ML20072H825
| ML20072H825 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 12/03/1981 |
| From: | Fels W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-06, TASK-6, TASK-GB NUDOCS 8306290762 | |
| Download: ML20072H825 (56) | |
Text
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
_x GENERAL PUBLIC UTILITIES CORPORATION, r
JERSEY CENTRAL POWER & LIGHT COMPANY, 3
METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
t Defendants.
___----_-____-_-x Deposition of Gene'ral Public Utilities Corporation, by WILLIAM FELS, taken by Defendants, pursuant to Letter Agreement and Rule 30 (b) (6), at the Marriott Hotel, Harrisburg, Pennsylvania, on Thursday, December 3, 1981, at 11:10 o' clock in the forenoon, before Nancy A.
Rudolph, a Shorthand Reporter.
h9 O
PDR n
DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS l
369 LExlNGTON AVENUE WALTER SHAP!RO. C.S.R.
N Ew Yo n x, N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELEPHONE 212 - 867-8220
I i
1 2
I 2
Appeara nca s:
l j
3 I f
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
i 4
Attorneys for Plaintiffs 425 Park Avsnue 5
6 By:
JOEL KATCOFF, ESQ.,
7 of Counsel i
i Ill 9
I 4
Il t
10 ;;
DAVIS POLK & WARDWELL, ESQS.
ll Attorneys for Defendants 11 [
One Chase Manhattan Plaza New York, New York By:
WILLIAM E.
WURTZ, ESQ.
I 13 h
-and-l-
JONATHAN QUINN, ESQ.,
i 14 !
l of Counsel 15 1-i 16 1
17 Also Present:
18 ROBERT LUTZ 19 1
20 I
t 21 l C-I i
22 i t
I l
23 li i
l' 24-25 i
~I t
..,_4
I 1
3 IT IS HERESY STIPULATED AND AGREED 2 l 3
by and between the attorneys for the i
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 the transcript may be 8
signed before any Notary Public with the 4
same force and effect as if signed before 9 :
l 10 3 the Court.
I 11 IT IS FURTHER STIPULATED AND AGREED 12 {L that all objections, except as to the form i
13 of the question, shall be reserved to the 14 time of trial.
I i
i 4
15 i
16 i
17 18 19 20 i
/
21
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4 l
1 il!i, 23 l
e ll 25
i 1
4 0
1v 2 l W I LL I AM F E L S, residing at R.D.
- 2 i
3 Rhoda Avenue, Mt. Joy, Pennsylvania 17552, having been first duly sworn by the Court Reporter 4
5 (Nancy A.
Rudolph), was examined and testified 6
as follows:
7 (Resume of William Fels marked B&W Exhibit 8
No. 329 for identification, as of this date.)
9 i MR. KATCOFF:
Once again, this deposition i
10 [
is taken pursuant to Rule 30 (b) (6) and is governed i
11 by stipulation as follows:
I 12 ;
"These depositions will not involve
.(
4 13 questions on the substantive iss.ues, such as 14
}
training, Davis-Besse, prior transients or l
15 ]
operator action during the accident."
16 EXAMINATION BY MR. WURTZ:
17 Q
Mr. Fels, we have marked as Exhibit 329 18 f a resume that you have just provided to us.
i
' 19 !
Did you prepare this resume?
20 A
Yes, I did.
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21 Q
Does this resume accurately set forth your 22 l educational and employment background as of today?
h 23 ll A
Yes, it does.
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24 Q
Could you describe what responsibilities 25 you have had from 1978 to the present for the TMI l
i e
I 1
Fels 5
J Unit 2 plant computer system?
2 :
l 3 !
A Basically, my respor.sibilities were to i
4 follow the installation, field input checking and proper i
(
5 operation of the operator interface for the Unit 2 6
computer system.
7 Q
Could you describe what you mean by the 8
field input checking?
9 i A
The transducer in the field that measures 10 '
the processes connected to cables in the computer.
11 !
The computer then digitizes the analog voltage.
The I
C~-
12 voltage is equivalent to mass flow, pounds, temperature, 13 whatever, and presents that as a usabl value to the 14 operators.
15 That checking would entail putting a voltage 16 in at the field and verifying that the proper number 17 comes out at the computer.
18 Q
The third thing you mentioned was the 19 operator interface.
Would you explain what you mean 20 by that?
21 A
The operator's interface is essentially
(.
22 the last part of the field input checking whereas you i
l 23 l
have the correct span, the correct engineering units,
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24 if that point belongs in an enunciator group, it is 25 there and the further checking of the operator interface
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I 1
Fels 6
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N-2 would entail verifying that the operator can do a l
3 ;
group print, a print point, all of the operator l
I 4
functions, that they work properly.
(
5 Q
Did you have any responsibility in the area 6
of deciding what inputs would be assigned to your 7
groups or-summaries.for the operator!s.use?
f 8
A What groups are you referring to?
9 Q
Well, if you had involvement in any groups, i
I S
10 could you just identify those and descr.ibe your I
11 j involvement?
12 !
A As far as deciding on points going in s
I f
13 groups, it would only be from the standpoint if points i
were identified that were not in an original group that 14 l i
15 I wcre being added from the same process or same area 16 of the plant, then they would be added to the appropriate 17 group.
l 18 For example, feedwater group, if the A/E, l
I l
19 l
the plant or the vendor added another point from the 1
20 !l feedwater system, then it would be prudent to put it 21 :
in the feedwater group.
{
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22 i Q
What groups exist?
Feedwater group is one, l'
l' 23 j,l I gather.
fq_j 24 ll A
There is quite a list of groups.
You would II P
25 ij have to refer to the operator's guide and the Macro l
1 Fels 6
i
-2 l
Corporation software descriptions.
3 Q
And that information is contained in 4
materials that we have here on the table?
5 A
Yes.
I don't see the operator's guide but i
6 I do see the two Macro books.
7 Q
Perhaps you could show us in the Macro 8
books what sections you are referring to.
9 ;
A Let me see one of those.
10 Q
Just provide an example or',two and a i
11 l general indication of what you are referring to.
12 A
I need volume 1.
O 13 This is an example (indicating).
14 Q
How would you identify this section of the 15 manual?
Would it be by those letters in the lower 16 right-hand corner of the page?
17 A
These letters and this number.
18 Q
The number is TMIC-82, Human Communications 19 ;
Extensions, and the page in'the book has the letters 20 HCE in the bottom right-hand corner.
i 21 j Which entry were you indicating on that il i
page?
It is page 7.
22 I:
23 ll A
well, these (indicating)..
OV 24 f Q
Additional print groups?
25 l-
_A Yes.
Well, that's what's 'in the
I 1
Fels 7
O 2
group.
Q For example, one says group 15 reactor 3
4 coolant and makeup pump conditions, and then other
(
5 groups are identified, groups 15 through 19, and so 6
all of the inputs in those groups would be put together 7
somewhere in the computer, is that what you mean, in 8
the wiring?
A well, no, they would be put together in 9 l 10 the software.
These groups just consik,t of individual l
11 ;
points.
6 12 j Q
I'm sorry, could you explain that.
The I
groups consist of individual points, you said, just 13 14 in reference to the one we read into the record, 15 group 15?
i l
16 A
The computer basically has, let's just 17 use that as an example, a thousand inputa.
It does 18 the things that I mentioned under field input checking i
19 ;
to each input.
Now, to make it useful for the operator, l
20 i if you have 20 of those individual points from the i
a 21 feedwater system in software, you make a group available 22 i and put those 20 points in it so that whenever he pushes 23 !
one button, it automatically prints out or displays
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24 h
those 20 points.
s-25 ll Q
Now, in order to know for each of the groups l
l 1
Fels 8
2 what 20 points come out when the button is pushed, I i
3 look in the Macro book, is that correct?
Is that 4 i information contained in there?
(
5 A
I don't know.
6 Q
Do you know some place where it is 1
7 contained?
i 8
A Yes.
9 !!
Q Where would that be?
a 10 !
A I can think of two places it should be, i
l 11 i It should be in the alpha listing and I am pretty sure
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12 f it is in the operating procedure, the plant operating l
13 procedure for the computer system.
Q What is the alpha listing?
14 15 A
It's another computer listing that contains 16 some of the group information and headings and titles 17 and messages that the computer outputs to.the operator.
18 Q
Who prepared the alpha listing?
l 19 i A
That was there when I got there so I have 20 to assume that it was prepared by the computer vendor.
21 i Q
You referred to an operator's guide earlier.
(.
!,i lf What is that?
I 22 h
23 !!
A That's a vendor document specifying the l
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24 operator interface to the computer system.
It tells i
25 I the operator how to use it, what the groups are.
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l 1
Fels 9
O
'Q.
2 Q
Now, the groups can be changed, though, 3
can't they?
4 A
Yes.
(
5 Q
How would we know what groups existed as 6
of the day of the accident, for example?
7 A
There essentially would be no changes to 8
the groups other than groups added at the time the syste 9 i was installed.
The groups themselves were not changed 10 i on a daily or weekly basis.
I l
Q Where are the groups that were added 11 12 identified?
%.s 13 A
Those are identified primarily in the Macro 14 write-up on the balance of plant additio t
i 15 :
Q Any place else?
16 A
Not that I could think of.
17 Q
Can groups be added to or subtracted from 18 by operators in the control room?
l 19 A
Only three.
20 Q
Could you identify those?
21 1
A Typically called operator group A, B and C.
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t 22 They wind up being groups 11, 12 and 13.
l 23 l
Q What can the operator do in those three i
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groups?
25 A
The operator can put points that he wants
I 1
Fels 30
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2 l to look at in those three groups.
3 Q
How many points are there in each group?
4 A
I believe there are 36.
5 Q
Per group?
6 A
Yes.
7 Q
If the operator wanted to add different 4
8 input to group A, what would be involved in that t
9 process?
10 A
There is another function ayallable that says add point to group and he merely uses that 11 12 function, enters the point that he wants to add to the 73b 13 l group, and that point goes to the head of the list.
14 Q
So you just push a button that says add
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i i
15 !
point to group and type into the computer group A and 16 identify the point by code number, is that it?
17 A
Yes, the operator's console prompts you I
18 !
when you push a button and if you add point to group, I
19 l it more or less asks for a group number which would be 20 the 11, 12 or 13.
After you enter that, it asks you 21 for point number.
1 i.
22 y Q
The point number's code number on the
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l 23 1 input / output list?
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24 A
That is correct.
f 25 Q
so it would only take a matter of a minute
i i
1 Fels 11 2
or less to add a point to one of these groups?
l A
That's true.
3 I
i 4
Q Do groups A,
B or C have trending functions?
(
5 A
Yes.
6 Q
Could you describe tho'se?
7 A
It's one function called group trend.
8 Q
How does that work?
9 l A
There ic a function number associated with 10 j any of the operator functions.
There 1,s a number i
11 :
associated with group trend.
The operator would enter i
12 ~
that number, specify the group and specify the interval O
13 that he would like that group trended.
4 14 Q
Could you give an example of that to make i
15 it concrete?
16 A
You request the function associated with 17 a group trend --
18 j Q
And that involves pushing a button?
l 19 A
There is a start clear button that prompts 20 the operator console to enter the function number.
You 91 i enter the function number.
C.
l 22 Q
So you don't. push a button that says group i
t i
i 23 trend?
l
(
34 A
You hit a start clear button and it asks youl I
25 to enter numbers from a numerical key pattern.
l l
1 Fels 12
($)
2 l Q
Which is right on the computer?
I 3
A
'It's on the console face.
I 4
Q You mean it appears on the screen or it is 5
taped onto the --
6 A
It's a hardware panel of buttons.
All of 7
the function buttons have inscribed upon them the 8
function number and the actual function.
All of the 9 l group buttons have the group number and group function i
t inscribed on the keycaps and you have a small numerical 10 ;
i 11 l keypad on the far right that has a stop clear and s
12 start cancel number buttons on it, O through 8,
and 13 decimal point, plus and minus.
Everything is keyed i
I 14 from the start clear button.
When the operator hits the start clear 15 u
16 button, a little display window just above that pad 17 asks for function number.
You give it a " function 18 number.
10 Q
Where does it get the function number 20 now?
He pushes the start clear button?
A The group of buttons on the left-hand side 21 l
i 22 :
are the function.
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23 l!
Q Function buttons?
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24 'j A
Well, it's a black, little square button 25 that has a function number and the function that you i
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I 1
Fels 13
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t want on it, e.g.,
the one in the upper left-hand 2
1 i
3 corner for function 1 might be print point and it will i
I 4 I have_on there a number 1 and print point inscribed on
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5 the cap.
When the computer asks you for a function 6
number, you put in a 1 and enter.
Then the computer 7
knows that it needs to ask you for what group or, in 8
this case, for a print point function.
The computer i
9 i would prompt you by asking you for point number.
l 10 So you enter the point numb,er from the 11 Io list and hit the enter again, and it will print the 12 value descriptor for that point number.
O V
13 All of the functions on the operator
~
14 console work in the same general manner.
15 Q
So in the case of the trending, you push 16 the start clear button and then you would find the 17 function button for group trend, is that. correct?
f 18 A
That's correct.
l 19 Q
You push that and the computer would say 1
20 -
what group?
01 A
True.
k.
22 Q
Then the groups are also identified on 1
l 23 ll the buttons?
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24 A
Yes.
The operator groups are identified on the buttons.
There are some balance of plant l1 25
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f I
l l
1 Fels 14 (v~b 2 j groups that aren't identified on the buttons, t
3 Q
so if you wanted to do some trending of 4 l group A, for example, you would walk over to the
(
5 console, punch the start clear button.
It would say 6
what function?
You would punch the function button?
7 A
No, you enter the function number.
8 Q
Then you would -- the final step after 9
you put in a group trend function number and you do i
10 i that on -- it's a keyboard that you enter that with?
11 i A
A small vertical keypad on the face of the l'
12 console.
O 13 l
Q I guess I don't know what a keypad is, i
l Where do you get the number 14 well, a keypad, where 15 do you get the number that you want to put on the 16 keypad?
17 A
off the inscribed caps.
18 Q
Then, finally, you enter the group and that 19 just involves that's another keypad or what is i
20 that?
21 A
The same keypad.
You would enter 11, 12 i
22 l or 13 depending on which group you wanted to trend.
j Il i
il Q
If you wanted to do a single point trending, 23
.A( )
24 how would you do that?
)
i 25 i
A
.That's a different function.
I i
.1
l 1
Fels 15 r^s N_.
2 Q
Could you do that step by step?
3 A
It's exactly the same as what I have just l
4 said except that when you are prompted, you are 5
prompted for point number instead of group number.
6 Q
How do you assign a point to the analog 7
trend recorder?
8 A
Again, it's another function.
l 9
Q So it's start clear and then you put in t
10 [
the function for analog trend recorder and then it will
- r 11 j say what point?
12 A
It will say what recorder,,what point and 13 ask for span information.
l I
1 14 j Q
I wonder if you would give us a general 15 description of the NOVA functions nnd what I would like 16 you to do is identify each of the NOVA functions and 17 give a brief description of what it does'and then as 18 to some of them, we might come back and try to go in 19 l more detail and into function.
20 y A
The basic purpose for the NOVA was to provide f
l 21
{
the same functions for monitoring of points that the 1
22 ;
Bailey does except that it's an expansion of that 23 l!
capability from a number standpoint.
So it does the
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24 I!
analog and digital scanning of points for an additional C
25 f group of points, most of_which come from the balance of i
i i
I l'
Fels 16
('J g
i
's_
2 1 plant as opposed to the NSS.
3 l In addition to that, it provided sequence l
4 !
of events, monitoring and processing.
In addition to
(
5 that, it provided a display CRT for the operators.
In 6
addition to that, it provided some utility functions 7
for computer people, mag tape, magnetic tape handling 4
8 capabilities.
9 ]
Q Anything else?
10 h A
Not that I could think of.t t
11 j Q
Take your time.
I just didn't know whether 12 l you were waiting for me or looking at any of these 13 materials, too.
14 A
Well, I really didn't review the entire 15 balance of plant design before I came here so that's 16 the high points, to the best of my knowledge.
17 iQ Now, the first point you ment,ioned was that l
18 it increases the number of inputs that c a'n be scanned, i
I 19 is that correct?
r 20 A
Yes.
I Q
And these are all balance of plant inputs?
21 k.
l 22 - l A
Primarily.
i l
23 l
Q Do we have here on the table a complete I
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24 list of those inputs?
25 A
Yes.
BOP input list.
I ll -
i
l l'
Fels 17
- O 2
Q I show you a black binder which has got a I
3 [
number on it, 2761-1-1.
It is called Unit 2 computer 4 ]
BOP Input Specs.
Il
(
5 Is this what you are referring to?
6 A
- Yes, i
7 Q
Now, does this BOP input specs listing 1-8 n contain all of the NOVA inputs as of the day of the
\\l l
9 N accident?
i I
10 ~
A Yes.
i l
Q Is it limited to NOVA inputs?
11 i
12 A
That particular listing is.
13 Q
on the first page it indicates there are i
i 14 r evis ion s 0 through 11.
11 was the last revision on i
4-15 February 1,
1979 before the accident?
t 16 A
If that is what the date is, yes.
I 17 Q
Then it gives, under the ID column on that I
j 18 -
same page, there are some initials.
What.are those?
19 A
That most likely would~be the person making I.
20 the revisions.
-(
21 Q
Is there some way to tell from the printout b
l 22 l what revisions were made on the date specified?
!i l
'23 y
'A I think -- there is a column for Rev. number s ;-
O
'l V
24 in other words, something was done to this at the Rev. 9 25 update.
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I 1
Fels 18
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2 Q
So you look in the Rev. column and there is 3
a number identifying when a change got made to a 4
particular input?
(
5 A
Y e s,.
6 Q
Would that mean, for example, you pointed 7
to one that said point No. 3049 ES Actuation B Building.
8 Did that mean you could put something new in and take f
something old out or you just changed what is there in 9
10 [
some fashion or what kinds of revisions,are involved
'i l
in a list like this?
11 12 A
Most of the revisions made from the basic
~
13 t list were made dealing with descriptors, points sources 14 and in the case of the point you used, for example, the 15 contact description.
1 16 Q
By that you mean what you call it, just 17 the words that you use there?
18 A
If it's open, you call it normal or you 19 call it trip.
You can change those depending on form i
20 of contact you have in the field.
21 I Q
And then point sources can also be revised, bl l
22 p you said?
1 23 $
A If the point source is changed, yes, you h
24 would typically revise that, yes.
25 I
Q What does that mean, a point source, what
. -~
i 1
1 Fels 19 OV 2
are you referring to?
'l 3
A
'I n the case of an analog input, the analog 4
source of the signal RTD, thermocoupler, pressure 5
transmitter, wherever you are getting your process 6
variable.
7 Q
Are those point sources identified in the 8
printout?
9 A
In those cases, they are, yes.
Not in all i
l 10 cases.
E 11 l Q
When would they not be?
Is there any system
}
12 i to it?
13 A
I really can't answer that.
Most of this 14 information was here when I started work here.
I 15 Q
The second thing you mentioned as another 16 function was the sequence of events monitoring and 17 processing.
Is that described by a software program?
18 A
Yes.
j 19 Q
Do we have that here on the table?
20 A
You do in the Macro books.
21 l Q
It is contained in the Macro volumes in the
~
l 22 l system description?
l i
23 l
A Yes.
i I
l
()g
.Q And those volumes accurately describe the q_
2 l.
25 l software?
l l
1 Fels 20 l
/
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l 2 l A
Yes.
l Q
There were no changes made to it?
3 i
4 A
Not that I know of. Any changes would be
('
5 marked up in the latest listings of the actual 6
Programs themselves.
7 Q
There would be some kind of entry showing 8
the change has been made?
I g
A Yes.
I i
10 ;
Q And we have the latest prog, ram for software?
i 11 j A
To the best of my knowledge, that is the l
12 latest, yes.
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l 13 Q
Could you identify that?
14 A
The two books on the bottom.
15 Q
These books have tags on them.
They are 16 identified as 2761-2-1 and 2761-3-1, both entitled 17
Mr. Fels' name is-o n the cover.
18 Are these your own personal copies?
19 A
Yes.
l
)
20 Q
And to the best of your knowledge, these 21 l
two volum'es contain NOVA software as of the day of
~
l 3
22 '
the accident?
I E.
~
23 f A
Yes.
24 l
Q And any changes from a Macro description h
25 ll would be included in this description contained in these i
l
_ ~
I 1
Fels 23
. A) 2 two volumes?
3 l A
That's true.
4 Q
To identify the inputs in the sequence of l
5 events, would we look in the software or the input list 6
or where?
7 A
The input list identifies the sequence of 8
events inputs.
9 l Q
In what manner?
l l
10 A
There is a column in there,that says point 11 type.
They are labeled SOE.
12 Q
Or if it says ALM, that means alarm?
13 A
standard digital input, yes.
14 Q
Are there any other possible entries?
15 You say it would be in the point type column?
16 A
Yes.
17 Q
That is where group assignments would be 18 indicated?
19 A
Not group assignments, no (indicating).
20 Q
I see.
When point type says ALM, what 91 does that stand for?
[
A Standard digital input.
22 23 4 Q
That is what the letters ALM indicate?
I l
24 A
Under the point type column in this listing, 25 that's.true.
i
l 1
Fels 22 2 l Q
Standard digital input?
3 A
Yes.
I 4
Q Is that an acronym?
-l 5
A Just alarm it stands for.
6 Q
You talked about a display CRT as a NOVA 7
function.
Could you describe that?
8 A
Well, essentially there is, I believe it 9
was a 12-inch monochrome CRT installed in the operator's i
10 i console.
I l
Q Was there just one CRT associated with the 11 i
12 l computer in the TMI-2 control room?
O 13 A
Yes.
l l
14 i
Q And it was this 12-inch CRT?
i 15 A
That's correct.
16 Q
How did the NOVA drive,or whatever expression l'T you use, the CRT?
18 A
The NOVA had the software handler and the
)
19 hardware serial interface to drive the CR$.
20 ;
Q What went up on the CRT?
I 21 l A
Group displays, both Bailey and BOP,
(_
22 i current alarms.
l 23 Q
Current alarms?
i
)
24 !
A Current alarms was the default display.
s Pt 25 i Q
Was the what display?
I 1
Fels 23
?
2 ;
A Default.
3 Q
'What do you mean?
i 4
A If you had a group up and canceled that 5
group, current alarms would come up automatically.
l 6
Q If you had a group on, the group would keep 7
showing up until you canceled it?
8 A
It stays there until you update values, yes.
9 :
Q If you cancel that out, the alarm comes out i
10 ll automatically?
I A
That's true.
11 ;
12 l Q
And that would not be a display of what is 13 on the alarm typer, it would be a display of what the i
14 computer is currently scanning and picking up?
i 15 A
It could be the same.
S 16 Q
What do you mean?
17 A
As the alarm printer.
18 Q
Are you saying you are not sure?
19 A
I am saying it could be.
It depends on 4
20 conditions.
21 Q
Oh, I see.
What does it depend on?
l 22 A
That particularly is a stored chronological !
i 23 display for the CRT, no time taking.
So if you're a 24 long, long time between alarms and an alarm comes in, i
25 the line that gets written to the CRT and the line that l
l l
1 Fels 24 t
2 gets printed will be there about the same time.
i 3 j q
If you are backlogged on the typer, then i
4 they would be showing something different?
(
5 A
That's true.
6 Q
The CRT shows 7
A The CRT is faster than the typer.
8 Q
In fact, there wouldn't be any delay time 9 ;i on the CRT, I imagine, is that right?
10 A
There is some but not much!,
u 11 ;
Q How many lines are there?
?
j 12 A
18.
O i
13 i Q
18 lines?
14 A
Yes.
15 Q
So if it is, let's say, a quarter to 5 and 16 the typer is typing out 4:15, the alarm CRT is typing 17 out or is showing quarter to 5 alarms?
18 A
That is essentially true.
I i
19 I Q
And the things that show up on that CRT are all of the points that have been designated as 20 21 alarm summary points, is that right?
22 l A
Any point in the system that goes into j
II I
23 1 alarm.
l 24 Q
Any point in the system that goes into 25 I alarm?
i I
I I
i Fels 25 O
2 ;
A Yes.
l 3 l Q
Does that include a radiation alarm, let's 4
say?
5 A
In Unit 2 I don't believe there we e any 6
radiation alarm inputs.
The only qualification on 7
whether the point would go into alarm or not was whether i
l 8
or not it was removed from alarm checking.
9 l Q
So if it is an input in the system, it is i
10 going to be on the alarm CRT?
t E
11 i A
If it goes into a,larm, yes.
12 Q
And you said the only exception is what?
, O 13 A
If it had been removed from alarm checking.
14 Q
What does that mean?
I 15 A
There is a function called remove from 16 monitor and essentially what that means is removed 17 from alarm monitor checking.
18 Q
Why would that be used, what's the purpose i
of that?
19 l;
'l A
Say you have an input go open and the field j
20 l
i I
21 input would be constantly changing erratically.
22 g Q
This CRT I gather can also be used to i
ll i
h; display any individual point as well?
23 24 -l A
No.
i 25 Q
So the CRT is limited to the group displays i
f
1 Fels 26 I
- .)
and then automatic current alarm function if a group 2 g I
3 l is not being used?
I 4
A Yes, that's true.
(
5 Q
If you wanted to get a -- use the computer 6
to draw a signal point, you would get that on the 7
utility typer, is that it?
8 ;
A No, there is a NIXIE display window also on a
'l 9 jj the console and if you want to display the value for a 4
10 signal point, there is a function conne.cted with that.
When you exercise that function the point number shows 11 12 up in one window and the value shows up in the other.
O i
l Q
What kind of a readout is that on the value?
13 14 A
I guess you would have to call it projection.
15 They're small, I would say approximately one inch by 1
16 one inch six segment displays.
When you crank up a 17 number, it shines the number on the face of the display.
18 l Q
And that gives you an ongoing reading for 19,j that value?
20 !
A Yes.
I-21 !l Q
It will tell you to cancel it?
l 22 ;,
A That's true.
?
l
{'
Q So that is a digital display of the value?
23
'T i-f 24 A
- Yes, ji t
l 25 g Q
Again, the way to put that into effect is l
I
i i
1 l
1 Fels 27 O
2 i the same way that we talked earlier about making any I
3 l group or point come out, you use the start clear and 1
the function button and the computer asks a question 4
I 5
and you put in a point that you want to have trended?
6 A
That's true.
7 Q
You mentioned also in connection with the 8
NOVA that it does some utility function such as, an 9
example you gave, as mag tape handling.
Were there h
10 any other such functions?
i 11 [
A Yes, they are described in the utility or hl l
maintenance sections of the Macro books.
12 C~t e
I 13 Q
By magnetic tape handling, what are you l
14 referring to?
15 A
Well, the Bailey did not come with mag tape.
16 It came with paper tape as a medium for software 17 maintenance dumping PDO's, that type of thing, which I
18 was cumbersome and time consuming.
A mag tape allows 19 you to do that much faster and clearer.
20 l-Q Now, as I understand it, in the NOVA lI 21 l software, there is a multiplexor task?
I:
22 N A
Yes.
1 23 Q
Could you describe that?
24 A
That is the route task for scanning the 25 plant inputs.
That task knows to address a piece of
,.y-
-- - - ~
m--
~
y---
I 1
Fels 28 O
i 2 '
hardware with the two wires on it that goes to the i
3 ;
field transmitter and bring back a digitized value that 4,
it read from the field input.
It is identical in i
k 5
concept and style to the same task in the Bailey.
6 Q
It works with the NOVA inputs?
7 A
Yes.
8 Q
It is limited to the NOVA inputs?
9 !
A Yes.
10 ;
Q There is an analog trend tb,st.
Have we 11 !
already discussed that or is that something different?
il 12 P A
You have asked me about how to put stuff on O
analog trend.
13 q
'l 14 l Q
Maybe you could describe that, the software 15 i also.
16 A
Very basic.
The computer reads the value 17 stored for the point you want on trend.
.Then re-outputs 1
l 18 :
that value back through another piece of hardware that i
19 q changes the digital value back to an analog value i,'
20 j corresponding to the span, analog span, of the pen i
4 h
- 1 ff recorder.
That is in a nutshell what it does.
(-
22 ',
Q And the CRT output task you already l',!
23 ;:
discussed in connection with the CRT display?
24 A
Yes.
25 j Q
There is something identified as a CRT l'
f
l 1
Fels 29 2
update task.
What is that?
I A
He's the guy that, if a value that you have 3
l
.g j displayed in any given group changes, he goes out and
- l
(
5 it updates that line.
6 Q
Could you give an example of that?
7 A
You have an operator group display.
Let's 8 ;
say the temperature goes up, one of the points you have i
i displayed is a temperature.
The cursor on the CRT 9
10 screen will move and that value will get updated without 11 having to black out the whole screen and redisplay the i
whole thing.
12 13 Q
I see.
Once an operator group display is l
14 l
put on the CRT, it j ust sits there and is automatically I
15 updated by this task if any particular value changes?
16 A
Yes.
17 Q
How frequent are the updates?,
18 A
30 seconds.
And I am not really sure of that.
19,
20 Q
So a kind of trending is occurring there i:
21 !!
in the sense that it is regularly updated?
k.
i A
Well, I guess I wouldn't call it trending i
22 0;
23 ;l but it is a real time function so you try to maintain h
/~Tj 34 your values current with the process.
- I 25 ['
Q-As I understand,the TMI Unit 2 computer
'l www t-y ww e
w w
V e
w r--
l l
1 Fels 30 N
i f
2 could do a leak rate calculation, is that correct?
l l
A That is true, 3
t 4
Q Is that software present here?
5 A
No.
i 6
-Q Where is that contained?
7 A
That would be user software.
8 Q
What do you mean?
I 9 i A
There is a unit function available in the i
10 computer to add your own programs in what they call a 11 ;j user area.
That is where that software is located.
i 12 Q
Which computer does that calculation?
O 13 A
The Bailey.
14 Q
Is there any other software in the user 15 area?
16 A
Yes.
17 Q
Could you identify that other software?
18 l
A No, I cannot.
It would require a printout.
I 19 l Q
What would you go and get if you wanted to 20 have a printout of all of the programs in the user area, what would you call for and ask somebody to bring you?
21 i
22 A
I would just get a list at the user library, i:
i 23 j Q
You would get a software printout in what
(~S 0
()
24 was called the user area?
25 J A
It would be a one-sheet page with program ii l
b
I i
Fels 31
- O i
2 i names and addresses associated with those names.
3 Q
Then you could select, if you were u
I 4
interested in a particular program, then you could get l
(
5 that?
a l
6 A
That's true.
i.
7 Q
But this one sheet would tell you what is 8
there?
9 y A
- Yes, i
i 10 l!
Q Are there any other program,s at TMI Unit 2 i
11 that we don't have other than those in the user area?
I 12 A
Well, you don't have the operating system O
4 13 software.
14 l Q
Are you able to see what is here?
15 A
Yes, I know what's there.
16 Q
Anything else?
17 A
You don't have the nuclear st.eam supply 18 system software.
l 19 Q
Anything else?
20 A
Nothing else other than the user programs ot l that I mentioned earlier.
k i
22 :
Q What does the operating system software 23 involve?
I 24 A
It's basically some core software that
- 25. I,I allows you to interface with the computer.
i I
l 1
Fels 32 2
Q Could you give an example?
l 3 j A.
Some of the functions available are, first i
4 of all, accessing the user program area, being able 5
to program in assembly language _ or FORTRAN and to edit 6
and compile, do all the normal things you do with 7
software.
There is -- the other side of it is some 8
utility functions to allow you to dump areas of memory, j
9 lj either hulk or core, put stuff on paper tape.
I
!l 10 j' Q
Now, as I understand it, th,ere are three i
11 i operator summaries and that's group A, group B and 12 l group C and that's all, is that correct?
13,
A That's correct.
l 14 Q
If I see ar. entry on the printout that says l
operator group trend, that is the group trend we were 15 s
16 talking about earlier?
17 A
Yes.
s 18 Q
The operator simply decides to trend one l
19 !
of those three summary groups, is that correct?
l og i A
That's true.
~
21 l Q
Since the operator-can change the inputs I
a h
in those group summaries, I guess the only information f
22 23 I on exactly what was in the groups on the day of the
' (,-,)
u 21 accident would be in the computer printout on the day.
25 of the accident, is that right?
y.m
...,.-., ~,,
l 4
i 1
Fels 33 0
2 A
If they requested that group on that day, 3
yes.
You would have to look at the time on the group 4
printout and the alarm printer printout for the time j
5 after that to find out whether it had been changed.
6 g
rem sorry, I didn't understand the second 7
part.
The alarm printer printout would tell you 8
something about this?
9 !'
A Yes, because add point to group is one of 10 the functions that is reported on the alsrm typawriter.
Ii 11 Q
Is there a list some place or would there lo t
be a list, would it be indicated in the input list pV li 13 l
vhat inputs were assigned to the operator summaries as I
14 l of any date, let's say, any given revision of the input f
15 :
list?
a 16 A
I don't understand your question.
17 Q
If I went to the input list for 18 l
February 1979 and looked at it, would there be some way 1
19 l of identifying which of the inputs had been put in, as I
i 20 of the point of time the input list had been put in l
21 l the operator summaries?
22 A
No.
i 23 Q
Who decided what inputs would go in the
[
2I operator summaries?
3 25 :i A
The operators.
g:
I
\\
\\
l l
1 Fels 34 t
O 2
Q Do you know anything about the process by l
3 which that occurred?
l 4
MR. KATCOFF:
Are you asking about 5
March 28, 19797 6
MR. WURTZ:
No, the initial, as a group 7
assignment.
I 8
A Generally speaking, if the operators were 9 ;j running a test of some form, they would have a list of F
10 ;
pointo that they wanted to watch, eithhr for precautionary 11 mearures or because to satisfy test r e quir em e.n ts. Those 12 are the points that they would put on the operator 13 groups.
l 14 Q
Was the makeup of those groups changed a I
15 t lot on a daily basis or weekly basis?
r 16 A
No.
To qualify that, they were typically 17 doing plant operation, one or two of the' groups were 18 pretty much left alone and had specific information on I
~
19 i them dealing with the primary and secondary side that 20 t the operators wanted to look at.
Any changing that was 1,
i 21 done primarily was done during the testing program 22 whenever the requirements for watching certain points b
23 ej were different.
~
i.
i 24 Q
During startup testing, you mean?
t!
!l A
Yes.
25
____-A
I 1
Fels 35 O
3 Q
Which were the two groups that were left i
alone?
3 1 a A
I don't really know.
1
(
5 Q
The ones that contained that specific 6
information about the primary and secondary systems?
7 A
I am not sure.
An operator would be better 8
qualified to answer that.
i 9
(Recess taken.)
f I
BY MR. WURTZ:
10 f
l 11 l
Q If I look on a utility typer printout and 12 see an operator group summary, does that mean that O
I 13 group summary automatically went up on_the display CRT i
l 1
14 i
or are those two things separate?
15 A
They are separate.
1G Q
So you get the operator summary on the CRT 17 only if you specifically request it on the CRT7 i
18 A
That's true.
19 Q
otherwise the CRT keeps giving you the 20 current alarms, is that correct?
i
~l y
A Yes.
o k.
N i
33 Q
And just so I have this clear, the display 1
dii 23 CRT would have the last 18 alarms on it?
c 's t
24 A
Yes.
(,,/
l l
l t
25 Q
so that when a new input goes into alarm, l
I 1
Fels 36 b-N_/
2 (~
the oldest of the 18 would go off the screen and a i
3 l new ne w uld come on?
i 4.,
A That's true.
(
5 Q
I have seen a group called the enunciator 6
group review.
What is that?
7 A
There is another row of buttons on the 8
operator's console that's called the enunciator group i
9 buttons and those have specific groups associated with 10 them as far as process function, such hs there is a i
11.
reactor coolant group, there would be a turbine group.
12 )
I forget the exact number of those now.
There is Ob 13.
something around 20, maybe a little less than 20 of 14 ll them.
You have the availability to do a'value display, ll 15 an alarm display by pushing the appropriate buttons 16 and a limit display.
17 Q
Could you convert that then into a l
18 step-by-step process?
Let's suppose you wanted to do i
i 7
19 one of the enunciator groups.
How would you go about 9
20 [
that?
i!
ll A
If you wanted to do values for that 91 33 :l enunciator group, you would push the value button and t
23.'
the enunciator group button that you want.
/~T I
I
(~)
24 L Q
And if it were a reactor coolant group, 25 h you would press reactor coolant value?
I!i l
l 1
Fels 37 3
A You would press value and reactor coolant 3 ;
group.
I 4
Q And it would then give you the values for i
l 5
that specific point in time?
6 A
Yes.
7 Q
You said there is an alarm display 8
function.
What does that tell you?
9 A
There are several.
There is an alarm h
request button associated with the enunciator groups, 10 t
f the same as there was a value button and a limit 11
{
button, so you can request for the enunciator groups, 12
(~)
i 13 j.
if you wanted to know what was in alarm in any of the i
I 14 given enunciator groups, you would follow the same l
i 15 procedure except you would push the alarm review button.
)
16 Q
What does the limit button give you?
j 17 A
It gives you its alarm limits.
18 l
Q It gives you the value at which the 19 particular input goes into alarm you mean?'
20 A
Yes.
I ot Q
And that would be something hadn't reached i.
22 ll alarm and you wanted to see how close it was, you could !
i f
call that j
out?
23 I f gg A
No, you could call the value of the alarm N
i 25 '!
out the value enunciator request.
It's not -- the l
[
l 1
Fels 38 2
limit request is only going to give you high and low limits, not a value.
3 l
4 Q
High and low limits, could you give me an 5
example?
6 A
If you have a temperature span, les say t
7 0 to 600 degrees, you might have a low limit, low alarm i
8 l limit set at 32 and a high alarm limit set at 500, so 3
9 that you will get alarms unless it's within those i
t 10 bands.
If it goes to 500.1, it will be a high alarm; if i
11 !
that goes to 32, it will be a low alarm.
12 Q
When you punch the limit display button,
%)
13 what comes out on the printout?
14 A
Just the limits.
15 Q
What words appear?
16 A
Point number, descriptor and low and high 17 limits.
18 Q
Just to tell you that there is a low and 19 high limit?
20 i A
Yes.
l 21 Q
Without telling you what it is?
22 l A
No, it gives you the value.
It. tells you i
- i i
i what it is.
~
23 21 Q
You referred earlier to a NIXIE display g
'i 25 ]
window.
What is NIXIE?
i 1
I 1
. Fels 39 O
3 l A
It's kind of an old description of one of 4
s 3
the first nethods of displaying digits.
There are two 4 i display windows.
They are not true NIXIE windows but 5
they are like a NIXIE window.
One is used more or t
6 less for point number functions and the right-hand 7
window is used for values.
8 Q
Where would we get a list of the enunciator 9 :
groups?
i i
l 10 A
Probably the easiest way w'Quld be to have 11 somebody just look at the console.
They are described 12 in the software listings somewhere.
I don't recall 13 exactly which listing they are in.
14 Q
Would it be in the Bailey software or the 15 NOVA software?
16 A
The Bailey software.
17 Q
Would it be possible to take photographs 4
18 of the console in such a way that one could identify 1
10 ;
what appears on the various --
l 20 A
Probably several photographs you could.
The caps are pretty small and the inscriptions are very 21 i
(-
I o_o small.
23 Q
The ability to trend certain values going
()
24 into the past, historical trending of values, is a 25 subject I want to touch on briefly.
I
't
I i
1 Fels 40 O
V 2
Does the software we have here describe i
the computer's ability to do those things as of the 3 i l
i 4
day of the accident?
5 A
There is essentially no historical trending 6
of data other than what was described by the analog 7
trend recorders.
8 Q
Well, I am thinking now about at 4:15_you 9
want to get information from 3:45 to 4:15.
i 10 A
Oh, that time period there',are two other 11 li functions available, i
12 Q
Could you describe those?
O l
A Memory trip review.
13 I
Q And that works from --
14 l
I 15 A
And post-trip review.
16 Q
Could you describe each of those?
17 A
The post-trip review is a program that 18 l gathers data for a specific set of points all the time.
I 19 l I think it's half an hour's data at a time.
I am not i
i 20 really sure of that.
There are what they call post-trip i
~
l initiators which, in general terms, usually means og l('
And the program at that 33 I
a 23 time gathers data in a more rapid fashion and stores a
(")3 I:
certain amount of data after trip, flashes a light on 24 :
25 the operator's console that's inscribed post-trip' review i
l l
I 1
Fels 41 2 l to let the operator know that it's ready.
f 3 l He can then request if if he wants it.
1 1
4 Q
Can he always cancel it?
5 A
Yes.
6 Q
He does that by pushing a button?
7 A
Yes.
8 Q
Does the sequence of events work in the 9 I same fashion, a light goes on?
L 10 A
Yes.
11 Q
And he can either request or cancel at that.
12 point?
j.
13 l A
Yes.
14 Q
The inputs of the post-trip review cannot
{
i 15 l be changed by the operator, is that correct?
i 16 A
That's correct.
17 Q
If it is 4:15 and you want in' formation from 18 the past, the post-trip review and the memory trip j
19 review are the only two places where that would be l
20 l
collected?
I 21 A
Yes.
I 22 Q
Could you describe the memory trip review?
i
. '.I 4
23 A
The memory trip review is essentially the
)
21 same as the post-trip review except that you specify hl -
the data gathering intervals but it works off the same 25
l 1
Fels 42
- O
- V 3
2 list of points associated with post-trip review.
3 Q
You specify the time interval you said?
4 A
Yes.
(
5 0
And it holds 30 minutes of information?
6 A
I believe that's true, t
7 Q
What are your options as far as time i
8 interval?
J
{
g i A
I don't recall.
f Q
But the inputs in the memoyy trip review 10 I
11 l and the post-trip review are exactly the same?
I 4
12 l A
Yes.
I k
i 13 Q
When you are dealing with the post-trip l'
review, what is it entitled on the printout?
14 15 A
Post-trip review, the date and time on 16 the header.
17 Q
Let me try to understand this.
If you 18 ask for the post-trip review, the computer would say l
19 l post-trip review and give you what information?
l l
A I am not sure exactly what the header says.
20,
[
d The format of the output and the point numbers in each i
21 f
of the groups are the same.
32 i
i li i
23 Q
Now, with the memory trip review, you c
i
[
4 24 specifically request that?
i i
25,;
A Yes.
\\;
i i
1
1 1
Fels 43
~h (V
2 Q
And the post-trip review, the light goes 3 i on and you just say, " Hey, I will take the information"?
I 4
A Right.
5 Q
so that if the memory trip function were 6
being used, there would be some entry on the printout 7
saying what, what would appear there?
8 A
Some entry where?
9 !
Q How could you identify the memory trip l
l t
10 j review, would there be some typed entry cn the printout?
l 11 A
There should be on the header, yes, there 12 should be something to distinguish between the two 13 Q
Just looking at this pag e -1 of 6,
it is 14 called the memory trip review.
Can you determine 15 whether that is the memory trip review or the post-trip 16 review there?
17 A
It looks like a post-trip review to me 18 because of the time of trip line in here.
't
~
19 i Q
You are pointing to those stars?
fl 20 A
Yes.
(
21 Q
What would you see there if it were the I
22 E memory trip review function?
i I'
h 23 A
You wouldn't have a trip line defined and
(~'l b
s-21 ::
I think it's probably just called memory review.
25 l
MR. KATCOFF:
Can you describe the document
I 1
Fels 44 l
%/
2 for the record, please.
}
3 i MR. WURTZ:
Yes.
This is one page from 4
the day of the accident.
It is called page 1 of 5
6 and it has a number that says E19726.
6 Q
So the trip line with the asterisks 7
identifies that and though it has the word " memory trip 8
review" on it, it is really the post-trip review
.I 9 f function?
I i
10 i A
That's true.
i 11 '
MR. WURTZ:
I would like to mark these 12 documents so that we will have a record of which gg O
13 ones we had here for this proceeding, although we will not take them nor will the reporter because 14 i
15 I realize in one case, anyhow, it is the only 16 printout?
17 THE WITNESS:
That's true.
18 MR. WURTZ:
So you can have it copied but i
19,
we will have the reporter's stamp on it just so l
l l
20 l we know what it is.
I 21 (Binder entitled " Unit II Computer BOP i;
22 j Input Specs 2/79" marked B&W Exhibit No. 330 for l
23 k identification, as of this date.)
(^)
l
(_)
24 i
Q Exhibit 330, as I understand it, is a 23 complete list of NOVA inputs as of the day of the j
1
l 1
Fels 45 r)\\
\\%..
2 l accident, is that correct?
I t
A
'That's correct.
3 !
i 4
(Two-volume document entitled " NOVA BOP
(
5 TMI Unit II, W. Fels" marked B&W Exhibit No. 331 i
6 for identification, as of this date.)
7 MR. WURTZ:
As Exhibit 331, we have two 8
volumes; one is 2761-2-1 and 2761-3-1.
9 ;;
Q Mr. Fels, as I understand it, these two d
volumes constitute the tetal software d,escription for 10 0;
5 11 NOVA as of the day of the accident, is that correct?
I i
12 A
That's correct.
/
(Two-volume document entitled "Three Mile
- 3
{
14 Island, Unit II, Balance of Plant Software, 15 Volume 1,
Revision 1,
February 1978" and " Volume 2,
4 16 Revision 1,
1978" marked B&W Exhibit No. 332 for 17 identification, as of this date.)
18 i MR. WURTZ:
Exhibit 332 consists of two I
I 19 ;
volumes prepared by the Macro Corporation, 20 Revision 1 dated February 1978 entitled "Three l
ot Il Mile Island, Unit II, Balance of Plant Software."
l j
33 4 Q
As I understand it, Mr. Fels, these two 0
1 23 d volumes are the NOVA system description, is that 33 correct?
'li 25 A
That's true.
I
1 1
Fels 46 l
2 l Q
These volumes actually describe the NOVA 3 ;
as it existAd on the day of t h e. accident?
I 4
A Yes.
5 MR. WURTZ:
Off the record.
6 (Discussion off the record.)
7 (Binder entitled " Unit II Computer PID -
Bailey Point Input List Bailey" marked B&W 8
II o
Exhibit No. 333 for identification, as of this 9
E l
'l date.)
f 10 i
gg (Blue binder entitled " Unit II Computer i
go FCC" marked B&W Exhibit No. 334 for identification /
l'l i
13 as of this da.te.1 o
.I g4 h Q
Exhibits 333 and 334 are Bailey computer f
1 15 i input lists, is that correct, Mr. Fels?
16 A
This one is an input list.
17 i
Q Exhibit 333 is an input list?
I 18 A
That's correct.
I 19 q Q
I see a revision date there of January 3, I
i 20 !
1978, is that correct?
4 gg l A
Yes.
I j
Q As I understand it, any revisions after 23,
4 i
i
.)'
l 23 January 3, 1978 are written on the pages in Exhibit 333?
24 l A
That is true.
f 25 d Q
So that Exhibit 333 represents a complete ll l'
I
1 1
1 1
Fels 47 s_ l 3
listing of the Bailey inputs as of the day of the accident?
3 i
4 A
That is true.
I 5
Q Could you identify Exhibit 334?
6 A
334 is the functional computer C software 7
in the Bailey.
i l
Q What is the revision date on that?
8 i
9 j A
1/16/78.
q I
l 10 Q
If there were any revisionb afte: January 11 !,
of 1978 up to the time of the accident, would these be 12 recorded in Exhibit 334?
13 A
Yes.
Ii 14 l Q
So that Exhibit 334 in fact is a complete 15 l software description for the Bailey as of the day of 16 the accident?
17 A
For that functional computer, yes.
18 MR. WURTZ:
There are certain additional 19 materials we request.
Mr. Fels may be able to 20 l assist in locating them quickly.
21 One would be the current alpha listing 32 being used.
i 0
23 4 MR. KATCOFF:
Current,you mean. 3/28/797 3;
MR. WURTZ:
The one in effect as of'the day' 25.'
of the accident.
l
i 1
Fels 48 O
2 ;
The second document needed to identify the l
user area software programs, and then we would, 3
I l
4 ;
after reviewing that, request certain programs, 5
Perhaps, I don't know, I would have to see what is 6
there.
I 7
Third, it would be helpful if we could get 8
some photographs of the console.
I 9 y I guess we are finished.
'l 10,j Thank you, Mr. Pels.
L l!
11 q (Time noted:
12:55 p.m.)
h e
i t ~o O
l 13 ll 14 l
William Fels 15 subscribed and sworn to before me 16 this day of 198 17 18 l l
10 20 91 k.
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22 i I
23 !!
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21 il 25 Il l
1 49
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t 2
_C _E _R, _T _I _F _I _C _A _T _E l
1 3
STATE OF NEW YORK
)
- ss.:
4 COUNTY OF NEW YORK )
5 6
I, NANCY A.
RUDoLPH a
7 Notary Public within and for the State of New York, 8
dc hereby certify that the foregoing deposition 9l of WILLIAM FELS Was taken DefOre t
10 l me on Thursday, December 3,
1981 j
11 That the shid witness was duly sworn 12 before the commencement of his testimony and 13 that,the within transcript is a true record of said 14 testimony; 15 That I am not connecthd by. blood 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 WITNESS WHEREOF, I have 'ereunto set h
(
21 my hand this di day of December 1981.
22
.)3
)
~
' , f. J.., / ;
24 NANCY A.
RUDOLPH 25
[
50 1
1 j
I N D E X
~
WITNESS PAGE William Fels 4
i EX H I B I T S I
1 B&W f
NUMBER FOR IDENT.
329 Resume of William Fels 4
i 4 :,
j 330 binder entitled " Unit II Computer j
BOP Input Specs 2/79" 44 1
J 331 Two-volume document entitled " NOVA BOP TMI Unit II, W.
Fels" 45
- O 1
332 Two-volume document entitled 1
j "Three Mile Island, Unit II, Balance of Plant Software, Volume 1,
Revision 1,
February j
1978" and " volume 2,
Revision,1, i
q 1978" 45 i
j 333 Binder entitled " Unit II Computer f
Bailey Point Input List"-
PID l
Bailey" 46
~
l 334 Blue binder entitled " Unit II -
Computer FCC" 46 l
l i
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s, e a > WA ;..
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. = -,.,.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
___________________________________________y, C'
GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 Civ. 1683 (RO)
-against-AFFIDAVIT THE BABCOCK & WILCOX COMPANY and McDERMOTT INC.,
Defendants.
_______._____x t
STATE OF FENNSYLVANIA)
- ss.:
COUNTY OF DAUPHIN
)
I have read the transcript of my deposition taken on December 3, 1981 and together with the attached corrections, it is accurate to the best of my knowledge and belief.
M 1 4
~
Willgam J. Fels Signed and sworn to before me this
~
/ sed day of Auwst., 1982.
Barbara A. Rote, Notary h
~
East Neerie'.s T.a.. PA tamaner County b
U A
Notary Public' G
i 4
i g
Corrections to Deposition of William J.
Fels
~-)
(
December 3, 1981 Page Line Correction
(
5 10
" processes connected to cables in f
the computer" should read
" processes is connected by cables to the computer" 5
15 "that checking" should read I
"the input checking" 5
24
" enunciator" should read " annunciator" 7
17 "that" should read "this" 7
21
" system in" should read " system, in" 23 23 "taking" should read " tagging" 27 24
" route" should read " root" 30 9
" unit" should read " user" O
34 11 delete "because" 34 17 "dcing" should read "during" 36 5
" enunciator" should read
" annunciator" 36 8
" enunciator" should read " annunciator" 36 10 "as there" should read "as, there" 36 11
" group, there" should read
" group, and" 36 14
" availability" should read " ability" k
(_,
36 15-16 "an alarm display by pushing the j
the appropriate buttons and a i
limit display" should read "an alarm display and a limit display, by pushing the appropriate buttons."
36 19
" enunciator" should read " annunciator" 1
s
~-
A Page Line Correction 36 22
" enunciator" should read " annunciator" 4
j 36 23
" enunciator" should read " annunciator" 37 10
" enunciator"should read " annunciator"
{'
37 12
" enunciator" should read " annunciator" 37 14
" enunciator" should read " annunciator" 37 25
" enunciator" should read " annunciator" l
38 2
" limit request is" should read
" limit request, it is" 39 8
" enunciator" should read " annunciator" s.
d 4
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i 8
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bdd C.'N(
9IG,1IdtN' I..
RESUME
[il. A. R' DDtPH J
WILLIAM JOHN FELS Address:
RD #2 Rhoda Avenue Birthdate:
2/6/44 Mt. Joy, Penna.
17552 (Married /3 Dependents)
Phone:
(717) 653-8292 i
EDUCATION Diploma Electrrnics Technology 1960 RCA Institutes, Inc.
AAS Electronics Technology 1966 Pennsylvania State Univ.
Rank Top Third BS Electrical Engineering 1971 Tri-State College Rank Top Third Certificate Prodae 250 Maintenance -
1972 Westinghouse i
i Diploma GC EHC Large Turbinen 1972 General ticctric Certificate Management & Supervisory 1975 Indiana & Michigan Seminar Pcwer Company Certificate Bailey 855 Computer 1976~ Bailey Meter Company i
Maintenance Certificate Microprocessor Seminar 1977 American Institute Certificate Nova Series Computer 1977 Data General Corp.
Maintenance and Assembly Programming Certificate Basic Supervisory Develop-1978 Metropolitan Edison ment Company Certificate Engineer in Training (EIT) 1978 Pennsylvania Professional Engineering Review Board o
(
Certificate Computer Graphics 1979 Integrated Computer Systems, Inc.
Certificate Max IV Assembly Language 1980 Modular Computer Systems Programming Certificate Max IV Operating Systems 1980 Modular Computer Systems Users 0
~.
.- l
l 6
EXPERIENCE 10/79 to Present GPU Service Corporation Promoted to Engineer Senior I after transfer to parent corporation of Metropolitan Edison Company. Duties included: Participation in system upgrade to TMI Unit 1 Plant Process Computer. Replaced existing printers with modern printers; from conception through design and fabrication of a microprocessor (Motorola 6800) interface with the Bailey 855 computer.
Performed industry survey of multi-plexing and remote multiplexing equipment for expansion and replacement of the existing front end equipment. Worked with software consultant to rectify proble=s with the data acquisition software to implement that software on a Mod Comp Classic computer.
1/76 to 10/79 Metropolitan Edison Co./GPU Service Corp.
1/76 to 10/79 -- Engineer II (Nuclear). Duties included: Organization and b:plementation of Standard Technical Specification requirements as applied to Plant Surveillance Procedares.
Included identification of requirements and authorship of soma of the procedares.
Supervised field input cheekout of large process computer (Bailey 855). This entailed test procedure generation, supervision of Largaining unit technicians and implementation of any required hardware or software changes.
Started system design to_ replace existing process 4
computer with a new system. Worked with A/E on necessary facilities design
(}
changes.
9/71 to 12/75 Indiana & Michigan Fower Company (Cook Nuclear Plant) 3/73 to 12/75 -- Assistant Control and Instru=entation Engineer.
Duties included:
Direct supervision of approximately 20 technicians, all of the below, and responsi-bility for conducting some of the plant preoperational tests in a s,afe and complete Was called upon to do trouble shooting on most sophisticated electronic manner.
control and test equipment.
9/71 to 3/73 -- Performance Engineer.
Duties included:
Large process computer installation, check out and operational maintenance, control systems testing for large diesel generator unit, automatic testing for solid state protection system, and computerized events recorder. Occasional direct supervision of Instrumentation Technicians, also made several engineering studies on technical systems. Design,ed
'{
and fabricated lake temperature monitoring system.
t s
12/69 to 8/71 Arkwright's TV Angola, Indiana Duties:
Service Technician: Did trouble shooting and repair work on the following types of equipment:
radios, television receivers, phonographs, radio control units, and some CB equipment.
Also some sales and customer relations.
During this f-'g time span, I was attending Tri-State College (BSEE).
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- s EXPERIENCE (Continued) 6/66 to 8/69 Eastman Kodak Co=pany Rochester, New York Duties:
Engineering Technician. Assisted senior design engineer in development of electronic servo system. This work involved the use of both linear and digital IC's.
Spent some time working in the high frequency screen room on EMI research. Also worked one year in the Quality Control Group and had the responsibility for initial checkout and maintenance of large automatic test console, including the generation of numerical control tapes used with the console.
SDDIARY Also worked 1!s years af ter graduating from high school as a Nasa Certified Assembler with RCA. Have spent 9 years in two different nuclear power plants and had responsi-bilities for installation, msintenance, end startup of the Plant Precess Computers in both. In additien, I have supervisory experience with both bargaining unit and exempt personnel. Away from work I enjoy raquetball, occasional golf, and home remodeling.
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