 24 l \_/
! "5 A Here in --
i
\
1 Illjes 87
.Q
_) 2 Q In page 362 of the control room log for 3 August 28, 1977, whether or not you remember the 4 incident.
A I don't remember the specifics of the
( 5 6 incident, so I wouldn't remember the relay number.
7 Q I would like you to refer to B&W 904, 8 your testimony to the NRC. .
9 Do you have that? Page 18, Mr. Illjes, 10 I believe you were talking about the electromatic t
11 relief valve here, and you stated "It has a solenoid
~
12 operated affair which accepts a pilot stem, or allows 13 the pilot stem to move up and the indichtion you have 14 is when that solenoid in actuated and that gives you 15 a red light. That doesn't indicate that the valve is 16 open. So you can deenergize the solenoid ^and the 17 valve can stay open and you have no indication."
18 Does that refresh your recollection that 19 you knew that the solenoid did not necessarily 20 indicate whether the valve was opened or closed? -
21 MR. MacDONALD: I object to the form.
22 A Well, this was testimony or an interview 23 after the accident, and since the accident and this
(~h 24 interview, we did quite a bit of review on the
()
25 specifics of the accident and I can't tell you whether
I 1 Illjes 88 2 I had that information before or after the accident, 3- but, as I stated before, I knew it was solenoid 4 operated.
5 Q I take it you received absolutely no
{
6 training after the light was installed to inform you 7 that that valve might stay open or stay closed, 8 regardless of what the light said?
9 MR. MacDONALD: Training from any particular 10 source, anybody?
11 MS. MCDONALD: Anybody.
12 Q Is that correct?
13 A I don't remember receiving 'any training 14 that that valve --
anything could happen.'
15 Q Isn't it a fact, Mr. Illjes, that you knew 16 before the accident that any valve includ'ing the PORV 17 could for some mechanical reason, binding, erosion, 18 whatever, I am not saying that happened, but just as 19 an example, stick open or closed, isn't it-true, 20 didn't you know that that could happen?
21 MR. MacDONALD: Isn't it possible that any 22 particular valve at any particular time could 23 stick up?
24 MS. MCDONALD: Yes, for mechanical reasons.
25 In other words, not electrical reasons.
1 Illjes 89 O
(- 2 -A It's possible that any valve could stick 3
open, but I have experienced I forget how many trips 4 I have been through and the relief valve opened when the light came on and when the light went off the
( 5 6 relief valve closed, and there were no problems associated with the relief valve during a trip. So, 7
8 as operators, we accepted the light as being an 9 indication for the position of the relief valve.
10 Q No one told you that that might not be c
11 true before the accident, is that righti 12 A Not to..my knowledge.
) 13 Q I would like to show you again a portion 14 of the control room log, wh.ich has been noted as 15 B&W 785. I would like to show you pages 367 through 16 369, and also the shift test engineer's log for one 17 of the shifts on August 30, 1977, which is part of 18 B&W Exhibit 174. The pages on the shift test 19 engineer's log are WO6042 through 06045. ,And I would 20 like to refer you to page 06044 of the shift engineer's 21 log.
l 22 Now, do you see an entry on that page 23 which reads, "Placed RC-RVin auto and' raised RCS 21 pressure to 2275 psig. RC-R2 lifted at approximately
(~
U 25 2250 psig. Sprayed down pressurizer to 2130 psig and
i 1 Illjes 90 A) k._ 2 RC-R2 never closed. The relay which actuates -RC-R2 3 did drop out, so it looks like RC-R2 is mechanically 4 binding."
1 5 Do you recall this incident on August 30,
({
6 1977? And if I could step over here, refer to the 7 control room log, you came on shift sometime on 8 August 30, 1977, the 3:00 to 11:00 shift, and I am 9 just wondering whether you heard about the incident 4
10 referred to in the shift test engineer's log when you t
- 11 came on shift on that date.
i 12 A I am not suggesting that you were on shift 13 at the time of the incident. I would l'ike to know
} 14 whether when you did come on shift you heard about it.
b 15 A I don't recall this particular incident.
l 16 Q Looking at the shift test engineer's log, i
17 do you see that the entry to which I just referred you 18 occurs during the first shift test engineer's shift 19 on August 30, 19777 -
i i 20 A You say that's the first shift from 21 11:00 --
this is August 2nd. You are saying --
l 22 Q Is this the first entry for this log on 23 August 30th?
24 MR. MacDONALD: The log is what it is.
(~}/
(-
25 Q I am just asking you whether that entry
- , - , - . - . -- s-.- , , - - , - - - , - - r-w-e . , - - -
,e...,r .
1 Illjes 91 x-) 2 appears during the first shift of August 30th.
3 A It depends. He could have waited until 4
somewhere in the morning.
5 Q Does it appear during the first shift at
{
6 sometime during the first eight hours in the 11:00 to 7 7:00 shift?
8 A You are saying that events listed in here 9 happened in the 11:00 to 7:00 shift?
10 Q Yes, that is all I am asking, based on
(
11 your review of the log.
12 MR. MacDONALD: The STE's log or the 13 control room log?
14 A We did not review this log. l 15 Q I know, but can you tell from this log by 16 looking at it today that this is the firs't shift on 17 August 30, 19777 18 MR. MacDONALD: The log will -speak f or 19 itself. What it is is what it is. Who wrote 20 .
the entry is when it was.
21 A It is also possible that the shift test 22 engineers were on a 12-hour rotation, so it might have 23 been the first 12. hours instead of just the first shift.
24 Q It might have been the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 25 rather than the first eight,is that what you are saying?
I I
]
I 1 Illjes 92
/~T -
(-) 2 A It's possible.
3 Q Can you tell me, based on.your review of 4 the contro1 room log --
5 A I can hardly read it.
(
6 Q Can you read that name? Is it Craig Faust?
7 A That's correct.
8 Q Does that signature appear directly after 9 the entry for the 11:00 to 7:00 shift on August 30th?
10 A Correct.
t 11 Q Did you have any conversations with --
12 A It doesn't appear after the 11:00 to 7:00.
13 shift. It appears at midmorning. The-next shift 14 starts on 11:00 o' clock, so this is probably 10:35 15 there.
16 Q Have you ever had any conversations with 17 Mr. Faust regarding any incident in which an electrical
, 18 signal was sent to the PORV, but for some. mechanical 19 reason the PORV stuck open? Or to rephrase that, have 20 you ever had any conversations with Mr. Faust in which 21 it was discussed that the electrical status of the PORV (1 22 might not necessarily. indicate whether or not it was 23 mechanically stuck, either opened or closed?
24 A It was a common practice to go back and 25 review the log prior to your taking the shift, and I l
1 Illjes 93 (3
\/ 2 don't recall talking with Craig specifically about 3 the incident that you are mentioning. For me to 4 remember that, I have to have a photographic memory.
5 Q Do you remember, you testified earlier
(
6 today about the installation of a light on the PORV, 7 an indicator light, you talked about that before?
8 A Yes.
9 Q I would like to show you an entry from 10 the shift test engineer's log, which is B&W Exhibit 11 176, an entry for October 4, 1978, which reads, 12
" Tested RC-Rv2 per Met Ed SOP 2-78-86, raised RCS p re s s,u re
() 13 to 2275. Received the red, open indica' tion for RC-Rv2 14 which indicates that an open signal is going to the 15 solenoid at the valve; however, there was no decrease 16 in RCS pressure. Reduced RCS pressure by" manually 1
17 spraying to 2155 psig. Shut RC-V2 and manually tried 18 to open RC-V2 while monitoring the limit switch 19 contacts at the patch panel. Again received the red, 20 open light on panel 4, but no indication from the patch 21 panel that RC-Rv2 opened. Shut RC-RV2 and opened L 22 RC-V2 "
23 Do you recall this incident with the PO RV ',
24 apparently taking place October 4, 19787
/']
G' 25 A This apparently still looks like it is in i
1 Illjes 94 s .
- 2 the testing program.
3 Q October of 19787 4 A Yes, they list the test procedure.
5 However, it is your recollection that,
( Q l
6 however,the light that you referred to before had 7 been installed by October of '78, is it not?
8 A when was the incident where the -- what 9 was the date for the incident where the electromatic 10 relief or the bus failed and the reli,ef valve went 11 open? It's hard for me to keep the dates straight.
12 I think it was before that.
r
k._)T 13 Q would it refresh your recol'lection if I 14 told you that incident took place on March 29, 19787 15 I don't want to put words in your mouth.
16 A I don't remember this particular incident, 17 but at the time we, out of our testing program we were 18 satisfied with the operation of the valve'in relation 19 to the light being on, the valve was open, and when it 20 was off the valv'e was closed. In other words, it 21 proved the operation of the light before they got out L 22 of the testing program, to the best of my recollection.
23 Q Mr. Illjes, --
(~h 24 A Excuse me. That was the purpose of the
\_)
25 testing program. You have to test all this equipment l
.1 Illjes 95 10 2 to make sure it functions properly.
3 Q I take it then that no one told you that 4 it was possible, as is suggested by this incident,
( 5 that the light could be on but the valve could be 6 closed?
7 .
MR. MacDONALD: Are you asking him whether 8 anyone told him about this_particular incident?
9 A From this particular incident, I don't 10 remember the particula;- incident, and I said before 11 we reviewed incidents like this, but the specifics 12 of this incident is not refreshing my memory.
13 Q As I understand your te s titiony , Mr.
14 Illjes, you understood before the accident that the way 15 this light in the control room worked was that it told 16 the operator whether the solenoid was energized or not 17 energized, is that correct?
18 MR. MacDONALD: I object to tlie form of 19 the question. -
20 MS. MCDONALD: It told him that, and it 21 may have told him other things. I just want to 22 understand if that is what the light indicated, 23 not how you interpreted the light. How did the
, 24 light physically work?
25 MR. MacDONALD: I object to the form.
I 1 Illjes 96
(
' 2 That.was asked and answered about three !
3 times so far.
4- MS. MCDONALD: I am not sure it is clear g 5 on the record.
6 MR. MacDONALD: It is very clear.
7 MS. MCDONALD: Go ahead. You may answer.
8 MR. MacDONALD: Could you read the question 9 back, please?
10 MS. MCDONALD: I will rephr se the questio.
11 BY MS. MCDONALD:
12 Did you understand prior to the Three Mile Q _,
. /'N
(_) 13 Island accident that the way this light'for the PORV
. 14 physically operated was that it showed whsther power 15 was or was not going to the solenoid? ,
16 MR. MacDONALD: Objection.
17 A In the testing program, we experienced 18 some difficulty with the valve, but at the~ end of the 19 testing program in my mind, and I will testify-from 20 my mind, I was satisfied that the operation in the I
21 valve coincided with the light being or. for the valve 22 to be open and the light being out for t.se valve being ,
1
~
23 c1osed.
(~h, 24 Q That is not my question.
L}
25 A And also coinciding that the solenoid l
1 Illjes 97
/~T '
(_) 2 would be energized to open the valve and deenergized 3 to close the valve.
4 Q Mr. Illjes, maybe you are not understanding 5 my question. I want to know whether before the Three 6 Mile Island acc'ident, you understood that the light 7 indicated whether or not power was going to the 8 solenoid. I am not asking you whether you interpreted 9 that or everyone interpreted that to mean that the 10 valve was opened or closed. I would like to know that t
11 physically the light showed whether power was or was 12 not going to the solenoid?
13 MR. MacDONALD: I object. He just told you 14 in his last answer his understanding about power 15 to the solenoid and position of the valve.
He 16 gave you both things in that answer".
17 MS. MCDONALD: All he gave me was operators 18 interpreted the light on to mean - -
19 THE WITNESS: I said the solenoid to be i
20 energized. ,
l l
21 BY MS. MCDONALD: )
j 22 Q But you haven't answered my question whether 23 there is any connection at all whether the solen'oid is 24 energized or not and whether the light is off.
l 25 A Yes, I did.
h 1 Illjes 98 O
,2 Q Would you tell me again?
3 A When the light is on,the solenoid is 4 energized, and when the light is off the solenoid is deenergized.
t
( 5 I
6 Q You knew that before the accident?
7 A To the best of my recollection.
8 Q Who told you that if the light was on,the 4
p l 9 valve was open and if the light was off the valve was 10 closed? t 11 MR. MacDONALD: Who specifically, you are i
12 a'sking, a person?
13 MS. MCDONALD: A person, first, yes.
14 A I don't recall.
15 Q Did you find that out from someone at Met 16 Ed?
i 17 MR. MacDONALD: Exclusively, you are 18 talking about only Met Ed?
- i 19 MS. MCDONALD: Well, GPU, Met Ed.
20 A To my recollection, I believe it was 21 covered in a training program and on-shift training.
I _
4 22 Information was available in the control room.
23 Q- On-shift training that was conducted by
/~) 24 personnel from Metropolitan Edison or GPU, correct?
t N.J '
25 - A It could have been either. I don't
-r,--.4 , - - - . - , - - - . - ,-r-,-:--.----- 9 = , .-
,.-m,. ,-rrw --- -,, y
f
- .I 1- Illjes 98A 1
1 ,
l a
r 2 remember who'it was.
f
=i i 3 Q It.was one of those two?
f .4 A- I b'elieve. '
+
( 5 (Recess: 1:00 p.m.)
. 6 7
8
- 9 10 t
+ .
. 11
- 12
- a. . . ,
?
y 13 o
14 i
15 I
16 k
I d
17 18 '
t 19 -
4 20 i
b 21
]
4 22 ,
i
, 23 i.
- a. . .
l .
24 4
, . 25 1
5 i-e u
. , . , -,..,,.,........_,__,,...,_,...m._... _ . . , _ - . . . . . _ . ~ _ _ , _ _ _ _ . . _ . _ - . _ , _ _ . - . _ _ . - . _ , . _ . -
1 99
/~ -
k_)/ 2 AFT E RNOON S E S S ION 3 (Time noted: 2:15 p.m.)
4 THE OD 0 RE F. I LLJ E S, resumed.
5 EXAMINATION (CONTINUED)
((
6 BY MS. MCDONALD:
I 7 Q one other brief incident I would like to 8 show you.
9 I show you a portion of, again, B&W Exhibit ,
1 10 785 which is the control room log. The pages I am u
11 going to show you are pages 453 through 455, and I 12 would like to direct your attention to the second pagd 13 of this portion of Exhibit 785.
14 Actually, on t.h e first page, Mr. Illjes, 15 do you see that Mr. Miller's entry is at least labeled 16 "10/3/77, 7-to-3 shift"? It is on page 453.
17 A Yes.
18 Q Turning over the page, at the top.of the 19 page, the second page there, do you see your name as 20 one of the people relieving the shift? I can't read 21 the first name. And then it says "Illjes." And right 22 before the first name, I believe it says " 7-11 " I 23 know it is hard to read.
(~} 24 Do you see that? That is not your LJ 25 handwriting on all those entries, is it, Mr. Illjes?
1 Illjes 100 fm.
-< 2 A No, it is not. !
3 Q Do you recognize Mr. Thompson's handwriting?
4 .A His name is on the bottom as signing out.
( 5 I don't recognize Mr. Thompson's handwriting 6 because I didn't work with him all that long, but his 7 name is on it.
8 Q Do you see at the top that apparently you 9 were also on the shift?
10 A Yes. g 11 Q The last entry on this page says, " Shut 12 RC-V-2 pressurizer electromatic is leaking by."
13 RC-V-2 is the block valve for the PORV, 14 is that right? I think you told me that before.
15 A Yes. .
16 Q Why was the block valve closed when it 17 was discovered that the electromatic was leaking by, do 18 you recall? '
19 MR. MacDONALD: Are you asking~for his 20 recollection at this time h.ere? ,
21 MS. MCDONALD: Yes.
C 22 A I don't recall.
23 Q Do you remember how it was determined l
_(^) 24 that the PORV was leaking by?
\.s' 25 A I don't recall. I don't remember this l
- . . - , , . - - , , .- ,-r -
1 Illjes 101
() ~
\J 2 particular incident.
3 Q Do you recall at any time before the 4 accident knowing any way to figure out whether the
({ 5' PORV was leaking?
6 A Not to nail it down to specifically the 7 PORV, no.
8 Q Was there a way to tell whether any of the 9 valves at the top of the pressurizer were leaking 1
10 based on your knowledge before the accident?
- \
l 11 A Yes.
12 Q I!ow was that done?
/~
(_)) 13 A You had the relief valves d'ischarge into 14 a tank which had level and pressure, temperature, those 15 indications.
16 Q Was that the reactor coolant drain tank? !
17 A Yes.
18 Q Any other way to tell?
19 A That would indicate one of the'-- not 20 . any of the relief valves. We had tail pipe temperature 21 or the relief -- relief valves discharged into a tail L 22 pipe, but this pipe for a ways it was separate, but 23 then it went into a common pipe, and so if one relief 24 valve lifted, you know, it could -- you couldn't 25 determine whether the other one lifted or not, because
1 Illjes 102 c, -
\ _
2 it would heat up the whole line, plus some of the 3 temperatures were affected by the heat coming off 4 the pressurizer.
5 g When did you become aware that temperatures
(
6 were affected by the heat coming off the pressurizer?
7 was that after the accident you found that out?
8 A I believe that would be true.
9 Q Do you recall it being the practice that 10 if an operator knew that the PORV was leaking that t
11 the block valve would be closed, as apparently was 12 done on October 3, 19777
) 13 MR. MacDONALD: I object to'his knowledge 14 of this particular event.
15 If you want to ask him if there was a 16 general practice that he knows of, go ahead.
17 MS. MCDONALD: Yes, that is the question.
18 A Here it doesn't show that he determined 19 that the relief valve was leaking. It doesn't explain 20 why he closed it. But as far as.the practice of 21 closing it, if you had a leak, I don't recall closing 22 it for, you know, for a leak condition. I don't have i
23 a recollection of closing it. I don't recall this l
~
24 particular incident. I 25 Q Seeing this log doesn't refresh your
1 Illjes 103 (ON )' 2 recollection in any way on that topic?
3 A No.
4 Q I should add that the log does say " Shut
~
5 RC-V-2 pressurizer electromatic is leaking by."
((
6 Mr. Illjes, when did you find out that 7 there was a transient in progress at Three Mile
'8 Island on March 28, 19797 9 A That morning.
10 Q Did someone call you on the phone?
t- i 11 A Yes.
12 Q Who? .
i
[~)h 13 A John Kidwell. .
14 Q Was he a control room operator?
15 A Yes.
~
16 Q was he calling you from the site, do you 17 know?
18 A Not to my knowledge. He was calling me 19 from -- not from the site. I don't know where he 20 was calling.me from.
21 Q What did he say to you?
22 A He asked me if I knew what was going on 23 down at the Island or something. I don't remember 24 the exact words, but he knew that I was aware of what 25 was going on down at the Island.
_ c, ,
_j j n o en
- i l I11jes 104
':(
.(G
') -
2 Q So you were aware that something <as going r on before you' received his call?
3 4 A No.
('
5 g I'm sorry; I misunderstoo'd you. -
w 6 What time was this call, approximately?
7 ( A Inithe morning.
8 Q can you e, stimate, 7:00 in the morning, 9 11 : 0 0 s.in the morning 7 t'
10 A Somewhere'in between there.g 11 Q Was it 6:00 in the morning? -
l 12 A It wasn't that early.
\ 13 Q What did you cay to Mr. Kid'well?,
s 14 A I hsdn't heard of anything to that point.
a, 15 Q D4d you then call the Island?
16 A. I don't recall.
- 17 Q You subsequently went to the site?
18 A Yes.
19 Q About what time did you get to'the site?
20 A It was about 1:00 o' clock, somewhere in 21 that point, to the observation c e n.t e ,r .
- C L 22 -
Who.was in the observation center when Q
J 23 you got there? ( ,,
['T
> \_)
24 A- I don't recall, except a lot'of newspaper i
s .
j: 25 J reporters. I think I met with John Kidwe,11 and I 3
4r %
,,. _ _. ~ _ , -t.. -_ - _. _- _ _
1 Illjes 105 m
2 don't recall anybody else. There were lots of people 3 there. -
4 Q Did you make any statements to the press?
( 5 A No.
6 The only person you remember being there Q
7 was Mr. Kidwell, although there were others there as 8
well, is that right? Was Mr. Arnold there?
9 A I don't recall who was there.
10 Q Did you have any conversations with any 11 of the people who were at the observation center 12 while you were at the observation center? ,
13 A I'm sure I had conversation ,'but I don't 14 recall what my conversation was.
15 Q While you were still at the observation 16 center, did you come to any understanding as to what 17 had happened? .
18 A Well, I knew that they had a t ri p . I 19 don't recall, you know, I can't say that's exactly 20 when I learned of these incidents. It's kind of hard 21 .for me to put that together.
22 When I learned about it, I can't say that's 23 exactly when I learned about.it. I can remember maybe b
GI 24 being briefed before we went over.
25 Q To the control room?
1 Illjes 106
,-s .
k- 2 A To the control room, but I don't remember 3 who gave us the brief.
4 Q You don't remember much about what was 5 said in general? '
((
6 A Separating from the.t day to other days at r
7 the observation center, no.
8 Q About what time did you get to the control 9 room?
10 A 3:00 o' clock in the afternoon, t
11 Q Who was there when you got there that you 12 recall?
13 A I reported to Joe ChwastykI 14 Q Was Mr. Zewe still there?
15 A I believe so, yes. I'm not positive, but i
16 I believe he was there.
17 Q Was Mr. Chwastyk a shift supervisor?
18 A Yes. '
19 Q Was he the next shift supervisor on after 20 Mr. Zewe?
21 A There is another shift supervisor in s
22 between there first, but I don't know how the relief 23 went.
24 Q Do you remember who he was?
25 A Let's see, who was the other shift
1 Illjes 107 2 supervisor?
3 (Pause) 4 Q Was Mr. Frederick there? ,
( 5 A Yes.
6 Q Was Mr. Faust there?
7 A Yes.
8 Q Was Mr. Scheimann there?
9 A I can't picture Fred.
10 Q Mr. Mehler? g 11 A I believe he was there.
12 Q Mr. Miller?
\_ 13 A Which Miller?
14 Q Gary Miller. I 15 A Gary Miller, I believe he was there.
16 Q Can you remember anyone else who was there 17 other than the ones I have mentioned? .
18 A Yes, I can remember Mark Coleman, Bill 19 Conaway. I can picture Jack Herbein coming in and 20 going out. John Kidwell, he came over with me. There 21 was an NRC inspector there, but I can't remember his 22 name. One or more. I think maybe there was two. I 23 remember one of them asking questions.
24 Q Is that the extent of your recollection 25 of who was there?
I L l
1 Illjes 108 f'N k/ 2 A Bubba Marshall. There was another fellow 3 there who was working along with Bubba Marshall, and 4 I can't remember his name, and he now works for Amp 5 Corporation. I can't think of his name. He filled in
({
6 the log for me.
7 Q Were his initials DAB?
8 A What do the initials stand for?
9 Q I don't know.
10 A Is it Barry or Berry or something like t
11 that?
12 Q Let me show you the log.
13 I show you B&W 903 and refir you to page 14 84.
15 ,A Don Barry. There are two Don Barrys.
16 One is Berry. One is B-e-r-r-y, and one is.B-a-r-r-y, 17 This is the Berry that I am referring to.
18 By this one, are you referring to the Q
19 entry on page 84 where it says " Late entry" and then 20 there are some initials, " DAB"? Is that who you 21 believe to be at least Don Berry?
22 A Yes.
23 Q Do you see an entry there, where "TFT" is (q 24 written?
(./
25 A Yes.
1 Illjes 109 2 Q What is the time opposite that? Can you 3 read it?
4 A It looks like 1850 to me.
5 It says, " Relieved the shift condition as
({ Q 6 follows."
i 7 MS. MCDONALD: I should note for the record 8 that the pages I am going to be referring to are 9 page 84, 85, and 86 of GPU 903.
10 Q Now, would you look at pagg 86, the last 11 page of what I am referring you to?
12 Do you see your name? Is that your
~
(N s.,/ 13 signature at the bottom of the page?
14 A Yes. I 15 Q can you look at the log and tell me where 16 you started to make entries from the handwriting?
17 A It looks like --
is that 19007 18 It looks like it. I can't make out the 19 number. -
20 Q could it be 7:00 in sort'of lay time 21 A No, 19.
22 Q Is that on page 857 23 A Yes.
I
('] 24 Q That is the first entry that is in your V
25 handwriting?
1 Illjes 110 7- .
2 A Yes. Except for the 1950 entry.
3 Q Can you describe for me what you did when 4 you got to the control room?
(; 5 A Well, we reported to Joe Chwastyk and Joe 6 Chwastyk was the person in charge at the time.
7 I was taking care of the left-hand part 8 of the panel.
9 Q Is that the primary side?
10 A The primary side.
11 Q Was there somebody who was taking care of 12 the secondary side?
13 A Yes, I believe that was John Kidwell. Yes, 14 I-believe it was him.
15 Q You said you got to the control room at 16 approximately 3:00 p.m. I take it you did not 17 officially relieve the shift until some later period 18 of time, as is shown in this log, is that correct?
19 A Yes, it says 1850. -
20 'Q Is that 6:507 21 A Yes, 6:50 p.m.
22 Q Did you receive a briefing from Mr.
i 23 Chwastyk when you arrived in the control room?
. s//') 24 A Yes.
i 25 Q Is that the first thing you did when you
a 1 Illjes 111
\ ~
2 got there after you reported to him? ,
i 3 A No, it wasn't the first thing.
4 Q What did you do first?
5 A I believe I talked to some of the operators.
({
6 I remember talking to Mark Coleman; to Ed Frederick.
7 .
Q Can you tell me about your conversation 8 with Mr. Frederick?
9 A No.
10 Q Do you remember anything he said to you?
11 A No.
12 Q I don't mean the exact words, even in Cj 13 general?
14 A He gave me a basic overall of'what to his 15 best knowledge is what transpired. He was pretty --
16 well, go ahead.
17 Q What understanding do you have of what had 18 transpired after your conversation with Mr. Frederick?
19 MR. MacDONALD: Are you asking-for specific 20 conversation as a result of the conversation 21 with Frederick?
- 22 MS. MCDONALD: Yes, if'he has one.
23 A I don't recall exactly what information I 24 got from -- you know, I had information from several
}
25 people, and I. don't recall what I got from Ed Frederick.
l 1 Illjes 112 i
^
(h
\/ 2 Q Did you have any conversations with Mr. ,
3 Faust?
4 A I can't remember if I did or not.
Q How about Mr. Zewe?
( 5 6 A I can remember talking with Mr. --
there 7 would be another person that was there.
, 8 Q Mr. Hitz?
9 A Correct.
10 Q H-i-t-z?
t 11 A I got to get my nights right.
12 Q' This was the first night you were there?
O\ 13 A Yes.
14 Q Do you remember any conversations with 15 Mr. Mehler? .
16 A I don't remember a conversa, tion specifically i
i 17 with him. I remember his face, but I can't remember l
i 18 talking with him. '
i 19 Q Did there come a time when M,r.-Chwastyk' 20 briefed you?
21 A Yes.
22 Q What did he tell you?
23 A That not to make any plant manipulations 4
24 without his specific orders, where my area of
{
s.
- 1 i
25 responsibility would be, and he briefed us basically
1 Illjes 113
[\ -
2 on conditions.
3 Q What conditions did he tell you existed?
4 A I believe that --
I can remember him
([ 5 talking about the condition of the reactor coolant 6 pumps being off and that'was obvious. We did not have 7 a bubble in the pressurizer. Some of the things he 8 mentioned about what was going on in the rest of the 9 plant. Whether or not that was him that gave me that 10 information, I can't --
e 11 Q Which information are you talking about?
12 A I didn't say the next information. I am 13 not sure whether that information I got from him, s o --
14 Q Let me ask you what information you are 15 referring to. ,
16 A Some of the environmental conditions. We 17 had water in the auxiliary building in the basement in 18 the auxiliary building.
19 Q You Jast mentioned that it was ~ obvious 20 that the reactor coolant pumps were off. Why was it l
)
21 obvious that they were off?
22 A We have indication on the panel of the 23 condition of the reactor coolant pump.
24 Q
\_
Let me refer you to the first entry you i
25 made on page 85, the first entry other than " Relieved
1 Illjes .114
/~'S b . 2 the shift" entry, it says " Attempting to collapse 3 bubbles in A&B hot legs by raising pressure."
4 How did you find out that there were
( 5 bubbles in the hot legs?
6 A I believe I was told that.
7 Q Who told you that?
8 A I don't recall who exactly told me that, 9 but that conversation was with -- I know that was 10 knowledge, common knowledge among the operators that 11 were there. We might have said something to each 12 ' other including Joe Chwastyk.
13 Q It was common knowledge that there were 14 bubbles in the hot legs?
15 A I remember something to that order.
16 Q Do you see that the next entry includes a 17 reference to pressurizer level and appears to say
~
18 " Pressurizer level 400 inches plus"?
19 Do you see that, the next entry, 1915 hours0.0222 days <br />0.532 hours <br />0.00317 weeks <br />7.286575e-4 months <br />?
l 20 It comes right after "T hot A 550 FT cold'." '
21 A Yes.
22 Q I take it you knew that since you wrote it 23 down?
[/)
\_
24 A That was indication.
25 g Did you discuss with anyone how it was
I 1 Illjes 115 l
(~)#
~
2 possible to have bubbles in the hot legs and, at the 3 same time, have a solid pressurizer?
4 A I don't remember discussing that with l[ 5 anybody in particular.
6 Q Mr. Illjes, did you express surprise to I 7 anyone that that situation existed?.
8 A I don't remember what my expressions were.
l 9 Q Did that remind you of any other event that 10 had occurred at the plant prior to the hree Mile 11 Island accident?
12 A No.
(')
(_) 13 Q That being you didn't remedber any 14 event where the pressurizer level had gone up, 15 pressurizer had become solid, and it was thought that 16 there were bubbles in the hot legs?
17 A No, I can't recall that.
18 Q Mr. Illjes, Mr. Mehler has testified that 19 he believes he had a conversation with you in which 20 the two of you-discussed an incident prior to the Three 21 Mile Island accident where there were bubbles or voids 22 or whatever you want to call it in the reactor coolant 23 system other than in the pressurizer.
24 Can you tell me about that conversation
(
25 wich Mr. Mehler?
l 1 Illjes 116 t ' 2 MR. MacDONALD: I object to the form.
3 Mr. Mehler testified to what he testified.
4 You can ask Mr. Illjes if he had a conversation l 5 with Mr. Mehler.
6 BY MS. MCDONALD:
I 7 Q Do you recall any discussion with Mr.
I
( 8 Mehler regarding an event that had taken place before I
9 the Three Mile Island accident involving voiding or 10 bubbles in the reactor coolant system gutside of the 11 pressurizer?
12 A I don't recall any such conversation.
O' 13 Q At any time. You don't recall ever 14 discussing that.with Mr. Mehler? I 15 A No, j
16 Q Do you recall today any incid nt at any 17 time at Three Mile Island other than the Three Mile 18 Island accident in which it was thought that there 19 were bubbles in the hot legs or voiding in'the reactor 20 coolant system in a place other than the pressurizer?
21 A No, I don't recall.
22 Q Referring to your testimony, to what you 23 said in your interview, B5W904, page 11:
"FASANO:
(
r}s 24 On your training... Let's get 25 off the subject here. You took over controls
l 1
Illjes 117 O 2 in this situation and, how did your training, 3 did it relate to what you had to do, or was 4 this a completely new situation to you or just
(! 5 how did your training background assist you in 6 performing your assignments?"
7 "ILLJES: As far as having a bubble in 8 more than one location, we never...let's see.
9 I don't remember discussing it in training. I 10 know it's, we had dropped the looks into the 11 pressurizer before during the testing program.
12 This was done, I think there was a time we had ~
O .
13 resin in our cooling system and we secured 14 reactor coolant pumps and we were in the 15 process of dropping pressure and in order to 16 cool the pressurizer and a little more quicker 17 than what we were experiencing. It.would have 18
- taken several days to cool down right an'd so 19 they wanted to speed it up, we dropped the hot 20 legs down and filled the pressurizer by...I'm 21 trying to think how that went, that's two years 22 ago."
23 "FASANO: So you were on shift when you 24 lost a level on the pressurizer. Is that what 25 you are saying?"
e 9 y 9 9
l 1
l 1
1 Illjes 118 I r~) i 2 "ILLJES: We didn't lose level. We went 3 solid, we didn't go solid, but we go solid in 4 the pressurizer and it was above 400 inches and k 5 we were in the process of getting on decay heat 6 system and we were depressurized or in the 7 process of getting depressurized."
8 I understand that it is a transcript of a 9 tape and it is a little hard to understand.
10 Can you tell me what inciddnt you were 11 referring to?
12 A I was mentioning the' resin and we had an b
\- 13 incident where a polishing system, the resin came out 14 of our polishing system and went into our demineralized 15 water system, got into our cooling water pump, pump 16 systems or cooling water systems.
17 Q This testimony refers to something about 18 the loops in the pressurizer.
19 What were you talking about there? What
. 20 was that aspect of this incident?
21 A Well, it says that we were cooling down too, 22 so if we were cooling down and depressurizing it's part 23 of a procedure where you drop the loops or candy cane
/~S
(_,1 24 part of the loops into the pressurizer.
25 g You mean drop the water? l l
1 i
! j 1
1 Illjes 119 j
- I
(~n N"
2 A You just depressurize -- the candy canes 3 are higher than the pressurizer, so you depressurize.
4 You can vent the pressurizer or vent the candy canes and then the level just then you depressurize and
(
5 6 then you use the decay heat cooling system as your 7 cool'ing -- the medium. In other words, we drop the 8 loops now and you can use the decay heat cooling system 9 as a means to cooling the reactor instead of the 10 reactor cooling pumps to pump it into ghe steam 11 generators.
12 Q When you do that procedure, are you s- 13 supposed to have a solid. pressurizer,450 inches of 14 water? 4 15 A It's possible that the pressurizer would 16 fill.
17 Q Mr. Illjes, in this testimony,you were 18 referring.to a specific incident, were yod not?
19 A Yes, this is the resin inciden't to where 20 the resin in the polishing system ends up in cooling 21 water systems.
22 Q I would like to show you portions of B&W 23 Exhibit 175. The pages I am going to show you are
[~)
%./
24 WO6066 through WO6079. B&W 175 is the shift test 25 engineers log.
, , e , . - - .
1 Illjes 120 2 Now, would you turn to page 06067 in that 1
3 log, which is an entry for September 7, 1977? Do you 4
see where it says, " Completed regeneration tank..." --
! l 5 do you think that is tank, "tk." --
" repair and cleared 6 tags. Nuclear service pump 1A/1B tripped on low cooling 7 H2O flow to motors. Tried to start nuclear service 8 pump 1C. It tripped within a minute. Pulled suction 9 strainers on all three pumps and found resin packed in 10 them. Resin has come from condensate polishers 11 through dimin. H2O up to..." -- that is what it says --
12 " nuclear service closed cooling water system through 0
13 auto makeup valve."
14 Is this the resin incident to'which you.
15 were referring?
16 A Yes.
17 Q Now, going on in this log, I would like
~
18 to refer you to page 06070.
~
19 Have you got that page?
20 A Yes.
2I Q A little up from the bottom is written, 22 " Opened RC-V155 and V137 and started venting the 23 pressurizer to the reactor coolant drain tank."
() 24 Do you recall being on shift when that 25 valve was open during this incident?
1 I11jes 121 1%
2 A I don't recall.
3 Q I will show you the control room log if 4 that will help you. Let me show you a portion of B&W
( 5 Exhibit 785, pages 385 through 399. B&W 785 is the 6 control room operators' log. I would like to refer 7 you to page 392 where it appears you are on shift.
8 Do you see that? j 9 A I am on 392, 8/7/77?
10 Q 'Right, 11:00 to 7:00 shift?g 11 A Right. I l
12 Q Do you see your name at the top of the
\- 13 page?
14 A Yes.
15 Q Would you look at the entry for 6/25 in 16 the morning? It says, next to that entry $ "Open..." --
17 next to that time, "Open pressurizer vent to reactor 18 coolant drain tank."
19 Do you see that?
1 20 A Yes.
21 Q Does this refresh your recollection that 22 you were on shift when the vent at the top of the 23 pressurizer was opened during this incident?
24 A As far as being -- this is Terry Thompson,
[(.)T 25 who was on shift or assigned into the control room i
1 Illjes 122 l
2 I don't remember him opening the pressurizer
^
log.
3 vent.
4 You were also on shift, were you not, Q
5 whether you remember the vent being open or not?
{
6 A During that time, I was also involved in --
7 since we had three CRO's, two of them could handle 8 what was in the control room at the time, and I was 9 involved in helping clean up the resin, taking different 10 systems apart and flushing the resin out of the t
11 strainers and different piping systems which the ,
12 resin got into.
13 Q Do you remember flushing th'e resins or 14 doing whatever you were doing with the resins 15 throughout an entire eight-hour shift?
16 A Oh, I believe I came up to eat lunch. I 17 came up to see what was going on. I don't remember 18 exactly what length of time I was in or otit of the 19 control room. -
' 20 Q Do you recall hearing that when the vent 21 at the top of the pressurizer was open the pressurizer L 22 level started to go up, continued to go up until it 23 reached a reasonably high level, approximately 320' 28 inches or more? .Do you remember hearing that, that V
25 it happened?
1 I
1 1
1 Illjes 123
~s 2 A No.
3 Q In the testimony, your NRC interview on 4 page 11, you were referring to or you meant going soild
( 5 in the pressurizer, and I would just like to know --
6 the testimony I just read you a little while ago, do 7 you see the last answer there under your name?
1 8 What were you referring to when you gave 9 that testimony?
10 A I am not sure, but part of ghe procedure 11 when you have the decay heat system on, you have a 12 decay heat spare line on going into the pressurizer.
ex -
( i '.
\/ 13 I'm not sure --
in other words, we could fill the 14 pressurizer up with the decay heat system if we were 15 cooling the pressurizer off. I don't recall exactly 16 uhat we were doing.
17 Q Let me refer you again to the, shift test 18 engineer's log you were looking at a secon'd ago. Let's 19 see if any of this refreshes your recollection that 20 when the pressurizer vent was open the pressurizer 21 leve. increased and then stayed high for some period L 22 of time? Would you look at the next shift after the 23 one we have just looked at? I am now referring to
("% 24 page 06071.
-1 25 Do you see John Ulrich's name at the top
I l
I 1 Illjes 124 m
2 of that page?
3 A .Y e s .
4 Q Then two-thirds of the way down the page 5 it is written,'" Pressurizer level unexpectingly
{
6 increased when venting the prensurizer and decreased 7 pressure from 500 psig to 460 p s i sj . Pressurizer level 8 increased about 150 inches during this evolution."
9 Does that refresh your recollection that 10 there was an unexpected rise in the pressurizer level 11 during this incident?
12 A No.
' O( /
. 13 Q Going to the next shift on the shift test 14 engineer's log, page 06072, halfway down the page do 15 you see a comparison was made between LT1-LT2-and LT3, 16 "All three were reading same. Pressurizer level 17 indication as shown in control room is believed to
~
18 be correct."'
19 And then going on down the page,"Whenever 20 RC-V137 was opened to vent pressurizer, level would i
21 indicate an increase." Do you recall there being any k_ 22 confusion or doubt as to why the pressurizer level 23 indicated so high, such that it was decided to verify 24 whether the level instrumentation was correct? Do 25 you remember that happening during this incident?
l
i i
1 Illjes 125 (h
2 A I don't remember.
3 Q I take it you don't remember either hearing 4 that or experiencing it?
( 5 A I don't remember it, and I don't remember 6 experiencing it.
7 Q I take it you don't remember that every 8 time RC-V137 was opened to vent the pressurizer, the 9 pressurizer level would indicate an increase?
10 A I don't remember opening RC-V137 and seeing 11 an increase in pressurizer level or --
12 Q o.K., let's go to the next shift. Page (O_) 13 06073.
14 Do you see it is written, " Closed RC-V137
,15 and applied nitrogen to the pressurizer. The 16 pressurizer level came down proving that there was a 17 steam bubble in each of the hot legs. Left nitrogen 18 on until pressure started to slightly incr~ ease and
,19 secured nitrogen." -
20 Do you recall being told that when pressure 21 was applied in the form of nitrogen that level came L 22 down proving that there was a steam bubble in each of 23 the hot legs, at least according to this entry?
/~N 24 A My recollection of this incident is that U
25 I know we had a problem with resin, and I remember
- - r
1 l
1 Illjes 126 gm .
\~ 2 having the cooling down part. I don't recall having i 3 any problem, as you say, a bubble in the hot legs.
I 4 don't remember that.
5 Q Do I understand you to be saying that it
{
6 was normal procedure to have a bubble in the hot legs 7 on occasion in the reactor coolant system?
8 MR. MacDONALD: I object to the form of 9 the question.
10 MS. MCDONALD: Strike that.
11 Q Do I understand your testimony correctly 12 that prior to the Three Mile Island accident you did n(_j 13 not consider it unusual to have a bubble in the hot 14 legs? '
15 A If it was a planned evolution to cool down 16 and depressurize, it wasn't called a bubble; it was 17 just that we equalized the level between the hot legs 18 or the candy canes and the pressurizer. There was 19 nothing abnormal about that. -
20 Q Did that happen all the time, any kind of 21 cooldown?
L 22 A It was a planned evolution where you would 23 cool down if you wanted to depressurize, you wanted to
(~T 24 work on a component and open the RCS, that was part V
25 of the procedure to go through that.
s
1 Illjes -127
's
(~J
\_ . 2 Q That involved pressure going down, 3 pressurizer . level going up, and a buSble in the hot 4 legs, is that correct?
5
( MR. MacDONALD: I object to the form.
6 He didn't testify to that.
7 MS. MCDONALD: Then I have misunderstood 8 the witness.
S A No, you have already been depressurized 10 and then the level changes or equalizes as you, 11 depressurize.
12 Q Now, do you have any explanation for why ~
(')T
(_ 13 it was apparently unexpected that pressurizer level 14 went up?
15 MR. MacDONALD: I object to the form.
16 Just so that we are sure, you are quoting 17 from somebody else who wrote this. .I don't 18 think the witness has ever seen it before.
19 You have no explanation for that?
Q 20 A I don't remember that situation. I told 21 you previously, but I was involved in what I can k_
22 remember, i 23 Q You recall absolutely no conversation about p}- 24 this incident that did not have to do with resins, is 25 that correct?
l 1 Illjes .128
. 5 A say it again, please.
3 Q You remember no conversations at all about 4 this incident that did not have to do with resins, is 5 that correct?
((
6 A I can remember talking to, I think it was 7 one of the people from the startup organization and 8 cooling down. I don't remember exactly what I said.
9 And I can remember being with an auxiliary operator 10 and an STE and involved in cleaning up ' resin. That 11 was when I was outside of the control room and I was, 12 I believe I had something to do in the control room O
13 with the cooling down and equalizing pressure. I'm 14 not clear. I don't remember exactly, you know, that 15 exact sequence of events.
16 Q What person from the startup group did 17 you have the conversation with about cooling down?
18 A I could give you a number of them, but I 19 can't tell you which one it was exactly. 7 I can remember 20 the different startup people, but I don't remember.
21 Q What startup people do you remember being L 22 there, being around at the time?
23 A John Ulrich, Craig McMullin, Andre
(. 28 Dominguez, Tom Hawkins, Ron Toole, Jack Garrison, 25 Carl Gatto. I remember those - were the people that
1 Illjes . 12-9 L .
\ '
2 were lirectly involved.
3 Q Do you recall discussing this cooldown 4 with one of those gentlemen, but you don't remember 5 which one?
(
6 A No, I don't remember which one.
7 Q But it was one of the ones you just 8 mentioned?
9 A I believe.
10 Q Would you refer to page WO6.079 of the 11 startup log you have been reviewing? It is the last 12 page.
(_) 13 Do you see an entry there that is 14 apparently signed by Mr. Toole, number 67, "There is no 15 reason given for how we got in,to problem on pressurizer 16 level. A change to cooldown procedure could be made 17 if we knew what to do." .
~
18 Does that refresh your recollection in any 19 way that what happened during,this event about 20 pressurizer level was not normal or expected?
- 21. A No.
22 Q Did you have any conversations with.Mr.
23 Toole about this incident that you can remember?
- 24 A' I don't recall having any conversations
-25 with him.
i
}
l Illjes . 130 e's .
U 2 Q Do you recall receiving any training from 3 Met Ed regarding the behavior of pressurizer level or 4 the thought that there might have been bubbles in the 5 hot legs during this' incident at any time, training at
(
6 any time?
7 A After the accident?
8 Q After the accident, what training did you 9 receive regarding this incident?
10 A You are talking about -- which incident 11 are you talking about now?
12 Q I am talking about the incident that we O
k/ I thought you meint the accidert 13 have been reviewing.
14 part. I'm sorry.
15 ,
Let me ask it again.
16 Do you recall receiving any training from 17 Met Ed with regard to the behavior of pressurizer 18 level with the thought that there were bubbles in the 19 hot legs after this incident that we have been reviewing 20 here today on the shift test engineer's log?'
21 A After the accident, we discussed conditions L 22 like this. We were a lot more aware of what this could 23 possibly be a result of, but before the accident I
(} 24 don't recall ever discussing this particular problem 25 or what might be the problem as it is related to.
~ . . . . - - - . . - . - - - -. -_ . .- _ - -..- - . - - . .
i 1 Illjes . 13 t . ,
l 1
2 Q You don't recall discussing this being 3 trained on this specific incident, this being the one i
4 we have been looking at on the shift test engineer's ;
( 5 lo9 prior to the accident?
6 A I don't recall any specific training on 7 this incident. As a matter of practice, though, if 8 significant events did occur we did review either on
, 9 shift or off shift in the training' department.
q 10 Q Were you aware, looking aga,in at Mr.
1 l 11 .Toole's entry, were you aware of any reanalysis of the 12 cooldown procedure that took place after this incident,
-O 13 this being the September '77 incident, but before the 14 Three Mile Island accident?
15 A We have many, many procedures and 16 procedures are subject to change, and it's possible 17' that this was changed, but-I don't remember that i
18 .specifically.
19 Q Did you become aware of any evaluation of 20 this September '77 incident tha't was done after.the 21 . accident by GPU or Met Ed?
~ k. .
2 22' A _After the accident?
, 23 - Q What I am asking you is,.did you become 24- aware of a post-accident evaluation of this September 25 77 incident that was done by Met Ed or GPU? _
J
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- 1. Illjes 132 -
2 1 7, Not specifically of this incident that I
, s 3 can reca.11.
4 t Q; Whnn you say "not specifically of this
( 5 incident," do you mean something was done generally?
6 A Well, as I said, we now have a much more --
7 we are much more aware of the saturation conditions in 8 the core and what could affect them than we were at s' this time.
F 10 Q Let me just ask you, have you ever been, 11 that you remember, itMked to or interviewed b'y anybody 12 from GPU or Met' Ed as to what you might remember a' bout A
13 this September '77 incident? ,
14 A If an incident or a report was writien on 15 it, it might have cone across for me to read along.with 16 stacks and stacks of other things.
iy 17 Q Let me just ask,rou, have you.ever seen --
18 I show you B&W Exhibit 837 entitled "TMI b September 19 1977 Hot Functional Testing Event.." It.- begin s , "On May 4 ,
20 21, 1981 at the request of R. C. Arnold, an '
21 investigation began into the circumstances surrounding-b ,
an event at TMI-2 'o'ccurring September 1977, in which 22 ,
N_ -
,- Q 23 steam was introduc'ed into 'the he t ' l'e g s . " '
1 s
D Y (j 24 Let me just ask.you, have you ever seen' 25 that document before today? I am not going to ask ou, ,
l
\ !
\ __ J s:
i 1 Illjes 133 7~
e l 2 about it. I just want to know if you have ever seen 3 it before.
4 A I don't recall seeing it in this form.
5 Did you see it in some other form?
(( Q 6 A 'I would ^ say if Met Ed went to the trouble 7 of putting it in this sort of document, it would have 8 been reviewed in the training department, but there 9 are many incidents that we do review and I don't 10 recall this particular incident specifically.
11 Q You don't recall being trained on this 12 . event after the accident?
\" '
13 A As I say, if Met Ed or GPU put it into
- 11. document form, then I would probably have had -- it 15 would have been reviewed by me, but I review quite a 16 few events and for me to discern from one to another 17 and remember the specifics of one, I' don't recall this l - 18 one. .
19 Q Let me show you another docume'nt and let 20 me just ask you whether you have seen this. I show 21 you'B&W Exhibit 838, and ask you whether you l' ave ever 22 seen'that. It is GPU Nuclear Technical Data Report 23 dated October 16, 1981. I ask you, have you ever seen O)
(w.,< 24 that before today 25 Again,'Mr. Illjes, I am not-going to ask
1 Illjes 134
(~%, '
'd 2 you any questions about it. I just want to know 3 whrther you remember ever seeing it.
4 A This is after the accident?
l 5 Q Yes.
6 A Not specifically, no. I don't remember 7 seeing it. Like 7. say, this sort of thing does come 8 across my desk and --
9 Q You don't remember, I take it, seeing any 10 reports or analyses of this September '77 event before 11 the accident?
12 A I don't recall. ,
\- 13 Q other than the September '77 event, are 1
14 you aware of any instances at Three Mile Island that 15 occurred where there was voiding in the reactor coolant e
16 sys. tem in a place other than the pressurizer up to the 17 time of the accident, I am talking about?.
18 MR. MacDONALD: I object to t e form.
.19 Q Do you recall any events whers there was 20 voiding in the reactor coolant system in a place other 21 than the pressurizer, any transients?
22 A Did you say, as a result of transients?
23 Q No, any transients or incidents. l I
'M/[) 24 A When you go from a depressurized condition, l 25 you will have some voids till you're pressurized and 1
i
-1 Illjes 135 2 you vent the void off.
Q Hw d y u vent the voids off?
3 4 A You pressurize your pressurizer or you can 5
f rm a bubble in your pressurizer or you could use
({
6 nitrogen and then you can vent the high points, like 7
I mentioned before, when you equalize level between 8 the candy canes or the hot legs and the pressurizer.
9 Well, to push that order back up there again, you 10 would pressurize in the pressurizer and vent out of
(
11 the top of the candy canes and also out of each of 12 the control rod drive mechanisms.
13 Q when you say " vent out of the top of the g4 candy canes," there was a vent at the top;of the candy
, 15 canes out of which those voids could escape while you 16 were putting pressure on the pressurizer?' Is that 17 what you are saying?
18 A There is a valve up there to vent the 19 nitrogen or whatever kind of gas was up there.
20 Q Could those vents be opened from the 21 control room?
L 22 A No.
23 Q Do you remember being aware of any transient 24 during which there was voiding in the reactor coolant v
25 system at a place other than the pressurizer prior to
~
1 Illjes 136
(
- - the Three Mile Island accident?
2 3 A I d n't recall any voiding.
4 Q Is that a buzz word for you, you could call it bubbles or voids or steam?
([ 5 6 A No, whatever you want to call it.
7 Q We are on the same wavelength?
8 A Yes.
9 (Recess) 10 BY MS. MCDONALD: t 11 Q Just one more question about this normal 12 cooldown evolution that we have been discussing.
[ .
\ 13 was it a part of that cooldown procedure, -
14 was it a normal part of that coold,,own procedure to 15 allow the pressurizer to become full of water, namely 16 for 400 inches or greater, for any substantial period 17 of time? ,
18 A You are still talking about the resin 19 situation. You are referring to the resin' situation.
20 Q No, I am not. You mentioned in our 21 discussion of the resin situation a normal cooldown L 22 evolution that you seem to be familiar with and you 23 talked about equalizing level and pressurizer in the
[~)
./
24 -hot leg and venting the hot leg.
25 Do you recall our conversation about that
1 Illjes 137
/s -
!) 2 cooldown procedure? Right, you just talked about that 3 a little while ago, and I am asking you in connection 4 with that, was it your recollection that one of the
( 5 things that would normally happen during that would 6 be that the pressurizer would be full of water, 400 7 inches or other, for a substantial period of time?
8 A You say it would be normal? No, that was 9 a different type of cooldown situation, because if I 10 remember correctly we didn't have cooling water 11 components, systems, reactor coolant pumps weren't 12 operating. I'm not sure why we were at 400 inches, O
\- 13 but I believe it had something to do with also cooling 14 the pressurizer off. You could run water-into the 15 pressurizer.from the decay heat system, and I am not 16 sure if that was the reason.
17 Q Mr.'Illjes, during the break, we just had
~
18 a break, did you in some way refresh your recollection 19 about this resin incident that you are now'able to 20 talk about the pressurizer and you remembered something 21 more than you remembered before?
L 22 MR. MacDONALD: I am going to instruct the 23 . witness not to discuss anything that is discussed
[)
'v 24 between the witne s s and counsel. That is 25 privileged information.
1 Illjes 138 ,
2 Q Can you tell me now whether now you 3 remember, wherever you got it --
4 A No, you are asking me if it was a normal condition; I am saying this could be possibly what
( 5 6 happened. I don't recall exactly what happened, but 7 by filling the pressurizer, you want to know why the 8 pressurizer was at 400 inches, and I said and it 9 also -- the cooldown situation, I don't remember 10 exactly how it went, but I'm saying possibly by 11 raising the pressurizer level up to 400 inches with 12 the decay heat system, with the pressurizer spray line, 13 that this would enhance cooling down the pressurizer.
4 14 I'm not sure if this was a reason for the pressurizer 15 being at 400. As I said before, I don't remember the t
16 incident well enough to go into specifics.
17 Q So you are saying today that that is one 18- possible reason for it.
19 Is it also a possibility that 'the bubbles ,
20 in the hot legs causeo the pressurizer level to, increase?
21 Is that another possibility that you just speculated L 22 upon, one possibility that you might prefer? Now, I 23 would like to know, is it also possible that bubbles f( )
w,-
24 in the hot legs caused the pressurizer to increase?
25 MR. MacDONALD: You can ask him about his
1 Illjes 139 2 recollection prior to the accident and what he 3
knew about an incident, what his understanding 4 was, but I am not going to have him sit here
( 5 today'and opine on what his understanding might 6 be based on knowledge he has today.
7 MS. MCDONALD: Mr. MacDonald, he has just 8 volunteered a speculation today, which, if that 9 is your view, I would like to have stricken from 10 the record. .t 11 MR. MacDONALD: You can make any motion 12 you want.
. - (~5 s
^
( j' 13 MS. MCDONALD: Can we strike it right now?
14 MR. MacDONALD: You can make any motion you 15 want.
16 MS. MCDONALD: I mean physically strike it 17 today. .
18 MR. MacDONALD: That was an answer to a 19 question. Your question was improper.
20 ES. MCDONALD: He volunteered something 21 that you consider improper, and you refuse to L 22 strike, is that correct; 23 MR. MacDONALD: He answered a question.
f'}
'4 /
24 You asked a question. I can object to your j 25 question and direct him not to answer.
I l
1 Illjes 140 o -
Do you recall, then, that it was not 2 Q 3 normal to have pressurizer level go up to 400 inches 4 during normal cooldown evolution?
5 A In a normal cooldown evolution --
({
6 Q And remain there for a substantial period 7 of time?
8 A It's possible that we could cool down in 9 a normal evolution and go to 400 inches and remain 10 there for a period of time for a specific purpose such 11 as hydrostatically testing the RCS.
12 Q I asked you, is that a normal thing to k 13 happen during dooldowns that you have experienced?
14 A Well, first, we weren't in a normal 15 situation.
16 Q I am not asking about this situation; I 17 am asking you about a normal cooldown. ,
18 MR. MacDONALD: What is a norm'al cooldown?
19 MS. MCDONALD: Well, he just s' aid this one 20 wasn't normal. I would like to know if it was 21 so in a normal cooldown that the pressurizer C 22 level would be up around 400 inches for a
~
23 substantial period of time.
()
.v 24 A It would depend on what my orders were to 2
25 leave'what pressurizer level would you want to end-up e t
1 Illjes 141 m
2 at.
3 Q How many times before the Three Mile 4 Island accident did you see the pressurizer solid 400
( 5 inches or more for a substantial period of time?
6 A I know we were solid for this hydrostatic 7 testing.
8 Q Any other time that you recall?
9 A There were other times in which we 10 hydrostatic cested RCS every time a pqessure boundary
- 11 was taken apart and put together.
12 Q Do you recall anything other than a
("T -
'Y 13 hydrostatic test?
14 A I don't recall any.
15 Q You don't recall any?
16 A I don't recall any other. ,
17 Q You characterized this September '77 18 incident as not a normal cooldown.
19 Were you aware at the time that it occurred 20 that it was not a normal cooldown?
21 A I am using that word now as a normal 22 cooldowns in other words, once you are in operation and 23 you are using an operating procedure, say going through
[)\
~
24 a normal cooldown, but at that period.what would you 25 .want to call normal? You went from one test procedure
1 Illjes 142
[
\~
2 to another, and it was a different situation for 3 each test procedure, so I really, you know, --
4 Q Mr. Illjes, this incident took place ,
( 5 during hot functional testing, did it not?
6 A Yes.
7 Q Isn't the purpose of hot functional 8 testing or one of the purposes to test the behavior 9 of the plant and the operation of the plant at 10 parameters approaching those which would be seen in 11 operation even though there is no core, I understand?
12 A Wo would test parameters at normal
(~h '
13 operation, but we would also test parameters of 14 abnormal operation also.
15 Like what?
Q 16 A Reactor coolant system temperature.
II Reactor coolant system pressure, ,
18 Where would you test the reactor coolant Q
19 system temperature for abnormal conditions'during 20 hot functional testing?
21 A You could use it to test the reactivity 22 coefficient of the reactor coolant, the moderator 23 coefficient of the reactor coolant.
() 24 - Q How about the pressure? How would you 25 test that?
1 Illje's 143 2 A Hydrostatic testing.
3 Q That went under a hot functional testing?
4 A Well, hydrostatic tests went on during hot
( 5 functional testing. It went on, in other words,every 6 time we lifted the head off, we had to hydro, so 7 hydrostatic testing went on during hot functional 8 testing.
9 Q Was hydrostatic testing going on during 10 this resin incident? 1; 11 A Not that I recall.
12 Were you aware before the Three Mile Island Q
'd 13 accident of an incident that took place on April 23, 14 1978 at the Three Mile Island plant Unit 2 in which the 15 steam safeties faile.d to reseat, among other things 16 happening?
17 A I remember -- you are talking.to the main 18 steam safety valves?
19 g yes, .
20 A I remember that we were supplied with a 21 new type safety valve and we had problems with safety 22 valves, the length of time at which the safety valves 23 would blow down or stay open.
) 24 Q Do you recall this' specific incident in 25 April of '78?
--_-----__..___-._a - - - - _ _ . - _ _ _ - - - == ~
1 1 Illjes 144 2 A The problem existed during hot functional
, 3 testings I'm.not sure of the date. I don't remember 4 the exact date. It was a period of time we went to a testing program to test the relief valves
([ 5 6 specifically.
7 Q Is it your recollection that this took 8 place in hot functional testing as opposed to a later 9 testing program, power escalation testing program?
10 A Yes, that was after a fuel Joad.
11 Q I am talking about an incident after fuel 12 load, right.
- 13 A Yes, you are saying --
14 Q I am asking if you recall an incident 15 after fuel load where the main steam safeties failed 16 to reseat.
17 A Yes, I recall that.
18 Q Do you recall that that event' caused the 19 plant to be shut down for some months, I think?
20 A Yes.
21 Q Were you ever given any training on that 22 event, the event after it happened,and before the 23 Three-Mile Island accident?
24 A You mentioned an event. My part in a steam
. [)T 25 -safety valve was to determine whether an-inherent
.,n -
1 Illjes 145 v) 2 problem existed with the safety valves, and I recall 3 that part of.the event in which we tested the safety 4 valves by raising reactor coolant system temperature,
( 5 laying the safety valves below, they blew below the 6 required reset point, and then it was termed that 7 the relief valves were faulty equipment and we were 8 shut down for a long period of time until they were 9- replaced. That's what I remember.
10 Q But you don't recall whetha,r you were 11 there for the event or not? You don't recall someone 12 coming to you and saying, "Now we are going to train
) 13 you on what happened to the plant parameters during 14 this evolution in which the steam safeties blew or 15 failed to reset"?
1G A I don't Lecall a specific instance in 17 which that incident was reviewed, although, again I 18 - say, we do review problem areas, and-I'm.not sure which 19 one you are talking about as far as the in'cident 20 that -- you are saying that we.had a problem with a 21 steam safety valve and you didn't give me'any detail.
22 Q Let me show you B&W 246, and see if this 23 helps place in your mind the' incident I am referring
() 24 to. I am sure you don't have to read the whole 25 document.
1 Illjes 146 O
V 2 A What was the date?
3 Q Of the incident? April 23, 1978.
4 A I don't remember being on shift at this
( 5 time.
6 Q Were you told about the event?
7 A I don't remember the specifics of the 8 details, but this incident, I believe, led up to 9 the testing program which I was involved in, which we 10 tested the relief valves. t 11 Q You were a control room operator, Mr.
12 Illjes.
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~
' -\J 13 was it the practice of Metropolitan Edison 14 to tell control room operators about transients that 15 took place on shifts other than their own in order that 16- they might be aided in doing their jobs as a control 17 room operator? ,
18 A Yes.
19 Q But you don't recall today,any'way, being 20 trained about this particular incident other than your
. 21 recollection that it led up to main steam safeties kJ 22 being tested and replaced?
23 A I don't remember receiving this specific (3
4 ,/ 24 training as normally given in this type of incident.
25 Q Do.you recall seeing this document ever
1 I11jes 147 2 before, B&W Exhibit 2467 3 A No, I don't recall.
4 Q I take it from your prior answers that no
( 5 one told you that flashing had occurred in the reactor 6 coolant system in a place other than the pressurizer 7 during this April 23, 1978 incident, and I am not trying 8 to say it did or did not; I am just asking you, did 9 anyone tell you that flashing had occurred in the 10 reactor coolant system other'than the p'ressurizer 11 during this event?
.. 12 A No one had told me that. ' '
\~/ 13 Q Are you aware of any event prior to the 14 Three Mile Island accident and during the time that 15 there was fuel in the reactor vessel in which .
16 pressurizer level rose at the same time that pressure 17 fell? .
18 A You say the pressurizer level rose?
19 Q The level increased and pressure fell at .
20 the same time.
21 A You want me to recall a specific instance k-22 when that occurred?
23 Q Yes.
[)
.v 24 A I can't recall a specific instance when that 1!5 - occurred.
I l l
l l
1 Illjes 148
%)
2 Q Do you have some general recollection of 3 when that occurred?
4 A Not prior to the accident.
( 5 Q Let me show you a portion of B&W Exhibit 6 176, pages WO6452 through WO6454. There is an entry 7 for March 29, 1978. I am going to refer you to page 8 06453.
9 Do you see, at the bottom of page 06453, at 10 1440, it appears at this time that "dur'ing ES testing 11 the fuse on 2-1V inverter blew and gave a reactor trip 12 and a full ES actuation. The electormatic relief, valve 0 13 lifted and pressurized the RC drain tank to approximately 14 100 psig. The inverter was put on alternate source and 15 the HP injection stopped"?
16 Going on, skipping a little, "The 17 pressurizer level was increased to approximately 200 18 to appro imately inches. RCS pressure decreased i
19 1200 psig before recovery started."
20 Do you recall previously today that we. ,
21' discussed'an incident that you did recall about-losing 22 power to the electromatic relief valve and'that it-23' stuck open --
that it was opened and remained op'en j
= 24 when it should have been closed? Is this that O
25 incident'that you were referring to?
l
1 Illjes 149 O
V 2 A Yes.
3 Q Now, do you see the entry that I just 4 read regarding pressurizer level was increased to
( 5 approximritely 200 inches,RCS pressure decreased to 6 approximately 1200 psig before recovery started?
7 Do you recall that happening during this March 29, 8 1978 incident?
9 A I remember the incident. I wasn't at 10 the panel at the time of the incident.(I don't 11 remember the specific -- this set of parameters as 12 occurring.
-s ,
') 13 Q Do you recall having any discussions with 14 Mr. Ulrich about this l'n cid e n t , anything about this 15 incident?
16 A No, I was not --
it was not my practico 17 to read his log. His log was kept in his.own office 18 that they had off the control room, and i was not 19 available to us as far as I was concerned.
20 I take it no one told you prior to the Q
21 Three Mile Island accident that pressurizer level may 22 have increased while pressure dropped during this ;
23 March 1978 incident?
/~h o4 i ) ~ A I don't recall discussing those two 25 parameters with anyone after the incident. j 1
1 Illjes 150
~
[%)\
2 Q After this March '78 incident, you mean?
3 A Right, after this time period.
4 Q Let me ask a clarifying question.
( 5 Do you recall discussing those two 6 parameters with anyone prior to the 1979 accident at 7 any time? I think I misunderstood your last answet.
8 A Well, the incident itself was brought up 9 in training, I can remember, and it resulted in 10 installation of a light on the e le c tr om'a tic relief 11 valve.
12 Q The training to which you just referred ~
O'J 13 occurred prior to the Three Mile Island accident, is ,
14 that right?
15 A correct.
16 Q Do you recall anyone in that training 17 telling you anything about what the pressurizer level 18 or the pressure did during that event? Namely, the 19 March 29, 1978 event.
20 A As I said, I don't recall specifically 21 discussing that with someone. We covered the 22 incident in training. I don't recall the exact nature 1
23 of the discussion.
J 24 Q Except you remember something of the light? -
25 A I remember going over the light was added
1 Illjes 151
/N 1
\_/
2 somewhere downstream or after that.
3 MS. MCDONALD: I have no further questions.
4 MR. MacDONALD: Off the record.
( 5 (Discussion off the record.)
6 (Recess) 7 EXAMINATION BY MR. MacDONALD:
8 Q Mr. Illjes, do you recall testifying 9 earlier today in this deposition on the subject of 10 leak rates? E 11 A Yes.
12 Q Do you recall testifying about the 13 technical specifications in respect to leak rates?
14 A Yes.
15 Q What was your understanding of the 16 technical specification requirements as they applied 17 to the four-hour time period you testified to earlier 18 today?
19 A That within the four-hour period that we 20 either got a --
satisfied that leak rate requirement 21 by requesting another one from the computer, or we 22 identified the leakage to satisfy the action statement.
23 Q During the time that you were a CRO on O)
(, - 24 Unit 2 performing leak rates, did you.ever perform a 25 leak rate test where you exceeded a one-gpm unidentified
- - . , y- - - , .we
1 Illjes 152
~
N i
- ~
2 leak?
3 MS. MCDONALD: Objection. Asked and 4 answered.
( 5 A We sxceeded, but within the four-hour 6 period we identified the part of the one gallon a 7 minute, greater than one gallon a minute, as being 8 identifiable leakage.
9 Q Did you ever have a situation when you 10 performed leak rate tests as CRO on Unit 2 where 11 within a four-hour time period you had not either, 12 after obtaining a leak rate in excess of one gpm, O-.
s- 13 that you either had not identified the source of the 14 excess unidentified leakage or performed another 15 leak rate which resulted in a less than one gpm ,
16 leakage rate?
17 MS. MCDONALD: Mr. MacDonald,.you are 18 referring to another leak rate within the four 19 hours?
20 MR. MacDONALD: Yes.
'21 A Not to my knowledge.
22 Q Do you recall testifying earlier in this 23 deposition, Mr. 111jes, in response to a question by rx
(} 24 Ms. Mcdonald about management awareness of practices of )
- 25. taking, repeatedly, leak tests?
I 4
m,
v.
1 I11jes 153
/~T '
( )
~?' A 2 Yes. .
3 Q Who were you referring to when you testified 4 about Met Ed management?
A shift foreman, shift supervisor.
( 5 6 Q Anyone above that position?
7 A No, not that I recall.
8 MR. MacDONALD: I have no further questions.
g BY MS. MCDONALD:
10 A I have one or two questions.
11 so I understand your testimony on 4
12 cross-examination, Mr. Illjes, was it your O
13 understanding of the technical specifications on leak 14 rates that at any time that a leak rate in excess of 15 one gallon per minute unidentified was obtained within 16 four hours, you must either get an acceptable one i
17 or identify the excess? .
18 A Correct.
10 Q I just want to make sure I understand you, a
20 .
Since we are back on the subject of leak 21 rates, where did you get the understanding that it l
22 was an acceptable practice to throw out leak rates l
23 which were obtained which were in excess of technical l l
( 24- specifications?
25 A. This was a common practice'among the 4
,. = , , -
i
)
1 Illjes 154 ;
I
- g .
2 operators, to my knowledge, and to who, I never received 3 any objection to throwing out the leak rates. It was 4 also an information item. If you want to know what
( 5 the leak rate was, it was considered an information 6 item, not necessarily a piece of paper which was a 7 legal document. It was a piece of information that 8 was available to us, but not some sort of document that 9 we held on to.
10 Q But acceptable leak rates Were documents 11 that you held on to, is that correct?
12 MR. MacDONALD: I object to the form of
~
(1) 13 the question. .
14 Q Leak rates that were within the tech i
4 15 specs were documents that you held on to, is that 16 correct?
17 A Acceptable rates were filed with the 18 surveillance procedure and signed as an acceptable 19 or an approved surveillance procedure to satisfy the 20 tech spec.
21 (continued on next page) 22 23
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25 i
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- - 1 Illjes 154A 1
2 MS. MCDONALD: I have no further questions.
3 Thank you,Mr. Illjes.
4 THE WITNESS: You're welcome.
1 f .
( 5' (Time noted: 4:45 p.m.)
6 !
1 7 THEODORE F. ILLJES
! 8 Subscribed and sworn to 1
I 9 before me this day' i
10 of , 1982. t
! 11' 4
12
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. 14 1
15 4
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l 1
155 l 2
CERTIFICATE 3 STATE OF NEW YORK )
- ss.:
4 COUNTY OF NEW YORK )
f- s Le^. 5
.{
6 I, NANCY A. RUDOLPH , a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9 of THEODORE F. ILLJES Was taken Defore 10 me on Tuesday, August 10, 1982 ;
11 That the said witness was duly sworn 12 before the cor::mencement of his testimony and O
- ta thee the within trenecr1pe is e e=ue secord of seid 14 testimony; 15 That I am not connected by blood or 16 marriage with.any of the parties herein nor
- 17 interested directly or indirectly in the. matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set
-. 21 my hand this .74 day of [... . c. ,
, 1982.
22
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23
'7 . O ,0.v.b-l../_
/
24 NANCY A. RUDOLPHj 25
_ __ . - _ . ~ _ _ . _ _ _ _ _ - - .-
i l l
l August 10, 1982 156
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I N D E X s
WITNESS PAGE
- Theodore F. Illjes 4 i
- EXHIBITS ' -.
'Q :, . lD r 9 y h' ]' , .
, -llC
(
B&W FOR IDENT.
903 Pages 1 through 98 of contrb1 i room log from February 14, 1979 through September 3, 1979. 67 i ,
4 904 Transcript of a tape recorded
, conversation between Mr.
Illjes and two gentlemen from.
l the NRC. 76 i
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