ML20072H820
| ML20072H820 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/28/1982 |
| From: | Zewe W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-06, TASK-07, TASK-1, TASK-6, TASK-7, TASK-GB NUDOCS 8306290760 | |
| Download: ML20072H820 (62) | |
Text
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UNITED STATES DISTRICT COURT pg SOUTHERN DISTRICT OF NEW YORK bk
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GENERAL PUBLIC UTILITIES CORPORATION, t
h' ',
JERSEY CENTRAL POWER & LIGHT COMPANY,
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METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCCCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
Defendants, t :
- - - - - - - - - - -x i
Continued deposition of GPU NUCLEAR CORPORATION, by WILLIAM H.
ZEWE, taken by The Babcock & Wilcox Company, pursuant to l
adjournment, at the offices of Davis Polk &
Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Friday, May 28, 1982, at 9:40 o' clock in the forenoon, before Harvey B.
- Kramer, R.P.R.,
Certified Shorthand Reporter and Notary Public within and for the State of New York.
g6Eoe oW$
I, T
DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS i.
369 LEAINGToN AVENUE WALTER SHAPIRO, C.S.R.
NEW Yo mic. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELE PHo N e 212 - 867 8220
t 792
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2 Appearan ces :
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
4 Attorneys for Plaintiffs 425 Park Avenue
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By:
ANDREW MacDONALD, ESQ.,
i of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By:
ROBERT B.
FISKE, ESQ.
-and-12 WILLIAM E. WURTZ, ESQ.,
4 of Counsel 13 14 l
KILLIAN & GEPHART, ESQS.
15 Attorneys for the Witness Box 886 16 Harrisburg, Pennsylvania 17108 17 By:
KEVIN WALSH, ESQ.,
of Counsel 18 19 20 Also Present:
21 JONATHAN QUINN, Law Assistant
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Davis Polk & Wardwell, Esqs.
22 23
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24
'a r s
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25 s-
l 1-(
2 WILLI AM H.
Z EWE, resumed, having 3
been previously duly sworn, was examined and 4
testified further as follows:
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5 EXAMINATION (CONTINUED) 6 BY MR. FISKE:
7 Q
Mr. Zewe, going back to the period of time 8
after you came back from the turbine room and before 9
the second set of reactor coolant pumps was turned 10 off, did you obtain any information during that period 11 on the temperatures at the discharge line?
12 A
I don't recall the exact time, but I had i
13 asked for another set of discharge line temperatures.
14 Q
Well, without holding you to the precise 15 minute, did you make that request sometime during the IS general time period that I just referred to?
17 A
As I recall, yes.
18 Q
Who did you ask to get those temperatures?
19 A
Mr. Bryan.
I 20 Q
Was there any particular reason why you P cked Mr. Bryan?
i 21 22
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A The availability of Mr. Bryan.
23 Q
And what did he do?
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24 A
He told me what the tailpipe temperatures 25-were at~that time.
s
1 Zewe 794
' k 2
Q How long did it take him to give you that 1
3 information after you had made the request?
4 A
As I recall, a fairly short time.
Within
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5 a couple of minutes.
6 l
Q Did you have any understanding as to how 7
he had obtained that information?
8 A
I assumed that he got them from the 9
ccmputer.
10 Q
What did he tell you the temperatures were?
11 A
I don't remember the exact readings.
But l
12 th.e readings were around 228 or 232, around there 13 somewhere.
14 Q
Did he give you a reading for each one of the 15 the three valves?
16 A
As I recall, yes, he did.
17 Q
And was the temperature for any one of the 18 three valv,es higher than for any of the others?
4 19 A
I don't remember making that distinction, l
20 though I am sure they were not exactly the same, so 21 one would have to be higher than another, but I don't
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l 22 remember differentiating between the three.
I 23 As I recall, they were all grouped
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24 closely together, around 230 degrees, and that's about 25 all I remember of that reading.
1 Zewe 795 2
Q Was one of the reasons why you asked Mr.
3 Bryan to get those temperatures to consider whether or 4
not any of those three valves might be open?
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5 A
As I recall, I did not do it because I 6
suspected that any of the three valves were open.
7 As I recall, I did it more in the course of follow-up, 8
and I don't remember dwelling on that particular point.
9 I had just asked for them, and he gave them to me, in 10 just the normal course of events that I'.had asked.
11 Q
What relevance did you think those 12 temperatures had to the problems that you were dealing
?
13 with at that time, other than their indication of a 14 possibility that one of the valves was open?
15 A
As I have stated, I did not feel that or 16 even suspect that the valves were open.
I don't 17 recall precisely what I was thinking at that particular 18 time that I had asked Mr. Bryan for the numbers, again.
19 I just remember that I did, and those were the numbers 20 he gave me.
21 Q
Can you tell us today, Mr. Zewe, any
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22 reason why you wanted those numbers, other than the 23 possibility that one of those valves was open?
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24 MR. MacDONALD:
I object.
He has 25
-answered part of that question already and
1 ZEMS 796 2
given you the reason why he asked for them.
3 MR. FISKE:
I don't think he has.
That 4
is why I am asking the question.
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5 Do you want to hear it again?
6 THE WITNESS:
Yes.
7 (Question read.)
8 A
Again, I don't remember considering that 9
the valves were open, but I was interested at the time 10 in what the line temperatures were.
I'had asked for 11 them before, and I had asked for them at that 12 particular point, though I don't remember exactly for 13 what one or two reasons I had asked.
But I do not 14 remember thinking that it was because I felt that 15 they were open.
16 Q
or that they might be open?
17 A
Or that they may be open.
18 Q
Does that answer that you just gave apply 19 to both times that you asked for the tempe'ratures?
20 A
Yes, it does.
21 Q
Did you at some point learn that at the
(..
22
. time Mr. Bryan obtained the temperature readings the 23 second time, that the temperature for the PORV was 1
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24 283 degrees and that the temperatures for the two 25 code safeties were 211.and 218?
l
1 Zewe 797 2
MR. MacDONALD:
Are you asking whether he 3
learned it on the day of the accident or at any 4
time?
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5 MR. FISKE:
At any time after he made the 6
request of Mr. Bryan.
7 A
Up to the present day?
8 Q
Yes.
9 A
Yes, I did learn that.
Because I reviewed 10 the printout sheets from the utility typer.
And I 11 read at that particular time period that he had asked 12 for them.
And I have -- since I have looked at that i
13 sheet, yes, 14 Q
When was the first time that you looked 15 at the utility printer?
16 MR. MacDONALD:
For the particular 17 temperatures?
18 MR. FISKE:
Yes.
19
-A I don't remember.
But it was several days 20 after the accident.
But I am not sure exactly when 21 that was.
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22 Q
Now, Mr. Zewe, going back'to the reactor 23 coolant pumps, I think the chronology evolved by GPU l
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24 shows the first two pumps were turned off about 5:15 l
25 and then the second set of pumps was turned off at i
1 gewe 79g
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2 about 5:40, 3
Were you involved in the decision to turn 4
off the first set of pumps?
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5 MR. MacDONALD:
Are you asking him in 6
that question about 5:15 to the best of his 7
recollection if the witness was involved?
You 8
had stated that, but I don't know if that was 9
incorporated in the question.
10 Q
The question is simply:
Wdre you 11 involved in the decision to turn off the first set of 12 r'eactor coolant pumps?
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13 A
It was my final decision to do that.
14 Q
Who else participated in that decision?
15 A
Mr. Kunder, Mr. Bryan, and the rest of the 16 operating shift in the control room at the time.
17 Q
Scheimann, Frederick and Faust?
18 A
That is correct.
19 Q
So in other words, everybody who was there 20 at the time participated in the decision?
21 A
Everyone participated in the discussion
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22 about the pumps.
It was my final decision to secure 23 the pumps.
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24 Q
Did any one of the people-you just named 25 express the view that the pumps should not be turned
1 gewe 799
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2 off?
3 A
Should not be turned off?
4 Q
Yes.
5 A
As I remember, there was a reluctance on g
6 the part of one of the operators.
I do not remember 7
which one it was.
He had expressed that maybe we 8
should not.
But the general consensus was that we 9
should protect the pumps.
10 Q
What was the reason given by the operator 11 who expressed the reluctance?
12 A
Maybe I should state it another way.
t' 13 I think that we were all hesitant all 14 right -- to secure the pumps, because it would not 15 have been a normal thing to do under normal 16 conditions, but that I felt I should do it in order 17 to protect the pump.
18 I don't recall the one operator that 19 expressed reluctance saying other than in general 20 terms we should not secure the pumps, but not for 21 any particular reason as I remember other than in
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22 a general case.
1 23 Q
Was there any reason why only one set of
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24 pumps was turned off at that time?
25 A
Yes.
I wanted to maintain RCS flow.
I
1 Zege 800
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2 didn't want to go straight to natural circulation.
i 3
Q Did you believe that leaving one set of 4
pumps on would allow you to maintain RCS flow without
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5 going to natural circulation?
6 A
As long as I have coolant pumps running, 7
I will not go to natural circulation.
And I had hoped 8
that whatever the problem was with the pumps, that 9
if I reduced the flow, that that would allow the two 10 remaining pumps to continue to operate'and circulate 11 reactor coolant.
12 Q
And then approximately 25 minutes later, 13 the second set of pumps was turned off; correct?
14 A
As I remember, that is correct.
15 Q
And did you make that decision?
16 A
Yes, I did.
17 Q
And did the same people participate in the 18 discussions leading to turning that set of pumps off 19 as had the first time?
20 A
Yes.
21 Q
And what was the reason why you decided 22 to turn off the second set of pumps?
23 A
I felt that the conditions indicating the
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24 status of the pumps was still deteriorating on the two 25 remaining pumps, and that I felt it was best-to secure
801 i
zewe
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l 2
those two pumps to preclude any damage to those pumps.
3 Q
In the course of your career up to that 4
point, Mr. Zewe, had you ever had experience with 5
running pumps beyond their normal operating limits?
6 A
I did not have experience on running the 7
pump past her normal operating limits, either at the 8
Island or B&W in transient response training.
9 Q
Did you have an understanding, from your 4
-10 training experience or otherwise,
that the limits gg that were prescribed for the pumps were for normal i
12 operations?
Putting it another way, that normally the 13 Pumps should not be operated beyond those limits.
14 A
I was aware of the pressure / temperature 15 curve for operation of the pumps.
I knew that that 16 curve was conservative and that the pumps were actually 17_
designed for lesser temperature and pressure J
18 relationships, but by staying on the proper side of
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19 that particular conservative curve, that.the pump W uld be perated well within its normal operating 20 i
21 capability.
j
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22 Q-At the time you turned the pumps off, did i
~ 23 you believe that the pressure / temperature relationship i
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24'
.had reached the level below the net po.sitive suction l
25 h.ead curve that you just referred to in your last l
l I
1 Zewe 802 k
2 answer?
3 A
(No response.)
4 Q
Did you follow my question?
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5 A
Yes.
6 As I recall, we were either right at the 7
curve or slightly on the wrong side of that curve, 8
though I don't recall exactly what position we were.
9 I felt that we were coming close to our 10 actual limit, but I didn't have a good feel for how 11 far beyond the conservative curve I could go without 12 pump damage.
So I was just precluding that operation t
13 of the pump so that there would not be any damage, by 14 securing it.
15 Q
Did you feel that you could not go any 16 further below the curve without incurring pump damage?
17 A
As I recall, I was thinking that I had'the 18 high vibration, the low amps, the reduced flow, plus 19 looking at the curve I felt that it was in the best 20 int'erest of trying to. protect the pumps to secure it.
21 I didn't think, well, how much more room 22 did I have before I have damage?
I was trying to 23 secure the pump based on not having damage, but I
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24 really didn't have a gauge to say that-I could go this 25 much more beyond the curve.
I didn't have that feel
1 Zewe 802-A i
2 for when the damage would occur.
I was just trying to 3
prevent any damage to the pumps.
4 (Continued on the next page.)
6 7
8 9
10 t
11 12 e
13 14 15 16 17 18
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19 20 21
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22
-23
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24 25
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Zew*
803
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2 Q
Was there any discussion at the time the se nd gr up pumps were turned off as to whether or 3
not that was the right thing to do?
4 A
I don't recall any discussion at that point
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5 other than we collectively agreed that we should 6
protect the pumps.
7 g
Q Did anyone in the group express any reluctance to turn off the second set of pumps?
g A
Yes, I believe that we all had some 10 reluctance, some inherent, you know, reluctance to 31 12 securing pumps.
But we felt th a t the action was i
~
necessary under the conditions that confronted us.
13 14 Q
What was the reluctance to secure the pumps based on?
15 A
Just that it is not a normal thing to do 16 17 to go to natural circulation as long as you still had 18 power to the reactor coolant pumps themsel'ves.
The 19 only time that you would be forced into going natural t
circulation cooling would be if you did not have the pumps available.
g
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In this case they were available.
But we 22 had made the decision to secure them to preclude the 23 I
damage.
24 Q
Did Y u Participate in any discussions as 25 l
r 7
m
22B 1
Zewe 804
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2 to whether you would be able to achieve natural cir ula tion?
3 4
A As I recall, the people present in the 5
control room, includ'ing myself, expected that we would
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6 he able to achieve natural circulat. ion.
7 Q
Let me show you a document that has 4
8 previously been marked as part of Exhibit 275.
9 275, I guess, is the LER which we have 10 referred to periodically throughout this deposition, 11 the LER that was filed with the NRC by GPU in 12 September 1981.
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13 I direct your attention to page 27.
14 A
What was that again?
I'm sorry.
~
15 Q
27.
16 MR. FISKE:
Well, let me withdraw that 17 last question.
18 Q
Did you see that LER at any time between the
~*
19 time it was filed with the NRC and'today?
20 A
Yes, I did.
21 Q
so you saw it in its initial form?
k 22 A
Yes, I believe I did, yes.
23 Q
Did you also see various drafts of this
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24 LER chronology as it was in the process of preparation?
25 A
Yes, I did, i
1 Zawa 805
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2 Q
Let me show you a document that we will mark as B&W Exhibit 758'for identification.
3 4
(Document consisting of a draft of
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5 chronology, dated July 16, 1979 was marked 6
B&W Exhibit 758 for identification.)
7 Q
Do you have Exhibit 758 in front of you, 8
Mr. Zewe?
9 A
Yes, I do.
10 Q
That is a draft of this chronology, dated 11 July 16,1979; is that correct?
12 A
Yes.
13 Q
Do you see the writing on the first page 14 of this exhibit?
15 A
Yes.
16 Q
What does that say?
17 A
"Zewe's comments 9/ 11/79."
18 Q
Whose handwriting is that?
19 A
I don't know.
20 Q
I would like to have you turn the pages of this exhibit with me for a second.
Would you look 21
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22 at page 1.
23 A
Page 17
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24 -
Q Page numbered 1, which may be like the 25 third or fourth page in.
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43 1
Zewe 806
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2 A
Yes.
3 Q
D y u see some handwriting on that page?
4 A
Yes.
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5 Q
Is that yours?
6 A
Yes, it is.
7 Q
Skipping over to page 3,
is that your 8
handwriting?
9 A
It looks like it's mine, yes, 10 Q
How about page 57 i.
11 A
Yec.
12 Q
67 13 A
Yes.
14 Q
77 15 A
Yes.
16 Q
97 17 A
I don't see any writing on page 9.
18 Q
I am sorry.
30?
19 A
Yes.
20 Q
11?
A Yes.
21 22 Q
-127 23 A
Yes.
24 Q
13?
A Yes.
25
SB 1
Zewe 807
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0 147 2
A Yes.
3 4
g 15?
A Y*8-(T 5
6 g
167 A
Yes.
7 8
Q By "yes" in all these answers, you are 9
indicating that the handwriting on that page is yours; 10 correct?
11 A
As far as I can determine, yes.
,12 Q
All right.
That is the pending question 13 for all these pages.
A Yes, I understand that.
14 15 Q
All right.
17?
16 A
Yes.
17 g
187 18 A
Yes.
19 Q
To save time, Mr. Zewe, at this~ point why 20 d n't you just go through the rest of this document 21 page. by page and let me know if there is any writing i
that appears on any of those pages that you do not 22 23 recognize as your own.
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24 Do you understand?
A Yes, I do.
25
l 1
Zewe 808
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2 I have r.eviewed through page 57, I believe.
And all the comments that I see appear to be ones that 3
4 I made.
5 Q
Thank you.
({
6 I would like to direct your attention to 7
page 28.
8 A
I have page 28, 9
Q There is a paragraph there that refers to 10 a time of 1:54.
t 11 Do you see that?
12 A
Yes, I do.
13 Q
Do you see the notation on the right-hand 14 side of that that says, "Two pumps on at 1,000"?
15 A
Approximately a thousand, yes.
16 Q
Does that little sign there mean 17 "approximately"?
18 A
As I remember, it does.
19 Q
Okay.
And what pumps were you' referring to 20 when you wrote that comment?
A Two makeup pumps.
21
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22 Q
I think we have established before, have we not, Mr. Zewe, that the makeup pumps are the pumps 23
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24 which also regulate high-pressure injection flow?
A The valves' regulate the flow.
The pumps 25
7D 1
Zewe 809
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2 supply the pressure in the water.
They are one and 3
the same pumps.
4 Q
Did you write that comment on this draft l
({
5 chronology.sometime between July 1979 and September 11, 6
19797 7
A I don't know exactly when.
8 Q
Was it in that general time period there, 9
about July through September 19797 l
10 A
I assume it was.
11 Q
Before you wrote that comment in that 12 draft chronology, you had stated to various people at I
13 Met ED that at or about the time the second set of 14 reac, tor coolant pumps were turned off, makeup or 15 high-pressure injection flow had been increased; is 16 that correct?
17 A
As I recall, yes.
18 Q
And at the time you wrote the comment 19 that is reflected in Exhibit 758, it was your 20 recollection that the flow was approximately a thousand 21 gallons per minutes is th at correct?
's 22 A
That's what I remember, yes.
23 Q
Let me show you another document which we
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24 will mark as Exhibit 759, which is ano~ther portion of 25 this same annotated sequence of events.
It consists p
-v
8B 1
ZeWe 810
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f a memorandum from Mr. Miller to a number of people, 2
dated July 13, 1979.
3 (Document consisting of memorandum 4
fr m
- r. Miller, da W W D,
(
5 6
1979, was marked B&W Exhibit 759 for identification.)
7 g
A I have it before me.
9 Q
You are listed as one of the people who 10 received that draft of the chronology from Mr. Miller, 11 are you not?
12 A
I belie ~e I was, yes.
v 13 Q
I would like to direct your attention to 14 page 27.
A I have page 27, 15 16 Q
D y u see the handwritten notation there at the time indicated as 1:407 37 18 A
Yes, I do.
19 Q
Does that read " operators manually initiated 20 full HPI prior to tripping pumps"?
A Yes, it does.
21 L
22 Q
Do you recognize that handwriting?
A I d n
t.
23 Q
Then there is a parenthes.s.
" Previous
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24 c mmen."
en says "per W.
Zewe "
25
811 Zawa D
y
(
Do you see that?
2 A
Y***
Id 3
Q Is it correct, Mr. Zeve, that at some time 4
bef re July 18, 1979 you had told people at Met ED
(
5 that were creating this chronology that at or about 6
the time the second set of reactor coolant pumps were 7
turned off, HPI flow had been increased to the full g
am unt?
9 i
A As I remember, that is correct, that I 10 remembered that we had initiated high-pressure gy injection flow at the time that we were tripping 12 i
the last two pumps.
13 After that time period, due to other 14 s
studies on BWST level and other people's 15 V
investigation, it had proved that that had not been 16 m
^
the case, but this is exactly how I had rememberd it.
17 18 Q
Just so we understand, Mr. Zewe,
'a t the time you made the comment on Exhibit 758 which says, 19 "Two pumps on at approximately 1,000" 20 A
I remember that, yes.
21 L
Q
--it is correct, isn't it, Mr. Zewe, 22 that at the time you made that comment it was your 23 rec llection at that point that that in fact had 24 I
happened; right?
i 25
.-a,
1 Zewe 8J2
(.
2 A
That is correct.
3 Q
.And at the time you made statements to 4
people at Met Ed between the day of the accident and
('
5 September 1979 that HPI had been initiated at 1,000 6
gallons per minute at[ or about the tim the reactor
_ Q 7
coolant pumps were turned off, in each case, each time 7
8 you made th at statement you were telling them then what 9
your best recollection was; isn't that correct?
10 A
yes.
(
11 Q
Now, you told us, Mr. Zewe, that sometime 12 around June -- that sometime in the spring of.1979 --
i 13 you gave testimony at a hearing before the Advisory 14 Committee on Reactor Safeguards of the Nuclear 15 Regulatory Commission, so-called ACRS?
16 A
I did talk before the ACRS in 1979.
I 17 don't recall exactly when that was.
18 Q
And did that group include Dr. Max W.
19 Carbon, Dr. Milton S.
Plesset, Mr. Myer Bender, 20 Mr. Jesse Ebersole, Mr. Harold Etherington, 21 Prof. William Kerr, Dr. Stephen Lawroski, Dr.
J.
Carson L
22 Mark, Mr. William M.
Mathis, Dr. Dade W.
- Moeller, 23 Mr. Jeremiah J.
Ray, Dr. Paul Shewmon, Dr. Chester P.
(
24 Siess?
25 MR. MacDONALD:
Are you asking him at I
llB 1
Zewe 833 k
2 the tima he gave the testimony before the ACRS if he remembers every name?
3 4
Q Do you know any.of.those gentlemen,
(
Mr. Zewe7 6
A I recall a few of those n ame s which you 7
just read as being members of the ACRS when I was 8
before them.
Not all of them, but I do remember some g
of them.
10 Q
Did you appear before that group of ACRS 11 in June of 1979 accompanied by other people from Met 12 E'd, including Mr. Herbein and Mr. Keaten?
13 A
Yes.
14 MRc FISKE:
Let me mark a copy of that 15 transcript as the next B&W exhibit, Exhibit 760.
16 (Document consisting of a copy of 17 Mr.
W.
Zewe's testimony before the members of 18 the-ACRS, June 1979, was marked as B&W Exhibit 19-760 for identification.L
~
20 THE WITNESS:
Ihave the copy, 21 Q
Let me direct your attention to page 326,
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22 Mr. Zews.
23 A
I have that page.
(
24 Q
I w uld like to read a question and an 25 answ'er from that page, starting at line 4.
l 8-1 Zewe 814
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Question from Dr. Moeller:
" Excuse me.
2 I Believe this 6:27 fr after -- and perhaps even 3
a half or more after -- you had shut down the 4
primary coolant pumps; is this correct?"
('
5 A'nswer by Mr. Zewe, "Yes, sir. At the same time 6
that we secured the last two reactor coolant pumps, 7
which were the A-side pumps, we initiated full 8
high-pressure injection at the same time, which was 9
approximately 5:40, if I remember right."
10 Were you asked that question and did you 11 give that answer the ACRS on June 15, on or about 12 June 15,1979?
13 A
I have no reason.to believe that this is 14 not &ccurate, though I don not remember the actual words.
15 Q
At the time you testified before the ACRS, 16
..Mr. Zewe
, were you telling the truth in the answers 17 that you gave to the questions that you were asked?
~
4 18 Telling the truth to the best of your ability at that 19 time.
20 A
Yes, I was.
21
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Q And on June 15, 1979 the truth with respect 22 to this situation as you remember it then was that HPI l
23 had been put on at full flow at the time the second
(
24 set of reactor coolant pumps were secured; is that 25
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1 Zeve 8J5 3B
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2 right?
A As I have stated earlier, that is what I 3
4 remember.
5 Q
Let me, Mr. Zewe, show you a transcript
{
6 of an interview that was conducted at Met Ed on 7
May 25, 1979, which we will mark as Exhibit 761, B&W 8
761.
9 LDocument consisting of a transcript 10 of an interview conducted at Met Ed on May 25, 11 1979, was marked B&W Exhibit 761 for 12 identification.)
f i
13 A
I have it before me.
14 Q
Do you remember participating in a 15 discussion with Mr. Miller, Mr. Porter, Mr. Ross and 16 Mr. Seelinger on or about May 25, 19797 17 A
I remember a discussion with t,hese
~
18 gentlemen and myself. I do not remember the date.
/
~*
19 Q
Who is Mr.
I.D.
Porter?
20 A
Mr. Ivan Porter was an instrumedt and control 21 engineer assigned to Unit 2.
22 Q
Directing your attention to page 6 of that, 23 Mr. Zowe, looking at the answer you gave right at the
(
24
. bottom of the page, let me just read it to you, or 25 the statement.
~m
i 1
Zewe 816
(
2 "Mr.
Zewe:
We talked about that yesterday after we reviewed the tape, and I went over the 3
4 complete scenario for training and everybody,
- *n aid f r future training classes and craig
((
5 6
and Ed thought again it was either just before the last two pumps or just after the last two 7
8 Pumps."
g Do you see that?
10 A
Yes, I do.
11 Q
Is it correct, if you look back at the 12 discussion that precedes that statement, that the "it" 13 that you refer to in that answer was putting HPI on at f"117 14 A
Let me review this for a second.
15 16 Q
sure.
A Yes, it is.
17 ig Q
Did you make that statement to these 19 gentlemen on or about the date the transcript reflects?
A I have no reason to believe that this is 20 not accurate, though I do not remember the words.
i 21
(
22 Q
This statement that I just read indicates that you and Mr. Faust and Mr'. Frederick had reviewed 23 this situation involving the HPI flow at the time the
(
24 reactor Co lant Pumps were turned off, sometime after 25
ISB 1
(
3 you reviewed a tape.
A That is what it says here, but I don't 3
4 recall. I remember having discussions with 5
Mr. Frederick and Mr. Faust, and I remembed the HPI,
(
6 and they certainly supported that even stronger than 7
what I remembered, and a few things that they had said 8
recalled my memory to say, "Oh, yes, I remember when we did that."
9 10 Q
so in this period of time in or about May 11 1979, you had conversations trith Mr. Fred. fick and 12 Mr. Faust in which they both said to you that it was I
s 13 their recollection of the accident sequence that HPI
~
14 had been put on at full at the time the pecond set 15 of reactor coolant pumps were turned offs is that 16 correct?
17 THE WITNESS:
Would you read that back, 18 please.
~
19 (Question read.1
~*
A As I remember, that was correct.
20 21 Q
And isn't it correct that they each made 22 that statement to other people at Met E.d besides 23 yourself?
(
24 A
You have to ask them and review their j
\\
25 recollection or their previous testimony.
I don't know.
16B 1
Zews 818
(
2 Q
Well,-let me put it this way, Mr. Zewes 3
Were you ever at a meeting or a gathering of people at 4
Met Ed in which, in your presence, Mr. Frederick 5
or Mr. Faust stated that HPI had been put on at full
((
6 at the time the second set of reactor coolant pumps 7
was turned off?
i' 8
A As I remember, yes.
9 Q
Did that occur on more than one occasion?
10 A
I don't remember.
e 11 Q
Who else from Met Ed was present other 12 than yourself.and Mr. Frederick and Mr. Faust during i
13 that discussion?
14 A
I.'m not sure.
I don't remember.
15
-Q was Mr. Miller present at a discussion in 16 which Mr. Frederick or Mr. Faust made that statement?
4 17 A
I don'-t remember Mr. Miller being present.
18 The time that I seem to recall that it hap'pened was 19 whenever we were reviewing the sequence of'ivents 20 with members of the PORC, and I don't remember 21 Mr. Miller being there.
22 And I know who the members of the PORC 23 were but I can't remember who was there that day and
(
24 who wasn't, because I did that many, many times and I 25 don't remember.
N 17 1
Zews 819
('
2 Q
Maybe it would be helpful, Mr. Zewe, if I
I showed you Exhibit 666, which is a' copy of a memo 3
4 from Mr. Miller to Da'ta Reduction, a,nd then a whole lot of other people listed on the first page
(
5 s
6 Do you see that?
A Yes, I have the document before me.
7 8
Q It says, "The attached marked-up copy of 9
the annotated sequence of events is the result of.TMI-2 10 PORC meetings held on May 14, 16, and 17, 1979."
11 Do you see that sentence?
12 A
Yes, I do.
<~
13 Q
was it those meetings that you were e -
14 referring to a moment ago?
15 A
It may have been. I am reasonably sure 16 that I participated in these particular PORC meetings, 17 but I am not sure if that is when they occurred or
~
18 not.
19 Q
Who were the members of PORC a't'that time?
A Mr. Kunder, Mr. Brummer, Mr. Bensel, 20 l
\\
21 Mr. Warren.
I believe Mr. Hilbish was.
Mr. Floyd was.
)
22 I d n't remember if Mr. Morck was still s 3
1 i
23 there or not.
I can picture a couple of-other faces,
(
24 25 but I don't recall their names at this particular time.
{
]
I,
-l
- 1 Zewe 820
(
2 Q
Do I understand your testimony correctly that at meetings with the PORC, with whatever members 3
4 wore present, in May 1979, going over this annotated l(
5 sequence of events, that both Mr. Frederick and
,g Mr. Faust stated to whatever members were there on y
that occasion that high-pressure injection had been g
put on at full at the time the second set of reactor g
coolant pumps were turned off?
10 A
That's as I recall.
And it brings to mind 11 that I believe that there was another person that was 12 Present in all of those meetings also, and his name i
13 appears here.
Tom van Witbeck.
I believe that he was s-14 there doing some of the research into the sequence of 15 events, and I believe that he was present during those s
16 discussions.
'17 Q
Could I ask you to look, Mr. Eewe, at the 18 completed sequence of events, Exhibit 275.
That 19 sequence of events is dated September 4, 1950, is it l
20 not?
A Yes, it is.
21 l
(
22 Q
At any time between the period of July to l
l 23 September 1979 when you made the notation that we i
(
24 referred to earlier, and September 4, -1980 when this 25 final chronology was filed, did you state to anyone
~
, 19 1
Zowe 821
(
i i
2 at Met Ed that high-pressure injection had not been 3
put on at the time the second set of reactor coolant i
4 pumps was turned off?
5 A
'I don't remember, I may have, Because (i
6 between the accident and this time I was aware of the 7
other studies conducted on water levels and flow 8
calculations.
And it was pointed out to me that 4*
(
had had that thousand gallons per minute flow at that g
10 particular time, that it would have showed the loss in 11 level from the BWST and that was not apparent in the 12 studies that were conducted.
('
13 Q
Do you know whether those studies had been 14 conducted, Mr. Zewe, before this chronology was filed 15 with the NRC on September 4, 1.9807 16 A
That I don't remember.
17 Q
Direction your attention to,page 41 18 A
I have that page.
19 Q
--down at the bottom do you "see the 20 statement that says, "The operator: manually initiated 21 the safety injection portions of engineered safety 22 feature trains A & B to supply additional cooling 23 water to the reactor core"?
(
24 A
Yes, I do.
l 25 Q
Were you aware in or about September 1980 L
l
[-
20 1
Zave 822
(
2 that that statement was going into the final 3
chronology?
4 A
I don't recall.
I assume that I received
(
a e py of the final version, and I believe I reviewed 5
6 it.
7 Q
Did you tell anybody when you reviewed it g
that you felt that statement was inaccurate?
A I did not.
The reason for my statement 9
10 before was that at some time after I had learned 11 through the calculations that it must have been in 12 error because it did not prove out but at no time did 13 I say I changed my mind, that I still didn't believe 14 that I had done it.
It is just that the' proof was 15 not there for it.
16 Q
Do I understand your testimony to be, 17 Mr. Zewe, that as far as you personally recall 18 sitting here today, your recollection is t'h a t this 19 happened?
~
~
MR. MacDONALD:
Based on all he knows?
20 MR. FISKE:
No.
21 22 Q
u told us that you have seen or heard 1
about certain analyses and certain studies that were 23
['
24 made.
A Yes.
25
1 1
Zeve 823 2
Q Putting those aside for the moment.--
3 whatever-they show they show -- I am just asking you, 4
independent of those studies, just in terms of the rec llection that you personally have about this
(
5 6
situation, has your personal recollection of it 7
changed since you gave the testimony that we referred g
to earlier and made the notations that we referred to earlier this morning?
9 10 MR. MacDONALD: I object to the form.
11 A'
What I stated earlier is what I remember.
12 Q
Well, I think I understand that answer, i
13 but just so we can make it clear, do I $$nd'ers tand 14 correctly that what you remember personally, sitting 15 here today, is that at the time the second set of 16 reactor coolant pumps were turned off, HPI was 17 reinitiated at full flow?
18 A
As I recall, what I remember March 28, 19 1979, that we did high-pressure injection at'or'about 20 the time we secured the second two pumps.
But I
. % *~
m cannot void myself of everything else that has 21
{
v
~
22 happened and what is fact from other sources.
t. ~_-
-23 That is what I remember, yes.
It hasn't
('
24 changed.
25 MR. FISKE:
Why don't we take a break.
(Recess taken.)
l.
1 ZGW3 t
824
(
2 BY MR. FISKE:
3 Q
You mentioned, Mr. Zewe, that in your 4
discussions with Mr. Frederick and Mr. Faust after the r
5 accident, you learned details from them about the 6
initiation of HPI flow at full that you didn't yourself l
7 know; correct?
8 A
(No response.)
9 MR, FISKE:
Let me rephrase the question.
10 Q
You said earlier, Mr.
Zewe, that in s
11 discussions with Mr. Frederick and Mr. Faust after the
, 12 ac"cident, you learned additional details about the 13 reinitiation of HPI at the time the second set of 14 Pumps was turned off; is that correct?
15 A
As I recall it, it was more than 16 additional details.
The things that they had 17 mentioned then improved my recollection, and I said, 18 "Oh, yes, I remember when we did that part'icular 19 thing."
20 So they added some additional information, l
P us they helped my recall.
21
(--
22 Q
Fine.
And is it correct that each of them 23
-- that is, both Mr. Frederick and Mr. Faust 24 Provided further information about the reinitiation of i
\\
l 25 EPI that in turn helped your recollection?
I
1 zewe 825
{
2 A
.As I recall, Mr. Faust remembered more 3
details than Mr. Frederick.
But, as I recall, they 4
both relayed information concerning that event.
5 Q
They both relayed information concerning 6
their recollections?
7 A
Of initiating the HPI at that particular 8
point at or before we tripped the pumps, yes.
9 Q
In this statement or transcript of this 10 discussion with Mr. Miller and Mr. Porter and Mr. Ross 11 and Mr. Seelinger which has been previously marked as 12 Exhibit 763 13 A
I have it, yes.
14 Q
and directing your attention to page 5 --
15 A
I have page 5.
16 Q
-- there is a statement that you make in 17 the middle of the page.
I would just like to read
~
18 that and Mr. Miller's statement and then yours.
19 It starts, "Zewe:
I think right here is 20 where we went back to full high-pressure injection.
21
" Miller:
Right at the point where you
('
22 turned the last pump off.
23 "zewe:
Just before or just after we did i
(
24 that because they took a countdown and Craig hit l
25
_high-pressure injection just as Ed secured the last
i Zewe 826 2
two pumps."
1 3
Do you see that?
4 A
Yes, I do.
g 5,
Q
, Did you make those statements to Mr. Miller 6
in or about the date of this transcript?
7 A
I have no reason to believe that this 8
statement is not accurate, though I do not recall the 9
actual words.
10 Q
Was the information that you gave Mr.
11 Miller in that statement information that you had 12 learned from Mr. Faust and Mr. Frederick after the 13 accident, or was that information that you yourself 14 recalled?
15 A
As I recall, that was information that I 4
16 recalled that was helped by talking with Mr. Faust and 17 Mr. Frederick at sometime later, but, as I recall, it 18 was my recollection.
19 Q
Mr. Zewe, you referred earlier this 20 morning to studies or analyses or whatever had been 21 done at some point with respect to water levels.
Do l
22 you remember that?
l 23 A
Yes, I do.
{.
24 Q
What specifically did these analyses 25 consist of?
l a
1 Zewe 827 k'
2 A
'I can only recall them in a general sense, 3
that they were -- they knew what the BWST level was at 4
particular time periods, and they knew from the
{
5 computer when makm2p pumps were started and stopped, 6
and they, based on the leve'1s and calcu' lated flow 7
rates and the starting and the stopping of the pumps, 8
they used all that-information in trying to reach a 9
conclusion on how much flow there was during any 10 particular time.
}
11 Q
Who is the "they" that you were referring 12 to in that answer?
13 A
I believe that there was more than one 14 group.
And "they" just referred to people that were 15 doing that calculation.
As I recall, there were a i
16 couple of different groups that were working on that i
17 very same thing.
18 Q
Who was the person that made this a
19 information available to you?
20 A
I don't remember who it was, except that 21 I remember reading various documents at the time from 22 these groups, stating that the flow rate in their 23
_ estimation was between two values during a particular
[
24 time period, and also from other discussions that I had t
25
_made_various times about having the full HPI flow at i
1 Zewe k'
2 that particular time, and then saying that the
(
w 3
calculations do not bear that out.
t
.m 4
Q When you reinitiated HPI flow at or about 5
the time t, hat the second set of reactor coolant g
6 pumps were turned off, did you believe at that point 7
that the high-pressure injection should be left on?
8 A
I don't remember what my thought processes 9
were at that particular time, except that I felt that 10 the conditions had deteriorated to where we had 11 secured the last two pumps and that we initiated the 12 high-pressure injection.
I don't remember thinking i
13 that I have to leave it on for any particular time 14 period.
I just don't remember what I was thinking at 15 that particular time.
16 Q
We established earlier, I think,-based on 4
17 the GPU chronology, that around 6:15 or so the block 18 valve was closed to the PORV;.do you remember that?
19 A
Yes.
20 Q
Did you take any actions yourself, Mr. Zewe, 21 to terminate or thrott'le back the HPI flow between the 22 time the second set of reactor coolant pumps were 23 turned off and the time that the block valve was
[
- 24 closed?
25 A
I don't recall.
I remember throttling i=
l
1 Zewe 829 l
(
2 back high-pressure injection somewhere after ths 3
closing of the block valve, whenever pressure and 4
level was high at that point.
{
5 Q
I am not talking about after the block 6
valve was closed.
7 A
Right.
I don't remember changing HPI flow 3
one way or the other between the tripping of the last 9
two pumps and the throttle after we had closed the 10 block valve.
I don't recall what the flow was or 11 whe the r we had throttled back flow and stopped and 12 started again, or what.
I don't recall.
I 13 Q
The GPU chronology, Mr. Zewe, that we were 14 looking at before, page 41 and 42 15 A
Is that the LER submittal?
16 Q
Yes.
17 A
I have those pages.
18 Q
The same paragraph we referred to before 19 indicates, does it not, at the bottom of 41 and the top 20 of 42, that based on the sequence of events put out, 21 makeup pump 1-C was stopped prior to 2:28:417 22 A
I read that here, yes.
~
23 Q
Now, if you could look at figure 80, which i (
24 is part of this chronology, do you have that in front of 25 you?
L
1 Zewe 830
(
2 A
80?
3 Q
80.
4 A
Mine doesn't go up that high.
Mine goes up
({
5 to figure, 63.
6 Q
Do you have a 60?
7 A
Yes, I do.
8 Q
Sorry.
Look at figure 60, Mr. Zewe.
9 Do you have that in front of you?
10 A
Yes, I do.
11 Q
And that ispart of this GPU chronology, 12 captioned " Pump operating history."
i 13 A
That is correct.
14 Q
O.K.
N ow, going down to the fourth box 15 from the bottom, do you see the heading, " Reactor 16 coolant make-up pumps"?
17 A
Yes, I do.
18 Q
That refers to pump A, pump B and pump C; 19 correct?
20 A
Yes, it does.
21 Q
All right.
And then do you see those k
22 little diamond-shaped symbols that appear next to the 23 reactor coolant makeup pumps?
(
24 A
Yes, I do.
25 Q
And then do you see'down on the lower
1 Zewe 831
(
2 right-hand side of this chart that that diamond symbol 3
indicates that the pumps ran for "a short period (less 4
than five minutes)"?
l 5
A Yes.
6 Q
Do you see such a diamond-shaped symbol 7
for reactor coolant pump C at or about the time of the 8
trip?
9 A
Yes.
10 Q
And it is correct, is it not, that reactor 11 coolant pump C ran for -- sorry -- that makeup pump C 12 ran for less than five minutes 1,n the first five 13 minutes of the trip?
14 A
That's what this would indicate.
15 Q
And then do you see another little diamond 16 symbol indicating that reactor coolant pump --
17 reactor coolant makeup pump C ran for a period of less 18 than five minutes sometime between an hour and a half a 19 and two hours into the accident?
20 A
I see that.
21 Q
Do you know who it was that turned off f
22 reactor coolant make p pump C at or about the time u
23 indicated by this GPU chronology?
f 24 MR. MacDONALD:
I object-to the form of the 25 question.
It has no foundation.
1 Zewe 832
(
~
2
.Q You can answer.
3 A
could I hear it again, please?
4 (Question read. )
(
5 A
(continuing)
No, I don't know.
I don't 4
6 know if it was turned off manually or if it had 7
tripped automstically.
I don't have any way of 8
recalling or knowing that.
9 Q
Did the analyses that you saw that you 10 referred to earlier purport to analyze'whether or not 11 high-pressure injection was initiated at full, and 12 then one of the pumps turned off within five minutes 13 after it was initiated.
e 14 A
I lost your question.
15 Q
You said you saw or were aware of some 16 analyses that looked at the levels of flow and water 17 in the tank and so forth and so on.
And I am asking 18 you, to your recollection were those analyses 19 directed at trying to determine whether or not 1
20 high-pressure injection went on at a thousand gallons 21 per minute at or about the time the second set of pumps k.
22 was turned off and then one of the pumps was turned 23 off within five minutes after that?
[
24 A
The study that was conducted that I 25 talked about earlier about BWST levels and starting
1 Zewe 833 I,
2 and stopping of the makeup pumps was used for the 3
entire time of the incident.
Not just for that 4
particular time, though it was covered.
But they were
(
5 trying to, determine inventory and flow to and from the 6
reactor coolant system during that entire period from 7
the trip up until -- I am not sure what their end 8
point was.
And it did cover that particular period in 9
question.
t 10 Q
In-the discussions that you had on this 11 whole s ub j e ct after the accident, was there a time 12 postulated at which core uncovery occurred?
\\
13 A
As I recall, there were several different 14 opinions on exactly when cover uncovering occurred, 15 Postaccident evaluation.
16 Q
What is the earliest time you saw in any 17 of those studies?
l t
18 A
(No response.1 l
19 MR. FISKE:
Withdrawn.
20 Q
Isn't it a fact that you didn't see any 1
21 study which postulated core uncovery before the time k
22 that the second set of reactor coolant pumps had been 23 turned off?
(
24 A
I don't recall.
+
25 Q
one way or the other?
1 zewe 834
(
2 A
One way or the other.
3 Q
Well, in the studies that you saw, what 4
assumptions were made with respect to how long the
(,
S C pump had been on after HPI was reinitiated in full?
6 A
I don't know 7
MR. MacDONALD:
Objection.
There is 8
nothing to show that the pump was even turned 9
on.
You are assuming something without basis of 10 testimony.
11 THE WITNESS:
Would you reread that, 12 please?
l 13 (Question read.)
14 A
I don't remember.
15 Q
Were any of these studies in writing?
16 A
Yes.
17 Q
How many different ones did you see?
18 A
I don't remember, because I have seen 19 documentation on it, and I am not sure how many were 20 individual and how many were further improvements of 21 the same thing.
So I am not sure.
(
22 Q
Can you tell us now that there was more 23 than one study?
(
24 A
I believe that there was more than one 25 study, yes.
1 zewe 835
(.
2 Q
Who were the organizations that did these 3
studies?
4 MR. MacDONALD:
I think you have already
([
5 aske,d that.
6 MR. FISKE:
If I did, I didn't get an 7
answer.
0 A
I don't recall who the groups were.
I know 9
that Met Ed-GPU was involved in it, but just"what group i
10 was studying that I am not sure.
11 Q
Were all of the studies that you saw 12 studies that were done internally at Met Ed or GPU?
(
13 A
I believe that there were also studies 14 made by outside groups, but I am not sure if it was 15
- NRC, EPRI, or -- I don't know.
16 Q
Did you see a written study from any 17 outside group that related to the subject-that we have 18 beendiscussing.here in the last couple of hours?
19 A
Yes, I believe that I did.
20 Q
Was there more than one study by an outside l
21 group?
s 22 A
Here again, I am not sure.
I have seen an f
23 awful lot of material relating to this-incident and
(-
24 this particular makeup pump operation.and the flows, 25 and I really don't remember.
1 Zewe 835-A
(
2 g
what specifically was it in these s tudies 3
that tended to show.that HPI was not initiated at 5:40?
4 A
As I remember, postaccident knowledge was
(
w 5
that they used information that they had gatheie'd to
~ _. _ _.. -
6 compare this particular chart, for instance, makeup 7
pump on and off, and the charts and levels from the 8
BWST, that kind of data.
f 9
(Continued on Page 836.)
/
10 11 12 ll 13 14 15 16 17 18 l
19 20 21 22
~
23
(
24 25
CK1 1
Zeve 83 6
(
2 Q
What specifically did it show?
A As : remember, it showed that we had had 3
4 a thousand gallons a minute of flow starting at that-particular time for any length of time that they would have
(
5 6
found the evidence to support that in the BW5 r level, 7
starting and stopping of the makeup pumps and so(
8 forth.
9 Q
What was the length of time you were 10 referring to in that last answer?
t A
I don't know, because I have stated that 11 12 I don't remember throttling HPI after that initiation lb or changing it until we throttled back after we had
^
PORV shut, after we recoverd pressure level.
14
_s 15 Q
Did the information that you saw show 16 that if HPI had been on at a thousand gallons per minute for only five minutes, that there would have 17
\\
18 been evidence in the water levels to support that?
19 A
I don't believe that a 5,000 gallon 20 change at that particular time would be very conclusive 21 one way or the other.
22 Q
Do I understand, Mr. Zewe, that you did not see any study or analysis that demonstrated that 23 l [
HPI did not come on at a thousand gallons per minute g4 and then was cut back within five minutes to 500 25
2 1
Zawa 837 2
or loss?
MR. MacDONALD:
Are you basing that just 3
4 on the last question as to water level or all
(
5 the things studied, makeup pumps, starting and 6
stopping and all the computers?
7 MR. FISKE:
Yes, everything.
8 THE WITNESS:
Would you read that back, 9
please.
4 10 Q
I will put it again.
11 Did you see any studies that demonstrated 12 that HPI could not have come on at a thousand gallons 1
13 per minute at 5:40, stayed on for five, minutes or 14 less at that rate, and then continued after that 15 point at a flow rate of 500 gallons per minute or less?
16 A
I don't recall.
17 Q
one way or the other?
18 A
No.
Your question.doesn't 19 rucall anything that -- any analysis relating to that 20 that I can recall one way or the other.
21 (Re ce s s. )
22 Q
Mr. Zewe, a couple of times earlier in 23 this deposition we talked about the point in the 24 accident sequence when the block valve was closed for 25 the first time.
3 1
zowe 838 h
2 A
- Yes, 3
Q Were you in the control room when that 4
happened?
k 5
A
, Yes, I was.
6 Q
By that time had some other people 7
arrived that you haven't placed in the control room 8
before?
9 A
I don't recall all of the people that were
(
10 there, but I believe at that point Mr. Mahler, was
. 11 there.
I believe Mr. Ross was there at that time.
t.
12 And all the others, Mr. Kunder was still there, 13 Mr. Bryan *was still there, and the operating staff was 14 still there and the two engineers from Unit I were 15 still there.
Mr. Weaver, I believe, was,there at 16 that time.
If not in the control room, he was in at 17 that particular time.
I am not sure, but'I believe 18 that Mr. Logan was there.
19 But near the exact time frame with relation 20 to closing the valve and when the people arrived, I 21 am not at all certain. It may have been just before, 22 it may have been just after.
23 Q
Did there come a point in time during the 24 accident sequence when someone else to'ok charge of the 25 situation?
l l
4 1
zowe 839
(
2 A
Mr. Miller arrived around 7 otelock, and he relieved me as the emergency director.
3 4
Q And were you in charge up until that time?
l 5
A Yes, I was.
6 Q
What were the circumstances that led up 7
to the closing of the block valve?
g A
As I recall, Mr. Mehler and I had a 9
discussion about the block valve, and he suggested 10 that we shut it just from the standpoidt, as I recall, 11 that why not shut it at this point.
12 And I said, "Yes, go ahead."
13 Q
Did he give you any reason why he thought 14 it might be a good idea to shut it?
15 A
Not that I remember.
Only generally, 16 because he had been there for some time at that point, 17 and he was going through an evaluation process in his 18 own mind and trying to help out.
19 And I don't recall if it was any 20 particular thing that led him to that conclusion, but it was based on that discussion, more like, yes, we 21 22 will go ahead and shut it.
23 Q
Had Mr. M'ehler been in the control room 24 any longer than fifteen or twenty minutes before he made that recommendation?
25
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ ~
5 1
Zewe 840
.(
2 A
I don't remember how long he had been there.
3 4
Q Mr. Mahler obtained readings from the
(
5 thermocouples on the discharge line?
6 A
Are you telling me that he did?
7 Q
I am asking you, did you know that he g
did.on the morning of the accident?
g A
I do not recall knowing that the day of 10 the accident, no.
(
11 Q
so there was no discussion between you 12 and Mr. Mehler about temperatures at the discharge 1
13 lines before he said he thought the b3ock valve should be closed?
_ 14 15 A
Not that I remember, no.
16 Q
Were you aware of any information with 17 respect to temperatures on the discharge line between 18 the time you had gotten the readings from Or. Bryan 19 approximately an hour earlier and the time the block i
20 valve was closed?
A As I recall, the only readings I remember 21 22 were the ones that I had asked of him, before I i
23 originally left the control room, and then sometime
(
later I had asked him again.
24 25 Those were the only two times that I
!l-
6 1
Zewe 841
(
l s
2 remember being aware of what the temperatures were, because I had asked for them on those two occasions.
3 4
Q Did you express any reason to Mr. Mehler
(
5 why the block vilve should not be closed?
6 A
I don't recall any words, but I believe 7
I said, 'Why?"
A'nd he said, more like, "Why not?"
g And I said, "Go ahead then, shut it."
g Q
Did you have any information concerning 10 temperatures at the discharge lines, pressure or 11 temperature at drain tank, or drop in reactor coolant t' e time the block valve was h
12 system pressure, at f
j 13 closed which was different in any meaningful way 14 from information that you had had on either of the 15 two occasions when you had asked for the temperature 16 readings?
17 THE WITNESS:
Would you read that back?
18 I couldn't keep track of what you were asking.
19 (Ques tion read. ) -
~
20 MR, MacDONALD:
I object to the form.
No 21 foundation.
22 MR. FISKE:
You weren't here earlier in 23 the deposition.
i h
24 MR. MacDONALD:
I don't know necesstrily 25 whether he testified when he received discharge i
+
1 Zewe 842
(
2
. temperatures that he knew what the drain tank 3
pressures and temperatures were.
4 Q
If that colloquy didn't divert you, you
(,
5
- ""**** the question.
6 A
The only thing.that I recall is, shortly 7
after we shut the block valve, that the RCS pressure 8
started to increase.
9 Q
I guess my question was not clear.
Let 10 me try it again.
t 11 A
Please do.
12 Q
At the time the decision was made to close t
13 the block valve, did you have any information.about 14 temperature in the discharge lines, reactor coolant 15 drain tank pressure and temperature, or drop in e
16 reactor coolant system pressure, that was different 17 in any meaningful way from the information that you
.lg had had about those parameters on either of the two 19 occasions when you had asked for dischargeline 3
20 temperatures?
A Not that I remember.
21 22 Q
Did you have any information on pressurizer 23 level at the time the block valve was closed that was
('
different in any meaningful way from the information 24 i:
l 25 that you had.about pressurizer level on either of i
8 1
zowe 843
<r 2
those two earlier occasions?
3 A
Not that I can remember.
4 Q
Were you aware, Mr. Zewe, on the day of
.l 5
the accident, that there were in-core thermocouples 6
which could measure the temperature in the core?
7 A
Yes, I was aware that there were in-core 8
thermocouples, 9
Q At any time between the time of the 10 reactor trip and closing of the block valve, did you 11 try to find out from those thermocouples what the 12 temperature of the core was?
('
A I did not.
s 13 14 Q
Was there a reason why you didn't?
15 A
There was never any training at Met Ed or 16 B&W on using these thermocouple readings at any 17 particular time in the course of either a. normal l
18 procedure or an emergency procedure, and I did not 19 think to use them.
20 Q
You did know, did you not, that if you l
21 had wanted to find out what the temperature was in
(
22 the core, that -
.could use these thermocouples for 23 that purpose?
(
24 A
Yes. But I would have to make a 25 determination that I would want to do that.
9 1
Zewe 844
(
2 Q
Right.
A And I had n t reached that conclusion, 3
4 that I would need to know the temperatures.
(
5 Q
In the core.
6 A
In the core.
7 Q
Was it your testimony, Mr. Zeve, that up 8
until the time the block valve was closed, that you 9
hadn't seen any condition in the plant which raised 10 any question in your mind as to possible increase 11 in temperature in the core?
12 A
As I recall, I believed at the time that i
13 as long as I had a full pressurizer level, that I did 14 nt feel that core temperatures were a problem.
15 Q
At any time before the Three Mile Island 16 accident in March of
'79, had you expressed any 17 dissatisfaction to anyone with the alarm system in-18 the control room?
gg A
I had expressed my opinion that'I felt that we c uld certainly improve upon the alarm system in 20 21 the control room.
Q Who had you said that to?
22 l
\\
A I remember discussing it with Mr. Ross and 23
! (
24 Mr. Floyd, and there were others, but 25 Q
In what way did you tell them that you
la 1
Zewe 845
(
2 felt that the alarm system could be improved?
"A As I recall, the discussions were around 3
-4 a couple of different areas.
(
5 one was that the alarms that were not 6
meaningful and were nuisance alarms should be 7
eliminated, and that the control room needed more 8
' acknowledge buttons placed at better locations, and 9
that the alarm acknowledge reset buttons sho ld be 10 separate functions as they were in Unit 1.
11 Q
Did you still hold those same views as
12
'of March 27, 4979?
(
13 "
A I still felt that there was need for 14 improvement.
There had been an ongoing process to
'15 try to evaluate and eliminate some of the unnecessary 16 and nuisance alarms.
17 As a matter of recall, there were two l
18 engineers that had been engaged in working on that
'he nuisance 19 Problem.
And I believe that they had cut t
r 20 alarms that I referred "to by as much as half as where they
~
were when they had started, and there also has been
(
additional buttons.Acknowlege buttons had been added.
23 Q
How many alarms went off on the morning
('
24 of the accident?
25 A
A large number.
1
1 1
Zeve 846 l
(
2 Q
More than a hundred?
A Y***
3 4
MR. MacDONALD:
That is his recollection 5
on the day of the accident?
(
i 6
MR. FISKE:
No, I am asking him n, fact' 7
now how many alarms.
3 A
I remember at one time I was asked by g
Mr. Miller, I believe, to write down a list of all 10 the alarms that I knew were in.
And th.e number.was, 11
- as I recall, in excess of a hundred alarms.
12 Q
Did you state to anybody at any time after
'5 i
r 13 the accident that you felt that the number of alar,ms' of the accident 14 that had gone off during the course
,a 15 sequence had made it more difficult for the oper tors 16 to diagnose the problems?
j 17 A
During the first few mir.utes of.the event 18 I had felt t. hat all the alarms that had come' on and i
19 the horns sounding was more of a hindrance'than a-20 help at 'that particular point because of the messive number of alarms and the sound.
21
(
22 So I had the operatore acknowledge the 4
~
a s
23 alarms, to silence the horns and to silence th'e w
('
24 flashing alarms.
25 After that point I felt'they were more D,s s
S, s
y.y t
2 1
Zewe 847
- ('
meaningful, but initially they were overwhelming from 2
the standpoint of sheer numbers and trying to take 3
4 action on each and every alarm.
Q Did you hear that same point of view 5
6 expressed By other operators that had been involved 3
7 in the early minutes of the accident?
8 A
Yes, I did.
9 Q
Had there been criticisms made of the 10 alarm system following the April 23 transient?
11 April 23, '787 l
12 A
I don't recall.
13 Q
Isn't it a fact that it was the April 23,
'78 transient which had prompted discussion of 14 15 improvements in the alarm system?
16 A
It may have been.
I don't remember.
17 Q
Mr. Zewe, when HPI comes on automatically
~
18 or when the operator presses the manual button to 19 actuate, what is the source of water for the HPI?
20 A
BWsT.
21 Q
You said earlier, Mr. Zewe, that when HPI k
comes on automatically, the operators take manual 22 23 control of it'.by bypassing HPI?
(
A After actuation, the operators go to bypass 24 so that if they did have to take manual control, they 25 j
w
13 1
Zewe 848
(
2 could then do it.
3 Q
And is there a regular procedure that s
4 after they have bypassed the HPI, that they are
(,
5 supposed to take action to cause the flo'w of water 6
into the system to come from the makeup tank rather 7
than the BWST7 8
A Could you rephrase that?
9 Q
Sure.
Talking about a situation where the 10 HPI comes on automatically.
The operator then takes 11 manual contol and bypasses and then at some point 12 starts throttling back.
And it was a regular k
13 p ro ce dure that when that happens, the operator is 14 supposed to flick some switch or change some valve 15 or whatever that will cause the water that is going 16 into the system at that point to come from the makeup 17 tank rather than the BWST7 18 A
That is true.
19 Q
And on the' morning of the accident,
~
20 March 28, 1979, was that procedure followed, to the best of your recollection?
21 22 A
As far as I can remember, it was, yes.
23 MR. FISKE:
I have no further questions.
l l[
24 (Recess.)
l 25 (continued on the next page.)
.4 1
zewe 849
(
2 EXAMINATION BY 3
MR. MacDONALD:
4 Q
Mr. Zewe. do you recall giving testimony
(
5 earlier in this deposition about a memorandum which 6
you wrote in May of 1978 to Jim Seelinger regarding 7
the condensate polishing system?
8 A
Yes.
9 Q
Do you recall your testimony about 10 portions of that document in which you'used the words 11 "very serious accident"?
12 A
Yes.
t 13 Q
And do you recall giving testimony in 14 relation to what you meant by those words?
15 A
Yes.
16 Q
Do you recall testifying possible 17 damage to equipment and personnel in the turbine 18 building might result --
19 A
Yes.
20 Q
If I can finish -- from problems with the 21 condensate polishing system?
22 A
Yes.
23 Q
could you explain in a little more detail
(
24 what you meant by " damage to equipment and personnel in 25
-the turbine building" as a result of problems with the
5 Zewe 850
(
2 condensate polishing system?
I 3
A The serious accident that I was referring 4
to was that there could be possible damage to the
(
5 feedwater and condensate system on the secondary side of the plant.
7 Whenever the feedwater is abruptly stopped 8
after flowing at about22,000 gallons per minute, O
there is a pressure surge in the condensate and feed system as a result of the sudden stoppa e of that flow 11 of water, and that may lead to damaging the secondary 12 side components of the feedwater and condensate itself,
(
13 the instruments, the feed pumps, condensate pumps, 14 booster pumps, the polishers themselves; and if there 15 are any personnel that are around these components when and if they should fail, they could result in II being injured.
~
18 I at no time wanted to infer that there s
19 would be any serious accident occurring on the 20 primary side of the plant.
21 The loss of feed condition would result 22 in a trubine trip and possibly a reactor trip, but. the 3
l plant was designed to handle a loss of feed and an
,l(
24 ensuing turbine trip and reactor trip, and I didn't 25 feel that there was any cause for concern that there
.6 1
Zeve 851 k
2 would be any serious accident occurring at all in the 3
primary side of the plant.
All of that damage or 4
serious accident that I referred to was strictly to
(
5 the secondary side of the plant in the feedwater 6
and condensate system.
7 MR. MacDONALD: I have no further questions.
8 EXAMINATION BY g
MR. FISKE:
10 Q
Mr. Zewe, was avoiding serious injury to 11 equipment and personnel on the secondary side of the 12 plant as important to you as avoiding serious injury
(
13 to equipment and personnel on the primary side of the 14 plant?
15 A
I don't believe that I could differentiate 16 between personal injury on either side of the plant.
17 Certainly I would not want to have anyone injured 18 on either side of the plant and I would certainly be 19 concerned with equipment damage on either side of the 20 Plant.
But I just wanted to clarify what I meant 21 there and the relationship to that particular memo, 22 MR. FISKE:
That's all.
23 (Time noted:
12:30 p.m.)
g4
~oOo=
25
lea 1
Zewe 851A l
2 WILLIAM H.
ZEWE 3
4 Subscribed and sworn to
(
5 before me this 6
day of 1982 7
8 9
10 11 12
+
13 14 15 16 17 18 19 20 21 22 23 l <
24 25
I Zewe 852 l
{
l CERTIFICATE 2
i STATE OF NEW YORK
)
3 j'
- ss.:
I COUNTY OF NEW YORK'
)~
4 I,
HARVEY~B. KRAMER.
, a Notary i
~ '
'Pnblic'of the Stut'e'of New York, do hereby certify that the continued deposition of 7
WILLIAM H.
ZEWE Was taken DefCre 8
me on Friday, May 28, 1982 consisting 9
of pages 791 through 851A
- (
I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor lo_
interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel.
18 IN WITNESS WHEREOF, 19 I have hereunto set my hand this f d, day of ill16
/f b i
20 I f(
21 on b
h* '/>N L
[ '
HARVEY B.
KRAMER, RPR,CSR 24 :1 n
25 l
853 j
i/28/82 I
N D
E X
WITNESS PAGE WILLIAM H.
ZEWE 793 E
X H
I B
I T
S B&W FOR IDENTIFICATION 758 Draft of a chronology, dated 805 July 16, 1979.
759 Memorandum from Mr. Miller, 810 duly 13.,1979.
760 Copy of Mr.
W.
Zeve's testimony 813 before the members of the_ACRS, j
June 1979.
761 Transcript of an interview 815 conducted at Med Ed on May 25, 1979.
-ooo-
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e 4
t l
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