ML20072H769
| ML20072H769 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/30/1981 |
| From: | Rosalyn Jones BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-GB NUDOCS 8306290732 | |
| Download: ML20072H769 (143) | |
Text
.
D LJ UNITED STATES DISTRICT COURT SOUTIIERN DISTRICT OF NEW YORK
g GENERAL PUBLIC UTILITIES CORPORATION, a
k JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and i
dq p PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, s
80 CIV. 1683
-against-(R.O.)
" TIIE BABCOCK & WILCOX COMPANY an,d J.
RAY McDERMOTT & CO.,
INC.,
Defendants.
X O
Deposition of defendant The' Babcock
& Wilcox Company, by ROBERT C.
- JONES, JR.,
taken by plaintiffs pursuant to notice, at the offices of Kaye, Scholor, F i e r m 'a n, Hays
& Handler, Esqs., 425 Park Avenue, New York, at 9:45 New York, on Tuesday, June 30, 1981 4 o' clock in the forenoon, before Joseph R.
1 Danyo, a Notary Public within and for the 1
State of New York.
(
oov's seeoaTimo '"c-O CERTIFIED STENOTYPE REPORTERS 369 t.exiNGTON AvCNUC l
ggg9 Ntw Y asc. N.Y.
ICQ17 PDR ADOCK 05000289 PDR TstteNoNE 212 = 867 8220
.<Ouw:
x 2
Appeara nce s:
f 3
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue
{(
5 By:
RICHARD C.
SELTZER, ESQ.,
6 of Counsel 7
DAVIS, POLK & WARDWELL, ESQS.
8 Attorneys for Defendants One Chase Manhattan Plaza 9
(
10 By s.
RODMAN W.
BENEDICT, ESQ.,
of Counsel 11
/~h 12 Also Present:
]
13 DAVID TAYLOR 14 15 16 IT IS HEREBY STIPULATED AND AGREED by and 17 between the attorneys for the respec}tiveparties 18 hereto that the sealing, filing and certification 19 of the within deposition be, and the same hereby 20 are, waived; that the transcript may be signed 21 before any Notary Public with the same force and m
22 offect as if signed before the Court.
23 IT IS FURTHER STIPULATED AND AGREED ti.
all G
.. f )
- x. -
24 objections, except as to the form of the question, 25 are reserved to the time of trial.
'k
g.
. v.
.y 7
s o
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_tg I'
s'q
1 3
s OL 2
ROBERT C.
JO NES, JR.,
having g
y 3
been first duly sworn by the Notary Pt;blic,, was s.
4 examined and testified as follows:
F 5
EXAMINATION BY MR. SELTZER:.AJ
,\\
Q 6
Q State your nmop and address, please.
'\\
7" A
Robert C.
- Jonos, Jr.,
418 Wood 1.and, Circle, 9-I' s
8 Lynchburg, Virginia.
e s
9 Q
What is your present position?
s w
10 A
I am a supervisory engineer in the.ECCS Analysis
(
11]
unit.
/~
12 Q
Do you report.to Bert Dunn?
13 4,,,. h Yes.
'q s
14 Q
You have held that position and reported
,5 to Dunn Yor approximately how many years now?
Y
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s'4 s!
16 A
Two years.
s;
~
17 Q
I interMed to include-the years in which
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18 you were acting supprvisory engineer.
v s
19 A
That is roughly six years.
i aj
}.
20 Q
In othe:t words, since approximately 1975 21 you have c. ther boon acting sup rvi.sory engineer or
~
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i 22 supervisory wnginocr reporting to Bert Dunn in B&W's 4
s m-23 ECCS Analys'is unit?
C'1
,?
s.
V 21 A
Yes, th a t' s igo r re ct.
4; t
/
lt s
m-25 Q
Did you graduato with' honors fr' Penn
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s s
i
' l.m.
.x.
m...-. -
M,;-
- : =;3 ; _ i
1 Jones 4
0-2 Stato in June 19717 3
A No.
4 Q
Did you prepare any written thesis or 5
senior project as part of your program in getting a 6
bachelor of science in nuclear engineering?
7 A
No.
O Q
Have you received the master's degroo 9
that in the past you have been pursuing at Lynchburg 10 collego?
11 A
No.
("%
12 Q
Are you still pursuing it?
(_)
~
13 A
I have not been pursuing it actively the last 14 year.
I intend to pursue it, but the last year or so 15 I have not been.
16 Q
Is there any particular area that you are 17 specializing in in that:now suspended master's degree i
18 program?
19 A
It was a massor's degree in physics, but I 20 haven't figured out which direction I was going to 21 take.
22 Q
Have you ever published anything?
23 A
Other than B&W topical reports, no.
b /
24 Q
llave you ever spokon before any group 25 other than in your capacity as a paid representative
(-
4
i 1
Jones 5
g3 U
2 of Babcock & Wilcox?
3 A
No.
4 Q
On what previous occasions have you 5
testified about incidents relating to the Three Mile 6
Island calamity?
I 7
A Relative to the accident, I have testified to the i
j 8
Rogovin itiquiry team, an ASLB hearing for TMI-1 9
restart,and an ASLB hearing for SMUD.
t 10 Q
Have you been interviewed by anybody with 11 regard to facts relating to the Three Mile Island 12 accident?
13 A
Other than the Rogovin investigative mean, not i
14 that ! can recall.
15 Q
What, if anything, have you written with 1G roupoet to the Three Mile Island accident?
17 MR. BENEDICT:
You
+7+an that sent outsido 18 of B&W7 10 MR. SELTZER:
No.
20 MR. BENEDICT:
Anything he has ever written 21 about the Throo Mile Island accident?
i 22 MR. SELTZER:
Yes.
23 MR. BENEDICT:
Other than for counsel.
(
24 A
Thoro were some reports that woro writton where 25 wo exercisod our computer modols and benchmarked theta g.
I
(
l
( g-1 Jones 6
D 2
versus the events that happened at TMI.
Other than 3
that, that is all I can remember.
4 Q
Have you ever written any lessons learned 5
from the TMI accident?
6 A
No.
7 Q
What writing did you do on the day of the 8
accident regarding the accident?
9 A
None that I can remember.
t 10 Q
Didn't you take some notes a't Allen 11 Womack's section meeting on the morning of the
(
12 accident in which you wrote down some of the plant 13 paramotors that were being relayed to the section 14 noeting?
15 A
Not that I can remember.
16 Q
I would like to show you GPU Exhibit 96 17 previously marked for identification.
It} states on 18 the cover " Notes of R.
C.
Jones on 11 a.m.
March-28, 19 1979 staff briefit.g for plant design."
k 20 Do you have that in front of you?
(-
21 A
Yes, I do.
91 Q
Would you take a look at the attached Ja notes.
Is that your handwriting?
O 24 A
The first page is not my handwriting.
25 Q
The first page is signed by Bert Dunn.
.. =.
7 I
Jones r'
1 2
A The second page, there are some notes on top 3
of the page and written below the date which are not 4
mine.
Other than that, the remainder of those appear 5
to be my writing.
Does this refresh your recollection that 6
Q t
7 you did take notes on the day of the accident recording plant parameters that had been related to you at a
8 9
staff meeting conducted by Allen Womack?
t 16 A
No.
11 Q
What is your best recollection as to when 12 you wrote these entries?
13 MR. BENEDICT:
If you can remember at all.
14 A
I don't remember writing them.
15 Q
Do you remember attending a staff meeting 16 on the morning of the day of the Three Mile Island 17 catactrophe?
f 18 A
I don't remember attending any meetings the 19 day of the accident.
20 Q
Where were you the day of ti.e accident?
21 A
At work.
22 Q
How did you hear about the accident?
23 I will withdraw that.
S
-d How did you hear that the.7e was a
~
24 25 transient-that was in progress, that had started
_t
I Jones l -
~3 8
2 sometime about four a.m.?
3 MR. BENEDICT:
In progress?
Are you 4
qualifying your question by when he heard it 5
that it was still in progress?
i 6
MR. SELTZER:
No.
When he first heard 4
7 there was a transient that had commenced at 8
four a.m.
9 A
I recall hearing about the accident either on t
10 the radio or from my wife telling me thdt she heard 11 it on the radio.
I don't remember the exact details
}
12 that there was a transient.
13 Q
When is the last time you saw your notes 14 which are marked as GPU Exhibit 967 1
15 MR. BENEDICT:
Other than in the presence 16 of counsel?
17 MR. SELTZER:
Including.
18 MR. BENEDICT:
I object.
19 You don't have to answer as to any 20 preparation sessions you had.
21 MR. SELTZER:
I think you are forgetting 22 Federal Rule 632.
23 MR. BENEDICT:
We resolved this the first 24 day of Dr. Womack's deposition, that as you said, 2.5 what-is sauce for the goose is sauce for the
.- l -
-~
9 1
Jones t%
2 gander.
What were notes and papers discussed
~
3 during preparation would not be inquired into.
4 MR. SELTZER:
Let me make it clear.
I 5
never agreed it would not be inquired into.
(,
6 MR. BENEDICT:
I object and I take the 7
position that it is attorney-client privilege.
8 Q
When is the last time you saw GPU Exhibit 9
967 10 MR. BENEDICT:
You can answer that t
11 question except you exclude from it at any time 12 you saw it in the presence of counsel.
O.
13 A
I don't remember looking at it.
14 Q
Did your wife tell you that she heard 15 about a transient occurring at Three Mile Island 16 before you left for work on the morning of March 28, 17 19797 18 A
As I stated, I cannot recall whether I heard it 19 mycoif on the radio or whether my wife mentioned to 20 me after I got to work that she had heard something 21 about a transient at Three-Mile Island on the radio.
22 Q
Did you say after you left for work?
23 MR. BENEDICT:
He said after he was at 24 work, arrived at work.
(}
25 Q
What is the next thing that you recall e--
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y m
g-rey, y
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Jones l
(~h.
l
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being a source of information about the fact that 3
there was a transient at Three Mile Island or a 4
detail about that transient?
5 A
I can't recall specifically what I heard or when 6
I heard the next information.
The next information Lou recall is a conversation I had with a Mr.
7 that I 8
Cartin.
9 Q
Prior to the day of the accident, had you 10 attended at any time meetings of the Plant Design L
11 Section staff?
12 A
I can't recall.
s
\\_
13 Q
Who was the head of the Plant Design 14 Section on the day of the accident?
15 A
Allen Womack.
Dr. Womack.
16 Q
Did you know that Dr. Womack convened 17 regular meetings of the staff of the Plant Design 18 Section or of come of the staff of the Plant Design 19 Section?
20 A
Yes.
21 Q
Did you ever attend any of Dr. Womack's 22 unit manager meetings as a stand-in for Bert Dunn?
23 7.
Yes.
[)
24 Q
Had you ever done that before the Three
'% J 25 Hile Island accident?
.m.
31 1
Jones 2
A I can't recall.
3 Q
Take a look at the second page of GPU 4
Exhibit 96.
In your handwriting just above the middle 5
of the page you have written " solid pzr."
Do you 6
see that?
7 A
Yes.
8 Q
What does that mean?
9 A
It stands for solid pressurizer.
E 10 Q
What does that mean?
11 MR. BENEDICT:
What did he mean when he
[l 12 wrote it?
s_;
13 MR. SELTZER:
Right.
14 MR. BENEDICT:
If you remember.
15 A
What I interpreted at the time was,that the 16 information apparently being given to me was that 17 somebody made an assessment that the pressurizer was 18 full of liquid.
19 Q
In other words, full of water in its 20 liquid state?
21 A
That is what the apparent information was, yes.
22 Q
Skipping down two lines, would you. read 23 what your notation is?
O V
24 A
"Possible two phase primary."
25 Q
What does "two-phase" mean?
~
I Jones 32 l(l.)
2 A
That there was a steam-water mixture.
3 Q
And to what does the word " primary" refer?
4 A
The nuclear steam supply system excluding the 5
secondary side of the plants that is, the feedwater
/
6 to turbine connections that is the loops, the steam 7
generator, the tubos, the pumps, the reactor vessel.
G 8
Q Just above that line, what did you write?
9 A
Which lino?
10 Q
Above the line you just reak.
11 A
" Low indicated flow region."
/)
12 Q
What does that mean?
(_/
13 A
I don't recall what it meant to me at the time.
14 Q
What does " flow region" mean?
15 MR. BENEDICT:
What did it mean when you 16 wrote it, if you remember.
17 A
I don't recall exactly what it meant when I 18 wrote it.
10 Q
In your work in ECCS Analysis, what does 20
" flow region" refer to?
(.
21 MR. BENEDICT:
If it has a meaning.
22 Q
Or what doos a " low indicated flow region"
-23 refer to?
)
24 A
That is not terminology that I would normally
\\'
25 uso, that I have over usod in the arca, that I can
.. I
13 I
Jones 0
2 remember.
3 Q
Do you see the point at which you wrote 4
"socured all pumps"?
5 A
Yes.
6 Q
What does the verb " secured" mean?
7 A
Stopped.
8 Q
Am I correct that the pumps that are 9
referred to are the reactor coolant pumps?
10 MR. BENEDICT:
If you rememb'er.
11 A
I don't remember what " pumps" referred to.
12 MR. SELTZER:
I don't think it is helpful 13 to keep having you interject "if you remember,"
14 "if you have any memory at all," because it 15 indicatos the kind of intrusion by counsel to IG try and guido a witness's testimony.
I think it 17 is a little bit demeaning to.the process of 18 oxamination on deposition to have you doing that 19 constantly.
I think it is also a little bit unnocessary for a witness who has testified in 20 21 hearings to the extent that Mr. Jones has, and 22 testified before the Rogovin Commission.
He 23 testified bofore the Rogovin Commission forthrightly, apparently, and without B&W's 24 25 counsel sooing the nood to intrude after almost
14 1
Jones (V"]
- 2 every question with "if you remember," and "if 3
you have a recollection."
4 MR. BENEDICT:
You have made an effort throughout these depositions to ask witness what 5
6 their present interpretation of a document is, and 7
I consider that to be inappropriate.
I want to 8
make it clear that nay question you ask is limited to his understanding of what he meant 9
t 10 when he wrote that.
His recollection of what 11 he meant when he wrote it.
()
12 I don't hink my adding two words or 13 three words in between your question and his 14 answer is such a grave intrusion, and I will 15 continue to do it.
16 Q
What is the entry that you have written underneath " secured all pumps"?
17 18 A
" Activity went up in building."
19 g
It is a fact, isn't it, that that is a notation referring to increased radioactivity in 20 L
the containnent building?
21 22 A
Yes.
23 Q-It is a fact, isn't it, that the
( w, containment building referred to is the containment
'^
34 25 around the Three Mile Island Unit 2 reactor?
- 'T:
I 4
15 1
Jones L
2 MR. BENEDICT:
You mean that you referred 3
to in the last question?
It is not referred to 4
here.
('
1 5
MR. SELTZER:
Right.
6 A
Yes.
7 Q
The ultimate source of any radioactivity 8
in the Three Mile Island Unit 2 containment building 9
is the nuclear core and the fission products generated 10 by that cores right?
11 A
Not necessarily.
12 Q
What are the other sources of radioactivity
()
13 in the Three Mile Island Unit 2 containment building?
14 A
The water itself contained in the primary system 15 can be radioactive, and it is possible that some of 16 tha tanks, the radioactive waste tanks, could also 17 be a source.
18 Q
I said the ultimate source was the core 19 and the fission products generated by it.
Isn't it 20 a fact that the radioactivity in the primary coolant 21 water comes from the nuclear core?
22 A
lt is a rosult of the fact that the core is 23 fissioning that can cause radioactivity in the 21 coolant, yes.
25 Q
Did you know on March 28, 1979 what was
~
^
\\
1 Jones 26 (y.
2 causing the level of radioactivity in the Three Mile 3
Island containment building to go up?
4 MR. BENEDICT:
Any time during the day?
5 MR. SELTZER:
Right.
6 A
I knew there was a loss of coolant that would i
7 cause activity to go up in the building.
8 Q
Did you learn during the day that the 9
fuel rods had rupturod?
t 10 A
Not that I can recall.
11 Q
Did you subsequently learn that the 12 cladding on the fuel rods had rupturod?.
13 MR. BENEDICT:
Up to today?
14 MR. SELTZER:
Yes.
15 A
Yes.
16 Q
What have you learned since the start of 17 the Throo Milo Island accident that cause@ radioactivity 18 to go up in the containment building?
19 A
My understanding of the transient is that they 20 had a loss of coolant through the PORV.
21 Q
That is the pilot operated relief valvo?
22 A
Yes.
And that subsequently during the transient 23 the core apparently became uncovorod, overhoated, 24 and ruptured.
25 Q
!!ow did the rupturing of the fuel rods-3
~
17
~
1 Jones
(%
%).
2 in the core contribute to the rise in radioactivity 3
in the containment building?
4 A
The fission gas which is contained within the 5
rods would have been released into the coolant.
6 Q
Into the 7
A Into the reactor coolant system, and then 8
subsequently exit the system through the pilot 9
operated relief valve.
t 10 Q
That is not supposed to happen, is it?
11 In other words, that is not part of B&W's intended 12 design and operation of nuclear plants, is it?
()
13 MR. BENEDICT:
B&W doesn't. operate plants.
14 A
The analyses which have been done to -- the 15 safety analyses which are done for the plant do not 16 indicate that as a condition which would occur.
17 Q
In your safety analyses dcne in conformance 18 with 10 CFR 50.46, is it a matter of safety concern 10 if there is a release cf radioactivity from the 20 primary coolant system into the containment building?
21 MR. BENE"~
Do you mean if the analysis 22 shows that?
Yes.
f~s 24 A
The an a.1 os wouso show that coola-would be 25 discharged int the containment buildin:.
which implies
. ~,
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y w.
y
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l 18 1
Jones
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2 that there would be radioactivity released.
3 Q
My question is:
is such a release a 4
matter of safety concern and was it a matter of safety 5
concern prior to the Three Mile Island accident?
Is 6
the release of radioactivity in the manner that you 7
just described something that was a matter of safety 8
concern prior to the Three Mile Island accident?
9 MR. BENEDICT:
The release that occurred t
10 at.Three Mile Island?
That is what you mean by 11 what he describod?
()
12 MR. SELTZER:
No, I was talking more 13 generally, when a safety analysis done in 14 conformance with 50.46 shows that there is a 15 release of radioactivity from the p,rimary 16 coolant system into the containment building.
17 Q
Did you understand before the'Three Mile 18 Island accident that that was a matter of safety 19 concern?
20 A
The fact that radioactivity would be released 21 in that accident would not be' considered a safety 22 concorn, per so.
23 Q
Did you understand that there were 21 conditior.s which would make it rise to a level of 25 safoty concern?
e 4+-
+-.
w-
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e e
r
+'
1 Jones 19 f-Q).
2 A
What I would say there is if you found that in 3
redoing analysos that you increase the radioactivity 4
releanod, there would be a safety concern in the sense 5
that it was beyond what was previously reported.
6 Q
Are you saying that something is a matter 7
of safety concern only if it hasn't been previously 8
reportod?
9 MR. BENEDICT:
That is not what he said.
(
10 If you can answer that question, be my 11 guest.
(
12 A
No.
What I was saying by that is,1f you have 4
13 dono a set of analysos for the plant and then for 14 some reason you subsequently redo additional analyses 15 and find that your previous analyses were,not or 16 did not predict as high a level of radioactivity 17 roloased to the building, then that would be a safety 18 concorn.
19 Q
Why would that be a safety concern?
20 A
Generally, because the potential implications 21 of that additional release have not boon studied.
i 22 Q
You aro very familiar with the requirements 23 for offectivo coro cooling under NRC regulations, 24 aro you not?
I 25 A
I am familiar with them, yes.
l i
1 Jones 20 O
2 Q
And you were familiar with them before the 4
3 Throo Mile Island accidents right?
4 A
Yes.
f i
(
5 Q
Where are those criteria spelled out?
6 A
The specific criteria that we analyao or that 7
we try to demonstrate compliance to are those listed 8
in 10 CFR 50.46, including the method of analysis 9
which is prescribed within that regulation.
t 10 Q
Does that include the methods of analysis 11 specified in the Appendix K?
12 A
Yes.
13 Q
It is a fact, isn't it, that both today 14 and prior to the Three Mile Island accident, there were 15 five concurrent criteria that had to be met in order 16 to ostablish that there was effective core cooling 17 under 10 CPR 50.46; isn't that right?
}
18 A
There are five criteria which you demonstrate 19 using models that are in conformance with the Appendix 20 K requirements, yes.
21 Q
All five critoria have to be met in order 22 to demonstrato there is effectivo coro cooling; right?
- 23 A
Using the Appondix K modol,,yos, p- )
I
(
21 Q
What are.the five critoria?
25 A
I can' t givo them to you_directly in order, but
1 Jones 21 2
the five critoria are:
the peak cladding temperature 3
should be limited to less than 2200 degrees --
t 4
Q Is that on the English Fahrenheit scale?
f 5
A Yes.
6 The localized metal water reaction should 7.
be limited to 17 percent of the cladding thickness; 8
the amount of hydrogen generated should be limited to 9
less than 1 percent of that capable from all zirconium t
10 in the core region; the core should be maintained in 11 a coolable geometry; and the final one is that
(
12 long-term cooling must be provided.
13 Q
Prior to the Three Mile Island accident, 14 was it your understanding that if there was a 15 postulated loss of coolant or break in the reactor 16 coolant system for which offective cooling within I
17 theso five criteria could not be demonstrited, that 18 would be a cause of safety concern?
19 A
If in using the models constructed to meet 20 Appondix K you violated one of the five critoria, 21 that would be a safety concorn, yes.
22 Q
If the peak clad temperature exceeds 23 2200 degrees Fahronheit, what danger does that
~
24 croato for the cladding on the reactor fuel rods?
25 A
Just exceeding 2200 does not nocessarily create
l 1
Jones 22 p
(_
2 a danger for the cladding.
You would have to reach 3
excessive temperatures in the range of above 3000 4
degrees before you would initiate any potential
(-
5 melting of the zirconium fuel rods, or if you are f
6 above 2200 degrees and have extensive localized 7
metal water reaction, it is possible that when you try 8
to ra-cover the core, the cladding will become 9
brittle and lose its integrity.
t 10 Q
Is there a temperature at which metal water 4
i 11 reaction begins to take place?
j ()
12 A
Not that I know of.
13 Q
There is no lower threshhold below which i
14 significant metal water reaction does not occur?
15' A
when you add the word "significant.," I would say 16 that you would have to be above 1500 degrees Fahrenheit any}significant 17 before you would start to worry about 18 metal water reaction.
19 Q
At what temperature did you, before the 20-Three Mile Island accident, begin to worry about any 21 significant possibility of clad rupture?
22 A
HWe don't really look at it from the standpoint l
23 of a epocific temperaturo.
It is a temperaturo-Os 24 proosure related phenomenon, the pressure of the i
25 inside of the fuol rods vorsus'tho temperature.of tho
- ,1 -
23 1
Jones 2
external environment, the coolant system.
That in 3
combination would determine whether or not there was 4
a criterion per se for cladding rupture.
In general, e
5 however, you were talking about temperature ranges of 6
14 to 15 hundred degrees.
7 Q
As you described it, there are two measures 8
of the extent of permissible cladding failure before 9
offective core cooling has been lost under the
(
10 criteria of 10 CFR 50.46; is that right?'
11 MR. BENEDICT:
I don't know what you mean (O) 12 by failure, but if he can answer the question, 13 that is o.K.
14 A
I don't understand your question.
15 Q
If there is hydrogen generation, that is 16 hydrogen that is being generated by the breakdown of 17 the zirconium alloy fuel cladding; right?{
a 18 A
That is hydrogen being generated by reaction of 19 the zirconium with the water.
20 Q
That is a failure of the fuel cladding,
(
21 isn't it?
~
22 A
I would not consider that a failure.
23 0
What would you consider it?
e ~s 24 A
I considor that just the fact that there.is 25 a reaction occurring.
I don't attribute that to
.9m+y e
.m e-
Jones 24 1
gO failure, per so.
2 Q
The loss of fuel cladding through metal 3
water reaction diminishes the ability of the fuel 4
cladding to perform its intended function; right?
5 A
There is not a loss of cladding due to the 6
reaction.
The cladding changes from zirconium to a 7
zirconium oxide, but you do not lose the cladding.
8 Q
What is your understanding as to why the g
i e
NRC had made the transmutation of zircon ~ium of 1 10 percent a criterion of effective core cooling?
gg MR. BENEDICT:
You mean at any time up to 12 L/
l-n w, whatever his understanding was?
13 Q
What was your understanding.before the g
Three Mile Island accident as to why that 1 percent 15 critorion had been imposed?
gg MR. BENEDICT:
If you know.
g7 A
The basic reason for the 1 percent criterion 18 i
j is to limit the amount of hydrogen generated and being gg vented to the containment, so that a potential explosive mixture does not develop.
Q What is your understanding as to why the NRC prior to the Three Mile Island accident had
/NU imposed a requiremont that the peak clad temperature
)
24 remain below 2200. degrees?
.m
I 25 1
Jones O
l 2
A For that specific criterion, alone, there is not 3
a direct reason.
It couples directly with the 4
second criterion, which is the 17 percent local 5
oxidation.
Those two in combination assure the 6
cladding will maintain its integrity upon the recovery 7
mode of the transient.
8 Q
Why did you understand that it was 9
important for the cladding to retain its integrity?
t 10 A
With the loss of the cladding integrity, there 11 is the potential for the fuel to be released into
()
12 the coolant, thus maybe additional radioactivity 13 being released, and additionally with the cladding, 14 with the lo'J s of the integrity of the cladding, there 15 is a potential for flow blockages, additional flow 16 blockages to occur.
17 Q
Why wasn't it a good thing to have 18 additional radioactivity released into the primary 19 coolant?
20 A
Generally speaking, it is not a good thing 21 to release additional radioactivity-if it is not 22.
necessary.
l 23 Q
The question is why.
21 A
You would want to design it to try to minimize 25 that, if possible.
m
l 26 1
Jones 2
Q Why prior to the Three Milo Island 3
accident was the design objective to minimize the 4
release of. radioactivity into the reactor coolant
(
5 system?
I I
6 A
I don't know.
7 Q
You are in ECCS Analysis for almost a 8
decado now?
9 A
Yes.
t 10 Q
And you have no idea why it is undesirable 11 to roloase' radioactivity into the reactor coolant
()
12 system from fuel rods on which the cladding has 13 lost its intogrity?
14 A
I can only speculate to answer, 15 Q
I don't want speculation.
I would like 16 informed judgment based on a decado of working 17 in the ECCS Analysis unit at Babcock & Wilcox, if 18 you have any informed judgment.
19 A
Gonorally speaking, you would want to minimize 20 the roloase of radioactivity into the building, but 21 tho exact details of the whys and wherefors, I can 22 only speculato.
23 Q
In your answer just now,_you said that ono O.
tid want to limit the release of radioactivity into 24 25 tho building.
Proviously, you had said that the loss
=
27
~%
1 Jones (U
of 2
of fuel clad integrity would result in release 3
radioactivity into the primary coolant system.
Is 4
it a fact that the danger in releasing radioactivity 5
from fuel rods into the reactor coolant system is 6
that that radioactivity may subsequently be released 7
into the containment building?
8 A
In answering the questions, I was assuming that and in answering 9
you had a break in the primary system, t
10 that, the. radioactivity being transmitted to the 11 coolant then has a potential for being released into
()
12 the building.
13 Q
And you understood before the Three Mile 14 Island accident that that was an undesirable result?
15 A
That was something that was to be designed around, 16 yes.
E 17 Q
Do you have any judgment based on your as to why that was something 18 profonsional experience 10 to bo designed against?
20 Let me back up and ask you the predicate 21 question.
Was it part of ycur job at B&W for the last 22 docado to contributo to the design of B&W plants 23 no that thoro would not be such a release of s
24 radioactivity into the centainment building?
.g 25 A
The release of additional radioactivity from
28 l
1 Jones m
2 the loss of the cladding integrity as a result of s
embrittlement was something that was to be designed 3
4 against within the confines of Appendix K and r
5 10 CFR 50.46 regulations.
6 Q
You have phrased that in what English 7
stud'ents call passive voice, was something to be 8
designed against.
I asked you whether it was part of 9
your job to work on developing a B&W design to avoid t
10 that type of release.
11 A
It was my job to confirm that the system 12 designs that were in place when the analysis was p)
(
13 performed within the confines of the regulations, 14 that such a release would not occur.
15 Q
Based on your professional experience at 16 B&W, based on your studying for a master's degree at 17 Lynchburg, and based on your undergraduate training 18 at Penn State in nuclear engineering, what was your 19 understanding prior to the Three Mile Island accident 20 as to why it was a design objective to prevent the 21 release of radioactivity into the containment building?
22 A
Basically because there was a potential for c
-23 release then from the building to the external U
24 onvironment.
25 Q
When you say release to the external
29
~
~
l Jones 2
environment, is that the part of the world where 3
human beings walk around and breathe and touch things?
4 MR. BENEDICT:
I object.
Do you want to r
5 withdraw the question?
6 Q
Do you understand the question?
7 MR. BENEDICT:
I consider it an improper 8
question, but if you want to answer the question, 9
be my guest.
(
10 MR. SELTZER:
I think the witness is 11 talking either in euphemisms or technical jargon.
12 MR. BENEDICT:
Outside environment?
13 MR. SELTZER:
I want this to be 14 comprehensible to everyone on the jury.
15 MR. BENEDICT:
"Outside environment" is 1G not technical jargon.
If you want to ask what 17 he meant by that, fine.
If you want to argue i
18 to the jury, you do it on your summation and 19 opening.
You don't do it in deposition.
20 MR. SELTZER:
I will thank you not to 21 1ceture me.
I think you are being rather 22 impertinent.
My question was entirely 23 appropriate.
When you depose somebody from our 7-N-
21 company, if you do so, you can ask the questions 25 the way you want.
If you want to object to form, a
.y y
w.
.%r.
g
-,m
--.9 w
,w,
Jones 30 1
p object to form.
2 MR. BENEDICT:
I did.
That is what 3
started your little lecture.
Q Do you understand the question?
5 MR. BENEDICT:
If you remember the 4'
6 question, you may answer.
)
7 A
I don't remember the question.
8 Q
When you referred to release of 9
radioactivity into the external environgent, were you 10 j
roforring to release of radioactivity into that part 11 of the world around the nuclear plant where p6ople walk and broatho and touch things?
4 13 A
What I was referring to was the atmosphere.
14 j
Q Do you mean the air around the nuclear 15 plant?
16 A
Yes.
~
17 Q
What was your understanding be~ fore the 18 Three Mile Island accident as to why it was undesirable 19 to roloasc radioactivity into the air around a nuclear 20 plant?
21 1
A There is a potential, depending upon the 22 sovority of the release, to affect people's health; 23 q-Q or the health of other animals or other parts of the
~
24 onvironment.
25
.c
N' s s
~
a.
6 l
I s
31 I
Jones.
A 1
'V 2
0,5 Q
Is it because of that potential adverse 4
At
-. c f f e c t on the health of humanjbeings and other parts 3
' tn
.j t
t 4
of the external environment tNat the inabili.ty to
(
t 5
. meet the cooli.ng critoria of 10 CFR 50.46 iha 3
6
-safety.4ancern?
s
$ 4.'.o n ' t kn ow.
I can only speculate.
7 A - '-
8 Q
Has it ever occurred to you in your s
9 professional work that what I just stated is part of safety concern,to be unable 10 the eason that it is a
'[
4 11 to meet th!' cpo)ing cri:oria of 10 CPR 50.46?
3
')
t 12 MR. BENEDICT:
What do you mean, it'is a
\\,
13 safety concern?
Obviously he doesn't know why safety, concern.
14 the NRC makes it a Why ha,'h(os considered 15 MR. SELTZER:
.y,
16 these things to be a safety concern.
17 A
I am confused as to what question I am to be
~
f, 18 answering.
. Record read.)%.
3
(
19 a'
s s
4 20 A
I $ ave spoculated th t that a reason for
.o s
(.
21 it to'bdsa safety concern, yes. 3
%i 22
'N Q
Could you road, please, the line that I J
2..
23 am pointing to on GPU Exhibit 96.
p N
24 A
\\ "A hundred MR personnel hatch implies 100
)
s 25 R per' hour in building."
.x,
32 1
Jones
(^)
\\_)
2 Q
What do your initials MR mean?
Milliremc?
3 A
Millirems or milliroentgens.
~
4 Q
That is a measure of radioactivity?
5 A
That is my understanding, yes.
6 Q
Does the capital R refer to rems or I
7 roentgens, where you wrote "100 R per pour"?
8 A
I don't remember what it stands for.
i 9
Q D$ you in your technical shorthand write t
t 10 capital R as an abbreviation for rems?
11 A
I generally do not vrite anything dealing with c
[)
.12 roms or ro e ntg'e n s.
s Q-
+
13 Q
Was there,within the containment building as you L.derstood it,~
14 at Three Mile' Island Unit 2, 7
15 on the' day of the accident something callcd the 16 personnel hatch?
/
17 A
I do'n't know.
18 3
Q From yr - familiarity.with nuclear plLnts 10 dosigne'd by' Bhbcock &;Wilcox, were you aw re before 20 the Three Mile::Islan'd accident that those plants had 21 an ong ywa'y into the containment building that was 22 cometimes referred to as a personnel batch?
\\
23 A
I knew th y had an entryway into the containment x_/
bdilding, b u t.
I did-not 1.now what it was called.
24
)
n Since tho$Three Mile. Island accident, 25 0 h.I
('!
r J;
. ll:
.Q o
. E :w
33 1
Jones 73
, \\~)
2 have you learned that on the day of the accident, elevated radioactivity readings were detected at the 3
4 entryway into the containment building?
r 5
A I don't remember that.
6-Q since the Three Mile Island accident, 7.
you have learned that there was a period of time in 8
which there was a two-phase mixture of liquid water J
9 and. gaseous water in the primary coolant system t
\\
10 outside the pressurizer; right?
i
]
t 11
'N Since the accident, yes.
' 4
[ )\\
\\
12 l;
Q, It is a fact, isn't lu, that except under
,3 r
i
,' 'hi,ghly unusual conditions, a two-phase mixture would 6
(
13 14 only, exist in the reactor coolant system outside the 2
pressurizer under loss-of-coolant accident conditions?
l 15 36' A
I don't understand what you mean by highly 17 unusual circumstances.
18 Q
You were aware, were you not, as of M
19 March 28, 1979, that a lors-of-coolant accident in a g
it
-3i 20 B&W designed nuclear plant could lead to two phase (r
21 conditione in the primary coolant system outsido the it 22
, pressurizer?
.U l' 23 A
Yes.
7(
Prior to th'e Three Mile Island,ccident,
- ~
24 Q
~
c
/
25 had there(been anyjactual situation in whi, a plant
~
4 e?'
\\
_, f, '
'.., ; < - ( -
34 1
Jones G.
2 that had been at power prior to the start of the s
3 transient had had a two-phase mixture in its reactor 4
coolant system outside the pressurizer other than as 5
a result of-a loss-of-coolant accident?
6 A
I don't know.
7 Q
You don't recall any as you sit here 8
today; is that right?
9 A
That's correct.
10 Q
Prior to the Three Mile Isl$nd accident, 11 you were aware of instances in which loss-of-coolant 12 accidents had resulted in a two-phase mixture in the f~}
v 13 primary or reactor coolant system outside the 14 pressurizer; right?
15 A
What I would say is that prior to the accident, 16 I was aware that there had been at Davis-Besse a 17 loss-of coolant for some period of time which had 18 resulted in two-phase primary conditions.
19 Q
When you say there had been two-phase 20 primary conditions, you are referring to a two-phase 21 mixture in the reactor coolant system-outside the 22 pressurizer?
.23 A
Yes.
i i
('"'J -
24 Q
On your normal operations, it is intended 25 that the pressurizer will maintain a two-phase mixture,.
t
35 I
Jones gg N.
contain two phases would probably be more 2
right, or s
3 accurate?
4 A
Yes, the pressurizer normally contains two 5
phases.
6 Q
One above the other; right?
7 A
Generally, yes.
8 Q
During the 1975 Oconee incident involving was there a 9
a failed pilot operated relief valve, 10 two-phrase mixture in the primary coolan't system?
11 A
I am not familiar with that incident.
[GD 12 Q
Prior to the Three Milo Island accident, 13 you had done a lot of work analyzing loss-of-coolant 14 accidents as part of your job in the ECCS Analysis 15 unit; right?
?
16 A
Yes.
17 Q
From the analysis you had done before the 18 Three Mile Island Accident, you had determined,'had 19 you not, that a loss-of-coolant accident will-produce 20 a two-phase mixture in the primary coolant system; 21 isn't thdt right?
22' THE WITNESS:
Can I have that question 23 read back.
7-U (Question read.)
21 I
25 A:
That's correct.
i g
36
)
Jones 1
v Q
Prior to the Three Mile Island accident, 2
y u say y u knew f n events other than loss-of-coolant 3
two phrase mixture in accidents that had produced a l
4 the primary in a trip from load.
Had the analyses 5
which you had dono prior to the Three Mile Island 6
accident indicated that there were any other possible 7
two-phase mixture in the primary coolant causes of a 8
a trip from load?
system following g
- MR.
BENEDICT:
From the analyses he made?
10 MR. SELTZER:
Right.
gy A
The analyses done in the ECCS Analysis area
/~h 12
(
s/
the generally restricted to loss-of-coolant accidents.
13 The only analysis I recall that shows two-phase g4 primary system previous to the accident was there was 15 analysis done for Three Mile Island wherein they 16 had a steam line break, subsequently lost,all 17 feedwater, and the system went through a $wo-phase 18 primary condition.
gg Q
The loss of feedwater produced the 20 two phase primary condition?
(
21 A
The loss of all foodwater, yes.
o2 Q
11 w did that cause a two phase condition?
23
[ /-
h A
Basically, because you had energy input to the N_
24 fluid from the core with no concomitant energy removal 2.'s
37 1
Jones i
)
f
%,/
2 from the system.
3 Q
Did that result in the reactor coolant 4
system hitting saturation?
5 A
Yes.
6 Q
In order to have that result, you said 7
you had to have a loss of all feedwater.
By that did 8
you mean a loss of both main feedwater and auxilliary g
E l
10 A
Yes.
11 Q
In other words, if you only lost main f~N 12 feedwater but were able to maintain auxilliary uJ 13 feedwater flow, there would not be saturation in the 14 Primary coolant system under the situation you were 15 describing?
I was basically not aware of a 16 A
Based on the 17 lot of analyses before the TMI accident, but prior to 18 the TMI accident I would say that is a tr e statement 19 so far as I can recall, other than a loss-of-coolant 20 accident.
21 0
During the studies that you had done 22 before the Three Mile Island accident, you had 23 analyzed emergency core cooling situations in which
(
,'\\
24 natural circulation was part of the cooling mechanism 25 right?
i 38 1
Jones
,f.3
~
(./
2 A
For a brief period of time, yes.
3 Q
You had studied it for a brief period of 4
time?
5 A
No, that it was a phenomenon which occurred for G
a very brief period of time in the analysis.
7 Q
What limited the duration of the phenomenon?
8 A
The time that the system maintained a natural circulation mode was basically limited to maintaining 9
10 basically a full primary system with the, exception 11 of the pressurizer, and the time duration that that 12 would occur would be break size dependent.
f'}
\\m/
13 Q
The smaller the break, the longer the 14 duration of dependency on natural circulation?
15 A
The longer natural circulation would have 16 occurred.
17 Q
And analyses that you had done before the 18 Three Mile Island accident assumed, did they not, 19 a loss of off-site power at the time that the transient 20 commences?
21 A
Generally the analyses assumed a loss of f
22 off-site power at the time of reactor trip, not at the 23 time of the accident.
However, there had been 24 analysos done without the assumption of a loss of 25 off-site power.
39 1
Jones G ).
2 Q
Prior to the Three Mile Island accident, 3
isn't it a fact that you believe that the loss of 4
off-site power was a limiting case?
5 A
I believe that a loss of off-site power had the 6
potential of being a limiting case.
7.
Q In analyzing various small break scenarios, 8
you had assumed that effective cooling had to be 9
achieved without the advantage of the reactor coolant 10 pumps running; isn't that right?
11 A
We had to demonstrate that cooling would be 12 maintained without the reactor coolant pumps, yes.
13 Q
Therefore, for certain smaller breaks, 14 your analysis was demonstrating that for some period 15 of time cooling was effective because of the operation 16 of natural circulation?
4 17 A
No.
18 Q
In the cooling descriptions f r certain 19 small breaks, didn't your analyses show that cooling 20 was facilitated by natural circulation?
21 A
The cooling of the coro is accomplished by the 22 fact that water is maintained over the core.
Natural 23 circulation, if you have natural circulation, you O
\\~Y
'21 have by definition a full primary system, so you know 25 that your core is covered with liquid, but the natural y,
1 Jones 40 g-(f 2
circulation itself being the cooling mode of the core, 3
no.
4 Q
Speaking about your knowledge and 5
understanding prior to the Three Mile Island accident, 6
what did you understand was the expected temperature 7
differential between hot leg and cold leg when a 8
B&W reactor was in a natural circulation mode?
9 A
My understanding was that they would be within t
10 40 degrees of each other.
11 Q
Do you see the notation at the bottom of
/~
12 the second page of GPU Exhibit 96, which is the entry b}
13 that you have on the line that I am pointing to?
14 A
It says:
"In natural circulation cooled out."
15 Q
what did you write below that?
IG A
"One-half hour, 250 degrees F.,"
then an arrow, i
17 "to 450 degrees F.,"
and then in parentheses, "no 18 steam release."
19 Q
You say no steam release.
What do you 20 have written there?
(.
21 A
Excuse me.
It is difficult.
That may be 22
" atmospheric."
I cannot tell whether it is steam or 23 atmospheric,-whether it is stm or atm.
O 24 Q
If Three Milo-Island Unit 2 was in a 25 natural circulation cooldown mode, was it your v:
,e e-,
41 I
Jones 2
understanding at that time, March 28, 1979, that there hot leg 3
would be a 40 degree difference between the 4
and cold leg temperatures?
5 MR. BENEDICT:
I object to the form of 6
the question, but if what you mean is, did on the 7
day of the accident he understand the natural 8
cir.ulation indicated a 40 degree temperature 9
difference, then he can answer that.
Is that E
10 your question?
11 MR. SELTZER:
Yes.
12 A
I understood that if they were in natural V
13 circulation, the temperature differential would be 4
14 approximately 40 degrees.
15 Q
What does your notation on the line 16 bolow, "in natural circulation cooldown" mean?
17 A
I don't' recall.
18 Q
On the morning of March 28, 1979, the 19 day when the Three Mile Island accident occurred, 20 did you have any thought that thic-was the Davis-Besse
((
21 accident replaying itself?
22 A
on the morning of March 28th, I recall very that I knew very little about the 23 little about the 24 THI-2 incident.
25 Q
Now would you answer the question?
42 I
Jones
(
s_>
4-2 MR. BENEDICT:
What was your question?
~
l 3
Q on the morning of March 28, 1979, did 4
you have any thought based on any of the information 5
that you were getting, including the information that 6
you recorded in GPU Exhibit 96, that this was the 7.
Davis-Besse transient of September 1977 repeating 8
itself?
9 A
As I stated, I did not know very much about the 10 TMI-2 incident that was occurring at the, time:
11 therefore, I was unable to draw any conclusions.
[O~'\\
12 Q
What did you think was causing the 13 possible two-phase mixture in the prima y coolant i
14 system that morning?
15 MR. BENEDICT:
If you remember.
i 16 A
I just don't recall.
1 j
17 Q
What did you think was causing radioactivity I
18 to go up in the containment building that morning?
19 MR. BENEDICT:
You mean what on the i
20 morning did he think?
21 MR. SELTZER:
Yes.
22 A
I don't recall.
23 Q
What did you think was causing a high
.i ' (~.
24 radiation reading at the personnel hatch at the 25 TMI-2 plant?
.,..-.s
,m n
i 43 l
1 Jones
(~1
~
v 2
A I don't recall.
I don't recall this meeting 3
occurring at all, and I remember very -- all I can 4
recall in the morning was that I knew very little 5
about the TMI-2 accident.
6 Q
You mean today you recall knowing very 7
little?
8 A
At that day, on the morning of March 28th, I 9
recall that I know very little about the accident.
10 Q
Seeing your notes doesn't r5 fresh your 11 rocollection that you heard this and wrote this down 12 in your own hand; is that right?
j
~j 13 A
That's right.
I do not remember _taking these 14 notes.
15 Q
But you have no doubt this is your IG handwriting and that you took these notes; right?
17 A
The handwriting appears to be mine,-but the 18 notation as to the time it was taken is n t mine, i
I don't know when these notes were l
19 so I have no
}
20 taken.
(_ >
21 Q
What did you-think had caused the 22 pressurizer to fill solid with liquid water on the 23 morning of March 28, 19797 i
r 24 Mk. BENEDICT:
I object to the form, but 2.5 it is just your syntax.
You mean, what on the t-t
5 f
44 1
Jones g
o
.(_)
2 morning did he think?
3 MR. SELTZER:
Right.
4 A
I don't recall thinking anything.
I don't 5
recall.
What did you think had produced the 6
Q 7
spread in temperature readings?
In other words, l'
8 what did you think that morning had produced the 9
spread in temperature reading between 250 degrees eY n though the 10 Fahrenheit and 450 degrees Fahrenheit 9
11 plant was supposed to be in natural circulation 12 cooldown?
O~/
13 A
I don't have any idea what that note means, 14 whether it indicates a spread of temperature or a time 15 dependency of temperature.
16 Q
In a natural circulation cooldown, based 17 on your knowledge on March 28, 1979, would you have 18 anticipated that a plant would be able to ecol down 19 200 degrees in half an hour?
20 MR. BENEDICT:
I object to the form of 21 the question, the "would you have."
22-MR. SELTZER:
I will ask backup questions.
23 Q
Prior to March 28, 1979, had you developed O
24 an understanding of how rapidly the reactor coolant s/
25 system cools down when it in natural circulation
i 45 1
Jones I \\
%.)
2 mode?
s 3
A My understanding of how fast it cools down was 4
basically up to the discretion of the operator.
5 Q
If the operators are not engaged in a 6
bleed and feed operation, can they achieve, to your 7.
understanding prior to March 28, 1979, a rate of 8
cooldown that would be 200 degrees in half an hour?
9 MR. BENEDICT:
I object to your 10 characterization of, if you are rkferring to --
11 for one thing, the arrow points in the direction 4
12 of the higher number.
If you want to just ask
[])
\\_
13 the question, could you cool down_200 degrees 14 in half an hour, that is fine.
15 Q
Prior to the accident, do you recall any 16 analysis or any knowledge you had prior to the 17 accident concerning the rate at which you could cool 18 the core in natural circulation other than the feed 19 and bleed mode?
20 A
My understanding was the operator could take 21 control of the steam generator and depressurize it 22 rapidly and yield rapid cooldowns.
I did not have a 23 fixed number as to what that capability was.
24 Q
Did your understanding include the rate 25 of.cooldown being 200 degrees in one-half hour?
- h*.au-i=
't 46 1
Jones
/'h V
2 MR. BENEDICT:
I object to the form of 3
the question.
4-You can answer.
~
5 A
My understanding was that if the operator opened G
tho valves in the secondary system, that he could 7-achieve very rapid cooldowns, including -- my belief 8
was greater than 200 degrees an hour.
9 Q
What about 200 degr'ees per half-hour?
E 10 A
Yes.
11 Q
That too?
You said he could achieve 12 200 degrees an hour.
I am asking whether he could
/~}
(/
t 13 achieve 200' degrees a half-hour.
14 A
Yes.
15 Q
He could also achieve brittle facture 13 if he did that in a half-hour; right?
17 -
A I don't know.
18 Q
Your counsel was being constrbctive when in the ' direction 19 he pointed out that the arrow goes 20 from the lower temperature to the higher temperature.
(
21 Do you see thst?
22 A
That is the way the arrow points, yes.
23 Q
In a natural circulation cooldown, the
.i. '-)
24 temperature would decrease, not increase; right?
25 A.
'Yos, but I don't know what that' notation means s
47 J
I Jones 0
V 2
at all.
3 Q
When did you first hear or conclude that i
Three Mile Island Unit 2 had had a serious problem 5
on March 28, 19797 6
A could you define " serious problem" for me?
7 Q
You know that the Three Mile Island 8
accident was a serious problem; right?
9 A
The Three Mile Island accident was beyond what I would', consider that 10 we would normally expect, yes.
11 a problem.
12 Q
Do you know anybody at B&W who thinks
[
13 that the Three Mile Island accident was,not a serious 14 problem?
15 A
No, with the exception of I do not believe 16 that there are many people that believe that the 17 Three Mile Island accident-was a serious problem as 18 far as it affected the public health.
10 Q
You said you don't know anybody at B&W 20
. who does not believe it was a serious problem.
In 21 what sense do you understand the Three Mile Island 22 accident was a serious problem?
23 A
In the sense that the core was severely damaged O
24 and that there was high radiation releases into the 25 containment building.
' ~ ~ ~ ~ ~ ~ ~
i 48 1
Jones p) -
\\v.
2 Q
When did you first lerrn that there had 3
been a 1,as-of-coolant accident a rhree Mile Island?
4 A
I knew it the next day.
I don't recall when I 5
knew it, when I may have first known it, but I knew 6
it by the next day.
7 Q
You have no recollection of reaching that 8
conclusion on March 28, 19797 9
A I just do not recall.
10 Q
In GPU Exhibit 96, let me adk you if you 11 could read this entry.
12 A
" Closed electromatic relief valve," and then in
(~
\\-
13 parentheses, " block valve," close parentheses.
14 Q
At the Davis-Besse plant, on September 15 24, 1977, the operators had closed the block valve e
16 behind the electromatic relief valve, hadn't they?
17 A
Yes.
r 18 Q
You knew th at on March 28, 19h9, didn't 19 you?
20 A
As I said, I don't recall taking these notes.
21 Q
Don't read more into my qu3stion than was 22 there.
I said, on March 28, 1979, you knew that the 23 Davis-Desse operators had closed the block valve in
(~N s/
24 front of their electromatic relief valve on September
-t I
25 24, 1977; isn't that right?
.m-
1 Jones 49 2
A Yes, I knew they closed their block valve at s
Davis-Besse.
3 4
Q Anu you knew they did that because the 5
Pilot operated relief valve.had failed in the open 6
position; right?
7 A
I don't know why they closed it.
They closed it 8
maybe under an assumption they had to.
I know they closed the block valve.
g 10_
Q You knew they closed the b1dyk valve after 11 the electromatic relief valve had been stuck in the 12 open position for approximately 20 minutes; right?
(~')j 13 A
Yes.
14 Q
You know that the stuck-open electromatic 15 relief valve had been releasing reactor coolant from 16 the reactor coolant system or from the primary coolant system; right?
17' l
I 18 A
At Davis-Besse, yes.
l 19 Q
The electromatic relief valve is another way of saying pilot operated relief valve; right?
20
(.
A Y"8*
21 22 Q
Prior to March 28, 1979, on what other oceani ns had you heard of a pilot operated relief 23 N'
valve having failed to operate as it was supposed to 24 n a nuclear plant?
25
.m f.
50 I
Jones
,q N_)
2 MR. BENEDICT:
What have you heard prior 3
to that time?
4 MR. SELTZER:
Heard, read, seen.
5 MR. BENEDICT:
As opposed to what he 6
knows now about what happened prior to that 7
time?
8 MR. SELTZER:
Right.
9 Q
In other words, I am interested in your 10 state of knowledge on March 28, 1979.
Just a list of 11 plants where you know there had been a failure of 12 the pilot operated relief valve to function as designed.
13 A
on March 28, 1979, the only one that I recall 14 knowing was the Davis-Besse one in September of 1977.
15 Q
You didn' t know there had been a problem 16 at one of the Oconee units in 1975 with the pilot 17 operated relief valve?
18 A
Prior to the accident, no.
19 Q
I am focusing on what you knew on March 20 28, 1979.
You know then, did you not, that the Davis-1
/\\s 21 Besse operators had shut off the high pressure 22 injection system during their September 24,-1977 23 transient before they had detected the loss-of-coolant
(-
24 accident; right?
25 A
I knew they had shut off the IIPI prior-to closing c.
51 1
Jones
~
2 the block valve, yes.
3 Q
You know that that Davis-Besse incident 4
and particularly the operator interruption of high 5
pressure injection is what had catalyzed Bert Dunn 6
to write his February 1978 memorandum to Jim Taylor; 7.
isn't that the fact?
8 MR. BENEDICT:
If you knew that from 9
something that you perceived or heard.
t 10 A
- Yes, 11 Q
Didn't it occur to you on the morning of
/~'\\
12 March 28, 1979 that the fact that a block valve had O
13 beon closed in front of the pilot operated relief 14 valve at TMI-2 was an indication that that plant 15 might have a loss-of-coolant accident or might have had 16 a loss-of-coolant accident?
17 A
I don't recall.
18 Q
Had you heard of any instance in which 10 the operators of a plant had closed a block valve 20 other than to arrest a loss-of-coolant accident prior 21 to March 28, 1979?
22 A
The only instance that I knew at that time 23 where an operator had closed the block valve was 24 during the Davis-Bosso I transient.
25 Q
When the operators closed the block valve t
J T J
52 1
Jones U
2 during the Davis-Besse I transient, that stopped the 3
loss-of-coolant accident: right?
4 A
That terminated the loss of coolant, yes.
5 Q
After your notation " solid pressurizer,"
6 you wrote " reactor system pressure decrease."
7 Do you see that?
8 A
Yes.
9 Q
You knew as of March 28, 1979 that the 10 pressurizer had filled solid with water 'during the 11 Davis-Besse event while the reactor coolant system
(
12 pressure was decreasing; isn't that rig t?
13 A
Yes.
14 Q
Other than the Davis-Besse transient, 15 were you aware of any other incident involving a 16 B&W plant where a pressurizer had gone solid with 17 reactor coolant system pressure decreasing?
18 A
Prior to the accident at TMI, I knew of no 19 other circumstances where there was even a solid 20 pressurizer, other than Davis-Besso.
(,
21 Q
You and Bert Dunn and Carlyle Micholson i
22 recognized prior to March 28, 1979 that a break at the 23 top of the pressurizer could produce system conditions 21 in which pressurizer water level would rise while 25 reactor coolant system pressure foll; isn't that right?
1 Jones 53 2
MR. BENEDICT:
I object to the form of the 3
question.
\\
4 A
Yes.
5 Q
other than a break at the top of the 6
pressurizer, do you know of any other condition that 7
could lead to pressurizer water level rising to the 8
point of the. pressurizer becoming solid with water 9
while reactor' coolant system pressure decreased?
e 10 A
Can I have it back?
11 Q
I will restate it.
I want to emphasize 12 I am asking about your state of knowledge on March 13 23, 1979, the day of the Three Mile Island catastrophe.
14 As of that date, did you know of any 15 condition other than a break occuring at,the top of 16 the pressurizer that could cause rising pressurizer 17 water level to the point of filling the p'ressurizer
-18 completely solid with water while the reactor coolant 19 system pressure was decreasing?
20 A
Prior to the accident, I can't recall whether 21 I knew that was the only circumstance.
22 Q
Can you think of any other circumstance 23 today that you knew back on March 28, 1979 would
~
(
24 produce a solid prossurizer with decreasing reactor 25 coolant system pressure?
54 1
Jones
(-)),
(m 2
MR. BENEDICT:
That is the same question 3
except you put a p.reface on it that didn't make 4
any sense.
I object.
Asked and answered.
C.
Let me hear the question again.
5 6
(Question read. )
7 MR. BENEDICT:
It is the same question I object as asked 8
you asked immediately before.
9 and answered.
(
10 A
I don't recall.
11 Q
31nce the Three Mile Island accident, could 12 have you analyzed any other situation that
()
~/
13 cause pressurizer water level to rise _to the point 14 of the pressurizer becoming filled solid with water 15 while reactor coolant system pressure decreased?
16 A
Specifically analyze, no, but an inadvertent i
17 opening of the spray valve or initiating pressurizer a reactor coolant system pressure 18 spray could cause 4
19 decrease while the pressurizer level rises.
I don't 20 recall when I had that knowledge, whether it is 21 previous to the accident or after the occident.
22 Q
You say that would be a result of
. 23 inadvertent opening of the pressurizer spray valve?
Y
/
24
'A I don't know whether that is the only cause,
~^'
25 but somehow having pressurizer spray on continuously 1
i i
l 55 1
Jones g
(
x_/
2 in an uncontrolled fashion would reduce the pressure 3
in the pressurizer and result in increasing water 4
level.
5 Q
You say you have never specifically 6
analyzed that?
7 A
No.
8 Q
No, you have not specifically analyzed it?
I have not specifically analyzed that case.
9 A
10 Q
Do you know whether that cifcumstance 11 which you have not specifically analyzed could lead
/~h 12 to such a rise in pressurizer water level that it
(_)
13 would take the pressurizer solid?
14 MR. BENEDICT:
I object to the question, 15 but you can answer.
16 A
I don't know.
17 Q
Are you familiar with a concept that 18
. involves the coefficient of expansion of water?
19 A
I don't understand the question.
20 Q
Water has in its liquid phase some ability 21-to expand and contract in response to pressure; right?
(
22 A
Yes.
23 Q
The degree of expansion or contraction is A-24 a function of the coefficient of the expansion of water; 25 right?
f 56 1
Jones (v'
2 A
Yes.
3 Q
Leaving the spray valves on would cause 4
some expansion in the water inventory in the reactor 5
coolant system because of a decrease in system 6
pressure; right?
7 A
Yes.
8 Q
It is that physical phenomenon that you 9
were referring to, right, when you said you had never specifically analyzed but you think you(pay have been 10 11 aware of a circumstance that could cause pressurizer 12 water level to rise while reactor coolant system 13 pressure decreased?
14 A
That phenomenon, plus the fact that you would 15 have to maintain pressure equalization between the 16 primary system and the pressurizer, assuming the 17 Primary system is still solid, and the fact that when 18 you turn on the spray valve and decrease the 19 pressurizer pressure, that upsets that balance and 20 hence the demand for flow, because the elevation head 21 balance has changed.
22 Q
What is causing the pressurizer water 23 level to rise?
n 24 A
The fact that the pressurizer pressure V
25 pressurizer presuure would be at a lower pressure k
T 57 1
Jones s
%J 2
relative to the balance required between the primary 3
system and the pressurizer, and you would have a
or a differential pressure between the 4
delta P
5 primary side and the pressurizer which would then G
cause flow to occur.
7 Q
Flow into the pressurizer?
l; l
8 A
yes.
9 Q
From where?
t 10 A
From the primary system.
11 Q
You have heard of the expression, nature 12 abhors a vacuum, haven' t you?
(
13 A
No, I have not.
14 Q
When water flows from the primary part of 15 the reactor coolant system into the pressurizer, you 16 said that the reactor coolant system primary volume 17 remains solids right?
18 A
Yes, at least that was an assumption.
Excuse 19 me.
20 Q
Am I correct then that the rise in 21 pressurizer water level with the rest of the reactor 22 coolant system remaining solid is due to expansion 23 in the water inventory in the roactor coolant system?
%)
24 A
Yes.
.25 Q
11avo you ever done any calculation of
+-
, - +,
58 I
Jones 2
how many inches of rise in pressurizer water level s
3 can occur in response to this expansion of the water.
4 in the reactor coolant system?
5 A
Not that I can recall.-
6 Q
Do you have any ball park feel for how 7
many inches rise in pressurizer water level is caused 8
by the expansion of water in response to falling 9
pressure?
10 MR. BENEDICT:
I object to dhe question.
11 If this is going to be short, I will let him 12 answer it.
}
13 A
I don't have a ball park figure.
14 Q
Is it your understanding based on your 15 review of this phenomenon that the expansion could 16 cause the pressurizer to go solid?
17 A
It is a possibility, yes.
18 Q
Who told you it is a possibility?
19 MR. BENEDICT:
If anybody.
20 A
That is just my judgment, that it is a 21 possibility.
22 Q
Since you have never done any specific 23 study of it, what is your judgment based on?
l.
.A The-fact that the spray water is cold and 21 25 therefore.can depressurine, has the capability of l
I
u 3
g s
(
s v
L 59 I
~~
, Cones
~
o 0
" m, a
s
\\
2 depressurizirrt thU pressurUrcr down to pressures on
'ga
(
g V.
.\\
l 3
the order of a thousand psi.' That would in' fact not i
7 l
4 even keep $the primpty system solid. }t would r(sult
(-
_s <
s (3'
5 in flashing within the prima'ry system, at that o
6 pressure.
s i
7 Q
Now you are changing assumptions on me; l
t
\\,I 8
right?
[y 9
A No.
What I had answered befo @ was just to try (j
'to give you an explanation that visualided or aided 10 /
15 in thelvisualization of the phenomenon.* 'I made that i f, i i 12 as an assunption for simplicity.
I didn'tbaay that v
13 the primary system would in fact remain subcooled.
I 1
t 14 said assuming that.
3 y
s.
- 1.,
adding #an intribuing nr.y
.t' 15
.e Q
I think you are y
+
,y.;
\\,
x, 16 element when you talk about 7,o longe'r.' remaining. ' *
(",
mq
.~
3 i
17 subcooled.
Based on what you have just said,you 2
, l x.
.4 i
's t'
q..
18
' un'd e r s to od. ? abo u t the mechanics of this, if the' g,
s a
19 pressupo dropped.to the point wherc flashing oc,:urred) i./
~
,1, ?
i there will be spontaneous <9eneration that means'tha*.f 20 21 of steam in tha reactor coolant systems right?
'm s
q.._
22 A
Steam would be generated, y e.s.
4' "
3 23
-Q i
Molecules of wn or in thiir gascous form 6
NlC 1._
than mo.acules g'! water in liquid a
34 take{ap]nore spaco sQ u
^ ~.7 y
~ icht?
25 form; r
- v 1.
y x
t 60 f
1 Jones 2
A That's corroct.
3 Q
If this flashing produces a solid 4
pressurizer, what is going to make room for the steam 5
that is being formod?
Wher6 is the water going to go?
G MR. BENEDICT:
I object to the form of the 7
question.
8 A
It is a dynamic situation whi ch when I was talking 9
possibilities, that is a possibility that could happen.
You asked me what my possibility was bad,d on, and I e
10 11 gavo you an answer, but if the pressurizer went solid
/
12 and you had a two-phase primary, the system would then v
13 stablize in that condition, assuming no additional 14 fluid was injected into the system.
15 Q
Havo you ever heard of anything like this 1G happcaing?
17 A
Not that I can recall.
18 Q
Do you know of anybody who has dono any 19 serious analysis of this?
20 A
I don't know whether it has boon analyzod.
21 Q
so you are not aware of any analysis of 22 this.
You have never heard of it happening.
You 23 aro juut throwing it out as a theorotical possibility; 24 is that right?
MR. DENEDICT:
You asked the question.
25
'k 61 1
Jones 0-,.
2 A
I was just answering the question to the best
.3 of my ability.
' p, {l 4
Q And it is right that it is just a theoretical possibility, not based on any empirical 5
l 6
observations or any theoretical analysis is that right?
7 MR. BENEDICT:
I object.
8 You can answer the question.
9 The question is objectionable.
10 A
It is based on my understanding of, system 11 dynamics.
12 Q
Have you ever discussed this with anybody
}
13 else?
14 A
Not that I can roca11.
15 Q
Did it occur to you that this was what 16 had caused the pressurizer to go solid while the 17 reactor coolant system pressure decreased,when you 18 wore thinking about it on March 28, 19797 object to the' question 19 MR. BENEDICT:
I 20 as assuming a fact not in evidence.
I would like to hear.it again.
21 f
(Question read.)
22 23 MR. BENEDICTt You can answer-the question.
O
-\\ j
-24
.A I am not suro -- I don't recall being awaro on
-25 March 20th that they had a solid pressurizer with a
'l
.s -
>o.,
,,1
62 I
Jones 7S 2
low reactor coolant system pressure, and I don't 3
recall thinking about this fact either.
a 4
Q I show you what has been previously marked 5
GPU 75, a memo from T.
E.
Geer to L.
P.
- Williams, j
6 dated August 18, 1980.
7 Do you see near the back a resume for 8
Robert C.
Jones, Jr.?
9 A
Yes.
10 Q
Did you prepare that?
11 A
Yes.
i
[~D 12 Q
Have you seen a copy of GPU Exhibit 75
\\_)
13 before?
14 MR. BENEDICT:
Other than possibly in your i
i 15 preparation in the presence of counsel.
16 A
Not that I can recall.
'17 Q
Would you turn to the second page of the 18 exhibit.
There is a heading at the top, " Areas of 19
. Expertise Within Unit."
20 Could you go down that list of 15 areas l'
21 and indicate in which areas you believe you had 22 expertino-at the time,of the Three Mile' Island 23 accident?
21 A
Can I'annwor them with just the numbers, or 25 -
would-you like me to read them?
l -
%rt,
Ii 63 Jonos I
O 2
Q Read thom.
Road the number and then the 3
heading next to it as being an area in which you 4
have expertise, or had exportise at the time of the 1(
5 Throa Mile Island accident.-
simulation and analysos of thermal 6
A Item 1,
7 hydraulic systems.
i 8
Item 2, analysis of RCS loss-of-coolant i
a 9
transfer - steady state 10 No.
4, heat flow.
11 transient conduction and convection two-phase 12 6, development of ECCS system performance
()
13 criteria.
14 7, development of analytical tools and 4
15 methods to perform thormal hydraulic ovaluations.
16 11, basic ECCS code understanding and 17 general computer code programming.
18 13, stress strain fuel ruptur modeling 19 and thermal responso.
And 15, development of linear heat rato 20 21 limits.
22 0-Look at item 8, which is development of 23 plant operating guidolinos for use in recovery from
-.bi
- \\ J loss-of-coolant accidents.
It is a fact, isn't it, 24 25
_that prior to the Throo Milo Island accident you had
64 1
Jones 2
reviewed and consulted with Bert Dunn on the guidelines 3
which he had draftod for the operation of high pressure 4
injection to recover from loss-of-coolant accidentsi 5
isn't that correct?
6 A
I had consulted -- I had a review function in 7
the memos that were issued, yes.
8 Q
You left out No.
9, which is liconsing 9
requirements for loss-of-coolant accident analyses.
3 Didn't you testify earlier this morning'that you 10 11 considered yourself very knowledgeable about the NRC 12 critoria for demonstrating effective core cooling 13 following loss-of-coolant accidents?
I 14 A
Yes, I did.
But I read this as in the vein of 15 sotting licensing requirements rather than just being 16 -
familiar with the general licensing requirements 17 that are proposod.
18 Q
The word "sotting" doesn't appear there, 19 doos it?
20 A
No, but I would, in looking at that line as
(.
21 areas of expertino, licensing roquirements other 22 than knowledge of liconsing requirements, I would 23 consider it to be an area of expertiso that I have,
\\ ')
24 but in'the global sonso,,11consing requirements ~,
25
'I did not considor. that to be my knowledge as I-do.not
_._.e.,
4 65 1
Jones rg 2
set them, so I did not endorse it globally.
3 Q
Do you know anybody in B&W who sets 4
4 licensing requiroments?
5 A
No, I do not.
6 Q
Isn't it your understanding that it is the Nuclear Regulatory Commission who sets licensing 7
8 requirements?
9 A
Yes.
10 Q
To the extent that B&W has an expertise 11 related to licensing requirements, it is an expertise 12 in understanding and hopefully complying with
()
13 licensing requirements for LOCA analyses isn't that 14 right?
+
l 15 MR. BENEDICT:
I object to the form.
4 16 A
It is an understanding of the licensing 17 requiroments so that they could be used when the 18 analyses are performed to demonstrate compliance with-t 19 those requirements.
i.
20 Q
Is thoro anybody in the ECCS Analysis ki unit whom you believe is more export.than you and Bort 21 22 Dunn in understanding of NRC licensing requirements i
I 23 for lons-of-coolant accident analysos?
O MR. DENEDICT:
'l object to the form.
Do
. 24 25
.you have a timo framo?
/
i 66 I
Jones
/~NU 2
MR. SELTZER:
As of the date of the Three 1
3 Mile Island accident.
4 A
That would be speculation to say whether I knew than 5
whether anybody was more or less knowledgeable G
Bert and I in that area.
7.
Q In terms of applied knowledge, not 8
something that is just in their cranium but not used, 9
do you know of anybody in the ECCS Analysis unit 10 at the time of the Three Mile Island accident who 11 had more applied knowledge about NRC licensing 12 requirements for loss-of-coolant accident analysos 13 than you and Bort?
14 A
I really don't know.
It would bo* supposition 15 for me to answer the question.
1G Q
Was there anybody in the group that 17 reported to you who had more knowledge about the 18 11consing requirements than you did?
19 MR. BENEDICT:
On the day of the accident.
20 A
I don't recall who was in the group at the time, 1
21 but ovon still, I would havo to make a supposition as w
22 to-the other people, the stato of the other poople's 23 knowledge, and I cannot answer the question without
(~h
.'w) 21 guoscing.
25 Q
What are the-specific sources that you s
i I
w_
.-. ~
f 67 I
Jones 2
were aware of in March 1979 of licensing requirements 4
3 for loss-of-coolant accident analyses?
4 A
The licensing requirements for loss-of-coolant 5
accidents are. contained in 10 CFR 50.46 and Appendix K 6
of 10 CFR 50.
4 7
Q Have you ever heard of a number called 8
the standard review plan?
2 9
A I know generally of standard review plans.
10 Q
Do you maintain a copy eithd,r in your 11 office or within the ECCS Analysis unit of the NRC's 2
12 standard review plan?
13 A
I have ccpies of some NRC standar,d review 1
14 plans in my office.
15 Q
Do you have a copy of the SRP's that 4
16 relate to ECCS?
I 17 A
I have a copy of the standard review plan 18 relating to the calculation of the minimu containment
~
19 back pressuro for LOCA analyses.
I don't recall 20 whether I have copies of'other ECCS related standard 21 review plans.
- 22
.Q Is it your understanding that the standard
' A-23 review plans contain licensing requirements ~ formulated 24 by the NRC7 I
4 25 A
It_is my understa'nding that they do not.
4
,,n
-p y
._ __=
l l
Jones 68
~
l '
2 Q
llave you ever heard of something referred 3
to as the GDC7 4
A I know of the general design criteria, if that is 5
what you mean by the GDC.
6 Q
It is a fact, isn't it, that the general 7
design criteria contain licensing requirements for 8
loss-of-coolant accident analyses?
D A
I don't recall the general design criteria t
i 10 containing requirements for loss-of-coorant accident 11-analyses.
()
12 Q
Do they contain any guidance for LOCA 13 analyses?
14 A
Not that I can recall.
15 Q
Have you ever heard of the single failure 16 criterion?
~
-17 A
I have heard that phrase, yes.
18 Q
What do you understand it means?
10 A
Generally that analyses should be. performed 20 assuming the worst caso single failure from a 21 mechanical standpoint.
22 Q
What do you mean, a worst case single 23 failure?
\\,/
l 24 A
That is a single failure that -- some mechanical i
some single mechanical failure that 25 failure that
69 1
Jones
[,)
V 2
would result in the worst set of equipment availability 3
for this specific analysis being done.
4 Q
Is the singic failuro criterion a 5
licensing requiroment impored by the NRC?
6 A
As related to LOCA analysis, there is a 7.
requirement for a single failure which is contained 8
within Appendix K.
9 Q
Does Appendix K explicitly limit the 10 singlo failure to mechanical failure?
11 A
My understanding of what it is, it is dealing 12 with mechanical failures.
13 Q
llave you ever heard it said,or written 14 that single failure should include single human error?
15 A
Not that I recall.
16 Q
Do you know a chap who goes by the 17 handle Rosztoczy?
18 A
I know a Zoltan Rosztoczy.
19 Q
Do you know any other Rosztoczys?
20 A
No.
21 MR. BENEDICT:
I-object to the question 22 and answer.
I move to striko it as badgering.
23 Q
llave you over had any discussions with
/~'s NN
-24 Dr. Ronztoczy relating or reforring to the single n
25 failuro critorion?
l
?
E 70 Jones 1
2 A
Not that I can recall.
3 Q
Aren't you aware that Rosztoczy has 4
expressed the view in writing that the single failure 5
criterion must include the possibility of human error?
6 MR. BENEDICT:
I object us asked and answered.
7 8
A Not that I can recall.
g Q
Would you turn to the third page of GPU 75 which is headed " Summary of Recent Ex'perience."
10 11 of the 18 items _ listed there, could you indicato 12 which ones you have worked on?
p 13 A
No.
2, tight packed lattice project.
No.
4, analysis of stuck open -- o-p-e-r 14 15 in the document, and I am assuming it is open -- PORV 1
to following a small break (177 low loop generic).
No. 5,1205 high point vent guidelines.
17 18 Fo.
7, loft and semi-scale experimental 19 verification.
20 Q
That is the Idaho testing?
(
^
YO8*
21 No.
8, TMI-2 accidont analysis.
22 No. 10, SMUD hearings as follow-up to-the 23
(~ \\
'ss/
THI-2 accident.
21 No. 11, thermal chock prouram'for 177 25 e-r v-T t v
?
71 Jones 1
3 s
2 owners' group, although that is limited involvement 3
in that.
4 No. 12, 205 small break evaluation program.
And No. 18, training operators on the 5
1 6
small break guidelines.
7 Q
Where, if anywhere, in B&W has work been 8
done on the ability of the core to remain effectively cooled with high void fractions in reactor coolant 9
t 10 system?
11 A
The only work I am aware of is within the ECCS 12 area.
13 Q
Who has done that work?
14 A
The only person I can recall is Nairu Shah.
15 Q
When was that work done?
16 A
I would like to add to my last response.
I believe Bert Dunn has done some work 17 18 along with myself for certain situations [calingwith 19 high void fractions.
_ Relative to your 2ast question, there was l
pg 21 work done over the span of several years dealing with
(
22 cnall break LOCA response wherein the core has been gl.
kept covered by a two-phase mixture and could have O
21 high void fractions within the mixture itself.
This U
t those analyses have. boon performed.
25 is under
= -
1 Jones 72 2
Additionally, Nairu did some work, as I 3
recall, dealing with cooling of the core with steam 4
flow into the core pum.i',
and that was done in early 5
1979.
6 There has also been work.done in response 7
to I&E Bulletin 7905C in August of 1979.
8 Q
You said you and Bert Dunn had done work 9
in this area over several years.
When did you begin 10 doing that work?
When did you and/or BEyt Dunn begin 11 doing this work?
12 A
Approximately 1972.
13 Q
Where, if anywhere, within.B&W has work 14 been done to study the ability'of the reactor coolant r
15 pumps to keep functioning with high void fractions j
1G including 100 percent voiding?
17 A
other than with discussions with counsel, I 18 don't recall any such work-dealing with c ntinued 10 pump operation, the ability of the pumps to continue 20 to operate in high void fraction.
(_
21 Q
Other than in conversations with counsel, 22 have you ever considered the question of the ability 23 of the reactor coolant pumps to continue to function
(~\\
\\-
21 with increasing void fraction'or with any void 25 fraction?
e w-m
-m=
y 9
ii h
I Jones 73 i
d 2
A I am aware that testo have been done wherein 3
the capability of the pumps to run with voided inlet 4
conditions have been studied, but a study on the 5
continued operation of the pump with those inlet 6
conditions I am not aware of.
7 Q
Where within B&W have studies been done 8
of the ability of the pumps to run with voided inlet 9
conditions?
involvement by the -- pEpsently 10 A
There was 11 called the Power Systems & Control unit wherein an i
12 individual has been involved in those tests.
13 Q
Who?
14 A
Bob Winks, and the toch staff unit, now the 15 Systems Analysis Technology unit,have been involved e
16 in doveloping models to characterize the test results, 17 and there have been studies performed by the ECCS 18 Analysis unit where the effects of these odel's 19 have been studied, specifically on pump overspeed 20 analysis.
(.
21 Q
You said that you and Bert Dunn had been 22 studying since 1972 the ability of the core to remain 23 offectively cooled with a mixed two-phase. That' ability 24
-to koop the core effectively cooled with a two-phase
\\~#
25 mixture requires that the reactor coolant pumps stay
. t
-~-
I I 74 1
Jones r
2 on, doesn't it?
3 A
No, the analyses I am referring to were analyses 4
where the reactor coolant pumps ware off.
5 Q
In those analyses, if the water level 6
is substantially below the top of the core, does the still remain at the 7
steam that blankets the core 8
saturation temperature until all the water has 9
evaporated?
t 10 A
No.
i 11 Q
Does the stean remain below 2200 degrees?
12 A
It depends on how far the core is uncovered.
13 MR. BENEDICT:
I object to any more 4-r 14 questions unless they are about the studies 15 he has done as opposed to his speculation now IG of what studies might show.
17 (Whereupon, at 12:30 p.m.
a lunch recess 18 was taken.)
19 20 21-22 23 a
^
25
s l
($)
2 AFTERNOON SESSION 3
2:05 p.m.
4 RO B E R T C.
J ONE S,
J R.,
resumed.
5 EXAMINATION (continued) 6 BY MR. SELTZER:
7 Q
What work did Nairu Shah do with respect 8
to the ability of pumps to keep on pumping with 9
increasing void fraction?
(
10 A
No work, to my knowledge.
11 Q
What work did Nairu Shah do on the ability 12 effectively to cool the nuclear core wi.th voiding 13 occurring?
14 A
What Nairu did, as far as I can recollect is 15 ho performed an evaluation -- what he did.was he IG assumed steam flow into the core under pumped flow 17 conditions and calculated the cladding te@peratures 18 that would result.
19 Q
Under pumped flow conditions;.is that what 20 you said?
21 A
Yes, on the roactor coolant pump.
22 Q
If RCP's stay on, does the steam water 23 nixture remain at the saturation temperaturo?
O 21 A
If it is a steam water mixturo, yes, at least 25 as far as the inlet to the core.
I am not sure what 1
.~.
l l
fq 76 l
Jones O
2 it would be when it comes out of the core.
3 Q
Did Nairu write up his results?
4 A
I don't recall.
5 Q
Who was Nairu working'for when he did this?
6 A
For me.
7 Q
. What did you ask him to do?
8 A
Specifically what he was asked to do was to 9
analyze a pump's on situation Eor the small break and.
e 10 to examine its consequences relative to 'a pump 's 11 off situation.
12 Q
Why did you ask him to study that?
13 A
I don't rocall the details.
What I generally 14 recall is somebody raised a concern relative to whether 15 keeping the pumps on was the worst' condition as 16 opposed to starting with the reactor coolant pumps off, 17 and we ran the analysis to try to draw come conclusions 18 relative to that.
19 Q
Who raised the concern?
20 A
I don't remember, s
21 Q
Was it somebody in ECCS?
22 A
I don't romember.
23 Q
Did the concern arine in connection with
\\'j '
24 the licensing of-a particular plant?
25 A
The study was done for the 205 fuel assembly
I 77 t
1 Jones CE) 2 plants, but I can't recall whether it was for a 3
licensing purpose.
4 Q
Was the study that Nairu Shah did 5
generic for 205 fuel assembly plants?
G A
Yes.
7 Q
Did he do any calculations for 177 fuel 8
essembly plants?
9 A
I don't recall.
10 Q
When did the concern first d,ccur to you 11 that pumps running might be a worse case for effective
(~}
12 core cooling than pumps off?
\\j 13 MR. BENEDICT:
When did it first come to 14 his attention?
15 A
Roughly December of 1978.
IG Q
When did you first study in ECCS Analysis 17 the possibility of having the pumps running and then 18 losing off-site power in the middle of a transient?
19 A
Around July of 1979.
20
.Q When did it first occur to you that'you 21 should study that?
22 A
The specific study done was done in response to 23 a request by Dr. Rosztoczy.
I don't recall coming to n
21 any conclusion to do that oth-than in response to his 25 concern, his questions.
That would put it in the July
~
78 1
Jones 2
'79 time frame when the actual. analysis was done.
3 Q
When did you first file a PSC on the pumps 4
running case?
It was in May 1979, wasn't it?
5 A
I don't recall filing a PSC on the pumps running 4
6 case.
7, Q
Isn't it a fact that there was a preliminary 8
safety concern filed with respect to the pumps running 9
case in May 19797 I
10 A
I don't recall.
A 11 Q
Do you know who Charlie Parks is?
l 12 A
Yes.
13 Q
What section does he work 1.n?
14 A
lie works in the Plant Engineering Section.
15 Q
What tnit?
16 A
He works in the Systems Engineering unit.
17 Q
It is news to you that a preliminary safety i
18 concern was filed with respect to the pumps running-19 case?
20 MR. BENEDICT:
Objection.
21 A_
I don't recall whether one was filed or not.
22 Q
Did you ever give'any consideration to 23 filing a preliminary safety concern with respect to r
\\~#~
24 the pumps running case?
25 A-I don't recall.
e i
.1
..mm
f 2
a 1
Jones 79 s
(:)
2 Q
You said in December 1978 you perceived 3
that the pumps running case might be a worse case than 4
pumps off for small break loss-of-coolant accidents.
5 What did you mean by a worse case?
)
6 A
I didn't say I perceived that.
7 Q
You said you were concerned that it might 8
be.
9 A
What I said was that a c$ncern had been raised 10 that it might be, and we examined it.
11 Q
What did you mean that it might be a worse 12 case?
Worse in what way?
13 A
Relative to previously analyzed cases.
14 Q
What would be worse about it?
Worse in 15 what way?
e 16 A
Leading to increase d cladding temperatures 17 over the pumps off situation.
18 Q
Cladding temperatures which might fail 19 to comply with 10 CFR 50.46; is that right?
20 MR. BENEDICT:
I object to the question.
21 A
I don't think tiore was any preconceived notion 22 as to what the implications on the temperature would
~
h.
23 bo other than we wore not sure whether it would be 24 worse than what we had previously analyzed, so we 25 wont and examined it.
y y
i%
- -+-
---,y m
--,*s
1 Jones 80 2
Q Did Nairu Shah prepara any reports on the 3
examination that he performed at your instruction and 4
diroction?
5 MR. BENEDICT:
Objection.
Asked and 6
answered.
7 A
I don't recall.
8 Q
Did anybody work with Nairu Shah?
9 MR. BENEDICT:
On this project?
10 A
Not that I can recall.
11 Q
Did there come a point in time when you 12 realized that turning the reactor coolant pumps off in 13 the course of a cooldown was a worso case than leaving 14 the pumps on throughout a cooldown or shutting them 15 off immediately at the start of cooldown?
1G MR. BENEDICT:
I object to the form of 17 the question.
18 If you understand it, you can answer.
10 A
Could you road it back.
20 Q
I will restato it.
21 Did thora como a point in time when you 22 realized that shutting the reactor coolant pumps off 23 at some pnint in the middle of a cooldown was worso i
O i
21 than shutting them off within the first two minutos 25 after the start of the cooldown or leaving them on
81 I
Jones 2
throughout a cooldown?
3 MR. BENEDICT:
Same objection, but go ahead.
4 A
No.
5 Q
Are you saying that as of today, you don't 6
believe that shutting the pumps off 10 or.15 minutes 7.
into the 1 css-of-coolant accident is a worse case 8
than running the pumps throughout the accident or 9
shutting the pumps off at the outset of the accident?
10 A
Dur.ing a small break LOCA situation, it depends 11 on the cace as to whether or not shutting the pumps 12 off for 15 minutes is a worse condition or better
(
13 condition or an acceptable condition.
14 Q
It is a fact, isn't it, that there are 15 small break loss-of-coolant accidents for which the 16 worst case is shutting the reactor coolant pumps off 17 in the middle of the transient?
18 A
yes.
19 Q
When did you first come to know that?
[
20 A
July 1979.
21 Q
Are you saying.that you only came to know 22 that in response to a question from the NRC7 23 MR. BENEDICT:
I object-to the question, p-b 24 but if the question is, did you become aware 25 of this in responso to.a communication with the
.v
+
~.
i f
82 1
Jones
("%
k- -
2 NRC, then that is fine.
Go ahead and answer 3
my question.
4 A
Yes.
5 Q
You had no plans to study that case prior 6
to getting the question from the NRC7 7
A I don't recall.
8 Q
You don' t recall anybody being assigned to 9
do that before the question came from the NRC; is t
10 that right?
11 A
Not that I can recall.
12 Q
Was it after your section had done the work 13 in response to the NRC's question that B&W changed 11 itc recommendations to the operators on whether to 15 shut the reactor coolant pumps off at the start of 16 the transient?
17 A
Yes.
18 Q
Bofore you had done that work, there had 10 boon a period of time when B&W's recommendations to 20 the operators vero to leave the reactor coolant pumps 21 on throughout small break loss-of-coolant accidents; 22 isn't that right?
23 A
Yes.
21 Q
That had boon tho advice that had 25 initially bocn given by nLW shortly after the Throo
I i
83 Jones 1
f--
2 Milo Island accident; right?
s 3
A It was the advice that was contained in the 4
original set of guidelines that went out around May 5
7th of 1979.
6 Q
Prior to May 7, 1979, what instructions and guidelines had B&W given the operators regarding 7
8 the handling of the reactor coolant pumps during a 9
small break loss-of-coolant accident?
E 10 A
I don't recall.
I 11 Q
Do you think you ever know?
12 MR. BENEDICT:
I object to the question.
(
13 If you can answer it, you c[n try.
I i
14 A
I don't rocall.
l I
15 Q
You don't recall whether you ever knew what B&W's instructions were regarding the operation 16 17 of reactor coolant pumps during a small break loss-of-18 coolant accident prior to April 19797 10 A
Prior to April, I did not know.
20 Q
Prior to the Three Mile Island accident, had it been the practice, to your knowledge, for the 21 22 ECCS Analysis unit to review the operating procedures 23 prepared and recommended by B&W relating to recovery 21 from a loss-of-coolant accident?
supplied operating 25 A
I don't know whether B&W over
I.
i-b Jones 84 1
3(a v
guidelines prior to the Three Milo Island accident, 2
and I know of'no instance whero we reviewed any such 3
i-quidelines, assuming that such guidelines existed.
j' 4
Q The "we" in your sentence is members of 5
the ECCS Analysis unit?
6 A
That's correct.
7
~
8 Q
You are saying that right up to today you were ignorant of whether B&W was drafting and g
runni,g B&W-supplied preparing operating procedures for n
10 nuclear equipment?
gg MR. BENEDICT:
I object to the 12 characterization of his testimony.
13 Q
Is that correct?
I am not trying to 14 charactorize testimony at all.
I am asking whether 15 that is correct or not.
16 Tile WITNESS:
Can I hear it again?
g7 (Record read.)
18 1
~
A Up to today, I still do not know whether B&W gg was p'roparing operating proceduros for the plants.
20 k
Q I would like to show you an execrpt-from y ur testimony before the NRC special inquiry group, 22 and I would like to ask you first whether cinco giving g
this testimony, yo, have road it over, and if it helps, 24 maybo I can ask your 1 to be so kind as to pass 2.
1 w
m:-
r e
- t-
+
_ _. = -
85 1
Jones 2
you a copy and you can peruse it.
3 MR. BENEDICT:
I object to it if it has i
4 to do -- he can answer the question outside of l'
5 any discussions he may have had with counsel 6
in which his testimony was reviewed.
7 A
other than examining it for accuracy after the 8
deposition, I have not reviewed this other than in 9
the presence of counsel.
10 Q
You have stated in your opening phrase t
11 exactly the substance I was driving at.
'I take it 12 it is a fact that you did review the transcript of your e,
k_)
13 deposition for accuracy; is that right?.-
14 A
Shortly after giving it, yes.
15 Q
Did you believe at the time you were 16 giving this testimony that it was accurate and 17 truthful to the best of your knowledge?
18 A
Yes.
19 Q
when you reviewed it in its typewritten 20 form in which you have it in front of you, did you I
21 believe it was still accurate and truthful?
22 A
Subject to whatever errata sheet I filed, yes.
23 Q
In other words, other than the errata
}
24 that you filed, everything else was accurate and V
25 truthful, to the best of your knowledge?
e V
s
86 1
Jones i
O 2
A Yes.
3 Q
Do you still believe that?
4 MR. BENEDICT:
I cbject to the question.
5 If he hasn't looked it over, how can he answer?
f 6
MR. SELTZER:
I think he said with counsel 7
he did look it over.
8 Q
Do you have a belief today that the accurate testimony that you are holding in your hands is 9
10 and truthful when viewed together with the errata
(
11 that you previously filed?
12 MR. BENEDICT:
I object to the question, 13 but you can answer it.
14 A
Yes.
15 Q
would you turn to page 68.
At the bottom of page 68, the NRC examinor stated:
"It. strikes me 16 17 as just a little strange that your group does the ECCS 18 analysis and yet you don't have sny involvement with the procedures associated with small breaks or breaks 19 20 of any kind.
Doesn't that strike you a's being at all 21 inconsistent?
22
" Answer:
It is somewhat inconsistent.
23
%s I said, to my knowledge, we never reviewed it.
After There may have boon instancos where we have.
24 aro definitely in the' review chain 25 Throo Mile, Island wo
-____-_ ____L 1___
j
k_
' f
+
s-h N
1 Jonea 87 s
~~ -
2 for procedures, but)J have ncver seen it before, and 3
it does seem st ange, yes..
4 Questiont In your opinion, should"you -
s.,
5 have been in that gnview chsin before Three. Mile
(
6 Island?
" Answer:
Yes.
7 i.
8'
" Question:
Do you know-if anyone.everc 1*
9 took any actions to try and have you. included ir,the 0
i l
10 review chain?
,. s 11
" Answer:
Not that I know of."
12
,(Jn your deposition by the NRC special s
13 inquiry, wa"re you asked those questions,and did you 14 give those gaswers?
15 A
Yes.
16 Q
why did you 5plieve, in your opinion, that x; s.
=
17 you and members of the ECCS Analysis unit should have 18 been in the chain of review of operating p,rocedures 19 prior to the Three Mile Island accident?
7 20 A
Basically, because we are the people that do 21 those analyses and would be able to draw conclusions k
i 22 as to whether or not they may be' adequate based on our 23 knowledge, but when I answered these, I answered'it
~}
24 in the sense of procedures generally for small breaks.'
V V..
25 I-am not referring to aq; s'pecific's&w procedures that t
.l' 88 1
Jones i
['
fl 2
'I can remember.
3 Q
Let me reassure you that I am not trying l
4 to bu id out of your testimony the fact that B&W l
l 5
did draft procedures.
Your counsel can tell you if 6
he cares to off the record the extent to which other 7
B&W witnesses have testified to the fact that 8
procedures are drafted 'uy B&W for the operating 9
utilities.
10 Are you aware that B&W has in Lynchburg 1
11 a control room simulator?
12 A
Yes.
13 Q
Are you aware that there are a set of 14 procedures for running the simulated plant which is 15 connected to that control room simulator?
16 A
Yes.
17 Q
Who, to your understanding, do you think 18 drafted the procedures for that simulator?,
19 MR. BENEDICT:
I object to the form.
20 If you know who drafted them.
21 Q
What is your understanding of who drafted 22 the m?
23 MR. BENEDICT:
I object to his understanding O-'
24 if it is based on recollection.
\\s 25 If you know who drafts them, you can tel?
t 89
{
Jones 1
b) 2 him.
4 3
A I don't know.
4 Q
Do you have any underst!,ading?
I am not I am asking for a 5
asking for a person, by the way corporation do you understand drafted 6
company.
What t
4
/
the procedures for the Babcock & Wilcox control room 8
simulator in Lynchburg, Virginia?
l MR. BENELICT:
I ' object to the question 9
of the word " understanding" if i
10 through ycur use
(
seeking something other thdn his 11 you are 12 knowledge of what he knows as to who drafted h1
'/
13 the procedures, the organization.
f 14 MR. SELTZER:
I don't want who.
I think 15 you are trying to disrupt the sense of the 16 question.
17 MR. BENEDICT:
I am not.
The pending 18 question is:
do you know what organ,ization i
19 drafted the procedures for the simulator at 20 Lynchburg.
I 21 A
I don't know.
anybody ever told you those procedures 22 Q
Has l
~~
were drafted by any organization other than Babcock 23
[)
24
& Wilcox?
%j 25 A
I don't know who drafted the procedures.
Nobody T'
W
]
4 90 1
Jones O
k/
2 has tell me whether it was B&W or any other 3
organization.
I don't know.
4 Q
Does the ECCS Analysis unit review l
5 operating procedures today?-
6 A
No, we do not.
7 Q
Have you ever recommended to anyone that 8
the ECCS Analysis unit should review plant operating u
9 procedures?
10 A
Not that I can recall.
t 4
11 Q
To your knowledge, has anybody in ECCS 12 Analysis, including Mr. Dunn, the manager of the unit, 13 recommended that ECCS Analysis could perform a useful 14 function in reviewing plant operating procedures?
15 A
Not that I can remember.
16 Q
When you said that you have never 17 recommended it, do you mean that you have never even 18 told Bert Dunn that you think the ECCS Ana,1ysis unit l
19 should be reviewing plant operating procedures?
20 A
I don't recall makhti such a statement to him.
21 Q
Do you know any unit within B&W that l
22 reviews plant operating procedures?
23 A
Not that I am aware of.
24 Q
Prior to the Three Mile Island accident,
("
(_-
25 what, if any, involvement did you have in the training m
y o
.I i
1 4
91 1
Jones l r
(
I i
l 2
of operators?
l 3
A None that I can remember.
'4 Q
You never went over to the Training 5
Department to give any instruction whatsoever to a 6
group of operators?
4
/
7 A
Prior to the accident?
8 Q
Right.
1 9
A No.
L 10 Q
Prior to the accident, were you ever in 11 the control room of a B&W supplied plant while it was
()
12 eritical?
13 A
No.
14 Q
What does critical mean?
15 A
I generally interpret that to mean a,self-16 sustaining nucicar reaction.
c 17 Q
So you were never in.a. plant before the 18 Three Mile Island accident while it was generating 19 power?
20 A
That's correct.
21 9
' Prior to the. accident, were you ever in a 22 plant that had fuel loaded in it?
23 A
Yes.
I
\\_/
Prior to the Three Mile Island accident, 24 Q
L 25 had you ever performed any operations on the B&W
.m-
32 Jones 1
simulator?
2 A
No.
3 Q
Prior to the Three Mile Island accident, 4
accident 1 ad you ever witnessed a loss-of-coolant 3
5 bding simulated on the B&W simulator?
6 A
No.
7 8
Q Prior to the Three Mile Island accident, had you ever asked anybody in training whether they 9
could please show you a loss-of-coolant (accident on 10 the B&W simulator?
gg A
No.
12 Q
Pri r to the Three Mile Island accident, 13 had you ever seen a copy of the procedures used by 34 p rat rs f any B&W plant to handle a loss-of-coolant 15 accident?
IG
^
17 Q
Prior to the Three Mile Island accident, 18
~
had you ever asked anybody to show you a copy of the 19 pr cedur s used by the operators at any plant to 20 respond to a Joss-of-coolant accident?
g A
It was not part of our job responsibilities to 22 valuate those, and I never asked anybody to see them.
23 Q
You never asked because you didn't think it g
was your responsibility?
,mg
93 1
Jones 2
A It was not part of the responsibility of the 3
unit, that's correct.
4 Q
What nuclear plant control rooms were you r
5 in prior to the Three Mile Island accident at which 6
fuol had already been loaded?
7 A
I don't recall whether I was in a control room 8
of a plant that had fuel in it.
9 Q
You mean you may have been in error in your i
10 carlier testimony when you said that you were?
11 MR. BENEDICT:
Objection.
He didn't say
['T 12 he was.
~
N./
13 MR. SELTZER:
I beg your pardon; he did.
14 MR. BENEDICT:
I object.
It is not 15 accurate.
IG MR. SELTZER:
What do you think he said?
17 MR. BENEDICT:
He said he was in a plant 18 that had fuel loaded.
It is a different 19 question than he had been in the control room.
20 Just don't badger the witness.
21 Q
Does Rod fasten on a distinction that has 22 substance?
23 A
Yes.
21 Q
What plant were you-in that had fuel
.\\
25 loaded?
4 94 1
Jones d
N,)
2 A
Peach Bottom 1.
s 3
Q Where is Peach Bottom?
4 A
I don't remember the exact location, but I e
5 believe it is in Pennsylvania somewhere south of 6-Philadelphia.
i 7
Q Is that a B&W plant?
8 A
No.
When were you in Pbach Bottom?
9 Q
t 10 A
In the spring of 197t.
11 Q
Why were you there?
12 A
One of the college professors arranged for a
(
13 class in the Nuclear Engineering Department to go and 14 view a couple of nuclear power plants.
15 Q
While you were a full-time employee of the 16 Babcock & Wilcox Company working as an engineer in 17 emergency core cooling system analysis, wdre you ever 18 in a nuclear plant that had fuel loaded?
19 A
No.
20 Q
Were you ever in a nuclear plant while 21 you Woro in the ECCS Analysis unit?
22 A
No.
23 Q
Did you ever talk to operators while you
. Ol
\\
24 were in ECCS Analysis?
25' MR. ILENEDICT:
Up to today?
\\
a
>--,w-
4 95 1
Jones
.gs
\\
~]
1 2
MR. SELTZER:
Prior to the Three Mile I
3 Island accident.
4 4
A No.
5 Q
Prior to the Three Mile Island accident, j
6 did you ever talk to members of tho training group at 7
Babcock & Wilcox to find out.what kind of training.
j P
was being given to operators on responding to 9
loso-of-coolant accidents?
E 10 A
No.
4 11 Q
other than simply saying it is not my 12 responsibility to do any of these things, did anybody
(
13 over tell you that you were forbidden to talk to 14 operators, talk to trainers, see procedures, or visit 15 nuclear plants, as an employee working on emergency 16 core cooling system analysis?
17 MR. BENEDICT:
At any time has anyone 18' ever told him that?
19 MR. SELTZER:
Yes.
20 A
No, and in fact, there have been tours arranged 21 at times for people to visit nuclear power plants,.
22 for example, so there was no prohibition on that.
23 Q
You just never saw fit to participate in 7_q
(
)
~
24 any of those?
25 MR. BENEDICT:
I' object to the form of the 1
96 1
Jones
(-)
4 3s /-
r 1
2 question.
3 g
Is that right?
through a nuclear power plant at 4
A Having gone 5
college, I didn't see any necessity to go through 6
another one.
7.
Q When you learned that the operators at 8
Davis-Besse had terminated high pressure injection 9
in the course of a loss-of-coolant situation, you e
10 concluded, did you not, that that termination of high 11 pressure injection was improper operator action?
12 A
Yes.
13 g
Did you ever ask, at the time that you 14 reached that conclusion, to see a copy of the procedures 15 that were in the control room at Davis-Desse?
16 A
No.
17 Q
Did you ever ask what guidanco B&W had 18 previously given the operatorn at Davis-Besso regarding 19 the operation of high pressure-injection?
20 A
No.
4 21 Q
You just felt it wasn' t yoor responsibility 22 to ho looking into those things?
23 MR. BENEDICT:
I object.
\\-]
24 g
-Is that why you didn' t ask?
25 MR. BENEDICT:.The question is, why didn't
97 I
Jones f%
2 he ask.
s 3
A one of the reasons I didn't ask at the time 4
was that after a discussion on the transient, we a couple of 5
discussed with another individual, 6
individuals and I discussed the inappropriateness 7
of the operators' response.
8 Q
When you had that discussion, it was with 9
Joe Kelly and Bert Dunn; right?
E 10 A
Yes.
11 Q
When you had that discussion, you didn't f~h 12 know what training those operators had received from J
13 B&W, did you?
14 A
No, I did not.
4 15 Q
When you had that discussion, you didn't a
16 know what, if any, procedures those operators had 17 received from B&W, did you?
18 A
No, I didn't.
19 Q
So you don't know whether the action'those 20 operators took during the Davis-Besse transient was 21 consistent or inconsistent with their B&W training 22 or any B&W supplied procedures?
i 23 MR. BENEDICT:
Or procedures drafted by O'
21 anybody else.
25 MR. SELTZER:
My question is limited to
98 I
Jones q
NY 2
What they were trained by B&W and what they were 3
told by B&W or by B&W drafted procedures.
4 MR. BENEDICT:
He already said he wasn't 5
told.
Therefore, limited to procedures by one 6
group or another is a meaningless question.
7 MR. SELTZER:
Would you like to hear the 8
ouestion reread.
9 (The reporter read the question as follows:
10 "So you don't know whether the aedion those 11 operators took during the Davis-Besse transient consistent or inconsistent with their B&W i
12 was N/
13 training or any B&W supplied procedures?")
14 MR. BENEDICT:
Objection.
15 MR. SELTZER:
Your objection is on the 16 record.
17 MR. BENEDICT:
He doesn't have to retype 18 the question thern either.
19 MR. SELTZER:
I am not asking him to 20 retype it to deface your objection, but because-21 it gets lost in your objection.
22 MR. BENEDICT:
He alrcady testified he 23 hasn't received any.
. (^)
^
kl 24 g
subject to your counsel's objection, my 25 question is:
it is a fact that-you don't know,
- L>
l 99 Jones 1
l'
\\s 2
do you, whether the action taken by the Davis-Desse perators on September 24, 1977, was consistent or 3
inconsistent with their training by B&W or any 4
pr cedures they got from B&W: isn't that a fact?
{;
5 I'
MR. BENEDICT:
I press my objection.
6 You can answer the question.
7 g
A No, I do not.
Q And you never took any steps to determine 9
whether thati action was consistent or inconsistent 10 wi'th B&W training or B&W supplied procedures, did you?
11 MR. BENEDICT:
I voice the oame objection;
/
12
(
improper in form.
13 A
No, I took no action.
g4 15 Q
Do you know of anybody in the ECCS Analysis unit who took any action to determine whether the 16 Davis-Desse operators'were acting in conformance to g7 B&W training and B&W supplied procedures when they 33 terminated high pressure injection prematurely on 39 September 24, 19777 20 MR. BENEDICT:
Same objection.
21 A
Specifically whether anybody did that, I don't 22 know.
23 h
D' Q
Do'you know generally whether anybody did g
25-that?
- - - ~,
- 27 4
100 1
Jones N_
2 (Record read.
3 MR. BENEDICT:
Do you have a time frame?
J 4
You mean evor?
(
1 5
MR. SELTZER:
Ever.
t l
6 MR. BENEDICT:
The question he answered.
7 He did not specifically recollect, and you asked 8
if he had a general recollection.
-9 MR. SELTZER:
Right.
I question (is utill
{
10 MR. BENEDICT:
The i
11 limited to your recollection.
i I'h 10 A
I don't know.
(~/
1 i
13' Q
Was anyone from the ECCS Analysis unit 1
14 involved in the training of operators prior to the 15 Three Mile Island accident?
16 A
There has been some involvement by ECCS 17 personnel.
{
18 Q
Had.Bert been involved?
10 A
I don't know.
20 Q
Who are the ECCS personnel you were thinking 21 of when you said there had been some involvement?.
22 MR. BENEDICT:
If you havo names.
23.
A A follow by the name of Bill Schormer.
. o.
'\\/
24 Q-Anyone also?
25 THE WITNESS:
Can I have the original W
4
~
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..a
+,..n n
,----,.,vn.-
,.,,..~,-,.,m-
101 I
Jones
(~N
' N_Y 2
question?
s 3
(Record read.)
~4
-A Not that I can recall.
C 5
Q Do you keep a chronological file of 6
correspondence and memos that you generate?
7 A
My secretary keeps one or the unit secretary.
8 Q
Do you know whether that chronological 9
file was searched for documents that should be t
10 produced in this lawsuit?
11 A
I can't recall.
I examined all documents that 12 I felt needed to be reviewed.
I don't recall whether (s
13 that specific document was examined.
14 Q
You don't recall telling anybody to bring t
IS you the chronological file for review in this lawsuit; 16 is that right?
17 A
No, I don't recall.
18 MR. SELTZER:
So we can make an attempt 19 to fin 1sh this depositien this week, can we 20 get a copyLof Mr. Jones's chronological file?
21 MR. BE!! EDICT :
If he has one.
22 MR. SELTZER:
lie just said he did.
23 MR. BENEDICT:
Let_me add,that hasn't O
24 been produced.
2,5 Q
Do you have filing cabinets that are your
1 Jones 102 i,
l
\\-
2 personal files at B&W7 i
{
3 A
Yes.
4 Q
What did you do to attempt to ferret out 5
the documents that should be produced from those C/
6 filos?
7 MR. BENEDICT:
I object to these questions.
8 If you have a problem with the document 9
production, up to this. point you and I have 10 tried to work it out off the record.
If you
(
11 have some questions that you want to ask Mr.
12 Jones about what kind of documents he kept, I am 13 happy to do that, but I really think this is 14 wasting everybody's time and not at all clearly 15 appropriate to spend a lot of time talking 16 about what he did to collect the documents for 17 this case.
18
!!R. SELTZER:
I have found in my experience 19 taking depositions and conducting discovery that 20 this form of examination is frequently very 21 fruitful and well worth the time spent in its 22 potential for finding documents that inadvertently 23 were not previously produced.
I do say r~
24 inadvertently because I am not suggesting by
\\.-
25 my ex, amination that the nonproduction or any
1 Jones 103 I
2 files, if there was nonproduction, was done 3
through venal motive or intent.
s 4
MR. BENEDICT:
I appreciate that.
I do 5
not intend to stop you from asking what sort
(
6 of files Mr. Jones keeps.
That is all right.
7 And to ask him whether he knows the material 8
ultimately was produced to you.
9 MR. SELTZER:
I really want to do it my 10 way.
I know it is proper.
I have seen it done E
l 11 to' witnesses I've defended, I hav'e done it 12 repeatedly, and that is the way I intend to
()
13 proceed.
[
14 MR. BENEDICT:
I will continue to press 15 my objection.
I will object to the question 16 pending.
17 Q
The question is, what steps did you take 18 to ferret out documents from your files which you 19 thought were responsive or should be reviewed for 20 responsiveness in this case?
21 MR. BENEDICT:
Any answer has to exclude 22 any discussions you had with lawyers or l
l 23 representatives of the law firm or of people 1
24 in houseoor working at the request of lawyers.
n'^'
25 Also it has to exclude any communications,.
_____.___________._____________.________m
i 104 1
Jones whether they were written or oral, with lawyers.
2 3'
If you can answer the question without delving 4
into those subjects, go ahead.
(Discussion of f the record between the 5
witness and his counsel.)
6 7
A What I did was pulled out the files that I felt 8
might possibly contain information relative to the 9
document request, reviewed those files, and ifI
(
10 found information that fit the categories, they were 11 produced.
12 Q
What did you mean by " fit the categories"?
(
MR. BENEDICT:
I object to your trying 13 to ask him what he understood the categories 14 would be because I understand that would be part 15 16 of the attorney-client communication.
I think your question might be better phrase'd -- I 17 18 withdraw that.
I don't think I am going 19 to take a shot at rephrasing the question.
Let's hear what we have.
20 (Rec rd read.)
21 MR. BEMEDICT:
I request or I direct that 22 the witness anewer the question limiting 23
-)
himself to not discussing the substance of the
\\
24 categories.
2.")
/
7 1
' ~ ^
-=e.
.. ~... -,
i i
1 Jones 105 f^g 2
A The information -- there were certain types of 3
information requested, and that information was produced.
4 Q
Did you have a list of categories that 5
you were working from?
6 MR. BENEDICT:
I object and instruct the 7
witness not to answer unless he has a list of 8
categorios provided to him other than by tho 9
lawyers.
I 10 Q
You can answer the question."
11 MR. BENEDICT:
I disagree.
He cannot
(
12 answer the question unless -- he can answer the s_-
13 question as to whether he had a l'i s t that was 14 provided to him other than by lawyers or 15 representatives of lawyers in this case that 16 he used.
17 Q
Did you have any list that you got from a 18 non-lawyer?
19 A
No.
20 Q
Did you ever soc the list that the 21 attorneys for General Public Utilitics had prepared 22 roquesting documents?
23 MR. BENEDICT:
You mean the court papor?
^
.24 MR. SELTZER:
There was a request just 25 served on Babcock & Wilcox.
L
l 106 I
Jones
~)-
2 MR. BENEDICT:
If you didn't get it from a 3
lawyer.
4 MR. SELTZER:
Even if he got it from a 5
lawyer, there is nothing privileged about 6
handing him the Rule 34 request prepared by 7
Kaye, Scholer.
We are not lawyers for him, 8
and you can't clothe it with a privilege just 9
because you handed it to him.
t 10 MR. BENEDICT:
You can answer if you got 11 it from someone other than a lawyer.
f~ )
12 A
I don't recall.
\\/
13 Q
How long did you spend reviewing your files 14 for the purposes of culling out material to be 15 produced?
IG A
one or two days.
17 Q
Solid days or were you doing other work 18 at the same time?
19 A
As best I can remember,_they were solid days.
20 Q
Did anybody else review your files to see
.21 if there was material that should be produced, other 22 than the review you made of your files?
23 MR. BENEDICT:
Other than lawyers.
24 Let me back up.
Do you mean, did someone
~'
2i' review the files that he' reviewed, or did someone j
- ~=.
1 107 1
Jones
(~s t) 2 assist him in reviewing files?
3 MR. SELTZER:
Both.
4 MR. BENEDICT:
You can answer the question.
C3 5
A Not that I can recalle 6
Q Did you take any steps to retrieve any 7
files which you had previously sent to central filing 8
in order to review them for production in this i
9 litigation?
t 10 A
Yes.
1 11 Q
Did you review files previously sent to
- Ol 12 contral filing?
(
13 A
- yes, 14 Q
How did you determine which ones to 15 request from central filing?
16 A
We have our own -- we have a unit set of filos I
t 17 which contain documents which are contained in 18 contral files, and those documents were reviewed.
4 10 Q
Who reviewed them?
i 20 A
Various people within the group.
21 Q
Does-ECCS Analysis have.a copy of the 22 calculation filos which have been cont to contral 23' filing?
- L/
24 A
Yes.
25-Q Who in ECCS Analysis, if anyone, reviewed
'~'
i =
1 Jones 108 2
the calculation files to see if some of those should 3
be produced?
4 MR. BENEDICT:
If you know.
5 A
Several people within the unit.
6 Q
who?
7 A
I know I did.
I don't know specifically who 8
else did.
All I can recall is that several people
(
l 9
did.
k 10 Q
After his deposition, did Bert Dunn 11 discuss with you any of the subjects that had been 12 covered in his deposition?
13 MR. BENEDICT:
Other than in the presence 14 of lawyers.
15 A
Not that I can recall.
16 Q
11a s anybody who has previously been 17 deposed in this lawsuit discussed with yon anything f
18 about their depositions?
19 MR. DENEDICT:
Same limitation.
20 A
Yes.
21 Q
Who?
22 A
Joe Kelly and Frank Walters.
Generally what they 23 said was it was very tiring.
(
I 21 Q
What, if anything, elue did Joe Kelly 25 tell you about his deposition?
_.~
t 109 1
Jones
(")
'J 2
A Other than just the general nature of what it 3
was like, the tiring nature of it, nothing about the 4
contents that I can recall.
The same holds true for C
5 Mr. Walters.
6 Q
10 CFR 50.46 A-1 states, in part:
"ECCS 7-cooling performance shall be calculated in accordance 8
with an acceptable evaluation model and shall be 9
calculated for a number of posculated loss-of-coolant L
10 accidents of different sizes, locations,*and other 11 properties sufficient to provide assurance that the 12 ontiro spectrum of postulated loss-of-coolant accidents
()
13 is covered."
14 Do you recognize that as being in 15 substance something which is contained in,_50.467 16 MR. BENEDICT:
Why don't you show him the 17 regulation?
18 MR. SELTZER:
Because I want to ask him if 19 he recognizes that as being, in substance, what 20 is in 50.46.
21 MR. BENEDICT:
You want to test his i
22 momory as to the language of'a statuto.
~
23 A
Generally I remember there are statements to 7-4
\\'^']
21 that effect within the. regulation.
25 Q
Who, if anybody, has over explained to you
- - ~.
~.
110 i
Jones fg 2
what that requirement 50.46 means?
I will withdraw that.
3 4
Has anybody ever explained to you what (t
5 that requirement of 50.46 means?
6 MR. BENEDICT:
I object to these questions f
7 because you won't show him the language of the 8
statute.
You are welcome to answer the question, 9
but I object to the form.
e 10 What is the pending question?
11 (Re cord read.)
12 A
only that generally the analyses have to be
(.
13 performed over -- nobody that I can remember has ever 14 explained it in detail that I can recall.
15 Q
Is it fair to say that you gained an 16 appreciation of the meaning of that section of the 17 regulations through working with it?
18 A
Yes.
19 Q
I show you a photocopy of 10 CFR part 50, i
l 20 opened to 50.46 A-1.
Do you see the portion in the lower right-hand corner of the page which is the same I
21
/
f 99 as I read to you?
I I
l f
23 A
Yes, as far as I.can remember your quote.
~
i 2.g Q
The requirement that ECCS cooling
~
25 performance be calculated for a number of different l-r
111 1
Jones
-(
2 sizes, locations, and other properties, sufficient to entire' spectrum of postulated loss-of-coolant 3
cover the i
4 accidents means that your analyses have to bound 5
all postulated accidents; right?
Is that your understanding?
6 MR. BENEDICT:
7 A
Yes, within the confines of the requirements of 8
Appendix K for the analysis.
9 Q
What does the reference to different 10 sizes mean to you as you have~ applied thfs regulation 11 in your work?
O 12 A
Basically, that the area of the postulated' leak
()
13 be varied.
you m'ean the square 14 Q
When you say the area, 15 feet or square inches of the break?
16 A
Yes.
17 Q
What do you mean, it must be varied?
18 A
You look at several different leak areas'in 10 square feet.
20 Q
Does it mean in the convaxt of 50.46 21 there should be no break which is either smaller or 22 larger than the. breaks you have studied which prcduces 23 a worce result than the breaks that have been studied?
7 24 A
Within.the confinns of Appendix.K, yes, and
\\ ^)
25 recognizing that Appendix K limits the upper size and
112 Jones
/~N 1
}
bsY i
2 lower size of_the holes to be analyzed.
3 Q
What is the upper size limit?
4 A
Double-ended rupture of the largest pipe in the q
i 6
Q Is the largest pipe a recire pipe?
7 A
I am not familiar with the language recire 8
pipe.
9 Q
A recirculation pipe attached to the t
10 primary coolant pumps.
11 A
No.
12 Q
What is the largest pipe?
13 A
The hot leg.
14 Q
What is the smallest break defined by 15 Appendix K?
16 A
It is defined in 50.46 C-1, that it is a size 17 which would result in'the loss of reactor coolant at a 18 rate in excess of the capability of the reactor coolant 19 makeup system from breaks in pipes in the reactor 20
-coolant system pressure boundary.
as to the 21 Q
What is your understanding i
of break which is defined by that lower 22 smallest area 23 ond?
l
\\_).
24 A
I don't-remember the area, but it corresponds
(
l' to roughly a one-half inch diamotor pipe.
- 25 r
m
.._~w..-
'I 113 1
Jones b%
i 2
Q How big is the orifice of a pilot operated 3
relief valve?
E 4
A It has an area of about.007 square feet, but 5
I don't remsmber its diameter.
6 Q
Do you know whether a stuck open pilot 7
operated relief valve is within the range of break 8
cize that should be studied under to CFR 50.467 9
A It is within the range of break sizes which must i
10 be demonstrated that the ECCS system-pr' ovide 11 acceptable core cooling as defined by the regulation.
12 Q
The regulation you are refeyring to is
(
13 50.46 A-17 14 A
50.46 and Appendix K in combination.
15 Q
What does the reference to different IG locations mean in the context of 50.46 A-17 17 A
Different locations in the primary system, for 18 example, the hot leg, the cold leg, piping.
19 Q
The top of the. pressurizer?
20 A
That would be a location, yes.
21 Q
What are the other properties that have 22 to be studied in order to provide assurance that the 23 entire spectrum of postulated loss-of-coolant accidents 7y
's' 'I-24 is covered?
25 A
The shape of the break, that is,.the general
114 I
Jones
(~T Q) _
2 nature of the break, and its effective discharge 3
coefficient.
4 Q
It is a fact, is it not, that you knew 5
by the time of the Three lille Island accident that 6
breaks of the same size can have different effects 7
on the reactor coolant system depending on their 8
location?
9 A
- Yes, t
10 g
You knew as of the date of the Three Mile a given size 11 Island accident that studying a break of
)
12 in one location does not bound a break of the same I3 size at another location?
14 A
No, I wouldn't agree with that.
15 Q
What if I asked you, didn't you learn that 16 a break ot a given size in the pump suction line 17 did not bound a break of the same size in the pump 18 discharge line?
10 A
That's correct.
20 Q
And you know that at the time of the Three 21
!!ile Is1 I accident, didn't you?
22 A
Yes.
23 Q
And the principal difference was that it fs
\\
LJ a break in a different location but of the same 24 was 25 size; isn't that right?
115 1
Jones
(~'. -
e].
2 A
Yes.
3 Q
In fact you were the author of the that dealt with that 4
preliminary safety concern
)
5 problem, weren't you?
6 A
I was the author of the prolininary safety 7
concern which stated that the previously analyzed 8
breaks in the suction did not bound breaks in the 9
pump discharge piping, yes.
t 10 Q
You have chosen to use a phrase in 11 response to something else, telling me that something 12 was not your responsibility.
Prior to the Three Mile
[ ).
v 13 Island accident, did you consider it your 14 responsibility to determine whether B&W.was in 15 compliance with 10 CFR 50.46 for the full range of 16 different sizes, locations, and other properties 17
.that needed to be studied to assure that the entire 18
. spectrum of loss-of-coolant accidents had been 19 studied for the 177 plants?
20 A
I deemed it my responsibility to perform the
{.
21 analyses necessary to demonstrate that, _ yes, that the-i 22 ECCS systems were in compliance with 50.46.
i-i 23 Q
It was your responsibility to determine 24
=that all of the necessary sizes, locations, and'other
'~'
25 properties had been studied?
~
116 1
Jones 0
2 A
I viewed my responsibility as assuring myself 3
that sufficient analyses had been performed within the 4
guidelines of Appendix K to assure that the effects 5
of different locations or sizes or other propertica 6
were indeed bounded by what we had done and that we 7
had demonstrated compliance with 50.46.
8 (whereupon, a recess was taken.)
3 BY MR. SELTZER:
(
10 Q
During the years that you have been acting 11 supervisory engineer or supervisory engineer, has
/~
12 your group within ECCS Analysis had any particular t},
13 area of responsibility, and if so, what?
14 A
The major area of responsibility is to perform 15 the analyses for the plant to demonstrate, compliance 16 with the 50.46 and Appendix K requirement.
17 Q
Is it correct to say, to your' knowledge 18 you are the person at Babcock & Wilcox who'has had 19 the greatest continuous responsibility for compliance 20 with 50.467 21 A
Other than Bert Dunn, yes.
22 Q
Since the Three Mile Island accident, 23 what, if any, involvement have you had in the training
{\\
24 of operators?
25 A
I have given lectures on small break LOCA
+
t i l 117
!)
Jones
'(
1 2
behavior.
l 3
Q Anything elso?
4 A
And also I guess it contains some discussion on 5
Operator actions during the various small break 6
scenarios.
7 Q
Do you review with the operators the 8
response of the reactor coolant system to small breaks 9
occurring at various locations?
E 10 A
Yes.
i 11 Q
Is one of the locations which you cover 12 breaks at the top of the pressurizer?
[')
%s 13 A
Yes-14 Q
Have you ever gained any understanding as 15 to what, if any, training B&W was giving to operators 16 prior to the Three Mile Island accident with respect 17 to breaks at the top of the pressurizer?
That.is what he:lcarned.at MR. BENEDICT:
18 any time, what he was-given before the accident?
19 MR. SELTZER:
Exactly.
20 A
N0*
21 Q
sinco the Three Milo Island accident, have 22 you had any opportunity to watch simulated transients 23 on the B&W simulator?
24 i
A-Yes.
2."s i
i r
118 1
Jones 2
Q Have you observed small break loss-of-3 coolant accidents en the B&W simulator?
4 A
Yes.
5 Q
It is a fact, isn't it, that prior to the 6
Three Mile Island accident, the B&W simulator did not 7
have the capability of reproducing breaks at the top 8
of the pressurizer?
9 A
I don't know, t
10 Q
You mean you have never heard from anybody 11 that the B&W simulator needed to be reprogrammed in 12 order to reproduce the principal scenario from the f'}/
l' 13 Davis-Besse transient and the Three Mile Island 14 accident?
15 MR. BENEDICT:
I object to the question.
16 Can I hear it again.
17 (Record road.)
t 18 MR. BENEDICT:
I withdraw my objection.
19 You can answer the question.
20 A
I understand that they had to reprogram it to 21 reproduce the Three Mile Island accident, but I 22 don't know whether that was necessary just because it 23 was a pressurizer break.
O
21 Q
What is your understanding as to why they 1
25 had to reprogram it?
.m-11-
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6 119 1
Jones
. f s, j
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A I don't know.
I don't recall the specifics.
1 3
0 Who told you it had to be reprogrammed?
j i
l 4
A I don't recall.
e Have you ever had any hands-on experience 5
Q 6
at the B&W simulator?
7 A
Yes.
8 Q
Have you ever handled a small break 9
loss-of-coolant accident on the simulator?
t 10 A
I can't recall.
i 11 Q
You spend most of your professional life 1
12 analyzing small break loss-of-coolant accidents,
- ( ')'n.
s_
r 13 don't you?
4 14 A
That is what my job entails, yes.
15 Q
And yet you don't remember whether you
' 16 have ever handled a small break loss-of-coolant i
17 accident on the B&W simulator?
18 A
That's correct.
1 ID Q
From your analyses and studies done before 20 the Three Mile Island accident, you knew that 21 saturation occurs in the reactor coolant system a loss-of-coolant 22 outside the pressurizer during 23 accident; right?
f 24 A
Generally, yes.
symptom of a 2
25 Q-Generally, saturation is a eN r e
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se r
- -t e
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i 120 1
Jones 2
loss-of-coolant accident; right?
s 3
A It is a symptom of one, yes.
4 Q
Did you know that before the Three Mile C,
the B&W control room simulator could 5
Island accident, 6
not model saturation in the reactor coolant system 7
outside the pressurizer?
8 A
Can I hear that back?
9 Q
Did you know before the Three Mile Island 4
10 accident the B&W simulator could not model saturation 4
l 11 occurring in the reactor coolant system outside the
[';
12 pressurizer?
x.)
13.
A I did not know what capabilities the B&W 14 simulator had.
15 Q
About how much time have you spent at the 16 B&W simulator?
t 17 A
Maybe four hours.
18 Q
All of that is since the TMI accidents 19 right?
l t
20 A
That's corroct.
Havo you gained any understanding in.y.our 21 Q
22 profossional work as to what the purpose of the B&W t
t 23 simulator is?
I object to the form of
\\
/
'~'
25 the question.
~,...
121 1
Jones 2
You can answer.
3 A
My understanding is that it is a device to aid 4
the operator in his diagnoctic skills and in handling C
)
5 transients.
l 6
Q How does it aid the operator in his 7.
diagnostic skills?
Y l
8 A
I don't know.
9 MR. BENEDICT:
You have answered the i
i 10 question.
11 A
I. don't know.
12 Q
Are you serious?
13 MR. BENEDICT:
Mr. Jones is under oath.
14 I suspect he is seriouc.
15 MR. SELTZER:
I want to make sure he l
i 16 understands he is under oath.
4 question 17 MR. BENEDICT:
If you have a l
other than "are you serious," please proceed L
18 19 with it.
I object to_that question.
20 Q
When you said that you understood that the 21 simulator had as one of its purposes to aid the 22 operators in their diagnostic skills, what did you l
l 23 mean by the phrace aid them in their diagnostic (T
24 ski 31u"?
25 A
I answered your question to the best of my
-e
.m,+,--.e
~
g-
1 122 1
Jones N
2 understanding as to its purpose.
3 Q
I don't understand the phrase " diagnostic i
i i
4 skills."
5 A
Basically it gives him a chance my 6
understanding is it gives him a chance to see different 7
transients and to figure out what they are.
8 Q
Did you ever make any attempt to speak 9
to any of the Davis-Besse operators after the September
(
10 24, 1977 transient?
11 A
I did not view my responsibilities to include
[
12 talking to the operators at that point in time, so, no.
~j 13 Q
At the time that you were reviewing 14 Bert Dunn's proposed guidelines for handling high 15 pressure injection in a situation like the Davis-Besse 16 September 1977 transient, did it ever occur to you 17 that it might be useful to find out why the Davis-Besse 18 operators responded as they had?
19 MR. BENEDICT:
Can I have that back?
(. Record read.)
20 21 A
My review of the Bert Duan memo was to just --
22 was to oxamine it to assure that the prescriptions that 23 were in there appeared to be adequate for the LOCA s
24 situation.
I did not oven consider it at the time, 25 talking to Davin-Besse operators.
1 Jones 123
(
2 Q
Were you aware that for years, going back 3
at least into 1977, B&W has had procedures for 4
processing of safety concerns?
5 MR. BENEDICT:
Is your question whether 6
he was aware in 1977 they had such things?
7 MR. SELTZER:
No.
Is he aware today that i
8 B&W had such procedures going back into 1977.
9 A
I have known they had procedures, but I am not t
10 sure as to how far back they go.
11 Q
Who at B&W is responsible for the filing I
l 12 of safety concerns,'in other words, the, initiation of i
13 them?
14 MR. BENEDICT:
Pursuant to their procedure?
15 M R..
SELTZER:
Absolutely.
16 MR. BENEDICT:
The PSC.
17 A
Anybody.
18 Q
You mean everybody?
19 A
Anybody who has a safety-concern could file a 20 proceduro.
)
k-21 Q
If an employee of B&W rocognizes that 22 somothing is a nafoty concern within the definitions i
23 -
of tho B&W proceduros, is the filing of a proliminary
[)
t
\\'
24 safoty concern form somothing that in mandatory or i
j 2r, voluntary?
/
y
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7 4
124 l~
Jones A
i k_)
2 A
I would consider it mandatory, but it is 3
obviously up to the individual.
4 Q
When you say you would consider it I
5 mandatory, are you saying that you understood that b
)
6 the B&W policy mado it mandatory?
4 f
7 MR. BENEDICT:
Did you put a time frame-t i
8 on this?
9 MR. SELTZER:
I don't think the procedure 4
h
(
4 10 has changed in this respect.
)
11 Q
If it has, please tell me.
4 12 A
That would be my reading of it, yes.
13 Q
I would like to show you what has been 14 previously marked as GPU Exhibit 94.
It is Revision 15 5 of the B&W procedure for processing of safety concerns.
16 Is GPU Exhibit 94 a copy of a document that 17 you received or saw in 1977 in the courso of your 4
18 employ at B&W7 4
t' 19 A
I can't recall.
20 Q
Havo you soon somo versions of the i
1 21 procedures for processing safety concerns?
t l
22 A
Yes.
23 Q
Havo you road thom?
4
, b V
24 A
Yes.
i' 25 Q
Do you boliovo you undarstood them?
L k-m
125 I
Jones 0
2 A
Yes.
3 Q
You soo the definition on the bottom of 4
page 2 of substantial safety hazard?
r 5
A Yes.
6 Q
Did you understand that B&W had an 7
obligation to notify the NRC if any component delivered 8
by B&W failed to comply with NRC requirements that 9
related to a substantial safety hazard or contained a t
10 defect which could create a substantial safety hazard?
11 MR. BENEDICT:
Again, are you limiting this I
12 in any respect in terms of when he knew this?
V) 13 MR. SELTZER:
No.
I am just asking 14 generally.
15 A
That is my understanding, that the reportability 16 is the purview of the Licensing Department.
17 Q
I show you GPU Exhibit 93, which is another
~
18 vorsion of this processing of safety concerns.
19 Can you. toll from GPU 93 that it is a 20 lator revision of GPU 947 21 A
Yes.
22 Q
Woro the successivo revisions of the 23 procoduro relating to procosning of cafety concerns O
24 gonorally availabic to you?
25 A
As the procoduro was updated, the updatod version MM
126 1
Jones 1
2 would be available to me.
s 3
Q Would you take a look at the second page of i
4 GPU Exhibit 93.
Do you see the description of item f(
i 5
2, substantial safety hazard?
6 A
Yes.
l.
7 Q
Did you understand.from this that if there i
8 was a failure to comply with NRC regulatory requirements 9
on defects in either components or' services provided j
i
(
10 by B&W, that B&W had to report that to the NRC7 a
i 11 MR. BENEDICT:
Did he at the time he 12 received this understand that?
l 13 MR. SELTZER:
No.
Is that the understanding 14 he has from this.
15 MR. BENEDICT:
If you had an understanding.
1 1G If you can recall what your understanding was 4
l 17 at the time you received this, that is fine.
18 You don't have to read'it now and interpret it.
19 MR. SELTZER:
He can read it to rofresh 20 his recollection.
- w 21 Mk. DENEDICT:
Absoluto1y.
I recommend it.
22' A
I am not sure I romombor what I roca11 when I 4
23 road'it.
A
\\,)
21 Q
Do you soo the roferonco to organizations 7
25 that construct, own, oporato, or supply compononts or 4
4
-y w
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127 1
Jones r%g
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i 2
services?
3 A
Yes.
4 Q
Did you understand in 1978 that B&W was an
]
5 organization that constructs and supplies components a
6 and services for nuclear plants?
7.
MR. BENEDICT:
.Did you at that time?
Do 7
8 you recall understanding that?
9 MR. SELTZER:
I am not acking for t
10 understanding.
I am asking:
4 11 Q
Did you know in 1978 that the Babcock &
12 Wilcox company was an organization that constructed
()
4 i
13 or supplied components or services for nuclear 14 facilities?
t 15 A
Yes.
5 16 Q
In fact you know that B&W was an 17 organization that both constructed and supplied both 18 components and services for nuclear facilitics; 10 isn't that-right?
20 MR. BENEDICT:
Did you know that at the 4
l 21 time?
f' 22 A
Yes.
23 Q
You know that training was one of the l
f 24 corvicon that n&W suppliods right?
25 A
No, I do not roca11 whether I know that or not.
re
,'t-128 1
Jones f}
N.)
2 Q
Hold on a minute.
Are you saying that you did n t know in 1978 that there was a Training 3
4 Department at Babcock & Wilcox?
5 A
I cannot recall whether I knew in 1978 that there was a Training Department
.t Babcock & Wilcox.
6 4
7 Q
You didn't know that Norman Elliott 8
was in charge of a group that was called Training Services at B&W in 19787 9
10 A
No, I do not recall whether I kned.in 1978 that Norman Elliott was in chargo of the Training 11 12 Department or such a department existed.
13 Q
Did you know in 1978 that B&W had a control room simulator that was used for training 14
/
}
15' operators of B&W-supplied plants?
A Yes.
16 17 Q
Did.you know in 1978 that B&W supplied 4
18 training services in connection with that simulator?
A I would only -- I could only speculato.
I 4
19 4
a n't recall whether I know that fact or not.
20 Q
Do you soo the definition of substantial I
21 saf ty hazard in both GPU Exhibit 94 and 937 22 A
YO8*
i 23 f
\\'
Q It says:
"A 1 ss f safoty function to 24 tho extent that thoro is.a major reduction in the 25 1
4__
129 I
Jones 2
degree of protection provided to public health and 3
safety for any licensed facility or activity."
~
4 Would a loss of the integrity of the fuel 5
cladding be a loss of safety function, as you 6
understood this?
4 7
MR. BENEDICT:
From any cause?
i 8
MR. SELTZER:
Let's say from a j
9 loss-of-coolant accident.
t 10 MR. LENEDICT:
It is what you remember 11 understanding at the time.
i 12 A
I don't understand what you mean by a loss of 13 cladding integrity.
14 g
That was the phrase you used this morning
~
15 when we were talking about damage to the cladding 16 such that it no longer met the criteria of to CFR 4
4 I
17 50.46.
i 18 MR. BENEDICT:
I object to the 19 characterisation, but if that is what you mean 20 by it, that is fine.
4 21 A
I'am not sure whether I would have considered
.i i
22 that within that definition.
I don't recall.
23 Q
In 1978, did you understand that if the 21 cladding on the fuel rods was no - longer able to contain f
25 the radioactive matorial inuide the fuel rods, that
-, _. ~. _ -,
130 1
Jones
,f-g
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1 2
that was a loss of safety function within the 3
definition in GPU Exhibit 93 or 947 T
4 MR. BENEDICT:
Again limited to your 5
understanding at that time.
Your recollection 6
of what you remomber.
7 A
I cannot recall what I would have considered
.i
},.
8 that to be, whether it fit that definition.
9 Q
Let's be very clear about this.
Do you t
10 mean that a nuclear core could be spewing irradiated 11 fuel into the primary coolant system because of f~h 12 ruptures in the fuel cladding, and you don't know V
13 whetho~r that would be a loss of safoty1 function?
l l
14 MR. BENEDICT:
I think --
s 15 MR. SELTZER:
That is the question, i
16 MR. BENEDICT:
It doesn't matter what 1
17 caused that to happen?
18
!!R. SELTZER:
It doesn't matter what caused i
10 it.
20 A
If there was a small amount of it, no.
i 21 Q
Remember, we also said that it has to be 22 exceeding the criteria of 50.46, so it has to bo l
23 cither the 17 porcont critorion that you listed or the 21 1 porcont critorion.
25 MR. BENnDICT. I object.
You can't.now L
l
^
r 131 1
Jones
,-('
\\
2 limit your question to the issue of a loss of the 3
clad, some oxidation on the clad, when before f
4 you were talking of spewing radioactive fuel 5
into the primary coolant system.
We are not i
6 talking about the same criterion there.
7 MR. SELTZER:
He wanted to know how 8
much, and that is how much.
9 MR. BENEDICT:
You are going back to the dre telling me?
10 50.46 criteria; is that what you i
11 MR. SELTZER:
I am saying that the spewing
[~/)
12 of irradiated fission product into the reactor sm 13 coolant system is a spewing that occurs because 14 of a loss of fuel cladding integrity beyond 15 that which is permitted by 50.46.
16 MR. BENEDICT:
And your-question is?
R 17 Q
Is such a spewing of radioact1ve material 18, into the reactor coolant system something which you
~
I 19 say you have no idea whether that would be a loss of l
20 safety function as you understood that in 19787 l
21 MR. PENEDICT:
That is absolutely not what 22 he said.
Ile said he doesn't recall it.
Do 23 not characterize his testimony.
\\_)
24 Q
You toll me.
j 25 A
If my calculations performed in complianco with
_ = ;-
132 1
Jones
~
%,)
2 Appendix K and 50.46 led to conditions where that would 3
be the predicted outcome, I would have believed that 4
to be a substantial safety hazard.
r 5
Q When Bert Dunn wrote in his February 9,
6
'78 memorandum that "had the Davis-Besse event occurred 7
at a reactor at full power with other than insignificant 8
burnup, it is quite possible, perhaps probable, that 9
core uncovery and possible fuel damage would have i
t 10 resulted," what did you understand the phrase "possible 11 fuel damage" meant?
see the 12 MR. BENEDICT:
Do you want jo
(
13 document, Mr. Jones?
14 MR. SELTZER:
The end of the second 15 paragraph, the last sentence.
16 Q
You see what I just read to you?
17 A
Yes.
I don't remember what I thought when I 18 read that.
My basic review of this memo was really 10 limited to examining the prescription that Bert 20 provided within the memo as to its adequacy from the 21 ECCS standpoint.
I don't remember doing -- having.
22 any thoughts about his writing at the time.
23 Q
You don't recall having any thoughts about O
24 what?
25 A
About what he wroto other than the prescription.
l 133 1
Jones e.O 2
Q Did-you ever consider, based on your 3
conversations with Joe Kelly, with Bert Dunn, or your 4
review of Dunn's memos, that the premature termination r
5 of high pressure injection in a reactor at full power 6
could produce core uncovery and possible fuel damage?
7.
EMR. BENEDICT:
Did he ever consider that?
8 MR. SELTZER:
Yes.
9 MR. BENEDICT:
Even after the. accident?
t 10 MR. SELTZER:
No.
I said as a result of 11 the Kelly conversation, the Dunn conversation, 12 and the review of the Dunn memos.
[~}
%s 13 MR. BENEDICT:
I think -- I.Will have to 14 hear the question again.
1 15 (Record read.)
16 A
Yes.
17 Q
Did that thought occur to you at or about 18 the time that you were having these discussions with 19 Dunn and Kelly and reviewing Dunn's February 1978 20 memoranda?
21 A
YeS*
22 Q
What is the possible-fuel damage that you 23 thought-could occur?
O 24 A
' Rupture of tho' fuel cladding could occur.
25-Q Ruptures in excess of those permitted
134 1
Jones
/~
(}p 2
under the ECCS offective cooling criteria of 10 CFR 3
50.467 4
MR. BENEDICT:
I object to the idea that 5
the statute applies in this condition, but if 6
you are just using it as a notation for those 7
criteria, then he can answee the question.
8 A
There is no specific critelion in 50.46 dealing 3
9 with cladding ruptures.
(
10 Q
would the ruptures which you, anticipated 11 could occur be ruptures that created a substantial 12 safety hazard within the definition of GPU Exhibits
(-}
%/
13 93 and 94?
14 MR. BENEDICT:
Independent of their 15 cause?
Is that what you are asking?
16 MR. SELTZER:
No, due to the cuase 17 described by Kelly and Dunn.
18 MR. BENEDICT:
And your question is whether 19
'he ever thought about that at the time?
20 MR. SELTZER:
No.
Now I am asking whether 21 the fuel rupturing that he did think about would w
22' constituto a substantial safoty hazard as ho i
23 undorstood GPU Exhibits 93 and 94.
O 21 MR. BENEDICT:
I have to object if you 25 are asking him now to sit hora and put together
.b
135 I
Jones
(~N -
4 b,
2 his two recollections and decide.
You are asking 3
him to draw a conclusion now.
You are entitled
~4 to ask him what his recollection is about each 5
of the events, but you can't ask him to draw the a
6 comparison now and try to bring him back to I have to object 7
the years three years ago.
8 to the question.
fuel 9
Q Did you ever consider whether that t
10 rupturing which you did think about constituted 11 a substantial safety hazard?
12 MR. BENEDICT:
Did he ever at any time
()
13 my only problem is the timing of all of this.
4 14 If you mean -- you have asked him what his 15 understanding was of a substantial safety hazard 16 and what he remembers understanding about'this 17 procedure at the time of its release, and you G
18 asked him what he thought about-at the time he 19' had the conversations.
20 MR. SELTZER:
Let me step in and try to 21 allay your concerns.
22 Q
Do you understand that I am talking about 23 the time period in which you and Kolly and Dunn were i
(
termination of high pressure 21 discussing the promature 25-injection that had occurred at Davis-Pesse-and the I-I~,
g j '
r 136 1
Jones 7-)
N_
2 time th at you had the thought that this could produce 3
rupturing of the fuel cladding?
Do you understand that 4
time frame?
(:
5 A
Yes.
6 Q
In that same period of time, did it-ever such an uncovery of the core and 7.
occur to you that 8
rupturing of the fuel rods constituted a substantial
).,
9 safety hazard?
I 10 MR. BENEDICT:
What is your, recollection of 11 that period?
12 A
I did not draw a conclusion that that was a
[~}
s N_e 13 substantial safety hazard.
14 Q
Is there anything that you know about the i
4 15 definition of substantial safety hazard in 1978 which 16 would rule out such a rupturing of the fuel rods from i
J 17 being a substantial safety hazard?
18 A
Rupturing of fuel rods is not in and of itself I
19 a safety hazard.
20 Q
What happens when you have rupturing of-
}
t 21 fuel rods due to uncovery of the core?
i l
22 A
You can have a release of some of the fission I
23 products in the cladding.
O#
24 Q
Into what?
25 A
Into the coolant.
)
~ -
137 1
Jones v
2 Q
Now, you were thinking that this could 4
3 happen in the course of a transient such as the L
4 Davis-Besse accident; right?
5 MR. BENEDICT:
I object to that.
6 Q
Isn't that right?
7 MR. BENEDICT:
Let's hear the question 8
again.
9 (Record read.)
t 10 MR. BENEDICT:
I will continue my objection, 11 but if you understand what he means, go ahead.
[ '/)
12 A
Given the operator throttling the HPI or shutting N_
13 it off, as occurred at Davis-Besse, and doing it fcr 14 a long period of time, it could result in core 15 uncovery and possible fuel' damage, yes.
16 Q
And you knew that at Davis-Besse the 17 operator termination of high pressure injection had 18 occurred while the pilot operated relief valve had 19 failed in an open position; right?
20 A
Yes.
I 21 Q
So there was an eccape of coolant outside i
22 the reactor coolant system; right?
7 23 A
Yes.
I 21 Q
And if there was a rupturing of fuel rods 25 and a release of radioactive fission particles into i
7,
. ~,,..,
y
~ - -..,
138 I
Jones rx
!v) 2 the reactor coolant system, there would also be a 3
release of those radioactive fission products outside i
4 of the reactor coolant system, wouldn't there?
5 MR. BENEDICT:
I object unless you have 4
6 a recollection that you thought those events 7
through as Mr. seltzer sets them forth.
8 A
I can't recall whether I thought that sequence 9
of events through.
t 10 Q
Under the situation that you.have described, 11 there would not be anything to contain those radioactive
/~
12 fission products within the primary c o ol e.n t system if
(_}-
stuck open pilot operated relief valve not 13 there was a 14 blocked by a block valve; isn't that right?
15 MR. BENEDICT: 'You are asking for his s
16 general understanding?
17 MR. SELTZER:
Absolutely.
18 A
That's correct.
19 Q
If there is nothing to prevent the 20 radioactive fission products that have been released 21 into the reactor coolant system from then escaping.
22 into the environment outside the reactor _ coolant systom, 23 are you aware of anything in the B&W processing of f
24 safety concern procedure which would say that a f
25 release of radioactive fission products outside the L
139 1
Jones p
. N-2 reactor coolant system is not a substantial safety 3
hazard?
t 4
MR. BENEDICT:
I object.
Are you asking (o
5 what his understanding of the PSC is today?
6 MR. SELTZER:
No, as he understood it in 4
7-1978.
8 MR. BENEDICT:
You are not going to give him i
I 9
a hypothetical and apply it_to his knowledge i
L 10 then.
11 MR. SELTZER:
I am asking him to apply it w
12 to a state of facts that he knew about.
\\mJ t
l 13 MR. BENEDICT:
He said he can't recall a
14 thinking through the fact that if there is a i
15 fuel failure while there is a leak in the system I
16 that radioactivity may be released into the 17 containment.
If that is the case, he can't have 18 thought through what you are proposing.
i 19 MR. SELTZER:
He just testified under oath 20 that he knew that with'a stuck open pilot 21 operated relief valve, there was nothing that 22 would contain the. radioactive fission product 23 that was in the reactor coolant system.
So that doesn't get to the you can ask him for his recollection.
25 point l
i
'em
140
~
I Jones 2
You can't ask him to go back and reconstruct 3
some event that didn't occur.
4 MR. SELTZER:
I am not asking for any C
4 5
artificial reconstruction.
I am asking him to 6
work with what he recalls from 1978.
Let me 7
ask the question.
He recalls thinking that core 8
uncovery could lead to possible fuel damage.
9 He recalls that the possible fuel damage that 10 he was thinking of was rupturing the fuel rods 11 such that radioactive fission product would be 12 released into the reactor coolant system.
He
- (~'s) s 13 recalls that if there is a stuck open pilot 14 operated relief valve, that there is nothing to 15 contain that radioactive fission product from 16 getting out of the primary coolant system.
17 Now I am asking him
~
18 Q
Do you recall anything that you knew 19 about the preliminary safety concern procedures in 1978 20 that would say that such a scenario as you have just 21 described is not a substantial safety hazard?
22 MR. BENEDICT:
I object.
He does not have 23 to answer that question.
You are not asking
[h I
24 him to recall somethiag that happened.
You
~'
25 are asking him now to take a series of separate
~
141 1
Jenos g-)
x.)
2 incidents, which he testifies he cannot recall, s
3 and assemble them into one, and then asking him 4
for his understanding of a procedure three C.,\\
5 years ago.
That question is just improper.
6 MR. SELTZER:
Since this is one of the top 7
experts at B&W in handling small break analysis 8
and in handling the core cooling criteria of 9
10 CFR 50.46, there is nobody in the company 10 more knowledgeable about respondi$g to this 11 question, and I am only asking for what he knew
/~h 12 in 1978..' If he can't answer it based on what 13 he knew in 1978, he can say so.
14 MR. BENEDICT:
The only question you are 15 entitlad to ask is what he thought at that 16 period.
You may not assemble a series of 17 separate instances in 1978 and ask, based on
~
18 those two things in 1978, what you would have 19 thought in 1978.
That is your question, and I 20 won't let him answer the question.
MR. SELTZER:
I press the question.
21 MR. BENEDICT:
I instruct him not to 22 23 answer.
n
~#
24 Q
Did you ever consider filing a preliminary in connection with.your apprehension 25 safety concern
l 142 I
Jones
.O termination of high pressure injection
~ 2 that prematuro 3
could lead to the type of fuel clad rupturing under 4
the circumstances you just describ.ed?
5 A
No, I did not.
6 (Time noted:
4:50 p.m.)
4 7.
8 Robert C.
Jones, Jr.
9 10 subscribed and sworn to before me.
11 this day of 1981.
O
'2 13 14 15 16~
~
17 18~
19 20 21 22 23
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cggrgygcarg 3
STATE OF NEN YORK
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- ss.:
4 COUNTY OF NEW YORK )
Qt 4
5 JOSEPl! R.
DANYo a
6 7,
N15tary Public within and for the State of New York, j.
7 8
do hereby certify that the foregoing deposition ROBERT C.
JONES, JR.
was taken before 9
of e
10 3""*
30*
1*
i me on 11 That the said witness was duly sworn e
hi8
)-
12 before the cownencement of testimony and 13 that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor i
17 interested directly or indirectly in the-matter in e
)
18 controversy, nor an I in the employ of any of the
,j
~
19 counsel.
j i
20 IN WITNESS WHEREOF, I have hereunto set
[v [y' 198i.
21 my hand this
/ 7 day of
/
22 pD
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[JosephR. Danyo [
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