ML20072H780
| ML20072H780 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/30/1982 |
| From: | Floyd J METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-04, TASK-07, TASK-1, TASK-10, TASK-2, TASK-4, TASK-7, TASK-GB NUDOCS 8306290738 | |
| Download: ML20072H780 (97) | |
Text
dab 529 UNITED STATES DISTRICT COURT
>v' SOUTHERN DISTRICT OF NEW YORK
_x GENERAL PUBLIC UTILITIES CORPORATION, :
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.,
- Defendants. :
_x Continued deposition of METROPOLITAN V
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 Friday, April 30, 1982, at 12:05 o' clock in
~
the afternoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
9 s.7 ,
O DOYLE REPORTING. INC.
T CERTIFIED STENOTYPE REPORTERS 369 LaxtNGTON AVENUt WALTER SH APIRO. C.S.R. Ntw Yong. N.Y. toot 7 CHARLES SHAPIRO, C.S.R.
TELEPNoNE 212 - 867 8220
l'J O
1 530
,r's i )
\~/ 2 App e a ra nc e s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attornoys for Plaintiffs 4 425 Park Avenue New York, New York By: MYRON KIRSCHBAUM, ESQ.,
6 of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants
, 9 One Chase Manhattan Plaza New York, New York 10 By: KAREN E. WAGNER, ESQ.
11 -and-K. ANN MCDONALD, ESQ.,
12 of Counsel l
14 LeBOEUF, LAMB, LEIBY & MacRAE, ESQS.
15 Attorneys for the Witness 1333 New Hampshire Avenue, N.W.
16 Washington, D.C. 20036 17 By: MICHAEL F. McBRIDE, ESQ.,
18 of Counsel 19 20 Also Present:
21 DEBORAH JACOBS 22 SUSAN HANSON 23 NINA RUFFINI
(~) 24 s._/ . . .
25
I 1 531
(_/ 2 JAM ES R. F LOY D, resumed, having 3 been previously duly sworn, was examined and 4 te s':ifi ed further as follows:
5 EXAMINATION (Cont'd.)
6 BY MS. WAGNER:
7 Q You understand that your testimony today 8 is still under oath?
, 9 A Yes.
10 MR. KIRSCHBAUM: Before we proceed with 11 the redirect, I would like to make a suggestion.
12 As the witness testified yesterday, he
(,_,)' 13 understood certain questions that you had asked 14 on Wednesday concerning allegations of cheating 15 against TMI-2 operators as applying to control 16 room operators, shift foremen and shift 17 supervisors, and I might suggest to you that if 18 you are interested in further information on 19 that subject, that you might want to ask the 20 witness questions concerning other TMI-2
, 21 Personnel in that regard.
22 MS. WAGNER: All right.
23 Q Did you ever cheat on a requalification
- (~N 24 exam?
( ,i 25 A No.
1 Floyd 532 7-k-) 2 Q Did you ever turn in somebcdy else's exam 3 and represent that it was your own?
4 A I handed in another men's work. I did not i
h 5 sign those papers and claim them as my'own.
6 Q Did you have an understanding that these 7 papers were understood to have been your work by the l 8 people to whom you handed them in?
, 9 MR. KIRSCHBAUM: At the time he handed them 10 in or at some later time?
11 MS. WAGNER: At any time.
12 A It was my understanding that they would be 77
(_) 13 detected as not being my work and would not be accepted 14 by the man they were handed in to.
15 Q Why did you hend in the work of another' 16 person? ,
i 17 A we had been working some' rather long'ho'rs. u 18 My priorities dictated that I devote my time to the 19 operation of the plan, the stabiliza. tion of the plant, 20 the understanding of the accident, and I gave the 21 completion of that exam a very low p$1oritz until I 9 1 22 was up against a time clock when'it had to be banded -
l 23 in that day, and so that evening , - I wa's writind out
- /
(~') 24 the answers to'this exam, ,and'I could see where it was G -
_; , i, 25 going to take much more of the~ night that I had initially a
1 Floyd $33 73 6 i planned on, and I tras leaving on vacation in the
\J 2 morning and it var the firrt vacation I had had since 3
the accident. I was tired, uptight, so I asked another 4
man to fill out some questions for me, some answers.
He did not know that I was going to hand in his work.
6 He may not have even known it was an exam question he 7
was filling out. He was a subordinate of mine. He 8
was on company time. He responded to my request.
. 9 I then took his papers and at least in one 10 section as I recall, some of the questions were -- some 11 of the answers were in my hand and some were in his 12
,_ hand. I write almost intelligibly. He writes is ,) 13 rather neatly. It would be obvious to the man 14 receiving this paper that there was not consistency.
15 The reason I did it was I was pressed for 16 time and I wanted to go on vacation and I made an error 17 in judgment.
18 Q Was it your understanding .00 turning in 19 the work of another person would be a fulfillment of the 20 training requirement that was being met by this examination.
22 A No. I fully expected I would have to 23 l requalify on those sections.
1
(~N x ,/
24 Q Is it correct that in 1977, you on a 25 cross-licensing exam scored less than 80 pe rcent on
1 Floyd 534 O 2 two sections of the exam and so were required by the I
3 FSAR to take additional training under the FSR j 4 program?
lh 5 A I do not recall that happening, but I know i 6 it happened many times. I just don't recall that 7 specific instance.
8 Q You do recall at one time or another being
, 9 assigned to participate in the FSR program?
10 A Yes.
11 Q Did you understand that the requirement 12 that you attend the FSR program came from the
) 13 obligations of Metropolitan Edison which were 14 delineated in the FSAR?
15 A Yes.
16 Q, Is it correct that you did not comply with l'T the requirement that you attend the FSR program?
18 MR. KIRSCHBAUM: On what occasion are we 19 talking about?
20 MS. WAGNER: On all such occasions prior 21 to the accident.
l.
22 MR. KIRSCHBAUM: You are asking if he ever 23 attended the FSR program?
- p. 24 MS. WAGNER: I am asking if he ever d
25 completed the FSR requirement that was imposed
1 Floyd 535 q
2 on him. i 3 MR. KIRSCHBAUM: For a particular year?
4 MS. WAGNER: For any year between 1977 and h 5 1979 before the accident.
6 A My memory is not accurate enough to be 7 very responsive to your question, but I remember that I 8 did sufficient amount of work to maintain my license.
9 If that encompasses your question, then to the best of 10 my ability I have responded.
11 Q Do you recall in March 1978 being assigned 12 to four sections of the FSR training cycle because of
( 13 having a grade of less than 80 percent on four sections 14 of a cross-licensing exam?
15 A I do not specifically recall that, but, 16 again, I could believe that it happened.
17 Q Is it correct that you attended very few 18 FSR sections in 19787 19 MR. KIRSCHBAUM: What do you mean by "very 20 few"?
21 MS. WAGNER: Fewer than was mandated by the 22 FSR requirement.
23 A I don't recall that specifically.
24 Q Do you recall that you met whatever FSR d(~T 25 requirement was imposed upon you in 19787
I 1 Floyd 53 6 2 A I don't recall specifically. I merely 3 recall that I did r.ufficient work to keep my license i
4 current. I am already on the record here as putting '
ll h 5 a low priority on my personal training and I think 6 this reflects it very well.
7 Q Did you understand that it was a violation 8 of the obligations of your license to fail to participate 9 in the training you were required to participate in?
10 A I did not know that then and I do not know 11 that now. I should think if I were violating our 12 license, I wouldn't be recertified.
() 13 Q Is it correct that after you submitted 14 the work of another person, that you were suspended 15 from work for a week?
16 A, Not in the traditional sense of suspension 17 from work without pay. I was merely put into the 18 requalification program for a week or two, I don't 19 remember which, and that was normal in my mode of 20 training to pass what I could, sight unseen,and then 21 take a week or two of training to pass the rest of it.
22 The end result was I spent one or two weeks 23 a year in training instead of six or eight.
24 Whose work was it that you handed in?
O 4 +
25 Q
MR. McBRIDE: I object to that for a reason 1
1 I
l L .
l*
1 Floyd 537
( )
'~#
2 that may not be immediately apparent to you.
3 There is an outstanding order in the Nuclear 4 Regulatory Commission Licensing Board put out 1h 5 by the Appeal Board of the Nuclear Regulatory 6 Commission that the identity of that individual 7 and certain other individuals not be disclosed, 8 and I therefore have to instruct the witness
. 9 not to answer the question.
10 MS. WAGNER: Do you have a copy of the 11 order with you?
.12 MR. McBRIDE: This is an order of the
/"X 6 4 k/ 13 Atomic Safety and Licensing Board cf the Nuclear 14 Regulatory Commission in Docket No. 50-289 in the 15 matter of Metropolitan Edison Company, Three 16 Mile Island, Nuclear Station Unit 1, dated 17 November 17, 1981, signed by Ivan W. Smith, 18 Administrative Law Judge, Chairman of the Board, 19 approving a stipulation entered into by the 20 parties, including me on behalf of Mr. Floyd 21 and one of the other individuals, and the 22 stipulation so provides for confidentiality of 23 the witnesses.
(.
l ) 24 MS. WAGNER: Do you have a copy of the v
25 stipulation?
l 1 Floyd 538 O 2 MR. McBRIDE: Yes. I have a copy of the 3 stipulation carrying a cover sheet order signed 4 by Gary L. Milhollin, Administrative Judge and dh 5 Special Master, the Atomic Safety and Licensing 6 Board, Docket No. 50-289, the same matter as 7 before.
8 The stipulation was approved by signature
, 9 of Judge Milhollin on November 12, 1981.
10 MS. WAGNER: I would like to have both of 11 these, marked as B&W Exhibits 642 and 643, 12 (Stipulation carrying cover sheet order O)
(_ 13 signed by Gary L. Milnollin, Administrative Judge 14 and Special Master, the Atomic Safety and 15 Licensing Board, Docket No. 50-289, approved on 16 November 12, 1981 marked B&W Exhibit No. 642 17 for identification, as of this date.)
18 (Order dated November 17, 1981 of the 19 Atomic Safety and Licensing Board.of the Nuclear 20 Regulatory Commission, Docket No. 50-289, in the 21 matter of Metropolitan Edison Company, Three 9 22 Mile Island, Nuclear Station Unit 1 signed by 23 Ivan W. Smith, Administrative Law Judge and 24 Chairman of the Board marked B&W Exhibit No. 643 25 for identification, as of this date.)
1 Floyd 539 O' 2 MS. WAGNER: I understand you are 3 representing that your signature on the stipulation ,
4 which is B&W 642, was given in representation of, llh 5 among others, Mr. Floyd?
6 MR. McBRIDE: Let me clarify that technically 7 that is not my signature. It was signed for me 8 by Ernest L. Blake, Esq., counsel for Metropolitan 9 Edison Company in that proceeding, because of a 10 change in the typing of the stipulation after I l
11 had left Harrisburg, but it was signed for me f
12 on my behalf. I signed on behalf of Mr. Floyd
() 13 and an individual who is designated in that 14 proceeding as Mr. O.
15 MS. WAGNER: You are representing both 16 Mz. Floyd and Mr. O in that proceeding?
17 MR. McBRIDE: Yes.
18 Q Can you tell me by any designation other 19 than his name who was the person whose work you handed 20 in?
21 A Mr. o.
22 Q Can you tell me what Mr. O's position was 23 at the time that this occurred?
(~N i
24 MR. McBRIDE: The witness may be unsure 25 of the technicalities of the stipulation, so if
l 1 Floyd 540
> ("~\
(_) 2 you will, let me just give you the answer.
3 Mr. O was a shift supervisor and that is a 4 matter of public record, the shift supervisor I
1h 5l in Unit 1. You may recall in response to a 6 question of yours on Wednesday that Mr. Floyd l
7 responded as to a question about allegations of 8 cheating, that there were two shift supervisors 9 in Unit 1 that were responsive to your question.
10 This is one of those two individuals.
11 Q I take it, Mr. Floyd, you don't disagree 12 with anything your counsel said?
() 13 A Not yet.
14 Q Is it correct that Mr. O is no longer at 15 Metropolitan Edison?
16 A. The answer is Mr. O is no longer in the 17 employ of Metropolitan Edison.
18 Q Is it correct Mr. O was terminated by 19 Metropolitan Edison for cheating?
20 A I believe Mr. O resigned.
21 Q Was he asked to resign?
22 A I don't know.
23 Q Were you aware that the work of Mr. O was 1
24 submitted to the NRC as having been your work? i C).
25 MR. KIRSCHBAUM: Objection. I believe
--)
I L
1 Floyd 541 2 the witness has testified that he didn't
, und.rstane that at th. time he .as involved in 4 handing in that exam.
jll 5 .
MS. WAGNER: I thought he testified he 6 did not turn it in as his work.
7 MR. KIRSCHBAUM: Are you asking him as to i
8 what he understood somebody else understood?
i
,, 9 MS. WAGNER: I am asking whether he knew 10 that work was later turned in to the NRC by 31 someone other than Mr. Floyd.
12 MR. McBRIDE: This is the work that was 13 the subject of your earlier questions of today 14 in 1979, is that correct?
1 a
15 MS. WAGNER: Yes.
16 A. It is my understanding that my week or 17 two in training is what qualified me for recertification, 18 not the previously submitted work of someone else.
39 Q Do you know if anybody told the NRC that you 20 had submitted work of somebody else in complying with 21 a requalification requirement?
22 MR. McBRIDE: At any time or in 19797 23 MS. WAGNER: At any time since it happened.
c f-' 24 A I have no firsthand knowledge of such an l
'25 event taking place. l l
. l
1 Floyd 542
, s 2 Q Have you heard from anybody else that such 3 an event took place?
4 MR. KIRSCHBAUM: When?
h 5 MS. WAGNER: At any time.
6 MR. KIRSCHBAUM: Has he heard at any time?
7 MS. WAGNER: Yes.
8 Q Other than if your counsel told you that,
, 9 A It is my impression that Mr. Arnold called 10 this event to the NRC's attention at-the time the 11 " cheating scandal" was first being uncovered on.Three 12 Mile Island.
13 Q Can you tell me when that was?
14 A It was in the spring or early summer of 15 '81.
16 Q. Are you saying that at that time Mr. Arnold 17 told the NRC that you had previously submitted the work 18 of somebody else in complying with the requalification 19 requirement?
20 A I am not clear as to what Mr. Arnold said 21 to the NRC. I am only aware that because the other 22 person was involved in the Unit 1 episode, Mr. Arnold 23 remembered he was also involved in this episode, and he 24 called it to the NRC's attention ap probably within 25 the scope of their investigation.
l 1 Floyd 543 i s
\/ 2 Q At any time prior to the time that you 3 testified about, did you ever turn in somebody else's I 4 work and represent that it was your own?
5 A No.
6 Q Did you ever turn in somebody else's work 7 in fulfillment of a licensing requirement?
8 A No.
. 9 Q And it is your testimony that you did not 10 consider the turning in of Mr. O's work to be cheating?
11 A That is true, because I had helped design 12 the system's checks and balances internal in te Met Ed
,m,
(_) 13 organization, so that I was aware that this would not 14 go unnoticed and be accepted. In fact, that is the 15 way the system worked.
16 Q. Was any disciplinary action taken against 17 you by the company for this action?
18 A I was relieved of licensed responsibility 19 permanently.
20 Q Is it correct that before the Three Mile 21 Island accident, you did not have re3pect for the 22 training program at Metropolitan Edison Company?
23 MR. KIRSCHBAUM: What do you mean by not
'~'
24 have any respect for?
('v}
25 MS. WAGNER: I think the witness probably
i 1 Floyd 544 O
k_) 2 knows what it means to have respect for something 3 or not.
4 MR. KIRSCHBAUM: You mean in his mind have dlh 5 respect for? Are you asking about his actions 6 or state of mind?
7 MS. WAGNER: I am asking if he respected 8 the Met Ed training program.
9 MR. KIRSCHBAUM: I object.
10 MR. McBRIDE: I would like to have it 11 clarified. I am not sure whether you are asking 12 whether he had respect for the program per se
() 13 or whether he had respect for the program 14 insofar as it applied to his subordinates or 15 as it applied to him.
16 ,
MS, WAGNER: I am asking if he had respect 17 for it in general.
18 A Was this limited to the time before the 19 accident?
20 Q Yes. Is it correct that you did not prior 21 to the Three Mile Island accident have respect for the 9 22 Metropolitan Edison training program?
23 A No. I had respect for the Metropolitan 24 Edison training program as it applied to my operators, 25 and I felt responsible for my own training.
1 l
1 1
1 Floyd 545
() 2 Q You do not feel that the Met Ed training 3 department was responsible for your training, is 4 that what you are saying?
5 A True. ,
6 MR. KIRSCHBAUM: Could I have the last 7 question and answer read back.
8 (Record was read back.)
9 (Discussion off the record between the 10 witness and his counsel.)
11 MR. KIRSCHBAUM: I believe the witness would 12 like to make a further statement in answer to n
13 that question.
(]
14 MS. WAGNER: After consultation with hic 15 counsel.
16 A. Technically, the training department may 17 have had that responsibility. The fact that I assumed 18 responsibility for my own training with the aid of 19 the training department, I would frequently rely on 20 them to help me with my training, but it was a personal 21 assumption on my part to be responsible for my own 22 training.
23 Q Did you understan .he requalification (S ! 24 program which was set forth in cropolitan Edison t
V 25 FSAR was intended to implement the requirements of
i l
1 Floyd 546 l
2 10 CFR Part 507 3 A Yes.
4 Q And 10 CFR 55, Appendix A?
h 5 A Yes.
6 Q Did you understand that compliance with 7 the requirement set forth in the FSAR was voluntary 8 on your part?
9 A No.
10 Q I would like to show you what has been 11 marked as B&W 260 which is the training section of the 12 TMI-2 FSAR, and I refer you to page 13.2-6 of the FSAR
( 13 and in particular to a sentence which indicates "The 14 basis of the requalification program is the need to 15 maintain operator competency and proficiency in the 16 quest for continued safe operation."
17 Do you see that sentence?
18 A Yes.
19 Q Was 'it your understanding that you were 20 better able to achieve those goals by your own training 21 approach than by attending the training required by 22 the FSAR?
23 , MR. KIRSCHBAUM: Are you asking whether he 24 was better able to achieve those goals for himself 25 in terms of his own training?
l 1 Floyd 547 A
- 2 MS. WAGNER: Yes.
3 MR. KIRSCHBAUM: You are asking for his 4 understanding as of some previous time?
( 5 MS. WAGNER: Yes. At the time before the 6 accident.
7 MR. KIRSCHBAUM: In general up to the time 8 of the accident?
, 9 MS. WAGNER: Yes.
10 (The record was read back as follows:
11 " Question: Was it your understanding that you 12 were better able to achieve those goals by your
( 13 own training approach than by attending the 14 training required by the FSAR7")
15 A I relied on the training department to 16 mai.,tain the records that had to be maintained legally 17 to support my recertification. I relied on them to 18 provide me information that I needed to make my 19 knowledge complete.
20 I don't think I ever characterized my 21 training versus their training.
22 Q Did you think the instructors in the 23 training program prior to the Three Mile Island 24 accident were as competent engineers as you are and
.O 25 were before the accident?
I I Floyd 548
/m i l
\/ 2 MR. KIRSCHBAUM: Are you asking about all 3 the training instructors as a group compared to 4 Mr. Floyd in any and all fields of engineering?
h 5 MS. WAGNER: You asked Mr. Floyd a lot of 6 questions yesterday about his own competency, and 7 I think we have established Mr. Floyd was an 8 extraordinarily competent operator and engineer.
, 9 MR. KIRSCHBAUM: I agree.
10 MS. WAGNER: I would like to know if he 11 thinks the training, the individuals that 12 administered training to Metropolitan Edison f')
(_) 13 licensed operators were as competent as he in 14 those fields.
15 MR. KIRSCHBAUM: As a group as applied to 16 any and all fields?
17 MS. WAGNER: As a group and as applied 18 specifically to operating nuclear plants and 19 engineering involved in the operations of the 20 nuclear plant.
21 MR. KIRSCHBAUM: I object to the question 22 on the grounds that it is compounded several 23 times over.
'^
24 j ) Q I:will.ask first if he thinks these people a
25 in the training department who trained the TMI licensed
I 1 Floyd 549
\- 2 engineers were as competent as you in engineering?
3 MR. KIRSCHBAUM: Objection.
4 A The mhjority of the instructors for the 5 requalification program at TMI were reactor operators 6 as opposed to engineers. While they were quite 7 competent to teach reactor operators and senior 8 reactor operators, they did not have engineering
, 9 backgrounds and degrees, and in most cases, I would 10 think they had less nuclear training than I had had.
11 Q Is that one reason why you chose to rely
,12 on your own approach to training rather than to rely
('N t s
\/ 13 on the training department?
14 MR. KIRSCHBAUM: You are referring 15 specifically now to the witness' statement that 16 they had less nuclear training than he had?
17 MS. WAGNER: Yes.
18 A I had been an instructor in the naval 19 nuclear program. I have been active in instructing 20 all the time I have been in the nuclear power industry.
21 I felt I was perfectly capable of maintaining my own 22 level of requalification, s
23 Q Was it yo0r understanding before the
, 1 24 accident that the level of requalification training
[a')
25 which was being administered to licensed operators at l
1 Floyd 550 4
b 2 TMI-2 was at a lower level than that you administered I
l 3 to yourself in terms of engineering?
4 MR. KIRSCHBAUM: Objection. I am not sure l 1 l 5 I understand what you mean by " lower level."
6 MS. WAGNER: Could I have the witness' last 1
7 answer read back.
8 (Record was read back.)
, 9 Q Did you think that the level of 10 requalification being maintained for nuclear operators 11 at TMI-2 prior to the accident was the same as your l
12 level or different?
13 MR. KIRSCHBAUM: I am confused here about 14 the use of the term "requalification level."
15 I am fully aware that the witness used that 3
16 phrase in his answer. I am not exactly sure i
17 that it is clear on the record that that is 18 referring to some level of competency or referring 19 to some, legally mandated level.
i 20 MS. WAGNER: Let's ask the witness what
- 21 he meant by it.
22 MR. XIRSCHBAUM: Fine.
23 A I would say that both the level of 24 requalification as taught to the control room operators 25 and senior operators by the training department and my
1.
1 Floyd 551 fn,
) 2 own level of requalification which I maintained were 3 adequate.
4 Q Would you say they were different?
h 5 A The levels were both adequate, but I 6 tended to think about problems differently than the 7 Operators tended to think about them, and that 8 difference in thinking would tend to make the 9 requalifications different, even though they were 10 both approaching a level of adequacy.
11 MR. KIRSCHBAUM: I still don't think it 12 is clear on the record what the witness means by
[v ') 13 requalification level.
14 off the record.
15 (Discussion off the record.)
16 Q, Did you ever discuss with the training 17 instructors at TMI-2 prior to the accident your own 18 different approach in terms of thinking about 19 requalification?
20 A No.
21 Q Did you think your approach was a useful 22 approach?
23 A For me, it was.
7- 24 Q Did you think it would be useful for anybody i )
\_/
25 else?
l 1 Floyd 552
() 2 MR. KIRSCHBAUM: Are you asking whether he 3 thought about this prior to the accident?
4 MS. WAGNER: Yes.
h 5 A No.
6 Q Given the fact that both you and the 7 operators at that point were required as I understand 8 it to be licensed and to therefore undergo a 9 requalification training session program, can you tell 10 me why it was that you did not think your approach to 11 it would be useful to the operators who were undergoing 12 the same requalification?
13 A My --
14 MR. KIRSCHBAUM: Objection. I believe the 15 witness said he didn't think about that issue at 16 all.
17 MS, WAGNER: I understood him'to say that 18 he didn't think it would be useful.
19 Q But please clarify your answer.
20 A I thought I was responding as Mr. Kirschbaum 21 expressed it that I hadn't thought about the 9 22 differentiation.
2G Q You had not thought prior to the accident 24 one way or another whether it would be useful to
[)
v 25 disclose to TMI training instructors or li[ensed
1 1 Floyd 5 53
( 2 operators your thought processes with respect to 3 requalification training?
4 A That is true.
(jll 5 Q Did you think the operators at Three Mile 6 Island prior to the accident would be incapable of 7 understanding your approach?
8 MR. KIRSCHBAUM: Did he think this at that 9 time before the accident?
10 MS. WAGNER: Yes.
11 A Before the accident at Three Mile Island, 12 I did not try in any way to analyze how I trained
}, 13 myself, and if I used that parallel technique on the 14 operators, how it would impact on them.
15 Q Did anyone from the training department 16 at Three Mile Island prior to the accident ever ask 17 you why you weren't attsnding training programs?
18 A Not that I specifically recall.
19 Q I believe you testified yesterday in i
20 response to your counsel's question that the training 21 instructors at Metropolitan Edison received their 9 22 training in a 1969 course offered by B&W concerning 23 pressurized water reactor technology, as I recall.
_ 24 MR. KIRSCHBAUM: I believe that testimony V
25 was with respect to the first group of TMI
.i
- _ , . __ - , . ~
1 Floyd 554
, ~ .
() 2 instructors.
3 MS. WAGNER: I believe that is right.
4 Q Is it your testimony that you are aware of tll 5 no other source of training for Metropolitan Edison 6 instructors?
7 MR. KIRSCHBAUM: That first group of 8 instructors?
9 MS. WAGNER: That first group.
10 A I do not remember specifically by name 11 who that first group of instructors were, but at that l
12 point in time, I would have known who they were and
()
V 13 what their educational backgrounds were, and I would 14 think that they had received training at facilities 15 other than B&W in tddition to the training at B&W.
16 Q You also testified that Met Ed used 17 terminology, ideas, concepts and theories which were 18 obtained from B&W in 1969 in that course as the basis 19 for all of Met Ed's training programs.
20 Is it your testimony that there was no 21 other source of which you are aware for anything being 9 22 taught by the Metropolitan Edison training department 23 between 1969 and 19797
,. 24 MR. KIRSCHBAUM: Are you asking now for his N '~/
25 present understanding or recollection of what was
l 1 Floyd 555 2 used in those courses?
3 MS. WAGNER: Yes.
4 A I don't think I testified to that yesterday, jlg 5 and I certainly wouldn't testify that way today. In 6 the B&W scope of supply, the B&W information was very 7 helpful, but we also trained on the turbines and things 1
i I 8 that weren't in the B&W scope of supply, so we had to 0 use other reference material as well.
i 10 Q Is it your testimony that for items within l
l 11 the.B&W scope of supply, the only source of training 12 terminology, ideas, concepts and theories was this
( 13 training course in 19697 14 MR. KIRSCHBAUM: Objection. That is a 15 compound question.
16 Q. You can answer.
17 A No, B&W's information was not the only one.
18 One good example, of course, would be the area of reactor 19 theory which is well within the.B&W scope of supply I 20 but which there are many valid textbooks on the market 21 which also teach concepts, theories and ideas, and 9 22 they may or may not have been used.
23 And the other problem I had with your
~T 24 question is in tying this question to 1979. There were (d 25 undoubtedly instructors in 1975 until 1979 that were
l 1 Floyd 556 r~N
(
~~/
) 2 not in the first B&W technology course but have since 3 had probably similar training, so I can't tie all the 4 instructors back to that first technology course.
jl} 5 Q You believe that there were instructors 6 who were hired sometime after 1969 in the Metropolitan I
I 7 Edison training department?
1 8 A There were people who moved out of the 9 operations department that were licensed control room 1
10 operators or senior reactor operators that were 11 transferred to the training department to become 12 instructors, and these may have joined the company (a'; 13 any point in time. Certainly we didn't restrict 14 instructors to the people who went through the 1969 15 technology course.
16 Q, Do you heve any knowledge of the basis of 17 training of those instructors who did not go through 18 the 1969 program?
19 MR. KIRSCHBAUM: Any and all instructors 20 who joined the company after 19697 21 MS. WAGNER: No, any and all instructors O. 22 who becams instructors after 1969.
23 MR. KIRSCHBAUM: I object on the grounds 3 24 i that it is compound.
( ) l 25 A There have been a lot of instructors in
1 Floyd . 557
() 2 that training department in those ten years, and I 3 cannot begin to identify each of those people from 4 memory, let alone their educational backgrounds from (lh 5 memory.
6 Q So I take it you are not today in a position 7 to tell me how instructors in the training department 8 at Metropolitan Edison were trained?
9 MR. KIRSCHBAUM: Objection. I think his 10 testimony is he is not in a position to tell you 11 about each and every instructor.
12 A In a general sense they went through an g~s
- i 13 NRC license exam to become licensed senior operators, w) 14 Each senior reactor operator training program is 15 designed for the individual. You take the man and 16 wherever you find him, you design a training course to 17 bring his level of understanding to the requirements 18 of the law, so each man would have his own individual 19 training course.
20 Q And that training course was conducted by 91 Metropolitan Edison?
22 A They may have used contractors or 23 subcontractors in addition to their own instructors
,y 24 and engineers.
l l,i 25 Q But it was your understanding that the l
1 Floyd 558
() 2 individual licensed course was set up and designed by 3 Metropolitan Edison, is that right?
4 A Yes.
jll 5. Q You testified yesterday that you believed 6 that the most important training for Metropolitan 7 Edison operators on transients was simulator training.
8 I take it you believed that before the accident?
9 A Yes.
10 Q Given that belief, what steps did you 11 take, if any, to change the decision to send operators l
12 to the simulator only once every two years rather than once every year?
( 13 14 A I do not recall.
15 Q Do you recall being upset about that 16 decision?
17 A Only insofar as I thought there was a better 18 way.
19 g War there any training which was implemented .
1 20 at Metropolitan Edison after that decision was made to 21 send operators once every two years whichwas intended to 9 22 take the place of the transient training which had been 23 prior to that time obtained at the simulator?
24 ! MR. KIRSCHBAUM: Intended by whom?
25 MS. WAGNER: Metropolitan Edison Company.
1 1 Floyd 559 s
2 A Not that I can specifically recall. i 3 Q Are you aware that of the four operators 4 on duty on March 28, 1979, three had not been to the llh 5 simulator for almost two years?
6 MR. KIRSCHBAUM: You are asking for his i
7 Present awareness?
8 MS. WAGNER: Yes.
9 A I don't recall that.
10' Q Do you recall whether before the accident 11 you were concerned about the amount or the quality of 12 training operators were receiving in responding to 13 transients? . . .
14 A I don ' t recall that specifically.
15 Q Do you recall generally?
16 A. No.
17 Q So even though you believed before the 18 accident the simulator was the most important place 19 to train operators about transients, you don't recall 20 having any concern or taking any action with respect 21 to the fact that operators were not going to be going 22 more than once every two years?
23 A I don't have such a recollection.
o4 (Recess taken.)
25 Q Do you recall a conversation with a
i 1 Floyd 560 O
F V 2 Mr. Don Miller on or about July 9, 1979, con erning 3 your submission of Mr. O's work as part of your 4 requalification requirement?
h 5 A No. '
i v
6 Q What was the date at which you were removeg 7 from licensed duties? '
8 A I believe it was July or August of 197.9. ,-.-'
9 Q You gave some testimony yesterday about. '
10 your understanding of what the effect was of simulator 11 training. Was it your understanding prior to the ,-
12 accident that every conceivable transient was/ going to
) 13 be shown to the TMI-2 operators on the simulator?
14 MR. KIRSCHBAUM: Conceivable to whom?
15 MS. WAGNER: Every one that could happen.
16 Every, transient in the universe of possible 17 . transient'6 whether or not ':onceivable. .-
18-A It was ay'understan' ding'that the s[mula$ci
, .. s 19 wa's 't h e r e to train the operators on wh't a was expected j
%g I had no delusions t ha, . .t.. fany ;p f u n 20 from the p1' ant.
1 i
/
were omniscient.
~
og
~
[, y, l - l' 22 Q Is it your testimony 7ther 3 hat you
. . ~ ~.
,, fj' ,
23 understood prior to the THI-2 -apcide'nt i. hat'the ,
I
.y .r '
\
, ;;,s o4
~
' operators weite net\ being shown;2 $ >, every}it'en f r *
?. * . *which sient,
~ ~
Q
, .. n 25 could possibly.< happen,to a thusle a, .r steam supply system?~;
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n
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a 1 Floyd 561 m
2 MR. KIRSCHBAUM: Even if not conceivable?
3 MS. WAGNER: Even if not conceivable on 4 the simulator.
'jll 5 A I don't think that was my understanding of 6 it at that time. In the light of your question, your 7 question would bound my thinking at that time.
8 Q Did you have any understanding prior to the
, 9 accident as to whether or not the operators were going 10 to be shown every possible transient on tha simulator?
11 Was it not your understanding that the simulator was 12 going to show them some transients and not all possible
((D ,,-
13 transients?
14 MR. KIRSCHBAUM: Are you dropping your 15 statement "whether or not conceivable? "
16 MS. WAGNER: Yes.
17 A In going to the simulator for a week, I 18 recognized that it was not possible to see all transients 19 in any one year, but over the course of years, all 20 conceivable transients would be covered.
21 Q Whether or not they were single failure 22 or multiple failure?
23 A Multiple failure does not enter into normal
(~'} 24 , operator training, sJ-25 Q And you understood that prior to the a
_ _ _ _ ~ __
1 Floyd 562
{) 2 accident?
3 A Y'8*
4 Q So your testimony is that if the operators jll 5 went to the simulator for a given number of years, 6 they would see every possible single failure transient?
7 MR. KIRSCHBAUM: By "possible," do you 8 mean. conceivable?
9 MS. WAGNER: Possible. I think the witness 10 and I understand what we are talking about.
11 MR. KIRSCHBAUM: I don't think the record 12 will reflect that understanding.
[')
v 13 A I would agree with tr.at statement if you 14 would add the two words "of significance" at the end 15 of your question. There are many possible single 16 failures.which have no bearing whatsoever on the course 17 of the transient, and it would be a waste of time to 18 spend time simulating those, but if in fact the single 19 failure had significance to the course of the 20 transient, then, yes, I would have expected over a given 21 number of years they would be seen.
9 22 Q I take it that they would be seen, these 23 transients, in the course of requalification training l l l
7 24 on the simulator?
I \
~
25 MR. KIRSCHBAUM: That his understanding was
1 Floyd 563 I 2 that they would be seeing these transients?
3 MS. WAGNER: That's right.
4 A Yes.
Do you have any understanding now as to (lll 5 Q 6 how many years it would have taken to see all of them?
7 MR. KIRSCHBAUM: How many years it would 8 have taken for one operator or for the operators 9 running the plants?
10 MS. WAGNER: One operator, 11 MR. KIRSCHBAUM: As a single individual?
12 MS. WAGNER: Yes.
() 13 Q I take it it would be more than one year?
14 A Yes, but probably not more than five years 15 where you have a week of training each year. So I am 16 talking.between one and five weeks, in that area.
17 Q For the time period in between the one and 18 the five years before the operator had seen all of these 19 transien'ts, did you have any understanding as to whether ,
20 Operators at Metropolitan Edison were being trained 21 on what to do if they saw a transient which was not 22 identical to one they had seen on the simulator?
23 A Prior to receiving his NRC license, each i
24 licensed person was required to be familiar with all l v l 25 emergency procedures. The fact that he had or had not
.7. , - + -
i 1 Floyd 564 2 seen it on the simulator reflected on his comprehension, 3 but his actions are governed by the procedures, so in 4 an attempt to be responsive to your question, I would llll 5 have to say the operators were instructed to do by 6 the procedures.
7 Q You testified yesterday that in your 8 opinion the accident which occurred at Three Mile 9 Island on March 28, 1979 was not governed by the loss 10 of reactor coolant /re a ctor coolant system pressure 11 procedure. Is it your position --
12 MR. KIRSCEBAUM: I believe what he
( 13 testified was not as to whether it was or was 14 not governed but rather that the operators 15 wouldn't be in that procedure.
16 MS. WAGNER: I think I have his testimony.
17 I believe he indicated it was whether or not the 18 procedure covered the event.
19 MR. KIRSCHBAUM: i If you have the testimony 20 and you want to refer to it, I suggest you do.
21 But if you are asking for his present testimony, 22 fine.
23 Q Is it your position that there was no 24 procedure in effect on March 28, 1979 which governed
\_/
25 the actions of the operators with respect to the
1 Floyd 565 2 transient in which they found themselves on that date?
3 MR. KIRSCHBAUM: You are asking for his 4 present understanding?
1h 5 MS. WAGNER: Yes.
6 MR. KIRSCHBAUM: I don't understand what 7 you mean by the word " governed" in the context 8 of this question.
9 MS. WAGNER: The witness testified that l 10 the operators were taught to follow procedures.
11 I am asking whether he understands now whether 12 or not there was any procedure which they should
( 13 have been following during the accident.
14 MR. KIRSCHBAUM: Based on the training they 15 received before the accident?
16 MS. WAGNER: Based on anything.
17 MR. KIRSCHB UM: You are asking him now 18 sitting here in hindsight whether they should 19 have done something differently?
20 MS. WAGNER: You asked him yesterday 91 whether or not the LOCA procedure covered their 22 actions. I am asking whether any procedure 23 governed their actions.
s 24 MR. KIRSCHBAUM: I believe what I asked
%J 25 him was whether or not his understanding at the
1 Floyd 566 l
i A
'( ) 2 time of the accident was such that the operators 3 would have been trained to follow that particular l
4 procedure on that morning. I don't understand your question as asking for that same information.
llh 5 6 Q My question is given the transient which 7 occurred on that date, was there a procedure in effect 8 on that date which was intended to govern the actions 9 of the operators?
10 MR. KIRS CIIBAUM : Objection to the form.
11 A In order to be governed by an emergency 12 procedure, the operator must recognize that he is in A
13 that area. In response to Mr. Kirschbaum's question
()
14 yesterday, I was relying on the fact that the symptoms 15 in that procedure were not descriptive of what occurred 16 at the i.sland on March 28, 1979.
17 Therefore, I would not have expected the 18 operators to be in that procedure, because they didn't 19 recognige the symptoms. Had they recognized that 20 a LOCA was taking place, then that would have been the 21 proper procedure for them to be in. But it was the 22 operator recognition due to the confusion introduced 23 !
by the diametrically opposite behavior of pressurizer w 24 pressure and pressurizer level that was so different l
(V \
than their training that I would have expected them to 25 l
1 Floyd 567 2 not recognize that they were in a LOCA, and therefore 3 not be in that procedure.
4 Q So what your testimony is, if I can just hlh 5 understand it, a LOCA was occurring on that day, 6 therefore, the LOCA procedure was applic'able, but 7 since the operators didn't know it, they didn't apply
{
f 8 it? ;
9 MR. KIRSCHBAUM: Objection. That is a 10 mischaracterization of the witness' testimony 11 which was very clear as to the fact that symptoms 12 in the procedure were confusing and misleading, j 13 and that is why the operators would not have 14 recognized that they were in the procedure from 15 their training.
16 MS. WAGNER: I heard the witness' answer l 17 already. I am trying to get him to clarify it.
18 I don't think I need another bit of testimony 19 from you.
20 MR. KIRSCHBAU!!: The witness' answer was 21 perfectly clear, and your question was a 22 mischaracterization of the testimony, plain 23 and simple.
24 (Whereupon, the reporter read back the 25 record as follows: " Question: So what your
l 1 Floyd 568
/"N
(,) 2 testimony is, if I can just understand it, a 3 LOCA was occurring on that day, therefore, the 4 LOCA procedure was applicable, but since the
) 5 operators didn't know it, they didn't apply it?")
6 A I mean to imply, and I will try to state 7 clearly, that the operators' training did not apply to 8 what the plant was doing on the morning of March 28, 9 1979, and therefore they were in an unchartered region, 10 a region they had not been prepared to see, nor to 11 respond to.
12 Q Whether or not the operators had been O
() 13 trained in this regard, is it your testimony that the 14 procedure for loss of reactor coolan t/re a ctor coolant 15 system pressure is or is not applicable to the accident?
16 MR. KIRSCHBAUM: Objection; asked and 17 answered.
18 Is that in the present tense or are you 19 asking as of the date of the accident?
20 MS. WAGNER: The present tense.
21 MR. KIRSCHBAUM: The procedure as written 22 together w'ith the 50 degree subcooling instruction--
l 23 MS. WAGNER: The procedure in effect on g- 24 the day of the accident.
\
v' 25 MR. KIRSCHBAUM: You are asking the
~
l 4
1 Floyd 569 I 2 procedure in effect on the day of the accident, 3 whether or not it would apply today if the same 4 accident happened today?
MS. WAGNER: No, I am asking if the
!lh 5 6 procedure applied on that day. I am asking 7 whether the accident was one to which this 8 procedure applied, whether or not the operators 9 were trair.d about that.
10 MR. KIRSCHBAUM: Including the symptoms 11 as part of the procedure?
12 MS. WAGNER: I think my question couldn't
/"%
( ) 13 be clearer. The procedure in effect on the day
</
14 of the accident and all of its components.
15 A The symptoms that were in front of the 16 control. room operators on the morning of March 28, 1979 17 did not put them into any procedure. If we had a 18 procedure which spoke of pressurizer level going up 19 while reactor coolant system pressure went down, it 20 would have looked very much like the LOCA procedure 21 looks, but such a procedure did not exist on the morning 22 of March 28, 1979.
23 ; Q Had the operators at TMI-2 been given any g- 24 training prior to the accident with respect to how they
~
25 should govern their actions in the event of a transient,
1 Floyd 0 2 the symptoms of which did not fit precisely into any l j
3 procedure then extant? l 1
l 4 MR. KIRSCHBAUM: Any training by whom? l jll 5 MS. WAGNER: Anybody.
6 A I don't know of any training that was given 7 to the operators at TMI concerning their behavior when 8 on unchartered waters. That does not mean to imply that 9 there wasn't any training. Just that I am not aware of 10 it.
11 Q During the time before the accident and 12 while you were supervisor of operations, were you aware
() 13 that the operators had been trained in the event of a 14 transient to take the most conservative course of 15 action in responding to the transient?
16 A. Yes.
17 Q Did you understand prior to the accident 18 while you were supervisor of operations of TMI-2 that 19 the most conservative course of action in any transient 20 is to insure that the core is covered with water?
21 MR. KIRSCHBAUM: Most conservative action 1 22 as opposed to what?
l
'3 MS. WAGNER: Any other action.
f- 24 MR. KIRSCHBAUM: You are saying that the 25 most conservative action would be to insure that
1 Floyd 571
(~)N
(_ 2 the core is covered with water as opposed to 3 n t insuring that the core is covered with water?
4 MS. WAGNER: That seems to be the lll 5 implication of my question, yes.
6 A I think I am on the record with a statement 7 very similar to that.
8 Q So you agree with that concept?
9 A Yes.
10 Q Is it correct that the operators were 11 trained while you were supervisor of operations and 12 before the accident that in order to follow the most
() 13 conservative course and to insure that the core be 14 covered, the safest and most conservative thing to do 15 is to let the safety systems run and inject water into 16 the core to insure core covery?
17 MR. KIRSCHBNUM: In any and all 18 circumstances?
19 MS. WAGNER: Yes.
20 (Record was read back.)
21 MR. KIRSCHBAUM: Objection; compound, a 22 A I do not remember receiving any such l
23 training from B&W or from our own training department l
24 or from anyone else to that effect.
s_- ,
25 Q So it is your testimony that for the time i
l Floyd 2 1
) 2 you were supervisor of operations and before the TMI-2 3 accident, you did not believe the operators had been 4 trained that in the event that they were not sure of jll 5 what was happening to their system, the safest and most 6 conservative thing to do was to allow for the operation 7 of automatic safety systems which were designed to 8 insure core covery?
9 MR. KIRSCHBAUM: Do you follow that 10 question?
11 THE WITNESS: I think so.
12 MR. KIRSCHBAUM: Then answer.
[)
v 13 A I don't remember that the details of 14 Operating in unchartered waters were that explicit.
15 Q You are saying you don't recall the details 16 of the training?
17 A I didn't recall any training until you 18 pointed out a few areas here, but I certainly don't 19 recall anything being that explicit in that training.
20 Q Do you know whether during the time that 21 you were supervisor of operations for TMI-2 and before 9 22 the accident your operators had that notion in. mind?
23 Was it something they understood?
24 MR. KIRSCHBAUM: Does he know what they O 25 understood or does he know what they were told?
l l
i
I 1 Floyd 573
{)N
(_ 2 MS. WAGNER: Does he know what they 3 understood.
4 A I don't believe they understood that prior lll) 5 to the accident at Three Mile Island.
6 Q Did you have an understanding prior to 7 the Three Mile Island accident as to whether or not 8 they understood this concept?
9 MR. KIRSCHBAUM: What concept?
10 Q That the most conservative thing to do 11 if you don't know precisely what the situation your 12 system is in was to allow the automatic safety systems O)
.\s 13 to continue to put water into the core.
14 MR. KIRSCHBAUM: Under any and all 15 circumstances?
16 MS. WAGNER: Under the circumstances I 17 described.
18 MR. KIRSCHBAUM: I don't know that you have 19 specifically described the circumstances.
20 MS. WAGNER: The circumstances are those 21 in which safety systems have actuated and the 22 operators are not clear what is happening in 23 their system.
(3 24 MR. KIRSCHBAUM: No matter what else is
's.)
25 happening in the plant at the time?
l
Floyd 574 1
2 MS. WAGNER: I think my question is clear 3 enough.
4 A I don't recall that action, that recommended jll 5 action, as being an explicit part of the B&W training !
6 program nor the Metropolitan Edison training program, 7 and therefore I would think that the operators did not 8 have that concept in their mind at the time of the 9 accident.
I 10 Q Do you recall today whether you knew prior 11 to the accident whether or not the operators had that 12 in their mind? I understand you have given me today
- ( 13 what you think they had in their mind. I am wondering l
14 if you recall whether you knew before the accident what 15 they had in their mind.
16 A. I do not so recall.
17 Q Prior to the accident and while you were 18 supervisor of operations at TMI-2, did you th' ink this 19 was a concept that was important for then to know?
20 MR. KIRSCHBAUM: What is the concept again? i 1
l 21 Q The concept is that when safety systems have 9 22 actuated and the operators are not sure what is 23 happening in their system, that they should allow the 24 safety systems to continue to inject water into the 25 system to insure core covery. j l
/
1 Floyd 575
) 2 A I don't recall.
3 Q Had it occurred to you prior to the 4 accident at TMI-2 that a transient might occur which lI . 5 the operators, whoever was in the control room at that 6 point, had not seen before?
7 MR. KIRSCHBAUM: On the simulator?
8 MS. WAGNER: Any place. I am asking about 9 a transient occurring at TMI-2, not at the 10 simulator.
11 MR. KIRSCHBAUM: You are asking him if he 12 had in mind that they might see a transient that
() 13 they had not seen previously at TMI-27 14 MS. WAGNER: I am asking did he think it 15 was possible for a transient to occur at TMI-2 16 which the operators in the control room at that 17 time had not seen before.
18 MR. KIRSCHBAUM: At any place?
19 MS. WAGNER: At any place.
20 MR. KIRSCHBAUM: And yot, are asking whether 21 he recalls having that thought in mind before 9 22 the accident?
23 MS. WAGNER: That's right.
24 A My thoughts before the accident were that 25 the plant was bounded by plant procedures.
1 Floyd 576
,r 3 i j 2 Q Do you mean by that that you thought the 3 symptoms in the various plant procedures bounded every 4 conceivable event?
lh 5 A Yes.
6 Q Do you also mean that if the operators 7 followed one of those procedures, assuming it was the 8 right one for whatever event was occurring, that the 9 procedure prescribed whatever course of action would 10 keep the plant safe?
11 A Yes.
12 Q I believe you testified that one of the
()
- m. 13 symptoms in the procedure for loss of reactor co olan t/
14 reactor coolant system pressure was decreasing 15 pressurizer level, is that correct?
16 A. Yes.
17 Q I believe you also testified that you 18 understood that during some loss of coolant accidents 19 boiling could occur in the reactor coolant system, 20 is that correct?
l 21 A Yes. )
22 Q And you further testified that you knew l 23 prior to the accident that boiling in the reactor i
24 coolant system could cause a rise in pressurizer level, r') f
', J 25 is that correct?
l
1 Floyd I
)
2 MR. KIRSCHBAUM: In the event of a LOCA?
3 MS. WAGNER: My question is what it is.
4 Would you read it again and retype it Il h 5 into the record.
6 (Whereupon, the reporter read back the 7 record as follows: " Question: And you further 8 testified that you knew prior to the accident 9 that boiling in the reactor coolant system could 10 cause a rise in pressurizer level, is that 11 correct?)"
12 A I had this piece of knowledge from the uavy
() 13 days from an experiment which involved the intentional 14 reduction of thermal margin that said if we had boiling 15 in the reactor coolant system, you would see a rise 16 in pressurizer level.
) 17 That experiment did not deal with loss of 18 coolant accidents nor did it involve ruptures in tops 19 of pressurizers, but the tie between the two is not 20 quite as firm as your phrasing of the question would 21 imply.
22 Q My question was simply whether you knew 23 prior to the a'ccident that boiling in the reactor
-~s 24 coolant system would cause a rise in pressurizer level, 25 and I believe you already testified that you did.
1 l
l 1 Floyd 578
['\)
i A s._/ 2 Yes.
3 Q could you tell me what you mean when you 4 say " thermal margin"?
llh 5 A The temperature difference between the 6 pressurizer and the next hottest water in the plant.
7 (Recess taken.)
8 BY MS. WAGNER:
9 Q In your Navy experiment, how did you obtain 10 a reduction in thermal margin?
11 A By raising the T-Av and running with a 12 constant delta T across the core. The hot leg
()
(~m 13 temperature went up one degree for every degree rise in 14 T-Av, and since the hot leg water was the next hottest 15 water in the plant outside the pressurizer, the 16 reduction of thermal margin came about because the 17 pressurizer temperature stayed constant and the hot 18 leg was rising in temperature and the thermal margin 19 was thereby reduced.
20 Q You indicated yesterday that the experimental 21 procedure which governed this experiment caused the 22 operator to be alert for a pressurizer level rise which 23 would be indicative of steam formation in the reactor r- 24 coolant system other than in the prersurizer.
!u/
25 What is your understanding as to what would )
l l
1
1 Floyd 579 2 cause steam formation in the reactor coolant system 3
other than in the pressurizer?
4 MR. KIRSCHBAUM: What was his understanding at the time the experiment was being conducted?
dll 5 6 MS. WAGNER: His understanding at any time 7 before the accident.
8 MR. KIRSCHBAUM: I object insofar as there 9 is an implication in the question that his 10 understanding was the same at all times leading 11 up to the accident.
12 MS. WAGNER: I am leaving it open for the
(
O) 13 witness to correct me if it wasn't.
14 , (Record was read back.)
15 MR. KIRSCHBAUM: His understanding now?
16 MS. WAGNER: I said before the accident.
17 A While it is not the hottest temperature 18 in the reactor coolant system outside the pressurizer, 19 the hot leg tempezature was the best indicator we had 20 of that hottest temperature which would be in the hot 21 channel of the core itself. It would be a higher 22 temperature than the T hot.
I 23 Since it is an unmonitored parameter, g- 24 its absolute value is therefore calculated. If the C)/
25 temperature of the water in that hot channel exceeded l
i i
1 Floyd 580 i
[/\
\. 2 t t.e local saturation pressure in that channel, which 3 is also unmonitored, then boiling would occur and it 4 would probably have been of the nature of nucleate I 5 boiling, because of the forced flow in the system.
6 Q I take it it was your understanding prior 7 to the Three Mile Island accident that if in any region 8 of the reactor coolant system, temperature exceeded
, 9 the saturation pressure, you would end up with boiling?
10 A You left one temperature out of there. If 11 the local temperature exceeds the saturation temperature 12 corresponding to the local saturation pressure, i I'T
(_/ 13 then boiling would occur.
14 Q I take it it was also your understanding 15 prior to the accident that if in any part of the 16 reactor. coolant system water remained at a constant 17 temperature butpressure on the water was reduced, that 18 the water would boil at some stage?
19 MR. KIRSCHBAUM: That continued happening 20 indefinitely?
21 MS. WAGNER: That's right.
O A Yes.
22 23 Q -I take it you did know prior to the 24 accident that during a loss of coolant accident, t
V(')
25 pressure decreases?
l
m 1 Floyd 581
% 2 A Yes.
3 Q You testified yesterday that on the day 4 of the accident, March 28, 1979, you were in Lynchburg
]ll 5 attempting to simulate the accident on the simulator and 6 you were unable to do so.
t
, 7 MR. KIRSCHBAUM: He testified that he was i 8 in Lynchburg and he attempted to simulate the 9 accident. He didn't testify that he was in 10 Lynchburg for the purpose of attempting to 11 simulate the accident.
12 MS. WAGNER: I don't think I suggested that.
13 MR. KIRSCHBAUM: It was ambiguous in my 14 view.
15 A Can you tell me precisely what you did in 16 order to attempt the simulation?
17 A To the best of my recollection, I instructed 18 Mr. Smith to actually carry out the simulation, because 19 I was busy on other things, and my instruction to him, 20 to the best of my recollection, was to normalize the 21 simulator at a high power level such as Three Mile 22 Island was at on that morning, 97 or 98 percent of rated
~
23 power, to trip off the feed pumps, which was the 24 initiator event as far as I knew, and I didn't know that i 25 they had been tripped off simultaneously, so I asked him
1 Floyd 2 to run a parametric study based on time intervals for 3 tripping the boiler feed pumps, to first try the 4 tripping together and then to try tripping them h 5 30 seconds or a minuts or five minutes apart, and to 6 delay the emergency feedwater coming in for the area 7 of ten minutes and then to run a parametric study on 8 it in the region of five to fifteen minutes on 9 probably one-minute intervals to see if he could 10 reproduce the pressure that was experienced at the 11 plant which we knew was below the HPI set point and 12 was probably down in the region of a thousand to 13 1200 pounds.
14 Q So you yourself did not actually manipulate 15 the simulator?
16 A I may have been actively involved in the 17 first transient, and when that pressure did not come 18 down on that one to the HPI set point, I then invented 19 these parametric studies for him to carry out.
20 After the 9:30 phone call when I heard 21 that the PORV had been stuck open, I then gave him 22 instructions to let the PORV open in response to the 23 , loss of feed like it should and then to keep it open i
24 to attempt to pull plant pressure down faster.
25 I Q Did you keep any notes of what you told
g Floyd 583
(_) 2 Mr. Smith to do?
A No.
3 Q Did you keep any notes of the results of 4
what he did?
lll . 5 A No.
6 7
Q I take it you didn't keep any notes of 8 what you might have done apart from what Mr. Smith g did either?
10 A No.
31, Q Are you aware of any computer printouts or 12 other data reflecting the results of the experiments?
/"N I
q,) . 13 MR. KIRSCHBAUM: In existence today?
14 MS. WAGNER: Ever in existence.
15 A We had a small multipoint recorder operating 16 n the 855 which allowed us to track several parameters 17 of interest through the' course of each event. The 18 simulations were being run off of the console meters, I
19 but we were making a record of what was going on on 20 those meters through this multichart recorder.
21 Multipen recorder, excuee me. Those records were not 9 22 retained, to the best of my knowledge.
23 Q Are you aware of any records which were
(~) 24 retained?
\-) l 25 A No.
1 Floyd 584 g
- J
'- 2 Q of any kind, written or --
3 A I just hesitated there because I was trying 4 to remember if the B&W simulator instructors may have
.lll 5 been making notes or keeping a record of what was going 6 on, and I don't recall that any notes were retained or 7 were made by those people.
8 Q Do you remember what assumptions you made 9 l
, in running this simulation with respect to decay heat? l 1
10 A The initialization of the simulator allows l
11 for that to be programmable with the initialization, 12 and so I would have requested that it be at equilibrium
(~N
(_ 13 fission product inventory since that was most 14 representative of the core at Three Mile Island on i
l 15 that morning.
16 Q. Do you recall what, if anything, you did 17 with respect to letdown?
18 MR. KIRSCHBAUM: At any point during any 19 of the simulations?
20 MS. WAGNER: Yes.
21 A The reactor trip procedure requires that 22 the letdown be shut off, and so they, the operators, 23 would have shut off the letdown as part of the normal
[V ') 24 response to the reactor trip.
25 Q Are you saying that that is what you did at
1 Floyd 585
('h
(_) 2 the simulator?
3 A I am saying that is what I would have 4 expected the operators to do.
dh 5 Q Do you recall now whether that was part of G the simulation?
7 A I don't recall.
8 Q You testified yesterday that you did not 9 believe that plant operators could understand transient 10 analyses but thci they were interested in the outcome 11 of transient analyses, as I recall.
12 To the best of your understanding, prior O.
(_) 13 to the accident, did such a transient analysis 14 underlie the loss of reactor coolant / reactor coolant 15 pressure procedure?
16 A. Yes.
17 Q It is correct that that procedure describes 18 the automatic actuation of high pressure injection when 19 plant pressure is below 1600 psig?
20 MR. KIRSCHBAUM: You say it describes.
21 You mean does it mention that that occurs?
22 MS. WAGNER: Yes.
23 A Yes, as well as a decrease in pressurizer f^x 24 level.
(._)
25 Q Did you have an understanding prior to the
1 Floyd 586 O 2 accident as to whether or not your operators understood 3 enough of the transient analysis underlying the loss 4 of reactor coolant / reactor coolant pressure procedure dlh . 5 to understand why that automatic action occurred?
6 MR. KIRSCHBAUM: Objection because of the 7 assumption that the automatic action occurred 8 because of a transient analysis as opposed to
, 9 being set to do that.
10 MS. WAGNER: If the witness thinks that
'l that occurred in some manner that was contrary 12 to what was required by the transient analysis, 13 I guess he can tell me that.
(
14 MR. KIRSCHBAUM: I am not suggesting that.
15 A It is my belief that the operators 16 understood before the accident at Three Mile Island 17 that the hole which created the LOCA allowed system 18 pressure to decrease and that the emergency core 19 cooling system was called into play at about 1600 20 pounds in order to protect the fuel from overheating.
21 Q Is it correct that the high pressure l
22 injection was designed to actuate at TMI-2 upon a loss 23 of pressure to 1500 or below and not on a loss or a 24 gain of pressurizer level?
25 A That is true, but the operator training l
1 Floyd 587
(~)
k/ 2 was not clear on that point.
i 3 Q D you think the operators believed prior '
4 to the accident at TMI-2 that HPI was actuated based on pressurizer level?
()lh 5 6 A No. They were just taught that the symptoms 7 of a LOCA was decrease in both pressure and level, and 8 that their follow-up actions were based on pressurizer 9 level, so the controlling parameter for them, although 10 they knew the initiating event was on pressure, the 11 thing they had to take control of was based on 12 Pressurizer level.
13 Q You have testified previously in this 14 deposition that it was your understanding that if HPI 15 actuated automatically, the operators were not to 16 terminat.e HPI until LPI was actuated as described by j 17 the procedure for loss of reactor co olant/ r eactor 18 coolant system pressure, B&W 272.
19 MR. KIRSCHBAUM: Could you point out where 20 in the prior testimony that is and let the witness 21 see that?
22 MS. WAGNER: I will.
23 Q I will show you the procedure. I would
) 24 like to read into the record prior questions and answers.
s /
25 What I am going to read you are some i
j.
1 Floyd 586-1
) .," ,
( ,
'L J 2 I questions and',answars which begin at the bottom of *
, > t 3
page 279. , j,
,{ ,
' ,i 4 " Q u e s '31on: Dous Part B , and that ref,ers J
,/ ,
i
'5 to the loss of coolait procedure. ;, "abartes cir cam s t.en c e s <
69 ~ e' ~ .
- l <
,^
6 or conditions under which HPI m4.y be teYainated after it 7 has automatically actuated?
y
' " 1.n s w e r :
8 On pagetJ.0 ci;Che procedure under m
9 Step 3.5, it . gives you pcmission, to ' throttle tae'high
, t 10 pressure 1:Gecdisn f jov andTon-page 10.2, Step 3.6.3 11 reads, ' Shut off Nb umps.'"
?
/ 4 12 "Que stion : 'What conditions have to be in p '
f Y ' '
() 13 effect for Section 3.6.3 to be apN. cab *t.e? - ,,
LDI has tb be Ln service'with,a 14 "'k n swe r : j '
i ,1 ,
15 flow rate above750 gal.lons'per miaSte each! N -
16 ,
. Were you asked ,those 3nestions and did you
/ ,,
17 give those answurs? .
18 A Yes. ~ -
19
- 9. !I yould 15.ke you to show me any-place in !
20 Part '( O f the lossof'hactor co ol an t /r e a'c tor coolant.
21 .systen pressure procedure which tells the operator to 9 22 terminat'e high pressure injection based upon pressurizer 25 level. j f') 24 MR. KIRSCHBAUM: Are ycu asking him to find ,
\
%) l 2; -
those words in the procedare? ,
g.
6 C;'
, t.
'I /,
Floyd $'
, 1 2 MS. WAGNER: The words in the procedure.
,e, i 3 (Record was read back.)
4 A I would not expect to find that instruction
)lh 5 in Part B, because Part B is talking only about leaks i
6 that are greater than the capacity of the HPI system.
7 If you are going to look for that, you have
. 8 to look at Part A, which is ruptures of sizes ruch that
, 9 the HPI system can more than make up for the leaking 10 water. So in fact, that instruction does appear in
, 11 Part A, but I wouldn't even look for it in Part B.
12 Q Was it your understanding prior to the 13 accident that the operators could follow Part A of this 14 procedure after high pressure injection had automatically 4
15 actuated?
16 . MR. KIRSCHBAUM: You are assuming that the 17 operators would have been in Part A and that HPI 18 would have automatically actuated?
19 MS. WAGNER: No, I am not. I object to 20 your interjection.
21 MR. KIRSCHBAUM: Would you read back the 22 question.
23 (Record was read back.)
24 MR. KIRSCHBAUM: If you are refusing to
(
25 clarify the question as I have asked, I will
Floyd 590 5-) 2 object to the form.
3 A No.
4 Q Is it correct that you understood prior llh 5 to the accident that B&W . advised operators of its G nuclear stuam system not to opera,te the system in a 7 solid water condition if possible because of the 8 potential danger of excessive stress due to possible 9 pressure spikes?
10 MR. KIRSCHBAUM: Objection; compound.
11 A I remember the B&W instruction to be as 12 you have characterized it with the exception of the g
(_) 13 words "if possible."
14 Q So you did understand that the reason for 15 this instruction or at least one reason for it was 16 because.of the potential for pressure spikes which 17 might cause damage to the system?
18 A Yes.
19 Q Did think think that was a valid 20 instruction?
21 A Yes.
22 Q You testified yesterday, I believe, that 23 you had been told by a B&W instructor that personnel I
(~'
%.j' 24 I l
from oconee had been criticized for allowing the plant, 25 I guess the simulator, to go solid.
I 1
1
1 Floyd 591 2 Do you recall what was the condition of 3 the plant at the time the operators had allowed it i
4 to go solid?
'l h 5 A It was critical and power was being 6 increased into the power range.
7 Q Was the plant suffering a loss of coolant 8 accident?
9 A No.
10 Q You testified yesterday in response to 11 your counsel's questions that B&W taught you to use 12 pressurizer level as an indicator of reactor coolant
() 13 system inventory. ,
14 Is it correct that B&W taught you to use 15 pressurizer level as an indicator of reactor coolant 16 system 1,nventory only in conjunction with RCS 17 temperature and pressure?
18 MR. KIRSCHBAUM: Objection to the form.
19 MS. WAGNER: What is the basis of the 20 objection?
21 MR. KIRSCHBAUM: Unclear what you mean in 22 that question by "in conjunction with." Teaching 23 in conjunction with or pressurizer level in l
24 conjunction with?
25 MS. WAGNER: The pressurizer level in
1 Floyd 592 O 2 conjunction with RCS temperature and pressure.
l 3 Q Is it correct that B&W taught you that 4 when you were using pressuriser level as an indication of system inventory, you were to consider, while you dlh 5 6 considered pressurizer level, also, temperature and 7 pressure of the reactor coolant system?
8 A In a strict interpretation of the word
, 9 " inventory" which implies mass, both reactor coolant 10 system pressure and temperature would have to be 11 considered in conjunction with pressurizer level. As 12 a rough indicator of inventory, pressurizer level is 13 sufficient by itself.
14 MR. KIRSCHBAUM: The question was what 15 B&W taught you.
16 . MS. WAGNER: That's right.
17 Q I would like to clarify whether that was 18 what B&W said to you.
19 A I don't recall that B&W instructed us in 20 the simplification, but it follows logically from 21 knowing the foundation of the word " inventory" and.
22 operating a pre'ssurized water reactor.
23 Q So if I understand your testimony 24 correctly, B&W did tell you to regard three things, 25 that is, pressurizer level, KCS temperature and "CS i
1 Floyd 593 t i
'/ pressure in order to determine system inventory?
2 3 MR. KIRSCHBAUM: Objec ion.
4 Q I am just not clear on your last answer.
lh 5 That is the reason for my clarifying question.
6 A I think B&W instructed us properly in 7 how t'o arrive at an inventory. A result of that F training is a realization by the operator that 9 temperature and pressure make normally minor corrections 10 to inventory as indicated by pressurizer level, and 11 therefore it would be very natural for the op era tcc s 12 to equate pressurizer level to inventory without going
\_/ 13 through the minor adjustments necessary for pressure 14 and temperature.
15 Q Did you ever tell anyone at B&W that you 16 knew that if bulk boiling occurred in the reactor 17 coolant system, pressurizer level would rise and thus 18 could be a misleading indicator of reactor coolant 19 system inventory if taken alone? !
20 MR. KIRSCHBAUM: Objection. No foundation 21 that this witness knew that at any time during O which he spoke to anyone from B&W.
22 23 MS, WAGNER: I object strenuously to your
[T 24 objection. It is contrary to the witness'
%.)
25 testimony several times in this deposition.
1 Floyd 2 MR. KIRSCHBAUM: I don't believe it is.
3 MS. WAGNER: You can believe what you want, i
l 4 I guess his testimony is on the record.
1 llh 5 MR. KIRSCHBAUM: I guess it is. I think it 6 will speak for itself. I don't believe you should 7 he making assumptions in the question. If you 8 want to ask the witness a question based on a
, 9 piece of testimony, point to that testimony with 10 any testimony surrounding it and ask him the 11 question or just ask the question.
12 MS. WAGNER: Could we have the question 13 read back and typed in the record.
f 14 (Whereupon, the reporter read back the 15 record as follows: " Question: Did you ever tell 16 anyone at B&W that you knew that if bulk boiling 17 occurred in the reactor coolant system, 18 pressurizer level would rise and thus could be 19 a misleading indicator of reactor coolant system 20 inventory if taken alone?")
21 A I think the record is clear that I knew 22 that fact when I was in the United States Navy and it 23 never' entered my conscious mind while I was assigned ,
l 24 to TMI which is the totality of the time that I had 25 been dealing with asw. Since it was never in my
- ----------------------U
1 Floyd 595 O 2 conscious mind while assigned to TMI, I certainly 3 would think that I did not mention it to anybody at 4 B&W.
jll 5 Q You testified yesterday that between 6 September 24, 1977 and March 28, 1979, Norm Elliott 7 did not tell you anything about the event at Davis-Besse.
8 During that same time period, did Gary 9 Miller tell you what he had learned about the event 10 at Davis-Besse?
11 A I do not recall any such discussions with 12 Gary Miller.
13 Q Did Jim O'Hanlon tell you what he had learned 14 during that same time period about the event at 15 Davis-Besse?
16 A. I don't recall such conversations with 17 Mr. O'Hanlon.
18 (Recess taken.)
19 BY MS. WAGNER:
20 Q Yesterday you testified at some length 21 about how B&W draft procedures were turned into TMI 22 procedures. I believe you said, among other things, 23 that when Met Ed took the B&W draft procedures for 24 l Unit 1 and put them into the TMI format and made them 25 Plant specific, the substance of the procedure was not l
1 Floyd 596
( )
\' changed or was maintained in substance.
2 3 Do you recall generally that testimony?
4 A Yes.
(ll 5 Q I would like to show you now two documents.
6 I would like to show you first B&W 418, a document 7 entitled " Drawing Submittal Form," and behind that is 8 a preliminary draft procedure DP-5120206, " Loss of 9 Reactor Coolant /Rcactor Coolant System Pressure" for 10 Metro'politan Edison Company.
11 I also would like to show you a document 12 which has previcusly been marked as B&W Exhibit 417 n
_ 13 which is the first draft by the PORC of Unit 1 of 14 Emergency Procedure 1202-6, " Loss of RC/RCS Pressure."
15 I would like you to tell me whether you 16 believe.that these two procedures are in substance the 17 same.
18 MR. KIRSCHBAUM: Just so I understand, you 19 are asking the witness to compare them and based 20 on the comparison he is performing today to say 21 whether or not he believes they are in substance 22 the same?
23 MS. WAGNER: No, he testified yesterday (n)
\.J 24 to quite a lot of knowledge of procedures and 25 testified that based on that knowledge, he l
1 Floyd 597 c
(_,xl 2 understood they were the same, and I wanted to 3 ask him whether seeing the procedures now in 4 front of him he believes that they are consistent llh 5 with that testimony.
6 MR. KIRSCHBAUM: Did he testify concerning 7 this procedure yesterday?
8 MS. WAGNER: N3 , he testified concerning g procedures in general. I will be happy to show 10 you yesterday's testimony if you want to see it.
11 (Record was read back.)
12 MR. KIRSCHBAUM: Could you show the witness
('N x.J i
13 the testimony that you are referring to?
14 MS. WAGNER: Sure. Pages 495 and 496.
15 MR. KIRSCHBAUM: You are referring to the
- 16 94estion beginning on page 493 and the answer on 17 pages 495 and 4967 18 MS. WAGNER: I wasn't asking the witness 19 for a clarification of that. I was drawing my 20 characterization of his testimony from those 21 pages, yes. Certainly, if the witness doesn't 22 agree with that characterization, he should say 23 so.
I r^x 24 (Record was read back.)
NJ 25 A I believe my testimony yesterday was to the
1 Floyd 598 2 effect that the substance of the procedure was 3 maintained in going frem the B&W draft to the plant 4 Procedure. The first document I have in front of me, (llh 5 I believe it is 418, the B&W draft procedure, reflects 6 that after this procedure was sent to Metropolitan 7 Edison Company, it was commented on as requested by 8 B&W and some 17 out of 19 comments that were made by
, 9 the Met Ed staff were incorporated into the procedure, 10 and this carries a date of mid-1970 or it.
11 B&W Exhibit 417, which is the plant 12 Procedure, carries a date of late '73, so in this in k_) 13 Particular instance which you called to my attention, 14 well over three years passed between the time 15 of the two documents I have in front of me. I don't 16 know if.there were any subsequent iterations between 17 the two, but there was certainly a lot of knowledge 18 gained between the time of these two documents, and 19 while it is true that the B&W draft procedure starts 20 out with sections labeled " Purpose," " Description,"
21 " References," " Limits and Precautions" and " Set Points,"
9 22 none of those sections are in the format of the Met Ed 23 procedure, nor were they ever planned to be.
('
\_)
) 24 It is a section labeled No. 6 commencing 25 on page 3 of the B&W draft entitled " Procedure" that i
1 Floyd 599
\'l 2 I had reference to yesterday as the substance of the 3 Procedure and what should be preserved into our 4 document. I have not made a line-by-line comparison
)lh 5 but if you want me to, I will.
6 I would probably prefer if you wished to 7 examine that, if you asked me the questions on the 8 differences, and I can then respond if that is a 9 substantive change or not.
10 Q I would like to refer you to the third page 11 of Exhibit 418 which is the page on which the first 12 page of the preliminary draft procedure appears.
m.
N._) 13 Under the section entitled " Description,"
14 there is a sentence which indicates, "However, the 15 Operator should assume the cause of the sympcoms 16 described above is a system rupture or leak, unless 17 another causa can immediately be established."
18 I would like to ask you whether or not that 19 Part of the procedure, that idea,.was maintained in the 20 Met Ed draft which is B&W 417?
21 MR. KIRSCHBAUM: You are asking him for 22 his present understanding based on a reading 23 now of these two documents?
l'D
%-)
24 MS. WAGNER: Present understanding if he l
25 has a recollection. Certainly, any knowlege he l
1 Floyd 600 7~
L-) 2 has now.
3 A I do not find that thought carried forward.
4 Q You testified yesterday that prior to the
)lh 5 accident at TMI-2, it was your understanding that there 6 was a leak in one or both of the code safety valves 7 which was causing the P O R*J discharge line to register e
8 a higher than normal temperature.
9 How did you know that it was a code safety 10 and not the PORV that was leaking?
11 MR. K I R S C H B1. J M : Asked and answered.
12 A The highest of the three temperatures would C)\
(_ 13 be indicative of the leaking valve. If two of them 14 were at the same temperature, then you could have two i
15 leaking valves, but since they have a common tailpipe 16 and hence a common back pressure, the temperature 17 exiting the valve will be the same for more than one 18 leaking valve, and the highest temperature would be 19 the indicator of the leaking valve.
20 MS. WAGNER: I would like to have marked 21 as B&W Exhibit 644, a series of four pages, each 22 of which is entitled " Unit 1, Unit 2"and appears 23 to be some type of periodic reporting document.
f~D 24 (Series of four pages, each entitled LJ 25 " Unit 1, Unit 2" marked B&W Exhibit No. 644 for
1 Floyd 601 1
2 identification, as of this date.)
3 Q Have you ever seen the documents which are 4 marked as B&W 644 before?
1h 5 A I am familiar with the form. I have no 6 recollection of seeing these particular forms.
1 1
7 Q When you were supervisor of operations l 8 for Unit 2, would you in the normal course of your l g business see these type of forms?
10 A They were filled out daily by the shift 11 supervisors and sent to Reading as a status report.
12 I am copied on them, and so I would have expected to 13 see them on a daily basis.
14 Q The'four pages which we have marked 15 are dated respectively March 27, 1979, March 25, 1979 16 March 24, 1979 and March 23, 1979. Each of them 17 indicates, among other things, under the Unit 2 18 section, temperatures for RCV-1A, RCV-1B, RCRV-2.
19 Do you know what RCRV-2 is?
20 A The power operated relief valve.
21 Q On Unit 27 22 A Yes.
23 Q The documents indicate, I believe, in each i
[') 24 case that the temperature for RCRV-2 was in excess of l
V 25 130 degrees. Is that correct?
602 1 Floyd
(-) 2 A Yes.
3 Q Is it your testimony that because that 4 temperature in excess of 130 degrees was you believe attributable to an open or leaking code safety rather llll 5 6 than a leaking PORV, that the requirements of the 7 pressurizer system failure procedure, EP 2202-1.5, did 8 not apply?
9 A That is true.
10 Q I show you th'e procedure. Was it one of 11 the purposes of the pressurizer system failure procedure, 12 as you understood it prior to the accident, to aseist (G_) 13 the operators in diagnosis of a leaking or failed open 14 PORV?
15 A Yes.
16 Q. Is it correct that it was your understanding 17 prior to the accident that that symptom,which is relief 18 valve discharge line temperature exceeding the normal 19 130 degree Fahrenheit, was thus always present but not 20 attributable to a leaking PORV?
21 MR. KIRSCHBAUM: Always present when?
22 MS. WAGNER: In the few days before the 1 1
1 23 accident.
l
! i 24 I MR. KIRSCHBAUM: On the days reflected in (V]
25 these sheets?
l
1 Floyd 600
,3 I
\_-] 2 MS. WAGNER: Yes.
3 A With the information that you present me 4 on the daily status sheets, I would feel perfectly jll 5 free to authorize a TCN to be written to the emergency 6 procedure to remove that symptom, and the reason for 7 that TCN would be that RCRV-1B was the leaking valve.
8 Q Did you execute such a TCN?
9 A Not to my knowledge.
10 Q In the absence of such a TCN, were the 11 operators to regard the temperature of the PORV discharge 12 line wh'-h was in excess of 130 degrees Fahrenheit as O)
(_ 13 a symptom of an open PORV or leaking PORV?
14 A Negative.
15 -
MR. KIRSCHBAUM: Was your question intended 16 to. deal with the circumstances reflected in these 17 status sheets?
18 MS. WAGNER: It was intended to reflect 19 the circumstance which was present during the 20 time period before the accident about which 21 Mr. Floyd has testified oreviously.
22 Q Did it occur to you prior to the accident 23 during the time period when the discharge line from the
(~)
24 PORV was in excess of 130 degrees Fahrenheit that the G'
25 operators could be confused because of the apparent l
l
? l I
1 Floyd 604
(_/' 2 symptom of an open or leaking PORV which was not to be 3
regarded as such?
4 MR. KIRSCHBAUM: Objection to the form. No 5 foundation.
6 A No.
7 Q No, it did not occur to you?
8 A It did not occur to me.
9 Q Looking at the pressurizer system failure 10 Procedure, B&W 305, does the procedure indicated under 11 the section entitled " Symptoms" indicate any time 12 Period during which the discharge line temperature fq,j 13 must exceed the normal temperature before it should 14 be considered a symptom?
15 A No.
16 Q. You testified yesterday that you believed 17 Prior to the accident that the operators at TMI-2 were 18 able to identify or diagnose a failed open PORV 19 provided the PORV failure was an isolated failure or l 20 words to that effect.
21 Do you recall that?
22 A Yes.
23 MR. KIRSCHBAUM: I think you might want I
(~
') 24 I
to refer to that testimony. I am not sure that
..)
25 reflects it properly.
1 Floyd 605 C')
- d 2 MS. WAGNER: Rather than actually looking 3 back --
4 Q Did you understand that your operators could
'llh 5 identify an open PORV, failed open PORV, prior to the 6 accident?
7 A When PORV failure was in isolation, yes.
8 Q Was it your understanding prior to the 9 accident that the operators at TMI-2 would only be able 10 to diagnose a failed open PORV if it were to occur in 11 isolation?
12 A No.
g
. (.) 13 Q Did you'believe your operators would not be 14 able to diagnose a failed open PORV if, in conjunction 15 with a failed open PORV, the system the/ were operating 16 suffered a total loss of all main and emergency 17 feedwater?
18 MR. KIRSCHBAUM: Are you asking if he 19 thought about this before the accident?
20 MS. WAGNER: That is my first question.
21 A Before the accident, I felt comfortable 22 that my operators were properly trained, and that !
t l
l 23 includds responding to a transient with a single failure 24 which is what you are proposing in this specific case j f'J')
A- l 25 here. l l
l l l
l
1 Floyd 606 k) 2 So in the general sense that I thought 3 they were properly trained, yes, I would give them 4 credit for that specific instance.
jll 5 Q Are you saying you would expect them to f
6 diagnose an open PORV in conjunction with a total loss )
7 of feedwater or you wouldn't have expected that before 8 the accident?
9 I don't understand your answer. !
1 10 A I would have expected them to diagnose it 11 properly.
12 Q You testified yesterday that for reasons (8 ) 13 based upon your work with a radiation monitor at TMI-1
(
v 14 in 1973, I believe you said, and because of the 15 calculations you performed at that' time, you understood 16 when you heard the readings from HPR-227 on the day l 17 of the accident that some portion of the cladding had 18 failed at TMI-2.
l
- l 19 Is that correct?
20 MR. KIRSCHBAUM: Is that correct that was 21 his testimony?
22 MS. WAGNER: No, is it correct that that 23 statement reflects --
(~
lj) 24 l MR. KIRSCHBAUM: My objection is that is 25 not his testimony.
i Floyd 1 607 O 2 MS. WAGNER: I am asking if that is correct 3 apart from what he testified.
4 (Record was read back.)
l 5 A It was the calculation that I had made on 6 the Unit 1 on the maximum hypothetical accident which 7 enabled me to arrive at the conclusion in the morning 8 of March 28, 1979, that some portion of the cladding 9 had failed.
10 Q Did you understand prior to the accident 11 that the procedure for loss of reactor coolant / reactor 12 coolant pressure at TMI-2 identified as a symptom 9
b)
(_ 13 unique to a loss of coolant accident the alarming of 14 HP R- 2 2 7 7 I
15 MR. KIRSCHBAUM: You mean unique as opposed 16 to some other e,ent or unique as opposed to all 17 other events?
18 MS. WAGNER: I mean was it a symptom unique 19 to a LOCA as opposed to being a symptom of some 20 other event.
21 MR. KIRSCHBAUM: Some unspecific event?
22 MS. WAGNER: Any other svent.
23 A I believe the emergency procedure entitled 24 " Loss of Reactor Coolant / Reactor Coolant System 25 Pressure" listed the reactor building high radiation 5
,,m ..-
1 Floyd 608 p
\" 2 and/or temperature alarm as a possible cause. I would 3 like to change the word "cause" to " symptom." The'last 4 word "cause" to " symptom."
tjll 5 Q was it your understanding prior to the 6 accident that persons other than yourself at Metropolitan 7 Edison understood that if HPR-227 went into an alarm 8 condition, that was a symptom of a loss of coolant?
s A I believe that the licensed operators at 10 TMI-2 before the accident were trained to recognize 11 a LOCA by observing a decreasing reactor coolant system 12 pressure and decreasing pressurizer level and that that 13 event, a combination of those two events, could'be 14 precipitated'by any of three transients in the plant, 15 and that once they saw thos'e two indications, then to 16 differentiate which of the three events was causing 17 it, they were directed to look at HPR- 2 27 particulate ,
18 iodine and gaseous radiation monitor.
19 Q I take it it was your understanding before 20 the accident that should they look at that monitor, 21 they would understand what it meant, even though they 22 had not had your particular background with respect 23 to calculat'ing the maximum accident and the other 24 things you mentioned in your prior testimony?
U'~h 25 A I would expect them to respond to an
1 Floyd 609
( )
\> 2 HPR-227 alarm in isolation in the time immediately 3 prior to the accident as being more symptomatic of 4 a rupture of a reactor coolant drain tank rupture h 5 disk than a LOCA, especially if they didn't see both 6 pressure and level in the pressurizer decreasing 7 together and rapidly.
8 Because of the leaks that we had into the
, 9 reactor coolant drain tank, it was full of reactor 10 coolant, and if that rupture disk would blow, it would 11 probably give you an alarm on HPR-227, 12 g Did you think the operators prior to the
/~
(_)N 13 accident at TMI-2 understood that an alarm on HPR- 227 14 was an indication of radiation release of some kind 15 from the reactor coolant system? I am not referring 16 now to an accident particularly. I am referring to --
17 A It is not quite as firmly connected as you 18 imply with your question. HPR-227 is looking at the 19 atmosphere inside the reactor building, so when an 20 alarm on that channel says there are curies released 21 in that building, the highest source of curies in that l 22 building is the reactor coolant system, but it does 23 not disallow some other source for that radiation, such
(~'s 24 as a chemist dropping a vial of radioactive material l V
25 on the floor.
1 Floyd 610 7_
)
KJ 2 (Recess taken.)
3 BY MS. WAGNER:
4 Q To go back to your testimony about the
()ll 5 pressurizer system failure procedure and its application 6 during the period before the accident when a leak was 7 causing the discharge line on the PORV to be above 8 130 degrees Fahrenheit, is it your testimony here that 9 despite the fact that the temperature on the discharge 10 line was above 130 degrees and despite the fact that 11 there was no temporary change notice in effect with 12 respect to the pressurizer system failure procedure
/~N
( ,) 13 that the operators were free to disregard that 14 procedure?
15 MR. KIRSCHBAUM: Objection. I don't 16 believe the witness testified whether there was 17 or wasn't a temporary change notice in effect.
18 A I think the answer to that question is no, 19 but let me put it into my own words and maybe it will i
20 be a little clearer. The procedure under question is 21 a procedure that is important to nuclear safety, and O therefore chang 5s to it are reviewed by the PORC and 22 i 23 signed by the unit superintendent, and even if a
(~T 24 two-man TCN was put into effect, it would receive that
( m _-)
25 same review after the fact, so until that paper
1 Floyd 611
> t k/ existed, the operators were not free to respond in a 2
3 m de contrary to this procedure.
4 However, the 130 degrees is only one of 5 the symptoms listed, and as such, it may not justify G entering the procedure based on one symptom.
7 Q So is it your testimony that this was 8 in the time period before the accident still a symptom
, 9 to be considered a symptom of a failed open PORV or 10 a leaking PORV whether or not that symptom taken alone
, 11 would require you to enter the action statement of 12 the procedure?
'~N
_j 13 MR. KIRSCHBAUM: Objection to the form.
14 I don't understand the question.
15 A Let me t;/. The 130 degrees, a l l
l 16 temperature greater than 130 degrees that existed on 1
17 the tailpipe of the PORV in the days immediately I 18 preceding the accident at Three Mile Island was not 19 indicative of a leaking PORV nor should it have been 20 considered indicative of a leaking PORV by the plant 21 operators.
22 If for some strange chance they felt so 23 obligated, that assumption by itself would not justify f)
U 24 i l
entering this procedure.
25 Q Do you have the procedure in front of you,
1 Floyd 612 r a
\> 2 the pressurizer system failure procedure?
3 A Yes.
4 Q Do you see under Section A8.1, " Symptoms,"
dlh 5 that it is indicated that a symptom of a le& king PORV 6 is relief valvo discharge line temperature exceeding 7 the normal 130 degrees Fahrenheit?
8 A Yes, I see that.
9 Q Is it correct in the time period before 10 the accident when something was causing the PORV 11 discharge line to be heated in excess of 130 degrees 12 Fahrenheit that that was a condition which fell within
/^N b, 13 this symptom?
14 A That is true. It is a condition that fell 15 within this symptom, but I am saying that one symptom 16 by itself is not necessarily justificiation for 17 jumping into a procedure.
18 Q I understand that. I am asking whether the 19 symptom remained a valid symptom in the days prior to 20 the accident pursuant to this procedure.
21 MR. KIRSCHBAUM: What do you mean " valid 22 procedure"?
23 MS. WAGNER: That it was not changed by
[ 24 any TCN.
(/ ')
25 A I don't know if thex . valid TCN on
Floyd 613 1
O- 2 this procedure or not at the time of the accident.
3 Q If there was no valid TCN or TCN of any 4 kind, and whether or not the presence of the symptom would cause you to go into this symptom or not, would
]ll 5 6 it nevertheless still be considered a symptom, or is 7 there someth'ing in your testimony which is telling me 8 for some reason it was no longer a symptom?
9 MR. KIRSCHBAUM: Objection. Asked and
~
1 10 answered, l 11 I think the witness has made very clear --
12 MS. WAGNER: I am not trying to irritate 13 you or the witness. I guess I don't think it 14 is clear.
15 MR. KIRSCHBAUM: I am not suggesting you 16 are trying to irritate anyone. But I am objecting 17 that the question'has been asked and answered 18 I believe more than once.
19 A I would have to say that in the temperature 20 range from 130 degrees to whatever temperature was 21 indicated on RCRV-2 on these data sheets, for instance, 9 22 that that would not be a valid symptom for that 23 temperature range, because it was already at that 24 temperature as indicated by these data sheets without 25 it leaking.
t . - .ii---i-...... . . . i .. . _ .
1 Floyd 614
[ ;
kJ 2 Q Was that fact used to amend the procedure, 3 to the best of your knowledge?
4 MR. KIRSCHBAUM: Asked and answered.
jll 5 A I don't know.
6 Q I am asking you if it was not used to amend 7 the procedure,as I believe it was not, whether that 8 simple fact which you testified to is sufficient to
, 9 permit the operators to consider that that is no longer 10 a symptom of a 1* ailed open PORV even though this 11 procedure says that it is a symptom of a failed open 12 or leaking PORV.
'S
(~/
'x- 13 MR. KIRSCHBAUM: Objection to the form.
}4 To the extent I can understand the question, I 15 believe it has been asked and answered at least 16 three times.
17 If it is a new question, I don't understand 18 it.
19 (Record was read back.)
20 Q Let,me make it clear. You testified, as 21 I understand, that it was your understanding prior to 22 the accident that a code safety was leaking and as a 23 result of that there were high discharge temperatures,
( ,
~
24 discharge line temperatures on the discharge line from
\._/
25 the PORV. Correct?
l I i Floyd 615 l 1
2 A Yes.
3 Q And it was y ur understanding that the 4 PORV itself was not leaking?
, 3 A True.
6 Q My question is, does the fact that you knew 7 that the PORV was not leaking but the discharge line '
g from the PORV was above 130 degrees, are those facts 9 sufficient in the absence of any change in the 10 pressurizer system failure procedure, are they gg sufficient to allow the operator no longer to consider 12 the symptom described in the procedure as being a m
g3 symptom?
(wJ) g4 MR. KIRSCUBAUM: Asked and answered.
15 A It is my belief that if an operator were 16 aware of this symptom and if actual reading of the 17 temperature on the three relie'f valves on top of the 18 pressurizer and if he recognized that the high 19 temperature on the discharge of the PORV was coming 20 from RCRV-1B, then he should have initiated the TCN 21 at that point in time to eliminate this symptom from O 22 this procedure until the repairs were effected to 23 RCRV-1B.
/- 24 Q Assuming all the facts that are in your
!'~'/
25 answer, for the time period before the TCN was issued, l
- 3. ,
, e
'y
~
1 Floyd 616
.W
(_)
,y g 2 was it your unde,rstgnding that the operator wIs 3 obligated to regard this symptom as'still a symptom as 4 described in this procedure?
5 A It is still a symptom. It is still to be (llh 6 regarded by him, and even though it is being regarded 7 by him, it doesn't force him to enter this procedure 8 based on that single symptom.
9 Q Is it correct that the pressurizer system 10 failure procedure also addresses the issue of leaking 11 code relief valves?
12 A Yes, it does.
13 Q Is it correct that one of the follow-up 14 actions when a leaking code relief valve is diagnosed 15 is " Place code relief discharge line temperatures on 16 an analog trend recorder"?
1- A Yes.
18 Q What is an analog trend recorder?
19 A It is a single point recorder-- there are 20 four of them --
mounted on the left-hand side of the 21 operator's console for the Bailey 855 digital computer 9 22 which can be pro'grammed to accept most recorded 23 parameters in the nuclear steam supply system.
(~}
\, ./
24 Q Is it correct that that recorder produces 25 a strip chart?
l
1 Floyd 617 O
'w.l 2 A Yes.
3 Q And is it correct that the purpose of 4 Step No. C3 to the pressurizer system failure procedure, a step which says " Place code relief llh 5 6 discharge line temperatures on analog trend recorder,"
7 is to permit the operators to see on a strip chart 8 what is happening to the temperatures at the discharge 9 of the code safety?
10 A It may have been placed in there to 11 create a continuous record as opposed to make it 12 more visible to the operator.
O t
y , ) 13 Q To the best of,your knowledge, in the 14 time period prior to the TMI accident when you had 15 diagnosed that a code relief valve was leaking, was 16 the code relief discharge line temperature put on an 17 analog trend recorder?
18 A I don't know if it was placed on or was 19 not placed on.
20 Q You do not today have knowledge of any og such strip chart?
22 A Nor have I looked for any such strip chart.
23 Q Again, to return to the loss of reactor
(~'s 24 coolant / reactor coolant pressure procedure, do you have
(_)
25 that in front of you?
1 Floyd 618 2 A Yes.
3 Q The procedure indicates at page 1.0 that 4 one of the ways in which an operator may distinguish llh 5 between a loss of. coolant inside containment, an l
l 6 OTSG tube rupture, and a steam line break is that if 7 there is a loss of coolant inside the reactor building, 8 a particulate, iodine and gas monitor alarm on HPR-227 9 will exist.
10 Did you understand prior to the accident 11 that if HPR-227 did alarm, this procedure required 12 that the operator consider that a symptom of a loss of 13 coolant inside reactor building?
14 A Yes. In fact, these words are exactly 15 right in here. It is a loss of coolant inside the 16 building, not a loss of coolant accident.
17 MS. WAGNER: I have no further questions 18 today.
19 I would like to reserve the right to recall 20 Mr. Floyd in the event ' Lat the order concerning 21 the testimony given to the ACRS about the 22 alleged cheating is changed, but other than that, 23 I have no further questions.
l 24 MR. McBRIDE: There is an error in the 25 acronym in there. This is ASLB, Atomic Safety and i
e 1 Floyd 619
\'
2 Licensing Board.
3 MS. WAGNER: Thank you.
4 MR. KIRSCHBAUM: We would have to take 5 any such request under advisement at the time hlh 6 based on whatever circumstances existed then.
7 I would like a couple of minutes for 8 possibly asking some brief questions on g recross.
10 (Recess taken.)
11 BY MR. KIRSCHBAUM:~
12 Q Did you have an understanding before the 13 accident that if an operator were in doubt about.the 14 action to take with a transient, he should take action 15 to insure that the core was covered?
16 A Yes.
17 Q Before the accident, did you understand 18 that in order to insure that the core was covered in 1
' 19 such circumstances, the operators should in all cases 20 allow the engineered safety features to run without 21 interruption?
22 MS. WAGNER: Objection.
23 A In all cases except where pressurizer level l
24 was visible.
25 Q Why is that?
i I
1 Floyd 620 4 l
1 2 A That would be indicative that the core 3 was covered.
4 Q If pressurizer level were full, is it your lll 5 understanding that the operators would not have been 6 required to allow emergency engineered safety features 7 to run without interruption?
8 MS. WAGNER: Objection.
9 A Yes.
10 Q You were asked several questions on r 11 redirect examination about your understanding of B&W 12 Exhibit 418 which is a B&W draft procedure for loss of 13 reactor coolant / reactor coolant system pressure. As 14 you understand this procedure, under what circumstances 15 does it apply?
16 A. I read from Section 2 of the procedure 17 called " Description." This procedure describes the 18 action to be taken "in the event of a sudden and rapid 19 unexplained decrease in reactor coolant system pressure 20 and pressurizer level caused by a leak or rupture in the 21 high pressure envelope of the primary system."
9 22 Q Ms. Wagner read you the sentence on the 23 third page of the exhibit which reads as follows:
<^g 24 "However, the operator should assume the 25 cause of the symptoms described above is a system l
I Floyd 621 f~'%
t )
\/ 2 rupture or leak unless another cause can immediately 3 be established."
4 What do you understand that to mean in jll 5 the context of this procedure?
6 MS. WAGNER: Objection.
7 A I understand that to mean if you have a 8 LOCA, then the statement which you just read would 9 apply.
10 Q Does B&W Exhibit 418 provide any guidance 11 as to when you would or would not have a LOCA?
12 MS. WAGNER: Objection. You mean other Ot
(_j 13 than the sentence which you just read?
14 MR. KIRSCHBAUM: Including or other.
15 A The first symptom listed on page 3 of the 16 procedure says, " Pressurizer level and reactor coolant 17 system pressure decrease initially," et cetera, et 18 cetera.
19 Q Would the sentence I quoted to you before 20 and which Ms. Wagner quoted to you apply in a situation 31 in which pressurizer level was high while system 22 pressure was low? I 23 A No.
I
(~}
V 24 MS. WAGNER. Could we get a clarification 25 here. Are you asking the witness for his
1 Floyd 622 (3
i !
\# interpretation today of this document or his 2
3 recollection?
4 MR. KIRSCHBAUM: I am asking for his I 5 interpretation today of this document because I.
6 don't think it has been established by you or me 7 that he ever saw this document before.
8 Q Is B&W Exhibit 417, which is the TMI-1 9 Emergency Procedure 1202-6, Revision 0, different in 10 substance from B&W Exhibit 418 on the issue of the 11 existence of a LOCA?
12 A No.
(x,
\_) 13 Q Was it your understanding in the days 14 leading up to the accident on March 28, 1979 that 15 Section A of Emergency Procedure 2202-1.5 applied, or 16 was it your understanding that it did not apply?
17 A It did not apply.
18 Q You testified on redirect examination that 19 an alarm on HPR-227 was a symptom of a loss of coolant 20 within the reactor building but not necessarily a loss 21 of coolant accident.
9 Could you explain what you meant by that 22 23 distinction?
ex j
( ) 24 A If it were indicative of a loss of coolant l 25 accident, you would want to enter the loss of coolant
1 Floyd 623 Ch
(-) 2 accident procedure. If it is an indication, as it 3 really is, of a loss of coolant, then you need to 4 isolate that source of coolant before you enter the
'llh 5 procedure, and that source of coolant could well have 6 been reactor coolant drain tank which has reactor 7 coolant in it normally.
8 MR. KIRSCHBAUM: No further questiens.
9 (Recess taken.)
10 BY MS. WAGNER:
1 11 Q Your counsel asked you a couple of questions 12 about B&W 418, the description section. Is it correct
(
(3 ) 13 that the second paragraph of the description section 14 begins, "These initial symptoms could be caused by a 15 malfunction of the makeup system or by steam line 16 rupture,as well as by a loss of coolant from the 17 reactor coolant system. In addition, a dropped control 18 rod could cause a short 'but appreciable drop in 19 RC system pressure"? It goes'on te describe actions 20 to be taken in the event of various other transients 21 including steam supply system rupture and loss of 22 reactor cool' ant makeup.
l 23 l The paragraph ends, "However, the operator i
(~'- 24 l should assume the cause of the symptoms described above
(-) I 25 is a system rupture or leak unless another cause can
1 Floyd 624
[ '\
\ 2 be immediately established."
l 3 Is that correct?
4 MR. KIRSCHBAUM: Is that correct that that 5 is what it says?
6 MS. WAGNER: Yes.
7 A Yes.
8 Q Was HPR-227 a continuous alarm in the days
, 9 preceding the TMI-2 accident?
10 A I don't know.
11 MS. WAGNER: Thank you very much.
12 (Time noted: 5:05 p.m.)
fO)
\._/ 13 14 15 James R. Floyd 16 Subscribed and sworn to before me 17 this day of 1982.
I 18 19 20 l 21 tipp 22 23 l
24 (v~')
25
I 1
625 !
I CERTIFICATE
(~J'S
(_ 2 l;j h STATE OF NEW YORK )
3it : ss.:
b COUNTY OF NE*d YORK )
4' !
I, JOSEPH R. DANYo , a Notary !
Public of the State of New York, do hereby l certify that the continued deposition of JAMES R. FLoYD was taken before i 8
- I me on Friday, April 30, 1982 consisting 9
of pages 529 through 626 ;
I further certify that the witness had been previously sworn and that the within
./i transcript is a true record of said testimony;
(_ / 13 That I am not connected by blood or lo, 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 I
of the counsel.
18 IN WITNESS WHEREOF, I have bereunto set my
, 19 lj l
- hand this /JI~ day of May ,1982. j l 20 21 61) 22 q
- l k MT
[ OSEPH R. DANYO !
I)
L. ;
24 !
25 I !
l I
t I
f 626 O
INDEX WITNESS PAGE James R. Floyd -(r e sumed ) 531 t
I \
EXH I B I TS B&W NUMBER FOR IDENT.
642 Stipulation carrying cover sheet order signed by Gary L. Milhollin, Administrative Judge and Special Master, the Atomic Safety and O Licensing Board, Docket No.
50-289, approved on November 12, 1981 538 643 Order dated November 17, 1981 of the Atomic Safety and Licensing Board of the Nuclear Regulatory
. Commission, Docket No. 50-289, in I
the matter of Matropolitan Edison Company, Three Mile Island, Nuclear Station Unit 1 signed by Ivan W. Smith, Administrative Law Judge and Chairman of the Board 538 644 Series of four pages, each t entitled " Unit 1, Unit 2" dated
, respectively March 27, 1979, 1- March 25, 197,9, March 24, 1979
[' -
and March 23, 1979 600 i-D -
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vp: ;pl,; l; r.. da
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