ML20072H796
| ML20072H796 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/25/1982 |
| From: | Zewe W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-03, TASK-05, TASK-06, TASK-1, TASK-10, TASK-3, TASK-5, TASK-6, TASK-GB NUDOCS 8306290746 | |
| Download: ML20072H796 (128) | |
Text
.-
l r%p s ',
351 t
al.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
--x GENERAL PUBLIC UTILITIES CORPORATION, e
i JERSEY CENTRAL POWER & LIGHT COMPANY, l
METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, s
Plaintiffs 80 CIV. 1683 (R.O.)
-against-l' THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
e.
Defendants.
's
x t
r)
Continued deposition of GPU' NUCLEAR CORPORATION by WILLIAM H.
ZEWE, taken by Defendants, pursuant to adjournmenti at the offices of Davis Polk & Wardwell, Esqs.,
One Chase Manhattan Plaza, New York,.New I
York, on Tuesday, May 25, 1982, at 9:35 I
o' clock in the forenoon, before Harvey B.
- Kramer, R.P.R.,
Certified Shorthand Reporter and a Notary Public within and for the State i
of New York.
A 0306290746j302g PDR ADOCK PDR DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LsulNGTON AVENut WALTER SH APIRO, C.S.R.
New YomK. N.Y.
loo 17 CHARLES SHAPIRO, C.S.R.
Tst.spwoNE 212 - 867 8220
i 352 1
2 A p p e a r a n c.e s :
3 KAYE, SCHOLER, FIERMAN, MAYS & HANDLER, ESQS.
4 Attorneys for Plaintiffs 4.25 Park Avenue
(
BY:
DAVID KLINGSBERG, ESQ.,
of Counsel 7
J 8
DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 9
One Chase Manhattan Plaza New York, New York 10 BY:
ROBERT B.
FISKE, ESQ.
11 WILLIAM E.
WURTZ, ESQ.
4 RODMAN W.
BENEDICT, ESQ., and 12 K. ANN MCDONALD, ESQ.,
()
of Counsel 14 KILLIAN & GEPHART, ESQS.
Attorneys for the Witness 15 Box 886 Harrisburg, Pennsylvania 1 7 1 0'8 16 BY:
KEVIN WALSH, ESQ.,
17 of Counsel 18 19 Also Present:
20 JONATHAN QUINN Law Assistant 21 Davis Polk & Wardwell, Esgs.
22
~
23 oOo
\\_)
4 25
353 1
2 WILLI AM H.
2 EWE, having been 3
Previously duly sworn, resumed, was examined 4
and testified further as follows:
('
5 EXAMINATION (CONTINUEJf 6
BY MR. FISKE:
7 Q
Mr. Zewe, in addition to the transients 8
that we discussed yesterday, were there any.
9 other transients-at Unit.2 where 10 HPI had come on automatically, befor's 11 the 1979 accident?
12 A
Not that I recall.
13 Q
Yesterday I asked _you some, questions about 14 the pilot-operated relie.f valve and the light.
15 Let me show you an exhibit which has been 16 marked 262, which is a diagram of the PORV.
17 I would like to ask you whether or not, bftheway in 18 before the 1979 accident, you were aware j
19 which the PORV opened and closed, the mechanism by 20 which it opened and closed.
21 A
Basic understanding, yes.
22 Q
Just looking at this diagram, I think you 23 testified yesterday that when the light was on, on the 1
( ()
24 control panel, that indicated that power was on to the 25 solenoid?
I
1 ZeWe 354 2
A Yes.
3 Q
Do you see the solenoid on this diagram?
4 A
Yes.
(
5 Q
What did you understand happened when power 6
went on to the solenoid that caused the piloted-operated 7
relief valve to open?
8 A
When the solenoid would energize, the g
plunger underneath the solenoid assembly would go'down, 10 hitting the pilot operating lever, which would then 11 open up the port for the pilot valve itself, which 12 would allow the pressure to go over and actuate the main O.
u 13 valve.
14 Q
So this thing that is referred to as a 15 solenoid plunger on the right-hand side of this diagram 16 would come down and push the pilot operating lever?
17 A
That is correct.
18 Q
So that would mean that the other end of
~
19 the pilot operating level would lift up; is that 20 correct?
. Sort of like a seesaw?
21 A
Fulcrum point, yes.
k."
22 Q
And that would open up.
Then what would 23 happen to the pilot valve spring at that point?
f~h 24 A
The. pilot valve spring would move up, which
-d 25 would allow the pressure that was on the pilot actuator
1 Zewe 355 2
valve to go over to the relief valve portion.
3 Q
How would that work?
4 I don't remember exactly on this drawing
(
5 how it worked.
I would have to review the technical 6
manual that describes its operations exactly.
But 7
in effect, it allows the pressure from the pressurizer 8
to go through the pilot valve and to actuate against 9
the spring pressure in the relief valve that opened 10 it up to discharge from the inlet of th'e relief valve 11 through the outlet of the relief valve.
I2 Q
O.K.
Is it correct that when power went U
13 off to the solenoid assembly, then the, solenoid 14 plunger was supposed to move back up to its original 15 position?
~
16 A
Yes, it would.
17 Q
And then that was supposed to-allow the 18 pilot operating level to go back to its original 19 position; correct?
20 A
Correct.
21 Q
And to allow the pilot valve spring to go
(.
22 back to.its original position?
23 A
Correct.
24 Q
And did you understand before the accident 25 that the fact that the light was off did not indicate
1 zewe 356 2
one way or the other whether the solenoid plunger had 3
stuck?
4 MR. KLINGSBERG:
Didn't we cover thi
('
5 yesterday in some detail?
Don't you reca.
6 almost that exact question?
7 A
The light in the control room was the primary f
8 means that I used as an operator to determine what the 9
valve position was.
10 Q
I know, but that wasn't my'guestion.
11 MR. FISKE:
Do you want to read it back, 12 please?
[)
~#
13 (The reporter read the pending question, 14 as follows:
"And did you understand before the 15 accident that the fact that the light was off 16 di.d not indicate one way or the other whether the 17 solenoid plunger had stuck.")
18 A
It did not indicate whether the plunger i
l 19 had stuck.
It only indicated whether the solenoid l
20 had power or not.
I 21 Q
And it didn't indicate whether the pilot 22 operating lever was stuck?
i 23 A
It did not.
O)
(_
24 Q
And it didn't indicate whether the pilot l
25 valve spring was stuck?
i L
1 Zewe 357
~g (N.).
2 A
It did not.
3 Q
I would just like to ask you to look 4
briefly again at this list of 26 potential failures of
(
5 the PORV that I showed you yesterday.
I ask you to 6
look at those and to tell us, with respect to each one, 7
whether the fact that the light was off would be an 8
indication one way or another as to whether that 9
particular condition existed.
10 MR. KLINGSBERG:
Which exhibit is this?
11 MR. WURTZ:
156.
12 Q
Let me put it to you this way, to save
(
\\'
13 time, Mr. Zewe:
Numher 19 on this list of 26 14 indicates, " Wiring malfunction, solenoid energized."
15 If that event occurred, I take it the light 16 would be on?
17 A
I believe it would.
18 Q
Now, with respect to any of the other 26 on this list,would the fact that the light w a's of f: indica te 79 20 one wa'y or the other whether that condition existed?
21 MR. KLINGSBERG:
Can I have the question l
22 again, please?
23 (Question read.)
(
24 MR. KLINGSBERG:
Now, this is a document l
l 25 which is dated July 1980.
Are you asking him to
(
L
1 Zewe 358 2
assume now the role of your valve expert and 3
give an after-the-fact expert opinion on this 4
document?
(
5 MR. FISKE:
No.
6 MR. KLINGSBERG:
Or are you asking him for 7
his recollection of some event which occurred 8
when he was in the control room?
l 9
MR. FISKE:
No, I am not doing either one 10 of those things.
11 I am asking him whether it was his 12 understanding before the accident -- to take O
~
13 number one as an example, was it.his understanding 14 before the accident that the fact that the light 15 was off on the control panel would not indicate 16 one way or the other whether there was a scored i
17 piston ring in the main valve.
18 MR. KLINGSBERG:
But before you do that, 19 you have to establish some foundation for the 20 fact that he had some awareness of the fact that 21 there was some event prior to the accident in
(
i l
22 which this occurred.
23 This is a list dated in 1980 of potential
(~h
(_)
24 failures.
i 25 MR. FISKE:
Sure.
I y
>--y-rr mw.-
2
1 Zewe 359 2
MR. KLINGSBERG:
There is just no foundation 3
for indicating that this list was known to Babcock 4
& Wilcox or GPU or anybody in 1979, or that
(
5 anybody ever thought about it or has any 6
recollection of it.
7 MR. FISKE:
I think that the foundation --
8 MR. KLINGSBERG:
I think you are crossing 9
the line between asking him for his recollection 10 or understanding of events and tr'ying to make 11 him an expert witness.
12 MR. FISKE:
No, no, I think there is 13 plenty of foundation in the record for the fact 14 that all of these 26 different potential 15 failures of the-PORV to close were known to 16 people at Met Ed or, at the very least, this 17 information was available to them, prior to the 18 accident.
So I think that there is plenty of 19 foundation for putting the question.
20 If Mr. Zewe wants to say that he personally 21 wasn't aware sefore the accident that a scored
'22 piston ring in the main valve could cause the 23 PORV to stay open, he can say that.
f) 24 MR. KLINGSBERG:
I don't know what your 25 foundation is. Maybe it was somewheres in some
~-
1 Zewe 360 3
2 other deposition or some document --
3 MR. FISKE:
It is.
4 MR. KLINGSBERG:
or something like that
(
5 that,one of these things occurred, but this'looks 6
like some kind of post-accident analysis, and it 7
seems to me you are asking the witness 8
abstractly what the witness's expert opinion is 9
on how these particular potential failures in 10 1980 related to light indicators,.which I think 11 is beyond the scope of what you have defined in 12 these depositions.
O 13 MM. FISKE:
I am not asking Mr. Zewe to 14 look at the list today and tell us based on 15 everything that he knows today whether or not 16 these would have been covered by the light.
17 All my questions relate to the pre-accident 18 period.
I think there is a sufficient foundation 19 for the question.
20 If it-turns out that there isn't, then the 21 question will not survive the trial.
But I am
(
22 entitled to ask it now.
23 MR. KLINGSBERG:
In other words, your O(_)
24 question is:
Were you aware of the fact before 25 the accident that a potential failure of the
m 1
ZeWe 30 O
2 PORV to close could result from a scored piston 3
ring in the main valve; was that brought to your 4
attenti6n in some way?
And if so, what would
(
5 happen to the light in that case?
i
~
6 MR. FISKE:
Yes.
Maybe the best thing to 7
do is just go down the list one at a time.
8 Were you aware before the accident that 9
each one of these could cause the valve to close?
10 And if so, were you aware one way or the other i
11 as to whether that would be reflected by the 12 light?
Why don't we just do that, to save time.
O 13 (Continued on Page 362.)
14 15 l
16 l
17 l-l 18 l
l 19 20
(.
21 22 23 1
fh Q
24 25 I
~,_,,-,,,.#
..w.-
,-r_,...-.,
.~_,-yr,.~m.
,....,,y-ww-..vw,,,.
-,mmm,,
,,n.3-,,--,.
_p.m,r,
-ms--
362 2k 1 1
Zewe
]
2 Q
Let's start with No.
1.
Were you --
3 MR. KLINGSBERG:
The witness is not 4
sure he understands.
(
5 MR. FISKE:
I will start again.
6 Q
Were you aware before the accident, Mr.
7 Zewe, that a scored piston ring on the main valve 8
could cause PORV to stay open?
9 A
As I recall, prior to the accident I 10 wasn't thinking in terms of individual, components 11 on the pilot valve or on the main valve.
I believe r
12 I was aware that certain mechanical failures on the 13 pilot valve or on the main valve could fail.
But 14 as far as scored piston ring on the main valve, not 15 that specific.
16 Q
All right.
Were you also aware that i
17 there were certain mechanical failures on the pilot 18 valve that could fail that would cause the PORV to 19 stay open?
20 A
I was aware more in a generic sense 21 that it is a mechanical-electrical device and there 22 is also the potential for some failure, though I 23 didn't get into the individual parts and say this f~h
()
24 was possible, that was possible.
25 Just generally, dealing with valves and
363 1
Zewe
~
2 operators of valvns, there is always room to have 3
something break, some bind, something scored in 4
some manner to render the valve inoperable or at
(
5 least partially inoperable.
6 Q
Did you understand before the accident 7
that the fact that the light was off on the panel 8
would not indicate one way or the other whether 9
there was such a mechanical failure?
10 MR. KLINGSBERG:
That is about the 11 fourth time that we have had that question.
12 You had yesterday, "the light off, the only 13 thing directly indicated was no longer power 14 to the solenoid?
15
" Answer:
Not entirely trut.
You don't 16 go through each console, et cetera."
17 "Where are the ways in which the PORV 18 could cause other than prior -- other than 19 power continued flow to the solenoid?
Things 20 could cause the valve to stick open and not 21 shut when the power to the solenoid had 22 closed."
23 We had this whole line of questions
()
24 yesterday.
Are you going to repeat it?
25 MR. FISKE:
He can just answer this.
1 Zewe 364
/~T 0.
2 MR. KLINGSBERG:
That is what y'ou said 3
ten minutes ago when you asked the same 4
question.
(
5 Let's have the question.
6 (Pending question read) 7 A
I knew then that there could be a A
8 mechanical failure of the valve and it would not
\\
9 indicate by the indicating light.
10 Q
One lact question with respect to this 11 list.
12 Prior to the accident, were you aware of V
13 any of the specific items on this list,as a
14 potential cause of the PORV failing to close?
15 THE' WITNESS:
Would you read that back, t
16 please?
17 (Question read) 18 A
As I remember, I had thought about the 19 fact that pressure switch contacts could stick 20 closed due to an electrical malfunction of the 21 p re ssure switches, and also possibly that the l,
C.
22 plunger could jam.
23 Other than those cases, I do not recall l
24 thinking about these individual potential failures i
~
25 of the valve.
I 1
Zewe 365 2
Q You said yesterday that at the B&W 3
simulator, there was a light with respect to the 4
position of the PORV.
What did you understand that l
5 light on the simulator indicated?
6 A
Indicated whether the valve was open or i
7 closed.
8 Q
Did someone from B&W tell you that the 9
simulator light was a direct indication of PORV 10 position?
L 11 A
Since the light indication at B&W, I
12 Lynchburg is really actuated through a computer, I 13 don't believe I had thought to differentiate the 14 difference between an actual and a demand indication, 15 because it would probably have been a contact 16 operation on the computer, which doesn't have 17 anything to do with the real valve.
18 Q
How many different simulated transients 19 did you go through on the simulator where you had to j
20 use this light as part of a diagnosis of whether the
(.
21 PORV was open?
22 A
I don't remember.
23 Q
More than one?
O
(_/
24 A
Yes.
25 Q
As many as five?
5 1
Zewe 366 2
A-Possibly.
3 Q
Did you go through such simulations on 4
more than one trip to Lynchburg?
(
5 A
As I recall, yes.
6 Q
I think you said that your best 7
recollection is that you went to Lynchburg for 8
simulator training just about every year from 1974, 9
1975, right straight through until 1979.
l 10 A
'73 through
'79, virtually every year, i
11-yes.
I 12 Q
To the best of your recollection, on how O
13 many of those different trips were there transients 14 simulated in which you had to use this light?
15 A
I don't recall.
16 Q
But at least two?
17 A
As I remember, yes.
18 Q
Did you have any discussions with anyone 19 during the course of these training sessio s at B&W 20 on the difference between a light that was a direct 21 indicator of PORV position and a light that showed k
22 only the power to the solenoid?
I i
23 A
Not that I can remember.
We used the O
t i
24 indicator light that we had available, and that was J
25 all.
l t
m
- - -. - - - -. _ - - _.. ~. _ _, _.. ~ - - _,,... -,. _,,, _ _
,,.__,m,.,.,_--.-,,-
1 zewe 367
%f 2
Q In that last answer, you were referring 3
to when you were at the simulator?
l 4
A Yes.
(
5 Q
Mr. Zewe, we have covered this subject 6
in part in the course of asking you about a couple s
7 of different transients, but I would like to ask 8
question on a broader basis at this point.
9 Were you aware before the 1979 accident 10 that there were circumstances under whi'ch pressurizer 11 level might not be an accurate reflection of system 12 inventory?
13 A
You are asking at any time?
14 Q
Yes, up to the time of the accident.
15 A
I mean any mode of operation.
J 16 Q
Yes.
17 A
I can only recall that there would be I
18 three times when the pressurizer level would not 19 be a true and accurate indication of inventory in i
l 20 the RCS.
l 21 Q
Could you tell us what those three are?
22 A
one of them is when the pressurizer l
23 level is off-scale low, zero or less.
Then you are 24 not sure exactly whers the level is, but you know 25 that you are less than the indicating range of the l
l
1 Zewe 368 O
2 pressurizer instrumentation.
3 Another case is when the pressurizer 4
level instrumentation isn' t reading correctly.
In
(
5 other words, an instrument-type failure.
6 And the other case is when the reactor 7
coolant system is partially drained for maintenance 8
operation.
9 Q
You mean when the reactor coolant 10 system is simply not full of water; right?
11 MR. KLINGSBERG:
I don't think that was
)
0 12 his answer.
13 Q
It is partially drained.
14 MR. KLINGSBERG:
For maintenance 15 operations.
16 Q
For maintenance operations.
I am simply
[
17 asked in that third instance, are you referring to' l
18 when the reactor coolant system is not full of i
19 water?
20 MR. KLINGSBERG:
For maintenance l
I 21 operation?
k.
l 22 MR. FISKE:
Yes.
l 23 A
An example of that is every fuel outage N.
24 we worked on reactor coolant pump seals or do eddy 25 current testing in the steam generators, at which
303 1
1 zewe OU 2
time we would be partially drained and pressurizer 3
level would not be an accurate indication of 4
inventory of the system.
(
5 Q
Is the reactor shut down at that point?
6 A
cold shutdown, yes.
7 Q
What happens to pressurizer level when 8
you partially drain the reactor coolant system?
9 A
Pressurizer level would go down and 10 read approximately 35 to 40 inches.
i 11 Then, depending on how you reduced the 12 level, you could drain the pressurizer completely 13 to less than zero indicated, or you could still 14 drain the RCS cold legs while the pressurizer would 15 still be indicating between 35 and 40 inches.
16 Q
But at any time before the accident in 17 1979, did you learn that in a situation where there 18 is saturation in the reactor coolant system, that 19 that fact can cause an increase in pressurizer level?
20 A
I do not remember having that 21 information.
22 Q
were you aware at any time before the 23 accident in 1979 of an incident at Unit 2 in the
(~%()
24 course of hot functional testing in September of 1977 i
25 where, while venting the pressurizer, pressurizer t
370 1
Zewe 2
level increased?
3 A
I do not recall having that knowledge 4
at that time.
(
5 Q
Whether or not you knew about this 6
event at that time, did you learn of it at any time 7
before the accident in 1979?
8 A
I did not.
That is the time frame that 9
I was referring to, that entire time frame.
10 Q
During that same time frame,, did you 11 learn that in the course of this same hot functional 12 testing incident, pressurizer level had been high O
13 curing the time when there was a steam bubble in the 14 hot legs?
15 A
No.
16 Q
Were you working at Unit 2 in September 17 of 19777 18 A
Yes, I was.
19 Q
And you were doing a regular shift?
20 A
As I recall, yes.
21 Q
Is it your testimony, Mr. Zewe, that 22 during the period of time covering September 8 and 23 September 9, 1977, you did not become aware of an O)
(,
24 incident in the course of hot functional testing 25 where pressurizer level increased either because
4 3-1 Zewe 3 73
(')'T s_
2 the pressurizer was being vented or because there 3
had been a steam bubble in the hot legs?
4 A
I don't recall having that information.
(
5 Q
Did you have any discussion with any 6
shift test engineer, in or about either September 8 J
7 or September 9, 1977, about the fact that 8
pressurizer level had been unexpectedly high during 9
the course of the hot functional testing?
10 A
I don't remember any such Epnversation.
11 Q
So you don't remember any discussion at 12 all that you were a party to or that you overheard 13 about any kind of unusual event occurring in or 14 about that period of time relating to pressurizer 15 level?
i 16 A
I do not.
17 Q
No discussions about trying to figure 18 out why it is that the pressurizer level is so high?
19 A
No discussions that I can remember about 20 that subject.
21 Q
Do you remember any event during the 22 course of hot functional testing in September 1977 23 that provoked any discussion relating to anything I
24 unusual that had occurred?
l t
25 A
At this time I don't recall anything
i 372 i
1 zowe 2
that was unusual that was discussed during that i
3 P' articular time period.
]
4 Q
Do you know someone by the name of l
5 John Ulrich?
f 6
A Yes.
4 7
Q who is John Ulrich?
8 A
You are asking me who and what he was 9
at that particular time?
10 Q
Yes.
What was he in Septe5per '777 11 A
As I recall, he was a shift test 12 engineer.
13 Q
Is he still with Mot Ed?
i 14 A
He is not.
15 Q
Did you know somebcdy in September '77 r
16 named Jack Garrison?
i 17 A
Yes.
18 Q
Was he also a shift test engineer?
19 A
Yes.
20 Q
And did you know someone by the name of i
21 Andre Dominquez?
22 A
Yes.
I l
l 23 Q
was he also a shift test engineer in 24 that time period?
25 A
Yes.
373 2
1 Zewe C
2 Q
You at that time were a shift supervisor, 3
were you not?
4 A
Yes.
(
5 Q
In fact, back on the first day I think 6
of your deposition, you testified that when you came i
7 on shift, it was your practice to have conversations 8
with your counterpart among the shift test engineers 9
for the purpose of finding out whether there was 10 anything of significance that had occur, red in the 11 previous shift that you ought to know about.
12 were Mr. Ulrich, Mr. Garrison and Mr.
OV 13 Dominquez people with whom you had that type of 14 conversation from time to time?
15 A
Yes, they were.
16 Q
And I take it it is your testimony that 17 neither one of those three individuals told you 18 anything in or about September 1977 of any event 19 in which pressurizer level had been high?
20 A
Not that I recall.
21 Q
I asked you yesterday or the day before about an incident in March of 1978 in which a PORV 23 failed open.
Do you remember the discussions on 24 that?
25 A
Yes, I do.
13 1
Zewe 374 2
Q In the course of your training by Met 3
Ed on that event, did you learn that during the 1
4 course of that transient, pressurizer level had
(
I 5
increased while pressure was decreasing?
6 MR. KLINGSBERG:
Are you referring to 7
the documents we looked at yesterday?
8 MR. FISKE:
No.
9 THE WITNESS:
Could I have that repeated, 10 please?
(
11 (Question read) 12 A
I do,n't recall that'particular fact 13 being addressed in the training.
14 Q'
Did you know a shift test engineer in 15 March of '78 by the name of Craig McMullin?
16 A
Yes, I did.
17 Q
Was he a person with whom from time to l
l 18 time you had the kind of conversations you described 19 earlier in your deposition?
20 A
He was a shift test engineer, and I 21 would have the same type of discussions with him as 22 with all the other shift test engineers.
23 Q
Is it your testimony, Mr. Zewe, that
?~
(h) 24 neither Mr. McMullin nor Mr. Ulrich nor Mr.
25 Dominquez told you at any time in or about March
4 1
~
Zewe 375
/"O; 2
1978 that in thE course of that open PORV transient, 3
pressurizer level had increased while pressure 4
was decreasing?
(
5 MR. KLINGSBERG I don't think there was 6
any testimony about that either way.
You just I
asked him about his training.
We had a lot of 8
testimony yesterday about the incident.
I 9
don't recall any.
10 Q
Just so there is no confusion about the 11 question, did Mr. Ulrich, Mr. McMullin, Mr.
12 3
Dominquez, tell you at any time between March 28, 13 1978 and the date of the accident in 1979 that I4 in the course of the open PORV transient in March of 15 1978, pressurizer level had increased while the 16 reactor coolant system pressure was decreasing?
17 MR. KLINGSBERG:
I am going to object 18 to the form of the question because you make 19 it appear in the question that this happened 20 for some significant period of time.
21 My recollection from at least one of 22 the charts that you showed him yesterday is 23 that it happened for 45 seconds or something 24 like that.
When you say "during the course,"
25 it makes it look like
,+,. --.
-w r-. - -<
~
---w,
.,m-
--+,ms,-
15 1
Zewe 376
(
2 MR. FISKE:
Mr. Klingsberg, I believe 3
you are referring to a differen't transient 4
than this one.
3
(
5 MR. KLINGSBERG:
It may be.
6 MR. FISKE:
And I think there is s
7 sufficient foundation in the question.
8 THE WITNESS.
May I have that re re a d,, '
i 9
please?
l 10 (Question read) 11 A
No.
12 BY MR. FISKE:
13 Q
Let me show you a document. wbi'gh has
\\
14 been previously marked B&W Exhibit 176, which are 15 pages in the shift test engineer's log, M!.rch 28, l
i 16 1978.
17 MR. KLINGSBERG:
Is this part of' 76?
i, 18 MR. FISKE:
Part of 176.
19 Q
Do you have those in front of you, Mr.
20 Zewe?
\\
21 A
Yes, I do.
22 Q
Directing your attention to what is the 23 fourth page of this collection, I direct your 24 attention to the top of that page, two sentences
~.
l 25 that read, "The pressurizer. level was increased to l
I l
\\_
-- - - - - - -~
s_s s
.i 16 1
Zewe 377
.s s
- 2.,
approximately 200 inches.
RCS pressure decreased to 3
pproximately 1200 psig before recovery started."
4 Did you ever see the page of the logbook
(
5' in which those sentences appear at any time before 6
the 1979 accident?
i 7
A I don't recall.
4 8
Q Did you ever see pages from the shift 1
9 test engineer's log relating to a hot functional 10 testing incident in September 1977 in khich 11 pressurizer level was,high?
k 12 A
Not that I recall.
O 13 Q
At any time before the Three Mile Island 14' saccident in 1979, did Mr. Floyd, supervisor of l
15 1 operations for Unit 2,.tell you that pressurizer 16 level might not be an accurate measure of system 17 inventory in a situation where you had saturation 18 iin the reactor coolant system?
(
19 A
I do not recall any conversation with 20 Mr. Floyd relating to pressurizer level in 21 saturation conditions not being accurate.
22 Q
Was there training done of control room 23 operators by the operations staff as well as by the 3
w i
24 training department?
s 25 h
Yes.
i.
x
' f 4
17 1
Zewe 378 fG 2
Q And is it correct that Mr. Floyd, as 3
supervisor of operations of Unit 2, was in overall 4
charg'e of that training?
(
5 A
He was in charge of it from the 6
standpoint that he was the department head, but he 7
left most of the operational training up to the 8
individual shifts themselves, their shift foreman 9
and their shift supervisor and their control room 10 operators and auxiliary operators.
11 Q
Who actually did the training?
12 A
we did'it together.
I did some.
The
%.)
13 shift foreman did some.
The senior aux. operators 14 helped to train the junior aux. operators.
The more 15 experienced control room operators helped to train 16 the new. control room operators.
17 Q
Training of control room operators then 18 was done in part by you and other shift supervisors 19 and in part by Mr. Scheimann and other shift 20 foremen?
21 A
Yes.
The entire training process in k..
22 part done by the training department themselves, the 23 on-shift foreman and shift supervisor, the other
(~)
(_j 24 control room operators and by B&W, Lynchburg, 25 Virginia.
1,
18 1
Zewe 379
(~~\\
u 2
Q Did Mr. Floyd make any effort to 3
coordinate the training that was being done in the 4
operations department to make sure that each of the
(
5 different shift supervisors and each of the different 6
shift foremen were es sentially doing the same kind 7
of training?
8 A
I cannot speak for Mr. Floyd, but it was 9
my view and understanding that Mr. Floyd was trying 10 to insure that all shifts were trainind,on 11 comparable -- that all the sh'ifts would at least 12 obtain some minimum knowledge standard 13 Q
And did you periodically have meetings 14 with Mr. Floyd and the various shift supervisors to 15 discuss the kinds of things that should be done in j
16 the training that was being conducted by the 17 operations department?
18 A
Yes, we did.
l l
19 Q
How frequently did you have those 20 meetings?
l 21 A
We had meetings which were called shift 22 supervisors meetings approximately once a month and 23 discussed training and a large range of other things.
24 Q
Did you discuss, in any of those 25 meetings, Mr. Zewe, the fact that operators at Unit l
)
1 Zewe 380 2
2 were relying on pressurizer level as an accurate 3
measure of system inventory?
4 A
I don't recall that that particalar
(
5 point was discussed as such, though it was general 6
knowledge that the operators did rely on the 7
indication and they did rely on pressurizer level 8
indication as a means of determining the primary 9
inventory.
10 Q
You have no reason to believe, do you, 11 that Mr. Floyd was unaware that operators were 12 relying on pressurizer level as an accurate measure O
a 13 of system inventory?
14 MR. KLINGSBERG:
As to that triple 15 negative, reverse question, can we hear that 16 again?
17 (Question read) 18 MR. KLINGSBERG:
Would you mind 19 rephrasing that in the positive?
20 Q
when you said a moment ago, Mr. Zewe, 21 that it was general knowledge that the operators k.
22 were relying on pressurizer level as an accurate 23 measure of system inventory, were you including Mr.
24 Floyd among those that had that general knowledge?
25 A
Yes, I was.
~.. -
.f
.10 1
Zewe 381 0
2 Q
Before the Three Mile Island accident, 3
did you know someone named Ron Toole?
4 A
Yes.
(
5 Q
I don't remember whether I have asked 6
you this before in the deposition.
If I have, I 7
will take the liberty of asking it again.
t 8
What was his position before, a year or 9
so before the accident?
10 A
As I recall, his position das shift test 11 superintendent.
12 Q
Did he at any time before the Three Mile
%.)
13 Island accident obtain some management. position at 14 Unit 1?
3 15 THE WITNESS:
Could I have that back, i
16 please?
17 (Ques tion read) 18 A
I don't remember Mr. Toole's title in 19 Unit 1,
but he was the lead start-up and test 20 engineer in Unit 1.
21 Q
Did he become superintendent of Unit 1 22 at any time before the accident?
23 A
He did not.
24 Q
Did Mr. Toole tell you, before the Three 25 Mile Island accident, that in a situation where
,,..---.----,---,_,e v.=-
~,e.
,-.,,.,,,~.,,------+-,,-----,9.,-7,
-w9.,,,c---,
I 1
Zewe 382 2
saturation existed in the reactor coolant system, 3
pressurizer level would increase?
4 A
Not that I recall.
5 Q
And did he ever tell you that in a 6
situation where there was saturation in the reactor 7
coolant system, pressurizer level could not be 8
relied on as an accurate measure of system 9
inventory?
10 A
Not that I recall.
11 Q
I would like to show you a document 12 previously marked as Exhibit 558.
It is a book g
s_J 13 captioned " Nuclear Power Preparatory Training, Core 14 Performance 4,
A Course for Metropolitan Edison 15 Company Via Video Tape by NUS Corporation, 16 Rockville, Maryla.nd."
17 Let the record reflect this is a book 18 that was utilized in the Met Ed training program.
19 I would like to direct your attention to 20 page 4 21 MR. KLINGSBERG:
Can we have a copy, 22 please?
23 Q
page 4-20.
24 MR. KLINGSBERG:
Okay.
25 A
What time frame was this training book i
l L
..~, - -..._.
..- - ~_
I 1
Zewe 383 s,
[O 2
used?
3 Q
Testimony to date is a little vague on 4
that, Mr. Zewe.
We have been trying to find that
(
5 out.
It was used during some portion of the training 6
program.
7 MR. KLINGSBERG:
Go on your own 8
recollection as to that.
9 Q
And copies of it were produced from 10 Faust's and Mr. Scheimann's personal fi'les.
11 I would like to read to you from page 12 4-20, one particular paragraph.
It reads as follows:
\\~)
13 "The reactor coolant in a PWR system is 14 kept under pressure to prevent bulk boiling in the 15 core.
In the case of an abnormal transient, where 16 this pressure is lost and some steam is generated 17 in the core, how will we know it?
We will see a 18 large increase in level in the pressurizer until 19 pressure is built back up above the saturation value l
20 corresponding to the temperature in the core.
The l
21 steam bubbles will then condense, and the level will l
22 drop back down close to its normal value."
l 23 At any time before the accident did you I
j.O)
(_
24 read that paragraph in this training manual?
25 A
I did not.
..y..
~.,. -
-r-..
13 1
zewe 384
("%
J 2
Q Is it your testimony that in the course 3
of the training that you received from the Met Ed 4
training department, that at no time prior to the
(
5 accident did anyone in the training department make 6
you aware of the principle reflected in this 7
paragraph?
8 A
I do not recall any such training.
9 Q
What was Gary Miller's position at Met 10 Ed during the year prior to the Three Nile Island 11 accident?
12 A
I don't remember the date that he was
\\-
13 promoted from Unit 2 superintendent to. station 14 manager, but it was during that time period.
15 Q
What did the station manager do?
16 A
The station manager was the senior 17 management person at the island.
18 Q
Before the Three Mile Island accident, l
l 19 did you know th at periodically meetings would be l
i 20 held under the auspices of B&W in Lynchburg at which 21 representatives of various utilities would attend?
,L l
22 A
I was aware of a B&W users meeting, if l
23 that is what you are referring to.
O()
24 Q
Which was attended by representatives of 25 the various utilities that had B&W reactors; right?
i i
385
!.4 1
g,,,
_, ~ ~
2 A
That was my understanding, yes.
3 Q
Did you personally ever go to one of I
4 those meetings?
(
5 A
I did not.
6 Q
Did you knou there were people from Met 7
Ed that attended those meetings?
8 A
As I recall, there was a representative 9
from Met Ed at all the meetings.
10 Q
Did you have an understanding before the 11 accident that one or more people would try to 12 attend all of the meetings?
F' k/
13 A
Yes, that was my understanding.
14 Q
So that there would be some continuity 15 in attendance?
16 MR. KLINGSBERG:
What do you mean by 17
" continuity"?
18 Q.
Well, in other words, did you understand 19 that the same person or same people from Met Ed 20 would try to go each time?
21 A
As I recall, Mr. Miller used to go to 22 them, Mr. Seelinger and Mr. O'Hanlon used to go to 23 them.
l 24 Q
What did you understand was the purpose 25 of those meetings?
i 1
Zewe 386 O
\\
>V 2
A My understanding was that the various 3
utilities could get together with each other and 4
B&W and discuss the operation of the B&W units at
(
5 any particular phase that their utility was 6
connected with and share any information that may be 7
available.
8 Q
Did you understand that one of the 9
purposes of these meetings was to allow the utility 10 representatives to exchange information with each 11 other about operating experiences at their plants?
12 A
Yes.
From time to time I had seen 13 various correspondence from those meetings from 14 other utility representatives.
.i 15 Q
And from time to time, Mr. Zewe, did 16 you personally receive information that came out of 1
t 17 those meetings about operating experiences at other 18 plants?
19 A
Yes.
In my last answer I stated that I
/
20 had from time to time seen correspondence from i
21 meetings frcm indivi, duals of the various utilities.
t 22 Q
Was there any procedure at Lie t Ed that 23 you are aware of whereby, when Mr. Miller, Mr.
r
)
24 Seelinger, Mr. O'Hanlon came back from those 25 meetings, they would give to other people at Met Ed 4m--
7,
,n-,y
,;-.,ym-
~y-,,c,-,,w.,.
.+v-.y-.,-
.--,---,-----.-m-cy,,y.,
v7,wr e-
387 i
1 Zewe
/N O
2 the information that-they had learned at the 3
meetings about transients at other plants?
4 A
It was my understanding that the three k-5 gentlemen would pass on whatever information they 6
felt would be helpful to the operational staff, the 7
maintenance staff, engineering staff, whatever they 8
' felt would be helpful.
9 Q
Were there occasions when they, any one 10 of them, gave information directly to Mr. Floyd as 11 supervisor of operations, Unit 27 12 A
The normal chain of command would be g-N~))
13 that all correspondence of that nature;would go 14 through Mr. Floyd to the various shifts.
15 Q
I am not talking, Mr. Zewe, solely about 16 correspondence.
I am talking also about oral 17 debriefings or whatever else you want to call it,'a 18 method by which Mr. Miller, Mr..Seelinger, Mr.
19 O'Hanlon, when they came back from one of these 20 user group meetings, they would communicate to Mr.
21 Floyd or others at Met Ed the information that they 22 had learned at the mcoting about transients at other 23 plants.
O
(,,/
24 A
What communication took place between 25 those men and the rest of the staff, I don't know.
1 gewe 388 27 O
\\"/
2 I would see the end result, either orally from Mr. Floyd or in a written correspondence, the 3
4 information that was passed on from those meetings.
(
5 Q
Did you ever receive information that 6
had been obtained in those meetings from people in 7
the training department?
8 A
I don't recall that specifically.
9 Q
Did it ever come to your attention, Mr.
10 Zewe, that at some time in November or. December of 11 1978 Mr. Miller and Mr. O'Hanlon had been told --
12
'77, sorry -- had been told at a users group meeting O
13 at B&W aboup a transient at Davis-Besse in which 14 pressurizer level had increased while there was 15 saturation in the reactor coolant system?
16 MR. KLINGSBERG:
The question is 17 ambiguous.
Are you saying were they told 18 about a Davis-Besse transient, brackets, saying' that the 19 incidentally, in which you are 20 pressurizer level increased or are you saying 21 that they were told that pressurizer level 22 increased, et cetera, at Davis-Besse?
l 23 I think the question could be read 24 either way.
l 25 MR. FISKE:
I don't think I understand e
!8 1
Zewe 389 v/ \\
2 the difference between the two.
Maybe th at is 3
the problem with the, question.
4 Let me put another one.
(
5 BY MR. FISKE:
6 Q
Did it come to your attention at any time 7
before the Three Mile Island accident that at some 8
time in the fall of 1977 Mr. Miller and Mr. O'Hanlon 9
had been told at a users group meeting at B&w about the 10 transient at Davis-Besse in which pressurizer level 11 had increased while pressure was decreasing?
12 MR. KLINGSBERG:
In other words, was he D)
'\\_
13 told about all of those things.
14 MR. FISKE:
Yes.
For the time being, 15 yes.
16 A
Not that I recall.
17 Q
Did you ever learn, before the Three 18 Mile Island accident, that Mr. Miller and Mr.
i 19 O'Hanlon had been told at a users group meeting in l
20 the fall of 1977 about a transient at Davis-Besse?
4 21 A
Not that I recall.
22 Q
Did you yourself, Mr. Zewe, at any time l
l 23 before the Three Mile I'sland accident, learn about
(
24 the transient at Davis-Besse in which pressurizer 25 level had increased while pressure was decreasing?
I 1
Zewe 390 O
2 MR. KLINGSBERG:
Again your question 3
includes all of those things.
4 MR. FISKE:
Yes.
(
5 A
No, not that I recall.
6 Q
Did you learn about a transient at 7
Davis-Besse in which there had been an open PORV?
8 A
No, not that I recall.
9 MR. KLINGSBERG:
Is this a good time for 10 a break?
11 MR. FISKE:
Yes.
12 (Recess taken) 4 13 (Continued on next page) 14 i
15 16 17 18 19 20
-21 22 23 O
24 25 i
I
1 Zewe 391 s
)
~J.
2 (Mr. Benedict entered the deposition room.)
3 BY MR. FISKE:
4 Q
Mr. Zewe, let me show you a document
(
5 previously marked as GPU Exhibit 153, which is a 6
supplement to a reportable occurrance, Davis-Besse I
Nuclear Power Station, Unit 1.
7 8
Do you have that in front of you?
9 A
Yes, I do.
10 Q
Is that what has sometimes been referred to 11 as an LER?
12 A
Yes.
(~)
13 Q
Did you review this document at any time
'~'
14
'before the Three Mile Island accident in " arch of 19797 15 A
No, I do not recall it.
16 Q
Did anyone bring thi3 document to your 17 attention during that time period?
18 A
Not that I recall.
19 Q
Let me show you a document which has been 20 marked as B&W Exhibit 161, which is a publication 21 called " Current Events, Power Reactors."
22 Do you have that in front of you?
23 A
Yes, I do.
I 24 Q
Before the Three Mile Island accident, were 25 you familiar.with a publication called " Current Events, Power Reactors"?
I 1
Zewe 392 0
2 A
As I recall, I was.
3 Q
How did you become familiar with that 4
publication?
(
5 A
I don't recall whether it was in training, 6
whether it was passed on to me from Mr. Floyd or another 7
source.
8 Q
Was there a procedure at Met Ed before the 9
accident whereby publications containing information 10 about transients at other plants were made available 11 to the operators?
12 THE WITNESS:
Could I have that repeated,
(~%
A-13 please?
14 (Question read) 15 A
As I recall, there were a couple of 16 mechanisms that were used to pass on this information.
17 Q
What were those mechanisms?
~
18 A
one of them being training.
In our normal 19 course of requal training, they would cover'other 20 transients.
There was also a license events report 21 book, as I recall, in the Unit 2 control room that 22 was updated periodically that was available for the 23 operator's review.
And any correspondence that was
[)
24 received through Mr. Floyd or Mr. Seelinger or from s/
25 Unit 1 would be put out to the operators in Unit 2.
1 Zewe 393 OV 2
Q Did you understand that there was a 3
procedure at Met Ed before the accident whereby 4
publications containing information about other l(
5 transients were reviewed in the Training Department 6
so that the Training Department would be in a position 7
'to pass on important information to the operators?
8 A
I don't recall a particular procedure that 9
was used.
4 I
10 Q
well, you were aware beforee the accident, 11 Mr. Zewe, that there were publications out there 12 containing this kind of information, right?
l j
13 A
Yes, I was.
I 14 Q
And it is correct, isn't it, that you 15 felt it was important to you as an operator to_ learn 16 about those transients?
17 A
only if useful information could be.
3 18 obtained from it that we could learn from and put into 19 practice.
20 Q
And was it important to you as an operator, 21 as a shift supervisor, that someone at Met Ed was i
22 going through these publications to pick out the useful 23 information that could be c ommunica ted to the operators?
()
24 A
My understanding was that that was being 25 done.
1-Zewe 394 Q
2 Q
Who did you understand was doing that?
3 A
Training and management above myself.
4 MR. FISKE:
I am sorry.
I didn't hear tho
(
5
' answer.
Would you just read it back?
6 (Answer read) 7 Q
By " management above yourself" you are 8
talking about Mr. Floyd and the unit superintendent 9
for Unit 27 10 A
They are included, yes.
t 11 Q
And then people up the line from there?
12 A
Yes.
13 Q
Which particular individuals in management 14 above yourself did you understand were conducting this 15 kind of review of the publications?
16 A
Supervisor of operations.
Unit 2 17 superintendent, technical support.
Unit 2 superintendent; 18 station manager.
Engineering staff in general'.
And 19 training.
20 Q
Who did you understand was doing this in 21 the Training Department?
22 A
Supervision in training.
23 Q
Pardon me?
O)
(
24 A
Supervision in training.
j 25 Q
That is a title?
Is it supervisor of
1 Zewe 395
()
2 training?
3 A
No.
I am referring to that there is 4
training instructors, and they have a supervisor.
I
(
5 feel that he would make it available to the instructors 6
and they in turn would pass it on to the operators 7
during their normal course of training.
i 8
Q But the person you understood that was 9
doing the review to pick out the useful information 10 was the supervisor?
11 A
I am not at all sure that I made that 12 distinction in my mind that it was solely restricted
'w/
13 4
to those people.
Whoever was on the mailing list for 14 those documents, that had access to them, would be i
1.
15 included.
16 Q
And you understood that the Training 17 Department was receiving publications containing this 18 kind of information?
19 A
It was my understanding that they did 20 receive such publications.
21 Q
You mentioned a number of positions here, 22 some of which I think we have placed individuals with 23 and some of which we haven't yet.
24 Supervisor of operations for Unit 2 was 25 Mr. Floyd, correct?
This is for about the year before
1 Zewe 396 v)
I 2
the accident?
3 A
Yes.
4 Q
The Unit 2 superintendent was at one point k
5 in time Mr. Miller, before he became station manager?
6 A
That is correct.
7 Q
And who succeeded him as Unit 2 superintendent ?
8 A
Mr. Logan.
9 Q
And then you referred to a Unit 2 E
10 superintendent for technical support.
11 A
Yes.
12 Q
who was that in the year or so before the 13 accident?
1 14
~
A During that time frame, I am not sure if it 15 was Mr. seelinger during a portion of that time and 16 during the latter areas of that time it was Mr. Kunder.
17 Q
Now, was " Current Events, Power Reactors" 18 one of the publications that you unders tood was being 19 reviewed-according to this process you described 20 earlier?
l l
21 A
That was my understanding, yes.
22 Q
Was " Nuclear Power Experience" a 23 publication which you understood was being reviewed 24 according to this procedure you described earlier?
25 A
It may have been.
I don't remember.
i
.. _,, _ -,..... - -, _..,,,,.. _. _ - - ~.. - _ _ _... _... - -.. -.. -, -..
1 Zewe 397 O
2 Q
Was it your understanding that there was 3
more than one such publication that was being reviewed?
4 A
Yes.
(
5 Q
Did you have an understanding as to 6
approximately how many different publications were 7
being reviewed?
8 A
I don't recall knowing that number, no.
9 Q
.Were you familiar with a publication called 10 "The Atomic Energy Clearing House"?
E 11 A
I.was familiar with the name, yes.
12 Q
And was that one of the publications that I\\'
13 was being reviewed?
14 A
Yes, I believe it was'.
15 Q
Let me ask you to look at B&W Exhibit 161, 16 which is.a copy of an edition of " Current Events, Power i
17 Reactors."
Directing your attention to page 2,
th e re 18 is a caption there called " Valve Malfunct ons."
19 Do you see that?-
20 A
Yes.
21 Q
There then follows a description of a 22 depressurization event at Davis-Besse No.
1.
23 A
Yes.
24 Q
Did you see this document at any time before 25 the accident?
1 Zewe 398 O
\\_f 2
A No, I do not recall seeing this document 3
before the accident.
4 Q
Let me show you the document which is part
(
5 of Exhibit 208, which is an edition of " Nuclear 6
Power Experience."
7 Do you have that in front of you, Mr. Zewe?
8 A
Yes.
9 Q
Looking at it now, do you see that there 10 is a description in that document of an, incident at t
11 Davis-Besse in September of 19777 12 A
Yes.
{
\\_/
13 Q
Did you see that document at any time 14 before the Three Mile Island accident in '797 15 A
No, not that I recall.
16 Q
Let me ask you to look at another portion 17 of that same exhibit, which is an edition.of " Atomic 18 Energy clearing House," published by the Congressional l
19 Information Bureau.
This is dated January 9, 1978.
20 Do you have that in front of you?
21 A
I do.
22 Q
Turning to the second page of this 23 document, do you see that there is a lengthy description i
24 of the Davis-Besse transient in September 19777 25 A
There is a discussion of the Davis-Besse
-e r
gr-c--e
'e w
ser---,
=m-set
-i--aw
-+-r W
- - - - = -
enes%g-
- .,_2
.t E.;
.1 4
9 1
Zewe 399 bv 2
transient in the next page or so,.but the wording is 3
j.
very, very poor and I can hardly read it.
4 Q
I am not asking you to read it now.
What 0
I am asking you is whether you saw this publication, 6
this particular issue of this publication, at any time 7
before the Three Mile Island. accident.
8 A
No, not as I recall.
9 Q
At some time after the accident, Mr. Zewe, 10 t
did you learn that there had been publications sent to 11 various people at Met Ed that ontained information 12 h'
about the Davis-Besse transient?
'v 13 THE WITNESS:
Would you repeat that, please?
14 (Question read) 15 MR. KLINGSBERG:
Excluding conversations 16
~
with attorneys?
17 MR. FISKE:
Yes.
18 Q
I am not asking about the content of any 19 conversation with a lawyer.
20 A
That is up to the present date, today?
(
Q Yes.
22 THE WITNESS:
One more time, would you read 23 it, please?
24 (Question read) 25 A
Yes, I am aware that there were publications
_ -. _.. - _ _ _ -.,, _ _ _ _...... -. -, _. _, ~ _ -
I 1
Zewe 400 0
2 sent to various people at Met Ed that concernef 3
information about the Davis-Besse accident, the contents 1
4 of which I am not familiar with, how much and in what
(,
5 details the publications delve into the accident.
6 Q
Did you personally make any effort after 7
the accident to try to find out why none of the 8
information in those publications had been communicated 9
to you?
10 MR. KLINGSBERG:
I object to the form of 11 that question.
12 You can answer.
\\~
13 A
I did not.
14 Q
.I will show you a document which has been 15 previously marked as B&W Exhibit 419, which is a copy 16 of a letter from Mr. Ward at B&W to Mr. Lanese at GPU 17 Service.
18 Do you have that in front of you, Mr. Zewe?
19 A
Yes, I do.
20 Q
Did you ever see that document at any time 21 before the Three Mile Island accident?
22 MR. KLINGSBERG:
Take as much time as 23 you need to look at it.
24 MR. FISKE:
Yes.
25 THE WITNESS:
Would you repeat the question,
-m-a vw>.
M e--
g wy>p
,y wq y-++w+ew-
=7
-n y
y
+-nf
1 zewe 401 2
please?
3 Q
The question is, did you see this document 4
at any time before the Three Mile Island accident?
(
5 A
No, not that I can recall.
6 Q
Directing _your attention to figure 3,
which 7
is part of this document, do you have that in front of 8
you?
9 A
Yes, I do.
10 Q
This reflects the movement 'of pressure 11 versus time for various break sizes.
Did you ever see 12 this figure at any time before the Three Mile Island O
13 accident?
14 A
No, not that I recall.
15 Q
Was there a procedure at Met Ed before the 16 Three Mile Island accident for raising safety concerns 17 within the Met Ed organization?
18
.THE WITNESS:
Read that again, please.
19 (Question read)
"20 A
Yes, there was.
21 Q
How did that procedure work?
(t 22 A
There were two mechanisms that we had to 23 point out problems.
D)
(_
24 One was a GPU problem report that we would 25 initiate and then have that responded to.
1 Zewe 402
~ v).
2 Then there was also under the. code of Federal 3
Regulations 10 CFR, part 21, which was used at the 4
Island as another means of bringing to light any safety l
5 concerns that we felt existed.
6 Q
And was;there written material distributed 7
to operators that described each of those two procedures.
8 A
As I recall, yes.
9 Q
At any time before the accident did you ever 10 yourself initiate a 10 CFR 21 report?
11 A
I had not.
12 Q
In the operation of the secondary part of O
13 the systes, at some point after the water leaves the 14 condenser, it goes through condensate polishers?
15 A
Yes, it does.
16 Q
What is the purpose of the condensate 17 polishers?
18 A
To insure feedwater quality for the steam 19 generators.
20 Q
The purpose is to eliminate impurities in 21 the water at that point?
22 A
Yes, to insure that the feedwater quality 23 is within our specs before it goes into the steam
(
24 generators.
25 Q
How many condensate polishers are there?
1 zewe 403
[~h
%)
2 A
Eight.
3 Q
Is it correct that the system is set up so 4
that under normal operations, seven are functioning at
(
5 any one time?
6 A
During design flow conditions, seven are 7
used and one is in standby.
8 Q
What is the process by which the impurities 9
are removed from the water in the condensate polishers?
10 A
Basically there is two separate means.
One 11 is actual filtration that is done by the resin that is 12 within the polisher units, and the other is a resin O
13 exchange process whereby impurities are exchanged on 14 the sites for the resin beads.
15 Q
And after that process has gone on for a 16 while, does it become necessary to replenish with resins?
17 A
At some point in time the resin is either 18 contaminated with impurities to tae point that it can 19 no longer provide the desired chemistry output, that it
- 20 needs to be regenerated.
21 Q
Is the system set up so that seven out of 22 the eight condensate polishers are functioning during 23 normal operations and whichever one of the eight is not
/%
()
24 functioning is having its resinc regenerated?
25 A
At some point in time tae resin in the f
m w
em
~ - - - =
s-<,.w-e,
--m w
e
-n-w---
ww,,,v-.1 v-s,e-w=vt,-~=
w y
-"s"u
~-sww-v<,ww<-
~
M 1
Zewe 404 2
standby vessel was either regenerated or it was under-3 going the process of regeneration and once it was 4
regenerated, then it was put in standby to be used'as l
5 the next vessel to go on line.
6 Q
Does the regeneration process involve 7
moving the resins from the standby polisher into a 8
regeneration tank?
9 A
Yes, it does.
10 Q
And then back again into the standby polisher 11 after the resins have been regenerated?
12 '
A Yes.
13 Q
Is part of the process for. regenerating the 14 regins that air is injected into the cylinder?
15 A
Yes, that is part of the process.
~
16 Q
Is that called service air?
17 A
It is.
4 18 Q
Is it also correct that as part of the 19 process for moving the resins from the standby polisher 20 into the regeneration tank, demineralized water is used 21 to in effect force the resins through into the other 22 tank?
23 A
Yes.
24 Q
Is that demineralized water under pressure?
25 A
Yes, it is.
1 Zewe 405 p
4
\\
2 Q
At any time before the Three Mile Island
+
3 accident, were you aware of a potential concern that 4
the demineralized water which is under pressure might
(
5 be forced into the service air line?
6 A
Yes.
7 Q
Are there some kind of valves that are 8
supposed to be designed to prevent that from happening?
9 A
Yes.
10 Q.
Let me show you an exhibit'which we will 11 mark as the next B&W exhibit, Exhibit 742, which is a-12 collection of pages from the FSAR for Unit 2.
a 13 (Collection of pages from the FSAR for 14 Unit 2 was marked B&W Exhibit 742 for identifi-15 cation, as of this date.)
16 Q
Do you have that in front of you, Mr. Zewe?
. 17 A
I do.
l 18 Q
Do you see the section 10.4.6.1 called 19
" Design Bases"?
l 20 A
Yes, I do.
21 Q
The last couple of sentences in the big 22 paragraph read, "The design also provides a bypass of i
23 the entire condensate polishing system.
The design of i
i
(~)
24 the polisher units and regeneration equipment is based s-25 on a 28-day resin in-service life."
l-
1 Zewe 406
,C\\
V 2
What did you understand, Mr. Zewe, was the 3
purpose of pr'oviding the bypass of the entire condensate 4
polishing system?
l 5
A The purpose of the bypass was to insure that 6
we could maintain condensate and feedwater flow even if 7
the polishers had a problem and would not permit flow 8
through them, or that their pressure was that their' 9
delta pressure was high enough that it would reduce 10 flow sufficiently; we could then open up the manual 11 bypass valve and maintain flow.
12 It was also us,ed in the start-up phase to
\\/
13 assure initially that the condensate and feedwater systems 14 were full of water.
15 Q
Did you understand that if something 16 happened in the condensate polishers to interrupt or 17 s ub s tan tially reduce the flow of water, that that'could 18 produce a turbine trip?
19 A
Indirectly, yes.
20 Q
And how would that work?
21 A
We have several protective features to 22 protect the operation of the rain turbine.
23 One'of those involves the operation of the
[ ').
24 main feed pumps.
If we should lose both main feed pumps, v
25 it initiates.an automatic turbine trip.
And if you
1 Zewe 407 2
would interrupt flow to the main feed pumps, they were 3
equipped with low suction pressure trips.
4 So in effect, if you would lose flow to the
(
5 Pumps, you would lose the pumps, andlthey in turn would 6
activate a turbine trip.
7 Q
Was it your understanding before the 8
accident that in the event of some condition occurring 9
in the condensate polisher which interrupted the flow, to ma$ually bypass the 10 that the operators would be able 11 system before you lost the main feedwater pumps?
12 A
As I recall, it was dependent upon several b) 13 factors:
Whether you had two main feed pumps running and 14 the flow was only reduced, not lost; whether the runback 15 that you would get when one feed pump would trip was 16 sufficient to avert a trip or not.
17 So it really depended on what^ power level, 18 on what your flow was and,actually how much flow yr>u lost; 19 Q
What was your unders tanding be fore the 20 accident as to whether, if you had under normal opera-21 tions a complete interruption of flow through the 22 condensate polishers, you would be able to activate the 23 manual bypass in time to prevent a turbine trip?
24 A
I believe my understanding was such that if 25 I had a total loss of flow through the polisher units,
1 Zewe 408
(~%
~
\\_.]
2 that I would not have sufficient time to open up the 3
. bypass valve in order to avert a turbine trip.
4
.Q Was there a bypass valve on Unit 1?
(
5 A
Yes, there is.
6 Q
Did that work any differently than the one 7
at Unit 2?
8 A
Yes, it did.
9 Q
How was the one in Jnit 1 different?
l 10 A
The Unit 1 polisher bypass yalve is an 11 air-operated valve that can be operated manually from 12 the control room or automatically as sensed by high 13 delta pressure.
14 In Unit 2 it was operated manually from the 15 control room.
It was a motor-operated valve, and it 16 did not have an automatic function on opening on i
17 high delta pressure.
18 Q
Had you had any situation on Unit 1 19 before the Three Mile Island accident where there had 20 been a total loss of flow through the condensate 21 polishers?
22 A
That was caused by the polishers themselves?
23 Q
Yes.
Something where, an incident where the
()
2; bypass would become relevant.
i 25 A
O.K.
They are two different events.
All l
~
1 Zewa
'409 O
~
2 right?.
s 3
I don't recall any where the polishers 4
themselves suddenly resulted in a total loss of flow.
5 But there were numerous occasions where the bypass 6
valve did come open automatically, based on high 7
pressure across the system.
4 8
Q In those cases where it came on 9
automatically, was there a turbine trip?
10 A
No, there was not.
'll
(. Continued on Page 410.)
12 0
13 14 15 16 i
l 17 18 19 20 21 22 23 24 25
~.
- 1 1
zewe 410
/~T V
2 Q
Let me show you a document which has 3
been marked as B&W 165.
4 Do you have a copy of that in front of
(
5 you, Mr. Zewe?
6 A
I do.
7 Q
Have you ever seen that document?
8 THE WITNESS:
Would you repeat the 1
9 question?
10
'(Question read) 11 A
I do not recall seeing the first page 12 of the document, the GPU start-up pro'blem report.
O 13 I do remember seeing the rest of the 14 report.
15 Q
This report deals with a situation 16 where there was a loss of feedwater resulting from 17 the closing of the discharge valves in the 18 condensate polishers?
19 A
Yes.
20 Q
Is it correct that the operators were 21 not able to open the manual bypass valve in time to 22 prevent that trip from occurring?
23 A
I am sorry.
What trip are you referring 24 to?
A turbine trip?
25 Q
Yes.
. = -
4 1
Zewe 415 2
A The turbine was on turning gear at the s
3 time.
It was not operating.
4 Q
All right.
(
5 This incident resulted in a total loss
-6 of feedwater; isn't that correct?
7 A
Yes.
Yes, it did.
8 Q
Which under normal operations would 9
produce a turbine trip?
10 A
Yes, it would.
11 Q
Okay.
Is it correct that the total loss 12 of' feedwater resulted from the fact that the 4
13 discharge valves on the condensate polishers had i
14 closed?
i 15 A
That they had closed, yes.
16 Q
Was it also correct that the control 17 room operator was not able to open the bypass valve
~
18 in time to prevent the total loss of feedwater?
19 A
That is true.
l 20 Q
You said, I think, Mr. Zewe, that the l
t 21 unit was not at power at this time.
22 A
It was in cold shutdown.
23 Q
Right.
Directing your attention to the i
24 second paragraph on page 1,
in the section captioned 25
" Summary of Events," I would like to direct your l
I 1
Zewe
.412 2
attention to the last sentence of that paragraph, 3
which reads, "If this would have happened while at 4
power, the unit would have been placed in a severe l
6 transient condition resulting in an emergency 6
feedwater actuation, main steam relief to atmosphere, 7
turbine trip and reactor runback with possible trip."
8 Do you see that sentence?
,9 A
Yes, I do.
10 Q
Did you express any disagred, ment with 11 that conclusion when you received this memorandum 12 back in 1977?
/~'\\
b 13 A
I did not.
14 Q
Is it correct, Mr. Zewe, that it was 15 water in the instrument air lines which caused the e
16 discharge valves on the polishers to close?
17 THE WITNESS:
Would you repeat-that 18 again, please?
19 (Question read) l l
20 A
As I recall, that is what we suspect l
w 21 at the time.
22 Q
Could you tell us, Mr. Zewe, why water 23 in the instrument air lines might cause the
)
24 discharge valves to close?
25 A
If I remember correctly, it is because
=
- -. = -.
1 i
1 zewe 413
/~h V.
2 of the regulato rs that are used for the control s
3 valves.
They have a fine mesh-type strainer on the 4
air lines going to the operator._ And if there is l
5 water indu,ced, it will completely block up that 6
passage, and the operating air for that valve will' 7
not reach the operator of the valve.
And the valve, 8
upon loss of this supplied air, will fail shut.
9 Q
It was postulated after the accident, 10 was it not, that 11 MR. KLINGSBERG:
When you say "after the 12 accident,"
you mean after this November l
13 accident?
14 MR. FISKE:
I will start again.
15 Q
It was postulated sometime after this 16 incident, was it not, that water'might have gotten l
17 into the instrument air lines from the service air 18 system?
19 THE WITNESS:
Would you restate that, 20 please?
i 21 Q
Let me read a paragraph from page 2 of 22 the memo, to save some time.
23 The second paragraph on page 2 reads, 24 "one remote fluid path was recognized, that being i
25 that the demineralized water, because it was at an i
I g,y, 434 r
%/.
2 abnormally high pressure, was forced through the 3
service air system, through three check valves, the 4
instrument air dryer and back to the condensate k
5 polishing controls, being the lowest point in the 6
system and the most consuming point of instrument 7
air."
8 Do you remember reading that sentence 9
sometime during November 1977?
10 A
Yes, I do.
11 Q
And were recommendations made following 12 this transient, or following this incident, about G
13 things that should be done to provent demineralized 14 water going through the service air lines.and into 15 the instrument air lines, causing the discharge 16 valves to close?
l 17 A
Yes, there were recommendations.
18 Q
And these recommendations were made by 19 Mr. Brummer and Mr. Ross, were they not?
20 A
Yes.
They did.
21 Q
Directing your attention to the front 22 page of this memo or this exhibit, which is the 23 page called GPU start-up problem report, down at the 24 bottom over the signature of Mr. Toole, November 17, 25 1977, it says, "No further action required by this
1 zewe
.435 i
2 PR," which I guess means " problem report."
Is that s
3 right?
4 A
I believe so.
(
5 Q
Okay.
"If when the plant is restored 4
6 the problem is better defined, we will resolve the i
7 problem."
8 Do you see that?
9 A
Yes, I do.
i
[
10 Q
That was written on Novemb$r 17, 1977 11 and Mr. Ross and Mr. Brummer wrote their memorandum i
12 containing the recommendations on November 14, 1977.
13 Do you know what action, if any, was s
14 taken with respect to Mr. Ross' and Mr. B rumme r '.s 15 recommendation in the three days between the time 16 they wrote the memo and the time that Mr. Toole said 17 no further action was required?
e 4
18 A
As I recall,, items 1 through 9 on page 19 2 and 3 were accomplished, at least in part.
20 Q
During that three-day period?
21 A
During that three-day period I am not 4
22 sure.
But I think that there was work under way.
23 If it had not been accomplished in that three-day 24 period, that in the days following they were 25 accomplished.
-, _. _., _ _ _, _ _. _ _ _, _ _.. _ _,. _ _ _.,. ~. _.... _ _ _
-j 7
1 Zewe
.43 6 4
2 Q
And by "they" you mean items 1 through 97 3
A Yes.
4 Q
In whole or in part?
i 5
A Yes.
Without i
reviewing them and 6
looking at the old logs to make sure that they were 7
completely-revised during that' time period or not, 8
but as I remember, the tasks were undertaken and i
9 were in fact accomplished, but I am not sure of the 10 actual time frame.
11 As a matter of fact, I believe that 12 item 4 is what precipitated the cover sheet for the O
13 stant-up problem report.
14 Q
There was another incident, was there 15 not, in May 1978 when there was a problem with the 16 condensate polishers?
17 A
There were various problems with the i
18 condensate polishers, though I am not sure I know 19 which one you are referring to at this point.
20 Q
Are you telling us'that after the 21 october 1977 incident there were a number of 22 incidents in which the discharge, valves of the i
23 condensate polishers closed?
(
24 MR. KLINGSBERG:
I don't think that is l
l l
25 what he said.
You can ask him the question.
i l
- - _,.. _.. - - ~ - - -
.417 1
Zewe O'd 2
MR. FISKE:
I know.
That is what I am 3
trying to find out.
4 A.
No, that was not my answer.
My answer
(
5 was that there were various problems with the 6
condensate polisher.
Whether there we re a number of 7
closures of the discharge valves in May of
'78, I
8 believe you said, I don't recall a number, two, 9
three or four -- I don't remember that, but there 10 were problems.
(
11 Q
Were there problems that resulted in 12 turbine trips?
13 A
I would have to review them to be sure 14 of that.
i 15 Q
Were there problems that resulted in the 16 loss of feedwater?
r 17 A
I believe during that period we did have 18 transients in the condensate and feedwater during 19 that period, yes.
20 MR. FISKE:
Could I hear that answer?
i 21 (Answer read) 22 Q
I guess my question was whether any of 23 them resulted in the total loss of feedwater.
24 A
Here again, I would need to review that j
25 time period to be certain.
I believe there was.
1 Zewe 418 2
Q Now I would like to direct your attention 3
to a specific incident in May 1978, in which the-4 polisher discharge valves shut.
5 Do you recall.that incident?
6 A
I believe I have already answered that.
7 Q
Well, let me show you a document that 8
has been marked as Exhibit 166, which is a memorandum 9
dated May 15, 1978 to Jim Seelinger from W.
H.
- Zewe, 10 and the caption is " Water in Service AEr and Inst l
11 Air."
i 12 Did you write that memorandum?
C')
13 A
Yes, I did.
14 Q
Did you write that memorandum after you 1
15 learned of a transient in which the discharge valves 16 in the condensate polisher had shut?
17 A
I believe so, yes.
18 Q
Let me show you a document marked B&W 19 176, pages from Exhibit 176, pages from the shift 20 test engineer's log of May 12, written by Mr.
21 McMullin.
22 Do you have that, Mr. Zewe?
23 A
Yes, I do.
O
(_)
24 Q
Page 2 of that document, which is part of 25 Mr. McMullin's report of May 10, 1978 or maybe it t
I
~
Zewe 439 I
2 is May 12, '78 says, "Due to opera' tor error 3
water entered service and instrument air systems via 4
cond polisher fluffing air line."
(
5 Do you see that?
6 A
Yes, I do.
7 Q
Now, in your memorandum to Mr. Seelinger, 8
-the first sentence says, "It's time to really do 9
something on this problem before a very serious 10 accident occurs."
E 11 Is it correct that "this problem" refers f
12
,to water in the' service air and instrument air lines?
13 A
Yes, it does.
1 14 Q
The next sentence of your memo reads, 15 "If the polishers take themselves off line at any i
16 high power level, the resultant damage could be l
17 very significant."
18 Do you see that sentence?
l 19 A
Yes, I do.
20 Q
And in that sentence you meant, did you 21 not, that if the polishers take themselves off line 22 because of water getting into the service air or 23 instrument air lines at any high power level, the 24 resultant damage could be very significant?
That is 25 the situation you were referring to in that sentence,
420 l
1 Zewe 2
isn't it?
3 A
It states what I meant.
4 Q
Okay.
(
5 Now, you make three recommendations in 6
this memo, do you not?
7 A
Yes, I did.
8 Q
After talking with Doug Weaver; is that 9
right?
10 A
Yes.
t 11 Q
Who is Doug Weaver?
12 A
Instrument and control lead foreman, A
13 Unit 2.
14 Q
Item No. 1 says, "COV12--must be made an i
4 15 automatic valve that opens on high polisher Delta P."
16 Correct?
17 A
Yes.
18 Q
Is COV12 the manual bypass valve?
l 19 A
Yes, it is.
l
~
t 20 Q
Item No. 2 says, "SAV356 --
move valve I
i 21 to between SA-P-1 and SA-P-1A.
Keep this valve shut 22 at all times to isolate SA and IA."
23 Do you see that?
()
24 A
Yes, I do.
25 Q
And you have attached a diagram, have you
12 1
Zewe 421 v
2 not, to the memo, indicating how that could be done?
3 A
Yes.
4 Q
And is it correct that that
(
5 recommendation, if implemented, would prevent water 6
from the service air line hitting into the instrument 7
air line?
8 A
That is true.
9 Q
No.
3,
" Install inline DEW cell 10 instrument downstream of air dryer.
This should be 11 made to alarm and record."
12 Could you tell us what the purpose of f
13 that recommendation was?
14 A
The purpose was to insure that if you 15 did have any water or substantial moisture in the 16 instrument air lines, that you could detect it and 17 then take action to eliminate it before you would 18 contaminate the instrument air system with water.
19 Q
Going back to Mr. Ross' and Mr. Brummer's 20 memo of November 14, 1977, do you see item 6 in 21 their recommendations, which reads, " Develop a PM 22 program to take dew readings in the instrument air 23 system as a minimum on a weekly basis, at the 24 instrument air dryer and at the condensate polishing 25 contro1 panel."
I 422
- gew, OJ 2
Had that recommendation been implemented 3
by the time of the May '78 transient?
4 A
As I recall, it had, yes.
(
5 Q
So your recommendation No. 3 was for 4
6 further instrumentation with respect to moisture in 7
-the instrument air lines?
)
8 A
Yes, it was.
9 Q
Had any of the recommendations in Mr.
10 Brummer's and Mr. Ross' memo involved dction that 11 would have prevented water from the service air lines 12 getting into the instrument air lines?
13 THE WITNESS:
Would you read that back, 14 please?
15 (Question read) i 16 A.
In part, yes.
17 No. 7 would have partially corrected that l.
18 problem by insuring that all the air compressors 19 were blown down of any moisture, and then to log if 20 there was any abnormal amounts, which may have been 21 from a service air compressor cooler leak which may i
22 develop if the operator would use that as part of i
f 23 his mechanism in trying to prevent the water.in 24 service air from going into the instrument air I
25 system.
i l.
,,c
1 zewe 423 O
Un.
2 Q
Is that the only one?
3 A
Also No. 2 would have an effect on that, 4
to completely realign all the air and water controls l
5 on the condensate polishing regeneration system.
6 Q
Had both of those steps recommended in 7
paragraph No. 2 and No. 7 of Mr. Ross' and Mr.
8 Brummer's memo been implemented by May 12, 1978?
9 A
I believe that they were at least 10 started, if not completed.
11 Q
I take it then that it is fair to say, 12 M r.' Zewe, that you felt that the th r.e e recommendations j
13 that you were making on May 15, 1978 were things that i
14 needed to be done in addition to the things that Mr.
15 Ross and Mr. Brummer had recommended back in 16 November?
17 A
Yes.
10 MR. KLINGSBERG:
Is this a good time?
i 19 MR. FISKE:
Sure.
20 (Luncb recess taken at 12:30 p.m.)
i 22 23 24 25 l
i
,.. -. _ - - _,. - ~. - - _ - _ _
.~.
5 1-424
(~)
^
(./ -
2 AF TE RNO ON S E S S I O N 3
2:10 p.m.
4 (Ms. Wagner and Mr. Benedict not present)
(
ZEWE resumed 6
and testified further as follows:
7 EXAMINATION (continued) 8 BY MR. FISKE:
9 Q
Mr. Zewe, by the time of the accident in 10 1979, had the first recommendation thaE you made in
'11 your May 15,78 memo been implemented?
That is, t
12 had an automatic bypass valve been installed?
O\\--
13 A
At the time I believe that.it was still 14 under evaluation and determination if that was the 15 best route to take, so it had not been accomplished 16 as I had it.
J 17 Q
As of the day of the accident, had the 18 second recommendation in your May '78 mem been 19 implemented?
20 A
Here again, it was under evaluation on 21 if this was the best approach.
I hadn't realized 22 that this wouldn't be a complete fix, a 100 percent 23 fix.
When I instituted this, it was just in my
(
24 estimation that this would certainly help to 25 alleviate the problem, and further evaluation was
Zewe 425 1
("%
~
\\~).
2 still undergoing at that time.
3 Q
Had the third recommendation been 4_
implemented?
-(
5 A
The third recommendation was still under 6
evaluation also.
7 Q
I will show you a' document that has been i
g marked as Exhibit 167, B&W 167, which is a 9
handwritten memorandum from Mr. Seelinger to Mr.
10 Brummer with a couple of carbon copies) including 11 one indicated to you.
12 I will ask you whether or not you i
13 received a copy of that memo in or about May 1978.
~
14 A
Yes, I did.
15 Q
What is the first name on the carbon 16 copy?
17 A
Which area, sir?
18 Q
At the top.
It says " carbon copy" --
19 A
Bezilla.
l 20 Q
Who was Mr. Bezilla?
21 A
Mark Bezilla at that time was the 22 procedure coordinator and task assigner.
23 Q
What was his function, as you understood 24 it?
N_-
25 A
He would coordinate procedure changes and
)
i 1
Zewe 426
(~
(.s} -
2
. also tasks that we re assigned to various Unit 2 3
people.
He kept track of who was responsible for 4
what and where the job stood at any particular time.
(
5 g
Who did he report to?
6 A
As I recall, he reported to two people.
7 One was the PORC chairman, and the other one was Mr.
8 Seelinger.
9 Q
Who was the PORC chairman in May of '78?
10 A
I don't recall.
I pelieve'it would have 11 been either Jim Seelinger or Ron Warren.
12 Q
The first item in this memo says, "See
(
s,/
13 Zewe's attached correspondence."
14 when you received a copy of Mr.
15 Seelinger's memo, was there anything attached to it?
16 A
As I recall, the memo that we went over 17 before lunch was attached.
18 Q
Paragraph 2 says, "There are some good 19 ideas here."
Do you see that?
20 A
Yes.
21 Q
Did you learn at any time in or about 22 May 1978 which ideas Mr. Seelinger was referring to?
23 A
I assumed at the time that he was 24 referring to all three of the ideas.
25 Q
The next numbe r says, "The quickest route
, _. _ _. ~,.. _
J il 1
1 j Zewe 427 k.
l1 a
rm i
2 '
to go on SAV376 might be a GPU problem report."
3 Do you see that?
4 A
Yes, I do.
(
5 g
Your second recommendation refers to a 6
valve marked SAV356.
Did you understand Mr.
7 Seelinger was re fe rring to that valve in his memo?
8 A
I believe that I recall that he was in 9
error and that he meant 356, but actually wrote 376.
10 Q
Was a GPU problem report wkitten on that 11 recommendation?
12 A
I don't know.
13 Q
The next item says, "With respect to 14 COV12, it will undoubtedly be a capital project so 15 let's get paper moving."
16 That refers to the automatic bypass, does 17 it not?
18 (Ms. Mcdonald entered the dep sition room) 19 A
As far as I can remember, yes.
20 Q
What did you understand Mr. Seelinger 21 meant by " capital project"?
22 A
As I recall, it made reference to a 23 capital project; that is where the money would come 24 from in order to fund the change to that particular 25 valve.
1 Zewe 428 2
Q What kind of paper was it necessary to 3
get moving in order to get funding for that kind of 4
a capital project?
(
5 A
In the budget progress or process 6
that the company was in, certain types of projects 7
were designated either O&M budget money or 4
8 capital project, and there were a few others.
And
~
9 each of those particular groupings of projects from 10 which the money would be funded for it had to go 11 through their own level of approval.
And I don't 12 s
recall offhand exactly what level had to approve a L
13 capital project.
14 Q
You mean an O&M and a capital project 15 were two different things; right?
16 A.
Yes.
The O&M was operational and 17 maintenance budget, and there were certain items 18 that were funded under that.
Other things were 19 under capital proj ects, which then had.to have a 20 different level of approval and a different chain of 21 approval.
22 Q
What was the route to obtaining approval 23 of a capital project?
24 A
I don't remember completely, but it had 25 to deal with what the cost was.
And over and under
.. -. ~ _.. ___..,._, _-.-__ -_.. --. _. _ _. _...~. _.
429 i
1 zewe
'O V.
2 a certain amount had to be approved at a certain 3
level of management.
And I don't recall exactly 4
what the estimated cost of this was, nor at what
(
5 level that breakof f point was in the dollar figure.
6 Q
But it was necessary to put something in 7
writing in order to get funding for this kind of 8
project; right?
9 A
Yes, it was.
10 Q
When you got this memorand$m, who did you 11 understand was supposed to prepare the necessary 12 documents to get approval of this as a capital 13 project?
14 A
I can only recall that I felt that John 15 Brummer, under the direction of Jim Seelinger, was 16 directed at least in part to be directed toward this 17 effort.
18 Q
This is the same John Brummer that had 19 co-authored the November '77 memo?
1 20 A
With Mike Ross?
21 Q
Yes.
22 A
Yes.
23
,Q And who did you understand was supposed O
\\_,/
24 to prepare the GPU problem report with respect to 25 the SAV356 valve?
l 1
Zewe 430 2
A It's not clear to me who was assigned 3
that.
4 Q
Did you talk to Mr. Seelinger after you
(
5 received this memo, to ask him whether you personally 6-were supposed to do anything further with respect to 7
this?
8 A
I don't recall asking Mr.Seelinger, 9
after I got this, if it was my responsibility.
10 I remember asking him aboud.the status of 11 it some time period later, but that's the only other 12 reference I remember towards this particular item.
O 13 Q
were there meetings held periodically 14 among the management of TMI Unit 2 to discuss open 15 items that had not been resolved?
16 A.
When you say "open items that were not 17 resolved," what exactly do you mean?
18 Q
Well, I tried to make it as broad as I s
19 could.
20 A
Do you mean items like this, that we 21 made sure that we captured, that we were progressing 22 on a particular area like this or --
23 Q
Yes, I certainly would include items l
24 like these three items in my question.
25 A
There were periodic meetings of
!2 1
Zewe 431 2
management that would discuss items of this nature 3
on a pretty frequent basis.
4 Q
Did you ever participate in any of those
(
5 meetings?
6 A
Yes, I have from time to time.
7 Q
Were you ever invited to attend a 8
meeting that was dealing with any one of these three 9
items?
10 A
Not that I recall.
11 Q
Were written lists made of open items 12 that had not yet been resolved?
~g
+]
13
'A I believe that there were.
14 Q
What were the names of those lists?
15 What were they called?
16 A.
As I remember, we would call them 17 incomplete work lists.
18 Q
And where were these incomplete wo rk 19 lists maintained?.
20 A..
By the management staff.
21 Q
Any one individual in particular?
22 A
It was my understanding that Ron Toole 23 had such a list, along with Jim Seelinger, Mr. Logan m) 24 and Mr. Miller.
25 Q
Did they all have the same list or did
I 1
zowe 432 2
they each have their own list?
3 A
It was my understanding that they would 4
all have basically the same list.
(
5 Q
In other words, they each would have a 6
copy of the same document.
7 A
Yes.
8 Q
Were there target dates on this list 9
for the completion of the unresolved open items?
10 A
Usually there was.
11 Q
Are you able to tell us what the target 12 date was for the resolution of the automatic bypass 13 question?
14 A
I don't recall.
15 Q
Can you tell us what the target date was 16 for the. resolution of the SAv356 question?
17 A
Again I don't recall.
18 Q
Do you know what the target date was for 19 the dew cell instrument?
~
20 A
I don't recall.
I 21 Q
Were you aware of those target dates l
(-
22 during the period May 1978 through March '79?
23 A
I don't recall if I knew them at that f
(
24 time or not.
25 Q
Well, did you ever ask Mr.Seelinger or
\\
.,v-,
,,- --+ - -,
~
24 1
Zewe 433 O
2 Mr. Brummer or any of these other gentlemen whether there was a tar' Jet date for completing any one of 3
4 these projects?
(
A I recall asking Mr. Seelinger sometime 5
6 after this memo, though I don't recall exactly when.
I had asked him where the items stood, and he told me 7
8 they were still under evaluation.
That is the only time that I remember commenting about them to him.
9 10 g
Did you ask him how much longer it was 11 going to take before any of these three items was f
12 resolved?
fg Y. "
13 A
I don't recall asking that, no.
14 Q
Did you have any discussions with any of 15 the others that I mentioned a minute ago -- Mr.
16 Brummer, Mr. Toole, Mr. Logan or Mr. Miller -- about 17 any of these three unresolved open items anytime 18 between May '78 and the day of the accident?
l 1'
19 A
I don't recall.
20 (continued on next 'page) 22 23 24 25
1 Ocwe 434 2
Q Did you have a view as of the 1st of March 3
1979 whether it had taken too long for Met Ed to resolve 4
any one of these three items?
l 5
A I don't recall thinking that much about it 6
during that time period.
I may have, but I don't 7
remember thinking that particular point.
8 Q
Did you have any conversations with Mr.
9 Weaver at any time during the approximately ten months 10 between May 15,
'78 and the middle of M' arch 1979 about 11 any of these three open items?
12 A
I don't remember one way or the other.
13 Q
Did you change your opinion.at any time 14 between May 1978 and the middle of March 1979 as to 15 whether a very serious accident could occur from having 16 water in the instrument air lines?
17 A
I had not changed my mind.
18 I would just like to clarify what may not 19 be clearly understood, what I meant by "a serious 20 accident."
All right?
21 In relationship to that, what I was saying l
22 was that we would have a severe feedwater condensate 1
23 transient, which I knew that the plant was designed to
(~%
-(_)
24 handle safely, but it was that upset that I said could I
25 be very serious, because a loss of feed pump i
o 1
zewe 435 m
_s 2
operationallywise which would result in a turbine 3
trip or a reactor trip would be a serious upset.
4 Q
It was as a result of that kind of an
(
5 upset that you felt. quote, the resultant damage 6
could be very significant, correct?
7 A
Yes, from an equipment standpoint of 8
view from the feed pumps, condensate pump, polishers, 9
from the shock of isolating it at full flow, I felt t
10 that there was a definite potential for, equipment 11 and/or per.s.onnel damage resulting from such a feedwater 12 transient in the turbine building.
(~h V
13 (Recess taken) 14 BI MR. FISKE:
15 Q
Mr. zewe, during the short recess that l
16 we have just had, have you had an opportunity to l
17 look at.the next B&W exhibit, which has been marked l
18 7437 19 (Do c ume n t marked B&W Exhibit 743 for 20 identification, as of this date.)
l 21 A
Yes, I have, i
22 Q
Is that a memorandum which you wrote?
I 23 A
No, it's not.
[N
(,/
24 Q
Is it a memorandum that you eo -authored?
25 A
May I review it first?
1 Zewe 436 0
2 Q
Sure.
3 A
I haven't seen this in a long time.
4 (Witness examining document) k 5
THE WITNESS:
Would you read the last 6
question, please?
7 (Question read) 8 A
Not as I remember.
9 Q
Looking at the last page of this document, the bottom 'of the page?
10 does it have three names at 11 A
Yes, it does.
12 Q'
The first one is D. Weaver, right?
l 13 A
Yes.
14 Q
The second one is W.
Zewe?
15 A
Yes.
16 Q
The third is GPM2 17 A
Yes.
~
18 Q
Is that Gary Miller?
19 A
Those are his initials.
20 Q
Did you see this document at or about the 21 time that it was written?
22 A
This document was written after the 23 March 28th accident.
I don't recall when I was made 24 aware of it.
25 Q
Do you recognize the handwriting on this l
l 1
Zewe 437 O
2 memo?
3 A
I am not sure whose it is.
4 Q
Do you recognize Mr. Weaver's handwriting
(
5 when you see it?
6 A
I.believe I would.
7 Q
Is this Mr. Weaver's handwriting?
8 A
It does not appear to be.
9 Q
Do you recognize Mr. Miller's handwriting 10 when you see it?
11 A
I believe I would, yes.
12 Q
Is this Mr. Miller's handwriting?
13 A
That I am not sure gf.
I think maybe it 14 could be, but I am not a hundred percent sure.
15 Q
Look at the front page if you would, Mr.
16 Zewe, by,the top.
Do you see some numbers and then 17 some names or initials afterwards?
18 A
Yes, I do.
l 19 Q
Do you see the number 1 and then a slash 20 and it says "Zewe" with a little arrow next to it?
21 A
Yes.
22 Q
And another one with a slash and " Weaver" 23 next to it?
24 A
Yes.
25 Q
Does that indicate that you received a
1 Zewe 438
/~hU 2
copy of this memorandum?
3 A
I don't know.
4 Q
If you could look at the first page of
(-
5 this memorandum, Mr. Zewe, about two-thirds of the 6
way down, "The shift before second shif t of the 7
accident there were problems with the resin transfer."
8 Do you see that paragraph?
9 A
Yes.
10 Q
Are the statements in tha t ' paragraph 11 accurate according to your recollection of what was 12 occurring at that time?
,f s t
13 A
Yes.
14 Q
Now, looking at the next paragraph, it 15 says, "The operators would be using 160 psi in 16 deminera.lized water pressure and 100 psi in service T
17 air to try to break the resin brockage per their 18 procedure.
This has the potential of forcing water 19 into the instrument air part of the system if check 20 valve SA-V-402 leaks back."
21 Do you see that?
22 A
Yes, I do.
23
-Q Did you agree that there was that 24 potential?
25 MR. KLINGSBERG:
Wait a second.
Did he
Ii 8
1 Zewe 439 l
(~T
,I
~-).
2 agree when?
[
f 3
Q Isn't it a fact, Mr. Zewe, that you
(
i 4
understood before the accident that there was the i
(
5 potential of forcing water into the service air?
6 A
Yes.
L 7
Q And didn't you also understand that if the 8
check valves did not do their job properly, the water l
9 in the service line could go into the instrument air
[
10 line?
11 A
Yes.
12 Q
Now, directing your attention to the last
's-)
13 page of this memo, do you see that says,
, " Day of s
a 14 incident (after fou'r a.m. and before seven a.m. ) "?
g i
15 A
Yes.
16 Q
That, of course, refers to March 28, 1979, i
I 17 does it not?
I 18 A
I believe it does.
19 Q
The last sentence in this memo s a y s.,
20 "After the trip, Zewe noted that all the outlet g
21 polisher valves were shut."
22 Do you see that sentence?
L 23 A
Yes.
24 Q
Did, in fact, you made that observation 25 after the trip?
i
1 zewe 440 3
_).
2 A
I did.
3 Q
Do you remember how long after four a.m.
4 you found out that the outlet polisher valves were
(
5 shut?
6 A
I don't recall the exact time.
Sometime 7
af ter I had lef t the control room, before I returned 8
to the control room, I was down at the polishers.
9 And that is where I made by observation that the valves 10 were shut.
11 Q
And that was sometime between the trip 12 and the time that the reactor coolant pumps'were O
13 turned off?
f 14 A
That is' correct.
15 Q
Now, the preceding paragraph says, t
16
" Weaver.noted air in instrument air regulators."
17 The Weaver that is referred to there is 18 Douglas Weaver?
19 A
Yes.
20 Q
~
Was he on duty on March 28, 1979 at four 21 a.m.?
22 A
He was not.
23 Q
Did he at some point come to the site?
24 A
Yes.
25 Q
This goes on to say, "He went to dryers l
i
1 Zewe 443 2
on instrument air which indi,cated totally wet.
Also s
3 they got water out air storage tanks.
Checked the 4
c ro s s -co nne ct between service and instrument air at 5
its drain and found water.
A lot of water at each 6
point."
7 Do you see that paragraph, referring to 8
Mr. Weaver?
9 A
Yes, I do.
e 10 Q
On the day of the accident,.did you know 11 that Mr. Weaver had made those observations?
12 A
I believe I did.
[s 13 Q
Did you learn sometime after the accident 14 that valve SA-v-402 had been found open?
15 MR. KLINGSBERG:
Had been found open when?
16 MR. FISKE:
On the morning of the 17 accident, sometime after four a.m.
18 A
I am afraid I am confused.
Are you asking 19 me if I had found that that valve was found open that 20 morning?
21 Q
Yes.
In other words, at any time since 22 the trip at four a.m.
right up to today, have you 23 learned that this valve, SA-V-402, was open at four
. g,/
24 a.m.
on March 28, 1979?
25 A
I did learn after the accident, when they
9 1
Zewe 442 p
2 disassembled the bonnett to SA-V-402, that it was 3
found at that time to be in the open position.
4 Q
Having that valve in the open position
(
5 would permit water to go from the service air lines 6
into the instrument air lines; isn't that correct?
7 A
I would have to review the drawings.
I 8
believe that that would allow water to go from the 9
steam and water supply into the service air lines, e
10 but I would need to review the flow prints to be 11 certain.
12 Q
Well, referring to the statement by the V
13 authorof Exhibit 743, do you see on page 1 at the 14 bottom where it sa'ys, "This has the potential of 15 forcing water into the instrument air part of the 16 system if check valve SA/V402 leaks back"?
Do you see 17 that?
~
18 A
Yes, I do.
19 Q
Did you understand that same potential 20 of forcing water into the instrument air part of 21 the system would exist if check valve SA-V402 was 22 open?
23 MR. KLINGSBERG:
Did he understand when C\\
(_)
24 he got this information after the accident?
25 MR. FISKE:
Yes.
1 Zewe 443 k_)
~
2 A
I would like to review the print to 3
refresh the actual location of SAV402, because as I 4
recall, that valve would result in water getting into k
5 the service air system, and since the cross-tie 6
between service air and instrument air was open, 7
it would then allow it to get in the instrument air 8
system.
9 Q
okay.
10 A
Which I believe is how I readIthe next 11 page, to say that also.
D.
12 Q
The next page of this Exhibit 7437
(
)
2
\\_ /
13 A
Yes.
(
f 14 It says that the water would go back past 15 valve SAV402, which is in the service air system, 16 through the service air and through the open 17 instrument air cross-connect valve SAV356 to the i
18 instrument air system.
/
19 Q
In your memo of May 15,
' 7 8, yo had indicatedon(
20 recommended that SAV356 be moved, as 21 the attached diagram ; right?
22 A
That was my recommendation.
23 Q
And that is the same SAV356 valve that is 24 referred to on page 2 of Exhibit 743, is it not?
N/
25 A
Yes.
~
~~
~~,
1 gewe 444 S
2 Q
Was it your intention, in making the 3
recommendation that you did on May 15, 197 8 about 4
moving SAV356, in' keeping that valve shut, that would k
5 prevent the movement of water from the service air 6
lines into the instrument air lines?
7 MR. KLINGSBERG:
Can we have that again?
8 It is very complicated.
9 (Question read) 10
(
MR. KLINGSBERG:
The question is very 11 confusing.
Either you recast it or the 12 witness can answer it in'his own,words without
'w) 13 saying yes or no.
14 Q
I think you have already answered that 15 question in slightly different form earlier.
Let me 16 put it to you more simply and hopefully only one more 17 time for the record.
You see the sentence at the 18 top of page 2 of Exhibit 7437 It says, "The water 19 would go back past valve SAv402 which is in the 20 service air system, back through the service air to 21 and through the open instrument air (cross-connect 22 SAv356) to the instrument' air system."
23 Do you see that?
24 A
Yes, I do.
l 25 Q
Was it your understanding that if the
Z*"*
445 a
>V 2
recommendation that you had made on May 15,
'78 had 3
been carried out, that that would not happen?
4 MR. KLINGSBERG:
Was it his understanding
(
5 in May 78 or after the accident?
6 MR. FISKE:
Either time.
7 A
My original recommendation was based on 0
the fact'that I thought service air and instrument 9
air should always be isolated from each other and iInpo rtant 10 that instrument air, I felt, was more than 11 service air.
12
(-)
Q And if the instrument air had been isolated k,/
13 from the service air, then the movement of water 14 described at the top of page 2 of this Exhibit 743 15 would not occur; is that correct?
16 A
It is true that if there was water in 17 the service air system, that it would no t b e 18 communicated to the instrument air system if SAV356 19 was closed.
20 Q
Let me show you a document which is 21
- called, "A final report, inspection of the condensate 22 polishing system, Three Mile Island Nuclear Station 23 No.
2, " conduc ted by M. A.
Opeka, assistant chief of OV 24 operations, Engineering Service Division, Goddard 25 Space Flight Center, dated September 12, 1979.
y--
e
,-m
1 Zeve 446 C.
2 We will mark this as Exhibit 744.
3 (Document called "A final report, inspection 4
of the condensate polishing system, Three Mile
(
5 Island Nuclear Station No.
2," conducted by 6
M.A. Opeka, assistant chief of operations, 7
Engineering Service Division, Goddard Space 8
Flight Center, dated September 12, 1979 marked 9
B&W Exhibit 744 for identification, as of this 10 date.)
11 Q
You are free to look at this whole 12 document if you are interested, but I would like to d
13 direct your attention to the statement,at the bottom 14 of page 13, which reads, " Note that check' valve is 15 SAv402 near the polisheris skid was found frozen in 16 the open position after the March 28, 1979 accident."
17 Do you see that sentence?
18
.MR. KLINGSBERG:
Take your timo and look 19 at whatever you need to.
20 There is no question yet.
l 21 MR. FISKE:
"Do you see the sentence," is 22 the question.
23 MR. KLINGSBERG:
Obviously he sees the O
l
()
24 sentence.
You might want to give him the 25 next question before he spends a lot of time.
i
1 1
Zewe 447 V
2 A
I had noticed before I had made a 3
statement that I was aware that this valve had been 4
found in the open position after the accident.
5 Q
Did you learn that it had been found 6
frozen in the open position?
7 A
Yes.
A check valve normally always shuts 8
or it opens up when the water pressure causes it to 9
open.
And for me, for a check valve, when a check 10 valve is found open, it is in the abnormal condition.
11 It should normally be shut when you would inspect it.
12
~s And in fact, I did know that it was frozen 13 open.
14 Q
Mr. Zewe, you said that sometime between 15 the trip and turning off-'
the reactor coolant pumps, 16 you went.down to look at the condensate polishers.
l 17 This is on the morning of the accident.
i 18 A
I went down for other reasons.
But 19 while I was there, I did look at the condensate l
l 20 polishers, i
l 21 Q
And is it correct that there was no l
22 automatic bypass around the condensate polishers in
(
23 effect on the day of the accident?
I 24 A
There was not.
25 Q
Were efforts made to open the manual
1 Zewe 448
].
2 bypass valve COV12 from the control room?
A Yes, there was.
3 4
Q Was there difficulty in accomplishing l
5 that?
A The valve would not open from the control 6
room.
7 8
Q When you went down there, did you try to g
open the bypass valve from that location?
A Yes, I did, manually.
10 gi Q
And did you have any problem in opening it when you were down there?
1.9
(
A No, not as I recall.
13 14 Q
How do you, by what mechanism do you 15 open the manual bypass from that location?
16 A
The valve has a motor operator.
And on 17 the motor operator is a clutch lever and a manual' 18 hand wheel.
You engage the clutch and then turn the 19 manual hand wheel in the open direction to open up i
the valve.
20 ny Q
This is down in the turbine room?
l l
A Yes, it is.
22 23 Q
Isn't it a fact that when you went down
[
there, you had a little trouble finding the manual 94 s
l hand wheel?
25 i
l
. _. - _ = _ _. - _ - _
1 Zewe 449
/~
V) -
2 A
Yes.
The manual hand wheel was not 3
attached to the stem mechanism on the motor operator.
r 4
It had come off and was slid down behind a ventilation I
(
5 duct.
6 I had located it and then operated the 7
valve.
8 Q
How long did it take you to find the 9
hand wheel?
I 10 A
Several minutes.
11 Q
Mr. Zewe, I would like to read to you 12 some testimony that you gave to Mr. Madden and Mr.
13 Rogers from the Inspection and Enforcement Division 14 of the Nuclear Regulatory Commission on April 3, 1979.
15 I am reading from page 42, reading from the bottom l
16 of 42 and the top of page 43.
17 A
one minute, please.
~~
18 Q
sure.
19 A
okay.
f 20 Q
Question by Mr. Rogers.
"Mr.
Rogers:
21 Early in the sequence you mencioned the condensate 22 polishing pumps being shut, the valves being shut.
23 Any idea what caused that to happen?"
)
24 "Mr.
Zewes Yes.
While the incident 25 was still progressing, we.had found that the air
1 Zewe 450 2
system going to the polishers that operates these 3
air-operated valves was full of water and it has 4
happened in the past that water in eur air system
(
5 automatically slowly take's the valves."
6 Do you see that sentence?
7 A
Yes, I do.
8 Q
When you said that,"While the incident 9
was still progressing,we had found that air system 10 going to the polishers that operates th'ese air-
.11 operated valves was full of water," were you 12 referring to the observations that Mr. Weaver made 13 that are contained in Exhibit 7437 14 MR. KLINGSBURG:
I object to he form 15 of the question.
16 Q
Do you understand the question?
17 A
I believe I do, yes.
l 18 I don't know if that's what I mean at l
l 19 that particular time or not.
I 20 Q
When you said in this answer that, "It 21 has happened in the past that water in our air (L
l 22 system automatically slowly takes the valves," were 23 you referring to the incidents in the fall of 1977 24 and May of 1978?
~
l 25 MR. KLINGSBERG:
Same objection.
i
~..-
_ _ _.. -, _ - - - _. - - _. _ _ _,.. -. - - - ~ ~ _ - - - -.
1 Zewe 451 s
2 MR. FISKE:
What is the objection?
3 MR. KLINGSBERG:
If this does not refresh 4
his recollection if it needs refreshing or
(
5 impeach, therefore it is improper.
It is 6
alright for discovery.
I reserve the objection.
7 MR. FISKE:
Would you answer the question?
8 THE WITNESS:
Would you repeat the question?
9 (Question read) 10 A
I believe I was recalling those particular 11 instances, yes.
12 Q
And as you sit here today, do you remember
(~~s)
~'
13 any other incidents other than those two, before 14 March 1978, in which water in the air system had 15 closed the valves?
16 THE WITNESS:
Read it again, please.
l 17 (Question read) i 18 A
You are asking me if I know today of l
l 19 any others that occurred before the March 28 20 accident?
21 Q
Correct.
(_
oo A
Not that I can recall, no.
23 Q
Does listening to the answer from this
/~N l
()
24 testimony that I just read refresh your recollection 25 as to whether there were any such incidents?
i
~_
l' Zewe 452 2
A It does not.
3 Q
Is it correct, Mr. Zewe, that on the 4
day of the accident you did find that the air system
[]
5 going to the polishers was full of water?
6 A
As I've said earlier, I believe that I 7
did find it out that day.
Not that morning, but that 8
day.
9 Q
And after April 3,
1979, Mr. Zewe, 10 approximately five or six days after thh accident, 11 did you have the view that the valves of the 12 condensate polishers had shut because of the water O
13 in the air system?
14
.MR.
KLINGSBERG:
I object to the form.
15 April 3 is what?
16 MR. FISKE:
The day he gave this 17 testimony.
18 A
That was my understanding at the time, 19 yes.
20 Q
Were you asked this ques tio n by Mr.
21 Rogers or did you make this statement in response 22 to the question by Mr. Rogers that I have previously 23 read?
"So I am certain the valves did go shut
(_f 24 because of excessive water in the air system"?
25 MR. KLINGSBERG:
Same objection.
Y w
w-
1 Zewe 453 F
u 2
Q Did you make that statement to Mr. Rogers 3
and Mr. Madden on April 3, 19797 4
A I recall making a statement like that,
(
5 though I don't recall the exact words, but I don't 6
have any reason to believe that this is not accurate.
7 MR. FISKE:
This is a good time for 8
that break.
9 (Recess taken) 10 (Continued on next page) 11 12 13 9
14 15 16 13 I 1!)
20 21 22 23 i
6 25 d--. - - ---
e
-ymem
?
MT'"
?--'Tt5
- W'yef
- P""
-PM'"'*PNW""
P PMFeT S"
W
+"*Mw y
FPv"a
~W
&-T-'
t'
1
-1 1
gewe 454 r
L-)y 2
BY MR. FISKE:
3 Q
Mr. Zewe, since April 3,
1979 are you 4
aware of any investigation or analysis that has been l
5 made by GPU which concluded that the valves in the 6
condensate polishers shut for a reason other than 7
water in the instrument air lines?
8 A
Not that I can recall.
9 Q
Are you aware of any investigation or 10 analysis made by GPU which concluded t6,at water got 11 into the instrument air lines from anyplace other 12 than the service air lines?
/~N U
13 A
Not that I can remember.
14 MR. FISKE:
Off the record.
15 (Discussion off the record) 16 Q
Mr. Zewe, you were shift supervisor on k
17 duty at 4:00 a.m.
on March 28, 1979?
18 A
Yes, I was.
l 19 Q
Mr. Scheimann was the shift foreman?
20 A
Yes, h e w a s.-
21 Q
Mr. Frederick and Mr. Faust were control l
22 room operators?
l 23 A
Yes, they were.
/~T l
()
24 Q
I think you said, going back to the i
25 April 23, '78 transient, that at that time you and
-e
1 455 gewe 2
Mr. Frederick and Mr. Faust were all on the same 3
shift, although you personally had not been on duty 4
on that particular day.
k 5
Do_you remember that testimony?
6 A
I remember the testimony, but I was on 7
duty that day.
I was on a previous shift prior to 8
the transient in question.
9 Q
As of April 1978, were you regularly 10 assigned to a shift which included als$ Mr.
11 Frederick and Mr. Faust?
12 A
Yes.
That was my n'ormal shift.
v 13 Q
Was it your normal shift to be with 14 both Mr. Frederick and Mr. Faust from April '78 15 through March '797 16 A.
As I remember, yes.
17 Q
Is there some policy at Met E'd either 18 for or against having the same group of operators 19 work together all the time?
20 A
It is my view that the policy leans 21 toward having the same people together on shift on a 22 regular basis.
23 Q
Under what kind of circumstances would 24 it have happened, between April '78 and March
'79, 25 that you, Mr. Faust and Mr. Frederick would not have l
1 Zewe 456 2
all been on the same shift?
3 A
I can think of a few instances.
One at 4'
which Mr. Wright was a control room operator on our-l 5
shift for a while and Mr. Frederick was on another 6
shift,.and I am not sure what_ time frame it was that 7
Ed Frederick came to my shift and Lynn Wright went 8
to another shift.
9 Also, if either of those men were sick 10 or on vacation, they would be replaced'by another 11 operator.- And they in turn, if they were on the 12 relief shift, would be working on another shift to O
13 replace their operators for vacation, sick or what 14 have you.
15 Q
Do you recall now when it was in this t
16 time frame between April '78 and March '79 that Mr.
17 Scheimann joined the group?
l 18 A
I don't remember the exact date, but Mr.
19 Lydon was my shift foreman normally.
On April 23 he 20 would have been my shift foreman if I were working i
21 on my normal shift.
l
(-
r l
22 Sometime after that, Mr. Scheimann 23 replaced Mr. Lydon as my shift foreman when he was 24 promoted from control room operator to shift foreman l
[
25 and obtained his senior reactor operator's license.
i Zewe 457 e
2 Q
Could you just very briefly describe what you understood to-be the respective 3
responsibilities of each of the four people that was 4
(
n duty in the control room at 4:00 a.m.
on March 28, 5
6 1979, starting with yourself?
A I had senior management responsibility 7
8 for the station.
9 Q
Does that mean that basically you were 10 in charge of the entire operation until,someone gg senior to you arrived on the scene?
l l
12 A
Yes, until I was relieved by senior O
\\d management, I had that responsibility.
g3 14 Q
What was Mr. Scheimann's responsibility as shift foreman?
15 16 A
operation and control of Unit 2 under my 17 supervision.
18 Q
And then you had two control r'oom 19 operators.
What were their responsibilities?
A Their responsibility was plant operations 20 as directed by the shift foreman and also directing 21 the auxiliary operators in the plant.
\\
22 23 Q
Was there some division of responsibility between the two control room operators?
24 A
Normally control room operators from 25
1 gewe 458 2
shift to shift would alternate.
One night one s
3 control room operator would have primary 4
responsibility of operating the unit, with the other 5
operator acting as his backup and also as the 6
switching and tagging control rcom operator.
Then 7
the next night they would reverse their roles and 8
the other one would act as backup for the former.
9 Q
What does switching and tagging consist 10 of?
11 A
Switching and taggir-is a term that's 12 used to describe one of the duties and i
13 responsibilities of the control room operator in 14 isolating and placing of personal tags on 15 equipment that is out of service for maintenance, to 16 allow protection for the individual working on that 17 particular component.
The control room operator 18 would process the paper work and insure that the 19 plant was in a condition that would allow that 20 component to be isolated and that he would issue the 21 safety tags that would be hung by either himself or 22 the aux. operator in isolating that component.
23 Q
And the safety tag is supposed to tell b j 24 everybody that that particular piece of equipment is s
25 out of service?
6 1
Zewe 459 m.
)
2 A
It is used, one, to provide the 3
isolation to protect the workers and two, to alert 4
the people that that equipment is out of service and l
5 what the status is of that particular component.
6 Q
Are there certain steps that have to be 7
taken by the new shift every time the new shift comes 8
on?
If ycu understand the question.
Maybe it is 9
not too clear.
10 When your shift came on duty, for 11 example, at 11:00 p.m.
on March 27, was there a set 12 list of things that your group had to do righc at
/~%
13 the beginning of that shift?
~
14 A
Yes, there was.
15 Q
What kinds of things did you have to do?
16 A
At each level.
My level, shift foreman's 17 level, control room operator's level or the 18 auxiliary operator level.
They would talk over plant 19 status with their respective watch station that they 20 were relieving and assuming the responsibility for.
21 They would review their logs, logbook, and turnover 22 notes, in that the oncoming shift would be aware of 23 the plant status, what p'7bblems there were, general
()
24 operations that had taken'plac.e of interest.
25 Also the control room staff would look
/~
1l 1
n
---m v-w~-
r
-' ~
-r-
l Zewe 460
/\\
2 at-the switching, tagging book, revision review book, 3
lock valve book, and a lot'of the books that we had 4
mentioned last week that were available in the
(
5 control room.
6 These all were not looked at before I
7 taking responsibility of the' watch, but from tine to E
time during the watch they would be consultei.
9 l
Q Was it part of this regular =hopk 10 procedure that cortain valve positions',would be I
11 -l datermined?
{
h.
c r
]
12 ll A
The effgning shift wotId pass on any n
in abnor411 ties, li'r.e va lves that were out of posi tion.
j Also, the operator that was asuuming the 14 r;
15 watch wculd make a visual tour of the control. room, 16 observing the status.
17 Q
When you say " ope rato r, " who <1o you 18 mean in your shift?
19 A
Everyone that was in the control room.
20 Q
You mean all four of you?
21 A
Yes.
22 Q
Just sort of' eyeball the place to see if 23 anything looks out of line?
24 A
Exactly.
I would scan every panel, 25 electric plant, turbine plant, primary plant, backup
I
_ \\..
1 Zewe 461 2
~
a 2
,sys tems, and make sure that I was aware of its 3
particular status.
4-And if.there was anything that I didn't
(
5 understand or that I thought was out of the norm, I 6
would ask the person that I was relieving to clarify 7
it or I would have sone other checks made.
l!
8 Q
Dil you understand that Mr. Scheinann, 9
Mr. Proderick and Mr. Faust were each going through 3
c 10 that same procedure also?
t-11 A
That was m:r understanding, yes-l 12 Q
N o' ?, the energency feedwater valves are O
e, 13 refer:Ed to scnetiues as the 1 2 ' s.: is that correce?
s's
.l VJ 14 A
There are a ceries of emergency feedwater r
15 valves..,Thi 12's are not-the most important valves.
N 16 So if 'you would ask me that question, I would say no.
v
\\
i
. 17 Q \\
well, let's refine it in light of your
's s
18 answer.
i 19 There are a number of different valves 20 that control the flow of emergency feedwater to the a
21 steam generators; is that correct?
22-A' There are two that are normally 23 controlled.
'(
24 Q
Pardon me?
,i t
25 A
There are only two valves that normally 7
i
~T
.1 y. _
..r,
...__,-L---,_._-,~,
--.,,m-,
-~.-r--
er-
>~ --. + --
- - - = - - - - - - - - - -
1 Zewe 462 4
gg I
'V
'2 control the emergency feed to the steam generators.
3 Q
Do they have numbers?
4 A
Yes. 11-A and B.
(
5 Q
When the plant is functioning normally, 6
I taks it those valves are closed?
7 A
That is correct.
8 Q
What is it that is supposed to open, i
i 9j to open those vs1ves?
Mhat kind of an event?
i-10 l A
Whenever emergency feed iskrequired, 11 either automatically or manually by the operator.
12 Q
Is there some sort of a signal that goes O'
13 to these valves that will open them automatically?
- 14 A
Yes, there is.
4 15 Q
What triggers that signal?
16 A.
Basically there is two signals.
One is, 17 on a loss of main feed pumps, these valves would 18 open up and throttle to control the desired steam 19 generator level.
And on a loss of all four reactor 20 coolant pumps, these valves would again.open up and 1
21 throttle to maintain another desired steam 22 generator level.
23 Q
What is the reason for having emergency r
(_)h 24 feedwater come on when all four reactor coolant 25 pumps are lost?
-,p
-rc,,.
n--
-y,
,e,__
n.- - _ -
p m,
'l Zewe 463 m
-l]
2 A
The primary plant and emergency 3
feedwater is designed to enhance and to promote 4
natural circulation in the reactor coolant system.
l 5
Q How does having emergency fee,dwater.come 6
on enhance the natural circu3ation of the primary 7 -
system?
8 l A
There is two fcctorr that era considered.
9 One is tnat the emergency fec4 water 10 no=zles are located hign in the ence-through stean 1
11 generator ano you are putting in this relatively cold 12 feetwater frem the condensate storage tanks, which
~
13 is outside artient tem 7eratures, and you are 14 apraying them in directly on tubes in tne upper
+
15 portion of the steam generator, thus adding a cooling 16 effect for the water that is in the primary side of 17 the steam generator in the upper end of the steam 18 generator, the hot leg water.
i 19 Also, you raise the steam generator water 20 level to a high level of 50 percent in the operating 21 range, which also promotes natural circulation by i
l 22 having a higher thermal center in the steam 23 generator.
(
24 Q
Now, what are the 12's?
25 A
The 12's are isolation block valves,
~
t n,
..,, -..,.. _.,.. ~...
--,n
1 gewe 464 (Oi g
2 which is downstream of the EFV-11 control valves.
3 Between the 11 valves and the steam generators.
4 Q
When you refer to them as isolation block
(
5 valves, what do you mean by that?
6 A
Basically you have two types of valves.
7 You have valves that are used for control which are 8
either globe. valves or needle valves,or you have gate, 9
valves which are just used to be either open or shut, 10 l'
either to permit fu;.1 flow or to isolate that flow.
11 These were of the latter type.
They were 12 gate valves, used only for isolation if acaded to be D
\\'
13 fully shut or to be fully cpan to permit full flow, 14 but they did not regulate flow.
15 Q
In other words, it was all or nothing 16 with these valves?
17 A
That is their use.
Either wide open or 18 wide shut for isolation.
19 Q
And there were two of them?
20 A
There are two separate emergency 21 feedwater lines, one going to the A steam generator 22 and one going to the B.
And you had a 12A valve 23 which isolated the A feed line and you had a 12B 24 valve which isolated the B feed line.
25 Q
corresponding in each case to the 11A
1 Zewe 465
~~\\
(0 2
and the 11B valve?
3 A
The same idea applied, but there vere 4
other valves in the emergency feed system, like
(
5 EFV-33 and 32A and B that provided parallel paths 6
around the EFV-11's.
But the EFV-12's were the bloch 7
valves.
8 Q
So that the 12's blocked all paths, not t
9 just the path through the 11; is that correct?
10 A
Yes.
11 Q
At all times during normal operations 12 the 12 valves were supposed to be open?
13 A
Yes, they were.
14 Q
Were there any circumstances which 15 permitted closing the 12's?
16 A.
Yes, there was.
17 Q
What were they?
18 A
surveillance testing.
19 Q
What is the purpose of surveillance 20 testing?
21 A
It depends on the surveillance that you 22 are testing.
23 (Continued on next page) 24
,m, 25
i Zewe 466 Iu 2
Q Generally what is the purpos e of 3
surveillance testing?
4 A
The general purpose of surveillance
(
5 testing is to prove and to insure that the 6
particular component that you are testing still l
7 meets its design capability.
8 Q
And whau components would you be 9
testing that would involve closing the 12's?
10 A
Surveillance testing involvi,ng the l
11 emergency feedwater pump testing.
12 Q
Any other?
O 13 A
The only other time that those valves 14 would be cycled would be if the valves themselves 15 had had some maintenance performed on them and if 16 they were being checked to make sure that the 17 operator and the valve had been repaired as a 18 result of that maintenance that was performed.
19 Q
Was it part of the responsibility each 20 shift to determine, at the beginning of the shift, 21 that the 12's were, in fact, open?
22 A
It was the responsibility of the shift f
1 23 to look over the control room and t6 gain whatever
()
24 understanding they could.
But in relationship to 25 those particular valves, it was not a pointed-out
Z8W8 1
467 responsibility to check those particular valves any 2
more than checking any number of other valves.
4 Q
Was there any kind of a procedure at Met 5
for regular periodic checking of those valves to Ed
(
determine that they were open?
6 A
I don't recall at this
- t. ime, though I 7
8 believe they were on the lock valve list, and that the lock valve list is checked periodically to insure g
that the valves listed in the lock valve checklist 10 gg are in the desired locked position.
12 Q
Lo you know the last time that that had been done before eleven p.m. on March 2'7?
g3 A
I do not.
14 15 Q
When that kind of a check is made, is there some written record of it?
16 A
Yes, there is.
17 18 Q
What kind of a written record?'
gg A
There is a lock valve checklist *that is checked. The particular valve line-up for that 20 particular emergency feedwater system has it listed 21 and signed off for the correct position at the 22 23 particular time of the check.
O Q
It is fair to say, is it not, Mr. Zewe, q
(
~
eleven p.m.'on March 27, 1979, those 12 that as of 25
3 1
Zewe 468 2
valves were supposed to be open?
3 A
My understanding was that they were open.
4 Q
How did yousobtain that understanding?
l 5
A only from the negative side of it, that 6
I did not know that they were closed.
I had assumed 7
that they were open.
8 MR. FISKE:
Off the record.
9 (Liscussion off the record) 10 Q
Where were you on March 28,at four a.m.
I 11 on March 28, 19797 12 A
In my off. ice in the rear of the Unit 2 O
13 control room.
14 MR. FISKE:
Mark this as 745.
15 (Diagram of Unit 2 control room layout 16 marked B&W Exhibit 745 for identification, as 17 of this date.)
18 Q
Let me show you, Mr. Zewe, a document 19 that has been marked as B&W Exhibit 745, and ask you
~
20 if you recognize this as a disgram of the Unit 2 21 control room layout, 22 A
Yes, I do.
i 23 Q
Your office is reflected on this diagram?
/^\\
yd 24 A
Yes,it is, i;
25 Q
Can you just give us some idea?
What is
4 1
Zewe 469
\\
~
the distance between the nearest part of your office 2
3 and the part of the control panel which is marked 4
feedwater console?
l 5
MR. KLINGSBERG:
What is this from?
6 MR. FIS KE :
One of these post-accident 7
reports, I guess.
TDR.
8 A
Thirty feet.
9 Q
Is this, by the way, a generally J
10 accurate reflection of the layout of the control
'll room?
12 A
Yes, it is.
'O 13 Q
Do you see the section of this marked a
14
" computer console"?
15 A
Yes.
i 16 Q
What instrumentation was located there?
L 17 A
A Bail ey. A55 computer.
1 18 Q
Is that were the alarm printed was?
I
~
19 A
Yes, it was.
20 Q
Is that where the utility printer was?
21 A
Yes, it was.
22 Q
The sequence of events review?
i 23 A
Sequence of events printout and a
(
24 utility-type writer.
25 Q
The analog trend recorders, were they at c-.. -,
-,,,_,--,~-,,.,--.-_-.,%.--m.....
r._-.-..
._.--___,.v___.w-.
.-,--,,_+--me 3
,-.v---
1 Zewe 470
- 2 that console?
3 A
Yes, they were.
4 Q
What is the first thing that came to your
(.
5 attention at or about four a.m.
that indicated to 6
you that something out of the ordinary was going on?
7 A
The sound of alarms.
8 Q
So what did you do?
9 A
I left my office and proceeded ou t to 10 the control room area.
t 11 Q
What did you observe when you got out 12 there?
(~)
\\/
13 A
Turbine trip alarm and reactor trip 14 alarm.
15 Q
What happened next?
16 A
As I remember, I yelled out, " Carry out 17 the action for a turbine trip, reactor trip," and 18 I announced it on the page phone system.
We just
[
19 call it the page.
I 20 Q
Are the actions to be carried out for 21 turbine trip and reactor trip spelled out in any 22 procedures?
23 A
Yes, they are.
[)
24 Q
Which procedures?
'% )
25 A
Reactor trip emergency procedure, turbine
1 Zewe 471 i.
2 trip emergency procedure.
3 Q
Where were Mr. Frederick and Mr. Faust 4
at this point?
(
5
'A At the' operator console.
6 Q
Where is the operator console on this 7
diagram, Exhibit 74S?
8 A
'.'he area between the CRO desk and the 9
panel there that is marked with pressurizer level, 10 pressure, temperature, flow, power.
t 11 Q
Are there certain basic actions that have 12 been taken when there is a reactor trip ans a turbine N
13 trip?
14 A
Yes, there is.
15 Q
What are they?
16 A
They are the manual actions that are 17 listed in the body of the procedures.
18 Q
Can you tell us what they are without 19 refreshing your memory from the procedures or would 20 you like to see the procedures?
21 A
If you have them available, I may as well 22 use them.
23 Q
We have them available.
24 A
They have changed between what they were s-25 then and they are now.
.. ~..
i t
1 I
t I
-1 gewe 471 A i
l :
2 Q
Well, obviously we are interested in what 1
3 they were then.
t 4
A Exactly.
h
('
5 (continued on next page) 6 1
7-4 s
5 8
1.
9 1
1 r
10 t
l 1
i 11-i t
f' 12
~
t i
i 13 t
l.
14 1
f
[
1 l
16 f
17 i
1 18 19 20 l
r 21 22 1-t 23 1.
I Qj i
25 i
--,,,r-,n,--
,,._n,-.,,___n,
I 1
Zewe 472 4
2 MR.-FISKE:
The reactor trip procedure 3
will be marked B&W 746.
4 (Four-p age document relating to Unit #2
(
5 emergency procedure 2202-1.1, reactor trip, 6
was marked B&W Exhibit 746 for identification; 7
as of this date.)
8 Q
Do you hase the reactor trip procedure in i
g front of you, Mr. Zcwe?
i 10 A
Yes, I do.
t 1
11 Q
Page 2 contains the manu,al actions, does t
12 it not?
+
13 A
Yes., it does.
~
14 Q
Just looking at that now, can you tell us 15 which of those actions was appropriate for the d
16 conditions as you saw them in the first few seconds i
17 of this transient?
18 A
You are asking which ones apply?
19 Q
Yes.
20 A
Let me make sure I understand.
You want i
21 to know which of these actions applied that particular 22 morning?
23 Q
Yes.
()
24 A
0.K.
(a) applies, (b) applies, (c) 25 applies, (d), Ce ), (f).
.1 Zewe 473 7's
~
(
)
v 2
No stations were in hand, so (g) did not 3
apply.
4 It did not go below 80 inches, so that Ih 5
didn't app.ly.
6 Q
Ch) didn't apply.
7 A
(1) did not apply, and fi) did not apply S
because,wa.did not have anything else in hand.
9 Q
(d) says, "CLOSE letdowa isolation valve 10 MU+v376."
Right?
II A
Yes, it does.
Q What is the retson to do that after a 13 reactor trip?
l 14 A
To limit the reduction in pressurizer 15 following a reactor trip.
16 Q
In other words, closing the letdown 17 isolation valve prevents any water from leaving the f
I l
19 A
From that particular path, yes, t
l l
20 Q
(e) says, " START second make-up pump.
t i
21 Open MU-V-16B as necessary to maintain 100 inches in l
22 pre ssurizer. "
l l
23 I take it the purpose of that step is also f~())
24 to maintain pressurizer level at 100 inches?
25 A
It is to maintain pressurizer level greater
1 Zewe 474' 2
than 100 inches, ye's.
3 Q
Which operator did those two things?
That 4
is, close the letdown isolation valve and start the
(
5 make-up pu.mp.
6 A
I believe it was Mr. Faust.
7 Q
Then the next one says, " Verify turbine 8
bypass control valves are maintainir.g he ade r pre ssure t
i hl at 2010 psig."
9 i
10 What is header pressure?
j 11 A
Header pressure is the main steam header 12 I that is going to the main turbine.
13 Q
That refers to pressure incthe ateam t
14 generator; correct?
15 A
Pressure from the steam generator, but not 16 actually pressure in the generator.
In the line down-17 stream between the generator --
18 Q
And the turbine.
19 A
and the turbine.
20 Q
Why was that important?
21 A
on a reactor trip, you automatically change 22 the turbine bypass control valve setpoint at which 23 they control that.
And you are just verifying that (Q) 24 this change to a new s e tpoin t has occurred.
25 Q
Which operator was doing that?
l i
1 zewe 475 p
i i
s/
2 A
I don't recall which operator it was that 3
verified that portion.
4 Q
Was any immediate action required, Mr. Zewe, 5
with re spe,ct to the steam generators?
6 A
What do you mean by "immediate action ?
j d
7 li Q
Well, the reactor trip precedure specifies l
8 varioua manual act. ions that have to be taken after a 3 '[h raccher trip, and so-far I don't son a'ny that relate to 10 the s te am gener.a tors.
I was simply asking whether there 11
+
were any on that day that had to be taken that related I2 I ta r..l e steam generators.
-~
s) j 15 MR. KLIMGSBERG:
The witness, asked to be 14 shown the reactor trip procedure and the turbine 15 trip procedure.
16 g
we.will show you the turbine trip procedure i
17 also which will be marked Exhibit 747.
18 (Five-page document relating to Unit #2 19 abnormal procedure 2203-2.2 turbine trip was 20 marked B&W Exhibit 747 for identification, as 21 of this date.)
22 Q
You have the turbine trip procedure in i
23 front of you?
I
's /
24 A
Yes, I do.
25 Q
Go ahead.
I 1
Zewe 476 O.U 2
A Several of the manual actions directly 3
affect steam generators.
4 Q
Which ones?
()
5 A
Verifying that the turbine has tripped 6
directly affecta the steam generator parameters.
~
i 7
Verifying _that the turbine bypass control valves are 0
6 3 j; maintuining header pressure directly affect steam i
l 9
generator conditions.
II.a feedwater station were in 10 y hund, they would directly affect it.
5f you_had any I
11 l other'of a number of ICS station mentioned in item 5
+
(j) that were in hand could directly affect it.
)
12 h O
t 13 Q
I think you have already said that none 14 of those things were applicable on the day of the a 15 accident.
16 A
O.K.
I took this question more I
17 Q
No, I am sorry.
18 A
-- broader.
19 Q
It was simply, on the' day of the accident, 20 was the re any manual action under either the reactor 21 trip procedure or the turbine trip procedure which 22 had to be taken which involved the steam generators?
l 23 A
All right.
Other than the ones that I have 24 already mentioned under the turbine trip procedure 25 number 5 I'm sorry.
Those are the only ones under
. ~. -.
1 Zewe 477 2
the immediate and manual actions in either procedure 3
that apply.
4 Q
I guess I am not quite clear as to what
(,~
5 you me an by "those " are the only ones, because'you did 1
6.h mention a few that I think we agreed are not
. 18 7
appli c able.
I E'i 3 l 3L. KLING3 BERG:
What?
f
~
9 A
Now I an co.sfused.
You asked me knich 1
1 l
10 ones apply.
And I li If j
11 Q
Which ones were appia able to the steam I
12
'j i
generators ca the day of the eccident?
g
]
13 3:R. KLINGS3 ERG:
Which ones.affected the 14 steam generators.
15 A
And I said number (c) under, manual in 16 the reactor trip, verifying that the turbine trip, l
17 was one.
~~
18 And number (f), the turbine bypass t
19 control valve maintaining header pressure at 1010, were 4
20 two that applied.
21 Q
Were there any in the turbine.' trip 22 procedure that applied?
23 A
Yes.
Number 1 under " Manual Action."
b).
(,
24 Here again, you verify that the turbine had tripped.
25 And number -- no.
Those are the only ones.
.. _., _ _. -. _.,.. _.. ~. _ _... _ - _.. _., _-.
b s
4 1
Z*We 477-A 9
l 2
MR. FISKE:
We can stop for today.
3 (Time noted:
4:38 o ' clock p.m. )
4
.(
5-l 6 {,
William II. " awe g-yl 1
7 [
Subscribed and sworn t.o before ne l
l
'E tnis day of 1s82.
c i
9 [,
)
i 1
f 10
(
i g
_yy Notary Public:
t 12 1 '..
13 0
14 15 16
?
j' 17 18 19 i
I 20 21 1
i
' k-I i
22 t
1 23 i
f O
24 1-4 25
478 1
,~~
kT CERTIFICATE 2
STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
)
4 n
l I,
HARVEY B.
KRAMER, RPR, CSR a Notary Public of the State cf New York, do hereby l
certify that the continued deposition of u
W:.-,LILN 1-iEWE
_ uss taken before l
Tuh.s dc y,. May 25, 1962 me on
. ____.consistiI;g g
of pages_353
<g,ough_477 A1J t
,0 2
14 1
I f;n'ther certify that the witness had 11.,
l i
been previously sworn and that the within
,A 12l k'
I tr.inscript is a true record of said test *neny; 13 That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am,I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, I have hereunto set my 19 hand this-YIr day of d < ! rd '[5
,1982.
20
-(b.
21 22
/
h,O,% i l( L.. e r wi'.'.h t
(Q HAR'VEY B.
KNAMER, RPR, CSR
'v' 24 25 L
479 i
=-
I NDE X (s,
I WITNESS PAGE WILLIAM H.
- ZEWE, Resumed 353 EXH I E I T S BEW FOR IDENTIFICATION l
l 742 collection of pages from the FSAR I
for Unit 2
(
105 i
743 Memorandum 435.
1 t
744 Document e n tit *.e d A final, report, inspection of the condensate <
. polishing system, 'fhree Mile Island Nuclear Station No.
2,"
dated September 12, 1979 446 745 Diagram of Unit 2 control room layout 468 746
_Four-page document relating to.
Unit #2 emergency procedure 2202-1.1,, reactor trip 472 747 Five-page document relating to
($
Unit #2 abnormal procedure 2203-2.2 turbine trip 475 f
oOo Q
~
.~.
[. -
.T 4
3 m,
., _..