ML20072H776
| ML20072H776 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/29/1982 |
| From: | Floyd J METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-07, TASK-1, TASK-2, TASK-3, TASK-7, TASK-GB NUDOCS 8306290736 | |
| Download: ML20072H776 (105) | |
Text
hd 433 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
-x GENERAL PUBLIC UTILITIES CORPORATION, t
(~'
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
a Defendants.
- - -x e
Continued deposition of METROPOLITAN EDISON COMPANY by JAMES R.
FLOYD, taken by Defendants pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Thursday, April 29, 1982 at 11:50 o' clock in the forenoon, before Joseph R.
Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
E#
l 8306290736 820429 (DRADOCK 05000289 PDR v
DOYLE REPORTING. INC CERTIFIED STENOTYPE REPORTER 369 LEXINGTON AVENUE WALTER SHAPIRO. C.S.R.
NEw Yostsc. N.Y.
10o17 CHARLES SHAPIRO. C.S.R.
TELspHo NE 212 - 867-8220
l 434 2
Appe arances:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York i
By:
RICHARD C.
SELTZER, ESQ.
6
-and-MYRON KIRSCHBAUM, ESQ.,
i 7
of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants One Chase Manhattan Plaza 11 New York, New York 12 By:
KAREN E.
WAGNER, ESQ.
O-
-and-t 13 K.
ANN MCDONALD, ESQ.,
14 of Counsel 15 16 LeBOEUF, LAMB, LEIBY & MacRAE, ESQS.
Attorneys for Witness l
17 1333 New Hampshire Avenue, N.W.
I Washington, D.C.
20036 18 By:
MICHAEL F.
McBRIDE, ESQ.,
a 19 1
of Counsel 20 4
' 21 Also Presents 22 DEBORAH JACOBS 23 i
24
?
- il
1 1
435 f')\\
\\m 2
JAME S R.
- FL0YD, resumed, 3
having been previously sworn by a Notary Public, 4
and testified further as follows:
ll 5
MR. SELTZER:
You know that your testimony 6
today continues to be under oath?
7 THE WITNESS:
Yes.
8 EXAMINATION (CONTINUED) 9 BY MS. WAGNER:
10 Q
I just have a few more questions, and 11 then I will turn you over to Mr. Seltzer.
12 Were you familiar during the time when O)
(_
13' you were supervisor of operations of TMI-1 with position 14 indication in the TMI-1 control room for the PORV 15 position?
16 A
I believe I was.
17 Q
Could you describe for me what indication 18 was available in the TMI-1 control room for the 19 position of the PORV7 20 A
I don't recall what that position 21 indication was.
22 Q
Do you recall that there was position 23 indication?
rm
(
)
24 A
I don't recall if it"was position 25 indication or command signal indication.
1 Floyd 436 1
1
()
2 Q
Do you recall whether it was the same i
1 3
indication as was available after March 29, 1978 in 1
4 TMI-27 jll 5
A No, I do not recall.
6 Q
Do you recall whether it is different?
i 7
A No.
l 8
Q Do you recall whether when you and others i
9 were trying to decide what type of position indication
!=
f 10 to install in TMI-2 whether you ever studied the i
l 11 position indication in TMI-17 12 A
I don't recall.
()
13 Q
You don't recall making any evaluation as t
l 14 to whether the indication available in TMI-1 was i
l 15 adequate?
3 1
i 16 A
No, I do not recall.
l 17 Q
I would like to show you three documents,
}
,i 18 all of which have been marked as part of a larger 19 exhibit, B&W 208.
These documents are periodicals, 20 each of which describes an event at Davis-Besse in 21 1977.
22 First lot me ask you if you are aware 23 independently of the documents of an event which a
24 occurred in September 1977 at Davis-Besse in which, 25 among other things, the PORV stuck open?
1 Floyd 437 2
MR. SELTZER:
Are you asking was he aware 3
of it before the Three Mile Island accident?
4 MS. WAGNER:
That would be my next h
5 question.
6 A
I was not aware of it before the Three 7
Mile Island accident.
8 Q
Are you aware of it now?
9 A
Yes.
10 Q
You testified previously that you were 11 familiar with a periodical called Nuclear Power 12 Experience.
The first document I would like you to 13 look at, which is the top one, is an issue of Nuclear 14 Power Experience for July 1978, and I would like to 15 refer you to the paragraph under the section entitled 16 "SFRCS Pressurizer Relief Valve and FW Pump Conprol 17 System Failures."
18 Do you see that section?
19 A
Yes.
20 Q
Do you recall ever having seen that 21 before?
22 A
wo.
23 Q
I refer you to the next page of that 24 exhibit, the first full paragraph, and a sentence in 25 that paragraph which says, "RCS pressure continued to
1 Floyd 438
()
2 decrease until zaturation pressure was reached and 3
ateam began to form in the RCS (approximate T = 8 min).
4 This caused an insurge of water into the pressurizer
{lg 5
and the pressurizer level went off scale at 320 inches."
6 Do you recall ever readin that before?
7 A
No.
l 8
Q Do you recall anybody ever telling you in 9
words or substance something to that effect about the 10 Davis-Besse event before the accident at TMI?
11 A
No.
12 Q
Do you recall Gary Miller ever telling
()
13 you~in words or substance something to that effect I
14 that he had been told at a User's Group meeting?
15 A
No, I do not recall.
16 Q
I would like to refer you now to the 17 document entitled " Current Events Power Reactors,"
18 which you have also testified was a periodical which 19 you saw periodically, and I would like to ask you if 20 you recall having seen this issue.
21 A
No, I don't recall seeing this issue.
9 N-l 22 Q
Page 3 of that document indicates 23 essentially the same ideas I read to you from the last 24 document, in the third paragraph on page 3.
25 I take it you do not recall having seen
1 Floyd 439 (O
_)
- 2 that before either?
3 A
No, I lo not.
4 Q
Finally, I would like to refer you to the ll 5
last document, which is called the " Atomic Energy 6
Clearinghouse," which is, again, a document you have 7
testified you recalled seeing periodically.
8 I would like to ask you if you recall 9
having seen this issue before.
10 A
No, I do not recall seeing this issue 11 before.
12 Q
If you would turn to the third page of 13 the document, again the third paragraph, which is not 14 terribly legible, actually the fourth paragraph, which 15 says in words or substance the same notion that I read 16 to you previously.
17 I take it you do not recall having seen 18 that before?
l 19 MR. SELTZER:
It is very difficult to 20 read what it says there.
I doubt if anybody 21 can remember reading that.
22 MS. WAGNER:
I can read it to the witness 23 if he would like me to.
l ()
24 A
It gives a different pressurizer level l
l 25 than the other douements, but I don't recall seeing it l
l t
~
l 1
Floyd 440 i
()
2 before.
3 Q
Again, I take it you don't recall hearing 4
from anybody else what was in this issue?
g 5
A No.
6 MS. WAGNER:
Your witness.
7 EXAMINATION BY MR. KIRSCHBAUM:
4 8
Q Did you join the Navy as an enlisted man 9
or as a commissioned officer?
10 A
As an enlisted man.
11 Q
While you were in the Navy, did you ever 12 become a commissioned officer?
13 A
No.
14 Q
You testified at page 6 of your direct j
15 examination that you attended the Navy Advanced Nuclear 16 Powr School in Vallejo, California, and that you took 17 courses there in mathematics, physics, nuclear physics, 18 and electrical engineering, among others.
19 was that school open to enlisted men or 20 just to commissioned officers?
21 MS. WAGNER:
I object to the question as 22 leading.
23 MR. SELTZER:
Overruled.
24 A
The school was designed for officers' 25 training, and I think I am the only enlisted man who
i 1
Floyd 441
(
2 over succesfully completed the school.
3 Q
As an enlisted man, how did you come to 4
attend this school?
llg 5
A I had a recommendation from a previous 6
commanding officer, Captain Wilkinson.
Since the 7
commanding officer of the school was a commander, he 8
agreed with the captain's recommendation to allow me 9
to enroll in the advanced course.
10 Q
What was that recommendation based upon?
11 A
My performance in my previous six months 12 where I was teaching mathematics review to people who
()
13 were scheduled to go to Nuclear Power School.
14 Q
Can you tell me how you got to be an 15 instructor in that mathematics course?
16 A
Our division officer recognized the 17 availability of our time and wished to utilize it in 18 a mathematics review, so he drew up a rather broad-based 19 math exam based on high school mathematics to see 20 where this class of 20 people should be taught.
21 My performance on that exam was 104 points 22 out of a possible 105, and the next highest mark in 23 the class was about a 65.
He decided I was qualified 24 to teach the course.
O 25 Q
Do you know of any other onlisted men who
1 Floyd 442
()
2 ever attended the Advanced Nuclear Power School?
3 A
Several enrolled in the class immediately 4
behind me, but to the best of my knowledge none of them ll) 5 completed.
6 Q
while you were supervisor of operations 7
at TMI Units 1 and 2, were you generally familiar with 8
the service and academic bacgrounds of the reactor 9
operators who worked under you?
10 A
Yes.
11 Q
To the best of your knowledge, were any 12 of the reactor operators who worked under you at TMI
()
13 Navy veterans?
14 A
Yes.
15 Q
Did any of them attend the Navy Advanced 16 Nuclear Power School?
17 A
No.
18 Q
You testified at page 18 of your direct 19 examination that you received a Bachelor of Science 20 degree from Columbia University in 1965 in chemical l
21 engineering.
L 22 Did any of the reactor operators who 23 worked under you at TMI have engineering degrees?
24 A
No.
25 Q
Did any of the operators under you have
i 1
Floyd 443
( ),,
(~
\\
2 college degrees of any kind?
3 MS. WAGNER:
Objection to the form.
4 A
Yes.
(l) 5 Q
How many?
6 A
One had a Bachelor of Science, I believe, 7
in chemistry.
8 Q
Based on your experience in the commercial 9
nuclear power industry, was it normal in the industry 10 to staff nuclear power plant control rooms with 11 control room operators who were not college graduates?
12 MS. WAGNER:
Objection to the form.
()
13 There has been no testimony that this 14 witness is familiar with the staffing of nuclear 15 power plants.
16 Q
Let me ask you how longwere you supervisor 17 of operations at TMI Units 1 and 27 l
18 MS. WAGNER:
Objection.
Asked and answered 19 A
Since 1971, I guess.
20 Q
Prior to that, were you involved in 21 nuclear power plant operations?
l 22 A
Yes, commercial business from '65 until 23 the present.
(}
24 Q
During that time, did you have contacts 25 with management of other nuclear power plants other
1 Floyd 444 i
2 than the ones that you were employed at?
3 A
some, yes.
4 Q
Based on those contacts and based on 1
N 5
your own employ' ment in the nuclear power plant
- 4 6
industry, did you have any understanding as to the 7
general requirements for nuclear power plant control 8
room operators?
9 MS. WAGNER:
Objection to the form.
10 A
Yes.
11 Q
Based on that understanding, was it 12 normal in the industry for control room operators to 13 have college degrees or not to have college degrees?
14 MS. WAGNER:
Objection; still no 15 foundation for the witness to give this 10 testimony.
17 A
Noncollege-degree personnel were normally 18 filling that role.
19 Q
You testified at page 18 of.your direct 20 examination that you worked as an assistant in 21 columbia's Nuclear Physics Department on a research 22 project considering the nuclear fission process, 23 headed by Dr. Malconian.
24 Did any of the reactor operators who 25 served under you at TMI ever participate in the time
1 Floyd 445 2
of academic research in nuclear physics that you 3
worked on under Dr. Malconian at Columbia?
4 MS. WAGNER:
Objection to the form.
5 A
Not to my knowledge.
6 Q
can you compare your academic background 7
in the sciences, engineering, and nuclear power theory 8
with the general academic background of the reactor 9
operators who worked under you at TMI-1 and 27 10 MS. WAGNER:
I object to the question 11 because I believe the witness was unable to 12 describe those backgrounds when I was asking 13 him about them.
14 MR. KIRSCHBAUM:
Your question was, as I 15 recall, "Do you know where.they came from?"
I 16 already asked the witness fi he was familiar 17 generally with the academic and service 18 backgrounds of the operators, and his answer 19 was "Yes."
20 MS. WAGNER:
I object to the form.
21 A
I don't believe there is any comparison 22 really between my background and the average operator, 23 if there is such a person.
24 I would say, I probably had at least an 25 order of magnitude of more training than the average h 6 69 ey
--<:e e
D@
l l
1 Floyd 446 l
^
2 reactor operator would have had.
3 Q
Did that difference in academic background 4
between you and your operators, would that also hold l
5 true if you were to compare your background with that 6
of the average reactor operator in the industry 7
generally?
8 MS. WAGNER:
I object to the form.
9 The witness doesn't know if there is an 10 average reactor operator.
11 MR. KIRSCHBAUM:
I will take out the word 12
" average."
~
(~T 13 Q
I am asking you whether your answer would V
14 hold true for reactor operators in the field generally.
15 MS. WAGNER:
There is no testimony that 16 he knows of the reactor operators' experience 17 generally.
18 MR. KIRSCHBAUM:
I believe the witness 19 already testified to his knowledge of the 20 industry generally and reactor operators in the 21 industry, and based on that knowledge he can 22 answer.'
23 MS. WAGNER:
I object.
24 A
Yes.
g3
\\j 25 Q
Yes, what?
1 Flcyd 447 2
MS. WAGNER:
I object to the question.
\\
3 MR. KIRSCHBAUM:
Unfortunately, the 4
question has been interrupted so many times from 5
your objections, I am afraid the record will 6
appear disjointed unless I tie it back.
We can 7
have it read back.
8 MS. WAGNER:
I would like it read back.
9 (Record read) 10 BY MR. KIRSCHBAUM:
11 Q
Your answer is?
12 A
Yes.
'13 (continued on next page) 14 l
l 15 l
16 17 18 19 20 21 22 23 24 b)
\\_/
25
1 1
Floyd 448 2
g I refer you to your deposition testimony 3
before the President's Commission given on August 1,
4 1979, and specifically to the testimony at page 98, 5
beginning on line 12, and continuing on page 99 through 6
line 8, which reads as follows:
7
" Question:
Do you remember any of the 8
specific complaints with respect to substantive areas?"
9 The question was referring to training.
10
" Answer:
No.
The training department 11 liked to teach us some transient analysis, and the 12 control room operators are normally reticent to learn
'13 transient ana~1ysis.
14
" Question:
Why is that?
15
" Answer:
They are rather a deep and 16 complicated subject.
The engineers love it and the 17 people that write the programs and run computers like 18 to tell you what hot spots in the core is and make a 19 livelihood and manage every year to dress it up enough 20 to keep the engineers interested in what they are 21 doing.
We have not yet progressed to the point where t
22 we can bring it down to the operators' level and get 23 them very excited about it.
It tends to come out
- 24 in the early morning very rapidly when you bring up 25 such a subject as that.
There are traditional areas
i 1
Floyd 449 2
where operators are not interested.
There are others l
J where they are very interested such as the nuts and 3
'4 bolts of the systems and the components, such
^ ;
5 lectures."
4 6
were you asked those questions and did you 7
give those answers?
8 MS. WAGNER:
I object.
It has been asked 9
and answered.
10 MR. SELTZER:
Off the record.
11 (Di'scussion off the record.)
12 A
I believe that to be true.
13 Q
Is that testimony correct, to the best 14 of your knowledge?
15 A
It was correct then and it is correct 16 now.
However, hearing it read back, it could 17 Probably be clarified..
18 Q
Could you do that, please?
19 A
The subject that I was addressing in here 20 was transient analyses which is a rather deep and 21 complicated subject and requires several highly 22 educated engineers with further specializations to 23 conduct.
The operators are very interested in the 24 output of that analysis.
In the course of the O
25 transient itself they are vitally interested, as they
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1 Floyd 450 r~
2 are in the emergency procedure which comes out of N_TA 3
that analysis, so I didn't mean to imply by omission 4
that the operators weren't interested in either the 5
transient or the procedure which comes from it but 6
rather they did not have the technical background 7
to understand.the analyses that went into usually the 8
computer program that is called the transient 9
analysis.
10 Q
Shouldn't the control room operators be 11 able to understand transient analysis?
12 A
No, I think it is too complicated and as 13 an engineer, a degreed engineer, I am not sure I 14 understand all of the transient analysis.
It is a 15 speciality unique to the nuclear industry, and we 16 rely heavily on the vendor to supply us that expertise.
17 Q
Who is the vendor in this case that you 18 are talking about?
i 19 A
Babcock & Wilcox.
20 Q
While you were supervisor of operations 21 at Unit 2, were the reactor operators and supervisors 22 who worked under you divided into crews?
23 MS. WAGNER:
Objection.
24 A
Yes.
25 Q
Did the members of those crews generally
1 Floyd 451 gS 2
work together on a particular shift or were they V
3 changed from day to day?
4 MS. WAGNER:
Objection to the form.
.r
5 A
They generally stayed together as a crew.
h 6
Q who were the reactor operators and
{
i 7
supervisors on duty at Unit 2 at 4:00 a.m. on 8
March 28, 19797 9
A The shift supervisor was Bill Zewe.
10 Shift foreman was Fred Scheimann.
The control room 11 operators were Craig Faust and Ed Frederick.
12 Q
Have these men worked together before as 13 a crew on Unit 27 14 A
Yes.
15 Q
One time or many times?
16 A
I think for at least six months.
17 MS. WAGNER:
Objection.
18 Q
For at least six months on a continuous 19 basis?
20 A
Yes.
21 Q
Prior to the accident at TMI-2, had you l
I 22 made any evaluation in your own mind as to how well I
23 the various crews working under your supervision were 24 functioning?
p 25 A
Yes.
e ae..==--
+eeewee-
1 Floyd 452
/~'s 2
MS. WAGNER:
I object to the form as (b.
3 leading and it is not within the scope of 4
cross-examination.
[9 5
Q What factors did you take into account 6
in arriving at these evaluations?
7 A
Primarily their job performance although 8
some areas such as their expected response to emergency 9
procedures was extrapolated from my understanding of 10 their base of knowledge and as such, it wasn't based 11 solely on performance.
12 Q
Did your evaluations take into account (d
3 13 the ability of the members of the crew to work 14 together?
15 A
Yes.
16 MS. WAGNER:
Objection.
17 Q
Prior to the accident, had you made 18 comparisons in your own mind between the performance 19 of the various crews under your supervision based on 20 these factors?
21 MS. WAGNER:
Objection.
O 22 A
Yes.
l 23 Q
Prior to the accident, what was your 24 evaluation of the Zewe crew's performance, and I am f3 l
25 referring to the crew for which Bill Zewe was the
1 Floyd 1453
(~'
2 shift supervisor?
3 MS. WAGNER:
I want to have a continuing 4
objection to this entire line of questioning.
5 MR. KIRSCHBAUM:
On the grounds that it 6
is outside the scope of direct?
7 MS. WAGNER:
Yes, and leading.
8 MR. KIRSCHBAUM:
I don't think I can agree 9
to an outstanding objection that it is leading.
10 MS. WAGNER:
I will have a continuing 11 objection that this whole line of questioning 12 is outside the scope.
13 MR. KIRSCHBAUM:
If you have determined 14 in your mind that you are going to object to 15 every question because you are convinced that 16 every question is leading, I will not agree to 17 that.
18 MS. WAGNER:
I am asking for a continuing 19 objection on the grounds that it is outside the 20 scope, and I will interject another objection 21 if I believe it is leading.
^9 22 MR. KIRSCHBAUM:
I don't believe I have l
23 asked a single leading question today, but be 24 that as it may.
3 25 (Record was read back.)
1
1 Floyd 454 2
Q The crew at Unit 2 for which Bill Zewe 3
was the shift supervisor.
4 A
I ranked Bill's crew among the better 5
crews.
Certainly above average.
9 6
Q You testified at page 28 of your direct 7
examination that you attended the B&W technology 8
course in 1969.
Can you describe the content and 9
format of that course?
10 A
The content of the course was everything l
11 in the B&W scope of supply and the format was 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> l
l 12 a week for nine weeks.
13 Q
Can you just describe briefly what you 14 understood at that time to be within the B&W scope of l
15 supply?
16 A
Basically the nuclear steam supply system 17 and supporting. auxiliaries and fuel-handling equipment.
18 Q
You testified at page 30 of your direct 19 examination that the training provided by Met Ed on 20 the first group of TMI operators was tailored primarily 21 on what had been taught in the B&W technology course.
22 could you explain what you meant by that?
d 23 MS. WAGNER:
Are you referring to the 24 first group at TMI or the first group of TMI-2 0
25 operators?
1 Floyd 455 2
MR. KIRSCHBAUM:
I am referring to the 3
testimony at page 30 which I believe was the 4
first group of TMI operators.
5 A
What I meant by that was that we used B&W 6
terminology, B&W ideas and concepts and theory that 7
was taught to us and just transmitted it on to the 8
next group that needed to be trained, and in fact the 9
handout materials may have been identical.
10 Q
Where did the first instructors, where 11 did Met Ed's first training instructors receive 12 their training?
13 MS. WAGNER:
Objection.
14 A
With us the first time the technology 15 course was taught and that was January and February 16 1969.
17 Q
You testified a number of times during 18 your direct examination about the B&W simulator 19 training which you and the Met Ed operators received 20 in Lynchburg.
21 What, in your view, are the relative 22 advantages and disadvantages, if any, of simulated 23 training as compared to the type of training which 24 Met Ed provided to its operators at Three Mile Island?
25 MS. WAGNER:
Objection to the form.
It is i
1 1
Floyd 456 l
2 leading.
3 A
While at Metropolitan Edison at Three Mile 4
Island we were able to sit the people down in a
^
5 classroom and go over the words on a piece of paper 6
or even take them to a console and say this meter 7
will move up scale this far or down scale this far, 8
it does not lead to the imprinting or patterning 9
which you can gain at the simulator, by talking about 10 the procedure in the classroom, telling the man this l
11 is what you are going to see, and then immediately l
l 12 taking him to the machine, showing it to him, 1
13 letting his eyes see what is going on and his hands 14 carrying out the procedure by finding the right 15 switches and turning them at the proper time.
16 In addition, if he turns the wrong switch, 17 he will see that is unexpected, and then in the 18 critique, you can point out his error and point out 19 what happened as a result of his error, so it is a 20 auch mora positive learning experience to do it in 21 conjunction with the similator.
22 Q
Are there aspects of operating a nuclear vL,Ch 23 power plant as to LAs simulator training that-is 24 more useful than the type of training provided by 25 Met Ed at Three Mile Island and vice versa?
l
1 Floyd 457 2
MS. WAGNER:
Objection.
3 A
There are aspects that I just mentioned 4
possibly that can't be taught without a simulator.
5 Emergency procedures is one who,le large area.
6 Transients in general, whether they are covered 7
by emergency procedures, but even such things as 8
repeated startups would be very time consuming on the 9
plant itself where it can be done on the simulator 10 at much less cost.
11 Q
Where did the most important traning 12 for Met Ed operators on transients take place?
13 MS. WAGNER:
Objection.
14 A
At the simulator.
15 g
To what degree, if any, was it important 16 to Met Ed that the simulator accurately portray the 17 conditions which the operators would encounter at 18 TMI-27 19 A
It was vitally important in that if they 20 were imprinted with false information, it would be 21 to their detriment when they actually saw the plant 22 respond.
23 Q
What was your understanding of the effect 24 if they were given correct information?
O 25 MS. WAGNER:
Objection.
em
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Floyd 2458 n
2 A
Thst is probably why I used the word -
3
" imprinting" or " patterning."
It is a conditioned 4
response that when you see these meters doing these 5
things, your hande automatically do that.
It is like
^
6 practicing a piano piece before going to a recital.
7 Q
Prior to the accident, did Met Ed operators 8
receive traning at the simulator on loss of coolant 9
accidents or incidents?
10 A
Yes.
11 Q
When TMI-2 operators were trained at the N
12 simulator on loss of coolant accidents, what
,s i
13 procedures, if any, did they use?
l
~
V 1
14 A
We used our own procedurds.
15 Q
Did the B&W simulator training...on loss k
16 of coolant accidents cover different break dize~s and-17 locations?
\\
i 18 A
Yes.
s 19 (Continued on the following page.)
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Floyd 2
Q Did any training which you received at 3
B&W prepare you for a loss of coolant accident in
,s :. ch 4
response to 4dunt pressurizer level rose and system 5
pressure dropped?
6 MS. WAGNER:
Objection.
7 A
No, neither the classroom training nor the 8
simulator training.
9 Q
To what extent, if any, did the training 10 which you received from B&W lead you to expect that 11 pressure and pressurizer level would trend in the same 12 direction in response to a loss of coolant accident?
13 MS. WAGNER:
Objection.
14 A
Every loss of coolant accident which we 15 were instructed on or which we saw on the simulator had 16 them both tracking down together.
17 Q
what do you mean by tracking?
18 A
Running in a parallel path on the face of 19 the meter.
20 Q
In your previous answer, ware you referring l
21 to simulator training and classroom training?
4 22 A
Yes.
23 Q
Based on the training which you received 24 fr m B&W prior to the accident what, if anything, did i
25 you expect would be the response of pressurizer level 1
1
Floyd 460 1
to a loss of coolant accident at TMI-1 or TMI-27 2
' O MS. WAGNER: Objection.
3
)
)
1 A
I would have expected pressurizer level to 4
decrease.
5 lh Q
where were you on the morning of March 28, 6
1979 from 7:30 a.m.
on?
7 A
Bsw offices in Lynchburg, Virginia.
Q What were you doing at B&W on that morning?
9 A
I was there for annual simulator 10 4
requalification.
Q Did you receive any information from the TMI-2 control room that morning concerning the events 13 O
I which were taking place there?
14 A
Yes.
I made two telephone calls.
Q What information did you receive in those calls?
17 MS. WAGNER:
Could we have a time, perhaps, for these calls?
19 Q
You referred to phone calls, is that correct?
l 21 4
A Yes.
22 Q
When did those phone calls take place, approximately?
24
()
A one about 7:30 and one approximately 9:30.
25 i
-._-,--,,,,..w_
__..-,_w.
1 Ficyd 461 2
The 7:30 phone call I learned that the reactor had 3
tripped about 4 in the earning due to a loss of 4
feedwater, total loss of feedwater, both feed pumps 5
had tripped, and that emergency feedwater was delayed l
6 about ten minutes before it was initiated, that the plant 7
pressure was between 1000 and 1200 pounds per square 8
!".ch, that the radiation monitoring panel was lit up like g
a Christmas tree, and I inquired about two particular 10 radiation monitors and received numbers on those.
11 That was HPR 214 and HPR 227.
12 In the 9:30 phone call, I also learned that 13 the PORV had been stuck open.
14 Q
Using the information which you received 15 from the control room that morning, did you attempt to 16 simulate the accident on the Bsw simulator?
17 A
Yes.
18 Q
Were you able to simulate the accident 19 that morning on the B&W simulator?
20 A
8 21 Q
Why not?
9 22 A
I could never get pressurizer level to l
23 rise as it did at the Island.
24 Q
When you say pressurizer level to rise as O
25 it did at the Island, what do you mean by that?
462 g
Floyd
("T 2
A fter I had time to study the transient in O
detail, I became aware that pressurizer level rose 3
4 rather rapidly just a few minutes into the transient, 5
and I never saw that behavior that morning on the 6
simulator.
7 Q
ere you unable to simulate the rise in 8
Pressurizer level which you just described as having 9
taken place at the plant because you failed to let any 10 of your simulations run fro sufficient time before 11 terminating them?
12 MS. WAGNER:
I object to the form.
('N 13 Leading.
d 34 A
May I hear the question?
15 (Record read.)
16 A
I ran simulations long enough in time that 17 that should have manifested itself.
18 Q
What is it that you are testifying should 19 have manifested itself?
20 A
The rise in pressurizer level.
21 Q
That should have manifested itself within 22 the time that you performed the simulation?
23 A
- Yes, 24 Q
Ket ne refer tiy ti your interview with s
\\
25 the United States Senate subcommittee staff which took i
1 Ficyd 463 1
l 2
place on August 23, 1979, and particularly to the J
testimony which appears beginning on page 5, line 16 and 3
4 continues on to page 6,
line 10.
The last part of that testimony on page 6, 5
6 starting with line 5, reads as follows:
7 "Again I did not let it run out to the 20, g
25, 30 minutes that would have been required to see the 9
drop in pressure down to 1000 or 1200 pounds so I was 10 still all afternoon unsuccessful in simulating what had 11 happened to this plant primarily because I didn't let 12 the thing run far enough in real time."
' 13 Do you recall being asked those questions 14 and giving that testimony or giving those answers?
15 MS. WAGNER:
I object.
16 A
I do not have a specific recollection of this 17 question or this answer, but since it is here in front 18 of me, I suspect it was so given.
19 Q
Is it correct that you were unsuccessful 20 in simulating what occurred at TMI-2 on March 28, 1979, 21 primarily because you didn't let the simulation run 22 far enough in real time.
23 MS. WAGNER:
Objection;1eading.
It has 24 been asked and answered.
O 25 A
I think this testimony was true, to my l
464 I
Floyd 4
2 knowledge, at the time I gave it.
There is knowledge that I gained since then that tells me I was watching 3
l 4
the wrong parameter to determine success or non-success i
4 r~1 of simulation.
5 l
6 Q
What knowledge is that that you are referring l
j 7
to?
I j
8 A
The rise in pressurizer level.
I l
9 Q
on the date of the accident, did you know I'
10 how long it had taken for the plant pressure to drop to I
l 11 1000 to 1200 pounds?
l l
12 A
No.
(}
13 Q
Based on what you now know concerning the i
14 behavior of system pressure on the date of the 15 accident, do you believe that the simulator accurately i
16 portrayed the behavior of system pressure which took i
j 17 place at the plant that day?
l l
18 MS. WAGNER:
Objection to the question.
i i
19 No foundation and leading.
i 20 A
No.
I 21 Q
Why not?
i 22 MS. WAGNER:
I have a continuing objection 1
j 23 to this line.
24 A
The actual pressure in the plant dropped
! ()
l 25 much more rapidly than it dropped in the simulator.
J I
i
Floyd 465 1
O 2
Q On what are you basing your testimony as to (G
h w rapidly pressure dropped on the day of the 3
accident at the plant?
4 A
vari us plant parameters have been plotted 5
O 6
up n various time scales but basically out to 8 o' clock in the evening of the 20th, and by comparing those actual 7
8 plant performance parameters with what I saw on the simulator, it was difficult to get the simulator to come 9
gg down to the HPI set point even, let alone to.a thousand or 1200.
11 12 Q
Prior to the accident at TMI-2, did you ever see the pressurizer go solid in response to a
- 13 V
simulated loss of coolant accident on the B&W 14 simulator?
15 16 A
No.
17 MS. WAGNER:
Objection.
18 Q
What training, if any, did B&W give Met 19 Ed operators regarding whether it was ever permissible to let the pressurizer go solid?
20 MS. WAGNER:
Objection.
21 A
Id n t know of any training from B&W 22 23 which said it was permissible to go solid in the 24 pressurizer.
25 Q
Was there a B&W limit and precaution in
466 1
Floyd g-2 effect at TMI-2 at the time of the accident which dealt
\\v with the question of operation in a solid mode in the 3
A res.
3 6
Q What did that limit and precaution provide?
7 A
That pressurizer level should never go above 8
400 inches indicated.
g Q
Prior to the accident, did you understand
~
10 that limit and precaution to apply whether or not the 11 I reactor was critical at the time?
12 MS. WAGNER:
Objection.
13 A
Yes.
14 Q
Prior to the accident at TMI-2, was there a 15 tech spec in force relating to TMI-2 which dealt with 16 the issue of whether or not it was permissible to operate 17 the reactor coolant system in a solid mode?
l 18 MS. WAGNER:
Objection.
19 A
Yes.
20 Q
What did that tech spec provide on the 21 subject?
22 A
In modes 1,
2 and 3, pressurizer level was 23 not to exceed 385 inches.
24 Q
You testified at page 288 of your direct bo 25 examination concerning the operation of Navy reactors
1 Floyd 467 2
in what you called the semi-solid state.
Was any distinction drawn in either the B&W limits and 3
4 precautions or in the tech specs or in the plant
~
5 Procedures for TMI-2 which distinguished in any way 6
Operation in a solid state and operation in what you 7
referred to as a semi-solid state?
g MS. WAGNER:
Objection.
9 A
No.
10 Q
To your knowledge, did anyone from B&W 11 ever criticiae operators for permitting the pressurizer 12 to go solid?
~ 13 MS. WAGNER:
Objection.
14 A
In performance at the simulator, it 15 would be expected that they would have.
16 Q
Did they?
17 A
I know of one instance where I was told by 18 a B&W instructor that the people from Oconee who had 19 let the plant go solid were severely criticized for 20 that action.
21 Q
What, if anything, were you taught by W
22 B&W to use as an indicator of a reactor coolant system 23 inventor?
24 A
Pressurizer level.
O 25 MS. WAGNER:
Objection.
. ~....
10 1
Floyd 468 l
2 Q
Where did B&W teach you that?
3 A
In a classroom and on the simulator.
4 Q
Did anyone from B&W ever indicate to you 5
in any way that pressurizer level could be a misleading 6
indicator of reactor coolant system inventory?
7 MS. WAGNER:
Objection.
O A
No.
9 Q
You were given certain documents a few 10 minutes ago by Ms. Wagner concerning an event at 11 Davis-Besse which took place on September 24, 1977.
12 After the date of that incident, did anyone from B&W ever 13
()
tell you or indicate to you in any way that pressurizer 14 level could be a misleading indicator of reactor coolant 15 system inventory?
IO MS. WAGNER: Objection to the form.
17 A
No.
18 (Luncheon recess:
12:50 p.m.)
IO oOo 20 21 22 23 24
,O) 25
s/1 1
469 e
2 (AFTERNOON SESSION) 3 (Date :
April 29, 1982) 4 (Time noted:
2:30 p.m.)
5 JAMES R.
F L0YD, resumed, having been 6
previously duly sworn, was examined and testified
~
7 further as follows:
8 EXAMINATION (Cont'd.)
9 BY MR. KIRSCHBAUM:
10 Q
While you were supervisor of operations 11 at Unite 2,
what was the nature of the relationshio 12 between the operations department which you headed and 13 the' training department?
14 MS. WAGNER:
Objection.
15 A
The training department was responsible 16 for providing training to the people that worked with 17 me, and in that sense, we had a fairly close working 18 relationship.
19 Q
While you were supervisor of operations 20 for Unit 2, did you or members of your department ever 21 make suggestions to the training department as to 22 the content or format of the training which it was 23 providing?
24 A
Yes.
n
'~'
25 Q
What was your reason for making these
1 Floyd 470 2
suggestions?
E A
To produce better operators.
3 4
Q Generally speaking, was the training 5
department responsive or unresponsive to your 6
suggestions?
7 A
They were responsive to my suggestions.
g Q
Do you know of any instance in which the 9
training department refused a request by you to provide 10 training as to any particular aspect of the operation 11 of TMI-27 12 MS. WAGNER:
Objection.
13 A
No.
O 14 Q
As supervisor of operations, were you 15 satisfied or dissatisfied with the training being 16 Provided to your operators by Met Ed's training 17 department prior to March 28, 19797 18 A
Satisfied.
19 Q
Let me refer you to the testimony which 20 you gave at your Kemeny Commission deposition on 21 August 1,
1979.
The testimony begins on page 96,
(&
'T 22 line 6, and continues through page 98, line 11 on the 23 subject of training.
24 Could you take a look at that testimony, O'~
25 Please.
1 Flcyd 471 I
2 O
Have you finished looking at that LJ 3
testimony?
4 A
Yes.
5 g
Were there continuous complaints by members 6
of your department as to how and what the training 7
department was teaching?
8 A
There were continuous comments as you 9
would expect from any group of persons receiving common 10 training, and these comments were meant to improve the 11 end result that is to end up with a more trained 12 operator.
Some of them may have been in the nature
'13 of complaints, but I think it was with a constructive 0e 14 frame of mind that they were made.
1 15 MS. WAGNER:
Are you asking him to comment 16 on his prior testimony or are you asking him a 17 question independent of his prior testimony?
18 MR. KIRSCHBAUM:
He can read back the 19 question but I believe the question stands on 20 its own.
21 MS. WAGNER:
I was wondering why you showed T
22 him this testimony.
Does his testimony refor to 23 that?
24 MR. KIRSCHBAUM:
The testimony is on the
(^)
\\-
25 subject of training.
1 Ficyd 472 2
MS. WAGNER:
I don't quite get the 3
connection, but if you are happy with the record, I
4 I am.
5 Q
Did members of your department complain 6
that the training department was not doing the job?
7 A
No.
8 MS. WAGNER:
Objection to the question as 9
leading.
10 Q
Referring you to that testimony that you 11 have before you at page 97, lines 12 through 15, what 12 did you mean in that testimony?
~ 13 MS. WAGNER:
Objection.
No foundation that 14 he recalls it.
15 Q
If you don't recall it, you can so state, 16 and then you can testify asoto whether or not the 17 testimony recorded there is true and complete, to 18 the best of your present knowledge.
19 A
My reference to the training department 20 not doing the job was my invention of a criticism which 21 then I could work off of as to how I would resolve 22 typical comments coming from people in my department.
23 I did not make an allusion to a specific 24 comment that I had heard previously.
(:)
25 Q
Do you recall sitting here now ever hearing N
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w 7
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w
-%-sue-v 7-"W-MT
""M?=+-r-"@
1 Floyd 473 2
a member of your department say, in words or substance, O
3 that the training department was not doing the job?
4 A
Words very close to that would be not doing
('
5 as good a job as they could, but I don't remember the 6
precise words you used.
7 Q
What did you understand such comments to 8
mean?
9 MS. WAGNER:
Objection unless you are 10
'asking for his recollection rather than his 11 present-day understanding.
i 12 Q
The question was what did you understand
-13 those comments to mean?
O 14 MS. WAGNER:
I am becoming confused whether 15 the witness is analyzing his prior testimony or 16 whether he is giving his recollection about 17 his prior testimony or his recollection 18 independent of the prior testimony.
19 That is the basis of my confusion.
20 If you can clarify that the witness is 21 giving his recollection of his testimony or 22 inlapendently, I would be happier.
23 Q
I am not asking for recollection of your 24 testimony.
O 25 A
May I hear the question?
,..-m-.
_,-,.,,___m.
w.,
y
-,-e ay..
,,,,w,e-,.
y
1 Floyd 474 2
(Record was read back.)
s/
3 A
I understood them to mean that there is a 4
better way of doing business in any business you are in,
(~T 5
and this was a cry for eliciting a better performance.
O 6
Q Did you understa nd those comments to mean 7
that the members of your department were dissatisfied 8
with the general performance of the training 9
department?
10 MS. WAGNER:
Objection.
11 A
Again, I would interpret those comments 12 to be that there should be an improvement in performance, 13 an attempt to find a better way to invent the wheel.
)
G 14 Q
Prior to the accident, how high a priority, 15 if any, did you personally place on the training of 16 your operators?
17 A
very high priority.
18 Q
Why was that?
19 A
It was important that they know what they 20 were doing and how they were doing it.
21 Q
Prior to the accident, -how high a priority,
[
22 if any, did you place on your own requalification 23 training?
24 A
Not nearly as high as I placed on the 25 training for my operators.
m -
1 Ficyd 475 l
2 Q
Why was that?
3 A
I felt that I was capable of providing my l
4 own training, and if I detected weaknesses in my own
~
5 knowledge, I was free to go about correcting them and O
6 could correct them pretty much on my own, since my time l
l 7
was not nearly as structured as the control room 8
operators' time.
9 Q
When I referred to operators in the last 10 few questions, and you also referred in your answeres, 11 you understood that I was referring to control room 12 operators, shift supervisors and shift foremen?
'13 A
Yee.
14 MS. WAGNER:
Objection; leading.
You 15 should ask the witness what he means by operators.
16 Q
What do you mean by operators?
17 A
Control room operators, shift supervisors 18 and shift foremen, the operating crew.
19 Q
When Ms. Wagner asked you yesterday about 20 cheating on the part of operators, did you understand 21 her questions in the same sense in terms of the use 22 of the word operators?
23 A
Yes, the operating shift, the shift foremen, 24 shift supervisors, and CRO's.
(^T
\\l 25 Q
Prior to the accident on March 28, 1979 at
1 Floyd 476 2
TMI-2, were you familiar with the events which took V
3 Place at Toledo Edison's nuclear plant at Davis-Besse 4
on September 24, 19777
^
5 A
No.
O 6
Q Prior to the TMI-2 accident, had you heard 7
that a PORV had stuck open at Davis-Besse on that date?
8 A
No.
9 Q
P'rior to the TMI-2 accident, had you heard 10 that the reactor operators at Davis-Bessee had failed 11 to recognize the stuck open PORV for some period of 12 time?
'13 MS. WAGNER:
Objection.
O-14 A
No.
15 Q
Prior to the accident, were you aware of 16 the activity of the pressurizer at the Davis-Besse plant 17 on September 24, 19777 18 A
No.
19 Q
Were you aware that the pressurizer had 20 filled when pressure had gone down?
21 MS. WAGNER:
Objection.
22 A
No.
23 Q
Do you know someone by the name of 24 Norm Elliott?
i 5-25 A
Yes.
I Floyd 477 2
Q Who is Mr. Elliott?
3 A
I believe manager of training for B&W.
4 Q
Did Mr. Elliott ever tell you prior to the 5
accident that the pressurizer had filled while pressure 6
dropped at Davis-Besse on September 24, 19777 7
MS. WAGNER:
Objection.
8 A
No.
9 MS. WAGNER:
Leading and no foundation that 10 he ever spoke to Mr. Elliott before the accident.
11 Q
Prior to the accident on March 28, 1979, 12 had you ever spoken to Mr. Norm Elliott?
13 A
Yes, usually whenever I was in Lynchburg 14 I would'see Norm.
15 Q
Would you speak to him on those occasions?
16 A
Yes.
17 Q
Did any such occasions take place between 18 September 24, 1977 and March 28, 19797 19 A
If my training records show I was at the 20 simulator in that time period, they would have.
21 Q
Did anyone from B&W tell you prior to the 22 accident that the pressurizer had filled while pressure 23 dropped at Davis-Besse?
l 24 A
No.
25 g
Prior to the accident, were you aware that
1 Floyd 478
("3 2
the operators at Davis-Besse had terminated high l
O 3
pressure injection in response to the rise in 4
pressurizer level?
5 MS. WAGNER:
Objection.
6 A
No.
7 Q
Were you ever told by anyone from B&W 8
anything about improper operator action at Davis-Besse?
9 A
No.
10 MS. WAGNER:
Objection.
11 Q
I am handing you two memoranda which have 12 previously been marked as GPU Exhibit 78, a memorandum
(~N 13 from Bert Du.nn to Jim Taylor dated February 9,
- 1978,
\\,)
~
14 and a memorandum from Bert Dunn to Jim Taylor dated 15 February 16, 1978.
16 Prior to the accident, had you seen either 17 of these two memoranda written by Mr. Dunn?
18 A
No.
19 Q
Were you aware of their contents prior to 20 the accident?
21 A
No.
22 Q
There has been previous reference in this 23 deposition to the Michelson report.
Do you know what 24 I mean by that?
25 A
Yes.
i
1 Floyd 479
(^3 2
Q Prior to the accident, were you aware of V
3 the existence of the Michelson report?
4 A
No.
5 Q
Prior to the accident, were you aware of 9
6 its contents?
7 A
No.
f 8
Q Do you know of anyone at Met Ed or GPU who
{
g was aware of the Michelson report or its contents 10 prior to the accident?
11 A
No.
12 Q
Do you know of anyone at Met Ed or GPU '>ho 13 was aware of the existence or the contents of the Dunn 14 memoranda,which were marked as GPU Exhibits 78 and 79, 1
l 15 prior to the accident?
l 16 A
No.
17 Q
Let me refer you again to your Kemeny 18 Commission deposition testimony beginning on page 101, 19 line 4, and continuing through page 106, line 1.
I 20 will ask you to read that testimony over, please, to 21 yourself.
I 22 MS. WAGNER:
If I can make a suggestion 23 for testimony about prior testimony, the record 24 I think is extremely confused if you don't read O
25 into the record what it is the witness is
1 Floyd 480 7S 2
testifying about when you are trying to get him
()
3 to clarify prior testimony.
4 It is up to you whether you want to do 5
that.
6 MR. KIRSCHBAUM:
I think the record has 7
been clear up to now but if you find any problem, 8
I am sure you will let me know.
9 Q
Have you finished reading that testimony?
10 A
Yes.
11 (Continued on the following page.)
12
(~)
14 15 16 17 18 19 20 t
21 22 23 24 25 t
1
id 1 1
Floyd 483
(~
2 Q
Were you aware of the Dunn memoranda or V) 3 their contents at the time you gave that testimony?
4 MS. WAGNER:
Objection.
I' 5
A I don't believe I was aware of the Dunn 9
6 memo at this time.
7 Q
By "this time," you mean?
8 A
This was given in August, I believe of 9
1979.
10 Q
Were you aware at the time you gave this 11 testimony that B&W had received the Michelson report 12 prior to the accident?
("}
13 MS. WAGNER:
Would it be possible for the
\\~)
14 record to indicate what the testimony is about 15 that you are talking about?
You don't have to 16 if you don't want to.
I <1on't see any relation 17 between whatever you are asking Mr. Floyd and 18 whatever is in his testimony.
19 MR. KIRSCHBAUM:
I believe it will become 20 clear to you if it isn't already.
21 MS. WAGNER:
It isn't.
22 MR. KIRSCHBAUM:
Read back the last 23 question.
24 (Record read) 73 U
25 MS. WAGNER:
I also object because there 4
2 1
482 Flcyd 2
is no foundation.
3 A
At this time I gave this testimony, I knew 4
that Michelson report existed.
I don't recall if I 5
knew that B&W had it before the accident.,
6 Q
In light of what you now know concerning 7
the Dunn memoranda and the Michelson report, is the 8
testimony which I have referred you to accurate to the 9
best of your present knowledge?
10 MS. WAGNER:
Objection.
11 A
It is probably right in substance, but 12 not in degree.
The existence of the knowledge within 13 B&W to have properly trained us for this transient 1
14 which we saw and thereby prevented it from deteriorating 15 to the point where it did would bear heavily on their 16 responsibility to us.
17 Q
Let me refer you to the answer which 18 begins at the bottom of page 102, line 25, which reads, 19 "Well, the Michelson report, of course, was unknown to 20 any of us, and we should have been aware of that, but 21 I guess that we could have even viewed it on the 22 simulator and c'uld have been trained for that specific o
23 thing which happened to us, but we weren't.
B&W 24 probably bears some responsibility on that.
We O
s 25 probably bear some responsibility on that, but it turns
I 1
Floyd 483 2
out we warn't prepared for it.
When something awfully 3
close was written down on a piece of paper, it would 4
have been recognizable had we been familiar with that 5
piece of paper before March 28th."
O 6
can you tell me whether or not that 7
testimony is accurate and complete, to the best of 8
your present knowledge?
9 MS. WAGNER:
Objection.
10 A
It was accurate at the time I gave it, 11 but in light of my present knowledge, it is not 12 accurate in that a much larger share of the 13 responsibilities is transferred to the person who 14 knew about it before the fact.
15 Q
Who is the person who knew about it 16 before the fact?
17 A
Apparently B&W.
18 Q
Referring you to GPU Exhibit 78, which
~
19 is a memorandum from Mr. Dunn to Mr. Taylor dated 20 February 9, 1978, the third paragraph,first sentence 21 states:
"The incident..." -- referring to the* incident 22 at Davis-Besse -- "... points out that we have not 23 supplied sufficient information to reactor operators 24 in the area of recovery from LOCA."
25 Based on your present knowledge of the
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1 1
1 Floyd 484 l
2 Davis-Besse incident, is that sentence correct or q
V 3
incorrect?
4 MS. WAGNER:
Objection.
5 A
correct.
6 Q
what, if anything, was B&W's role in 7
formulating the emergency procedures for TMI-1 and
)
l 8
TMI-27 9
MS. WAGNER:
Objection.
10 I think we already had testizcony on this.
11 MR. KIRSCHBAUM:
That is what 12 cross-examination is about.
'13 A
In the formulation of emergency procedures, 14 you first run a transient analysis and find out what 15 the plant is expected to do and how you have to design 16 equipment to mitigate those consequences.
\\
l 17 So B&W played a very heavy role in this 18 formulation in reducing that to an emergency procedure.
19 I,think in Unit 1,
B&W supplied rough drafts of 20 emergency procedures which carried the substance of 21 what had to be done, and we took that procedure and 22 made it plant specific by writing in our valve numbers.
23 In Unit 2, I think they supplied a plant specific 24 draft.
b)
(
25 Q
With respect to the procedures for Unit 1,
1 Floyd 485 2
did B&W review the final procedures?
3 A
After we had put in our valve numbers, 4
the procedure that went into the plant to be used was, 5
in fact, reviewed by B&W.
O 6
Q Did you ever attend PORC meetings?
7 A
Yes.
8 Q
For Unit 17 9
A Yes.
10 Q
For Unit 27 11 A
Yes.
12 Q
At any of those meetings, were there 13 discussions concerning changes or proposed changes 14 in emergency procedures?
15 A
Yes.
16 Q
Was there anyone from B&W present at such 17 meetings?
18 A
B&W was not present as a member of PORC.
19 However, they attended whenever their scope of supply 20 was involved.
21 Q
What, if anything, was B&W's role in 22 formulating the operating procedures for TMI-1 and 23 TMI-27 24 A
The operating procedures come out of a O
25 foundation called the operating envelope, which was l
l
i 1
ricyd 466 2
created by B&W and used in their transient analysis, 3
and in their scope of supply they provided operating 4
procedures, drafts in Unit 1,
which we made unit 5
specific, and unit specific procedures in Urait 2.
6 Q
Did you or, to.your knowledge,;anyone else i
N 7
at Met Ed undertake an independent > st'udy as to the 8
accuracy and. completeness of the transient analyses 9
underlying the B&W draft emergency procedures?
10 A
yo, i
11 Q
Why not?
f 12 A
It would have been outside our scope of 13 expertise.
14 Q
Did you or, to-your knowledge, anyone 15 else at Met Ed undertake an independen't' study as to 16 the accuracy and completeness of the plant limitations
+2 17 and precautions supplied by B&W7 18 MS. WAGNER:
Objection to the form.
j 19 A
The procedures that were supplied by;B&W 20 were reviewed by Met Ed, but to say an independent 21 study would be, the answer to the' question would be no.
4' 22 Q
What was the type of review that was 23 performed by Met Ed?
24 A
We would frequently question them as to V
25 why this limite or precaution existed, and we were
1 Ficyd 487 2
looking for the technical justification of it, 3
especially if it was impinging on the area of the room 4
to operate the plant.
5 g
You referred to "them" in your previous 6
answer.
7 Who did you mean by "them"?
8 A
B&W.
9 Q
In your direct examination by Ms. Wagner,
,s 10 you were referred to page 36 of your November 15, 1979 11 Senate subcommittee interview which contained the 12 following question and answer on page -- or en lines
'13 13 through 20.
14
" Question:
Do you know who, I guess, put 15 together the operating procedures fos: Unit 2?"
16
" Answer:
I have to have a very vital hand 17 in that.
It really, I guess, is the PORC 18 responsibility, Plant Operations Review 19 committee, but as a member of that group and as 20 the operations supervisor and as the man with 21 the most years of nuclear operating experience, 22 why the operating procedures were very much in 23 my domain."
24 Do you see that testimony?
25 A
Yes.
I I
Floyd 488
}
2 g
Do you recall being asked that question 3
and giving that answer?
4 A
I don't recall it specifically, but it 5
is testimony that is here, and I imagine it was given O
6 that way.
7 Q
In what sense, if any, did you have, 8
quote, a very vital hand, close quote, in putting 9
together the operating procedures for Unit 27 10 MS. WAGNET.:
Now you are asking for his 11 present recollection of what he actually did in 12 terms of procedures rather than his recollection 13 of his testimony, is that correct?
14 MR. KIRSCHBAUM:
I think that is exactly 15 what was asked.
16 A
I had to insure that there were procedures 17 availnble to operate the plant when it was time to 18 operate the plant, since that was my area of 19 responsibility.
~
20 In addition, the procedures that were not 21 nuclear safety related were issued over my signature, 22 and, therefore, I had direct responsibility for those.
23 The ones that were nuclear safety related, the 24 responsibility fell to the PORCs however, as a PORC 25 member and the PORC member with the most experience in i
1 Ficyd 489 1
l l
2 nuclear power plants, I had a very real input to the l
3 review of those procedures also.
4 Q
Do you see any inconsistency between that r-5 testimony that you have before you and the statement O
6 that you just made now and your previous testimony this 7
afternoon concerning B&W's role with respect to the 8
emergency procedures at TMI?
i 9
MS. WAGNER:
Objection.
t l
10 A
No.
11 Q
Let me refer you again to that testimony 12 at page 36.
In what sense, if any, were the Unit 2 13 b(~%
operating procedures very much in your " domain"?
14 MS. WAGNER:
I take it you are asking for 15 his recollection of those events rather than his 16 interpretation of his prior testimony which he 17 does not recall,.is that correct?
18 MR. KIRSCHBAUM:
I am asking for his 19 present recollection.
That's correct.
20 MS. WAGNER:
Of what he actually did, not 21 his prior testimony.
22 MR. KIRSCHBAUM:
There has been no 23 suggestion that I am asking about his prior 24 testimony.
O 25 MS. WAGNER:
You are referring to his i
l I
1 Floyd 490 l
2 prior testimony.
I want to make sure the record O
3 is clear.
4 A
It was my department that was responsible p
5 for executing those procedures on the plant.
Since we 9
6 were the end user, what was in there was important to 7
me.
8 (Recess) 9 (continued on next page) 10 11 12 13 14 15 16 17 18 19 i
20 21 e
22 M
24 25
1 Floyd 491
(
2 Q
Did B&W supply Met Ed with a set of limits 3
and precautions for TMI Unit 17 4
A Yes.
5 Q
Did B&W supply Met Ed with a set of plant O
6 limits and precautions for TMI Unit 27 7
A Yes.
8 Q
Was the set of limits and precautions 9
supplied for Unit 2 the same or different than the set 10 nupplied for Unit I?
11 MS. WAGNER:
Objecti9n.
There is no 12 foundation that the witnesr, ever saw the limits 13 and precautions, ever examined them or ever 14 compared them to answer this question.-
15 Q
You may answer the question.
16 A
The areas covered were similar.
Since the 17 power level in Unit 2 was higher and the reactor 18 coolant pumps were different, there had to be unique 19 or different things in Unit 2 than there were in Unit 1.
20 Q
Were there differences in the draft 21 procedures which B&W supplied for Unit 1 and Unit 2?
22 MS. WAGNER:
Objection.
23 A
Yes.
The Unit 1,
they supplied generic 3
24 procedures basically that were not plant specific, and
%.)
25 in Unit 2 they supplied plant specific procedures.
j Q
Were there any other differences between l
\\
1 Floyd 492 2
those procedures supplied for Unit 1 than supplied for 3
Unit 27 4
MS. WAGNER:
Same objection; no foundation.
5 A
Not that I can think of.
6 Q
Let me refer you to page 32 of your 7
President's Commission deposition which took place on 8
August 1, 197'9, pages 32 and 33, beginning on line 18 on g
page 32, which reads as follows:
10 "Q
In September 1975, you came to the 11 position of supervisor of operations for Unit 2, 12 correct?
()
13 "A
Yes, ma'am.
14 "Q
And at that point, were you involved 15 with drafting of procedures for Unit 27 16 "A
Yes, ma'am.
17 "Q
Could you explain that process?
18 "A
Well, there we pretty much relied 19 heavily on Unit 1's procedures."
20 The answer continues on to the following 21 page.
My question is, do you recall the extent, if any, 22 to which you relied on Unit 1's procedures.in formulating 23 the procedures for Unit 27 24 MS. WAGNER:
AGain, you are not referring 25 MR. KIRSCHBAUM:
Present recollection.
- ~'
1 Floyd 493 2
MS. WAGNER: Present recollection of what he O
3 did rather than the recollection of his testimony, 4
is that correct?
5 MR. KIRSCHBAUM:
That is the question.
6 A
In the case where the systems were similar 7
between Unit 1 and Unit 2, such as intermediate cooling 8
system, we would merely have had to change valve 9
numbers to make it applicable because we knew we had a 10 working procedure.
11 On the systems that were different, which 12 is the main turbine, you had to write an entirely new
~13 procedure.
Where they were in the B&W scope of supply, O
14 I don't know if B&W relied on Unit 1 procedures or 15 not, but we relied on what was given to us by B&W.
16 Q
What was given to you by B&W for Unit 27 17 A
Yes.
18 Q
Referring now to page 20 of that same 19 Kemeny Commission deposition, you testified as follows, 20 starting with line 7:
21 "Q
And who drafted the initial 22 operating and emergency procedures for Unit 17 23 "A
Those that were in the B&W scope of
' 24 supply would have had the first draft written by B&W 25 and then massaged rather severely by our staff.
Those
4 g
Floyd i
494 2
outside the asW scope of supply would have been drafted 3
by our people initially."
4 Is it your testimony your staff massaged f'
5 the Bsw procedures rather severely?
4 6
MS. WAGNER:
Are you asking Mr. Floyd if he 7
gave false testimony previously?
8 MR. KIRSCHBAUM:
No, I am asking if it is 9
true to the best of his knowledge.
10 MS. WAGNER:
Since I asked Mr. Floyd about 11 this same issue and he couldn't recall, it would 12 he interesting to hear what he had to say.
'13 MR. KIRSCHBAUM:
Do you care to refer to 14 the part of his testimony that you are referring 15 to?
16 MS. WAGNER:
If you would like me to, I 17 will try to find it.
18 MR. KIRSCHBAUM:
Off the record.
19 (Discussion off the record.)
20 MS. WAGNER:
On page 211 of Mr. Floyd's 21 testimony on February 19, 1982, the following 22 questions and answers appear:
23 "MS.
WAGNER:
I would like to read in, 24 in response to your comment, a p'revious question O
25 and answer.
The question is, 'Who drafted the
I 1
Floyd 495 2
initial operating and emergency procedure for 3
Unit 1?'
4 "A
Those that were in B&W's scope 5
of supply would have had the first draft written 6
by B&W and then massaged rather severely by 7
our staff.
Those outside the B&W scope of 8
supply would have been drafted by our people 1
g initially.
10 "MS.
WAGNER:
Do you recall being asked 11 that question and giving that answer?
12 "A
No, I do not.
(-
13 "Q
The testimony would indicate that u
14 B&W provided draft procedures and then they 15 were massaged severely.
Do you recall that 16 happening?
17 "A
No, I do not."
18 BY MR. KIRSCHBAUM:
19 Q
I will go back to my previous question.
20 (Record read.)
21 A
In taking them in the form in which we 22 received them and putting them into our format and 23 making them plant specific, there was a lot of work 24 involved.
However, the substance of the procedure O
25 was maintained, so the substance of the procedure was
,--.,v.
---n
1 Floyd
!496
(~
2 not massaged, merely a lot of work to make them usable.
v 3
Q At page 166 and page 167 of your direct 4
examination, you testified that you understood that 5
boiling outside the pressurizer would lead to net steam 9
formation and that as the size of the steam bubble 7
increased, pressurizer level would incirease.
8 What led you to that understanding?
e 9
A Primarily an experiment which was run in 10 the United States Navy while I was an operator at A1W, 11 in which the object of the epxeriment was to get a 12 higher steam pressure by raising T-AV.
In the 13 process of raising T-AV, you reduce your thermal b(~N 14 margin, and that experimental procedure cautioned the 15 operator to be alert for a pressurizer level rise which 16 would be indicative of steam formation in the reactor 17 coolant system other than in the pressurizer in the 18 even that the calculations which the experiment was based 19 on were non-conservative.
20 Q
What did you mean in your last answer by 21 the term experimental procedure?
6,'-
22 A
It was unusual in the Navy to have anything 23 new and different.
It was a way of life that had been 24 well established, and so experiments were unusual.
I
~
b 25 think at that time the Navy had a strategic need to be
1 Floyd
- 497 2
able to launch heavier aircraft from their steam 3
catapults, and the only way to get the higher steam 4
pressure was to raise the T-AV of the reactor plant, 5
so we were talking the reactor into an area where it 6
had never been before and in doing so, we were reducing 7
its thermal margin, and if those calculations which 8
predicted it was safe to do that were non-conservative, 9
then we had the possibility of forming steam which would 10 then terminate the test that was underway so that we 11 didn't move the plant into a danger zone.
12 Q
So the procedure that you were referring to 13 in your answer applied specifically.to this experiment?
14 A
Yes.
15 Q
Were you ever trained in the Navy.to expect 16 a rise in pressurizer level in case of a loss of 17 coolant accident?
18 A
No.
19 Q
You testified at page 173 of your direct 20 examination that the thoughts you had in the Navy 21 concerning boiling outside the pressurizer and the 22 possible rise in pressurizer level never entered your 23 conscious mind while you were working at Three Mile S
24 Island.
d 25 My. question is, what did you mean by that
1 Floyd 1498 p
2 testimony?
3 MS. WAGNER:
I object to the characterization 4
I don't believe that testimony on page 172 5
refers to the Navy.
O 6
Q The testimony refers to the witness' 7
previous direct testimony about pressurizer level 8
activity which he has now today explained came to his 9
mind as a result of the experiment conducted in the Navy.
10 MS. WAGNER:
I don't know whether I agree 11 with that.
12 Q
The question is referring to your testimony
~13 on page 173, what did you mean by the answer you gave 14 about information not being in your conscious mind 15 while you were at TMI?
16 MS. WAGNER:
I object to the question.
l 17 A
Since I was not involved in any experiments 18 at Three Mile Island which involved reducing the 19 thermal margin, and since such experiments were neither 20 taught nor run, I had no tie-back to this previous 21 piece of information.
You misht say I forgot the y,,
t 22 information.
23 Q
Do you mean to say that in 1978 and 1979, for i
24 example, you did not then know about the rise in 25 pressurizer level?
__.________m_
__..____m_
1 8
1 Floyd 499 1
(
2 MS. WAGNER:
I object to the question.
3 A
No.
I don't mean to imply that.
I mean 4
it was in the memory bank but it wasn't in the 5
forefront of the memory bank.
It wasn't right behind ggg 6
my eyeballs.
7 MS. WAGNER:
I think it is highly proper 8
to get the witness to contradict precisely the 9
term and the testimony he gave earlier in his 10 transcript.
I think Mr. McBride might be 11 interested in taking some action in that regard.
12 MR. KIRSCHBAUM:
I think you on that very
()
13 page or the next page claimed you weren't able to 14 understand the witness' answers and claimed 15 that you felt there was some lack of clarity in 16 that testimony.
I am seeking to clarify that now.
17 MS. WAGNER:
I don't think I suggested 18 that his testimony is directly opposite to what he 19 believes to be the truth in this matter.
20 MR. KIRSCHBAUM:
I think you did suggest on 21 Page 173 that you felt there was an inconsistency G
22 in what the witness testi,fied to.
23 MR. McBRIDE: I would also say I haven't 24 heard anything that contradicted any prior b
25 testimony, and if you think there is such a
Floyd 500 1
contradiction, you can ask it on redirect.
(_)
2 I think it is improper for you to refer to 3
my presence as his counsel and indicate some 4
action be taken.
MS. WAGNER:
I don't believe that I said that 6
Mr. Floyd has testified to anything improper.
7 I am suggesting that Mr. Kirschbaum is 8
suggesting that.
9 MR. KIRSCHBAUM:
Are you suggesting that I 10 was instructing the witness or trying to have the 11 witness give false testimony?
12 MS. WAGNER:
I certainly am not attributing I' t 13 kl that to you, but when he has testified about what 14 he knew and then you are suggesting "Are you 15 suggesting that you didn't know," I think that 16 is an inappropriate wty to proceed.
17 (Continued on Page 501) 18 19 20 21 0
22 23 i
24 g_s (j
25
.b/1 1
Floyd 501 cx
)
2 MR. McBRIDE:
His testimony at page 173 on 3
line 10 in response to your question was your 4
question was:
5 "You didn't have a thought as to whether ggg 6
that was an important thing to tell the operators 7
or not?
8
" Answers No, just I didn't have the 9
thought enter my conscious mind while I was 10 working at Three Mile Island."
11 He was just asked a question about that 12 testimony as I understand.
What I thought I I~'
13 heard was testimony that was consistent with V;
14 that answer.
15 MS. WAGNER:
I heard it as well.
16 MR. McBRIDE:
Was it your position that 17 his testimony just now was consistent or 18 inconsistent?
19 MS. WAGNER:
Consistent.
20 Q
Prior to the accident, did you ever 21 associate your naval experimental training on the O
22 effects of boiling in the reactor vessel with a LOCA?
23 MS. WAGNER:
Objection.
24 A
No.
\\
/
25 Q
Was it ever your understanding prior to
l 1
Floyd
()
2 the accident that boiling in the reactor coolant system 3
would result in the pressurizer going solid with water?
4 A
No.
ggg 5
Q Did you ever conceive prior to the accident 6
that it was possible to have a solid pressurizer while 7
a LOCA was in progress?
8 A
No.
9 MS. WAGNER:
Objection.
10 Q
Was that your understanding regardless 11 of whether there was boiling in the reactor vessel?
12 A
Yes.
(
13 Q
Did you ever conceive at any time prior 14 to the accident that it was possible to have a water 15 level in the pressurizer and at the same time to have l
16 the core uncovered?
l 17 MS. WAGNER:
Objection.
18 A
No.
ID Q
Was that your understanding regardless 20 of whether or not there was boiling in the reactor 21 vessel?
O 22 A
Yes.
23 MS. WAGNER:
Objection.
24 Q
Did B&W ever demonstrate on the simulator O
25 or suggest in the classroom that it was possible to l
l
1 Floyd 503 4
()
2 have a water level in the pressurizer at the same time 3
that the core was uncovered?
4 MS. WAGNER:
Objection.
Leading.
5 A
Are you referring to the time before the (lg 6
accident?
7 Q
Yes.
8 A
Then my answer is no, they did not.
9 Q
Did you receive any training from B&W 10 prior to the accident on the simulator or otherwise 11 concerning the effects of boiling or saturat. ion in the 12 reactor vessel during or as a consequence of a small
(
13 break loss of coolant accident?
14 A
No.
4 15 Q
You testified at pages 151 and 152 of your 16 direct examination that it is possible in an overcooling 17 event to " suck the bottom out of the pressurizer and 18 cause the bubble to shift."
19 What did you mean by that testimony?
20 A
If you cool the reactor coolant system far 21 enough, the water in the reactor coolant system shrinks O
22 as it gets colder, and if you shrink it far enough, 23 you will end up without any water in the pressurizer, 24 merely the steam that you left behind, and if you t
[v<
25 continue to shrink it even further, the steam bubble
1 Floyd 504
(_)
2 will grow out of the reactor coolant system.
3 Q
Do you recall if you ever saw that happen 4
at the simulator prior to the accident?
ll) 5 A
No, I never saw that happen at the 6
simulator.
7 Q
Do you knc. of any overcooling events at 8
TMI-1 or TMI-2 in which the bubble extended from the 9
pressurizer to elsewhere in the reactor coolant system?
10 MS. WAGNER:
I take it you mean in the way 11 in which Mr. Floyd just testified to as opposed 12 to any other way?
(m) 13 MR. KIRSCHBAUM:
Yes.
/-
14 A
I believe the April 23rd transient led the 15 plant staff to conclude that there was a bubble in the 16 system, in the plant that was larger than the 17 pressurizer, although I believe B&W's analysis of that 18 same transient led to the opposite conclusion.
19 Q
Do you know of any overcooling event at 20 TMI-1 or TMI-2 in which pressurizer level rose as a 21 result of boil g or saturation outside the 22 pressurizer?
23 MS. WAGNER:
Objection.
24 A
Only the morning of the accident.
gS
%-)
25 Q
At some point during the April 23, 1978
l l
1 Floyd 505
(-(_)
2 trcnsient, was there an actuation of high pressure 3
injection?
4 A
Yes.
5 Q
During that event on April 23, 1978, did gg 6
the TMI-2 operators throttle HPI at some point?
7 A
Much later in the transient whm.
8 pressurizer level was regained, they throttled HPI to 9
hold pressurizer level constant.
10 Q
At the time when they throttled HPI as you 11 just described, was system pressure below the HPI 12 actuation point?
(,S/
13 A
Yes.
14 Q
To your knowledge, was B&W made aware by 15 Met Ed following the April 23, 1978 transient that the 16 operatcrs had throttled HPI while pressure remained 17 below the HPI actuation point?
18 A
I believe their analysis of that transient 19 included that knowledge.
20 Q
Did B&W ever inform Met Ed that operator 21 action on April 23, 1978 in connection with throttling O
22 high pressure injection was improper?
23 MS. WAGNER:
Objection.
S 24 A
Not to my knowledge.
Y 25 Q
Did B&W provide you or any of your operators i
1 1
Floyd 506
(_,)
2 with training as a result of the April 23, 1978 event 3
concerning the possibility of a rise in pressurizer 4
level in response to boiling or saturation outside the ggg 5
pressurizer?
6 MS. WAGNER:
Objection.
7 A
It would have been hard to train on a 8
phenomenon that I wouldn't have expected to occur.
9 Without a hole at the top of the pressurizer, I don't 10 think the level comes back up in the pressurizer due 11 to boiling, and as such, it would have been 12 counterproductive for our accident if we had trained
(~')
13 on that.
V 14 Q
I take it then you were not trained on it?
15 A
We were not trained on it.
16 Q
You referred to the fact that there would 17 not have been any point in training on the possibility 18 of a rise in pressurizer level as a response to the 19 April 23, 1978 event.
Was that due to the fact that 20 on April 23, 1978 there was no water level in the 21 pressurizer?
O 22 MS. WAGNER:
Objection.
23 A
That is true.
In other words, I didn't 24 mean to imply that we shouldn't have trained on a V
25 rise in pressurizer level in relation to that event
1 Floyd 507
(
2 which is what I thought your original question was 3
referencing.
4 Q
Did B&W in fact provide any training jgg 5
concerning a rise in pressurizer level in connection 6
with that event?
7 MS. WAGNER:
Objection to the question.
8 It has been asked and answered.
9 A
No.
10 Q
Let me turn to Emergency Procedure 11 2202-1.3 entitled " Loss of Reactor Coolant / Reactor 12 Coolant System Pressure" which has been previously
()
13 marked as B&W Exhibit 272.
14 Was the situation which confronted the i
15 TMI-2 operators on the morning of March 28, 1979 16 covered by that procedure based on your understanding 17 before the accident?
18 MS. WAGNER:
Objection.
This witness was 19 not in the control room on that day.
20 MR. KIRSCHBAUM:
The witness has testified 21 to having done a good bit of study concerning O
22 the events which did take -place in the control 23 room that day.
24 MS. WAGNER:
I didn't hear that testimony.
O 25 No foundetion for the question and it is leading.
'l me
1 Floyd 508 O()
2 A
I feel this procedure would not have been 3
entered by the operators because pressurizer level 4
and pressure were not tracking in the same direction.
(gg 5
MS. WAGNER:
I move to strike the witness' 6
answer.
7 A
And that has always been our fundamental 8
training in recognizing the LOCA.
9 Q
Was it your understanding of that 10 Procedure 2202-1.3 that that understanding is borne 11 out in the procedure?
12 A
Yes.
[D 13 Q
Where in that procedure is that
/
14 understanding borne out?
15 A
In the symptoms.
16 Q
What about the symptoms?
17 MS. WAGNER:
What is the question now?
18 I don't understand what the understanding is and 19 what your last question is.
20 MR. KIRSCHBAUM:
You want to read back the 21 previous three questions.
O 22 MS. WAGNER:
Is it possible for you to 23 restate it?
24 MR. KIRSCHBAUM:
I don't think it is 7-( }
v 25 necessary.
1 Floyd 509 2
A Symptom 1.1, initial loss of reactor 3
coolant pressure and decrease in pressurizer level 4
becoming stable after short period of time.
5 If you go back to section B on page 6,
1.1, ggg 6
rapid continuing decrease of reactor coolant pressure 7
1.2, rapid continuing decrease of pressurizer level.
8 Q
Based on your understanding prior to the 9
accident of those symptoms, what did they require in 10 terms of recognition of a LOCA?
11 MS. WAGNER:
Objection.
I am not sure what 12 you are asking, but I think therehas been prior
(}
13 testimony on exactly this point.
14 Q
What I am asking you is what those 15 symptoms, to your pre-accident understanding, told 16 the operator in terms of recognition of a LOCA.
17 MS. WAGNER:
Objection.
18 A
That the pressure and level meters would 19 be moving down scale together.
20 Q
Let me refer you to Unit 2 Emergency 21 Procedure 2202-1.5 entitled " Pressurizer System O
22 Failure," previously marked as B&W Exhibit 305.
23 Prior to the accident, did Emergency o
24 Procedure 2202-1.5 require that the PORV block valve O
25 he closed based on the fact that the discharge line
1 Floyd 510 C\\
\\J 2
temperature for the PORV had been in excess of 130 3
degrees for some time?
4 A
No, it did not.
lll 5
MS. WAGNER:
Objection.
6 Q
Why not?
7 A
This procedure required the closin7 of the 8
PORV block valve if the PORV was leaking.
If the PORV 9
leaked, it would be reasonable to see a high temperature 10 downstream of it.
However, prior to the accident, the 11 elevated temperature downstream of the PORV was stemming 12 from a leak in a code safety valve, and because of
()
13 the commonality of the discharge lines, all three 14 valves showed an elevated temperature based on one 15 valve leaking and the valve with the highest temperature 16 is the valve that would have been leaking.
17 Q
Which is the valve with the highest 18 temperature?
19 A
One of the two code safety, A or B.
I 20 don't remember which.
21 Q
But not the PORV line?
22 A
Not*the PORV.
23 MS. WAGNER:
Objection.
24 Q
Let me refer you now to your testimony O-1 25 before the Kemeny Commission itself which took place
/
1 Floyd 511 g()
2 on May 31, 1979, page 213, line 5, continuing through 3
line 19 which reads as follows:
4
" Commissioner Lewis:
What I am leading lg) 5 to is we had this key pressurizer relief valve that 6
everybody knew was leaking.
One reason why there was 7
confusion when you had the accident was that you knew 8
it was leaking and therefore you didn't pursue the 9
information that you were getting.
You may say that 10 is not a major safety feature of the plant and yet 11 when it came to this crucial moment, the failure to 12 maintain that particular valve was instrumental in
[/i 13 your having the accident.
G 14 "Mr.
Floyd:
I think I would agree with the 15 end of your statement there about it being important 16 to the course of the transient.
We responded to that 17 situation responsibly in that a decision to live with 18 the leaking valve and to schedule it for maintenance 19 when the parts were available was done legally as a 20 legal corporate citizen that we are.
It was done 21 within the technical specification which is imposed 22 on our plant."
23 Do you recall being asked that question and 24 giving that answer.
v 25 A
Yes.
ul1 1
Flcyd 512
)
2 Q
Looking at that testimony today, is
_j 3
it correct, to the best of your present knowledge?
4 A
Yes, from my standpoint where I was 5
thinking of the code safety being the leaking valve, lll 6
but when she, Commissioner Lewis, refers to a key 7
pressurizer relief valve that was leaking, I am not sure 8
that she wasn't thinking of the PORV.
If she was 9
asking a question about the PORV, and I responded to 10 a code safety valve, then my answer was not responsive, 11 although it is technically correct.
12 Q
You testified on page 275 of your direct
^h 13 examination that you believed prior to the accident, (G
14 that the TMI-2 operators, quote, were fully able to 15 identify a failed open PORV prior to the accident?
16 Do you now believe that the TMI-2 17 operators were able to identify h failed open PORV 18 prior to the accident?
19 MS. WAGNER:
Objection.
I don't understand 20 the meaning of the term " fully."
1 21 MR. KIRSCHBAUM:
I will take out the 22 word " fully."
23 A
Yes, a PORV failing open by itself as a 24 single incident in the plant would be readily 7_
(
)
25 recognized by the TMI operators.
However, if it is
I 533 j
2 1
Floyd
()
2 obscured because you are in the middle of a reactor 3
trip and it has been called on to operate and then it 1
l-4 fails to close, that is a very different situation i
5 than I referred to initially where it was happening ggg i
6 in isolation, and the more things you have going on 7
in the control room at one time, the better is the I
8 likelihood that something will be overlooked.
l 1
{
9 Q
Does the existence or nonexistence of a a-1 j
10 command position indicator light in the control room i
11 he.ve any bearing on your understanding of the ability 1
12 of the operators to detect the stuck open PORV7 i
13 MS. WAGNER:
Objection.
14 A
It was added to aid the operator in 15 knowing whether the valve was open or closed.
In the 16 course of our accident at Three Mile Island where it, i
]
17 in fact, indicated the opposites than what the valve j
18 was actually doing, it could be thought of as false l
{
19 intelligence and, hence, a detriment to the diagnosis 20 of what was wrong with the plant.
1 21 Q
Were you ever told by asW prior to the 1
22 accident that this command signal light could serve as 23 a detriment to the proper diagnosis of what was 24 happening in the plant?
1 25 MS. WAGNER:
Objection to the question.
-.. ~.
l 534 3
1 Floyd 1
[U 2
A No.
3 Q
Were you ever told by B&W prior to the 4
accident that this kind of position, come.and position 5
indicator, had misled the operators at Davis-Besse on g
6 September 24, 19777 7
MS. WAGNER:
Objection to the question.
8 A
No.
9 Q
Were you ever told by B&W that Davis-Besse 10 had asked for a better indication of valve position 11 than the one they had in their control room?
12 MS. WAGNER:
Objection.
(~}
13 A
No, v
14 Q
Before the accident, what, if anything, 15 was your understanding of what would happen with 16 respect to> tail pipe temperatures and reactor coolant' 17 drain tank temperature and pressure after tha closure 18 in due course of a PORV which had previourly opened?
19 A
Temperatures and pressure in the drain 20 tank would remain elevated for some period of time.
21 Q
Why-is that?
l
^
22 A
- j. The lines are thermally insulated and the 1
23 tank is large and contains a large quantity of water.
24 Hence, a lot of mass, and it, takes time for thg', heat f;
~
/
\\
25 to dissipate,to the ambient.-
f e
'I g
1 1
Floyd
.515
(
2 (Discussion off the record between the 3
witness and his counsel.)
4 BY MR. KIRSCHBAUM:
5 Q
Referring to your Kemeny Commission ggg 6
deposition, page 197, lines 14 through 23, which read 7
as follows:
8
" Question:
Are the auxiliary operators 9
aver able to affect the power level?"
10
" Answer Yes.
For instance, I think 11 the whole thing that precipitated this 12 transient at 4:00 o' clock in the morning was
()
13 an auxiliary operator,down in the basement of 14 the Turbine Building with the vessel, who made 15 a mistake that lost both feed pumps and the 16 reactor tripped, and everything worked fine for 17 a little bit, but them promptly' turned to hell.
18 He wasn't supposed to do that, but he did."
19 Do you recall being asked that question 20 and giving that answer?
21 A
Yes.
O 22 Q
Based on what you now now concerning the 23 accident, is that testimony as to what occurred on the 24 morning of the accident correct to the best of your 25 knowledge?
V
,+
l i
I Floyd
.536 (O_)
2 MS. WAGNER:
Objection on a number of 3
grounds including outside the scope of the 4
cross.
lll 5
A The testimony as given there is not 6
accurate now.
At the time, I thought that the most 7
likely source of the cause of loss of feedwater was 8
an operator error.
However, to this day, that has 9
not been proved or disproved, because the initiating 10 event that led to the loss of feedwater has not been 11 isolated, and even had the operator been in error and 12 caused a loss of feedwater, that is a transient for
()
13 which the nuclear steam supply system is designed and 14 can handle without failing fuel, so that testimony was 15 much too harsh on that operator, and it is certainly 16 not a pure causative event for what followed.
17 Q
I refer you now to your November 15, 1979 18 interview with the United States Senate Subcommittee, 19 page 3, line 7, which states as follows:
20
" Question:
From that period -- say '75 21 through the eventual startup of Unit 2 -- were O
~
of any major changes in the Unit 2 22 you aware 23 control room design?"
l 24
" Answer:
I have no idea what you have in 25 mind by, quote, major changes, close quote.
We
ll 6
1 Floyd 517
[D
(_/
2 added the panel, 8-A, which has come under 3
criticism, the one which has the reactor 4
coolant drain tank instrumentation on it, to lll 5
get the indication into the control room; that 6
was the only spot that was available, so it was 7
added at a back panel and, hence, out of line 8
of sight of the operator.
Some people may 9
consider that a major change.
It was an 10 addition and not added in the proper location."
11 Do you recall being asked that question 12 and giving that answer?
()
13 A
les.
14 Q
Uhat did you mean when you said that the 15 RCDT instrumention panel was an addition and not added 16 in the proper location?
17 A
By that point in time, the control room 18 was fairly well constructed, and certainly the design 19 had long since passed, and the need for this 20 instrumentattion in the control room became apparent, 21 so the panel was designed and constructed and added, 22 and in that sense it was an addition into the control 23 room.
It was added at an inconvenient location in 24 that the operator did not have it in his line of (x
\\_)
25 sight, but it was not inaccessible.
It was merely
I 1
Floyd 518
/
\\_/
2 inconvenient.
3 Q
Referring now to your appearance before 4
the NRC Special Inquiry on September 13, 1979, page lll 5
138, beginning on line 4, which reads:
6
" Question:
In your view, would the 7
differences in the design of the two control 8
rooms have had any impact on the ability of the 9
operators to respond to the transient that began 10 on March 28th?"
11
" Answer:
The one significant difference 12 is the location of the instrumentation for the (A) 13 reactor coolant drain tank.
In Unit 1,
it is 14 advisable from the console and it is not hard 15 to take a couple of steps toward it to read it 16 or at least see the area of the meter the needle 17 is in if you can't read it from the console.
18 "In Unit 2, you are forced to completely 19 desert the console and go back around the 20 corner and isolate yourself from the rest of 21 the plant in order to see those meters.
So 22 had the same transient taken place in Unit 1,
23 they may have come to the conclusion that the 24 drain tank was in duress earlier, and from O(^x, 25 that may have drawn the proper inference en
1 Floyd 519 2
on the electromatic relief valve.
There are 3
18 other things that go into that tank, but 4
they might have jumped on the right one."
lll 5
Do you recall being asked that question 6
and giving that answer?
7 A
Yes.
8 Q
Based on everything you now know 9
concerning the accident on March 28, 1979, do you 10 believe that the difference between the Unit 1 and Unit 11 2 control rooms in terms of the location of the reactor 12 coolant drain tank instrumentation was a significant
()
13 factor in the accident at TMI-27 14 MS. WAGNER:
Objection.
15 A
It might have been.
16 Q
Do you know whether or not it was?
17 MS. W AGNE R':
Objection.
18 A
It is speculation on my part to say 19 whether it was or wasn't.
20 Q
I refer you to the November 15, 1979 21 interview with the Senate Subcommittee staff, page 49, 22 line 9 through page 50.
23 "Mr.
Simpson:
Do you recall after that 24 transient any discussions that you had with the 25 operators somewhat reeducating them on the
1 l
1 Floyd 520 I
O
(_
2 previous concept they may have had about the 3
use of the alarm system or the importance of 4
the alarm system?"
ll 5
"Mr.
Floyd:
I would not have been 6
surprised to fiad myself ueLng the word, 7
quote, ignore, close quote, in talking to 8
them, because in the context that I would be l
j 9
talking to our control room operator, he would 10 automatically say, 'But what about this one 11 exception where I get a piece of information?'
12 That wouldn't even enter his mind, because he
()
13 knew if he had that piece of information, he I
14 would act on it in good faith.
So I might have 15 used the word, quote, ignore, in the conversation 16 with control room operators, and it might have 17 been after this transient that you called 1
18 4/23/78 transient; yes."
19 The answer continues on to page 50.
20 Do you recall ever telling your operators 21 to ignore the control room alarms during the transient?
22 MS. WAGNER:
I object to the question. It 23 is beyond the scope.
r~T 24 7
No, I do not recall ever having told
)
25 control room operators to ignor his alarms.
What I was
(
l 1
Floyd 521 7g l-2 more likely to have phrased it, rather than ignore, 3
which I speculate in here I might have used, was 4
that if there are too many alarms going off to lll 5
comprehend at one time, you have to bury your head in 6
the console to pay attention to the meters and the 7
recorders to determine the course the transient is 8
taking, but that if during that time you happen to 9
receive some intelligence from an alarm, you certainly l
10 don't ignore it.
You act on it if it is useful.
You 11 get around to responding to all the alarms once the 12 plant is stabilized, as soon as you can.
1 f~s
(,)
13 (continued on next page) 1 14 i
15 l
16 17 18 19 20 f
21 0
22 23 24
)
(U 25
I 1
Floyd 522 2
Q In that answer, you just mentioned 3
speculation in here.
What were you referring to by 4
that?
lll 5
A I said, "I would not have been surprised 6
to find myself using the word ignore."
I think that is 7
speculation on my part.
8 Q
You are now referring to your answer in 9
that interview?
10 A
Yes.
11 Q
On the morning of the accident when you 12 were in Lynchburg, did you arrive at any estimate as
()
13 to the amount of core cladding which had failed, if any, 14 at TMI-27 15 A
Yes.
16 MS. WAGNER:
Objection.
17 Q
What was your estimate?
18 A
In the area of one-eighth of the cladding 19 had failed.
20 Q
How did you arrive at that estimate?
l 21 A
Based on the radiation monitor reading from 22 HPR 227 and gassous channel and using a similar 23 instruement sensitivity, I was able to calculate the g-24 number of curies in the reactor building atmosphere.
(_))
25 Having made a similar calculation in Unit 2 for
Floyd 523 1
maximum hypothetical accident, and knowing that that
(
2 number of curies gave me a radiation reading, I was 3
able to equate the two and arrive at the conclusion 4
that approximately one-eighth of the cladding had failed.
6 Q
Did you tell anyone at Three Mile Island 7
about your estimate on that day?
8 A
No.
9 Q
Did you tell anyone at Lynchburg?.
10 A
Yes.
11 Q
Whom did you tell?
12 l
A The people that were in the simulator control room at the time I made the calculation, and 14 I mentioned it in the board room in the afternoon when 15 I was called up there at 2 or 3 o' clock.
16 Q
Who were the people at the simulator in the 17 morning that you just referred to?
18 MS. WAGNER:
Objection on the grounds it is 19 outside cross.
20 A
The Met Ed crew of operators that were lll there with me for the annual requalification training 22 were present in the control room as were several B&W 23 l
instructors,and several other people that I didn't 1
24 j
(~j}
recognize were probably B&W employees.
q 25
\\
i l
1 Floyd 524 O
i )
2 Q
Who are the people in the board. room?
8 #
3 What board room did you refer to in your 4
previ us answer?
g 5
A A large conference room on the second floor 6
of the old Forest Road building, B&W's office building 7
8 in Lynchburg, Virginia.
9 Q
Who was in the board room at the time you 10 discussed your estimate?
A There were many B&W people in the board room.
11 12 I cannot begin to name them.
I didn't recognize many O
f them.
(O 13 g4 Q
What was the reaction of the B&W people 15 in the board room when you gave them your estimate?
f*
MS. WAGNER:
Objection.
17 A
Surprise.
18 Q
Did you give anyone from B&W the other 19 information which you had received from the control 20 room on that day?
A In the morning, in the area of 9 o' clock, 21 O
22 Grant Ward, ten or fifteen people came down to the j
23 simulator to find out what I knew of what was going on 24 at TMI-2, so I took them into the classroom and
(
)
25 explained to them all the information I had gathered
l Floyd 525 in the 7:30 phone call.
i Q
Do you include when you say the information 3
that you had gathered from the control room, are you 4
including your failed cladding estimate?
A No, that calculation was made after I came out of that meeting.
7 Q
Did any of the B&W people with whom you spoke on the day of the accident tell you that day that 9
they believed there had been core uncovery, failed cladding or failed fuel at TMI-27 A
No.
12 MS. WAGNER: Objection.
Leading.
No O
foundation.
14 Q
Let me refer you to page 189 of your testimony before the President's Commission on May 31, 1978, in which you testified as follows:
" Professor Taylor:
Well, this in my mind is very important.
Is this correct:
that as far as you know, some quantitative reasoning was telling people at the plant that a substantial fraction of 21 the cladding had failed?
22 "Mr.FLoyd Yes, sir.
" Professor Taylor:
By early, Thursday morning ? By early,I mean very early in the morning.,
t
1 1
Floyd 526
(
2 "Mr.
Floyd:
I think that information was 3
available early Wednesday morning.
In fact, that is 4
how I got to my conclusion, was from information early lll 5
Wednesday morning.
Anyone else that was at the Island 6
was free to arrive at a similar conclusion if they 7
remembered a source term like I remembered, all right."
l 8
Do you remember being asked those questions 9
and giving those answers?
10 A
Yes.
11 Q
Based on your present knowledge, do you 12 believe that anyone else at the Island was free to
()
13 arrive at the same conclusion you had arrived at that i
14 morning?
15 MS. WAGNER:
Objection.
16 A
only if they had had the similar experience 17 that I had with the source term for the maximum 18 hypothetical accident, but to the best of my knowledge, 19 no one else had made that calculation besides myself.
20 Q
What is the calculation you are referring 21 to now?
O 22 A
When you release one hundred percent of the 23 gap activity, fifty percent of the radioactive 24 iodine inventory in the core and one percent of the O
25 particulates, you arrive at about one hundred million l
1
l i
l 1
Floyd 527 l
f'))
(_
2 curies in the reactor building.
3 Q
I am just trying to clarify that you are 4
referring to not the calculation you made on the day of lll 5
the accident, but some prior calculation.
6 A
Yes.
7 Q
At the time you gave this tstimony that I 8
just read to you, were you conscious of the fact that 9
no one else at the Island had been involved in that 10 previous calculation?
11 MS. WAGNER:
Objection.
12 A
I believe it was dawning on me as I was es (s. )
13 answering this question, because I realized they had 14 to have the source term and I included that in this 15 answer to Professor Taylor, and in fact, the very next 16 sentence says, "But unfortunately, I was privileged to 17 have made the calculation."
18 I think at that point in time I recognized 19 I was probably the only person so privileged and 20 uniquely positioned to make that calculation.
21 Q
Referring now to page 184 of your 22 President's Commission testimony, you testified as 23 follows:
24 "Professcr Taylor:
Well, let me explain.
(~]T L.
25 There is a reason I am following this line of questioning
l 1
Floyd 528
(
2 and that is:
I would like to have your reaction to this 3
statement,and that is it would seem to me that under 4
conditions where everybody is focusing, I am trying to 5
maintain ' solid water' in the whole primary system lll 6
except the upper part of the pressurizer,that any 7
indication that there is steam or some other gas in the g
primary system -- not up at the top of the pressurizer --
i 9
would be cause for very serious immediate concern.
10,
"Mr.
Floyd:
Yes, I agree with you."
11 Do you recall being asked that question 12 and giving that answer?
13 A
Yes.
14 Q
Can you explain what you meant by that 15 testimony at the time you gave it?
16 A
If the operators were aware of steam or 17 gas in some part of the reactor coolant system other 18 than the pressurizer, they should be very concerned 19 about it, but that does not mean that they are going to 20 have an easy time recognizing steam or gas somewhere
(
21 in the reactor coolant system besides the top of the O
22 pressurizer, and in fact there is no procedure 23 instructing them to insure subcooled margin exists on 24 any periodic frequency.
V 25 Q
Mr. Dunn had recommended in an internal B&W
i 8
1 Floyd 529 O
i,)
2 memorandum which I showed to you before that customers be advised to insure 50 degree subcooling in the reactor 3
4 coolant system before terminating high pressure 5
injection.
When was the first time that Met Ed ever ll 6
received such an instruction from B&W?
7 MS. WAGNER:
Objection.
8 A
Several days after the accident.
9 Q
Have you ever compared the effectiveness 10 of the 50 degree subcooling rule with the operator 11 guidance previously supplied by B&W concerning the 12 termination of high pressure injection?
()
13 MS. WAGNER:
Objection.
'14 A
Yes.
That comparison is rather stark.
15 Before this memo, we had identified the source of the 16 break, that is, where in the reactor coolant system 17 things had broken before you really knew what to do and 18 had to make some estimates about the size of the break 19 before you knew exactly what to do.
20 This rule that was then promulgated to us 21 after our accident is clear, simple, concise, and O
22 unequivocal.
23 Q
Do you have any reason to believe that the g-24 operators at TMI-2 either would or would not have N,I 25 followed the 50 degree subcooling rule if it had been
1 Floyd 530 (3
(,l 2
provided by B&W prior to the accident?
3 MS. WAGNER:
Objection.
4 A
It is my belief that they were trainable lll 5
in a rule this simple and straightforward and had they 6
had time to be trained, they would have followed the rule.
8 Q
I refer you now to the transcript of your 9
appearance before the NRC special inquiry on September 13 i
10 1979 at pages 96 and 97, in which you testified as 11 follows, concerning certain transients at TMI-2 12 which purportedly occurred in 1978:
l (A) 13 "the Witness:
The April transient with the 14 main steam safety valves is accurately portrayed on l
15 the record.
The loss of power to the electromatic 16 relief valve I am reminded occurred in March, not 17 November, in which I think the plant went dry, the 18 pressurizer,was prompted by the loss of power to the 19 outlet valves in the condensate polishing system. which 20 resulted in a total loss of feedwater and, hence, was 21 fairly similar to the transient on March 28.
22 "By Mu. Dinielt:
23 "Q
Of 19797 gS 24 "A
1979."
b 25 Do you recall being asked those questions
I 1
Floyd 531
[)
2 and giving those answers?
v A
Yes.
3 4
Q Is that testimony or is that statement 5
accurate, to the best of your present knowledge?
6 A
No, it is not.
My reference -- in here I 7
called it a November transient.
There was no such 8
transients on the plant at any ime, and I think I was 9
mentally confused and the testimony is plcub wrong.
10 (continued on following page) 11 12 O
13 v
14 15 16 17 18 19 20 l
21 9
22 23 24 CT l
l
\\ )
25
1 532 1
1 Floyd (D
's )
2 Q
Do you know of any transient at Three Mile 3
Island Unit 2 which was fairly similar to the one which 4
occurred on March 28, 19797 g
5 A
No.
6 Q
Do you know of any transient at any other 7
nuclear power plant, do you know of any transient at 8
another nuclear power plant which was fairly similar 9
to the March 28, 1979 transient at TMI-27 10 A
Davis-Besse in September 1977.
11 Q
Did Met Ed ever receive from B&W any 12 recommendations as to procedure changes based on
,-~)
13 experiences at other B&W-supplied units?
(wJ 14 A
Yes.
15 Q
What did Met Ed do in such cases?
16 A
Modified our procedures to take advantage 17 of that experience.
18 Q
Do you recall any such instances?
19 A
There was one on frequency and duration 20 of testing of main steam turbine governor valves.
21 There was another one on operating letdown coolers O
22 in parallel rather than singly.
There may have been 23 some more in the area of CRD venting, in-core venting, 24 RPS set points, out-of-core detector tilt calculations.
3
\\-)
25 Q
To what extent, if any, did Met Ed depend
1 Floyd
(~x
(,)
2 on B&W to warn it about generic problems that had arisen 3
at other B&W plants?
4 MS. WAGNER:
Objection.
5 A
They had built up a credible history of ll) 6 supplying us such information.
They were uniquely 7
Positioned to gather that information quickly and 8
transmit it to us through their site representative, 9
and so I would say we relied heavily on them.
10 Q
At page 189, beginning on page 188 and 11 continuing on 189 of your direct examination in this 12 action, you referred to certain guidelines for small f
13 break LOCA which were provided by B&W.
x 14 What type of break were you referring to in 15 that testimony?
16 A
Break in the high pressure injection line.
17 Q
Did B&W provide Met Ed with any warning 18 concerning the need to change procedures to deal with 19 such a break?
20 A
Yes.
21 Q
.io net E3 change its procedures after O
22 B&W warned of the need for such a change?
23 A
Yes.
24 Q
On page 280 of your direct examination, N,)
25 you testified or were asked questions concerning B&W
ll 1
Floyd 534
(
)
2 Exhibit 272 which is the Emergency Procedure 2202-1.3 3
and you referred specifically to 7.0, section 2.2.2 of 4
that procedure entitled "Small Break Loca Response."
lll 5
Prior to the accident, what was your 6
understanding as to the small break being referred to 7
in that section?
8 MS. WAGNER:
I think the witness has 9
testified to that.
10 A
The reference was to the break in the HPI 11 line.
12 Q
What was the small break LOCA response that 13 is referenced in the procedure?
14 A
If a high pressure injection pump fails 15 to start when there are symptoms of a LOCA, then within 16 two minutes the operator must carry out a cross-connect, 17 the opening of a cross-connect, so that if the break 18 happens to be in one of the high pressure injection is lines, the core will still be covered and remain safe.
20 Q
You testified on page 280 that that section 21 required recognition of a small break LOCA within two j
22 minutes.
What did you mean by that?
23 A
I meant he must recognize that a makeup 24 pump failed to start which means looking at the lights 7-l
\\-)
25 on the console, la
ll 1
Floyd 535 r~%
(V 2
Q Was it your understanding before the
)
3 accident that that section of the procedure required 4
that a control room operator be able to locate and
)
5 diagnose a small break LOCA within two minutes?
6 A
No.
7 (Recess taken.)
8 MR. KIRSCHBAUM:
No further questions.
9 MR. SELTZER:
We concluded the 10 cross-examination of Mr. Floyd before 5:00 p.m.
11 today and are willing to proceed with any 12 redirect examination.
I'~T 13 Mr. Floyd has indicated that he is willing O
14 to run later today.
Mr. Wise and Ms. Wagner 15 had asked me earlier whether in the interests 16 of completing Mr. Floyd's deposition expeditiously 17 he would be available to continue until 7 o' clock 18 on an evening, and I am indicating now that he is 19 available to continue today.
20 MS. WAGNER:
I asked if Mr. Floyd was l
21 available last evening which was the evening l
22 Mr. Wise and I had requested, and I was told he l
i l
23 was not.
I have been available for this I
i l
24 deposition since 9 o' clock this morning.
Nobody 7-1
\\'
25 informed me the deposition was going to start at
536 1
Flcyd
[)
2 noon which is when it did start, and I am uj 3
requesting that the deposition start at noon 4
tomorrow.
gg 5
MR. SELTZER:
We are distressed that the 6
reason for adjourning the deposition until noon 7
tomorrow is that another litigation is taking 8
precedence over this.
I can't believe with the 9
large stable of lawyers working on this case 10 and the number of people devoting their time 11 to Mr. Floyd's deposition that we are all going 12 to be sitting around cooling our heels until
(~N 13 noon tomorrow while some other case takes place,
)
%J 14 particularly since we reserved Wednesday, 15 Thursday and Friday for the conclusion of 16 Mr. Floyd's deposition.
17 MS. WAGNER:
I object to cooling my heels 18 without warning this morning while waiting for 19 this deposition to continue, and you told me that 20 you and Mr. Floyd were not available tomorrow.
21 The first time you informed me that Mr. Floyd O
22 was available tomorrow was about ten minutes 23 ago.
24 MR. SELTZER:
You are 100 percent wrong.
~y i
(
)
'~'
25 I have been and Mr. Floyd has been available.
1 Floyd
()
2 It was your office that wanted to take Scott's 3
d* Position tomorrow, Mr. Scott being a B&W 4
employee, so it is not any problem of availability ll) 5 of Kaye, Scholer that has not permitted Mr. Floyd 6
going on.
7 MS. WAGNER:
Is Mr. Floyd going to be 8
available at Kaye, Scholer tomorrow morning?
9 MR. SELTZER:
Yes.
10 MS. WAGNER:
I take it if I call earlier, 11 you will be available?
12 MR. SELTZER:
Yes.
13 MS. WAGNER:
I will do my best to start as 14 early as possible and to finish tomorrow.
15 (Time noted:
5:00 p.m.)
16 17 18 James R.
Floyd 19 Subscribed and sworn to before me 20 this day of 1982.
21 0
22 23 24 25
7 I
538 m
CERTIFICATE C
2 y:.
STATE OF NEW YORK
)
3'
- ss.:
COUNTY OF NEW YORK
)
4 O
I, JOSEPH R.
DANYo
, a Notary 5
Public of the State of New York, do hereby certify that the continued deposition of JAMES R.
FLOYD was taken Defore 8
l me on Thursday, April 29, 1982 consisting of pages 433 through 537 I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; I
J That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel.
18 I
IN WITNESS WHEREOF, I have hereunto set my 19 l I
i hand this day of April 1982.
l 20 '
l l
21 22 l
~3 l JOSEPH R.
DANYO O) 24.l c
25 I
i l
I i
.