ML20072H823
| ML20072H823 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/20/1982 |
| From: | Zewe W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-04, TASK-06, TASK-1, TASK-2, TASK-4, TASK-6, TASK-GB NUDOCS 8306290761 | |
| Download: ML20072H823 (121) | |
Text
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UNITED STATES DISTRICT COURT p
SOUTHERN DISTRICT OF NEW YORK g
_____________________---___--_________x GENERAL PUBLIC UTILITIES CORPORATION JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, J
cb Plaintiffs,
- 80 Civ. 1683
-against-(R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
__________-____--_____________-___2___x Deposition of GPU NUCLEAR g
CORPORATION, by WILLIAM H.
ZEWE, taken by Defendants, pursuant to notice, at the offices of Davis Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Thursday, May 20, 1982, at 9:45 o' clock in the f o r.e n c o n,
i before Harvey B.
Kramer, a Certified Shorthand Reporter, Registered Professional Reporte* and Notary Public within and for i
the State of New York.
k f[ DC OO DOYLE REPORTING, INC.
T q
CERTIFIED STENOTYPE REPORTERS 369 LExlNGTON AVENUE WALTER SHAPIRO, C.S.R.
NEw YORK. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELEPHONE 212 - 867 822o
I 1
2 2
APPe arance s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
'425 Park Avenue New York, New York
(
5 By:
DAVID KLINGSBERG, ESQ.
6
-and-ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 10 One Chase Manhattan Plaza e New, York, New York 11 By:
ROBERT B.
FISKE, ESQ.
12
-and-WILLIAM E.
WURTZ, ESQ.,
13 of Counsel 14 15 KILLIAN & GEPHART, ESQS.
Attorneys for the Witness 16 Box 886 Harrisburg, Pennsylvania 17108 17 By:
KEVIN WALSH, ESQ.,
18 of Counsel 1
19 20 Also Present:
21 JONATHAN QUINN and
(
ERIC ABRAHAMSON, 22 Law Assistants Davis Polk & Wardwell, Esqs.
23 25 e
. m
.-.____-.-,,__m.
.. _.. - ~ _ _ -, -.. _ _ -. _. _ _ _. _.. _.
l 1
3 l
2 IT IS HEREBY STIPULATED AND AGREED I
4 3
by and between the attorneys for the 4
respective parties hereto, that the sealing,
(,
5 filing and certification of the within 6
deposition be, and the same hereby are, 7
waived; and that said deposition may be 8
signed and sworn to before any officer 9
authorized to administer an oath, with the 10 same force and effect as if sworn', to bef ore 11 an officer of this Court.
12 IT IS FURTHER STIPULATED AND AGREED O)
(.
13 that all objections, except as to the form 14 of the question, are reserved to the time i
i 15 of the trial.
16 17 18 9
19 e
f 20 21-
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4
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- ZEWE, having been 3
first duly sworn by the Notary Public, was 4
examined and testified as follows:
(,
5 EXAMINATION BY MR. FISKE:
6 Q
What is your name?
7 A
William H.
Zewe.
8 Q
How old are you, Mr. Zewe?
9 A
36.
10 Q
What is your home address?(
11 A
Border Lane, R.D.
1, Hershey, Pennsylvania.
12 Q
What is your present employment?
(/
13 A
GPU Nuclear.
14 Q
What position do you hold there?
15 A
Shift supervisor, Unit 1.
16 Q
How long have you held that position?
17 A
Since May of 1976.
18 Q
Has the re been any change in your position 19 at Met Ed since the accident in 19797 20 A
Yes.
I was a station shift supervisor 21 at the time of the accident, with responsibility in 22 Units 1 and 2.
Now I am only a Unit 1 shift 23 supervisor.
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24 Q
Is there any difference between a station
. (V 25 shift supervisor and a shift supervisor?
l 1
Zewe 5
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1 2
A only that,I had responsibility in both 3
units.
Now I only have responsibility in Unit 1.
4 4
Q Are you aware that a request has been 5
made for the production of documents in connection 6
with this litigation?
7 A
Yes, I am aware.
8 Q
Have you ever seen that document request?
Y 9
A I have seen a request and heard of a 10 request from our lawyers, but I am not sure of the 11 actual one that you are referring to here.
12 Q
Without going into the substance of the
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13 communication back and forth between you and your 14 lawyers, is it correct that you have been requested by 15 lawyers for GPU to gather together documents and 16 give them to the lawyers, in connection with this 17 litigation?
18 A
That is correct.
19 Q
And have you given to the lawyers all of 20 the documents that they asked you to give them?
21 A
Yes, I have.
23 Q
During the course of your employment at 23 Med Ed before the accident, did you have occasion to
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24 take documents back to your home, to keep some
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25 documents there?
1 zewe 6
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2 A
Yes, I have.
3 Q
In the process of getting together 4
documents to give to your. lawyers, have you gone
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5 through the documents in your home as well as 6
documents that you might have kept on the premises?
7 A
I have.
8 Q
You are represented here today by 9
Mr. Klingsberg and Mr. MacDonald from Kaye, Scholer; 10 right?
11 A
Yes, I am.
12 Q
And also by Mr. Walsh?
13 A
That is true.
14 Q
At any time since you retained Mr. Walsh, 15 have you given documents to him?
16 A
I have not given any documents to Mr.
17 Walsh, and I do not recall giving docume ts to his 18 firm either.
19 Q
I recognize, Mr. Zowe, that since the i
20 accident you have given testimony and have been 21 interviewed on a number of different occasions.
I 22 know it may be difficult to sort them all out from
'23 memory, but I would like to go through that with you I
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24 and see if we can get your best recollection today 25 of the different places that you have testified.
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Zewe 7
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2 You have testified in connection with an 3
investigation being conducted by the President's 4
Commission, the so-called Kemeny Commission?
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5 A
Yes.
6 Q
And you have also given testimony in-7 connection with an investigation by semething called 8
the Special Inquiry Group of the Nuclear Regulatory 9
Commission, the so-called Rogovin Commission?
I 10 ;
A Yes, I have.
t l
11 Q
And you have given interviews, have you 12 not, to people from the Inspection and Enforcement
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13 Division of the NRC?
14 A
Yes.
15 Q
And you have also given interviews to 16 people from GPU that were conducting an investigation 17 into the circumstances surrounding the accident; 18 correct?
19 A
Yes.
20 Q
In addition to those four different 21 types of interviews. have you given any statements 22 or testimony to any other group that has been 23 l
investigating the accident?
~Y 24
-(J A
Yes, I have.
A j
25 Q
Would you tell us what group that was?
I 1
Zewe 8
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2 A
The Hart Commission group.
I 3
Q That is a Congressional committee; right?
4
. A Yes.
I l
5 Q
While we are on the subject of 6
Congressional committees, I guess you also gave some 7
testimony to Congressman Udall's coa.mittee; ts that 8
right?
,9 A
Yes, I did.
10 Q
Are there any other groups you have_given 11 testimony to?
12 -
A Yes.
The ACRS.
O 13 Q
When was that, Mr. Zewe?
14 A
I don't recall the' exact dates, but one 15 time occurred in Middletown at the Penn State 16 extension campus there.
And another one took place 17 in Washington, D.
C.
18 Q
Were each of these within a ye'ar after the 19 accident?
s 20 A
As I-recall, yes.
21 Q
Taking the one in Middletown first, what 22 was the format under which that took place?
they were trying 23 A
As I recall, it was 9
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O(_j 24 to determine what had happened.
More of a fact-25 finding group.
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2 Q
Were you the only one from Met Ed that j
3 appeared at that time or were there others?
4 A
There were others.
1
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5 Q
Did this take the form of a question-and-6 answer session?
t' 7.
A Yes, it did.
8 Q
With soaeone taking it down the same way 9
that the reporter is taking this deposition down?
10 A
I don't recall how the m e e t i'n g w a s 11 recorded.
12 Q
Do you know whether some record was made 13 of the questions and answers?
14 A
It's my recollection that there was, but 4
15 I'm not certain of that.
16 Q
Have you ever seen it since then?
[sked 17 A
There were times when I was to 4
18 further amplify or to explain certain questions that 10 came up during the course of those discussions.
20 Q
Do you remember the names of the 21 individuals from the ACRS that were conducting this?
.L 22 A
I can only recall two of the gentlemen's 23 names.
One of them was Mr. Michelson and another i
24 one was a Rags Mueller.
25 Q
Is-that all one name?
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A No.
2 f:
Q Two names?
3 I.-
A I believe his last name was Mueller 4
and his first name was Rags, as I remember.
I e
5 could be mistaken there.
6 7
Q Do you remember Mr. Michelson's first 8
name?
A I believe it is Carl.
9 t
10 Q'
Did you ever see any report that was 11 written by the ACRS as a resul.t of the investigation 12 that they had made?
D
%I 13 A
I have seen portions of it, though I 14 don't recall exactly when or to what degree.
15 Q
You referred to a second time when you 16 gave information to the ACRS, w ich you said was in 1~
18 A
That is correct.
19 Q
That was also a question-and-answer I
20 session?
21 A
Yes,it was.
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22 Q
Was there a record made of that proceeding?
23 A
My recollection of that meeting, also O) l
-- probably records were kept, if in
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I am not sure i
25 fact they were.
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ZeWe 11
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2 Q
Do you remember seeing a record of that 3
sometime after you appeared?
4 A
My recollection is that I did see portions
(
5 of it.
But there again, I don't have a very good 6
recollection on exactly how much of it.
7 Q
In addition to those.two sessions with-8 the ACRS, have you given information concerning 9
the accident to any other group other than the ones 10 we referred to earlier?
11 A
Just a moment.
ll2 Q
Kemeny, Rogovin, Congress, the I&E O(/
13 section of the NRC, and GPU.
And now the ACRS.
14 Are there any others?
15 A
Not that I can recall at this time.
16 Q
Did you give any testimony in connection 17 with the proceedings relating to the restart of TMI-17 18 A
I did not.
19,
Q Did you give any testimony in the 20 proceeding conducted by the Administrative Judge 21 Gary Milho111n relating to cheating on examinations?
22 A
I did not.
23 Q
Have you been subpoenaed to testify before
[V~h 24 a grand jury concerning anything relating to your 25 duties at Met Ed?
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zewe 12 2
A I have not.
3 Q
Going back to the period of time before 4
the accident let's take the period of a year
(
5 from March '78 to March '79 -- were you working as t
6 station shift supervisor for Units 1 and 2 at that 7
time?
8 A
Yes.
9 9
I am interested now particularly in. Unit 2.
10 My questions relate to that unless I state otherwise.
11 What records were kept in the control room J
12 concerning the daily operations of Unit 27 f)
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13 A
We kept a shift foreman's log.
A control 14 room log.
Switching and tagging log.
Special 15 operating procedure log.
Temporary change notice 16 log.
Lifted lead jumper and mechanical modification 17 log.
A dispatcher power outage log.
18 Also in the control room we had our 19 completed surveillance files and our completed I
20 procedure files.
21 Operating memo book.
Revision review 22 book.
23 That's about as complete as I can i
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24 remember at this point.
'd 25 Q
Who had responsibility for making the g
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2 entries in the shift foreman's log?
3 A
The on duty shift foreman.
4 Q
What did you understand the purpose of
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5 that log was?
6 A
To give a detailed account and description 7
of the shiftly activities.
8 Q
Who was responsible for making entries in 9
the control room log?
10 A
The on duty control room operator.
11 Q
What was the purpose of that log?
12 A
To again show the shiftly activities that
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li) occurred while they were on the shift.
14 Q
Did you understand that there was any 15 particular type of information that was supposed to 16 be recorded in one log rather than the other?
17 A
We had in place an administrative 18 procedure that gave guidelines on what type of 19 information could and should be displayed in the 20 shift foreman's log and in the control room operator's 21 log.
k' 22 Q
Can you tell us now in substance what 23 that said?
24 A
As I recall, without having it before me, 25 it would require you to list major power changes,
i 1
Zewe 14 2
reactor trips, any major plant equipment that was taken out of service or put in service.
Generally, 3
4 anything that the operator felt was significant.
(
5 And if he wasn't sure if it was significant or not, 6
'then he would write it down to make sure that it, 7
was caputred.for that particular date and time.
8 Q
And that same general saideline applies 9
to the shift foreman's log?
The shift foreman was 10 supposed ~to write down anything that he', con side re d 11 significant?
12 A
Yes.
13 Q
W'as-there a log called the shift test 14 engineer's log?
15 A
Yes, there was.
4 16 Q
Did you include that by some other name 17 in the list you gave me before?
18 A
I did not, because the shift test 19 engineer's log is not a normal log as such that we 20 keep in the control room.
21 Q
'What did you understand was the function i
22 of the shift test engineer's log?
23 i
A Its function, in my understanding, was gg to relate informa ion from one shift test engineer 25 ! to the other, and to their supervision, on a e
I.
1 Zewe 15 2
shift-by-shift basis.
3 Q
What kind of information did 4
you understand was recorded in the shift test
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5 engineer's log?
6 A
Generally, who had that particular shift 7
during a particular shift period, and who relieved 8
him, and anything else that that particular shift 9
test engineer felt was appropriate to capture and to 10
. pass on.
11 Q
Well, did you understand in a general way 12 that the shift. test engineers were supposed to write 13 down in their log anything that they considered 14 significant that had happened during their shift, the 15.
same way the control room operator and the shift 16 foreman were supposed to?
17 A
I am not really sure what guidance thep 18 had in maintaining their log.
So I would only be 10 guessing in saying that I would expect that they would 20' write down things that they felt needed to be passed 21 on and captured from their standpoint.
22 Q
Was there any practice at Met Ed before 23 the accident for periodic reviews by anyone of the 24 information in the shift foreman's log or the control 25 room log?
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Zewe 16 O
2 A
Woyld you restate that again, please?
3 I missed the first part of it.
4 Q
Sure.
Was there any practice or procedure
(
5 at Met Ed before the accident for periodic reviews 6
by anyone of the information that was recorded in 7
the shift foreman's log or the control room log?
8 A
Yes, there was.
The supervisor of 9
operations would review the log.
And I believe then 10 he would initial the log, saying that he had reviewed 11 it up to that particular point in time.
Plus, it 12 was a practice of the shift supervisors to,, review 13 the control room operator's log and the shift 14 foreman's log on a periodic basis.
15 Q
You were one of the shift supervisors; 16 is that. correct?
~
17 A
Yes.
18 Q
You had said that.
19 A
Yes, I did.
20 Q
And the supervisor of operations during 21 the period of time March '78 through March '79 for Unit 2, who was that?
23 A
James Floyd.
(
24 Q
What did you understand was the purpose 25 of having the supervisor of operations review the
I 1
Zewe 17 O.
2 information in the shift foreman's log and the 3
control room log?
4 A
I felt it had two purposes.
One, to
(
5 insure that the logs were being maintained in the 6
proper fashion, that they were complete and up to 7
date.
And also, as a review for Mr.'Floyd himself.
8 Q
What did you understand was the purpose 9
of having you and the other shift supervisors review 10 these logs?
11 A
I felt that it was also my role to insure 12 that the records were up to date and accurate and N
13 also as a personal review for myself.
14 Q
And when you say a " personal review" for 15 yourself, what do you mean by that?
16 A
We worked on an eight-hour shift basis.
17 And between the time that I left and when'.I came b'ck a
18 for my next eight hours of duty, I would review the 19 logs since the last time that I had left, just to 20 make sure that I was up to date on what had 21 transpired while I was gone.
22 Q
What practices or procedures were there 23 before the accident to have operating personnel I
i 24 review the information in the shift test engineer's l
25 log?
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Zewe 18
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2 A
As I recall, there was no set practice 3
f reviewing the shift test engineer's log on a 4
regular basis.
l 5
have reviewed portions of it from time 3
6 to time.
Other than that, that's all I remember.
7 Q
Under what circumstances would you review 8
the shift test engineer's log?
i t
9 A
The shift test engineer and the shift i
10 supervisor would get together at the st' art of each 11 shift.
And if he would point out to me that there 12 had been something written in the book by a previous 13 shift test engineer that was worthy of note, if he 14 would mention it, then I would go and review the book 15 itself, to try to gain a better understanding.
16 Q
Do I understand from that that it was
+
17 your practice as shift supervisor to trh to get 18 together with a supervising shift test engineer at 19 the start of each shift to find out if either of you 1
20 thought there was anything important that ought to 21 be discussed relating to anything that had happened k.
22 on the preceding shift?
23 A
Yes.
There was a pretty good relationship, 24 I felt, between the shift and the 25 shift test engineers and they were there to help i-
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2 us, and that we would certaidly get together to 3
brief on the next evolutions or past evolutions
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4 or anything of interest that could'a'ffect the
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5 operation of the plant or improve our involvement.
6 Q
Was that a practice that was followed 7
also by other shift supervisors and other s
8 supervising shift test engineers?-
t 9
A.,
It was my observatio s that that\\was A
10 generally true.
[u 11 Q
You weren't the only one* chat was doing 4
s 12 that?
O'.
13 A-I don't believe that I was, no. s 14 Q
How many shift supervisors for Un'it 2 3
15 were there in the year before the accident?
How
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16 many dif ferent people held that title?
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kt any one time?
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19 A
six.
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20 Q
And was there a comparable title for
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.21 shift test engineers to shift supervisor?
Nu 22 A
,I'm-afraid I don't understand what you 1
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I probably didn 't make it very clear.
25 You were a shift supervisor for the
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1 Zewe 20 I"%
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operators that were on duty during that particular.
3 shift; 'right?
4 Right?
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5 A
Yes.-
6
.Q
.There were also shift-test engineers on 7
duty during that same shift; right?
8 A
That is correct.
9 Q
O.
K.
Was there somebody that held the 10 same position relative to the test e ngi'n e e r s that 11 you held' relative to the operators?
12 A
(No response.)
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13 Q
Somebody in charge?
14 A
Yes, there was.
15 Q
What was that person's title?
4 16 A
As I recall, his title was start-up and 17 test superintendent.
18 Q
How many of thole people were there in 19 the year, year and a half before the accident?
20 A
only one.
21 Q
What was his name?
b gg A
Ron Toole.
23 Q
When you said that at every shift you
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I 24 would get together with somebody from the shift
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25 test engineers to discuss significant events that e
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2 had occurred on the preceding shift, was that always 3
Mr. Toole?
4 A
No, it wasn't.
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5 Q
What was the title of the person that 6
you would meet with to have that-kind of a 7
discussion?
8 A
Start-up and test engineer.
9 Q
Just, again, so I understand the way 10 this worked, would these discussions that you would 11 have, would '.hese be with-somebody that was just 12 coming on the next shift or would these be with
{)
13 somebody that had just finished the last shift?
14 A
Normally, I would have the d scussion 15 with the shift test engineer that would be coming 16 on to be.with me for the next eight hours.
17 Q
Right.
18 A
He would interface with his obf-going 19 counterpart and I would interface with my obf-going 20 counterpart.
21 Q
Right.
L 22 A
And then we would get together.
23 Q
To discuss things that your off-going f ')
24 counterparts had relayed to either one of you they ws 25 felt were significant on the preceding shift?
I l
1 Zewe 22
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2 A
Y,e s.
3 Q
Was there e. log that you yourself had 4
to keep, a so-called shift supervisor's log?
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5 A
No, there wasn't.
6 Q
You mentioned a technical change notice 7
log?
Did you?
Is that correct?
8 A
Temporary change --
9 Q
Temporary change notice.
I'm sorry.
I 10 A
Right.
11 Q
What was contained in that log?
12 A
That listed the temporary change notices k
13 that were in effect at any particular time.
14 Q
What was a temporary change notice?
15 A
Whenever a procedure needed to be changed, 16 we had two modes of changing it.
Either a permanent 17 change or a temporary change which would normally 18 lead to a more permanent change at a later date.
So if you needed to change a procedure that you 10 20 needed to use in the very near future, we had a l
21 I
mechanism that you could change certain portions of 22 !
a procedure, and all of these changes then were I
23 [
attached to the individual procedures and they were
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also put in this temporary change notice logbook.
24 ;
I 25 h Q
What were the circumstances under which l
l 1
Zewe 23 i
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2 you would be allowed to change a procedure by a 3
temporary change notice?
4 A
If we needed the change in the very near
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5 future and there was not sufficient time for it to 6
go through the permanent normal change routing, 7
then we would use a temporary change.
Or if the 8
change was only going to be in effect for a special 9
plant test that we were going to perform that would 10 not require a permanent change to the p'ro c e dure, we 11 used to use it then also.
12 Q
How high up in the organization did you f
i 13 have to go to get approval for a temporary change 14 notice?
15 A
Temporary change notice went through 16 what we called the plant operational review committee 17 review.
18 Q
so-called PORC?
19 A
PORC, yes.
And upon its approval, then 20 the unit or station superintendent would approve it, 21 and then the shift upervisor would then issue it 22 and carry it out.
23 Q
We are now talking about a temporary
(
24 change notice?
25 A
That is correct.
I 1
Zewe 24 2
Q Whet further review than that was 3
required fr a permanent change?
4 A
Permanent changes at that time had the
(
5 same channel to go through, the same routing.
6 Througn PORC, through the superintendent-But it 7
did not come back up to the shift supervisor then.
8 It was then -- the procedure itself was then 9
revised and rewritten, and it came up then as a new 10 procedure or a new portion of the proce' dure.
11 Q
You referred to something called an 12 operating memo book.
7-.s 13 A
Yes, I did.
14 Q
Could you tell us what kind of information 15 was put in that book?
16 A
It was a book used by Mr. Floyd to give 17 some further guidance to the operations department 18 concerning particular phases of the operation.
19 Q
Who was responsible for making the entries i
20 !
in this book?
31 A
The supervisor of operations.
k.
o2 Q
Did you ever review this book?
23 A
I did.
,m
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l o4 Q
Do you know where Mr. Floyd obtained the I
i 25 information that he put in the book?
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Zewe 25 Oa 2
A Wherever he could.
Whatever source he 3
had available to him.
4 Q
I guess-I am still a little unclear as 1
((
5 to what kind of criteria he had for putting 6
information in this book.
I mean, what kind of 7
things did you understand he was trying to record in i
8 this operating memo book?
9 A
As I recall, he was trying to insure that 10 all of the six shifts operated under hi's operating 4
11 g
philosophies.
12 Q
Was his operating philosophy recorded in (o
%-)
13 this book?
14 A
Not as such.
15 He would give each of the memos that 16 were in.the book dealt with a topic, a certain 17 specific topic itself.
And then he wo ul d '- a dd re s s 18 that one area, and then the next time that he wished 19 to address another area or even a related area, he 20 would make a separate memo that would address that i
21 area.
k.
22 Q
Were these memos circulated around among 23 the various shift supervisors?
(O) 21.
A Yes.
By virtue of the book being in i
~s l
25 the control room.
And it was part of the reading l
i.
1 1
Zewe 26 3
_ (j ~
i 3
material that the shift supervisors _and the on-shift 3
personnel were periodically to read.
4~
-Q So in other words, there was some sort
(
5 of an understanding prior to the accident that 6
shift supervisors and operating personnel were 7
supposed to go into the control room on a periodic 8 i basis and read this book?
9 A
Yes.
10 Q
To get Mr. Floyd's thoughts,for the day 11 and operating philosophy?
12 A
They weren't really thoughts for the day.
x_/
13 They were more items that he felt were necessary to 14 further clarify, and not necessarily those that 15 required a change in an operating procedure or a 16 great change in the way that we did business, but 17 just finally give direction in certain instances.
18 Q
Just one last question on thi How 19 frequently would Mr. Floyd put memos into this book?
20 A
It really varied.
21 Q
How frequently would you personally 22 review it?
23 A
I would review it every shift.
I j
}
24 Q
Then you mentioned a book called the 1
25 i
revision review book.
i l
1 Zewe 27 b) 2 A
Yes.
3 Q
could you tell us what kind of information 4
was in that book?
j(
5 A
When a new procedure,or a permanent 6
change had occurred relating to a procedure itself, 7
then the' procedure was placed in the revision review 8
book for all of the operating shift to review and to 9
make sure that they were aware that that particular 10 procedure had been changed or that thed9 was a new 11 procedure that had j.ust come into being.
12 Q
And again, I take it, this book was in O'
~13 the control room at all times?
14 A
Yes, it was.
15 Q
And shift supervisors and operating 16 personnel were. supposed to review this book
. 17 periodically?
18 A
Yes.
They would review it shiftly.
19 Q
could you tell us, Mr. Zewe, whether 20 there were any other types of material in the control
-21 room that you and the operating personnel were 22 supposed to review on a shiftly basis?
23 A
I just remembered two other logs that we
( )g 24.
l had there.
25 One of them was a locked valve book.
f i
?
l.
1 zewe 28
.O 6
%,J.
2 Another one was a transient cycle log.
3 Q
By your answer, did you mean that those 4
were two books that you were supposed to reelew on
(
5 a shiftly basis?
6 A
No, by 'and large, the transient cycle log 7
was not. reviewed on a shiftly basis.
Entries were 8
only made whene.ar you met the criteria to enter a 9
reading there that you had had a particular evolution 10 take place, so you entered it.
11 The locked valve book periodically was 12 reviewed.
I would review that shiftly.
f\\
'~'-
13 Q
Who was responsible for making entries 14 in the transient cycle log?
15 A
The shift foreman was.
16 Q
And what kind of information was supposed 17 to go into that book?
18 A
Information like feedwater, use of 19 emergency feedwater cycles on the nozzles.
Heatup f
20 and cooldowns.
Anything that had a cyclic effect on 21 the components.
Basically, the components of the 22 primary plant.
23 Q
Anything that had a cycli c effect on the r~%
)
24 l
components of the primary plant?
r(_/.
1 25 A
Yes.
There.Were set cyclic criteria
..~
I 1
Zewe 29 jrm -
'mj 2
that we had listed, that if you met those you would 3
then record it in the log.
.4-Q You listed several things in the course (L
5 of this discussion in the last half hour or so that 6
you would review when you came on shift in the control 7
-room.
Maybe you could just tell us or give us a 8
complete list when you came on duty for a shift, what 9
are the things that you understood you were supposed 10 to read during the course of that shif6, and if you 11 happen to repeat a couple that you have already 12 listed, that's O.
K.
1
\\/
13 A
The most important of which I believe I 14 haven't mentioned yet was, we had a shift supervisor's 15 handwritten current over-notes, which weren't 16 a log as. such and they weren't maintained, but they 17 we c from one shift supervisor to the next one so we 18 could gain insight into what had transpired through 19 the last shift and even through the last day.
20 I would review the shift' foreman's log 21 and the control room operator's log.
The surveillance 22 that was due for our particular shift.
23 I would review the locked valve book,
[)h 24
-revision review book, and the TCN book.
~.
25 Q
Was there information in the control room
l I
1 Zewe 30
/"%
t 4
- Q,i 2
concerning transients at Unit 2, prior transients?
3 A
Ask that again,, please.
4 Q
Wac there information in the control room
(
5 concerning prior transients that had occurred at 6
Unit 27 other than what might be reflected in the 7
control room operator's log or books that you t
8 previously referred to.
9 A
I don't recall now.
1 10 Q
Was there information in t h'9 control room 11 concerning transients that had occurred at other 12 plants?
13 A
Yes, and I don't recall between now 14 and back then exactly when the LER book was in the 15 control room.
I believe it was in effect during 2
16 that time period though I may be mistaken.
17 Q
What do you mean by the LER book?
18 A
License event report.
19 Q
I take it by an LER book, you mean a book 20 that contained LER's concerning transients at 21 other plants?
23 A
Yes.
l l
g Did you have any understanding prior to 23
(
34 the accident that you as shift supervisor were 4
25 supposed to review that book periodically?
l 1
Zewe 31 O
N_).
2 A
We would review LER's as such in our,
3 training program.
And I believe that I recall that 4
we would review it on shift periodically.
But I
(
5 don't remember the requirement to do that on shift 6
at any particular interval.
7 Q
How would you know when a new LER had been 8
added to'the book?
9 A
Periodic review, or another person would 10 say, " Hey, there is a new LER that is $here that you 11 should read."
12 Q
How often did you make your periodic A
I
'/
13-review of the LER book?
14 A
As I recall, it varied.
I really 15 couldn't say exactly.
16 Q
Well, without trying to be completely 17_.
specific about it, would you say that you reviewed 18 that book at least once a month?
19 A
At least that ~of ten.
20 Q
And sometimes more frequesntly than that?
21 A
Yes.
22 Q
on the occasions when you were reviewing 23 l it more frequently, would that be something like once i
h 24 a week?
x_/
25 A
Yes.
I 1
Zewe 32 A).
2 Q
From your observation of the other people
~ 3 that worked with you on your shift, will you tell us 4
whether it was their practice to review the LER book
(
5 at about the same frequency as you did?
6 A
It was my practice that whenever I 7
reviewed it, that I would remind the operators, "Have 8
you read it lately?"
They should have a look at it, 9
and if any particular event that was listed I 10 l thougnt they should review, then I used.to point it I
11 '
out.
12 Q
And were there occasions when one of
'_]
13 them, having read it, woiald point a particular one 14 out to you?
15 A
Yes, there was.
16 Q
And did that happen fairly often?
17 A
As I recall, it was pretty much both ways.
18 Q
You mentioned another log or book called 19 the locked valve book.
20 A
Yes.
21 Q
That is one you said you read every time.
k.
22 What kind of information was in the locked valve book?
23 A
Identified in our various procedures were b
24 valves where we were required to control the position
%d I
25 of them, whether it be locked open or whether it be
I 1
Zewe 33
[)
G/.
2 locked closed.
And there was a listing in the 3
1 cked valve book that would list all the valves 4
that were required to be secured in one particular l(
5 position.
6 Any time that a particular shift would 7
need to change the position, they would then log in 8
the date and the time and the reason for. changing 9
the valve, what the valve was, and who made the 10 change, and then it had a restoration hart, too, 11 where when you returned it to its normal locked 12 position, you would again mark that and indicate who n
~
13 and when and so forth.
14 Q
And why was it that you made it a point 15 to read this book every. time you came on shift?
16 A
I felt that it was essential that I know 17 the position of control valves of that nature.
18 Q
How many different valves were referred 19 to in this book?
20 A
I don't remember the number'.
21 (Recess taken.)
22 THE WITNESS:
I would like to make one 23 clarification, if I could.
i l
. [-s
\\_-}
~4 l
BY MR. FISKE:
9 l
25 Q
Yes.
I 1
Zewe 34 A/.
2-A In relationship to'the question that you 3
asked me, whether there were anything in the Unit 2 4
control room that related to prior Unit 2 transients
(
5 and I replied no, and then you refreshed my 6
recollection about the LER books, all right?
7 Unit 2 transients were also included 8
in that LER' book.
9 Q
O.
K.
1 t
10 A
I am still not certain yet whether the 11 time frame was right for the LER book, whether it 12 was as I remember.
fg 13 Q
I guess I understand from that statement, 14 Mr. Zewe, that.you are saying that the LER book 15 contained LER's not only for transients at other i
16 plants but also for prior transients at Unit 2; is i
17 that correct?
~
18 A
As I remember, yes.
19.
Q And when.you say you are uncertain about 20 the time frane, do you mean by that you are not sure 21 today whether the LER book in fact was in the control 22 room before the accident or not?
I l
23 I
MR. KLINGSBERG:
I think that you are --
3 j
24 4
well, your question as I understand it was 25 during the period March '78 to March
'79.
I 1
~
Zewe 35 N
N_lg 2
MR. FISKE:
Yes.
3 MR. KLINGSBERG:
You are asking 4'
particularly about the time of the accident.
(
5 Q
All of the questions that I was asking 6
you before we took the break concerning the LER 7
book and the re view and so forth, all of my questions 8
were referring to the time period roughly March '78 9
through March
'79.
10 A
I understood that.
11 Q
Did you understand that?
12 A
Yes.
O 13 Q
And just so I understand what your 14 testimony is now, it is your testimony that during
~
15 that period of time that is, one year before the 16 accident the book was in the control room and 17 was reviewed the way you have described it earlier?
18 A
As I recall, yes.
19 MR. FISKE:
Now I would like to mark 20 as B&W Exhibit 735 a letter from Mr. Zewe 21 to Mr. Collins dated July 5, 1977.
22 (Letter from Mr. Zewe to Mr. Collins, 23 dated July 5, 1977, was marked as B&W t
f\\
24 Exhibit 735 for identification, s_/
as of this 25 date.)
ll 1
Zewe 36-OV 2
Q Just before'I ask you a question about 3
that, Mr. Zewe, let me just go back to the'LER book 4
for one last_ question.
('
'5 A
O.
K.
6 Q
How much before March 1978 is it your 7
recollection that the LER book was in the control 8
room?
9 A
I don't remember.
10 Q
so if I asked you the same question 11 for the period of time, let's say, from March '77 to 12 March
'78, your answer would be you don't remember 13 whether the book was in the control room at that time?
14 A
I don't remember with any certainty.
15 Q
All right.
But just-so I understand your 16 testimony, is it your testimony that for whatever 17 period of time the book in fact was there,'the extent
~
18 to which you reviewed it was as you described it 19 earlier?
20 A
Yes, that is correct.
21 Q
O.
K.
Now I think we can get to Exhibit 22
,.735.
This is a letter that you wrote to Mr. Collins
.j-23 l_of the NRC in support of an application for senior 24 reactor operator's license examination?
i 25 A
Yes, it is.
l.
l 1
Zewe 37 7-U).
~
2.
Q This indicates that you graduated from 3 I West Mifflin North.
Is that a high school?
In 1964.
4 A
That is correct.
l 5
Q And then you went for a year to Steel 6
Valley Technical School in Pennsylvania.
7 A
That was actually for a two-year period, t
8 My last year in.high school was split between the 9
Steel Valley Technical School and then the year 10 after I graduated from high school, I c'ompleted the 11 final year.
12 Q
what course of study did you pursue at t
13 Steel Valley Technical?
14 A
Electronic technician.
15 Q
Then did you go from there into the 16 navy?
17 A
That's correct.
18 Q
And you were in the navy for approximately 19 five years?
20 A
Five years and nine months.
21 Q
On the top of page 2 of this letter it 22 says U.
S.
Navy 1966-1971.
It says, "I
served aboard 23 the USS BAINBRIDGE 1969-1971 as a reactor operator."
i f ')
24 Is that correct?
j 25.
A Yes, sir.
i y
,--c-.-,
.-7,-,,r
.yo-.,.--,,.ec
.,,,_,w,,,%.--
l 1
Zewe 38
/N V
2 Q
Did you have to obtain some sort of a 3
license to do that?
4 A
Yes.
(
'5 Q
From whom did you obtain the license?
6 A
From the ship's captain.
7 Q
Back on page 1 of this-letter it refers 8
to education at Basic. Nuclear Power School at 9
Bainbridge and also the Nuclear Power Prototype 10.
School in New York.
11 A
Yes.
12 r
.Q Was that training that you received in 1
(J -
13 preparation for obtaining a license to. operate the 14 reactor on the BAINBRIDGE?.
15 A
It was preparatory education for.that 16 license, yes.
17 Q
What kind of a ship was the B AINB RIDGE'?
18' A
Nuclear powered frigate.
19 Q
What kind of a reactor did it have?
20 A
It had two pressurized water reactors.
21 Q
Included in the training that you had k
22 before you received your license, was there any 23 simulator training?
( ') -
24 A
In the navy, you are referring to?
.v' t
25 Q
In the navy.
l 1
Zewe 39 2
.A The prototype training at S3G at West 3
Milton, New York was a simulator and training 4
facility.
_(
5 Q _
Did the pressurized water reactor on 6
the BAINBRIDGE have a pressurizer?
7 A
Yes, it did.
8
-Q Did you have written procedures that were 9
used by you as a guide to operating that reactor?
10 A
Yes, there were.
E 11 Q
Did you have training in the navy with 12 respect to emercency conditions?
O 13 A
Yes.
14 Q
Did you have training in the navy on 15 loss-of-coolant accidents?
4 16 A
Yes.
17 Q
What type of loss-of-coolant accidents' 18 did you receive training on in the navy?
19 A
Gross failures in the primary tbtat led 20 to loss of coolant.
l l
21 MR. KLINGSBERG:
Did you say " gross"?
i 23 THE WITNESS:
As I remember, yes.
23 MR. KLINGSBERG:
" Gross," g-r-o-s-s?
I
[
34 THE WITNESS:
Yes, large breaks.
A 25 g
I guess that leads to the next question.
l 1
Zewe 40
.s 2
Did you have any training in the navy on small-break 3
1 ss-of-coolant accidents?
4 A
Not that I can remember, no.
(
5 Q
Did the pressurized water reactors that
~6 you were trained on have high pressure injection 7
system?
8 A
As I recall, it had a system called a 9
flood system.
I don't recall the exact name of it
-10 now.
[
11 Q
Did it have any kind of system --
12 A
I do remember now.
Pardon me.
It was 13 called a fill system.
Fill system.
14 Q
Did it have any kind of a system for 15 injecting water into the primary system that was 16 actuated.by a drop in pressure?
17 A
As I recall, no.
It was manually 18 operated.
10 Q
Did you have any training in the navy on i
20 i this reactor with respect to saturation?
I 21 A
Only in terms of saturation conditions l
22 existing in the pressurizer and the steam generator.
23.
Q In the course of your navy training, did I
[
24 you ever have any discussions, either in the classroom i
s_
25 l
or on a simulator or during the course of operating i
f
I l
1' 1
Zewe 42
/~T
~
t i
v 2
solid" re fe rs to?
3 A
" Going solid" means adding enough water 4
to the primary in order to completely fill the
(
5 pressurizer.
.6 Q
Is it fair to say that it describes the 7
situation in which the entire reactor coolant system 8
including the pressurizer is full of water?
9 A
Yes.
10 Q
In the course of the experi'ence that you 11 had in the navy when you went solid.during cold 12 shutdown, as you have just described, did you have
(#)
?
13 occasion to experience the reaction of the system to 14 changes in pressure during solid conditions?
15 A
I don't recall specifics on it, but I 16 recall all of the precautions that we used to take 17 in order to insure that we did not either drain'from
~
18 and reduce pressure or add to and increase pressure 19 while we were solid.
20 Q
Well, wasn't that because you learned that 21 a small increase or decrease in water being added L..
22 to or taken away from the system could produce very 23 sharp changes in pressure at a time when the system
(-A) 24 was solid?
w t
25 A
That is my understanding, yes.
l 1
ZeWe 41 2
the reactor, about the possibility of saturation 3
ccurring in some part of the primary system outside 4
the pressurizer?
l 5
A I have no recollection of that.
6 Q
Did you have, on this reactor in the 7
navy, something equivalent to the reactor coolant 8
pumps that were at Unit 27 9
A We had what were called main coolant 10 pumps that would circulate the primary ' coolant, but 11 they were much different than Unit 2's.
12
-Q Did you have training in the navy on
(~).
\\/
13 cooldown procedures following a reactor trip?
14 A
We did have training on cooldown 15 procedures, yes.
+
16 Q
Did you have any training on use of.
17 natural circulation?
18 A
Not to my recollection.
19 Q.
I think you had testified on several 20 different occasions that during the time you were 21 in the navy you did have experience with going solid.
,L 22 A
The only experience that I can recall l
going solid was in a cold shutdown condition in order 23
(
24 to calibrate the primary instruments.
25 g
What do you understand the phrase " Going e
.,c.
~___
,_,m
,,.__-._m,-,-.
,m.,
..,,,,.,.,_.......-,.,-.,.....,r,
I 1-Zewe 43
'I 2
Q Let me just read to you some, questions 3
and ansvers from_ testimony that you gave before the 4
Nuclear Regulatory _ Commission special inquiry
.(
5 group.
6 MR. KLINGSBERG: 'Which is this?
Rogovin?
7 Q
Rogovin, September 11, 1979.
Here is 8
a copy (handing to the witness).
9 MR. KLINGSBERG:
What page?
10 MR. FISKE:
Page 195 and 196.
I will 11 tell Mr. Zewe what I am going to read.
12 THE WITNESS:
I was just looking in front
(~h
(,)
13 of that 14 Q
I will do this.
I will tell you what I 15 would like to read is from line 16 on 195 through 16 down to_the bottom of 196.
Before I even read it, if 17 you want to take time to look on either side of it, 18 take as much time as you want.
19 MR. KLINGSBERG:
O.
K.
20 Q
Line 16, page 195 starts with a question 21 by Mr. Frampton.
"MR.
FRAMPTON:
What were the things L
22 in your training and simulation that made you want to 23 avoid or be wary of going solid, running solid?
[h 24
" WITNESS ZEWE:
It is inherently unstable.
%_)
25 A solid system changing with large flow rates is
,,xs-,e---eswv---
1--"
1 e
e 1
Zewe 44 Q
%j.
2 inherently.a very large pressure transient, either up 3
-or down.
4 "If you are_ putting in a lot of water or
](
5 removing a lot.
It is inherently very difficult to 6
control.
From my previous experience in the navy 7
also, we used to take the primary plant solid-everyu 8
year to.do instrument calibrations and pressure was 9
very hard to control.
10 "M R. FRAMPTON:
When you say',prossure is 11 hard to control, is that because small changes in 12 liquid inventory result in large changes of pressure?
13
" WITNESS ZEWE:
Yes.
14 "MR.
FRAMPTON:
That is dangerous to the 15 system for stress reasons among others?"
16
" WITNESS ZEWE:
The controllability aspect 17 which relates to -- from going solid, you'are worried 18-about overpressurizing.
19 "MR.
FRAMPTON:
What was your experience 20 in the navy with these tests of going solid?
Can 21 you describe a little more~ about that?
22
" WITNESS ZEWE:
Well, we used to go solid 23 just to calibrate the primary instrumentation, but
(/)
24
. while we were solid, we took every precaution that w
25 we could to avert any pressure change because of
l 1
Zewe 45
_s
(
2 charging in water or adding heat to the system or 3
draining any water or removing any heat from the 4
system, so that you didn't have this pressure I
5 excursion because of the change in inventory system 6
affecting the pressure."
7 Do you remember testifying before this 8
Rogovin Commission back in September of 19797 9
A Yes, I do.
10 Q
And were you asked those questions and 1
11 did you give those answers?
12 A
I didn't recall these exact answers, but i
13 I have no reason to doubt that this is accurate.
14 Q
When you referred to a " pressure j
15 excursion" in that last answer that I just read, 16 is that.sometimes also referred to as a pressure 17 spike --
18 A
Yes.
19 Q
-- which also means a very sharp increase 20 in pressure; right?
If you were adding water.
21 A
While you were solid, yes.
l 22 Q
Yes.
i 23 l
What was your understanding as to why il r3 (v) 24 it was during normal operations that you wouldn't get t
i 25 a pressure spike if you added water to the system?
i 1-Zewe 46 O
2 A
During normal operation with normal
-3
-pressurizer level at 220 inches, we had about 4.
700 cubic-feet of steam space along with the 800-(.
5 cubic feet of water in the pressurizer, and it would G
be through the action of the pressurizer to limit 7
the overpressure condition from adding water.
8 Q
In other words, the presence of_ steam 9
acts as sort of a cushion to prevent that kind of 10 pressure spike?
~
r.
11 A
Yes, the pressurizer saturation conditions 12 result in dampening or limiting the pressure spike.
-( )
N' 13 Q
Did the pressurizer on the reactor on 14 the BAINBRIDGE have something that was comparable to 15 the pilot operated relief valve?
4 16 A
(No response.)
II Q
Maybe I will withdraw the question and 18 make it simpler.
19 Did the reactor on the BAINBRIDGE have any 20 type of - valve, safety valve, to allow pressure to 21 escape in the case of an overpressurization?
22 A
Yes, it had primary pressure relief 23 valves.
i 24 Q
What was it that caused those valves to 25 open?
J
I 1
Zewe 47 2
A An overpressure condition in the reactor 3
coolant system itself.
4 Q
Did you understand that those were 4
({_
5 safety items?
6 A
Yes.
7 Q
Did you have any other valve at the top of 8
the system which performed a function of relieving 9
pressure which was not a safety item?
10 A
As far as I can remember, the only-other 11 valve that we would have that would help in an 12 overpressure condition would be the spray valve.
- tN _
l 13 Q
Did you understand, as a result of your 14 training in the navy, that if one of these pressure 15 relief valves opened and failed to close, that you i
16 could have a loss of coolant?
i 17 A
Are you asking if I had training on that I
18 specifically?
10 Q
Yes, or did you have that understanding 20 while you were running this reactor on the 21 BAINERIDGE7 90 A
I don't recall the training on that, but I 23 l
did have an understanding that if the relief valve I
()
24 would fail open, that ycu would lose RCS water out of 25 it, yes.
1
-,-.---,-,,,,.r.,,..
.-...,--,,-.-,,r-.,~
..,-m-
-,._,,..,,m,--
sv-,--e,~~..
I 1
Zewe 48 g
\\
?
2 Q
Did you have any procedure, while you 1
3 were running this reactor, that was designed to help 4
you diagnose whether or not one of the'se valves had
(
5 stuck open?
6 A
Other than the loss-of-coolant procedure, 7
I don't recall any other procedures that dealt with 8
detecting that the primary relief valve was open.
9 Q
Put it another way. If you were in the course of a transient and the thought crossed your 10 i
11 !
mind that maybe one of these closed relief valves l
l 12 was op'en, did you have any way of determining whether i
I N'
13 or not that was the case?
14 MR. KLINGSBERG:
This is hypothetical 15 now.
You are not asking if he ever had such 16 a transient on the BAINBRIDGE.
I's MR. FISKE:
Not yet.
18 MR, KLINGSBERG:
All right.
10 A
I am afraid I lost track of exactly what 20 you were asking.
21 Q
Let me start again.
And maybe I will k
22 pick up Mr. Klingsberg's comment and put it in the 23 question.
[ ]
2;,
Did you ever in fact have a transient s
t 25 while you were in the navy where either one of these
A i
1 Zewe-49
(~N s
i N~s}
t 2
valves opened?
3 A
Not that I remember.now, no.
4 5
4 Q
As a result of your. training or from 4
l 5
whatever other source that was available, during 6
the time that you were operating this reactor in the i
7 navy, did you understand that if there were such l
8 a transient, that there was a way that you could 9
determine whether or-not these relief valves had 10 stayed open?
E i
i 11 A
I don't remember whether there was or not.
12 Q
Now, sometime in 1971 you left the navy?
I 13 A
Yes.
i 1
14 Q
And did you go right from there to Met Ed?
15 A
Yes, I did.
16 Q
And you started out as an auxiliary
~
17 operator in Unit 17 18 A
I did start out as an auxiliary operator, 19 but I was really hired in the group that was the j
i 20 group of auxiliary operators for Unit 2.
21 Q
You first were licensed, were you not, i
22 sometime in 1974?
93 j A
Yes.
Yes, that is correct.
w) 24 Q
Your letter to Mr. Collins says in j
25 paragraph 3 on page 2,
that from October 1973 to i
_~..-.
5 I
1 Zewe 50 3
2 May 1976 you were shift foreman; do you see that?-
3-A Yes, _ sir.
4 Q
That was at Unit 17
(-
5 A
- Unit 1,
and also Unit 2.
6 Q
Did you become a shift foreman before 7
you received your control room operator's license?
8 A
I was a shift foreman when I obtained my I
g I control room operator's license.
10 Q
You became a shift supervidor in May 1976; j.
11 is that right?
i 12 A
That is correct.
A\\J 13 Q
And you have held that position ever since?
1 14 A
That is correct.
t 15 MR. FISKE:
Could we mark this document 4,
16 as 736.
i 17 (Document bearing at the top the name 7
18 William Zewe and underneath that " Major Training 19 Programs" was marked as B&W Exhibit 736 for 20 identification, as of this date.)
i i
21 Q
Let me show you a document that has been
(_
j 22 marked as Exhibit 736, Mr. Zewe, which has at the top 23 l
" William Zewe."
Under that, " Major Training Programs."
3 i
~t Do you see that?
o.
J l
I 1
=
25 A
Yes, sir.
t l
I
_. - _. ~ -. _.. - _,, _. _ _.. _ _ - _. _..., _ _ - _ _,, _.. _,.. _.... _ _. _. _, _ _. _,. _ _,...... _ _ _. _. -,, _,. _ -, _,, _. _..
l 1
Zewe 51 2
Q Do you recognize this document?
3 A
I do not.
4 Q
Would you take a minute to look at it
[
(
~
5 and tell us whether, after having looked at it, 6
this document reflects accurately the training _that 7
you received from the time you started at Met Ed 8
through January 19797
.9 MR. KLINGSBERG:
Can we have the question 10 t back.
I 11 j (Question read.)
12 MR. KLINOSBERG:
You are asking if it O~
13 reflects all the training or, as it is entitled 14
.the maj or training? -
15 MR. FISKE:
Let's put it this way.
16 Q
Mr. Zewe, after looking at this, can you 17 tell us that you did in fact receive all of the 18 training that is listed in this exhibit?
19 A
As I remember, this is most of the major 2 -
20 training that I in fact received, yes.
I 21 Q
Just so we understand each other, you 22 did in fact receive all of the training that's listed i
23 l
in this document?
(^)
24 x
air of these courses, times, hours and 25 dates.are familiar in a general sense, but not as
I 1
Zewe' 52
/~.
_)
2 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Generally speaking, yes, but 3
I really couldn'tfattest to the-fact that at any 4
particular time that it was 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of training or
(
5 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6 The subject matter seems true, but only 7
in a general sense.
8 Q
As you look through this, do you remember
.9 receiving any training down at Lynchburg, Virginia 10 from B&W other than what's listed on-here?
11 A
It seems to me that between item 11 in 4
' 12 1975 and the next-listed s.imulator training in
'77, 13 I believe that I was down there in
'76.
My 14 recollection is being at the Lynchburg, Virginia 15 simulator facility every year since the origin al time 16 in
'73.
l 17 Q
Am I correct that you went to'the simulator i
18 in January 1979?
That is item 30 on this list.
19 A
That's correct.
20 Q
And you went at that time in your capacity 21 as a Unit 1 shift supervisor?
l 22 A
That is correct.
i
]
23 l
Q With the exception of the 1976 situation 24 that you referred to a moment ago, Mr. Zewe, is I
25 there any other training that you received at B&W that i
1 1
Zewe 53 i
v.
2 does not appear on this 1ist?
A N t that I could pick out at this time.
3 4
Q I would like to ask you some questions, l
5 Mr. Zewe, which now sort of really encompass all 6
of the training and learning that you had about the 7
operation of the reactor, Unit 2, right up to the g
time of the accident in March of 1979.
So I am 9
asking these questions in terms of your understanding 10 of the system and so forth as it exist $d in March 11 of 1979.
12 A
Unit 2.
tN' 13 Q
Yes, based on any learning.in the navy, 14 at B&W or. Met Ed or wherever.
15 The reactor in Unit 2 was a pressurized 16 water reactor.
17 A
Yes.
18 Q
How does that differ from a boiling water 19 reactor?
20 A
I have a very limited understanding of
~t the operation of a boiling water reactor since all o
C.
22 of my training has been on the pressurized water reactor.
But it is my understanding that in a 23
()
34 boiling water reactor, that the reactor coolant is 25 allowed to boil and that this steam then flows to 4
1 Zewe f-54 V.
2 the turbine, and that the control rods come in from 3
the bottom versus the top, instead of at the top 4
as in a pressurized water reactor.
5 g
Is it fair to say that a fundamental 6
difference between the two is that in a boiling 7
water reactor the reactor coolant itself boils, 8
whereas in the pressurized water reactor it does not; 9
is that right?
t 10 A
State that again.
11 MR. FISKE:
Why don't you read it.
12 (Question read.)
O--
13 A
The only boiling that occur,s,in a 14 pressurized water reactor is in the pressurizer, 15 whereas in the boiling water reactor it actually 16 occurs in the RCS itself.
17 Q
In the pressurized water react,or, the 18 water in the reactor coolant system itself is at 19 very high temperature right?
20 MR. KLINGSBERG:
What do you mean, l
21 "very high"?
22 Q
Let's say 550, 600 degrees Fahrenheit.
23 A
Yes.
(b
./
24 l
Q What is it that keeps the water at that i
25 temperature from boiling?
M 1
Zewe r"S 55 2
(_J.
2 A
The system is maintained at a higher 3
pressure than saturation for the particular 4
temperature.
1 5
Q And under normal operations that pressure 6
is 2155 pounds per square inch?
7 A
Psig.
8 Q
Psig.
9 A
Yes.
t 10 Q
And is it correct, Mr. Z e w e,' that the 11 function of the pressurizer is to maintain that g-12 pressure to keep the water in the reactor coolant
(],/
13 system from boiling?
14 MR. KLINGSBERG:
Pardon me.
.Just as a 15 matter of clarification, are you asking these j
16 questions based on his current understanding I
17 today?
18 MR. FISKE:
No.
19 MR. KLINGSBERG:
His understanding at some 20 prior point in time?
21 MR. FISKE:
Yes.
I 22 MR. KLINGSBERG:
Would you make that 23 clear.
l p)
\\-
24 l
MR. FISKE:
I explained to Mr. Zewe when i
25 I started this series of questions, that I was
, ~ -. _
.. _.l.,_
I Zewe 56 v
2 asking him for his understanding as it existed 3
in March 1979, based on any information that 4
he had learned from any source, navy, B&W, 5
Met Ed, wherever, at any point up to then.
6 Maybe you would like to hear the last 7
question again.
8 THE WITNESS:
Yes.
9 (Question read.)
t 10 A
It was my understanding that the 11 pressurizer had several functions, one of which was 12 to maintain an inventory level in the RCS to 13 accommodate for in-surges and ou t-surges from the 14 reactor coolant system on heatups and cooldowns, and 15 also to provide the highest pressure source for the' 16 reactor coolant system.
17 Q
But you did understand that it-was 18 necessary to keep the water in the reactor coolant 19 system under high pressure in order to keep it from 20 boiling and that it was the function of the
(
21 pressurizer to provide that pressure?
22 A
Pressurizer normally being the hottest 23 portion of the RCS to maintain the overpressure 24 l condition, yes.
i 25 I
Q Let me show you an excerpt, a section of
1 zewe 57 t
4 2
the final safety analysis repcrt filed by Met Ed 3
with the Nuclear Regulatory Commission, which is 4
section 5.5.10, captioned "The Pressurizer."
I will 5
just read one sentence from it and then show it to 6
you.
It says, "The pressurizer is designed to 7
provide a capability of maintaining the reactor 8
coolant system at saturation pressure to prevent 9
boiling of the coolant."
t 10 were you familiar with that section 11 of the FSAR before the accident?
f'}
12 A
I was generally familiar wi-th the FSAR,
. 'm/
13 Unit 2.
And I don't recall this particular paragraph 14 of section 5.
15 Q-But based on your understanding of the 16 system back in March of 1979, you wouldn.'t consider
^
l 17 that an inaccurate statement of the function of the 18 pressurizer?
19 A
No, I would not, i
20 Q
You referred a m.oment ago, Mr. Zewe, to
(
21 the fact that the water in the primary reactor 22 coolant system is at different temperatures in 23
[
different places.
There is a so-called hot leg and
!. ("
i
\\-
24 la so-called cold legs is that right?
o 25 A
Yes.
4-1 Zewe.
58
-/
1
(
2.
Q And'is it correct that the temperature.
3 in the hot leg ordinarily in normal operations is 4
i i
4 somewhere around 605 degrees?
(
5 A
602, 603, yes.
6 Q
And the hot leg is the portion of the 7
primary system after the water has gone through the 8
core and been heated up; isn't that correct?
Between 9
the core and the time the water gets to the steam i
10 generator?
11 A
The hot leg, yes.
i 12 Q
Yes.
And then after it goes through the 13 steam generator, the water gets cooled'down to 1
14
. temperature of around 550 degrees Fahrenheit?
l 15 A
Yes.
16 Q
And at that point it is in the so-called i
l 17 cold leg of the reactor?
18 A
Yes.
19 Q
And then it goes back through the core 20 again; correct?
l 21 A
Yes.
22 Q
And in the process of going back through 23 the core the water gets heated back up again to 602 l
(O_)
i
}
24 degrees; right?
25 A
- Yes, i
.,.,,,,_m.,,,.__._,.,_.._..._.,,..
.,.,....._,__,...,_,...,.,__.,__.,_,,,...~....._.....,.--.___,,m...._,,,--.-.-
Zewe 3-59 2
Q And isn't it correct that also in the 3
process of going through the core, the water which 4
enters the core at 555 degrees provides a cooling 5
function?
6 A
Yes, it does.
7 Q
Now, in the course of everything that you 8
learned about the system up to the date of the L
9 accident, what understanding did you have as to why-e 10 it was important in running the reactor'to keep the 11 water in the primary-system from boiling?
(~}
12 MR. KLINGSBERG:
Well, I object to the
'b!
13 form on the ground that I don't think you have 14 established a predicate for the quest on.
But 15 the witness can answer, if he can.
16 THE WITNESS:
Would you repeat the 17 question again, please.
18 (Question read.)
19 A
You are referring to other than boiling in 20 the pressurizer which in fact is part of the primary
(
21 itself.
22 Q
Yes, as a matter of fact, that is 23 probably a helpful point.
I think maybe we could
\\~
24 establish that when I am talking about the reactor 25 coolant system, let's assume from now on that I am
.. ~.
1 Zewe 60 t
1
%)
2 talking about that part of the system other than the i
3 pressurizer.
And when we talk about the pressurizer, 4
we will talk about the pressurizer.
O.
K.?
But you
(.
5 are right.
My question does refer to that portion of 6
the system outside the pressurizer.
7 A
Well, the importance was that the plant 8
was designed to have the primary in a liquid' state, 9-and that the heat removal provided by the reactor
(
10]
coolant in cooling the reactor was much'more efficient i
11 in a liquid, state than it would be.in a steam fs 12 environment.
13 Q
And what did you understand ~ were the 14 possible adverse consequences of reducing the coolant 15 capability of the water in the reactor coolant system?
16 A
The result would be overheating to the 17 extent that you reduce the coolant.
18 Q
overheating of the core?
4 19 A
That being your primary heat source, yes.
}
20 Q
And what did you understand was bad about j
(
21 overheating the core?
I 22 1 A
The reactor core is designed to operate 23 within certain thermal limits and to exceed these O
.i s_/
24
)
limits would be adverse to maintaining the reactor l
25 core in a desired mode.
l
____-_,.l.-_---_-_.----.,_-..-,,__-._.
1 Zewe
(~h 61 V.
2 Q
Well, did you understand that overheating 3
of the. core could produce damage to the core?
4 A
severe overheating could lead to damage 3
5 of the core, yes.
I believe that.
6 Q
Did.you understand that damage to the 7
core could result in the release of radioactive 8
material into the coolant?
.9 A
If the fuel cladding was damaged to a i
t 10 degree that the isotopes and gaseous pro' ducts from 11 the fission process would be released into the-0 12 reactor coolant system, yes.
l 4
13 Q
Putting it simply, you did understand i
\\
14 that one possible consequence of overheating the core 15 was causing damage which could produce a release of i
16 radioactive material into the coolant?
1 17 A
In a severe case, yes.
i.
18 Q
Under normal operations, Mr. Z e,w e, what j
19 was th pressure I guess we have already established 3
20 that the primary system pressure was 2155 psig.
{
i 21 A
Yes.
22-Q And I think we have talked about the l temperatures 4
23 i
in the hot leg and temperatures in the i
("%
i
'A 24
, cold leg, But what was the temperature in the i
25 pressurizer under normal operations?
d
.,,y-.~
.at
-r------~-
-*-e-e-
" emm
==++rm e---
- * &-+vver-v*r~ ~ "
-e-**-*ee-tr -w
^-w-*-*----a--t+-or
w-*-sv---"wv vw-
- e
1-Zewe 62 rN
-(
6
. %,)
2 A
648 degrees.
3 Q
Is it correct that under normal 4
operations the reactor coolant system pressure of 5
2155 was the same throughout the entire reactor 6
coolant system, including the pressurizer?
7 A.
No, that is not correct.
8 Q
Well, in what way is that'not correct?
i 9
A Throughout the reactor coolant system i
^
l 10 you had pressure drops ~in the water traveling through 11 the steam' generator and also traveling through the 12 reactor core and through the system piping itself, and
,!(
13-you had a pressure increase afforded by the reactor 14 coolant pumps themselves.
So if you would look at I
15 the loop at any particular point, the pre,ssure would 16 not always be constant.
j 17 Q
You had an instrument, didn't~you, in l
18 the control room, that reflected reactor coolant l
19 system pressure?
20 A
'Yes, I did.
21
.Q And at what point in the system did you i
22.
understand that was measuring the pressure?
i 23 A
In the hot leg.
(~)N
\\.-
24 Q
And that is 2155 under normal operations?
25 A
Yes.
- j. '-
i l
1 3 ewe 63 s-2 Q
And is the pressure in the pressurizer 3
under normal operations 2155?
4 A-Yes.
5 Q
so that in simple terms, under normal 6
operations the pressure was the same in the 7
pressurizer and the hot leg, but the termperature in 8
the pressurizer was higher than that in the hot leg?
9 A
Yes.
t 10 g
why did you understand that ~it was 11 important that the temperature in the pressurizer be 12 higher than the temperature in the hot. leg?
13 -
MR..KLINGSBERG:
You have skipped a 14 question.
You always ask "Why did you think 15 it was important," but you never established 16 first that he thought it was important.
Maybe 17 he did.
18 MR. FISKE:
I will be happy to ask the 19 question.
I guess maybe I assume the answer 20 to that.
(
21 Q
Did you understand, Mr. Zewe, when you 22 were running this reactor in March of 1979 that it was 23 l
important to keep the temperature in the pressurizer
[~
kT i
24 above the temperature in the hot leg?
1
(
25 A
Yes, I did.
s
1 Zewe 64 2
Q Why did you understand that was 3-important?
4' A
In order to maintain primary system 5
pressure control within the pressurizer.
6 Q
O..K.
But why were the relative 7
temperatures important - in order to be able to 8
maintain that kind of control?
9 A
Saturation conditions exist in the t
10 pressurizer and if I could maintain those saturation 11 conditions above the rest of th'e RCS, then I can
/~
12 maintain pressure control within the pressurizer.
()h 13 Q
And what did you understand would happen 14 if temperature in the hot leg exceeded --
15 equaled or exceeded -- temperature in the. pressurizer?
16 A
I don't recall considering that the hot j
17 legs would ever get hotter than the pressurizer i
18 temperature during normal operation or otherwise.
I 10 Q
Why did you think you might not be able i
l 20 to maintain pressure control if the temperature in I
(
21 the pressurizer did not stay above the temperature in 22 the hot leg?
23 j
A Well, the system is designed for the e
i s
(--)
4 24 i
pressurizer to run at a higher temperature than the i
25 RCS.
So it was designed that way in order to be 1
4 e
s-t--
=
-c r'
~-ew-'
v v
erv7- - m w e+
ev -' y e----"**---3*--
- = -
- =--*e-w'=---
w-
1 1
Zewe 65
.2 able to control pressure in the pressurizer itself.
3 Because we have a heater in the pressurizer, we have 4
a spray valve to reduce pressure in the pressurizer the heaters to raise pressure, and you always 5
or 6
wanted to have the control of that parameter in the 7
pressurizer itself.
i 8
Q Well, did you have an understanding that 9
if the temperature in the hot leg equaled the i
10 temperature in the pressurizer, that you might then 11 have saturation in the hot leg?
.(~}
12 A
I believe I realized that if the
\\/-
13 termperature in the hot leg reached the saturation 14 temperature for the pressure that existed in the hot 15 leg, that you would be at saturation, y e s..
16 Q
Were you familiar with a concept, before 17 the accident, called " transferring the bub,'ble"?
18 A
Could you rephrase in what context you 10 mean transferring the bubble?
20 Q
Were you familiar with the phrase
(
21
" transferring the bubble" or " popping the bubble"?
22 A
Yes, I am, in terms of we used to add 23 nitrogen into the pressurizer and form a nitrogen i
24 bubble in the pressurizer and then we would vent off 25 the nitrogen and draw a steam bubble in the r
,--e--,
e, m
,,.-,,-en,-.,,,,..,,----,,.,,n-r
-,.n,,,,ne,,,,--,,,,.
...w,...,,.,n-,,
e.--r,n.,
i 1
Zewe 66 2
pressurizer.
From that sense.
3 Q
No, I am talking about a concept of 4
transferring a steam bubble from the pressurizer into 5
the hot leg, or into the reactor coolant system 6
itself.
7 A
I see what you mean.
8 The only time that I can recall thinking 9
about transferring the bubble from the pressurizer to t
10 the RCS is if for some reason I would lose level and 11 pressure control in the pressurizer and result in 12 draining of the pressurizer and then drawing the 13 bubble in the reactor coolant itself in the hot leg.
14 Q
That is a concept that you were aware of 15 before the accident?
16 A
I have heard that concept, yes.
17 Q
Mr. Zewe, what I would like tkdo is show 18 you an exhibit that has been marked previously, 19 which is a section of the technical specifications for 20 Unit 2,
section 2.0, and then the caption is
(
21
" Limiting Safety System Settings."
This has l
I 22 been previously marked as B&W Exhibit 572 (handing i
l l
23 document to the witness).
i 24 I
I take it, Mr. Zewe, that in the course 25 of the training that is reflected on this Exhibit 736 l.
l l
1 Zewe 67 r
gu 2
that.we went through before, you did receive training 3
on the technical specifications for Unit 27 4
A I did.
(-
5 Q
Directing your attention to page 2-1 of 6
the technical specifications, at the top of the page 7
it says, "2.1 Safety Limits."
Right under that it 8
says " Reactor Core."
And then under 2.1.1, it D
says "The combination of the reactor coolant core 10 outlet pressure and outlet temperature shall not 11 exceed the safety limit shown in figure 2.1-1."
12 Do you see the reference, the section 13 of the specification that I just read?
14 A
Yes.
15 Q
And then there is a figure 2.,1 - 1, is there 16 not?
17 A
Yes.
~
18 Q
Made part of this same specification?
19 A
Yes.
20 Q
And that figure contains, does it not,
(
21 a range of pressure-temperature relationships within 22 which you were supposed to stay during normal 23 operations of the reactor?
24 A
Yes.
25 Q
At the top, it indicates "RCS Pressure
F 1
zewe 68
,(_,
2 High Trip."
3 Do you see that?
4 A'
Yes.
5 Q
Is it correct that if pressure reaches 6
that level, no matter what the temperature is, there 7
will be an automatic trip of the reactor?
8 MR. KLINGSBERG:
You are talking about 9
in relation to this 2.17 t
10 MR. FISKE:
Yes.
4 11 THE WITNESS:
He was asking about that 12 (indicating).
13 A
That itself is not a safety 1,im i t.
That 14 RCS pressure high trip is actually a limiting safety 15 system setting of the-RCS.
But if you do, exceed i
16 that, regardless of the temperature, you will have 17 a' reactor trip.
~;
18 Q
All right, and there is also an j
19 automatic reactor-trip on LOCAs; correct?
1
~
20 A
That is correct.
(
21 Q
And that is also a limiting safety 22 setting?
I 23 A
Limiting ststem safety setting, right.
i pU 24 l
Q And up at the right-hand side is the RCS j
i 25 pressure variable low trip; correct?
I l-l
,-. - a -.-
1 ZeWe 69 U.
2 A
That is correct.
3 Q
And does that indicate various pressure-4 temperature relationships at which the reactor.will 5
trip?
6 A
Yes, it does.
7 Q
All right.
8 A
I would like to point out that this 9
- figure, 2.1-1, as applied to the reactor core safety e
10 limit under 2.1.1, only is applicable in modes 1 11 and 2.
(~}
12 Q
And what are modes 1 and 2,
for the
\\_/
13 benefit of the uninitiated?
14 MR. KLINGSBERG:
Off the record.
15 (Discussion off the record.)
16 A'
Mode 1 is power operation greater than 17
-five percent power.
Mode 2 is a start-up mode which 18 allows you to go up as high as five percent power.
19 Q
O.
K.
But mode 1 is normal operations?
20 A
Yes, it is.
(
21 Q
Now, on the right-hand portion of this 22 figure there is a line that is designated " Safety l
23 Limit."
n' f
24 i
Do you see that?
I I
25 A
Yes, I do.
l' Zewe 70 fV 2
Q._
And did you understand that that is the.
3-safety limit that is referred to in section 2.1.17 4
A Yes, I did, h
5 Q
And this line indicates various pressure-6:
temperature relationships, does it not?
7 A
Yes, it does.
8 Q
And did you understand that the reactor 9
was supposed to be operated so that the pressure-L 10 temperature relationship stayed on the 'left-hand side 11 of that line?
(~h 12 A
Not only to the left hand of that line,
.U 13 but also to the left hand of the bounding curves of 14 the high pressure, low pressure, variable lower 15 pressure, and high temperature in the acceptable 16 operation region.
ihwas 17 Q
Why did you understand that a
18
. safety problem if pressure-temperature rel,ationships 19 deteriorated to the right side of the safety limit 20 line?
(
21 A
Say that again, please.
22 MR. FISKE:
Would you read it back.
I 23 (Question read.)
)
24 MR. KLINGSBERG:
Again I think you 25 skipped a question.
The witness didn't say
I Zewe
(
t 71 rw
%d 2
it was a safety problem.
3 Q
Can you answer the question, Mr. Zewe?
4 MR. KLINGSBERG:
If you can.
5 A
I believe I can, yes.
6 I believe that my understanding of 7
exceeding that safety limit, as you put it, would be 8
to prevent from overheating the cladding.
9 Q
Why did you understand that the pressure s:
10 at which the reactor coolant system was' maintained 11 had anything to do with whether the cladding was L '~'g 12 overheated or not?
.)
13 A
The overcladding
,- or the heating of 14 the cladding is related to departure from nuclear 15 boiling, and that the pressure and temperature has 16 a relationship in regard to departure from nuclear 17 boiling.
18 g
what happens if the pressure-19 temperature relationship deteriorates to the point 20 where there is a departure from nuclear boiling?
(_
21 MR. KLINGSBERG:
Again you are talking i
22 about and say what happens.
You mean what was 03 his understanding prior to March 1979?
(
l MR. FISKE:
Right.
24 l
25 A
My understanding in a theoretical l
r
I Zewe 72 I-w)
V 2
- sense was that once you left the efficient means 3
of heat transfer afforded by nuclear boiling and 4
departed-from that into ~ either film boiling or bulk 5
boiling, you significantly reduced the heat transfer 6
capability.
7 Q
What is the difference, as you understood 8
it, between film boiling and bulk boiling?
9 A
My understanding at that time I believe 5
10 was that the film boiling was the cover'ing of a steam 11 layer over a heat transfer surface area, and that
[~\\
12 the bulk boiling was a much larger layer of steam and V
13 it would lead to reduced heat transfer ~ capability 14 from that' surf ace area.
15 Q
Directing your attention, Mr. Zewe, to 16 page B2-1 of this same part of the technical i
~
17
. specifications --
18 A
o.
K.
19 Q
-- this part of the technical 20 specifications follows a note that says, "The summary
(,
21 statements contained in this section -"
l
- 22 A
Where is that?
23 Q
The preceding page.
It says, "The 1-i 24 summary statements contained in this section provide 25 the bases for the sp ecific a tions of section 2.0 and
-ev<
-w-w-y,.-v
~ar-..--
ew.
y
.c--
-c
--=- y
1 Zewe
' Q
~
73 r
Q 2
are not considered a part ~of these technical 3
specifications."
4 You were familiar with that before the 5
accident?
6 A
Yes, that the bases were included after 7
the. specs, yes.
f 8
Q And that the material on page B2-1 9
captioned " Safety Limits"'provides the bases for e
10 the specification back under section 2.'1.1 that 11 we were talking about earlier; right?
4 12~
A Yes.
3 t ' J 13 Q
Section 2.1 captioned "Saf'ety Limits" 14 has a section that says'" Bases" and then it reads 15 "2.1.1 and 2.1.2 Reactor Core."
It reads, "The i ~
16 restrictions of this -"
17 A
I was just referring back to"what 2.1.2 18 was.
19 Q
Let's start again.
Back in the very 20 beginning of this p a,g e 2-1, there is the paragraph
(
21 captioned " Safety Limits Reactor Core" under section 22 2.1.1 that we read earlier.
Correct?-
23 A
Yes.
r
\\
24 Q
What we are about to read now you 25 understood was the basis for that section; correct?
1 Zewe 74 v
2 A
Correct.
3 Q
That appears as B2-1 and reads, "The 4
restrictions of this safety limit prevent overheating 5
of the fuel cladding and possible cladding 6'
perforation which would result in the release of 7
fission products to the reactor core."
8 Do you see that sentence?
9 A
Yes, I do.
5 10 Q
And you were familiar with'that before 11 the accident?
(~'
12 A
Yes, I was.
v 13 Q
Just so we can complete the
,l o o p,
as they 14 say, this reference to safety limit in 2.1 -- this 15 reference to safety limit in the sentence that I just 16 read refers to the line on the figure captioned previ}ously; right?
17
" Safety Limit" which we referred to 18 A
Yes.
The far right-hand line.
19 (At this time, 12:30 p.m.,
a luncheon 20 recess was taken.)
l
(
21 t
22 i
i I
i 23
' 1 1
i
~ ' '
24 25 i
I l
1 75 i
2 AFTERNOON SECTION l
3 2:05 p.m.
4 W I L L IA M H.
ZEW E, resumed.
5 EXAMINATION (continued) 6 BY MR.-FISKE:
X e
7 Q
Mr. Zewe, were you familiar, before the
.3 8
accident, with the heatup/cooldown curve which was 9
a part of a number of the operating and emergency e
10 procedures at Met Ed, Unit 2?
11 A
I was familiar with the heatup and 4
12 cooldown curves which were contained in our v
13 procedure,- yes.
14 Q
Let me show you a document which has 15 been marked before as B&W Exhibit 540.
16 Do you recognize that as the operating 17 procedure for a unit cooldown?
18 A
It looks familiar as the unit cooldown 19 procedure as I recall, yes.
4 20 Q
Directing your attention to page 3,
at
(
21 the bottom there is a paragraph 2.1.1 It says, 22
" Reactor coolant temperature, pressure and cooldown 23 rates shall be maintained within limits specified
- b i
%/
24 in figures 3.4-2 and 3.4-3 of TS3.4.9.1," and then i
25 there is a reference to figures that are attached.
4
4 1
Zewe 76 C- )
J 2
Do y6u see that?
3 A
Yes, I do.
4 Q
Then turning to the back, the first 5
figure is a heatup/cooldown curve; correct?
6 A
Figure No.
1, yes.
7 Q
Did you understand the effect of this 8
particular paragraph of the procedure was that 9
reactor coolant temperature and pressure had to be i
(
10 maintained within the limits specified on the' curves 11 in this figure?
12 A
The limit and precautien did state it 13 was to be maintained within the limits'of,that curve, 14 yes.
15 Q
Just-looking at the figure, you see a 16 number of different curves there.
17 MR. FISKE:
Off the record.
18 (Discussion off the record.)
19 Q.
Are there curves on this figure called 1
20 fuel pin compression curves?
(
21 A
They are labeled, yes, the " minimum RC 22 pressure to maintain compression force on the fuel."
23 Q
Which curves?
What number are they?
O
\\-
24 A
Curve 2 and curve 3.
25 Q
Wh'at did you understand was the difference 2.
b
i,.
1 Zewe 77 k-i 2 i between' curve 2 and curve 37 i
I 3
A Forced-flow versus natural circulation.
4 Q
Curve 2 is forced flow?
8 5
A Curve 2 is natural 1 circulation.
~
6 MR. FISKE:
.Off'the record.
7 (Discussion off the record.)
8 Q
On which side of the curve did you i-9 understand you were supposed to stay?.
t 10 A
Between curve 1 and curve 3.
~
11.
Q I take it if you were in natural y
circulation you would be between curve,1 and curve 2 ?.
12 13 A
That is correct.
During.cooldown.
14 Q
Yes.
15 What did you understand that,the line 16 represented by this curve represented?
i 17 MR. KLINGSBERG:
which curve'are you i
i l-18 talking about?
19 MR. FISKE:
Let's take curve 2.
20 Q
Well, let's take curve 3.
21 A
What did I understand that curve to
(
22 represent?
{
23 Q
To represent, yes.
24 A
It represented a temperature and pressure 25 relationship'to insure that we had RC pressure I
1 j
Zewe 78 N,.
2 applying a compressive force on the fuel cladding.
i 3
Q.
Is it correct that it was important to 4
maintain a certain RCS pressure on the outside of 5
the fuel cladding _to compensate for pressure being 6
exerted from the inside.of the fuel cladding?
7 A
Yes.
Our fuel was pressurized.
And this 8
insured that the primary pressure pressing in on the 9
clad would counteract the inside pressure of the I
10 pressurized fuel.
11 Q
And why did you understand the i
h["N 12 temperature at any given level might have an effect 13 on that pressure ratio?
In other words,,why did you 4
14 understand that this curve represented a number of 15 different pressure-temperature relationships rather 16 than simply a straight line showing a constant 17 pressure?
i 18 A
I don't recall asking myself or having i
19 obtained that knowledge as to why there was a 20 particular temperature, other than for a cooldown
(
21 we always deal in a temperature-pressure relationship.
22 But I felt that basically it just dealt in the I
23 pressure between the two.
5
(~T i
\\-
24 Q
What did you understand would happen if l
l 25 you allowed the pressure-temperature relationship
l l
1 zewe 79 2
to deteriorate to the wrong side of the line?
3 A'
During a cooldown, again.
4 Q
Yes.
5 A
These curves do not apply during heatup.
I 6
only during a cooldown, the curves.
7 Q
We are talking now about during a 8
cooldown.
9 A
It was my understanding that you could 10 have some information of the cladding bhing 11 repositioned by the pressure inside the fuel, the
(~%
12 extent of which was determined on how far you would 13 violate the curves or be on the wrong side of the 14 curves; and that that determination would be made 15 after the fact, so to speak.
16 Q-Is it fair to say that you understood 17 the further you went on the wrong sideof]the curve, 18 the greater the risk was of distortion and possible 19 damage to the fuel?
20 A
I believe my understanding was, the
(
21 further that you exceeded the limit, the more 22 probability you had for greater damage, yes.
I 23 Q
Did you receive training at B&W on I
b
\\-
24.
j ccmpliance with this curve?
I
.25 A
I recall B&W training in relationship to
i 1
i 1
Zewe 80
.O_s 2
what they are for and how to use them, yes.
3 Q
Do you remember being trained at B&W 4
that if you found yourself on the wrong side of this 5
curve, you should try to get back on the right side 6
of the curve as quickly as possible?
7 A
Yes.
8 Q
Did anybody ever tell you exactly how far 9
to the right of the curve you would have to go before l
t 10 there was a serious risk of damage to the fuel?
11 A
No, I don't recall any discussions or
('~%
12 any training, either by B&W down at Lynchburg or at 13 any other place, that really addressed what exactly T
14 would happen or how far you could go or exactly.how 15 much these curves were conservative.
And it was 16 always as I recall that if you did have to 17 violate them, that an evaluation thenwou}ldbemade 18 to see if there was any problem that was caused by 19 it.
I do know that there were occasions that we 20 would violate them knowingly.
At the training in 21 B&W, insomuch as if you would have an OTSG tube leak
(
22 and in order to mitigate the circumstances of the 23 primary to secondary leak we would purposely s
3 N-24 depressurice outside of curve 2 or curve 3 in order 25 to handle that particular casualty.
And we had to
~
4 l
-q Zewe 81 t
]
2 address that on several occasions.
3 Q
And how far to the right of the curve did 4
you go on_those. occasions?
~
5 A
Magnitude-wise I really don't recall 6
exactly how far it was, but it was in excess of the 7
limit.
8 Q
It is fair to say, I guess, isn't it, 9
Mr. Zewe, that unless there was a specific reason t
10 to be on the right side of the curve, you were 11 supposed to be on the l'e f t ; and if you got on the
/~
12 right-hand side, you were supposed to get back to the D) 13 left as quickly as you could?
14 A
Yes, I would say that.
15 Q
Now, these other two or next two curves 16 of 5 and 6,
can you tell us what they a r,e ?
17 A
Curve.5 is the minimum RC pressure for 18 single pump in a loop net positive suction head.
10 Curve 6 is minimum RC pressure for two pumps 20 in a loop at positive suction head.
(_
21 Q
What does " net positive suction head" 22 stand for or refer to?
23 A
Net positive suction head is the total
. f~).
I
~
24 pressure felt as the suction of a centrifugal pump I
25 which is based on static pressure conditions of the
t '
1 Zewe 82 8.J 1
2 fluid at the pump suction and also the pressure of 3
the fluid due to elevation at the suction to the 4
centrifugal pump.
And this was the needed suction 5
pressure in order for that pump.to operate within its 6
design capability.
7 Q
Which side of the line did you understand 8
you were supposed to stay on?
9 A
To the left of the line.
t 10 Q
And again, why did you understand that 11 this line was presented in the form of a curve f'T 12 reflecting various pressure-temperature relationships?
, O i
13 A
Well, the pressure of a fluid at the
-s 14 suction of the pump had a relationship between its 15 temperature and its pressure.
What you were 16 concerned about is possible cavitation or 17 flashing of the fluid in pump suction, a n'd that 18 had a definite temperature-pressure relationship.
19 Q
When you refer to " cavitation or 20 flashing," is that the same thing as referring to
(
21 the formation of steam?
i 22 A
Basically, but it's not that simple.
23 The cavitation really refers to reaching the s
()
24 saturation pressure of the fluid at the eye of the 25 impeller and forming in this case steam, since the d
i W
-y y'*
my rmieyt r
yw 7-w
==
9r w-y-r yr
'q--g y---lp-35p-ag,emw-
's-w-g+"ye+oen-my-w-W
+-
l
~
i.
I Zewe 83 i
2 water is fluid; and then once the steam bubbles in 3
the water go toward the volute of the pump, the 4
increased pressure there is the pressure increase 5
which collapses the steam bubbles and it is really 6
the collapsing of the steam' bubbles and the filling 7
of that vo'id by the water which actually does the 8
damage and concern to the pump itself.
9 Q
So that the' process that you described t
1 10 as cavitation ends with the collapse of the steam 11 bubble.
It starts with the formation of the l
12 bubble.
13 A
Right, the real damage and concern is 14 the collapsing end of it, not the formation of it.
15 But you wouldn't have'the collapsing if y,ou-didn't 2
16 have the forming, right.
17 Q
And the curves, curves 5 and
'6, do they 18 reflect pressure-temperature relationships at l
19 which there is a danger of the steam forming at the 20 eye of the impeller?
]
(
21 THE WITNESS:
Would you read that 22 back?
I'was glancing down and missed the 23 beginning of it.
24 (Question read.)
l 25 A
It was my understanding that these 4
i 1
Zewe 84 U
2 curves were conservative curves that I would reach 3
.before I would reduce the pressure in the suction 4
of the pumps sufficiently enough to cause flashing 5
in the eye of the impeller.
6 Q
Did you have a mental line in your mind
'7 in or about March 1979 to the right of these curves 8
at which saturation would actually occur at the eye 9
of the impeller?
t 10 MR. KLINGSBERG:
Now we a r e" t a l k i n g 11 about --
[]/
12 MR. FISKE:
5 and 6.
\\_
13 MR. KLINGSBERG:
-- flashing,?
14 MR. FISKE:
Yes.
15 MR. KLINGSBERG:
O.
K.
16 Q'
Do you understand the question, Mr. Zewe?
~
17 We can read it again if you like.
18 A
I believe I do, yes.
19 You asked if I had some mental line that 20 I would say if I would cross this line I would
(_,
21 definitely have flashing and saturation conditions 22 for that pump.
l 23 Q
- Yes, i
24 A
I don't have any carticular line limit l
25 j in my mind.
I was going to use the curves that we l
l.
1 Zewe 85
/
N _.)
2 had in our procedures and use them as my guide.
3 Q
Mr. Zewe, you said earlier that curves 2 4
and 3,
the fuel pin compression curves, did not 5
apply during heatup; is that correct?
6 A
That is my understanding, yes.
7 Q
Did the net positive suction head curves 8
apply during heatup?
9 A
Yes, they did, t
10 Q
And isn't it correct, Mr. Z'e w e, that 11 there were in effect on the day of the accident
( ')
12 a number of different operating and emergency x.y 13 procedures covering both heatup and stary-up of the 14 plant and alco covering shutdown and cooldown of 15 the plant which had the heatup/cooldown curves as 16 part of'those procedures?
ahfully 17 MR. KLINGSBERG:
That is an 18 long, complicated question.
19 MR. FISKE:
Yes.
l 20 MR. KLINGSBERG:
Could we have that read.
(
21 Q
I will make it a little simpler.
22 Isn't it correct that as of March 1979 i
23 this figure, the one we have just been looking at
'\\
I s
y
\\-
24 called "hea. tup /cooldown curve," was made a part of l
1 25 j
a number of different operating and emergency l
}
1 Zewe 86 i :f 3
\\_)>
i 2
procedures covering both the start-up and the 4
3 shutdown of the plant?
E 4
A Not only those areas of shutdown and 5
start-up.
I am aware, and as I recall, there are 6
other procedures which have that curve and graph 7
included in the body of or appendices of those 8
procedures that govern other than heatup other g'
than start-up and cooldown, yes.
Those exact I
E 10 j procedures, without reviewing them I really don't i
11 know, but there are others.
/~g 12 Q
Let me just run through a few specific
(
%)
13 procedures and see if you can tell us.
And if you f
14 w'ould like to see the procedure, we can show it to i
15 you, if you have any question.
16 Do you remember whether these --
17 A
If I may just add something?'
l 18 Q
Sure.
l 19 A
A lot of my knowledge now over the last l
20 three years has been in Unit 1.
And I haven't held 21 a license in Unit 2 in almost three years now.
So i -
22 an. awful lot of these procedures, I'm afraid that 23 I may confuse what is in the current Unit 1 l
4 l
's 24 procedures rather than what was in the Unit 2 25 procedures prior to March
'79.
l 1
1 5
,n,,,-....-
r,.
,,,,-.4
,,.,c.m,,
a n,
-ee
-... -, + -, - -, -,,,
1 1
]
1 zewe 87 Well, let's just stop for a second.
2 Q
3 Am I correct in understanding that 4
everything you have told us up to now is based on an 5
understanding you had of Unit 2 procedures before 1
6 the a'ccident?
l 7
A To the best of my ability, yes.
8 Q
Let me just ask you about a number of i
9 specific procedures, and if you tell me that you 10 would like to see the procedures to answer the 11 question, I would be happy to show it to you.
t
(~T 12 A
Very well.
i
(_)
13 Q
I am referring first to procedures 14 applicable to the start-up of'the unit.
I would i
15 like to ask you whether or not, the figure, that we 16 have been talking about was a part of the unit heatup i
l 17 procedure.
~
4 18 A
I feel certain in my mind, yes, it was.
i l
19 Q
O.
K.
Was it part of the unit start-up 20 procedure?
4
-21 MR. KLINGSBERG:
Is there some reason I
22 why we shouln't show it to him?
i 23 MR. FISKE:
No, not at all.
, - t 24 A.
I would not think it was necessary for
)
25 the unit start-up procedure.
Because the unit heatup
d Zewe 88 1
i procedure ends at 525 and 2155 and you are already 2
i heated up.
But it would not surprise me if in fact 3
it was there.
4 Q
And with respect to shutdown, was it 5
6 part of the unit shutdown procedure?
A I would have to make the same comment as 7
to start-up.
I would-not absolutely think it 8
g necessary to be in the shutdown procedure.
10 Q
O.
K.
Well, let me show you at this 11 point, Mr. Zewe, a copy of the unit start-up 1
.g"}
13 procedure and a copy of the unit shutdown procedure.
(_/
A Fine.
13 MR. FISKE:
We will mark them as the g,g next two exhibits, 737 for start-up,, and 738 15 f r shutdown.
16 l
17 (Copy of unit start-up procedure was 18 marked as B&W Exhibit 737 for identification, i
19 as of this date.)
(Copy of unit shutdown procedure was 20 marked as B&W Exhibit 738 for identification, 21 as of this date.)
22 23 Q
W uld y u like to look at those two I
- -/
! - 5 3;
j documents, Mr. Zewe, and see if that helps refresh l
l 25 y ur recollection?
l 1
.,, ~. _ _ _.. - -...
., _., _. - _. -. _,, _ _. -. ~,.. _., - -.,,..,. _, - -. _... -
a u..
m h
A4s --
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e-.
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---4 5---
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i 1
Zewe 89 O
i.
2-A-
Yes, I would.
Thank you.
s 3
Yes, I agree now that they are in the 4
unit start-up and the unit shutdown procedures.
-{'
5 Q
In the procedure for decay heat removal k.
6.
'via the once-through steam generator procedure?
i 7
A I would believe that it would be 8
contained in there, yes.
9-Q And again, this is your understanding at 4
t 10 the time of the accident?
11 A
I would say yes.
12 Q
When you said you would have expected it 13 to have been there, why.would you have'eypected it
- 14 to have been there?
i.
- 15 A
Generally, any procedure that dealt with 16 decay heat removal or a unit cooldown or heatup, l
.17 I would expect to have heatup andcooldow) curve
.18
'as part of the enclosure.
Those like start-up and 19 shutdown, where you are not really changing pressure l
20.
and. temperature, they are included but I don't feel I
(
21 they are really necessary.
22 Q
I think we just looked at the unit 23 cooldown procedure a moment ago.
Did you understand i
i-'N 24 that the curves were part of the decay heat rempval 4
i 25 procedure?
h I.
y-y-
y-m-e p
v.
4 er79 m.
7
,.,,y
- y. - -p py y7yfv-y,-
y 9,.gmywq
,.pf.,9%m.w_pyp-.-e._y
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l 1
Zewe 90 i /'g V
2 MR. KLINGSBERG:
It would be better if 3
we showed him the procedure and then he can l
4 tell us if he knows.
~
5 MR. FISKE:
Sure.
6 Q
I show you a copy of the decay heat 7
removal system procedure, which is marked Exhibit 8
539.
I g
A It does not in clu'd e the heatup and 10 cooldown curve that appears in the o the'r p ro ce dure s.
11 Q
Is-there an expanded heatup/cooldown 12 curve as part of the decay heat removal system O,s i
13 procedure?
14 A
Yes, there is.
1 15 A
Do you have a copy of the decay heat 16 removal through steam generator procedure in front
~~
17 of you?
18 MR. KLINGSBERG:
What exhibit is that?
19 MR. FISKE:
Exhibit 572.
20 A
I do not.
I have shutdown, start-up, i
21 unit cooldown and decay heat removal system.
(
22 Q
You now have decay heat removal through 23 steam generator procedure (handing document to the 7
O 24 witntis).
f i
A I'now have it.
25
. ~.. - - - - -
~.
= _ _. -
1 Zewe 91
~
f~)
,U 2
Q I take it, Mr. Zewe, that you did receive i
3 training on.the use of all of these procedures in 4
the course of the training that you received at Met 5
Ed?
6 A
I did receive training on all' of these 7
procedures both at Met Ed and at B&W in Lynchburg, 8
yes.
9 Q
Now, looking at the decay heat removal i
l 10 through steam generator procedure, page 3,
section 11 2.1.1 states that reactor coolant temperature, 12 pressure and cooldown rate shall be maintained 13 within the limits specified in figure 3.4.2 of 14 TS3.4.9.1, and then there is a reference to a 15 figure 1.5.2 attached.
Correct?
i 16 A-That is correct.
17 Q
And the figure that is attached is the 18 heatup/cooldown curve we have been discussing; 19 right?
20 A
Yes, it is.
21 Q
Now, I would like to direct your
(
33 attention to 2.1.7, which is on page 4.
This reads, f%
"During decay heat removal by natural circulation, 23 i
1
(-
24 maintain TE 30 degrees Fahrenheit below the i
i 25 saturation temperature corresponding to pressurizer-i 1.
i 1
Zewe
.,s.
92 1
J 2
pressure in order to prevent boiling in the hot legs."
3 Do you see that?
4 A
Yes, I do.
5 Q
What did you understand was the purpose 6
of that requirement?
7 A
To insure that you ha'd RCS pressure 8
control in the pressurizer.
e 9
Q Did you understand that there was any E
10 particular reason applicable to decay heat removal 11 by natural circulation, why it was important to
(
12 maintain TH 30 degrees Fahrenheit below saturation?
13 A
Again, for the same reason that I just 14 stated, that it was important to maintain RCS 15 pressure control by way of the pressurizer.
I 16 Q'
I think you said this morning, when we
~
17 were discussing some of the ways the system works, 18 that you understood it was always important to keep i
19 the temperature in the pressurizer above the t-l 20 temperature in the hot legs in order to maintain
{-
'21 pressure control in the pressurizer; right?
22 A
Correct.
23 Q
I guess my question is, did you have 24 f
any understanding as to whether there was any other s
I I
~
for maintaining CH 30 degrees below the 25 reason I
~
1 Zewe 93
< V(~h i
2 saturation temperature that was particularly t.
3 applicable to decay heat removal by natural 4
circulation?
5 A
Not anything other than maintaining the 6
pressurizer hotter and maintaining the pressure 7
control that you have afforded in the pressurizer 8
itself.
Only in that relationship.
9 Q
During the course of the time that you t
10 went through training on this particular procedure, 11 whether it was at Met Ed or B&W, or wherever, when s
12 this was being discussed, did you ever ask anyone i
13 why do we have this particular provision in this l
4 14 procedure, why do we-have it stated in the decay heat 4-.
15 removal by natural circulation procedure that we-16 have to' keep TH 30 degrees below saturation in order 17 to prevent boiling in the hot legs?
18 A
My recollection is that I do remember 30 I
19 or 35 degrees as being the number, but the reason 20 was to maintain the pressurizer that amount of degrees i
I 21 above the RCS so that you maintain pressure.
33 Q
So we can finish with this, is it correct I
l 23 l
that you had no understanding that there was any i ' /'g j
(._).
24 l
reason to keep Tyr 30 degrees below saturation 25 applicable to decay heat removal by natural
1 4
1 Zewe 94-4 2
circulation that wasn't also applicable to n'orma'l i
)
3 operations?
4 MR. KLINGSBERG:
Can.we have that 5
again?
There are several negatives in the 6
- question, t
i e
7 MR. FISKE:
Sure, fair enough.
8-(Question read.).
g MR. KLINGSBERG:
I object to the form
~
t 10 of.the. question.
4 1
. 11 The witness can answer, if he can.
f i On 12 I find it rather confusing.
13 MR. FISKE:
Well, I don't want to 14 confuse Mr. Klingsberg or.anyone else, so let 7_
15 me -- I am trying to make this as simple as 16 I'can.
If you-think it confusing, I would 17 rather start again.
~
18 Q
You have this provision that we hav. just i
l 19 been talking about in the decay heat removal through l
1.
20 the steam generator procedure.
It specifically
(
21 refers to decay heat removal by natural circulation 22 and says that it is important to maintain the TH 30 l
t 23 degrees below the saturation temperature to prevent i,
l O
I i
24 l
boiling in the hot legs; right?
l, i
m 25 A
Yes, that is what it reads, yes.
--,,x y,-n%,,,,
,,.,..,._,,_,.ew.w.,m...,,,
,.,v,.n....,
,m,,,,m,..,gm,,w,,.-y,y,.my_.
,,,y-,-,-
,,,--,s-,
c
e 1
Zewe 95
. I')
\\m/ -
2 Q
My question is very simple.
Did you 3
understand that there was any reason why it was 4-important to do that during decay heat removal by 5
natural. circulation that wasn't also applicable 6
during normal operations?
7 A
Either in normal operations or in decay 8
heat removal by natural circulation, it was still 9
important and desirable to maintain pressure control J.
10 in the pressurizer itself.
~
11 Q
ThaE reason --
j 12 MR. KLINGSBERG:
Did you finish your 13 answer?-
- 14 THE WITNESS:
Yes.
15 Q
That reason applies to both, normal 16 operations and decay heat removal by natural t
j.
17 circulation; right?
18 A
Right, and the plant was designed for 19 both.
It was designed for natural circulation.
20 Q
Did you understand that there was any
{
21 reason to do this during decay heat removal by t'
22 natural circulation in addition to the reason that 23 was applicable to both conditions?
24_
MR. KLINGSBERG:
What is "this"?
l i
1 25 MR. FISKE:
Maintaining TH 30 degrees
's
~
1 Zewe 96 MV 2
below saturation.
3 A
No, as long as you could keep the i
4 pressure control in the pressurizer, it didn't make 5
any difference.
And in here, all right, natural 6
circulation implies that you have a loss of power.
7 All right?
Loss of power to your pressurizer 8
heaters.
All right?
Which was the main way to 9
maintain pressure control in the pressurizer.
But t
10-you were still looking at the same face, trying to 11 maintain the pressure control in the pressurizer in 4
/~N 12 either case.
NY 13 Q
Did you understand that it would be 14 more' difficult to achieve natural circulation if i
15 there was boiling in the hot legs?
16 A-I don't recall receiving any training 17 at Met Ed or B&W relating tonaturalcirc}ulation 18 being a problem because of boiling in the hot legs.
1 10 I don't recall any of that training and I don't i
20 recall thinking about if I had boiling would that 21 disrupt natural circulation and to what degree; I 22 don't recall having that knowledge before the i
1 23 accident.
O I
t 1
s-24 l
Q So you had before the accident no i
I 25 concern, then, that the formation of steam in the l
1 Zewe V,--
97 2
hot legs might make it more difficult to achieve natural circulation?
3 4
A My recollection is that the only time 5
that I would have boiling in the hot legs is only if 6
I would -- like during a LOCA where I would drain the 7
pressurizer and completely lose level in pressure 8
control, an d I would then be on a high pressure 9
injection mode of cooling, all right, feeding through t
10 the core and out the break and cooling it that way, 11 and I would not rely on natural circulation cooling al2 if I had boiling in the hot legs, and that is the 13 only time that I could relate to having boiling in 14 the hot legs is to have a LOCA and losing pressurizer 15 level and then having the hot leg boil.
So in 16 this case trying to establish natural circulation 17 and have boiling in the hot legs, I never really
~
18 considered that, as I recall.
19 Q
O.
K.
20 A
And also, as with -- any transient
(
21 response training that I received never showed where 22 I could have boiling and I would be concerned with 23 looking for natural circulation, either.
It was 24 always either I had normal natural circulation or i
25 in that case of boiling I have already had a loss of
1 Zewe O
98
.\\
2 coolant and I was relying on the high pressure 3
injection.
4 Q
How did you understand that you were 5
supposed to determine whether TH was 30 degrees 6
Fahrenheit below the saturation temperature 7
corresponding to pressurizer pressure?
8 MR. KLINGSBERG:
This is getting back i
9 to 2.1.7?
10 MR. FISKE:
Yes.
11 A
By comparing the saturation pressures a
12 and temperatures in the pressurizer and in the RCS.
i 13 Q
And how would you.know what the 4
14 saturation temperature and pressure was?
15-A By consulting steam tables I could j
16 compare'what the saturation pressure would be ' for kn 17 an existing temperature and vice versa.
actual 18 training or practice, I do not recall actually 19 doing that in any of my transient response.
I 20 don't remember pulling out the tables and verifying
(
21 the two.
Like I stated before, normally we either j
22 had it and didn't worry about it, that we already 5
23 had natural circulation, or we had the leak where t
l
\\m-24 we were on high pressure injection.
I 25 Q'
But you were aware by the time of the
.L..
_..... _,,. -. _ _ _, ~. _
t 4
4 1
Zewe 99 I,
v 2
accident that you could determine whether you were i
3 at a saturation temperature by looking at the 4
steam tables?
5 A
I did have working knowledge of the steam 6
tables and checking various pressures versus 7
temperatures, yes.
8 Q
Were you aware of the temperature in l
9 the steam generator during normal operations?
E 10 THE. WITNESS:
Would you repeat that, 11 please?
12 (Question read.)
13 A
Yes, I was, t
a.
14 Q
And the pressure'in the steam generator i
15 during normal operations?
16 A
Yes, I was.
17 Q
That is asaturationpressurektemperature 18 relationship, is it not?
19 A
The temperatures and pressures which 20 are indicated in the control room at normal operation
(
21 is really not saturation conditions.
It is actually 22 superheat conditions, which is the desired output 23 of the once-through steam generator.
So it is 24 actu, ally superheat which goes beyond saturation j
conditions.
25 t
w-
.,.--m wwu--~
<--4,w._--w--www._
,.r-
-y,.%w w.-.y
-.-,,-mvy--y
-w y p,n,,-~----e.yw-
.-,.~,,
4 1
Zewe 100 2
Q And what were those temperatures and 3
pressures?
4 A
Steam generator pressure normally runs I
5 around 925 pounds, and the. steam temperature 6
varies but it runs in the neighborhood of 585 degrees, 1
l 7
590 degrees.
8 Q
And you said that is superheat; right?
i 9
A Yes, it is.
]
i 10 Q
Not just ordinary saturation?
i 11 A
No, that is superb
.a t.
The B&W design 12 is-to provide and insure that-we have gt least a 13 minimum amount of superheat out of the steam 14 generator.
15 Q
And for there to be simply sa.turation 16 as opposed to superheat with temperature at 585, 17 did you understand that pressure would ha"ve to be 18 higher than 925 or lower than 9257 19 A
To be at saturation?
i 20 Q
Yes.
{
21 A
Temperature would have to be lower.
i 22 Q
Pardon me?
I didn't hear the answer, i
23 MR. KLINGSBERG:
Let's have the question.
24 MR. FISKE:
I think we might have i
25 crossed wires on that.
.- ~,,
~ ~
M 1
Zewe 101 a
V (Record read.)
2 3
MR. KLINGSBERG:
There is a mixup 4
because the question was about pressure and 5
he answered about temperature.
6 THE WITNESS:
Yes.
7 A
So you are asking that in superheat 8
conditions, l's the temperature higher than for 9
saturation conditions?
1
{
a=
10 Q
That is another way to put it.
J
,r' 11 e
A*.
And I am saying yes, just to clarify.
5
?
r 12 Q
O.
K.
And the other side of that
'13 equation is that pressure would have to he lower for r
14 superheat for the same temperature than it would,
- (.,,.
15 be for saturation?
'/
f j
i 16 A-Exactly right.,
17 Q
Now could you look again at t'he unit l
18 cooldown?
jo 19
~
'MR.
KLINGSBERG:
What exhibit is that?
l i
j 20
~; ". ' Md., FIS KE :
Withdrawn.
Before we do a s e' s
s 21 t" hat --
{
i n
2 L a; Q
Were you aware on the day of the
! ?.
23 accident,what pr'ossure would produce saturation as l'/7 l
1 zM 24 j_
opposed to superheat at a temperature of 585 degrees?
i
- i 25 fAi I don't want to end up like the last i
a 7
/
),_
s..
..c-.-.c,
, y-
'Y ll 1
Zewe e.1 0 2 2.
thing, answering in the wrong terms.';
N 3
THE WITNESS:
Would you mind repeating 4-
-- 4 that, please.
l y
3 MR. FISKE:
Just read it back I
6 !
(Question reed.)
l MR. KLINGSBERG; Are we still talking 7
i 8
abot:t the steam generator?
}
g l
o MR. FISKE:
Yes.
.)
10.
A I would Save to refer to tNe steam tables f
s 11 i for the answer tc that.
4 h
Q After a reactor trip, is there ordinarily 12 j
s,
j 13 c change in the steam generator temperature?
14 A
Yes.
It goes down.
15 Q
Does it go down to somewhere,in the
.s 16 vicinity'of 5507 i
~
17 A
Yes.
~
- )
t 2
18 Q
What is the saturation prensdre for that 19 temperature during post-trip conditions in the 20 steam generator?
s I
21 A
Approximately 1,010 pounds.
22 Q
Going back to the unit cooldown
.v 23 procedure, which I believe you have in front.of 1
\\
s_)
24 you --
i s.
25 MR. KLINGSBERG:
Which exhibit is that?
i,
I s
st e
s 1
)~
<4' I.
_~,
- -~
1 Zewe
. r0 103 V
2 THE WITNESS:
540.
3 MR. KLINGSBERC:
5407 l
4 THE WITNESS:
Yes.
f".
l Q
A 5
there is.a reference on page 14 at i '.
6 the bettom of the page to a spray adjustnent.
l 7
Do you see that?. After the word " note."
'l o
A Under 4.31. that note at the bottom?
p Q
Yes.
a 9
F.
10 A
O.
K.
^
i i
(
. )
11 l Q
The note says that "This spray adjustment,"
I 12 I
that is, the one referred to in 4.31, "is to prevent
- e i
sw j
13 pressurizer cut-surge in the RC hot l e g. ",
A Q.
I'
'14 Do you see that?
15 A
Yes, I do.
16 Q
What did you understand -- again, based 17 on your training before the accident w s the 18 reason to prevent pressurizer out-surge under the 19 hC hot leg?
20 A
I don't remember what my recollection 21 was there about this step exadsly now.
{
I am trying 22 very hard to remember what I thought then, but I 93 don't know, I can't recall.
O-24 Q
Have you got the decay heat removal l
s-l in front of you over 25 system operating procedure 4
l
.I Zewe.
104 4
%)
2 there?
3 A.
Yes.
4 MR. WURTZ:
B&W 539.
7 5
Q Directing your attention to page 5,
Mr.
'6 7 ewe, _the top of the page, paragraph 4, it says, 7 ".i.
" Insure that RCS pressure-is maintained above that t
i 8 [
chewn on figure ? to prevent the formation of a steau k
l P g b2bble at the highe st poir.t of the 36-inch reactor
+
10 l coolant riping."
11 Do you see that?
e s
- [~
12 A
Yes. 1 Co.
.. w,.
13 Q
And then directing'your a t. f.e n tio n to 14 figure 2,
is the re a curve on that figure which 15 is captioned " Minimum Pressure to Prevent' Boiling 16 in Top of the 36-inch RC Pipe"?
t 17 A
Yes, there is a curve labeled.such.
18 Q
o.
K.
Why did you understand that it 19 was important to preven t the formation of a steam 20 bubble at the highest point in the 36-inch reactor
(
21
-coolant piping in carrying out this procedure?
1 i
22 A
I don't have a recollection of that curve.
23 Q
Let me show you one more document, Mr.
b[
\\l 24 Zewe.
l 25 A
o..K.
l'
e 1
Zewe
, r s.
105
(
I
~J 2
Q The pressurizer operationi which I don't 9
3 believe has been marked before.
4 MR. FISKE:
We will mark this as B&W 739.
5 (Pressurizer operation prccedure was 6
rearked as B&W Exhibit 739 for identification, 7
as of this date.)
8 I
Q You have in front of you, Mr. Zewe, I
t l
9 l pressurizer operaticn procedore?
i h
t i
10. d Ye e. ?
i 1? l A
Yes, I do.
l
)
f-^g 12 Q
Directing your attention to,the back,
\\
t mai 13 figure 4,
page 27 --
14 A
I believe my figure 4 is on -- it-is 15 between page 25 and 26,' figure 4.
The numbers 16 aren't that clear.
17 Q
Look at page 27.
I 18 A
Mine may.not be in order.
19 MR. WURTZ:
I think there is a 27 along 1
20 it on the horizontal 21 THE WITNESS:
Oh, I'm sorry.
I see that.
22 MR. WURTZ:
Microfilm No.
1592.
1 23 THE WITNESS:
Mine appears to be 25 to
( -)
24 27 and then to 26.
They are just out of order.
I s_
I 25 Q
You have now found page 27.
t t
1 Zewe-106 2
A Yes.
I 3
Q D
yu see the fuel pin compression
'4 curves and the net positive suction head curves on 5-that page?
6
'A Yes-7 Q
Did you understand thst in f o l.'. o w i n g f
8 the pressurizar operati on precedure, it was 9
important to comply with those curves?
E 10 A
Yes.
11 :
Q
- would like to direct your attention to fg 12 paragraph 4.3.8.6, which is on page 2 2.,
And I direct k_
l 13 your attention to-the second paragraph, and 14 particularly the note that says, "Also insure that 15 approximately 45 psig is indicated on the, hot leg 16 indicator to prevent boiling at the top of both loop 17 hot legs."
~
18 Do you see that?
19 A
Yes, I do.
20 Q
Why did you underutand that it was 21 important to prevent boiling at the top of both loop 22 hot legs in carrying out this procedure?
23, l
A My recollection is of the 45 pounds, s_).
24 but I don't recall the reason behind the rest of the l
25 statement or why particularly that was bad at this
1 Zewe 107 (v
~
1 2
particular point.
Just that we would follow the 3
procedure for 45 pounds or 293 degrees in the 4
pressurizer, again, to maintain pressure control 5
within the pressurizer.
I dcn't believe that I 6
thought what if I did not maintain this.
I don't 7
recall that anyway.
8 (Recess taken.)
1 g
BY MR. FISKE:
10 Q
Mr. Zcwe, during the period'of time-i 11 before the accident, you had been employed at Met
("
12
.Ed as auxiliary operator and then as a shift foreman N]
)
13 and then finally as a shift supervisor; r,ight?
14 A
Yes.
J 15 Q
And that spanned both Units 1,and 2;
)
16 right?
17 A
Auxiliary operator, all of ths working 18 knowledge-was actually for Unit 1.
But as shift 19 foreman, both units.
And as shift supervisor, 20 both units.
21 Q
You letter to Mr. Collins states, in
{
22 paragraph 4 on page 2,
that your experience as shift 23 supervisor included the writing'and reviewing of p.
L 24 ope rating procedures.
I 25 Do you see that?
1 Zewe 108
-s x.._/
2 A
Yes, I do.
3 Q
And it is correct, is it not, that you 4
did participate in the preparation of operating 5
procedures for Unit 1 and Unit 27 6
A It is true that I was involved in the 7
upgrading and rewriting of procedures that were 8
in place and of 3 raft procedures which were provided 9
by B&W.
Really in that sense, of reviewing it, s.
10 making changes and having the changes approved for I
11 our plant operation and use.
w 12 Q
The final decision on each. procedure was v.
13 made by the PORC, was it not?
14 A
Actually made by the unit superintendent.
15 He gets a recommendation from PORC, but he actually 16 has the' responsibility of approving it or not.
khese 17 Q
Well, just looking at one of 18 procedures that we have had before us, there is a 19 form on the cove r o f the procedure, is there not, t
20 ;
with a number of blanks indicating approval by various 21 Pe0Ple?
{
22 A
That is correct.
I l
I 23 l
Q One of those blanks is the recommendation r m.
i 1
I
\\_ ?
24 d of the PORC that the procedure be approved; correct?
E i
l 25 l
A That is true.
They recommend approval.
i
1 Zewe 109 2
But the actual approval-before it is used is then i
made by the unit superintendent.
3 Q
And when the' procedure becomes final, it 4
5 carries with it both the signature of the chairman E
6 of the PORC signifying.the recommendation of approval 7
and also the-signature of the Unit 2 superintendent 4
8 signifying approval; right?
9 A
That is correct.
t 10 Q
certain procedures are designated 11 operating procedures and there are other procedures i
12 that are designated emergency procedures; is that s_
13 correct?
For Unit 2.
14 A
Yes, that is correct.
15 There are others besides those two, but 16 those are two of the procedures in use, yes.
i j
17 Q
And did you have any role in}the 18 preparation of emergency procedures as well as in i
19 the preparation of operating procedures?
20 A
I had a role insomuch as recommending 21 changes, reviewing, and alike, as far as the 22 emergency procedures went.
I periodically reviewed 23 them, recommended changes, trained on them.
/~T l
k 24 l
Q Isn't it a fact, Mr. Zewe, that before m
25 any operating procedure or any emergency procedure 1
l
_,._.._ __ _ _... _ _. _ _. _ _ - _ _ _. _ -.. ~ _. _ _ _. _ _., _
1 Zewe 110
- v 2.
'became final, the shift supervisors as well as others 3-were provided with the draft procedures and given 4
an opportunity to make whatever comments they wanted C.
5 to make cn whatever improvements they felt should 6
be made in the procedure?
7 A
Generally, that was the case, yes.
8 Q-And it is correct, isn'P. it, Mr. Zewe, 9
that you understood before the accident that these t
10 procedures were for the guidance 'of the " ope rators in 11 running the plant?
12 A
Yes, they were.
13 Q
Before the accident, did you,believe that 14 it was important that you and the operators that 15 were working with you understood the procedures?
16 A
Yes.
17 Q
Did you understand that it was important 18 that these procedures not be confusing or difficult 10 to apply?
20 A
It was my belief that the case to f
understand and the ease of applying the procedure
(
21 22 was a goal of the procedures, yes.
i 23 Q
And did you understand that in the course
/%
j l
24 of reviewing these operating and emergency procedures l
a 25 before they became final, that you were supposed to
r l~
Zewe 111
- (d.
2 report to someone if you felt that any of these 3
procedures were confusing or difficult to apply?
4 A
At any time when I reviewed a procedure 5
for whatever reason, if I felt there was a need for 6
a change, I would not' hesitate to initiate that 7
ch ar.g e.
8 Q
Did you also understand that you had the 1
9 same obligation at any time if you. felt that any e
10 procedure was wrong?
11 A
I believe my answer is the same, yes.
If r'
12 I felt that it was wrong, that I would, initiate any N_N
]
13 changes that I felt were necessary and'it would go 14 through the app roval chain to change the procedure 15 itself.
16 Q
And did you feel the same way if you felt 17 that any procedure that you had reviewedkas 18 inadequate in any way?
19 A
I think that question is parallel with the 20 other ones, and my answer is yes.
(
21 Q
Now, will you tell us on the day of the
~
22 accident how many different emergency procedures there 1
23 I
were that were in effect?
i
'/
24 A
Could you clarify that more?
Do you mean t
25 how many we had access to?
How many we should have i
I O
....e.-
m
,y-..-
~,
.,.,.-r
-.,,e.-~.-,*3-
-,---,-,----,r<.---
= - -
^
1 gew8 b;
112 R/
2 been using?
Or which ones were actually used?
or --
3 Q.
No.
4 A
I am not sure what you are asking.
5 Q
On Marchi27, 1979 l
6 A
' March 27th?
I 7
Q
-- how many emergency procedures were 8
there in effect at Three Mile Island, Unit 2?
9 A
Numbers, I am not sure.
I would have to i
L 10 i go through them and count one, two, three.
I don't i
11 know sh'eer number-wise how many emergency procedures t'
- . p-12 we had.
i i
v 13.
-Q Was it less that 15?
i 14 MR. KLINGSBERG:
Do you include 15 abnormal procedures?
4 16 MR. FISKE:
No, I am just talking i
j.
17 about emergency procedures.
The ones that 18 were labeled " emergency procedures."
t' 19 A
I would really have to sit down and just 20 add them up.
So I really don't know.
I would say 21 20, 25.
I don't know exactly what the number is right 22 now offhand.
3 23 Q
And it's correct, is it not, Mr. Zewe, A
i (s_ )
24 that in format the emergency procedures were divided 25 into two general sections?
one section that
.. _ -,. - _. _ _ _ -, -..,... -. _ _ _ _ _. _, _. _,.., _. ~ _. -, - -... - - _ _ - - -.. ~. _ -.
~
1 Zewe 113 (N-2 described symptoms of' a particular problem, and 3
then a second section that described the actions 4
4 that should be taken to deal with that problem?
5 A
Well, it was actually broken up into more 6
categories than just two.
One is one that gave i
7 symptoms of it; then it gave immediate automatic 1
4 8
actions, then manual actions, then follow-up actions.
9 Q
And the manual actions and folicw-up t
10 actions were things that the operator was supposed to li
- do to solve the particular problem covered by that 12 procedure; co.rrect?
4 t \\
13 A
He was supposed to use the manual actions i
14 and the follow-up actions as a guide and an aid in 15 combatting the particular upset that he had, yes.
16 Q
And the symptoms section of the procedure i
17 were a guide to the operator in determini g what 4
18 type of particular upset he had; correct?
19 A
He would use those symptoms in their 20 relationship to the plant parameters and his knowledge
(
21 in order to determine which of the procedures he was 1
22 into.
Because many of the symptoms were overlapping 23 l
and would be in various procedures, and there may
(
1 s.
24 also be a reason why he had a particular symptom for 25 what was happening, or what he has done.
i
~ - _.
l 1
. p ZeWe 114
\\,j) i 2
So it really was a tool that the operator 3
used in making the overall evaluation in how to 4
combat the particular upset or condition he had.
5 Q
But going back to where we started, isn't i
l It fair to say, as an overall general de s crip tion 6
g i.
I 7
of the procedures, that there was a symp tor:.Section i
8 used by the operators to help determine what the 9
problem was, and then there was an action section of-i 6
10 the procedure that helped the operator decide what 4
i i
11 to do to solve _ that problem once he had figured out 12 what the problem was?
g C/
I 13 A
They were used as part of the overall r
14 evaluation and action taken, yes.
They were a part 15 of that.
I 1G Q
Did you ever state to anyone, at any 17 time before the accident, that you felt that the 18 procedures were not set up well enough so that you 4
10
,might have a problem in deciding during a transient 1
j 20 which particular procedure to use?
i i
21 A
As I recall, I probably did, though I l
do not remember the circumstances or the individual 22 l
23 conversations.
But in effect, I was trying to I (~)
\\_/
24 relate, you know, that, yes, there is always a need I
i 25 fo r improving _ the p rocedu're s.
This one could be
1 Zewe 115 f
w.-
2 changed, be a little better for a particular event 3
that I was thinking about or that actually happened.
4 So there is always that need for 5
improvement.
And we had r. process there at the 6
I s l ar.d that we were continually reviewing and I
revising procedures.
I think more in that light, 7
8 that, yes, there is always a need for better 9
procedures.
e 10 f'
Q well, did you ever express to aayc ne if l before the accident that this whole structure of the j
l 12 procedures was wrcng bccause, during the course of a
(~y
)
i 13 t r an s i e r. t. operators might have difficulty trying 14 to figure out which procedure they should be into?
15 A
I don't recall making that statement, no,.
16 to anyone that I can recall.
17 Q
Now, with respect to specific procedures, 18 can you tell us now, Mr. Zewe, of any statement that 19 you made to anyone before the accident concerning any 20 emergency procedure which you said could be improved
{
21 that had not been improved pursuant to your 22 recommendation by the day of the accident?
23 Do you want to hear that question back?
j rx i
e l'
I i
\\
24 i
A I think I understand what you are asking.
f i
l 25 I am just while you were asking, I was thinking
r 1
ZeWe 116
)
2 also.
3 MR. KLINGSBERG:
Why don't we have the y
4 question back.
5 MR. FISKE:
Nothing wrong with that.
6 l (Question read.)
7 i
A I don't have any Iscollcction of that, 1; o.
I 8
Q Did you discuss the energency precedures 9
with the operatorc thst were working with you on l
10 l your shiftr?
11 !
A Yes.
Most of the t r ain ir. g that'we did o c.
12 a shiftly basis, we usad to make commenta and bricg 7x I.
l 13 oursnives up to date on currcrt changes in the LF't 14 and ask each other the EP's on shift.
We used to do 15 that quite regularly.
16 Q
For some period of time before the 17 accident, you had been working with Mr.
S'heimann, c
18 Mr. Frederick and Mr. Faust?
19 A
Q'ul t e sometime?
I i
20 I
Q For some period of time, you had been i
21 working with those three men on a regular basis?
I 22 A
Yes.
23 Q
Can you tell us approximately how long
, - )i
< ~
i 24 (
before the accident that had gone on?
n I
25 i A
I would have to refer to the records on I
1 Zewe 117 8
a s.
2 that, because I don't really know.
I've had several shift foremen in Unit 2 over a three-year period, 3
4 and I don't remember exactly when operators went k
between shifts.
i 5
6 Q
Was it at least for several months that I
7 you had been working with Scheimann and Faust --
g g
A I would say greater than four months or t
i g
so.
(
l Il I
i i
10 j; Q
and as of the morning of the accident, i
ll i
11 [
vere you aware of any respect in which any one of I
4 12 the three of them considered any of the emargency I'
l "13 procedures to be inadequato in any way?
i 14 A
Not that I recall, no.
4 15 Q
Mr. Frederick told us last week when he 16 was here that it was.part of his training that he I
17 was supposed to memorize the symptoms. portions of 18 the emergency procedures so that when a particular 19 transient occurred, he would have all of those i-20 various symptoms in mind without actually having to i
21 9
pull out the procedures.
I 22 I just wanted to ask you if that is i
)
23 in accordance with your understanding of the way l
4
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- \\_/
24 things worked before the accident, j
I I
25 A
We were required to know the symptoms 4
f 4
I
1 Zewe 118 I)
\\%.,,'t
-2 for the emergency procedures pretty much from memory,.
s.
3 along with the-immediate manual action.
4 Q
And I take it, then, as a sort of a rule
~
5 of thumb, that you made the decision during the course 6
i of a transient as to which particular procedure to l
t 7
pull out and starv lookinc at, based on the symptoa.s il 8 I that you saw?
j
[
9 A
Are you asking that me as a shift 1
l 1
e' l
10,
supervisor or me as an operator or --
I I
I t-l i
l 11 Q
I am sorry.
That was a fair questica.
{
i i
}--
12 Just as part of your training and Aet'a f
e I
n 13 not get yet to what actually happened on ene day cf l
t
.i i
14 the accident.
Just as part of your training, did you 1
15 understand that the way it was supposed to work 16 during a transient was that you would look for J
~
17 symptoms, apply those symptoms that you saw against 18 this bank of symptoms that you had memorized, and 19 based on that decide which particular procedure you l
20l would then pull out?
21 A
We would use a combination of things in
{
22 I making our overall evaluation of what procedures to i
23 use.
Those included from our memory the symptoms of l
" ' ~
-(
24 l
the EP's plus we also had overhead alarms, computer s_,
25 alarms, and most important, our parameters displayed a
c
, -. -. ~ -. -.. -,, - - - - -
1 Zewe
- C)'T 119 2'
-on control room panels.
So based on those and our 3
training and experience, we could then make the 4
4 determination and evaluation to-follow a particular
. \\'
5 procedure to handle the upset.
f..
G Q
Was one function of the symptoms that
.,a 7 i were 11?ced in the emergency proc::dures to tell you
+
i.
8 which particular alarms that you should be looking I,
e 9
for?
13 J A
There were various energency procedures ll i
4 j{
that actually listed alarn setpoints right in their 11 12 symot r,m s.
f Adninistrative procedute 100', which 13 p
14 has.been marked B&W Exhibit 237, states in sectica
'f I
15 3.2.3,
" Deviations from written procedure,s may not 16 be made'except in emergencies."
fou 17 Do you.have that in front of 18 (handing document to the witness)?
19 A
I do recall that, yes.
20 Q
Was it part of the training that was
{
'21 given to the operators at-Met Ed that they should 22 act-in accordance with that particular administrative 23 24 J
_Ccontinued on following paga) 25 l
1 zewe 11g_A
.s 2
procedure?
3 A
Yes.
4 (Time noted:
4:00 p.m.)
5 6
~i 4
I William H.
Zeve 8
j D i Subr.cribed at.d 1 wa rn to before m9 this d-v of 1982.
10 j
=
i 11 l
s 12 j
13 l 1
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14 I
~ i 15 16 17 l
18 t
f 19 20 21 i
22 !
23 j
I 21 !!
l 0
I 25
I 120 2
_C _E _R _T _I _F _I _C _A _T _E 3
STATE OF NEW YORK
)
- ss.:
4
~
COUNTY OF NEW YORK )
( I,..
5 6
I, NAnvzy e. Knanna a
7 Rotary Public within and for the State of New York,
~
l' 8
do hereby. certify that the foregoing depor.ition F
9 of WILLIAM _H.
ZEWS
\\[cs talen befcra 10 me on Thursday, May 20, 70,12 II lll That-the said witness was duly sworn a
b
~
12 hiS before the cornsn:ement of
_ testimony and I3
(
that the within transcript is a true recird of said 14 '
t testimony; 15 That I am not connected by b'lood or 16 marriage with.any of the parties herein nor 17 interested directly or indirectly in the ' matter in 18 controversy, nor am I in the employ of any of the 19 counsel.
20 IN *dITNESS WHEREOF, I have hereunto set my hand this )OYf7 day of 21
/
dV
., 1982.
/
22 Db j
dffC
,4 Harvey B.
Kramer, CSR, RPR 25 i
121 e
l i
i I NDE X s
WITNESS PAGE l
j William H.
Zewe 4
.i 1
1 1
E XH I B I TS l.
D&W FOR i
IDENTIFICATION 735 Letter frcm Mr. Zcwe tog 1
Mr. Collins, dated July 5, 1977 35 r
736 Document bearing at the top the name William Zewe i
,9, 4
and underneath that, " Major l
Training Prcgrams" 50 1
i l:
737 Copy of unit start-up i
procedure 88 e.
738 Copy of unit shutdown procedure
~
88 i,
739 Pressurizer operation i-i i
procedure 105 i
t' O
x
.L.
_a s d;
~ :. -
>a l
- - - - - -