ML20072H830
| ML20072H830 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/08/1980 |
| From: | Womack E BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-07, TASK-3, TASK-7, TASK-GB NUDOCS 8306290765 | |
| Download: ML20072H830 (188) | |
Text
J
't 1
{'
'3 UNITED ' STATES DISTRICT COURT l
3OUTHERN DISTRICT OF NEW YORK
' Ol b t. '
U.
______________x i
e O
GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY,
\\
METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs,
-against-Civil Action No.
50 civ. 1683 THE BABCOCK & WILCOX COMPANY and (R.O.)
J.
RAY McDERMOTT & CC.,
INC.,
4 i
Defendants.
________:_x Deposition of BABCOCK & WILCOX, by r
EDGAR ALLEN WOMACK, JR.,
tak.en by Plaintiffs, p4rsuant to Notice, at the offices of Kaye, Scholer, Fierm an, Hays & Handler, Esqs.
I
?
-/
425 Park Avenue, New York, New York, on
/
I Monday, December 6, 1980, at 9:35 o' clock in chaph.ro, the forenoon, before Charlee a
i l
Certified Shorthand Reporter pW Notary Public within the for the State of New York.-
l
. ('
r l
t DOYLE REPORTING. INC.
(
~ CERTIFIED STENOTYPE REPORTERS 369 LsxlNGTON AVENUE i
'7 i
8306290765 821208 PDR ADOCK 05000289 T
PDR TscapNoNs 2:2 - se7.e22o
.- A
2 Appe arance as 3
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER,.ESQS.
Attorneys for Plaintiffs 4
(
425 Park Avenue New York, New York 5
By:
RICHARD C.
SELTZER, E S Q'.,
6
-and-ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9
-and-t 10 11 BERLACK, ISRAELS & LIBERMAN, ESQS.
- 26 Broadway O
JESSE M.
MEER, ESQ.,
14 of Counsel 15 16 17 DAVIS, POLK & WARDWELL, ESQS.
Attorneys for Defendants 18 One Chase Manhattan Plaza New York, New York 19 By:
ROBERT B.
FISKE, ESQ.,
20 ROBERT F.
WISE, ESQ.,
-and-21 RODMAN.W. BENEDICT, ESQ.,
22 of Counsel 24 Also Presents 25 DAVID TAYLOR
CE) 2 IT IS HEREBY. STIPULATED AND AGREED by 3
and among the attorneys for the respective 4
parties hereto that the sealing, filing and 5
certification of th's within deposition be, and 6
the same hereby are, waived; and that the 7
transcript may be signed before any Notary 0
f Public with the same force and offect ao l'f 9
signed before the court.
- i. :
10 IT IS FURTHER STIPULATED AND AGREED 11 that all objections, except as to t'he form 12 of the question, are reserved to the time of 13 trial.
14 e
e 15 16 E DGAR ALLEN
- WOMACK, J
R.,
17 having been first duly sworn by the Notary 18 Public, was examined and testified as 19
- gallows, 20 EXAMINATION BY MR. SELTZER:
21 Q
State your full name, please.
22 A
Edgar Allen Womack, Jr.
23 Q
By whom are you presently employed?
24 A
Babcock & Wilcox company.
25 Q
What is your business address, please?
g 1
Womack 4
2 A
Lynchburg, Virginia.
3 Q
If someone were, addressing mail to you, 4
whare would they write to you?
(),
5 A
I think it's post office box 1260, 6
Lynchburg, Virginia, 20545.
7 Q
Do you work at the main office 8
building of Babcock & Wilcox in Lynchburg?
g A
There are several office buildings.
10 Yes.
I work at the main office building of the 11 Nuclear Power Generation Division.
()
12 Q
What is your present position with 13 B&W7 14 A
I am the Manager of the Reactor and Fuels 15 Management Department.
16 Q
When did you assume that position?
17 A
The 15th of July, 1980 18 Q
What had your immediately previous 19 position been?
20 A
Manager, Plant Engineering.
21 Q
When did you become Manager of Plant 22 Engineering?
23 A
Feburary 1980.
24 Q
What was your position immediately 25 previous to that?
i
A 1
Womack 5
U 2
A Manager, Plant Design.
3 Q
When did you become Manager of Plant 4
Design?
5 A
August 1978.
6 MR. SELTZER:
I would like to mark for 7
identification as GPU Exhibit 1 the resume 8
of E.
A. Womack, Jr. previously marked at 9
your deposition by the President's Commission.
10 (Resume of E.
A.
Womack, Jr. was 11 marked GPU Exhibit No. 1 for identification
(
12 as of this date.)
13 (Handing document to the witness.)
14 Q
Can you identify GPU Exhibit 1,
please?
15 A
This is a resume provided by me in an earlier 16 deposition.
17 Q
What earlier deposition?
18 MR. FISKE:
Do you remember?-
19 A
I don't remember, to tell you the truth.
20 Q
How many times have you been deposed 21 previously?
22 A
Three.
23 Q
Tell me who deposed you on each of those 24 three occasions, not the individual but what 25 party or organization was deposing you.
/~~T 1
Womack 6
U 2
A In the first case, the legal staff of the 3
Kemeny Commission.
f 4
In the second case, the legal staff
()
5 of the NRC Special Investigating Group, the 6
Rogovin Group, and in the third case, I gave 7
testimony to an NRC investigator.
In fact, -- excuse 8
me.
In fact, I have done that on two occasions.
9 Q
So you have been deposed four times, i.
10 is that right?
Once for the President's 11 Commission, once for the Rogovin Commission and
()
12 twice for an NRC investigator?
13 MR. FISKE:
Maybe you ought to 14 clarify what you mean by " deposition."
15 Q
I mean a transcribed event where 16 you are giving testimony.
17 A
Yes.
In that case, there were.-four times.
18 Q
Were the instances in which you gave 19 testimony that was transcribed instances that took 20 place in the order in which you 3ust described 21 them, namely, first the President's Commission, 22 second the Rogovin Commissioni and third and
(~}
23 fourth NRC investigators?
V 24 A
I believe that one of the NRC interviews 1
25 interposed between the Kemeny and the Rogovin
/~N 1
Womack 7
U 2
Commission.
It may have, preceded the Kemeny 3
Commission, e
4 Q
Have you reviewed the transcripts 5
of your testimony before the Kemeny Commission?
6 A
Do you mean since the deposition?
7 Q
It would be pretty hard to do it 8
before, wouldn't it?
I'm sorry.
I mean since.
9 A
Yes, I have reviewed the transcripts.
(
10 Q
Have you reviewed the transcript 11 of your deposition by the NRC Special Inquiry?
(9 12 A
Yes.
,/
13 Q
Have you reviewed your ' transcript 14 of each of the two interviews by an NRC 15 investigator?
16 A
Yes.
17 Q
Do you still have copies.of your 18 deposition or custody of each of those, deposition 19 transcripts?
20 A
Yes, I believe I do.
21 Q
What was the subject of the first 22 NRC investigat:r's deposition or interview?
23 A
As I recall, it dealt primarily with the
(~))
'\\_
24 with my recollections of the 28th of March, 1979.
25 g
What else did it deal with?
1 Womack 8
2 A
I believe that was the substance of it.
3 Q
That was exclusively what it dealt 4
with?
5 A'
To the best of my recollection.
6 Q
Do you remember who interviewed you?
7 A
There were two interviewers, one of them was a Mr. Creswell.
8 was Mr.
9 Q
Who was the other?
t 10 A
I don't recall.
11 Q
Was the other person a lawyer?
O( j 12 A
I believe he was not.
13 Q
Creswell is a member of the NRC 14 staff, is that right?
15 A
I believe that is correct.
16 Q
How long did that interview take?
17 A
About an hour.
18 Q
,Where did that interview take place?
19 A
In Lynchburg.
20 Q
Were you represented by counsel at 21 that interview?
22 A
Yes.
23 Q
Who?
(
24 A
I believe by Mr. Nelson.
25 Q
When, to the best of your 4
1 Womack 9
2 recollection, did that i,nterview take place?
3 A
I'm sorry, I can't pin it down for you.
4 Q
How soon after the accident do you
(
5 think it took place?
I 6
A I believe it was within two months.
7 Q
Were other people at B&W interviewed 8
by creswell at or about the same time?
9 A
Yes.
E 10 Q
About how many people'were 11 interviewed by creswell?
O 12 A
I don't know.
(,j 13 Q
How many of the peopl'e who reported 14 directly to you in the cesign section were 15 interviewed by creswell?
16 A
I don't know.
17 Q
Was Mr. Dunn interviewed?
18 A
I don't know.
19 Q
Was Mr. Karrasch interviewed?
20 A
I don't know.
21 Q
Whom else do you know was interviewed?
22 A
Sir, I can't recall who was interviewed in 23 that series of interviews.
(~
U 24 Q
You testified you knew other people 25 were interviewed.
l-
1 Womack 10
(~N 2
A Yes.
I recall that other people were 3
interviewed.
4 MR. FISKE:
And he said he didn't 5
recall who they were.
6 MR. SELTZER:
Right.
7 Q
You don't recall a single other person 8
who was interviewed?
9 A
Not with surety.
t 10 Q
What is your best recollection of who 11 else was interviewed?
(
12 MR. FISKE:
If you have one, 13 Mr. Womack.
14 A
Well, I would speculate that --
15 MR. FISKE:
No.
If you recall, tell 16 Mr. Seltzer.
If you don't recall, tell him 17 you don't recall.
18 THE WITNESS:
I told him,I don't 19 recall.
20 Q
Are you telling me that your mind is 21 an absolute blank or there are some names that 22 occur to you but you are not 100 percent positive r-23 that they were interviewed?
Which is it?
N 3]
24 MR. FISKE:
Mr. Seltzer, I don't 25 think this is going to go anywhere.
,-yw.
y
---..--.,---w
Womack 11
(-)
1 V
2 MR. SELTZE,R:
Let me pursue it just ne r two more questions.
3 4
A I am telling you that there are names 5
which occurred to me but I cannot tell you with 6
surety whether they were or were not interviewed 7
at that time.
8 Q
O.K.
I would like your testimony on 9
what names occur to you.
5 10 A
The two names you have sugges'ted certainly 11 occurred to me.
12 Q
Who else?
13 A
Mr. Seltzer, are you asking me for names 14 that could have been interviewed or names that I 15 have some idea that were because to go farther 16 would be speculation at this point.
17 Q
I am asking you,to the best of your 18 present recollection, what names are occurring to 19 you as people whom you believe were also interviewed 20 at or about the same time by the NRC.
A I suspect Dr. Roy and I suspect Mr. Taylor.
21 22 Q
When you say you suspect, that is 23 based on your own recollection as best you can construct it sitting here today, is that right?
24 25 A
That's correct.
1 Womack 12 2
Q By the way,, all I am asking you for 3
today is your best recollection as you sit here.
4 A
Yes.
I understand.
5 Q
If we all had memories like a 6
Univac computer, I would expect more precision but 7
I can't expect that.
8 were any of these other B&W 9
employees in the room at the same time that you e.
10 were being interviewed?
11 A
No.
()
12 Q
Were you in the room at the time 13 that they were being interviewed?
14 A
No.
15 Q
Who interviewed you the'second time 16 that the NRC deposed or interviewed you?
17 A
I can't recall the gentleman's name.
4 18 Q
was there just.one person?
19
,A No.
There was more than one person.
20 Q
How many?
21 A
Either two or three.
22 Q
Do you recall the identity of any s
23 of them?
24 A
No.
25 Q
How long did that interview take?
., _. - -.. - _ _ _ _ _ _, _ _ _ _ _ _ - - _ _ _ _.. _ _ _ _... _ _ _. - -, ~ _ _ _ _. - _. _ _. - - - _. - - _. _ ~
1 Womack 13 0
2 A
Approximately 30. minutes.
3 Q
What is your best recollection of 4
when that interview took place?
5 A
That was the last of the four depositions 6
I have mentioned and it took place perhaps early 7
in 1980.
8 Q
Where?
9 A
In Lynchburg.
10 Q
Who represented you at that 11 deposition, if anyone?
~%.
(Q 12 A
I don't recall.
13 Q
Do you recall whether you were 14 represented by anyone?
15 A
No.
16 Q
What was the subject of that 17 interview?
18 A
Again, certain events,and especially 19 communications on March 28, 1979.
20 Q
When you say " events on March 28, 21 1979," does that incl
- events leading up to 22 March 28, 19797 23 A
No.
24 Q
Did this ond interview in early 25 1980 have.anything to do with questioning you about
1 Womack 14
(N 2
tape recordings?
3 A
Yes.
4 Q
Could you tell me the substance of
(,
5 that.
4 6
A The --
7 MR. FISKE:
The substance of what?
8 MR. SELTZER:
Of what he was being 9
questioned on regarding tapes.
10 A
The interview included questions about 11 recordings of operations and conversations that
)
12 we had had on March 28, 1979 in B&W.
13 Q
Were internal conversations at B&W 14 on March 29th tape recorded or March 28, 19797 15 A
some were.
16 Q
Have the tape recordings that were 17 made of internal conversations at B&W.at or about 18 the time of the accident been transcribed, in 19 other words, typed?
20 A
To the best of my belief, some have.
(
21 Q
You have seen typed versions of some 22 of them?
23 A
No.
v 24 Q
Whom would you go to if you wanted 25 to get a copy of some of the typed versions of
f"x 1
womack 15 2
transcripts which you be,lieve have been typed up?
A To my counsel, to our contracts Legal 3
4 Department.
5 Q
Have you had any other depositions 6
or interviews with people outside of B&W regarding the accident other than the four that you have 7
8 identified so far?
A I have discussed the subject with others 9
e 10 many times and I have given testimony which, of
~
11 course, is recorded before the ACRS.
Is that the
)
12 subject of your question?
13 Q
That's part of it.
Have you given 14 any other transcribed testimony regarding the 15 accident or anything related to the accident?
16 A
Not that comes to mind.
17 Q
Have you been interviewed by anybody 18 outside of B&W in a fashion that may or may not 19 have been formally transcribed with respect to the accident er any aspect of it?
20
(
21 MR. FISKE:
You mean some formal 22 interview?
23 MR. SELTZER:
Formal or informal.
OO 24 If I get too formal, we can limit it to 25 interviews at which a transcript was taken.
~.-
es 1
Womack 16 U
2 Let me rephrase the question.
3 Q
Y u have identified several instances 4
on which you have been formally interviewed or 5
deposed by persons outside of B&W with respect to 6
the Three Mile Island accident, is that right?
7 A
Yes.
w.
8 Q
Other than those instances, what 9
other occasions, if any, have taken place when you t
10 were interviewed by somebody outside'of B&W with 11 regard to the Three Mile Island accident?
(
12 MR. FISKE:
Can we hear the question 13 again, please.
14 MR. SELTZER:
I will rephrase it.
15 Q
The question is other than the 16 instances that you have already described, on 17 what other occasions, if any, were you interviewed 18 by somebody outside of B&W with respect to the 19 Three Mile Island accident?
20 A
In an attempt to answer your question as
(
21 broadly as possible, I will indicate that I did 22 give an interview to NRC investigators in connection 23 with two of their allegations with respect to O
which they alleged a fine against B&W.
25 Q
Assessed a fine?
1 Womack 17 O
2 A
Assessed a fine.
3 Q
On what, if any, other occasions 4
were you interviewed by anybody outside B&W with 5
respect to the Three Mile Island accident?
6 A
I believe you have exhausted my memory, 7
Mr. Seltzer.
8 Q
On what, if any, occasions other than 9
the ones you have just identified have you t
i 10 discussed the Three Mile Island accident with 11 anybody outside of B&W7 b
12 A
On numerous occasic.ns.
qj 13 Q
Other than social conversation,with 14 what people outside of B&W have you discussed the 15 Three Mile Island accident other than the ones you 16 have alrea'y identified?
d 17 A
With many people.
18 Q
What groups have those people been 19 with?
20 A
Well, I have discussed the accident with
(.
21 members of the Atomic Industrial Forum, with 22 representatives of utilities, with students, with 23 members of the NRC staff, with members of the gg O
24 ARCS, with representatives of our colleagues in 25 Germany, both governmental and industrial.
1 Womack 18 2
Q Is the latter communication entirely 3
or partially with regard to the MK plant?
4 A
Yes.
5 Q
Entirely or partially?
6 A
Yes.
7 Q
Which?
8 A
Well, partially.
9 Q
With members of what other groups 10 have you discussed the Three Mile Island accident?
11 A
Outside B&W7 12 Q
Yes.
13 A
Certainly with counsel.
14 Q
Have you discussed it with counsel 15 for anybody except B&W?
16 A
No.
17 Q
Anyone else?
18 A
The American Power Conference.
19 Q
Are there any other groups that you.
20 have discussed the Three Mile Island accident or
(.
21 any of its implications with outside of B&W7 22 A
I don't think so, sir.
23 Q
Was a transcript made of the 24 interview that you had with the NRC investigators 25 regarding the all'egations that led to a fine
I Womack 19 2
against B&W7 3
A I believe not.
e 4
Q Which were the two allegations on 5
which you were interviewed?
The Carlyle Michelson 6
allegation?
7 A
If you could show me the allegations, I 8
could indicate to you specifically which two.
9 Q
What is your best recollection of 10 which two?
11 A
They were the second and the third is my
[
12 best recollection.
13 Q
The pumps running all'egation 14 A
Yes.
15 Q
-- was the third one.
16 A
And the second, I think, had to do with
'17 steam generator level.
18 Q
How long did that interview last?
19 A
About an hour.
20 Q
When, to the best of your
(-
21 recollection, did that take place?
22 A
I don't know exactly, sir.
23 g
was it before or after the fine was
~g
%)
24 imposed?
25 A
Before.
e's 1
Womack 20 2
Q Were you represented by counsel at that interview?
3 4
A I don't believe so.
5 Q
Did you take notes during that 6
interview?
7 A
No, I don't think so.
8 Q
Was there anybody present from B&W
~
9 who took notes during that interview?
t.
10 A
No, I don't believe so.
11 Q
After the interview, did you sit
()
~ 12 down with anybody and describe to them the 13 substance of the interview?
14 A
I don't recall doing so, no, sir.
15 Q
Did you prepare a memorandum 16 memorializ'ing that interview?
17 A
No, I believe I did not.
18 Q
You described discussions that you 19 had with members or representatives of a variety 20 of groups ranging from AIF to the American Power
(
Conference.
Did you have a written presentation 2
22 for any of those discussions?
23 A
Yes.
24 Q
How many different presentations 25 have you made up for groups that you have met
1 Womack 21 2
with to discuss the accident?
3 A
well, let me see.
The American Power 4
Conference. To the Summer Safety Program at MIT, 5
the student group.
6 Q
The Summer Safety Program, is that 7
what you called it?
8 A
That's what's it's called, yes.
9 When you say " written presentation,"
10 I am interpreting it broadly.
11 Q
Please.
O(_j 12 A
I presume that's,what you want.
13 Q
Yes.
14 A
In fact, that presentation was not written 15 verbatim but was a presentation from slides.
16 Q
In other words, you prepared slides 17 which became the matrix for your talk?.
18 A
That's correct.
19 Q
For what other discussions did you 20 have materials in writing that you had prepared?
~
21 A
I prepared a paper for our operating l
22 Experience Seminar which is a utility group.
r-23 Those are the principal ones that come to mind, k_-
24 Q
Are there some subsidiary ones 25 that come to mind?
1 Womack 22 2
A Well, certainly I have contributed to 3
papers and materials prepared for discussions 4
many times with the NRC, with our utility 5
customers, but those are the papers in which I had 6
a primary role.
7 MR. FISKE:
You mean the ones you 8
have just described?
9 THE WITNESS:
Yes.
10 Q
Would I be correct in assuming that 11 you kept copies of the materials that you had O(_)
12 prepared for each of these discussions in your 13 files?
14 A
Generally, yes.
15 Q
Do you believe that copies of each 16 of those papers should have been produced to us 17 in this litigation?
18 MR. FISKE:
I object to that question.
19 I don't think Mr. Womack is I am not even 20 sure whether he has read the documents, 21 the production request.
I am sure he is 22 not familiar with all the discussions that
(~
23 have gone on back and forth between N_)T 24 lawyers.
I mean, if you want to discuss 25 that subject, you can take it up with Bob r Ron at the recess, but I don't think you
f~)
I womack 23 V
2 ought to bother Mr. Womack with it.
3 Q
You may answer the question.
4 MR. FISKE:
No, you may not answer 5
the question.
6 Q
Has anyone ever spoken to you 7
regarding what documents in your possession might 8
have to be produced in this litigation?
9 MR. FISKE:
You could answer that t-10 question yes or no.
Just answer that yes 11 or no.
uO V
12 A
Yes.
13 Q
Who has talked to you about what 14 documents should be produced from your files in 15 this litigation?
16 MR. FISKE:
You can answer that, also.
17 A
Mr. Mullin.
18 Q
By whom is he employed?,
19 A
Babcock & Wilcox.
20 Q
Who, if anyone else, has spoken to 21 you regarding what documents from your files 22 should be produced in this litigation?
(J"]
23 A
An associate of Mr. Mullin's.
24 Q
Has a.7yone else spoken to you 25 regarding what documents from your files should
1 Womack 24 2
be produced in this litigation?
A I d n't think so.
3 4
Q Do you maintain personal files?
A Yes.
5 6
Q How extensive are your personal files at B&W7 7
4 g
MR. FISKE:
By " personal files,"
g you mean files that he keeps relating to 10 the company's business?
11 MR. SELTZER:
That's right.
I don't 12 mean letters to his aunt.
13 MR. FISKE: Right.
s 14 THE WITNESS:
That is what I 15 understood.
16 MR. FISKE:
0.K.
17 A
Please help me to understand what you mean 18 by " extensive."
19 Q
How many file drawers of material d
y u keep which are your files and under your 20
(
custody and direct control?
And let me clarify 21 that.
I would include your secretary or anybody 22 who is your clerk and who maintains files as 23 O
i 24 maintaining files that are your personal files.
A Perhaps six.
25
(~
1 Womack 25 V}
2 Q
six file drawers or six file 3
cabinets?
4 A
No,-perhaps six file drawers, not 5
necessarily filled.
6 Q
Where are those file drawers?
7 A
They will be in my office or in the 8
adjacent secretary's office.
9 Q
What types of material do you keep 10 in your personal files?
11 A
Items that I consider noteworthy for future y) 12 reference, material which may have been written by 13 me or by others which I believe will assist me 14 in any potential future reference to an issue.
15 Q
so let me try and get more specific.
16 with respect to the accident at Three Mile Island, 17 what files do you maintain in your personal files?
18 A
In the present tense, I maintain a file for 19 the MIT Summer Safety course and still have 20 maintained files of my deposition transcripts and 21 a few files of the material which I accumulated 22 after the accident, including the Atomic Industrial 23 Forum subcommittee material.
(~)N
\\_
24 Q
'How extensive are the materials 25 that you collected after the accident?
s 1
Womack 26 f
2 A
At their most extensive, they might have 3
occupied a file drawer.
4 Q
Did you maintain personal files 5
relating -- do you want to stop for a minute on 6
what you just said?
I see you are raising your 7
hand.
8 A
I have a shelf of published documents.
Do 9
you include those in files?
i.
10 Q
Yes.
11 A
Then perhaps an additional 4-foot bookshelf p~()
12 of published documents.
13 Q
Did you maintain in your personal 14 files at any time materials relating to your work 15 on the Technical Review Committee?
16 A
Yes.
17 Q
Do you still have materials relating 18 to that work?
19 A
I do not believe that I do.
20 Q
What did you do with the materials
(-
21 that you had assembled in connection with your 22 work on the TRC?
23 A
Whatever I had at the time of the request g\\
U 24 for document disclosure, I turned over to our 25 Contracts Legal Department.
1 Womack 27 2
Q Did you personally review your files 3
to assemble materials responsive to the document 4
request?
C 5
A Yes.
l 1
6 Q
How extensive were your files 7
relating to the TRC prior to your turning them 8
over to the Legal Department for production in 9
this case?
c.
10 A
Perhaps a file folder.
11 Q
.The Technical Review Committee has 12 issued its final report, am I correct?
13 A
Yes.
14 Q
Is there still any ongoing function 15 of the Technical Review Committee?
16 A
Not to my knowledge.
17 Q
while the Technical Review Committee 18 was active, you received interim reports and draft 19 reports, did you not?
20 A
Yes.
21 Q
You reviewed those interim reports 22 and draft reports, didn't you?
23 A
In some cases.
24 Q
In the gases in which you did 25 review them, did you make notes on your copies?
(~}
1 Womack 28 V
2 A
I may have done so.
3 Q
As you sit here today, do you believe 4
that you did do so, in any instance whatsoever
\\
5 touch a pencil or pen to your draft copy or 6
interim report copy?
A I suspect that I may have done so, yes.
7 8
Q Yes, you believe you did?
A Yes, I believe that I 9
t 10 MR. FISKE:
The question is do you 11 recall doing it.
12 THE WITNESS:
No, I don't recall 13 a ing it.
14 Q
Would it have bee'n your practice 15 in. reviewing a draft or interim report from a 16 committee on which you were serving to have made notations on the draft or interim report that you 17 gg were reviewing?
19 A
That's one of my practices, yes, 1
Q Do you generally use pencil, pen, 20
(-
highlighter or what?
21 A
Pencil or pen.
22 23 Q
What did you do with the draft and
(
interim reports prepared by you and others on the 24 Technical Review Committee?
25
m p.
,s e6
~
L Womack 29
.n) 4.,
2
-( v
- s
- s. '(
2 A..
Some of them I may have returned, some of t
t 3'
them I may have simply disposed of and all of.them
.t l
.that I had 3.n my possession at the time of the-C*
}
'5' document, requo)st '
turned over to Contracts I
)
6
. Legal.
q
',Q When y'ou say some may have been 7
g
/..\\
~
8' returned, to whom would you have returned them?
4
~
- frg)s 9
A To the person originating the draft which r
10 in most instances would have been th'e committee 11 Chairman.
12 Q
- M r..ini l ?
v 13 A
Dr. B all,.
s 14 Q
To the bent of your'racollection, i
e 15 would the copy which you had' received -show your
'k,,
16 name somewhere on the face of it?
(*'/
\\((d p
17 A
Yes, i t w o u l d l'i k e l y.
4
/I e
s 18 Q
If you wanted to yat back,,an 19 interim version or draft version which had your I
f
,i
.t hov would you go about 20 Pencilled or' penned notes, g't i
', hc 21 doing that?
s,
/
h\\n;
(
22 A
I would contact contracts Legal.
]f.*,
' C ' ".'/.123 C',
When is the lasfc, time that you saw hf l ;
..\\
i interim rep'ortis of th,e ':'EC?
/(W any of'th'e draft or t
I is e
.- 1
.. f i
sv
.s r e q.g f', A 10can't[ recall.
25 ]
I l
1 5 7.9[(.
/
e
/
r; <r. r
/,,,,3.
1,
/
)
2
,o G
- ~ nJ'
(~
1 Womack 30 V}
2 Q
In preparing for your deposition, 3
did you see any draft or interim reports of the 4
TRC7 Today's deposition.
5 MR. FISKE:
I am going to object to 6
that, Mr. Seltzer.
I don't have any 7
objection if you ask him a question in point 8
of time when is the last time he saw one, 9
but I am going to object to questions as i.
10 to what went on during his preparation.
11 I think that gets into lawyers' work (A) 12 product.
13 And just to make it clear, I am not 14 at all objecting to the general question of 15 when is the last time he saw it.
16 MR. SELTZER:
I am just a little 17 perplexed because I am not sure which way s
18 we would prefer to come out on this.
I 19 suppose what should be sauce for the goose 20 should be sauce for the gander.
k.
21 If you are going to instruct your 22 witnesses not to testify what documents they f~s 23 were shown in preparation for their
()
24 deposition, I would assume you will be 25 willing to stipulate not to ask any GPU 1
6
1 Womack 31
%J 2
people what documents they were shown 3
during their preparation for their 4
deposition.
5 MR. FISKE:
Well, I will not make 6
any stipulation now as to what we will 7
or will not do at some deposition in the 8
future.
You can obviously do whatever you 9
want to do at that time, depending on what 10 we do.
11 MR. SELTZER:
Then I will --
12 MR. FISKE:
Let's take one deposition 13 at a time.
14 MR. SELTZER:
Then I will have to 15 proceed.
16 Are you instructing him not to 17 answer my question about whether he was 18 shown --
19 MR. FISKE:
Yes.
20 Q
I take it you met with counsel to k
21 prepare for your deposition today, is that right?
22 A
Yes.
23 Q
For how many days did you meet with 24 counsel?
25 MR. FISKE:
You can answer that.
i
(~%
1 Womack 32 k._
2 Q
With whom did you meet?
l 3
A Mr. Fiske, Mr. Wise and Mr. Benedict.
4 MR. SELTZER:
Off the record.
i 5
(Discussion off the re co rd. )
6 (Recess taken.)
7 Q
Other than your work on the Technical 8
Review Committee, what other files did you maintain 9
in your personal possession relating to the e
10 Three Mile Island accident?
11 A
Shortly after the accident, during the
[)
12 period of time when I was directly a member of s_/
13 the recovery team, I kept some files of issues in which the 14 that the recovery team was 15 recovery team was providing assistance to the 16 utility and also some files relating to issues 17 which were being discussed with the NRC or matters 18 on which the NRC had issued directives, bulletins 19 and the like, and additional information which may 20 have related to information provided by other
(-
21 suppliers and vendors regarding the issues that 22 were being discussed by the NRC after the accident.
fw 23 Q
What, if any, other files did you
(
24 maintain relating to the accident?
25 A
I think that's pretty much it.
(}
1 Womack 33
\\v/
2 Q
Following the accident, B&W set up 3
several new programs which were an outgrowth of 3
4 the accident; isn't that right?
5 A
Following the accident, B&W set up some 6
new programs.
7 Q
And those new programs were as a 8
result of the accident, weren't they?
9 A
Not in every case.
10 Q
In some cases?
11 A
Perhaps.
{( N)
, 12 Q
What programs are you aware of that 13 were created at B&W as a result of the accident?
14 A
B&W initiated an effort to provide more 15 immediately available emergency response 16 assistance to its utility customers should they 17 request it in the event of an abnormal transient 18 in an operating plant.
19 Q
Is that your Abnormal Transient 20 Operator Guidelines program?
21 A
No, sir.
That's our emergency response 22 to the center.
23 Q
What other programs did B&W create 24 as a re s.ul t of the accident?
25 A
Not exclusively as a result of the accident m-c--
--<,,---,w-
---r
-,v--
-v--
-+ -
l Womack 34
~
v 2
but certainly in an attempt to assist, to provide 3
further assistance to its utility customers in 4
their management and operation o f their plants,
5 B&W worked with them to create the program to 6
which you referred.
7 Q
Why don't you --
8 A
The Abnormal Transient' Operating 9
Guidelines program.
t 10 In addition, B&W suggested to its 11 customers and undertook to provide to them at l,Oj 12
_ their option an analysis of an evaluation by.B&W 13 of reactor trip or automatic shutdown events that 14 might occur in their plants.
15 Q
Did that program have a name?
16 A
It has had a couple of names.
I think the 17 one most consistently used was the transient 18 assistance program or is the transient assistance 19 program.
20 In addition, Mr. MacMillan chartered
(-
21 the Technical Review Committee which you have 22 already mentioned to look, with the perspective 23 of the accident, at what could be learned from fgV 24 the accident for the future regarding not only 25 B&W's scope of supply and role in the provision
1 Womack 35
%/
2 of nuclear power plants but also its interfaces 3
and participation with its utility customers, 4
architect engineers and other segments of the 5
industry in the supply of nuclear power.
6 Q
What, if any, other projects were 7
spawned at B&W in the aftermath of the accident?
8 A
At the direction of the Nuclear Regulatory 9
Commission and at the. request of our utility t
10 customers we undertook a number of specific tasks 11 after the accident which bore a greater or lesser
)
12 relation to the events.
13 Some of these included preparation of 14 small break loss of coolant accident guidelines, 15 additional analysis of small break accidents 16 including an evaluation and discussion of the 17 Carlyle Michelson paper for the Tennessee valley 18 Authority, and operating experience and failure 19 modes and effect analysis for the integrated 20 control system and other specific projects.
(~
21 Q
What other specific projects?
22 A
well, I doubt if I can give you an g-23 exhaustive list, but at the direction o f the NRC k/
we analyzed for our customers resetting of the 24 25 pilot operated relief valve pressure relief set
I Womack 36
~ /"N 2
points.
3 Q
You say that was at the request of 4
the NRC?
5 A
Yes.
6 Q
Did your design section take the 7
position that those set points did not need to 8
be adjusted following the accident?
9 MR. FISKE:
Take the position of whom?
t 10 MR. SELTZER:
With themselves.
11 A
There was a considerable discussion as to (Gj 12 the advisability or-desirability'-.let me use x/
13 the word " desirability" -- of resetting those set 14 points following the accident.
The position with 15 which we advised our customers was as,follows:
I 16 In resetting those set points certain 17 capabilities of the reactor system, wh'ich we t
18 believe are of value to operation and safety, 19 would be reduced.
However, the objective being 20 requested by the NRC, which was a reduction in 21 utilization of the pilot operated relief valve, 22 would be achieved.
23 There was thus a trade-off involved, 24 as there almost always is, in reactor system design.
25 In this particular instance the NRC felt very
.T
1 Womack 37 U('%
2 strongly and made it clear that it felt very 3
strongly, to reduce PORV challenges and we agreed 4
with our customers that as an interim measure, 5
one which would require little interference with 6
operation in the short term, that the-set points 7
could be revised and we provided them with a 8
discussion of alternatives and a recommendation 9
to that effect.
e 10 Q
At the time that these discussions 1
11 and recommendations took place, you were the
("h 12 manager of Plant Design; is that correct?
(_,/
13 A
Yes.
14 Q
What was your independent view 15 regarding the desirability of changing the pilot 16 operated relief valve set points?
17 A
From a technical and safety point of view, 18 I did not consider it necessary.
From the point 19 of view of satisfying the desire of the NRC,
?
20 about which they were very insistent, it was
(-
21 clearly necessary.
22 Q
Is it your testimony that but for 23 the views expressed by the NRC you would have p%)
24 recommended leaving the PORV set points at the n
same place where they were prior to the TMI e
y r
w-y r - - - -
w
+~ -
=~s c--e,e-~+
'~
r~}
1 Womack 38 U
2 accident?
3 MR. FISKE: Could I hear that question 4
again, please?
5 (Question read by the reporter.)
6 MR. FISKE:
I think, Mr. Seltzer, you 7
better rephrase that questien.
I think 8
you have got an element in there, "but 9
for the position of the NRC."
I think the 10 NRC position is a very significant factor 11 in all of this and I think to that extent g) 12 you are asking him what is essentially a 13 hypothetical question.
14 MR. SELTZER:
No, I am asking him a 15 very real question.
I am asking for his 16 engineering judgment following the accident 17 at Three Mile Island.
18 THE WITNESS:
Well --
19 MR. FISKE:
That's all right.
20 A
I believe I have already given you that in
(
21 the sense that I said I didn't think it was 22 necessary for safety to do that.
I think, 23 however, that I would like to say that you have
(
one has to understand this in the context 24 to 25 of the concerns created in the wake of the Three
~
1 Womack 39 O
'd 2
Mile Island accident, the discussions then going 3
on with the NRC, and I certainly had no misgivings 4
at the time about taking the step to revise the 5
set points, if that was your question, and I 6
certainly --
.7 Q
It wasn't my question.
8 MR. FISKE:
I thought that was.
9 THE WITNESS:
I'm sorry.
t 10 MR. SELTZER:
I will rephrase my 11 question.
I will restate it.
(~'s 12 Q
If the NRC had expressed no opinion
\\j 13 regarding the changing of set points for the 14 pilot operated relief valve, would you have 15 recommended that there be no change in the set 16 points for the pilot operated relief valve following 17 the accident of Three Mile Island?
18 MR. FISKE:
I am going to object to 19 that question because that's exactly the 20 objection I made a few minutes ago.
I think
(
21 that it is a hypothetical question.
22 MR. SELTZER:
I am asking the manager 23 of Plant Design of Babcock & Wilcox.
24 MR. FISKE:
We know what his title 25 is.
i
~3 Womack 40 d
2 MR. SELTZER:
And I want to know 3
what his engineering judgment is after the 4
accident on that type of a questfan.
(:
5 MR. FISKE:
I think he has given you his 6
answer, Mr. Seltzer, based on his evaluation 7
of a number of different factors, including 8
the position that was taken by the NRC.
9 MR. SELTZER:
And I want to factor --
t 10 MR. FISKE:
Well --
11 MR. SELTZER:
I didn't mean to O
12 interrupt.
\\m/
13 MR. FISKE:
Go ahead.
14 MR. SELTZER:
I would like to place to 15 one side what the NRC contributed to the 16 discussion and ask Mr. Womack whether he 17 had developed an engineering opinion that 18 existed separate and apart from what the NRC 19 was recommending.
20 BY MR. SELTZER:
(
21 Q
Did you have an opinion?
22 A
O.K.
To the extent that I had -- that I 23 can -- it's really impossible, Mr. Seltzer, for
~
24 me to factor out the other environmental 25 conditions that were going on at that particular
+m r
+.,y
+ - - - - - -
1-womack 41 fs 2
time, and especially the position of the NRC.
3 Q
Let me see if I can make it easier 4
for you.
5 A
All right.
6 Q
You reported to Dr. Roy?
7 A
Yes, I did.
8 Q
If Dr. Roy had come to you in April 9
1979 and said, "A1, we have got the Three Mile
'ecommendation 10 Island situation, we need to make a r
11 to our customers about whether they should change I
12 the PORV set points.
Do you have an opinion bn
~
N,s) 13 that, whether we should recommend it or not, 14 separate and apart from anything that the NRC has 15 advised," would you have been able to. answer i
16 that question?
17 MR. FISKE:
Mr. Seltzer, this is just 18 another hypothetical put in a different way.
19 MR. SELTZER:
First I want to know if 20 he would have been able to answer that l
21 question.
s 22 MR. FISKE:
As I said before this --
23 if he was asked that question, I have no O
24 objection to him answering but if you are 25 just putting another hypothetical, I would L
<~s 1
Womack 42
}
2 object.
3 MR. SELTZER:
Are you instructing 4
him not to answer?
5 MR. FISKE:
In that form, yes.
6 BY MR. SELTZER:
7 Q
In substance, did anybody at B&W 8
ever ask you that, whether you had an independent 9
judgment as to whether the PORV set point should 5
10 be changcd?
11 A
I don't remember.
12 Q
Did you form an independent j udgm'e n t r
13 whether the PORV set point should be changed 14 following the accident?
15 MR. FISKE:
You mean independent of 16 the NRC?
17 MR. SELTZER:
That's right.
18 MR. FISKE:
Independent of what else?
19 MR. SELTZER:
Of just the NRC.
20 MR. FISKE:
I think Mr. Womack has
(_
21 said that there were a lot of factors that 22 were taken into account after the accident 23 in which the NRC view was one.
24 Q
I am saying absent the NRC view, did 25 you have a view as the manager of Plant Design
g-Mab/l 1
Womack 43 N,
2 about whether the PORV s,e t points should be 3
changed?
4 A
To tell you the truth, I can't remember 5
at that time whether I sat down and explicitly 6
tried to factor out all of the other considerations.
7 My guess --
8 MR. FISKE:
Don't guess.
9 THE WITNESS:
Excuse me.
(
10 Q
What is your best reco'llection?
11 MR. FISKE:
If you have one, 12 Mr. Womack, and I think it should be c' lear, Wom'ck says he 13 Mr. Seltzer, that if Mr.
a 14 doesn't recall, it really doesn't advance 15 the cause very much to say what is your 16 best recollection.
If he has no 17 recollection, he has no recolle.ction.
It 18 isn't best, better or.anything e,lse.
19 A
I think I have given you my best 20 recollection.
My best recollection was that
(
21 my best recollection was that I didn't think it 22 was necessary to do this and I also believe, if a
23 you will recall my earlier answers, I think I also V-24 said I had no qualms doing it in the context of 25 everything that was going on.
I Womack 44 gg V
2 Excuse me.,
I believe to be 3
complete, I said I didn't think it was necessary 4
for safety to do this, to make the change.
5 Q
Does that mean that you were 6
unconcerned about the frequency with which the 7
PORV would be challenged,to use your word, if the 8
set points were unchanged?
9 A
No, it does not mean that.
10 Q
Notwithstanding your c'oncern over 11 the frequency of challenge to the PORV, you would
[\\
12 have felt it was satisfactory to leave the s e't
%.)
13 points unchanged, is that right?
14 A
I believe it was not necessary for safety 15 to change the set points.
16 Q
Your answer is implying to me that 17 you think there were other reasons that were good 18 and valid reasons for changing the set points, is 19 that correct?
20 A
Yes.
(,
21 Q
What were those reasons?
probably the principal reason 22 A
Which was n
in importance was the NRC's wishes in this regard.
O N~
24 Q
What, if any, other reasons did you 25 have?
(S 1
Womack 45 4
\\m/
2 A
Certainly as an 1,nterim step to reduce 3
PORV actuation frequency since such actuations 4
in light of the TMI accident were a source of 5
concern for the NRC and for others.
6 Q
Are you presently aware of any 7
consideration within B&W prior to the Three Mile 8
Island accident to change the pilot operator 9
relief valve set points?
t 10 A
To invert them as was done a5ter the 11 accident?
Is that the question?
Is that the (n%,]'
12 sense of your question?
13 Q
Let me make the recor'd clear.
14 I am referring to changing the set 15 points so that the reactor would be tripped before 16 the PORV would be challenged.
17 A
No, I am not.
18 Q
Is it your testimony that you are 19 not aware of any discussions regarding changing 20 the set points in that manner between the time
(_
21 of the Davis-Besse September 1977 transient 22 and the Three Mile Island accident?
23 A
No, I am not.
%)
24 Q
Is it correct that following the 25 Three Mile Island accident, the Plant Design
(-
1 Womack 46 O) 2 engineers learned of for, the first time several 3
instances in which the pilot operator relief 4
valves in plants had failed to function as 5
designed to function?
6 MR. FISKE:
Wait a minute, 7
Mr. Seltzer.
I think you have a lot of 8
different concepts in one question.
9 First of.all, is the question v
10 addressed to what Mr. Womack himself 11 learned or are you asking him about his
()
12 entire division or what?
-13 MR. SELTZER:
I am asking him as 14 the Manager of his division whether he 15 believes that his division learned for the 16 first time after the accident.
17 MR. FISKE:
Well, I will object to 18 your question as to what he believes.
19 Other people in his division may or may 20 not have learned.
21 If you want to ask him what he 22 learned after the accident, fine, but I am going to object to it if you 23 just O
24 Put it on the other basis.
1 25 MR. SELTZER:
On what grounds?
g.,.y
..,.,,,n._,,eg.
..n.
,c-..,
--.,.-,,,,,-o,_,7-,
-..,.-,,,-..-_n.
1 Womack il 7 47 2
Hearsay?
3 MR. FISKE:
His belief as to what I don't think his belief 4
other people
(,
5 is relevant to this case.
6 MR. SELTZER:
This is a discovery 7
deposition and I believe these questions 8
may lead to the discovery of admissible.
9
- evidence, t
10 If somebody told him, d1d somebody 11 tell him that they had learned for the
(
)
12 first time afterwards, I might take thht I
13 other person's deposition so'I press the 14 question.
15 MR. FISKE:
Well, let's hear the 16 question again.
l 17 MR. SELTZER:
I will restate it just 18 to save time.
19 BY MR. SELTZER:
20 Q
Isn't it a fact that after the
(.
21 Three Mile Island accident, to the best of your 1
22 knowledge, engineers in the Plant Design Group 23 learned for the first time of instances when O
I
[
24 pilot operator relief valves had failed to 25 function as designed?
1
. ~.
/~h 1
Womack 48 b
2 MR. FISKE:,Again another problem I i
3 have with this question is that if you are 4
asking him whether there were incidents C/
5 of prior failures of the pilot operator G
relief valve that came to the attention of 7
B&W for the first time after the accident, 8
I won't object to that question, but when 9
a particular individual engineer learned 10 about something that some other engineer 4
11 may have known about all along really 12 does seem to be a little irrelevant.
13 You are asking about composite B&W 14 knowledge, is that correct?
15 MR. SELTZER:
I will take' that as a 16 start.
17 THE WITNESS:
Could you please repeat 18 the question as asked by Mr. Fiske.
19 MR. FISKE:
And you are talking 20 about failures in B&W reactors?
21 MR. SELTZER:
All right, I will start 22 there.
That's a good starting place.
(~}
23 MR. FISKE:
Well, I do think we have C/
24 to have some --
25 MR. SELTZER:
Let me see if I can
1 Womack 49
{')'N 2
capture what you have just helped us specify.
3 BY MR. SELTZER:
e 4
Q Doctor Womack, are you aware that 5
after the Three Mile Isl.and accident B&W as a 6
collective entity learned for the first time of 7
certain failures of the PORV to function as it was 8
designed on B&W plants?
9 A
Yes, I believe so, t-10 Q
When you say yes, you believe so, 11 have you discussed within B&W the fact that there l
)
12 was new information about failures of pilot 13 operator relief valves that came to B&W since 14 the Three Mile Island accident?
15 MR. SELTZER:
Can you let the record 16 reflect that there is a discussion between-17 counsel and the witness.
18 MR. FISKE:
Yes,.in order,to clarify 19 the preceding question.
20 MR. SELTZER:
You can ask me if you
/
b 21 have any problems about understanding the w
22 question.
23 MR. FISKE:
I want to make sure Mr.
-q 24 Womack. understands it.
25 Q
Do you understand the question?
nn
~
1 i
4 1
Womack~
50 2
THE WITNESS:
Please repeat the 3
question.
4 (Record read.)
5 A
Yes, I believe such discussior.s have taken l
6 P ace.
7 Q
With whom have you had such 8 l discussions?
I 9
A That is difficult for ne to recall.
I i
10 believe that Mr. Kosiba would have b'een among 11 the people with whom I discussed it.
12 Q
Kosiba is.in what section or was,*in 13 what section?
14 A
Kosiba is the Manager of the Service 15 Department.
4 16 Q
With whom, if anyone else, do you i
?
17 believe you had such a discussion?
18 A
Probably with --
19 MR. FISKE:
I will object unless he.
20 recalls it, Mr. Seltzer.
(-
MR. SELTZER:
That's all I asked him.
21 22 Q
With whom, if anyone else, do you 23 recall having such discussion?
\\.
MR. FISKE:
You asked him who did he d
24 25 believe he had a discussion with.
i
(-
I Womack 51 V}-
2 A
Mr. Taylor.
3 Q
With whom, if anyone else, did you have
(
_ discussion about new information coming into B&W 4
- 5 since the Three Mile Island accident regarding.
6 PORV failures having occurred?
7 A
I can't recall other specific people.
8 Q
Do you believe you had such i
9 discussions with other people?
v l
10 MR. FISKE:
I am going to object to i
- 11 that, Mr. Seltzer, unless you ask him what 12 he recalls.
If his belief is based o( a 13 recollection, I have no problem with the 14 question.
15 Q
Let me make it very clear on the 16 record when I asked for your beliefs, I am not 17 asking for fantasies or dreams that y,ou have had 18 at night, I am asking for what you in,your brain 19 believe occurred.
20 MR. FISKE:
Based on a recollection.
21 MR. SELTZER:
Obviously.
22 A
Your question is focusing on new information 23 and I'm trying to single out that area of focus
{'}
V 24 and I am having some difficulty recalling events 25 which took place many, many months ago.
4
~._.g.
.._.,...._---~..-....--.,m.
. - -, - - ~., -, _ _..
...,.-.<_-,.-_,~,_._,w,__..,
a i
Womack 52 2
Let me just,say this..
It would be 3
normal for me to discuss such questions with Dr.
4 Roy, perhaps with Mr. Karrasch, and those are the i
5 names that come to mind.. 'That does not constitute 6
testimony of assurance that I talked to those 7
people.
8 Q
I understand that.
You testified 4
9 earlier regarding what your recommendation would n
10 be for whether the PORV set points should have 11 been changed following the Three Mile Island 12 accident, right?
13 A
We discussed that, yes.
14 (Continued on following page.)
f 15 16 17 18 I
19 20 21 22 24 25 i
.,.-----..._._.,___,__._..,,._._.._,.-m,,_..
m I
Womack 53 N')
2 Q
And you have already testified what 3
your position is on that.
What I want to ask 4
you now ic I was asking you to go back in time 5
to some discrete period just after the accident l
6 and I was asking whether in light of the accident 7
you thought the set points should be changed and 8
you gave me an opinion.
9 Were you includi'ng in that opinion t
10 your knowledge that you possess now of the various 11 instances in which the PORV on B&W's plants had 12 failed to function as designed?
13 A
Probably.
Your question was pretty 14 hypothetical, so it's very difficult, as I said 15 earlier for me to factor everything out.
16 Q
The record that has been compiled 17 by the NRC special inquiry and the President's 18 Commission on Three Mile Island has shown that 19 there were approximately -- and correct me if I-ten instances in which pilot 20 am wrong, please 21 operator relief valves had failed to function as 22 designed on nuclear plants, isn't that correct?
/~
23 A
I believe that there were approximately b}
24 nine instances on B&W plants.
I cannot speak
.25 for plants of other manufacturers.
-)
1 Womack 54 V
2 g
Is it your engineering judgment that notwithstanding those nine failures of a pilot 3
4 operator relief valve to function as designed 5
on a B&W plant you still.were of the opinion e
that it would have been entirely appropriate to 7
leave the pilot operator relief valve set. points i
8 where they were prior to the accident?
9 MR. FISKE:
Mr. Seltzer, I am not sure t
10 that you have demonstrated on this record 11 that at the time the decision was.made at I )
12 B&W to do whatever they did with respect to v
~
13 the set points, all of the information that 14 you have just been describing had-been 15 developed.
16 MR. SELTZER:
Well, now, I am -- I was 17 aware of that, Bob, that's why I am now 18 shifting the question.and asking_him.
19 MR. FISKE:
Then I think it is more.
20 hypothetical.
You are asking him when
(_ '
they made a decision he took action and he 21 22 has given you the reasons why they did it 23 and I think you are entitled to that, and 4.)
24 you have that.
25 Now you are asking him what would he
~~
2 1.,
1 SWomack 55 2
have done if he knew about four other 3
things that he didn't know about.
I 4
think that's completely speculative and 5
hypothe.tical.
6 MR. SELTZER:
Let me ask him if he 7
has an opinion. If he wants to tell me he has none,'thenf t's hypothetical-and i
8 9
speculative.
Let me just state it and I 10 will let you respond, Bob.
11 I think his state of mind is a fact 12 and I am entitled-to inquire about facts.
13 MR. FIS'KE:
And you have done that, s
14 His state of mind at the time'they made 15 that decision.
He has testified about that.
16 But you are now asking him a hypothetical 17 question which builds into it 18 information which at least hasn.'t been 19 demonstrated that he had at the time that.
the decision was made'.4 20
(
I think that's completely hypothetical.
21 22 syou can ask him what would his opinion be N
23 if there were fifteen failures instead of
~
w/
24 nine.
I think you have gotten all you are entitled to.
25 s
- W
i w
1 Womack 56 i
\\j ]1 2
MR. SELTZER I don't want to make s
\\
l it any worse for B&W PORV's than it already-
\\'
3 is.
I think nine may be the correct numbyr.
4
(
MR. rISxE:
Well, anyway we object' 3
to the question.
,/
6
?
BY MR. SELTZER:
7 y.
8 Q
Adopting your counsel's suggestion, y,
at the time the recommendation was made to change
[,
g t
10 set points, were you aware of all nine prior.' 1, gg instances when a pilot operator relief valve or4
,, s
, 1 J i 12 a B&W plant had failed to operate as designe,d?
4 F
f MR. FISKE:
I don't kno~w that I made
'a g3 that suggestion.
g4
- 1. '
.1 A.
At this time I don't know whether I wss
,f' 15 aware rn t.
16 Q
In your judgment at that time did the g7 18 frequency of failure of pilot operator _ relief valves in any way enter into your analysis of j\\ /
gg t
whether the set points should be changed?
[..f
(
A You are suggesting by the question, Mr.
seltzer, that there was an analysis at that time done independently I am tracking from your 7s 23 (Continued on following page.)
24 25
.n. -
W
3 r>
13 ). M y e b, "
y 1
/
9
(.,
' fl b'
, h t*
, s s
Ii e'
Womack 57 i q,\\,
f
/
/,
k f.
y#
]
C fr tf, g' previo'us questions, independently of othrer
.-s
/'4 envircr$r ent al factors,shich.--iand then asking
[.p
- 3 s
2 ;
'-f.
J4
. ?'. questions.about that a n al y s :'.'s i, I. don't recall a
'~
T, I hope I,
having done such analysir'and it's s-3 T
,t
.i e
f' r saying this, but it is e
6 you will for+(lveme o
\\j a
../
7
/
rather difficult fo; ra to reconstruct what such
~.
s
+
y s
8 analysis might have been in my mind.
So I am s
.-, 1 y
(
9 hat.Eng some trouble answering your questions.
/
's' 5
u c'
10
'4 R. PISKE:
I think what this comes
(,9
(,,
-9 11.
.down to, Mr. Seltzer, so hopefully we can g,
12
</
reo v e on to something, I think he said,that
.,,) '
13 the URC had a strong position on it, that
/
e 14 Mr. Womack had no qualms about following
't
!5 the NRC position and they went-ahead j;
/-
~'
16 and did it.
It seems to me that explains i
17 what happened.
18 MR. SELTZER:
It's also Mr_.
Womack's 4
19 testimony that he believes that if the
\\r P
4
/
20 NRC had not been pressing to have the set y
21 points changed he would have been
.xl
~
t/
22 satisfied with leaving them unchanged just ll
'N 23 looking at considerations of safety and Q)'
- 24 operation of the equipment.
+
25 MR. FISKE, which we have all noted 4
..w
~
t
-3,--
ge-t y-
I Womack 58 2
is a rather hypothetical situation since 3
the NRC was taking the position that it was x
4 taking.
{e i
5 MR. SELTZER.
I don't mean to engage 6
in colloquy with you, Mr. Fiske, because 7
I can talk to you off the record without it costing GPU or Babcock & Wilcox money 8 l l
9 any time.
(
10 I really want to explore' this witness' 11 thinking and I want to explore the answer
_ (
12 that he gave that I just paraphrased.
13 BY MR. SELTZER:
14 Q
When you testified that you believed it 15 would have been a safe and acceptable means of 16 continuing to operate these plants without changing 17 the set points, were you taking into account the 18 nine failures of those pilot. operator relief valves 19 to function as designed?
20 MR. FISKE:
Mr. Seltzer, he just told k-you he doesn't recall whether he knew about 21 22 all nine at the time he made that decision.
f"N 23 He just gave that answer a few minutes ago, t
24 Q
Do you adopt your counsel's 25 characterization of your testimony?
,.,e-e n.
g
-;m,-,----m.-
/~3 1
Womack 59 D
2 A
Yes, I understood,that I had answered that 3
question.
4 MR. FISKE-It's not a characterization, 5
it's a statement of what it was.
6 Q
In~ making the judgment that it would 7
have been safe and acceptable to operate the 8 l plants without changing the set points, was any 9
component of your thinking before you gave that 10 answer your knowledge of the frequen'cy with which 11 PORV's failed to function as designed?
O)
(_
12 A
well,.certainly the failure or the app,drent 13 failure at TMI-2 was a component in the thinking.
14 Mr. Seltzer, I believe that the reactor system is 15 designed safely to tolerate such failures, it 16 was and is so designed and it is primarily based on 17 that understanding that I gave you the answer that 18 I gave.
10 In the atmosphere immediately following 20 the events of March 28th at TMI it's very
(-
21 difficult for me to recall, you know, every 22 element of my thinking.
/~')
23 Certainly, we at B&W and I
(_/
24 particularly wanted to take any step which could 25 assist our customers in avoiding any problem
-(~N 1
Womack 60 3 l that they might have eit,her -- specially any i
safety problem or any problem with regard to 3
4 their licensing or relationships with the NRC 5
and an awareness that all'of us wished to avoid 6
any PORV open failures was very much in my mind 7
and, however, whatever else is said I certainly 8
cooperated and assisted in the resetting of the 9
set points after the accident, that cooperation l
l' 10 {
is inextricable in my mind from discussions which 11 took place with the NRC senior staff in.which I 12 was personally involved and in which they wete 13 very insistent in their views and a's I have 14 testified to you earlier to separate all those 15 factors now is very tough for me.
16 Q
When you say that the B&W plants were 17 designed to tolerate such failures of.the pilot 18 operator relief valve, does that mean,that it was 19 a matter of no concern to you that the pilot 20 operator relief valves were failing with the k-frequency that they were?
21 22 A
No.
r 23 Q
Why was it of concern to you that they
"*** f*111"9 --
24 MR. FISKE:
Well --
25 -
_ -. _ - _ - - -. -. - ~
i i
l 4
)
1
~Womack 61 3
i 3
Q
-- with the, frequency that they
[.
3 were?
4 MR. FISKE:
At what point in time are i
l 5:
you talking, Mr. Seltzer?
6 MR. SELTZER:
At the point in time i
e a
7 when he first became aware that it failed 4
8 nine times.
E MR. FISKE:
Well, I am going to object 9
10 to that because I think it's 1 ready been established or at least it has not been 11
(
12 established to the contrary that this,*
j
_ discussion th'at went on with'the NRC leading 13 k
14 to the changes in the set points has not 4
been eetablished that at the time that i
15 16 discussion went on and that decision was 17 made Mr. Womack was aware of nine failures.
18 So --
19 MR. SELTZER:
My question was not i
as I just focusing on this period of time i
20 4
k; clarified it before you made your statement, 21 I
my question now is premised on the point 22 i-in time when he first became aware that l
23 i
there had been nine failures of the PORV i
24 l
function as designed.
2.5 l
1 Womack 62 2
MR. FISKE:
,I am not sure this is 3
relevant to this, Mr. Seltzer.
You are 4 i talking about something after the accident 5
and I don't see what his reaction to that was 6
at that time has to do with this case.
7 MR. SELTZER:
I don't want to be 8
intemperate in the first hours of the first 9
depositions in this case, but I think the 1
10 kind of intrusions that you are making 11 into the record every time we get.close to 12 something that's an important subject is 13 going to interfere very seriously with our 14 taking the type of discovery we think is 15 necessary to prosecute this case.
16 The PORV, the pilot operator relief 17 valve, is probably the single most important i
18 piece of equipment inv.olved in t,he 19 accident that happened at Three Mile Island 20 and I am going to explore,until I can't 21 think of another question, every aspect 22 of pilot operator relief valve failure and gs 23 I am going to explore it in ways that I 24 think are relevant and reasonably calculated 2.5 to lead to the discovery of admissible
Womack 63 1
f evidence, and I wish, without being 3
i l
ungentlemanly in the least, Mr. Fiske, if 3
I l
you could just state your objections, we 4
can proceed.
5 MR. FISKE:
Sure.
My objection is 6
really pretty simple, that if the fact is 7
8 that he learned about the fact that there g i had been nine failures of PORV's at some t
point six months after the accident occurred, 10 i i
11 at a time when the action had already been 12 taken by B&W to change the set points in compliance with what they understood the 13 NRC wanted, I really don't see what the 14 significance or the relevance is of Mr.
15 Womack's reaction to that at that point.
16 17 MR. SELTZER:
At whatever point he 18 had a reaction he was a respons:7J1e manager 19 for B&W, a manager whose scope of 20 responsibility included the operation of
(-
the pilot operator relief valve and, 21 22 therefore, I press him for his recollection.
MR. FISKE:
Let's hear the question r-)N '
23
\\.
again.
Maybe we can move on.
24 MR. SELTZER:
All right.
25
~
~
1 Womack 64 2
g You said in, response to my last 3
question that the fact that the pilot operator 4
relief valves had failed to function nine times 5
on B&W plants was a matter of concern to you.
6 My question was:
Why was the failure 7
of those valves to function nine times of concern 8
to you?
9 A
I believe you have restated the question s.
10 in a sense opposite the way you asked it. I believe 11 you asked --
()
,12 Q
Just answer if you could, please,, what 13 I just posed.
14 A
The failure to function of any piece of 15 equipment on B&W plant would be a matter of interest 16 or concern to me in the sense that I wished to 17 have each of those plants behave and perform 18 with the highest possible availability,and 19 safety.
20 Certainly a pilot operator relief
(.
21 valve failure would lead to some loss of time on 22 the part of our customer.and he in turn would 23 think less of his plant and I would like to 24 have him as a general rule feel that his plant 25 was excellent in all aspects.
i
. -, _. ~, - -.,, - -.,. _ _,,. _., _ - -
-rs 1
Womack 65 2
Q Is there any other reason specific l
3 l to the location or function of the pilot operator 4
relief valve that gave you concern when you first 5
learned that that valve had failed nine times?
G A
Well, the valve is at the primary system 7
boundary and that makes it more important, for 8
example, than a component cooling -- than a 9
valve in another system perhaps, t
10 Q
What were those last two words, "in 11 perhaps"?
i (m) 12 A
A valve in another less important syst.e'm.
i 13 Q
When you say that the pilot operator 14 relief valve is at the primary system boundary, 15 that is the same as saying that a failure of that 16 valve in the open position can lead to a loss of 17 coolant accident?
18 A
A failure of that valve in the open 19 position leads to a loss of primary coolant, yes.
20 Q
Just e it's very clear to somebody k*
21 reading this record, why is that more important 22 than a valve failing in some other part of the 3
23 plant?
\\_
i 24 A
Because the primary coolant is the coolant 25 which removes heat from the reactor's nuclear
l
<^
l Womack 66 2
core.
1 3 l Q
It's a fact, is it not, that maintaining i
4 proper core coolant is one of the highest priorities 5
in the operation of a nuclear plant?
6 A
It is a fact that maintaining coolant, 7
proper core coolant, is a very high priority in 8
the design of a nuclear plant.
9 Q
I think that's helpful but I asked i.
10 isn't it a fact that maintaining proper core j
11 cooling is a very high priority in the operation
/~N 12 of a nuclear plant?
(}
13 A
I didn't answer that question, because I am 14 not an expert in nuclear power plant operations, 15 B&W doesn't operate nuclear power plants, and 16 while -- and that's the reason I didn't answer 17 the question the way you asked.
18 Q
Isn't it a fact.that the sole purpose 19 for which B&W designs nuclear. power plants is 20 for operation of nuclear power plants?
21 A
Yes.
22 Q
Well, taking it then that logical 23 step that we have just gone, wouldn't you agree 24 that in designing a nuclear power plant for 25 operation it's a very high priority that in the
(w I
Womack 67 3
operation of the plant there always be adequate 3
cooling water to keep the core cool?
4 A
I believe that that should be a high 5
priority in the operation of a plant, yes, sir, i
6 Q
And you also believe that that's a 7
high priority in the manner in which B&W designs 8 l nuclear plants for operation, isn't that 9
right?
t 10 A
- Yes, THE WITNESS:
Could I have,a bathroom gg
()
lo break?
~
\\_
13 MR, SELTZER:
Sure.
[4 (Recess.)
15 BY MR. SELTZER:
16 Q
Is GPU Exhibit 1 for identification 17 accurate for the period of time which.it covers?
18 A
It's accurate up to about the beginning of 10 1980.
20 Q
O.K.
Is MIT the only place where you
(.
21 g t formal schoo'.ag after high school?
22 A
Other than correspondence programs, short 23 programs, yes.
V 24 Q
Your resume, GPU Exhibit 1,
indicates 25 that your area of study at MIT was physics.
1 1
1 Womack 68 1
2 i Did you have any areas of principal 3
concentration within the subject area of physics?
l A
Yes.
4 3
5 Q
what was that?
6 A
Cosmic physics.
Astrophysics, experimental 7
cosmic ray physics.
8 Q
What does that mean?
9 A
It is generally the study of electromagnetic t
10 and particle radiation from outside the Earth's 11 atmosphere and its interaction with the Earth's
/~N
()
12 atmosphere.
13 Q
so it's extraterrestial' sources of 14 radiation as opposed to radiation generated by 15 nuclear sources on the Earth?
16 A
Yes.
17 Q
while you were at MIT getting your 18 undergraduate degree and graduate degr.ees, did you l9 take any courses' involving nuclear power 20 generation?
21' A
No.
22 Q
Did you have any training at MIT in 23 any of the systems theory or systems analysis
~
24 involved in design of a nuclear plant?
23 A
In the fundamental' principles, yes.
In the
1 Womack 69 i
)
l applied systems design,. physically to nuclear 2
l 3 i plants, no.
I 4
Q Does MIT have courses that would i
5 relate directly to the applied physics of nuclear G
plants?
7 A
Yes.
8 Q
Is there a name to their program?
I 9 l A
It's called the Department of Nuclear i
10 Engineering.
11 Q
Did you take any courses in the MIT b) 12 Department of Nuclear Engineering?
(_j 13 A
No.
14 Q
Did any of the unit managers who 15 reported to you when you were the manager of 16 Plant Design graduate from that particular school 17 at MIT or program at MIT?
18 A
I don't believe so.
19 Q
Did you write a PhD thesis at MIT?
20 A
Yes.
21 Q
What was the subject of it?
the subject was X-rays from the 22 A
It was 23 Crab Nebula and from the Sun.
24 Q
When you were pursuing your PhD 25 degree at MIT, what application were you intending 2.
4 4
1 Womack 70 2
to make of your extraterrestial physics training 3
at MIT?
4 A
I intended to continue in basic research C
5 in cosmic physics.
2 6
Q Since graduating from MIT, have you 7
done any basic research in cosmic physics?
8 A
No.
9 Q
What was your first job after I
n I
10 receiving your doctorate degree from MIT7 11 A
As a Naval Reserve officer I was ordered to 1
(~N
' (,)
12 the United States Atomic Energy Commission.
i l
13 Q
What office or location of the AEC 14 were you ordered to?
15 A
The Division of Reactor Development and 16 Technology.
17 (Continued on following page.)
18 19 20 21 22 23 24 e
i 25 r
~
.9---e
..,1.,--,
m.,,
,-7+
c.
,,_,-,,_r_,----3
-,,-_r
,-,,n,,.,wr-m,7
,7
-_yw
_r-c-----p-oe-w.--,,.
.ww-
t r's 1
Womack 71
(}
2 Q
Where was that lo ca te d?
3 A
Germantown, Maryland.
4 Q
What were your principal responsibilities
{
5 in that division?
6 A
I was given program responsibilities related 7
to management of sponsored development in nuclear 0
reactor design, especially related to instrumentation 9
and control systems for sponsored programs of the i
10 Atomic Energy Commission, primarily programs related 11 to the liquid metal fast breeder reactor *.
ex
_)
12 Q
Other than the liquid metal fast. breeder
.p ro gram, what other programs were you working on?
13 14 A
At that time?
15 Q
Yes.
16 A
There may have been some very small programs 17 of general application to the reactor industry or 18 of experimental tesc application, but the great 19 bulk of my work was in the liquid metal fast breeder.
20 Q
Could you describe the areas that you 21 have adverted to other than the liquid metal fast 22 breeder program?
You said there were other areas 23 even though LMFB was your principal focus.
What
["')T 1
24 the other areas where you did work on nuclear were 25 reactor design and particularly on instrumentation m
1
[^)
1 Womack 72 kJ 2
and control systems?
3 A
I recall some participation, perhaps more 4
consultative than management, in development of, 5
as I said, generally applicable instrumentation 6
such as wide-range neutron detection systems, 7
high-temperature thermocouples, these kinds of 8
items, although even they were primarily intended 9
for liquid metal fast breeder tests or liquid metal e
10 reactor application; presumably could'have f.ou nd 11 application in other systems.
(ex) 12 Q
What other types of instrumentation 13 and control systems did you work on' that svuld 14 have applicability beyond the liquid metal fast 15 breeder program?
16 A
well, in the most general sense, perhaps, a
~
17 significant amount of the instrumentation on which '
18 I worked in liquid metal fast breeders could also 19 be applied to other reactors.
We were not making 20 such applications or I was not making such
('
21 applications.
There are particular and specific 22 r~s 23 instrumentation and control requirements for liquid k
24 metal reactors and these, o f course, received 25 attention.
y y
ya.e;e..
-.e-r.--
T'i
+
9 m
D 1
Womack 73
[d 2
Q Where, if anywhere, are there liquid 3
metal fast breeder reactors currently in operation?
3 4
A Well, there is a liquid metal reactor which 5
is probably in operation at the Idaho National 6
Reactor Testing Station called FVR-2.
There is a 7
liquid metal reactor in the early stages of 8
operation called the Fast Flux Test Facility in j
9 Hanford, Wa shing to n.
(
10
, At this point in time, other liquid 11 metal reactors in the United States have.either 12 been shut down or not completed.
There are liquid 13 metal reactors in operation or in startup in 14 France, in England, and presumably in the Soviet 15 Union.
16 Q
Do liquid metal reactors have better 17 heat transfer properties than water reactors?
very subjective word.,
Liquid 18 A
Better is a 19 metal has a higher coefficient of heat transfer 20 from fuel to coolent, in general, than water and, (s
21 further, since it does not boil at low temperatures 22 it can transfer heat at higher temperatures under
(~)
23 atmospheric pressure.
V 24 Q
Are there relief valves on the designs 2d for liquid metal f ast breeder reactors that you i
/"
1 Womack 74 b]
2 were working on?
3 A
There is no valve which is the equivalent of 4
the pilot operated relief valve since the systems 5
are not pressurized.
There are, however, 6
undoubtedly, some relief valves since. code 7
requirements require safeties, and on the secondary 8
steam systems, of course, they are similar in 9
almost all aspects,
- u. -
10 Q
On the primary side, do I understand 11 you correct to be saying that there are, valves 12 that are analogous to the code safety valves on a 13 PWR?
14 A
I believe so, yes.
But you will note that the 15 systems are not pressurized and such valves, I think, 16 would be quite different.
17 Q
In working on instrumentation and 18 control systems for plants other than the liquid 19 metal fast breeder, did you do any work in the 20 Division of Reactor Development and Technology 21 regarding control valves or relief valves?
22 A
No, I don't recall any work.
23 Q
Did you have contact during the years d
24 j
1969 through 1973 with the vendors of pressurized V
I water reactors in the United S ta tes ?
25 o
4-
.--.,e
4 4
1 Womack 75
(
l 2
.A Yes.
3 Q
Did you have contact with an outfit that 4
operates out of Lynchburg, Virginia?
i
{
5 A
I don't recall.
I don't think so.
4 6
Q At any time during your tenure with the 7
AEC, did you have contact with people from B&W?
8 A
I don't recall such contacts, no, sir.
J 9
Q With what, if any other, manufacturers e
10 of pressurized water reactors did you have contact 11 while you were with the AEC?
12 A
Westinghouse, General Electric.
~
13 Q
I thought GE only made boiling water 14 reactors.
15 A
I'm sorry, sir, I misstated myself.
You 16 asked pressurized water reactors and,you asked water i
17 reactors.
Please forgive me.
You are. correct.
18 strike General Electric.
19 B&W and Combustion Engineering would be l
20 the other two vendo rs, and I don't recall having l
21 any contact with them.
If I did, it certainly was 22 not significant.
B&W and Combustion Engineering
'N Zl were at the very early stages involved in the l [&
24 liquid metal programs, but not in an area in which i
a 25 I had contact.
--y-
{
1 Womack 76 2
Q With regard to any of the work that 3
you did on systems that were not related 4
specifically or just to the liquid metal program, 5
did you have contact with any of the vendors of 6
PWR Equipment?
4 7
A I don't recall any such contact.
8 I am still restricting my answers 9
to the period before 1973.
Is that your intention?
i.,
10 Q
No, no.
I broadened it about five 11 questions back, during your entire tenure with the 12 AEC.
13 A
Well, I don't believe it changes any of the 14 answers, but in 1973 I broadened my scope of 15 contacts to include the General Atomic Company 16 which does not manufacture pressure water reactors 17 but does manufacture or was at that time 18 manufacturing reactors of a different sort, 19 helium-cooled reactors.
And in case I have answered 20 any question to which that would be appropriate, I 21 would like to put that in the record.
22 Q
In 1973 your resume indicates that
(~h 23 you became chief of the Control and Electrical ig 24 Systems Branch of the Atomic Energy Commission.
Is 25 that a position that you assumed in 19737
(N 1
Womack 77
^
\\_
2 A
Yes.
3 Q
What were your principal 4
responsibilities in that position?
5 A
Technical review and management of protection, 6
control and electrical system design for liquid 7
metal fast breeder reactor projects.
8 Q
Did you do any work in connection with 1
9 control room design?
10 A
Yes.
11 Q
Could you explain what that was?
)
12 A
At the time of my tenure in the Control,'and 13 Electrical Systems Branch, the control room design 14 for.the Fast Flux Test Facility was being prepared 15 by. the Wes tinghouse Electric Corporation under 16 co n tra c t, and I was responsible for the management 17 and approval of that design.
18 Q
Did you review the designs,of other 19 nuclear plant control rooms in the process of 20 deciding whether the design for the Fast Flux 21 Facility was adequate?
22 A
Yes, I did.
And you have called to mind that s
23 during the course of that time, at one point I made 24 a trip to Lynchburg, Virginia to see the Babcock &
25 Wilcox simulator.
--.r-
,,c-,
r
,,-,-y--.
,,--,,-m-_,y_,_,3,,, - - - -
m,,
,,y,,,,ww.
r,r,w.-r-----
1 Womack 78
)
2 Q
So your prior tes timony about not 3
recalling any contact with B&W while you were with 3
4 the AEC now stands corrected?
l 5
A My prior testimony is correct.
I now recall 6
an instant in which I did, in fact, have contact 7
with B&W.
At the time I mentioned it, I did not 8
recall that.
9 Q
Why did you go to take a look at their t-10 simulator?
11 A
Well, because there were two reasons.
One O(_)
12 was because I was interested in seeing repres.ontative 13 control rooms of re a cto rs, and I presumed this to be 14 one. iAlso because we were considering a simulator 15 for the FFTF and I was interested in seeing a 16 simulator.
17 Q
Do you recall who at B&W explained the 18 operation of the B&W simulator to you?..
19 A
The name has slipped my mind.
I do recall 20 very clearly the gentleman.
He has since retired.
21 His name has slipped my mind.
22 Q
What else did you do, if anything, to
/~T 23 survey the state of the art in control room design --
i U
24 MR. FIS KE :
Well at the time you were working on the 25 Q
I' 1
Womack 79 b')
2 design of a control room for the fast flux machine?
3 MR. FISKE:
I just want to be sure that 4
Mr. Womack agrees that surveying the state of 5
the art of control room design was, in fact, 6
what he was doing.
7 Q
Is that a fair characterization of what 8
you were doing?
9 A
I think it is a generous characterization v
that might imply more than I actually had the 10 to 11 time or was able to do.
I did try to educate myself 12 on what others had done to a limited degree.
I was 13 a reviewer of the design as opposed to having the 14 prime design responsibility which, of course, was 15 subcontracted, but I did try to inform myself to 16 some extent.
17 To answer your question, what else did 18 I do, I believe at that time I had also seen the 19 EBR-2 control room.
I believe at that timo I had 20 also seen the control room at the Unit 1 plant of 21 the Fermi r eac to r, the liquid metal plant that has 22 since been decommissioned on the Detroit Edison
(~h 23 system, and in addition to some probably --
V 24 probably some general reading, that's all I recall.
25 Q
You testified that you were responsible v.
t womack 80 O
2 for reviewing the design,for the control room for 3
the fast flux machine, is that right?
4 A
Yes.
5 Q
Did you make any recommendations that 6
that control room ought to be simplified to take 7
into account human engineering factors?
8 A
well, I made recommendations that the control 9
room should be changed in a way -which I believed a
10 simplified it.
Whether I used the term " human 11 engineering factors" or whether that discipline had
()
12 the currency it now has, I don't remember.
13 (continued on next page) 14 15 16 17 18 19 20 21 22 C) 24 25 t
s' 1
I Womack 81 2
Q I was just using it as a shorthand 3
to refer to something.
4 A
I understand.
I 5
MR. FISKE:
I guess he did say he G
made recommendations to simplify it.
7 Q
In what ways were you recommending 8
that the control room be simplified?
9 A
Well, in the organization of the presentation t-10 of the plant conditions on the panels and in the 11 my primary recommendations had to do with the 12 locations of the panels.
13 Q
And principally what was your 14 recommendation regarding the location of panels?
15 A~
Simply that the bench panel configuration 16 which as I believe,as what was originally 17 proposed to be rather a deep U-shape.be opened 18 up to allow more access and freer access to the 19 controls, and there were probably additional --
20 my recollection is, without specification, which 21 I am unable to supply at this point in time, that 22 there were additional recommendations regarding 23 the displays and their organization.
A 24 Q
Did you make any recommendation that 25 there should be fewer display panels?
()
I Womack 82 2
A No, I don't believe I made such a 3
recommendation.
{
4 Q
Did you make any recommendation that 5
the whole control room scene ought to be more 6
, compact?
7 A
No, I don't believe I made such a 8
recommendation.
9 Q
Did anybody who was responsible for 10 designing that control room think that it ought 11 to look more like the cockpit of an airplane than 12 a room full of dials and --
13 A
I can't testify to that.
14 MR. FISKE:
Yes, that's a pretty j
15 difficult question to -- particularly as 16 you phrased it to answer.
I mean, if 17 you want me to tick off the separate 18 respects in which we have a problem, I would 19 be glad to, but maybe it would be easier 20 to start again.
21 Q
Did anybody that you recall talking 22 to about the design of that control room 23 recommend that the control room be much more j
24 compactly designed?
25 MR. FISKE:
I am sorry, just while you
,s
,--_y-
...-_-.y,
(~~'N I
Womack
~
83
(,)
s 2
are doing that, can I' hear that question 3
again, please?
4 (Question read by the reporter.)
C' 5
A There were a' diversity of opinions expressed 6
in those who had looked at that de x.L ns and I 2
7 believe that I can recall at least one person
~..
8 advocating a more compact design.
I don't recall 9
the advocacy of an airplant ccckpit's simile.
I l
1 10 Q
Do you recall who the individual was 11 who 3
\\-)
12 A
I recall the individual and I'as>naving i
13 difficulty with the name.
14 Q
Is that all you can't recall about 15 it?
What do you mean, you can recall'the 16 individual but not his name?
17 A
I know who he was and where he was.
18 Q
I see.
19 A
Probably I can resurrect the name.
20 Q
Was he someone superior to you?
21 A
I don't remember our relationships.
We 22 were in different organizations.
This particular Ih 23 gentleman who comes to my mind in connection with
(_)
24 your question was a member of the field of fice 25 staff at Hanford.
He may have been working for
1 Womack 84 2
Westinghouse or he may have been working for the 3
AEC, that I don't remember, but in any case, he 4
was physically located at Hanford.
5 Q
What does it mean to.be in charge of 6
Protection system design?
What is a protection 7
system?
8 A
In the case of the liquid metal fast 9
breeder reactor,.it is that system which performs e
10 the function of detecting and shutting down the 11 nuclear power generation in order to avoid
()
12 violating one of the established safety criteria 13 for the plant.
14 Q
In the design of the protection system 15 for the liquid metal fast breeder, was the system 16 one that required operator intervention for safe 17 shutdown or not?
18 MR. FISKE:
Can you answer that 19 question?
20 A
My recollection is that, no, it didn't require
(_
21 operator intervention.
22 Q
If the protection system sensed a 23 need for reactor shutdown, would the protection O
24 system automatically 25 A
Carry its action through to conclusion?
l.
(~
I Womack 85 V}
2 Q
Yes.
3 A
Yes.
4 Q
Could the operator manually override 5
the shutdown mechanism of the reactor protection 6
system in the liquid metal fast breeder?
7 A
The protection system to which I refer is 8
simply a scram system; it drops the nuclear 9
poison control rods into the reactor on the 10 detection of certain abnormal or incipient 11 abnormal conditions and the operator certainly 12 could, by taking
~
the operator or operators 13 could, by taking a series of actions could prevent 14 that from happening.
15 If that's the sense of your question, 16 override.
17 Q
Did the liquid metal fast breeder 18 hana equipment for energency core cooling?
19 A
Not in the sense that pressurized water 20 reactors have equipment for emergency core cooling.
21 Q
In another sense, did it?
22 A
The post-shutdown cooling of liquid metal 23 fas.t breeder reactors, the FFTF core in particular O("%
24 as I remember it, was natural circulation cooling 25 through the hea~t exchangers to the steam
~N 1
Womack 86 (b.
2 generators.
In that sense, emergency or post-3 shutdown beat removal was provided.
4 Q
When you say that there would be C
5 natural circulation of cooling, does that mean 6
that the primary coolant pumps would be shut off 7
as soon as the control rods were inserted?
8 A
Yes.
9 Q
Did the reactor protection syscem 5
10 have a mechanism for-automatically terminating 11 the operation of the primary coolant pumps?
12 A
As I recall, it did.
13 I just want to point out that you 14 are reaching back many years and I may be 15 confusing in my design recollections FFTF and the 16 clinch River breeder.
17 My recollection is that we shut --
i l
18 that we shut the pumps, the reactor coolant pumps 19 on scram on both thost. plants but that certainly 20 is a judgmental design decision.
(-
21 The reason for shutting the pumps l
22 down, of course, on a liquid metal plant is that 23 the core delta T is quito high and one reduces l
24 the forced convection to minimize thermal shock l
i 25 on the system components.
i
I Womack 87 I
2 Q
Where is the core delta T high, can you explain that?
3 r
r 4
A The temperature from the inlet to cool' 5
liquid sodium entering the cooler at the core 6
inlet as compared to the temperature at the 7
liquid center exiting the core is the temperature 8
differential or the delta T that I referred to.
9 That temperature differential may run from e
10 250 to 300 degrees Fahrenheit in the liquid i
11 metal reactor, whereas in a pressure water l
(~~I
(_,
12 reactor it runs perhaps 40 degrees.-
4 13 When the nuclear reaction is stopped 14 in a liquid metal core, the heat generation 15 very promptly goes to a very much smaller 16 quantity than when at full power operation.
The 17 incoming liquid sodium at the cooler temperature 18 is no longer heated to this large -- to this much 19 higher temperature and the previously heated 20 liquid sodium exiting the core is now followed by a mass of cool sodium into the system, and this j
21 22 presents an almost discontinuous thermal shock 23 to the system components, but shutting down the
(' ~))
~,
24 reactor coolant pumps and essentially reducing 25 the speed with which that cool sodium moves
[~h I
Womack 88 k-]
2 through the system, one can reduce that thermal 3
shock.
4 Q
And correct me if I am wrong, but is 5
the reascn for wanting to avoid thermal shock 6
so that you avoid any brittle fracture?
7 A
Avoid fractures of fatigue and induced 8
stress.
9 Q
on the B&W PWR plants, particularly 10 the 177 FA plants, B&W has now issued a procedure
[
11 that calls for the operators to, or for the plant 12 to go to natural circulation following a reactor 13 trip that involves high-pressure injection 14 actuation, isn't that right?
~
15 A
That's correct.
16 Q
Am I also correct that the reasons 17 for now recommending going to natural circulation 18 immediately following such a shutdown are 19 different from the reasons for going to natural 20 circulation on the liquid metal fast breeder?
21 A
Yes, you are correct.
22 Q
What are the reasons for going to 23 natural circulation -on the B&W plants?
24 A
Because a series of analyses which we had 25 begun late in 1978 and carried through into the
-,c,
I 1
Womack 89 O
2 summer of 1979 indicated to us that for a certain 3
range of primary system break opening size.., a 4
range which runs from breaks which are C
5 approximately three times larger than the pilot-6 operated relief valve area to about a half a -
7 square foot, that we could not with present 8
techniques demonstrate that water would not be 9
lost from the system at a rate higher than that t
10 considered in the classic LOCA analysis, which 11 always assumes that the electrical power and O) 12 therefore the pumps are lost when the LOCA occurs.
(_
13 There is still some question in my 14 mind that this is a real effect, but physically 15 one can imagine the operative effect as the 16 difference between the amount of water one would 17 lose from a full bowl with a hole three-quarters 18 of the way up its side in the condition in which 19 you simply let the water run out down to the 20 level of the hole and the condition in which you 21 stir the water and slosh some of it up into the 22 hole (indicating).
23 The question as to whether this fg V
24 actually happens in exactly this way in a reactor 25 system I believe is still open, but present
.-e-
I
[]
1 Womack 90
'u J 2
analytical techniques could not demonstrate that 3
it does not happen, and therefore, after some 4
investigation and with some reluctance, we 5
recommended to the NRC and to our customers this 6
operation of ceasing pump operation when there' 7
is a low-pressure initiation of the high-pressure 8
injection system.
9 Q
When you say, when there is a 10 low-pressure initiation, you mean when the 11 pressure in the reactor coolant system falls low O)
(_
12 enough to actuate high-pressure injection?
13 A
That's what I mean.
14 Q
In your answer you referred to the 15 analyses that had been done and you said that 16 those analyses had assumed a loss of off-site 17 power, if I understood what you were saying, is 18 that right?
19 A
That's right.
20 Q
If you lose off-site power, that in 21 turn loses the operation of the primary coolant 22 pumps; right?
23 A
That's correct.
24 Q
So the mode you were studying 25 previously had been a natural circulation mode?
A That's correct.
,_ - -. ~.
('
bt I
N))
Womack 91 2
Q Then your prior analysis had assumed 3
a natural circulation, so why was B&W having to 4
change its analysis?
5 A
We weren't changing our analysis.
We were 6
investigating a phenomenon of a particular smal~1 7
range qf brakes.
In prior analysis it had been 4
8 assumed and believed within B&W, and I believe 9
within the rest of the industry, that LOCA. analysis, t.
10 analysis of the worst case accident conditions would 11 always be a condition in which the reactor coolant 12 pumps ceased their operation at the time that the 13 reactor tripped following the LOCA, and the great 14 majority of the analysis filed for -- and for design 15 analyzing purposes on B&W plants 16 Q
This is pursuant to Section 50.467 17 A
Yes.
18
-- had been analyses of that kind 19 of LOCA accident.
20 It was suggested to me in the fall of
(/g, 21 1978 that that might not be the case and that 22 we should look at some other analyses, and we i
23 did proceed to look at some other analyses.
bd 24 What we found was that -- we look.ed 25 first at 205 plants because that was what we l
1
,m.
- ~.
. _. ~. _ _ _. _ _ _ _..
I 2
Womack 92 2
then had under contract.
What we found was 3
.that the the analysis showed that we certainly had 4
a case which met the requirements of Appendix K and 5
10 CFR 50.46 when the pumps were shut down 6
~
immediately.
7 It also appeared from our analysis that O
if the pumps continued indefinitely in operation 9
that the core would be cooled and thy Appendix K 10 requirements wero met.
We did see for some in 11 some instances the suggestion that high loss of 12 liquid water would occur in cases for some break si=e 13 and we were in the process of continuing to 14 investigate that finding, that preliminary finding 15 when TMI happened.
16 TMI, the accident, of course delayed 17 consideration of other matters and we -- when we 18 returned to that later in the summer, we investigated 19 more thoroughly and took the action that you have 20 mentioned with regard to pump shutdown.
21 This in my opinion is not relative 22 to the TMI accident because the brake size is 23 quite different.
24 Q
Although you were principally involved 25 in the liquid metal fast breeder reactor and the
(~'
3 1
Womack 93 O]
2 gas-cooled reactor projects, were you ever 3
consulted or asked to participate in NRC review 4
of questions regarding licensing of normal 5
commercial nuclear plants?
6 A
During the period of time I was at AEC?
7 Q
Yes.
8 A
I don't recall being so consulted at any 9
time.
10 Q
I mean formally or informally.
11 A
No, sir, n_,,
12 Q
When you were with the AEC and working 13 on the liquid metal fast breeder and the 14 gas-cooled reactor projects, were both of those 15 considered experimental projects?
16 A
~ Yes.
17 Q
To what extent if at all did either 18 of those projects have to comply with the NRC's 19 general design criteria?
20 A
Well, let me amend my last answer and 21 amplify it before I answer your question, please.
22 In the gas-cooled reactor work, the l'
23 General Atomic Company had sold a demonstration
\\-
24 gas-cooled reactor to the Public Cervices Company 25 of Colorado.
I was not directly involved in the
4 1
Womack 94 es V
2 design or sale of that but that was a plant which 3
was licensed under the rules of the Nuclear 4
Regulatory Commission.
5 Given the vintage of that plant, I am 6
not sure whether the general design criteria were 7
applied in its licensing or not.
My relationship 8
to that plant really consisted -- was indirect in 9
that we supported some general work in fuels
(
10 utilization development, fuel develop' ment, and a 11 very limited amount of additional work which had Ov 12 potential utilization in that plant which was 13 a plant licensed by the predecessor of the Nuclear 14 Regulatory Commission.
15 I don't know at this time what the 16 licensing requirements imposed on that plant were.
17 Q
Let me ask you, I am really seeking 18 for your background.
I want to be very candid about i
19 this.
20 During the period you were with the AEC
(.
21 from 1968 to
'75, did you have to work at all with 22 the general design criteria?
23 A
Yes, I knew about the general design criteria, w.
24 but we did not have the exact same licensing process 25 for developmental plants sponsored by the AEC that
.I
5 t
Womack 95 2
was followed by the NRC for commercial licensen.
Q When and under what circumstances during 3
4 y ur tenure tiith the AEC did you have to work with the 5
GDC, or the general design criteria, as they are m re explicitly called?
6 A
Well, I can't remember working with them very 7
8 much at all.
I can remember being aware of their existence and discussing it.
We had our own g
10 standards and criteria for our plants and
~
11 Q
So you w uld --
12 A
Yes.
13 Q
Y u w uldn't say then that coming out of seven or eight years at the AEC that you were g4 15 very familiar with the general design critiera, is that right?
16 A
No, not intimately familiar with the general g7 18-design criteria.
19 Q
You were not intimately familiar?
A That's right.
20
(
21 Q
Had you worked with them enough to know how the general design criteria applied to 22 23 pressurized water reactors, criterion by criterion?
A No.
24 25 Q
Had you ever worked with others at the
(~g 6
1 Womack 96 N.)
2 commission whose jobs it was to know and 3
apply the general design criteria?
4 A
Whose concurrent job it was, or at any time
()
5 in the past?
6 Q
Whose job at that tine it was to 7
apply the GDC.
8 A
No, I don't believe so.
9 Q
During the seven or eight years that t
10 you were with the Atomic Energy Commkssion, did you 11 gain any familiarity with the standard review 12 plan of the NRC?
13 A
No.
14 Q
Did they have a standard review plan 15 while you were with them?
16 A
I don't know.
17 Q
If they did, you weren't very familiar 18 with it, is that right?
19 A
I think that is what I said, yes.
20 Q
Since coming to B&W have you ceveloped
(_
21 a more intimate familiarity to use your phrase 22 with the general design criteria?
23 A
More familiarity, not completely intimate.
24 Q
Since coming to work for B&W have you 25 developed familiarity with the standard review plan
[V]
7 1
Womack
~
97 2
of the NRC?
3 A
Again, more familiarity.
4 Q
When you first joined B&W I know you 5
were working in the international program, is that right?
6 A
Yes.
7 Q
Was your first rigorous contact 8
with the general design criteria when you became 9
Manager of the Plant Design Section?,
10 MR. FISKE:
I didn't hear that.
11 THE WITNESS:
He used the word " rigorous."
12 A
Yes, I suppose so, although rigorous is 13 farther than I would go.
14 Q
Do you feel that you have ever 15 developed an intimate familiarity with'the 16 requirements of the NRC's general design criteria?
17 A
I think I have a pretty good familiarity 18 now.
To say that it is intimate, it would imply 19 to me, Mr. Seltzer, application in a design 20 project over a number of years, and I really would 21 not care to go that far because, as you can see 22 from my resume up until about 1970 the projects on s
23 which I worked did not address themselves to let sd 24 us go on and include the standard review plan 25 and the general design criteria expressly but rather
I 8
Uomack 98 2
to criteria which were appropriate from other 3
sources and incoming to plant design in 1978,
(
4 these criteria of course were applicable on 5
contracts which, for the most part, were either 6
in the fairly early stage of design or had their 7
design completed, had had their design coupleted.
8 Is that understandable?
9 Q
I think so.
10 A
o,g, 11 Q
Yes, it is.
12 If a plant is in a fairly early 13 stage of design, is that the stage at which B&W 14 would from your experience be applying the general 15 design criteria?
16 A
Well, B&W would apply the general design 17 criteria to any design or design change it 18 made if those criteria were applicable to that design 19 under the contract that it had with its customer.
20 But I was discussing the use of the 21 word " rigorous" and discussing the use of the 22 word " intimate" and we were not at the time that I 23 was Manager of Plant Dcsign doing any new plant 24 design.
We were looking at issues that came up 25 on essentially completed designs, and we were
(~
g I
womack 99 V}
2 looking at the application of new requirements to 3
new contracts, but the basic design work for the 4'
B&W pressurized water reactors had essentially 5
been settled and done many years before, and it 6
would be in that kind of an application that I 7
think one could qualify for intimate familiarity with 8
the GDC in a design.
9 Q
Are you saying that prior to your t
10 becoming head of the Plant Design Section, B&W had 11 already developed the generic designs for their 12 177, 205 plants?
13 A
That is exactly what I am saying.
14 Q
Are you also saying that it is the 15 people who would have developed the generic designs 16-for the 177 and the 205 plants whom you would 17 expect would have the intimate familiarity with 18 the GDC and the SRP?
19 A
Yes, sir.
20 Q
Do you know for a fact that when you k.
21 took over the Plant Design Section there were 22 people reporting to you who had competence and l
~N 23 intimate familiarity with the general design criteria (d
24 and the standard review plan?
25 A
Yes.
4 1
Womack 100 O
'10 J
2 Q
Who headed the unit that was mostly 3
responsible for having that familiarity and i
4 competence?
5 A
Well, the plant intergration unit headed.by 6
Mr. Bruce Karrasch had responsibilities in
~
l 7
that area.
8 MR. SELTZER:
Off the record.
9 (Discussion off the record.)
c 10 (Whereupon at 12:45 o' clock p.m.
a 11 lunch recess was taken.)
12 13 14 15 16 17 18 19 i.
20 21 22
!O 24 I
4 25
.....l
101 s
1
)
J f
AFTERNOON SESSION 11 '2 3
2:05 p.m.
~
4 ED GA R A L L E N W O MA C K,
J R.
5 resumed and testified further as follows:
6.
EXAMINATION (Cont'd.)
7 BY MR. SELTZER:
Q Dr. Womack, I am sure you understand 9
that your testimony continues to be under oath.
O g
- ygg, 11 Q
Is it correct that in 1975 you left the AEC to join B&W?
13 A
Yes.
14 Q
Why did you leave the AEC7 A
well, I had -- as the record reflects 15 16 begun a career in the nuclear energy business 17 and I had served in a number of positions and 18 responsibility within the Atomic Energy 19 Commission and felt that it would be to my 20 advantage to obtain some experience in an 21 industrial capacity, and I had an acquaintance who 22 had joined the AEC earlier who had expressed a
(
strong interest in having me join them.
23
(_])
24 Q
Who is the individual at B&W who 25 asked you to come join them?
w
+,--~gg y-v,-
=v-
,y---e_
,-.,,--,_.,,v.-,-,-r-
102
/~N 1
Womack 2
A Originally, Mr. Kosiba.
'3 Q
Did it become somebody else?
r.
4 A
Well, and then other members of the 5
management within that interview but Mr. Kosina.
6 was the person.
7 Q
What had Kosiba's position been 8
at the AEC?
9 A
He had held the position of Assistant 10 Director for Plant Engineering in the division 11 for which I had worked.
g_)
12 Q
According to GPU Exhibit 1,
your 13 first position at B&W was as a senior technical 14 consultant; is that right?
15 A
That's correct.
l 16 Q
Could you explain what you did as 17 a senior technical consultant?
18 A
In my initial assignment I re po r,te d to 19 Mr. Kosiba who had a job called Manager, 20 Nuclear Export Operations and was responsible
/
k-21 for some general review and support work which 22 was going on for the B&W Babcock joint venture,
(~S -
23 BBR, in Germany; B&W BBC joint venture, I N/
24 should have said.
25 Q
So that's Babcock & Wilcox in the
- - - =.... - - - -,.. - -.. _ - -
103
- O) 1 Womack
\\~
2 United States.
3 A
Yes.
4 Q
And Brown Boveri Corporation in 5
Europe?
~
6 A
That's right, BBC.
7 Q
What specifically did you work on 8
in your position as senior technical consultant?
9 A
well, some of the time, of course, was 10 spent acquainting myself with the company and 11 particularly with the joinc venture between (s_j~1 12 B&W and BBR which at that time was-primarily 13 devoted to the design, construction of the 14 Muelheim-Kaerlich plant.
15 Q
What kind of plant is the Muelheim-16 Kaerlich plant?
17 A
It is a pressurized water reactor.
18 Q
Was B&W principally respon,sible for 19 the design of the nucl~ ear steam supply components 20 of that plant?
21 A
No.
principally responsible?
22 Q
Who was 23 A
The joint German company.
24 (Continued on next page) 25
~7/1 l'
Womack 104
)
2 Q.
Who were the joint partners in BBR?
3 A
B&W and BBR.
4 Q
Has BBR designed other nuclear plants?
C.
-5 A
No.
Pardon me.
At that time they had not.-
6 This was their first plant design.
They have -
7 subsequently undertaken work on a second plant.
8 Q
Where was the design team located 9
that was-doing the deeign for the Muelheim-Kaerlich L.
10 plant?
11 A
In Mannheim, that is West Germany.
12 Q
From where did BBR get engineers 13 with technical qualifications to design a nuclear 14 plant if this was their first nuclear plant?
15 A
They hired them from the German engineering 16 plant generally and some were provided by the 17 companics, BBR and B&W.
18 Q
Had Brown Boveri Corporation previously 19 designed nuclear steam generators?
20 A
Brown Boveri Corporation has other joint
(-
21 ventures which have done this work.
22 Q
Am I correct that BBC-is not an 23 NSS vendor itself?
'\\ d
~
24 A
That's correct 25 Q
" Interface" seems to be a neat word I-l l
h,
,,,,..,_n
1 Womack 105 O
l l
2 that is used a lot in talking about nuclear plant 3
design.
What interface was there between the 4
Lynchburg nuclear plant design staff of B&W and 5
the BBR design staff that worked on the MK plant, 6
if any?
7 MR. FISKE:
What period of time 8
are you talking about?
9 MR. SELTZER:
During he time that 10 they were designing the MK plant.
11 A
Well, the MK plant was the MK plant O) 12 design was built upon the basic B&W'205 fuel q
13 assembly reactor design, which had been provided 14 to BBR under a license agreement by The B&W 15 company.
'16 Excuse me, before I continue that, 17 could you read back the question so I make sure 18 I ansNer all parts of it fully.
19 (Record was read back.)
The interface then consisted of the 20 A
21 transfer of design documents which had been.
22 created within B&W under the terms of the license 23 agreement.
It also included direct support for p)s
\\
s 24 design changes or modifications that the BBR 25
-wished or needed to make,-felt it needed to make
i.,
I" 1
Womack 106 O) 2 to meet German criteria as it evolved in the 3
Muelheim-Kaerlich design.
~
4 We also had additional communications 5
on research and development that we might have been 6
conducting and we did an overview for a period of 7
time of design changes that BBR had made.
8 Q
What do you mean by "an overview of 9
design changes which BBR had made"?
10 A
Looking at some of the modifications which 11 the BBR design team had made to provide additional w_)
12 review essentially to assure the basic engineering 13 soundness of the changes.
B&W had at that time a 14 financial stake in BBR.
15 Q
What were the principal' changes made 16 in the design between the MK plant and the basic 17 205 design of B&W7 4
1 18 A
Well, there were many such changes due to 19 the circumstances of the German market and a i
20 rapidly evolving licensing environment within l
21 Germany which was based on a licensing law which 22 required plants in the construction process to be
(~T 23 continually updated to current licensing concepts
%)
24 and rules.
25 Q
All right, that gives me some of the
7 i
4 1
Womack 7
107 l_)
2 atmospheries but not any of the specific changes.
3 Let me focus my question before you start giving 4
me changes.
~
5 of the many changes that you said 6
were made between the MK design and the basic 7
205 design, what changes, if any, were made that 8
would be of particular interest in light of the 9
Three Mile Island accident?
10 MR. FISKE:
I am going' to object to 11 the form of that question, Mr. Seltzer.
[ ')
12 I think if you want to ask him about L./
13 specific changes, I don't have any problem 14 with that, but I don't think you should put 15 it in the form that you just did.
16 Q
Isn't it a fact that you have 17 studied the MK design in light of the Three Mile 18 Island accident?
19 A
If you mean that I personally have studied 20 it?
I have reviewed material prepared by others.
(
21 Q
The material prepared by others was 22 prepared in light of the Three Mile Island m
accident, wasn't it?
7
(
)
24 A
Yes.
25 MR. FISKC:
Just so I understand
1 Womack 108 s..
2 where you were going with this in the 3
beginning, are you talking now about changes 4
that were made in the design after the 5
accident?
6 MR. SELTZER:
No.
7 MR. FISKE:
Oh, all right.
Then why s
8 don't you keep going.
9 Q
There are differences in the design 1
10 of the MK plant from standard B&W pl~nts which a
11 changes were made before the Three Mile Island
(~h 12 accident, isn't that right?
V 13 A
That's correct.
14 Q
There has been an analysis done of 15 those differences and that analysis was prepared 16 after the Three Mile Island accident, isn't that 17 correct?
18 A
That's correct.
19 Q
What would you say were the most 20 significant differences between the MK design and
(,
21 the American design of B&W plants in light of 22 the Three Mile Island accident?
23 MR. FISKE:
Well, I am having trouble i
J 24 with the last part of the question.
If you 25 want to ask him just the first part.
1 Womack 109 u/
2 MR. SELTZER:
No, I want to ask him 3
the second part because I believe he has 4
and B&W has specifically examined that 5
question.
6 A
Well, the analysis to which you refer was 7
a comparison between the Muelheim-Kaerlich plant 8
and the TMI plant.
B&W domestic designs have 9
themselves evolved such that there are differences 10 between B&W 205 domestic design and the TMI plant.
11 I believe your question was so broad
(
12 as to address both but if you would.like to refer 13 to that specific analysis, I would be glad to do 14 so.
I would appreciate being provided a copy of 15 the report.
16 Q
Well, at your request and suggestion, 17 I will certainly endeavor to do that. ~ Without 18 putting the report on the table at this moment,
{
19 what would you say is the most significant 20 difference batween the Muelheim-Kaerlich plant
(,
21 and the Three Mile Island unit in light of the 22 accident?
23 A
That's difficult for me to say.
g 24 MR. FISKE:
Yes.
25 THE WITNESS:
Excuse me.
Did you
(~%
1 Womack 2
wish to add anything?
3 MR. FISKE:
I am continuing to have 4
a little problem with the question but if 5
you think you can answer it go ahead.
6 A
There are a number of differences.
Let 7
me see if I can mention some of them to you.
8 For one thing, there is the loop 9
elevation.
For a second, there is the power level S
10 of the plant.
But even more fundamental than 11 those two obvious differences in design is the D(,)
12 difference in the institutional arrangement under 13 which the Muelheim-Kaerlich plant is being 14 constructed and the institutional environment 15 under w'ich it is being licensed.
h 16 Firstly, the consortium, BBC-BBR, 17 is responsible on a turnkey basis for.the 18 Muelheim-Kaerlich plant.
The BBR portion of the 19 consortium is responsible for a nuclear island, 20 a broader scope of responsibility than B&W k_
21 normally undertakes in U.S. domestic projects and 22 a broader scope of responsibility in the joint 23 arrangement, the consortium arrangement, than
()
24 B&W undertakes in domestic plant activities.
25 This has, coupled with a very
.. s
- - - +
+
y
,. -~,
_y 7 -.,, -
_7
1 Womack
.111 i'%
2 different licensing, set of licensing requirements
'3 in Germany, has led to a number of changes.
4 One of the significant differences 5
between the United States and German licensing 6
practice is the stipulation in German licensing 7
practice that the plant operator is positively 8
discouraged from taking any action within the 9
first~30 minutes following a transient or accident 10 and that the design itself must provide automatic 11 actions for all measures which may need to be l
12 taken or could be envisaged to be taken in such a 13 period of time.
In the United States practice, the 14 15 role of the operator in plant control.is much less 16 rigidly prescribed and is generally at the option 17 of the utility contracting for the pla}nt.
18 The difference between those two 19 design philosophies leads to some substantial 20 differences in control automation, control and
(_
21 automation of functions.
Additional differences include the 22 23 degree and level of redundancy of safety systems.
\\. d 24 For example, the Muelheim-Kaerlich plant has a 25 total of six emergency feed water systems, four
_--,cy.
m m.
e
rN
'l Womack
/
3
.112 V
2 of which are redundant closed loop systems; the 3
other two are bunkered underground.
No United 4
States plant has similar systems, to my knowledge, C/
5 and there are other differences.
I 6
Q Are there any other differences 7
that you believe are particularly significant 8
in light of the Three Mile Island accident?
9 A
Well, one of the automation points that has t
10 been pointed out in the analysis to which we have 11 both referred earlier was a system whereby one of
(
12 the -- one of the automatic protective or x-13 safeguard systems, I think when the time -- when 4
14 the containment itself isolates, it also isolates 15 the block valve in series with the pressurizer 16 relief at Muelheim-Kaerlich automatically.
17 Q
What trips block valve closing?
18 A
on Muelheim-Kaerlich?
19 Q
Yes.
20 A
There are about four or five different 21 functions which trip it closed.
My recollection and to answer that question 22 from this analysis is
,N 23 best I would request again to have the document t
s V
24 in front of us.
25 Q
Is Muelheim-Kaerlich a once-through
10 1
Womack 113 2
steam generator plant?
3 A
Yes, it is.
4 Q
You said that the power level is 5
significantly different.
What is the power level 6
of Muelheim-Kaerlich?
7 A
3800 thermal megawatts, approximately.
8 Q
What is the power level of TMI-2 9
in megawatts thermal?
10 A
I believe it's 2772, approximately.
11 Q
What does Muelheim-Kaerlich generate
()
12 in megawatts electrically?
What is.it slated to 13 generate?
14 A
About 1200 megawatts electrically.
15 g
What is TMI-27 16 A
It is around 900, I believe.
17 Q
You said that the loop e'levation 18 is different between Muelheim-Kaerlich and TMI-2.
19 Does that refer to the feature that is called i
20 lowered loop in TMI-27 21 A
Yes.
22 Q
What is Muelheim-Kaerlich?
23 A
We refer to the Muelheim-Kaerlich and other 24 205 plants of that design vintage as raised loop 25 plants.
....-.~...... a..
fg 1
Womack 114 b
2 Q
What is the significance of that in 3
light of TMI-2's accident?
4 A
Well, in the analysis, it was pointed out 5
that there would have been more water to drain 6
back into the reactor vessel given the same 7
discharge of water that had taken place at TMI 1
8 because of the raised steam generators and raised 9
cooling loop at Muelheim-Kaerlich.
t 10 Q
other things being equal, would that 11 mean that it would take longer to uncover the
()
12 core?
13 A
Other things being equal, th~at's correct.
14 Q
Could you compare the pilot operated 15 relief valve set points on Muelheim-Kaerlich with 16 TMI-2 as those set points existed on TMI-2 prior 17 to the accident?
18 A
No, I don't think I could.
19 Q
Since the TMI-2 accident, do you 20 know whether the pilot operated relief valve set
(-
21 points have been altered for the MK plant?
22 A
No, I don't know for sure.
23 Q,
Do you have any inclination one i
(g
\\~)"
24 way or the other?
What is your best belief?
25 MR. FISKE:
Mr. Seltzer --
.-=
1 Womack 115 f~}
v 2
-Q I won't hold you to it.
Tell me 3
what you think.
Do you think they changed the 4
MK set points?
.C, 5
A The designer has studied the expected 6
challenge rate to the pilot operated relief valve with a view to minimizing it.
7 8
Q Reducing the number of challenges?
9 A
-Yes.
B&W has, I believe, as isted BBR in 10 that study. Whether that's led to an'y change or 11 not, I don't know.
O
(_j 12 Q
Could you tell me, please, exactly 13 what your role was in lending engineering support for the Muelheim-Kaerlich project?
14 15 A.
At that time period, sir?
16 Q
Whenever you were working.
If it 17 evolved, give me the evolution.
18 A
Well, it was best defined from 1976 through 19 1978 when I held the title of Program Manager 20 for that project.
This was essentially a commercial project in program and administration 21 22 responsibility wherein I acted within B&W as 23 the customer's representative, the BBR 24 representative, to obtain materials for BBR under 25 the license agreement and also to establish at
6 4
116 fs 1
Womack V
2 his request engineering tasks or support functions f vari us sorts, whatever he may wish, to assist 3
4 him and from time to time, of course, I would go to BBR and report results of those tasks with 5
6 those who were actually performing them.
And that's the general character of 7
g the work.
9 Q
By the time you left the 1,
10 international program and became Manager of Plant 11 Design, had the design for the Muelheim-Kaerlich
[)
12 plant been completed?
(/
13 A
Well, the simplest answer to that is no.
14 However, the basic design was well established 15 even before that period of time.
But.because of 16 the situation I explained to you earlier in answer to one of your earlier questions, there was and 17 18 is continual design evolution, changes, if you 19 will, to meet new requirements.
The German law seems to croate the necessity for that.
20
(_
21 Q
Other than your experimental program W rk with the AEC, what involvement have you had 22 with AEC or NRC nuclear plant licensing?
23 O
A Almost exclusively since August of 1978 24 and even almost exclusively since March 28th of 25
M 1
Womack
-117 Q
2 1979.
3 Q
What does that mean, " exclusively"?
4 A
Well, that means that prior to that time, 5
I had little to nil involvement with the NRC.
i 6
Q I am asking you since August 1978 7
how much involvement have you hdd with AEC or 8
NRC licensing?
9 A
Let me divide that into two periods.
From 10 August '78 to March
'79, I had a limited amount 11 of interaction with the NRC and after the
(-s 12 March 28th event at TMI-2, I had extensive j
13 involvement and work with the staff of the NRC.
14 Q
So you are testifying that before 15 the TMI accident you had minimal, if any, 16 involvement with any NRC licensing?
17 A
Yes, by comparison, a small amount.
18 Certainly we did work with our customers in 19 supporting them in matters which were coming up 20 and their discussions with the NRC and I was (m
21 involved in that.
It was part of my day-to-day 22 activities.
But the level of involvement and my 23 acquaintance with and direct work with the Nuclear g~g L]
24 Regulatory Commission staff increased manyfold 25 after the TMI accident of March 28, 1979.
~
118
['l I
Womack V
2 Q
Is it your belief that prior to the 3
TMI accident NRC licensing requirements were 4
relatively static?
5 A
No.
NRC's requirements certainly have 6
never been static.
The NRC requirements are 7
applied to specific plant designs by agreement 8
between the licensee, the utility constructing 9
or operating the plant and the NRC on particular u
10 issues.
They are then passed to the Babcock &
11 Wilcox Company under contracts and from time to
)
12 time there may be additions or changes which 13 are passed by the utility to B&W and we were 14 certainly -- we certainly, from time to time, 15 worked on some of these changes, for example 16 working on, at or about that time was looking 17 at changes from one revision of the safety analysis 18 report _ guide to another, the kinds of things 19 that might have to be done to update one 20 revision to another.
21 Have I answered your question?
22 Q
I don't think so.
23 A
You said --
~g (d
24 Q
Let me see.
25 A
The answer to your question was no, I think.
I Womack 119 V[ T 2
MR. SELTZER:
That's a lot clearer.
3 MR. FISKE:
Let's say he more than 4
answered.
5 Q
In addition to B&W having involvement 6
with the NRC through utility licensees, it is a 7
fact, isn't it, that B&W has extensive contact 8
with the NRC directly on its submission of 9
topical reports, isn't that a fact?
10 A
NRC does have involvement with the --
11 B&W has involvement with the NRC through the O(_)
12 submittal of topical reports.
These topical 13 reports are, of course, submitted in connection 14 with activities to support the licensing of 15 specific projects.
They would otherwise have no 16 purpose for existence.
17 Q
The topical reports support the 18 licensing of a spectrum of plants rather than 10 just a particular plant; isn't that right?
20 A
That is the intention.
(-
21 Q
And that's also the practice, is 22 that right?
23 A
I believe so.
\\_'
24 Q
Has the Muelheim-Kaerlich plant 25 commenced operation yet?
120
('].
1 Womack 2
A No.
3 Q
When is it scheduled to begin low 4
power operation?
5 A
In the mid 1980s.
6 Q
Prior to the accident at Three Mile 7
Island, are you aware of any specific efforts 8
at B&W to examine the Muelheim-Kaerlich project 9
to determine whether there were good features of t
10 that project which should be transferred back 11 into United States plants being built by B&W7 I
12 A
This was done on an opportunity rather
(,j 13 than a systematic basis.
14 Q
Could you explain what opportunities 15 gave rise to that?
16 A
Well, if, for example, the German utility 17 sponsor might want some particular feature 18 designed or developed for the Muelheim-Kaerlich 19 plant which appeared to us to be a performance 20 improvement in which our U.S.
deonestic utilities 21 might be interested, we would from time to time 22 either look forward to, and I can't recall
'S 23 specific instances in which we actually did,
-(O 24 but look forward to offer such changes to them.
^ -
25 An example might be an extensive developmental 9
--w-r--
221 h
I Womack
[N 2
system which the Muelheim-Kaerlich plant has 3
for core power distribution monitoring during r
4 power operation and tying that system to power 5
operation control.
6 Q
To the extent that you are aware of 7
them, what were the circumstances that led to 8
your being appointed Manager of Plant Design?
9 A
Dr. Roy had been the Manager of Plant t
10 Design and received a promotion to Manager of 11 Engineering.
I presume that those responsible (J
12 for my selection felt that I could bring some w
13 management skills to that section which would be 14 of value and made the appointment.
15 g
Were you told that you were expected 16 to bring certain management skills to that job 17 which they were looking forward to seeing 18 applied?
19 A
Generally, I was told that I was expected 20 to do a good job in managing that section, yes.
21 Q
Did somebody tell you that they 22 thought from some prior work you particularly 23 had management skills that would be useful?
gT N.]
from what I 24 A
I believve from what I had 25 was told, that I had done a satisfactory job
I Womack 122 2 I on the Muelheim-Kaerlich work.
3 Q
Who told you that you were being d
4 assigned to replace Roy as Manager of Plant i
5 Design?
6 A
Both Dr. Roy and Mr. MacMillan.
And my 7
current boss who was a man named Dave Berger.
8 My boss at the time, excuse me.
9 Q
Had you met MacMillan before?
e 10 A
Yes.
11 Q
When you took over as Manager of the 12 Plant Design section, was there any description 13 of the function of each of the units that reported 14 to you?
15 A
Yes.
16 Q
What form did that description take?
17 A
Well, we have an organizational. responsibility 18 description for each of our organizati,onal units 19 and so they were written descriptions of these 20 units.
21 Q
How extensive is the description of 22 the function of each unit?
r'N 23 A
You mean in terms of written length?
\\
24 Q
Yes.
l 2.5 A
Perhaps two, two pages, three pages.
~. -.
l l
I Womack
- 123 9
Q During the time that you were the i.
3 Manager of Plant Design were those descriptions
.'[
[i r
4 revised?
5 A
Yes.
l 6
Q
- How many times?
7 A
I don't recall.
8 Q
More than once?
^
1 9
A Yes.
a i
10 Q
During the time that you' were Manager 4
11 of Plant Design, were those descriptions revised
(
12 before the Three Mile Island' accident?
l
.I 13 A-I don't recall having made revisions before i
14
.the Three Mile Island accident.
I 15 Q
So then is it a fact that.those t
16 revisions that were made were made several times l
17 and each time it was after the Three Mile Island 18 accident?
j 19 MR. FISKE:
He said more than once.
20 MR. SELTZER:
That's what I meant by several.
21 l
22 A
Yes, I think that's right.
i 23 Q
Who would have a copy of the current O
i i
I 24 description of responsibilities of each of the 25 units within Plant Design?
I 124 I
Womack
(~)-
(m/
2 A
Well, the section is now called Plant 3
Engineering.
However, I am sure that Contract 4
Legal could obtain a copy for you.
There would 5-be copies. available from our Procedures Group in 6
Lynchburg.
7 Q
During the time that you were Manager 8
of Plant Design and prior to the accident, did 9
the structure of the Plant Design.section remain 10 the same?
l 11 A
You said that during the time that I was 12 Manager of Plant Design and prior to the accident?
13 Q
Right.
14 A
I believe I have earlier said that my 4
15 recollection is that we did not change the
,e k
16 structure'in that period of time.
17 Q
During that time you had six units 18 that reported to you, right?
i 19 A
Yes.
20 Q
I am a real fan of yours and I have I
(
21
- read your Kemeny deposition testimony and your l
22 Rogovin Commission testimony, and I didn't I am 23 sorry for being more verbose than I normally am O
i 24 but I didn't get a sense from there of the i
25 interrelationship of the six units that reported
-..., -,, -, - ~., - - - - -,. -,,
.,c,,-,_,.,,
,,w..-.
p,,4....,y,_,-..
._,--,-r
,,.-,.,,._,,,,-w,
.,,,....,.,7
.._,,,.-.,,y.,,--.m.,.e..,m.,
,,.r--
,.-w,,
4 1
Womack 125
(~g_
O 1
2 to you and I say that by way of preamble, what 3
I would like to ask you in the design of a nuclear 4
4 plant for a particular United States customer, 4
5 what would have been the contribution of each of 6'
the six units that reported to you during the 7
period prior to the Three Mile Island accident?
8 MR. FISKE:
I think Mr. Womack is 9
ready to answer that question in the context 10 of whatever design activities'were going on 4
. 11 during that period of time.
l_ (
)-
12 A
I think I mentioned to you before that the 13 essential' design of the work for the reactors in the 14 United States had been completed sometime past so 15 our work was primarily addressing changes and 16 addressing new criteria and that is indeed design 17 work but not -- but it may not require an 18 organizational configuration of the kind that one
~
19 would put into place to design de novo a new h
20 reactor plant.
Now, let me answer your question.
~
(
21 Q
No, I don't want it answered any more 22 because you have changed the ground rules.
23 MR. FISKE:
No, he answered your 24 question.
25 MR. SELTZER:
He said now to answer your
,n..
n-,,.-,-
...,.,.,--,.,._..-----,,.~,.v.,.
.,,.-,.n,..,
--.nw,.,m.,.,,-
w.-,v.
,,--ne.-,
wwwo
fg I
Womack 126 4
3 question.
I am not going 3
MR. FISKE:
I mean if you want to 1
4 withdraw it, you can, but I think he 5
answered the question you have asked or was
]
6 Prepared to answer the question.
A I am prepared to answer the question you 7
8 asked in any detail you wish.
9 Q
Did you understand when you took over e
10 the Plant Design section from Dr. Ro'y that this 11 had basically been the structure of the Plant m i 12 Design section in the recent past?
.%-)
13 A
Yes.
14 Q
Had reactors been designed de novo, 15 as you say, by this structure of Plant Design?
16 A
I think not.
17 Q
You don't believe that this particular 18 six-unit configuration had ever designed a nuclear l
P ant?
19 A'-
I believe that this six-unit configuration 20
(
was created between 1974 and 1978, which was the 21 22 period of Dr. Roy's tenure, and it was created to address more of the kind of work that we were 23
' O doing in August of 1978, that is, application of 24 25 new criteria, looking at design changes and to
1 Womack
-126A 3
some extent support of operating customers at 3
their request rather than a first of a kind 4
design team.
(Continued on following page.)
-5 6
7 8
9 t
10 11 12 13 14-
^
15 1
16.
17 18 10 20 21 r
22 23 24 25
--wwwm-
~'\\
1 Womack 127 (d
2 Q
I wasn't limiting myself when I said 3
design of plant to first of a kind.
If you had 4
second-of-a-kind, third-of-a-kind plants being 5
designed, I would also include that.
6 Let me phrase my question to you this 7
way:
Is it your understanding that this six-unit 8
structure for the plant design section which you 9
inherited in Augus t of 1978 had ever designed any 10 plant whether it was the third or fourth in a 11 generation?
O)
(_
12 A
In that sence, to the extent that second, 13 third, fourth of a kind required new design, yes, 14 I believe this group had done that kind of work 15 for plants subsequent to TVA.
In other words, 16 nth-of-a-kind plants.
17 You see, Mr. Seltzer, the practice in 18 the industry and within B&W and the intention was 19 to, to the greatest possible extent, standardize 20 on basic designs, and this was for many reasons 21 and it was something that I believe almost every 22 component of the industry supported, and we were (N
23 attempting also to support it, so in terms of k.
24 second-of-a-kind and nth-of-a-kind design, the
'i5 issues to be addressed would be new requirements
~
f~-
1 Womack 128 Q/
2 or special requests of the utility customer and 3
so forth.
i Q
Once B&W had developed the 205 plant
(
5 design, did B&W withdraw in the market the 177 6
design?
7 A
No.
8 Q
Is it a fact that B&W continued to i
9 offer the 177 design as a generic design which
(
10 they were willing to sell to new customers?
11 A
I believe it was continued, that the offering O()
12 was continued.
13 Q
Did B&W, in fact, continue designing 14 subsequent generation 177 plants at the same time 15 as B&W was designing 205 plants?
16 A
There were subsequent generation 177 plants 17 whose construction was as yet incomplete, so in 18 that sense the answer is yes.
19 Q
After the first order was taken for a 20 20 5' pla nt, did B&W take any orders for 177 plants?
21 A
I can't answer that ques tion.
I don't know.
22 Q
What would be the fastest way to get the 23 answer to that?
24 A
Telephone Lynchburg.
25 Q
Whom would you call up and a.sk?
1 Womack 129 r-)
,U 2
A Oh, I could call any one of a number of 3
people.
4 Q
Would Dr. Roy know?
5 A
Probably, but he would also want to 6
check with the Marketing Department's records.
7 Q
I'would like then to focus on this 8
aspect of your prior testimony.
You have said 9
that during the period when the six-unit structure 10 of plant design existed, those six units were 11 called upon to assemble the components for
[J) 12 succeeding units in a generation of generic plants 13 that had already been established, is that right?
14 A
I don't think I said assembled components.
15 I think I said to address new criteria, specialized 16 requests of the customers or specialized contract 17 commitments, on-site, specific commitments and the 18 like.
19 Q
Who would put together the design 20 package that became the new plant if it wasn't the 21 plant design section?
22 A
A great deal of the design documentation 23 would be put together by other sections of the
,f \\
(~)
24 Engineering Department.
For example, there was a 25 component engineering section which would put together y
._..---r--
---,m-
r.
r~N 1
Womack 130
~./
2 part o f the design package related to code stress 3
analysis.
The Plant Integration Unit had among 4
its responsibilities pulling these design packages 5
together and looking to the interfaces among them.
6 Q
Could you please go across the 7
organization chart for your plant design section 8
and tell me what the contribution of each of the 9
units of plant design would be to the putting together of a design for a new plantf 10 11 MR. FISKE:
Well, I am not sure, Mr.
rO 12 Seltzer, that Mr. Womack has said that during
(_)
13 this nine-month period they did put together 14 the design components for a new plant.
4 15 MR. SELTZER:
I am asking him, though, 16 fron his knowledge of the responsibilities of 17 each of these sections what their 18 responsibility would be for bringing together 19 a design for a subsequent plant.
20 (Handing document to the witness.)
k.
21 MR. FISKE:
Well, I think it would be 22 useful if Mr. Womack
--I mean I don't
~T M
believe it has been established that they (V
24 actually did this during the period of time 25 that we are talking about.
1 Womack
(~Y 131 2
MR. SELTZER:
I think it has been 3
established, though, that it was part of 4
their job description, the description of 5
their responsibilities, and I am just trying 6
to get testimony of the man who headed the 7
section what he understood could be expected 8
from these units.
9 BY MR. SELTZER:
10 Q
If you say you couldn't expect much, I 11 will take that.
D)
(_
12 MR. FISKE:
I have no objection for your 13 asking what their functions and 14 responsibilities were during this period of 15 time and see if that answers your question.
16 MR. SELTZER:
I want to focus it, Bob, 17 on specifically what their function would be 18 with respect to designing or bringing the 19 elements together necessary for the 20 construc tion of an nth-in-a-series nuclear 21 plant.
22 MR. FISKE:
Whether or not they actually
(~%
23 ever did it?
t.]
24 MR. SELTZER:
Right.
25 A
O.K.
Referring to -- referring to the
.. :o 1
Womack i "r )
132 u
2 organization chart you have just ~ handed me, 3
MR. FISKE:
Can we mark that?
4 Q
Can_you tell for what date that is
(
5 MR. FISKE:
Excuse me, can we mark that 6
as an exhibit so we, later on, know what he 7
is looking at?
8 MR. SELTZER:
We can get a copy.
9 MR. FISKE:
Yes.
10 Q
Why don't you tell us what you were 11 going to, and then we can get a copy and mark it.
12 A
I believe you asked can I tell.from what 13 date, and there is a date at the bo ttom, right-hand 14 corner which looks like August 15th, 1976.
15 Beginning at the left of the chart, there is a unit 16 called Safety Analysis.
This unit provides 17 this unit provided engineers who specialized and 18 could perform analysis of plant accidents, 19 particularly those which were required to be 20 add'ressed in Chapter 15 of Safety Analysis Reports, 21 and especially those which addressed nuclear 22 reactive changes, steam-line break or rupture 23 accidents, radiological releases, and they also g's 24 did calculations for shielding and radiation 25 tra ns po r t.
1 Womack 133
{~)}
2 The next unit to the right, the Plant 3
Integration Unit, had a number of subunits.
Among 4
these was a subunit of plant integrators who were 5
senior technical engineers who had responsibility 6
on active contracts to pull together interfaces on 7
work which related to different functional 8
disciplines and technical disciplines within the 9
section and within the Engineering Department as a t
10 whole.
11 In addition, there was a group called 12 -
NSS Design, and this group called NSS Design would 13 apply itself to system questions that might come 14 up that would cut across various functional 15 disciplines in other areas on an ad hoc basis.
16 There was a group called RCS.
17 Q
I don't follow that.
They.would cut 18 across.
How do they know where to cut..a nd where 19 no t to cut?
20 A
Well, if a new licensing requirement came in
~
21 or if a customer made a request or a problem was 22 identified, in any one of these ways this group
("%
23 might be asked to address it,particularly if it Q) 24 involved more than one functional discipline 25 within the department.
Womack 134
(~}
1 V
2 Q
What do you mean by a " functional
' dis ipline within the department"?
3 A
Well, safety analysis, which I have just 4
described, is an example of a functional discipline.
5 These are technical specialists in the analyses of 6
the kinds of transience and events I described to 7
o 8
Y "*
If the new requirement required new g
t analysis and if the new analysis showed, perhaps, a 10 need for additional equipment, control equipment for 11
[))
13 example, then this group might assist the design trade-offs that have to occur between the equipment 13 designers who were in another section of the g4 Engineering Department and the safety analysts who
~
15 were 1 king at the ramifications of the particular 16 criteria.
Of course, this is a fairly' specialized g7 technical business and the department was and is 18 organized as a group of units of technical experts i
g responsible for specific disciplines and specific
(
areas and the Plant Integration Unit had some generalists in it, if you will, not a great number of them but some generalists who could help in making g
23 NJ these trade-offs by addressing issues where design 24 choices had to be made between functional units.
25
.,. - ~.
1 Womack 135
~
m 2
Essentially, that characterizes the 3
whole of the Plant Integration Unit.
The other 4
three subunits, RCS Integration, Fluid System 5
Integration, and Core Integration did similar tasks l
~
6 but with a little bit more specialization in those 7
areas that their names imply.
8 The Control Analysis Unit were technical 9
specialists who looked especially at the analytical 10 basis for the plant control systems.
There special 11 province was normal operation, - rea ctivity control,
()
12 and the like.
13 Q
When you say "and the like," what do 14 you mean?
15 A
Well, calculating the quantity and 16 requirements for borated water systems for reactivity 17 control in normal operation.
18 Then the next unit is the E,CCS Analysis 19 Unit.
20 Q
Let me just interrupt so I understand 21 exactly.
22 Did you say Control Analysis deals only 23 with control of the plant for normal operation?
z1 A
For the most part, although they had certain 25 dynamic analysis techniques which could also be
1 I
Womack 136 (3
lj 2
used to analyne some limited kinds of transient.
3 and where it was economical for the expercs who had 4
these teclniques to do so, they could also supply 5
analysis for the safety analysis report.
But 6
Control Analysis' primary function was to look at 7
such questions as if the utility wanted to have a 8
higher or lower turbine bypass. capability, to be 9
able to survive a tnrbine trip without reactor r
10 plant shutdown under different conditions, they --
11 they have the capability to make such analyses.
12 Q
Are you ready to go to ECCS Analysis?
13 A
Yes.
14 Q
ECCS stands for Emergency Core Cooling 15 System and the specialty of this group was the 16 loss of coolent accident or LOCA.
17 The main province of this group was to 18 perform those analyses which demonstrated the 19 design's compliance with provisions of Appendix K 20 of Part 10 of the Code of Federal Regulations and
(,
21 10CFR 50.46, 22 Q
Was Dunn the head of that when you 23 took over?
.O J
24 A
Yes, he was.
25 Q
What is Bert Dunn doing today?
1 Womack
~ 137 2
.A lie is the manager of ECCS Analysis.
3 Q
lia s his position been unchanged since 4
August 19787 5
A Yes.
6 MR. FISKE:
Off the record.
7 (Discussion off the record.)
8 (continued on next page) 9 10 11 12
)
i 13 1
l 14 i
+
15 t
d i
16 i
l 17 18
..s x
I 19 20 4
k.
21-22 i
i 23 l
O-24 l
25 l
,1
bt 1
(~
Womack 138
\\
2 MR. SELTZER:
I would like to mark for 3
identification as GPU Exhibit 2 an excerpt 4
from the NPGD organization charts which 5
details the organization of the Engineering 6
Group as of the summer of 1978 and shows the 7
chart for Plant Design Section headed by 8
Mr.,
or Dr.
E.
A.
Womack during that period.
9 (Excerpt from the NPGD organization 10 charts detailing the organization of the 11 Engineering Group as of the summer of 1978, I) 12 showing the chart for Plant Design Section V
13 headed by Dr.
E.
A.
Womack during that 2
14 period was marked GPU Exhibit No. 2 for 15 identification as of this date.)
16 BY MR. SELTZER:
17 '
Q What contribution was it the 18 responsibility of System Mechanical Anal.ysis to 19 render in the design of a new nuclear plant?
20 A
System Mechanical, Analysis contains specialists
(
21 in the analysis of the dynamics of physical structures.
22 It was therefore their contriubtion to analyze 23 the response of NSS components to mechanical O
24 perturbations such as earthquakes.
25 MR. SELTZER:
I would like to mark for i
0'N -
2' 1
Womack 139 2
identification as GPU Exhibit 3 the 3
position description for Section Manager, 4
Plant Design Section, dated February 27, 1975.
5 (Position description for Section
]
6 Manager, Plant Design Section, dated 7
February 27, 1975 was marked GPU Exhibit 8
No. 3 for identification as of this date.)
9 Q
Is GPU Exhibit 3 a copy of the description l
10 of the position which you assumed in August of 19787 11 A
I can't tell from this whether there was a l ()
12 subsequent revision or not.
But 13 Q
Go ahead.
14 A
That's all.
15 Q
You did become the Section' Manager for 16 Plant Design, is that right?
17 A
That's correct.
i 18 Q
Under the heading down near.the bottom, 19
" Education," it says "B.S.
Nuclear-!!echanical 20 Engiheering or other applicable technical degree."
(
21 You said that you had a PhD. in astro or 22 cosmic physics, is that right?
23 A
No, sir, I said I had a PhD. in physics.
J 24 Q
And the special area was cosmic or 25 astrophysics?
3 1
Womack 140 O
v 2
A That's correct.
3 Q
You did not have a B.S.
in Nuclear 4
Engineering, did you?
5 A
No, sir.
6 Q
You did not have a B.S.
in Mechanical 7
Engineering, did you?
i 8
A No, sir.
9 Q
15 years before you became the 10 Section Manager for the Plant Design'Section, what 11 were you doing?
(
12 A
I was studying at the Massachusetts 13 Institute of Technology.
14 Q
What was the division of responsibilities 15 between the group that reported to you=known as 16 Control Analysis and the division that reported 17 to the Manager of Engineering known as Control and 18 Instrumentation Engineering?
19 A
The-section which reported to the Engineering 20 Mana'ger known as control and Instrumentation
(,
21 Engineering was responsible for control and 22 instrumentation equipment, primarily for its 23 procurement and specification of equipment.
f)i
\\-
24 The control analysis unit which reported 25 to me was responsible for performance analysis of
w 4
1 Womack 141 2
this equipment operating in conjunction with other 3
parts of the nuclear steam system and through that 4
performance analysis for setting performance 5
requirements.
6 Q
Which of the sections reporting 7
to you, if any, would have responsibility for 8
the pilot-operated relief valve?
9 A
The pilot-operated relief valve would u
10 not be within the responsibility of the Plant 11 Design Section.
[)')
12 Q
Who would own up to having responsibility 13 for the pilot-operated relief valve?
14 MR. FISKE:
I object to the form of 15 the question.
16 Q
Whose responsibility would be the 17 pilot-operated relief valve?
18 A
The pilot-operated relief valve would be the 19 responsibility of the Fluid and Mechanical Systems 20 Section.
(,
21 Q
That section also reported to the Manager 22 of Engineering?
23 A
Yes.
V 24 Q
At any time prior to the Three Mile 25 Island accident, did you ever have occasion to examine
. - _ _, _. ~
/~S 5
1 Womack 142 U
2 in any way the operation of the PORV?
3 A
Not that I can recollect.
4 Q
How do you know that the PORV was the (r
5 responsibility of the Fluid and Mechanical Systems 6
Section?
7 A
Because that section has responsibility 8
for valves procured from -- for B&W in NSS: that 9
means the nuclear steam system.
i 10 Q
Which, if any, section in the 11 Engineering Group would be responsible for the
()
12 instrumentation of the pilot-operated relief 13 valve?
14 A
The control and instrumentation section.
15 MR. FISKE:
This is, I take it, 16 or your question is -- is it fair to say 17 your question is within B&W?
18 MR. SELTZER:
Yes.
19 MR. FISKE: Who, what part of B&W 20 would deal with that subject?
You are not
(.
21 asking him, or you are not assuming 22 in your question where the ultimate 23 responsibility for that instrumentation 24 lay as between B&W and others?
25 MR. SELTZER:
That's correct.
w 6
1 Womack 143 2
I just want to know prior to the 3
accident what was his understanding of what 4
section of the B&W Engineering Department would 5
have responsibility within B&W for 6
instrumentation of the pilot-operated relief 7
valve.
8 A
To the extent that instrumentation for 9
that valve was a part of B&W's scope, it would be 10 the Control and Instrumentation Sect on.
11 Q
Have you come to know since the x
( }
12 accident occurred to what extent, if any, B&W 13 personnel function had on the instrumentation 14 attached to the pilot-operated relief valve in the 15 TMI-2 plant prior to the accident?
16 A
No.
17 Q
Do you have any information.about 18 the extent of B&W's involvement in the.
19 instrumentation of that valve prior to the 20 accident?
(,
21 A
None that I can recall.
22 Q
Let me put it to you slightly 23 differently.
24 If Mr. MacMillan asked you what do you i
25 know about B&W's involvement in the instrumentation m
i
f) 7 I
Womack 144 N/
2 of the PORV at Three Mile before the accident, 3
what would your statement to him be?
4 MR. FISKE:
Well, I will object to 5
the form of that question, Mr. Selzer.
6 I mean, he has just you asked him what 7
he knew about it and he has answered it.
8 I don't think it helps to put it in terms 9
of a hypothetical question from Mr. MacMillian 10 on the assumption he would just answer that 11 differently than he has answered you.under e-k,)s 12 oath.
13 Q
could you try and answer that, please?
14 A
No, I don't think I have anything to add s
15 to what I have already said.
1G Q
Have you ever discussed with anybody 17 what involvement, if any, B&W had in the 18 instrumentation associated with the PORV at Three 19 Mile Island Unit 27 20 A
In terms of B&W's involvement, I don't 21-think I have discussed that specific question.
22 Q
Have you discussed the issue of 23 instrumentation of the PORV at Three Mile bland 24 Unit 2 generally with anyone?
25 A
Oh, yes.
8 1
Womack 145 2
Q Have you discussed with anyone the extent, if any, to which B&W was involved in 3
decisions relating to the instrumentation of 4
the PORV7 5
6 MR. FISKE:
Mr. Seltzer, he just finished answering virtually that exact question.
7 g
MR. SELTZER:
Virtually.
MR. FISKE:
He has told you that he 9
t-10 doesn't recall discussing B&W's involvement in the instrumentation.
I think that 11 12 is what he just said.
13 MR. SELTZER:
He said he didn't 14 recall specifically, but I am trying to find 15 out whether generally he discussed B&W's 16 role.
I believe that he did.
MR. FISKE:
' lou believe he what?
17 18 MR. SELTZER:
I believe he did.
19 MR. FISKE:
Did what?
MR. SELTZER:
Discuss generally 20 B&W's role in the implementation of the 21 PORV.
22
('
23 A
I could certainly say I have discussed the instrumentation of the PORV but I can't recall 24
~
25 specific discussion which part of that B&W I
~s 9
1 Womack 146 2
provided or might have contributed to provide as 3
Opposed to parts of the instrumentation that they 4
did.
I am trying to be precise.
I certainly 5
have discussed the instrumentation of the PORV.
6 Q
Have you discussed with anyone the 7
lack of any direct indication of valve position?
8 A
Yes.
9 Q
Have you discussed the role,.if-any, of L
10 B&W in arranging instrumentation that fails 11 to show direct valve position?
(
12 A
I don't recall specifically discussing 13 that point.
14 Q
Do you recall discussing it generally?
15 A
I recall discussing the indication provided 16 for the position of the pilot-operated relief valve, 1
17 yes.
18 Q
With whom did you have such discussions?
19 A
Probably with Mr. Taylor.
20 Q
And to the best of your recollection,
(,
21 what did you and he discuss?
22 MR. FISKE:
Well, I am not sure that 23 Mr. Womack even has said he recalls discussing CE) l 24 it with Mr. Taylor.
I think he said he 25 probably did.
I f
i 10 1
Womack 147 I w) v 2
MR. SELTZER:
Good.
3 And I want to know what he probably 4
discussed with him to the best of his 5
recollection.
6 MR. FISKE: I will object to the question 7
certainly in that form.
8 MR. SELTZER:
I am entitled to his best 9
recollection of any discussion that he had t:
10 regarding the lack of instrumentation of 11 direct valve position.
(
12 MR. FISKE:
You certainly'are but not 13 to any pr'obable discussion.
14 A
Are you asking for the best, my best 15 recollection?
16 Q
Yes.
17 A
My best recollection of my understanding 18 of these discussions was simply to understand 19 that the pilot-operated relief valve position 20 indication at TMI was an indication of the
(,
21 commanding signal to the pilot for the valve 22 operator, and I cannot recall for you at this point 23 in time exactly how and from whom I received that gSV 24 information, whether it was from specific oral 25 discussion with individuals, or whether it was l
I Womack 148 2
from reading written material subsequent to the 3
accident.
That's my difficulty.
4 Q
O.K.
5 MR. FISKE:
Could I hear the answer 6
again, please?
7 (Answer read by She reporter.)
8 MR. FISKE:
Mr. Seltaer, if I can make i
9 a suggestion which, of course, you are free 10 to take or not take, this is your 11 deposition, but I think it is in the interest
(-wL 12 of maybe making a constructive suggestion
-Q 13 that will save us all a lot of time.
14 MR. SELTZER:
Sure.
15 MR. FISKE:
When Mr. Womack tells you 16 that the responsibility for this valve l
1 17 and the instrumentation was not in his 18 section but was in somebody else's, it is 19 obvious there is going to be somebody 20 within B&W that can give you a direct answer 21 to this question, and it is obviously a fact 22 that it is going to be very easy to establish 23 and you will get the person but to spend a O
24 lot of time with Mr. Womack in terms of who he j
25 can recall discussing this with, what his
p 1
Womack 149 V
2 recollection on it.is, and it is very 3
vague, and it wasn't his responsibility in 4
the first place seems to me we are wasting 5
some time.
I am not going -- I haven't 6
instructed him not to answer.
You are entitled 7
I am sure under the rules to do this, but I 8
just think that in the long run we are all 9
going to waste an awful lot of, time if -- you 10 know, once you have ascertained what his areas 11 of expertise are, you don't reasonably confine 7-m
(,)
12 yourself to those.
13 Having said that to you, you may do 14 whatever you think you should do and I will 15 do whatever I think I should do.'
16 MR. SELTZER:
I knew you would.
17 Q
At the time of the Three Mile Island 18 accident, have you come to learn, or were you aware 19 then of whether any other B&W plants had installed 20 instrumentation which indicated directly the 21 position of the pilot-operated relief valve?
22 THE WITNESS:
Could you read the
(~g 23 question back to me, please?
V 24 Q
The question simply is, do you know 25 of any other B&W plant that had a direct indication
-w,
a O
1 Womack 150 i
2 of PORV valve position at the time-of the TMI-2 accident?
3 4
A No, I do not.
C}
5 Q
Do you have any knowledge of whether 6
the Muelheim-Kaerlich plant had been 7
designed to have direct indication of PORV 8
position?
A My belief is that it is not.
It does not 9
c 10 have such indication.
We have referred to direct 11 indication in these questions.
I have been assuming 12 that you have been referring to directly indidating 13 mechanical information.from the valve disk.
14 (Continued on next page.)
15 16 17 18 19 20 21 22 C) 24 25
o IL) 1 1
Womack 151 2
Q You are very good to have made 3
that qualification.
I appreciate that very much.
(
4 That wasn't what I meant.
I meant 5
any reliable indication of the open and closed 6
position of the. valve that would give a positive 7
reading of whether it was open or closed, 8
including an acoustic reading or some other 9
direct reading, as opposed to merely reading the 10 position of the solenoid or the pilot, as you 11 called it.
s-
.12 A
Oh, well, in that case I think I would.have 13 to review my answers.
14 I believe that from what I have 15 understood since the accident, that the discharge 16 thermocouples on that valve provide an ample
~
17 direct reading indication of the passage of 18 pressurized water through that valve. -
19 Q
Did any --
20 A
Would you --
21 MR. FISKE:
You have answered it.
22 Q
It's a fact, isn't it, that
/~T 23 immediately subsequent to the Three Mile Island b
24 accident, B&W recommended the modification of 25 its nuclear plants to include more direct
I Womack 2
indication of the position of the pilot-operated 3
relief valve?
(
4 MR. FISKE:
Just a minute, Mr.
5 Seltzer.
Number one, when you say "B&W,"
I 6
am not quite sure who you are referring tor 7
and secondly, when you say " recommended,"
f 8
I am not quite sure who you mean they 9
recommended it to.
I think you should 10 clarify that.
11 MR. SELTZER:
I would be happy to.
c')
(s 12 Q
By " recommended," I mean recommended 13 to the operators of its nuclear plants, and by 14 "B&W" I mean the company that you work for.
15 MR. FISKE:
The question is, did 16 they recommend to the operators what?
17 Q
Did B&W send out an official 18 recommendation that their nuclear steam systems 19 that they sold be modified in one of several 20 alternative ways to include a more direct 21 indication of the open or closed position of the 22 pilot operator relief valve?
23 A
I believe we have supplied such 24 recommendation in support of our custo.ners; I 25 believe that is in conjunction again with requests i
I 7S 153 1
Womack Q3 2
and from the NRC in connection with the so-called lessons-learned evaluation.
3
(
4 Q
Each of the operators o f your plants,
5 to the best of your knowledge, already had 6
thermocouples in the discharge liner right?
7 A
Yes.
8 Q
So it's a fact, is it not, that the 9
alternative methods for getting a more direct 10 indication of valve position were in addition 11 to the thermocouples in the discharge liner right?
12 A
Yes.
13 Q
Do you know whether prior to the 14 Three Mile Island accident any of the B&W plants 15 had already installed any of those alternative 16 indications of position of the pilot-operated 17 valve?
18 A
No.
19 Q
No, you don't know, or no, none of 20 them have?
21 A
No, I don't know.
22 Q
Prior to the accident during the time 23 that you were head of the Plant Design Section,
()
24 what if any regular reporting was done from your 25 unit heads to you?
J - -
l 154 1
Womack 2
A Regular monthly reports were filed by 3
each unit manager.
4 Q
Was there a particular format 5
prescribed for those reports?
6 A
Yes.
7 Q
Could you describe that format, 8
please?
9 l A
The format had substantial flexibility, 10 but it was generally to report accomplishments 11 in the preceding month, any new problems in the
-s N
12 preceding months that had como up or deviations 13 from previous commitments and status reports on 14 problems that were in consideration or in work.
15 Q
Is this a reporting procedure that 16 you inaugurated or had Dr. Roy had this same 17 procedure before you?
18 A
It existed when I came to Plant Design.
19 Q
When you took over as Manager of the 20 Design Section, did you make any attempt to
/k 21 review prior monthly reports to see what the 22 sections had been doing and what open items 23 remained?
24 A
Not through the method of reviewing 25 monthly reports.
e q
m w
w
-es
,ne
-e-
-w-
155 r~%'5 1
Womack (s_/
2 Q
What did you do to review what work l
3 I was in progress and what remained uncompleted?
4 A
Dr. Roy talked to me about issues that he
(
5 considered important.
6 Q
Did Roy mention to you that still 7
unresolved was the Dunn recommendation that the 8
operating utilities be advised about not 9
terminating high-pressure injection,under 10 circumstances such as had occurred at Davis-
'll Besse?
12 A
No, sir, to the best of my recollection he 13 did not.
14 Q
Prior to the TMI-2 accident, did 15 anybody raise with you the fact that that was 16 an unresolved issue?
17 A
To the best of my recollection,'no one did.
18 Q
Have you ever looked back-in the 19 monthly reports from the ECCS Unit to see 20 whether Mr. Dunn had indicated his concern about L
21 getting out such an advisory to utilities in his 22 monthly reports?
23 A
No, I haven't.
21 Q
Were you the only one who would 25 receive the monthly reports from your unit heads?
156 A
1 Womack 6
i V
2 A
No.
I believe that the'y shared those I
3 reports among themselves and may have given 4
copies to others.
(
5 Q
What did you do after you received G
those monthly reports?
What did you do with them?
7 A
I asked my advisory engineer, Mr. Parks, 8
in most instances to review them, select 9
important issues for my attention and important c
10 issues to be reported in my report to Dr. Roy.
11 Occasionally I did this myself.
12 Q
With what regularity did you report 13 to Roy?
2 14 A
Monthly.
15 Q
Do you know whether any of the Unit 16 Managers received periodic reports from the 17 people within their Units?
18 A
No, I don't.
I 19 Q
Where would you look if you now wanted 20 to review again the monthly reports that you were
(
21 receiving from your Unit Managers?
i l
22 A
In the shelf files of the Plant Design or I
('T 23 Plant Engineering Section.
\\_/
21 Q-Just to clear up my confusion, when 25 Roy left the Plant Design Section, he became the
(
7 1
Womack 157 2
head of something called Engineering.
Now you 3
say they have changed the name of Plant Design 4
to Plant Engineering.
To what entity does what's
(,
5 now called the Plant Engineering Section report?
6 A
To Dr. Roy.
7 Q
And what is his group called?
8 A
Dr. Roy is the Manager of the Engineering 9
Department.
10 Q
So the Plant Engineering Section 11 reports to the Engineering Department?
O(_)
12 A
Yes.
13 Q
Even at the time that you were head 14 of what is called the Plant Design Section, it's 15 a fact, isn't it, that there were other sections 16 that were responsible for elements of plant 17 design, isn't that correct?
18 A
Yes.
19 Q
If you wanted to retrieve now copies 20 of'the monthly reports that you cent to Roy, 21 would you also expect to find those in the vertical 22 files of the Plant Engineering Section?
23 A
Yes.
24 Q-other than the monthly reports from the 25 Unit Managers, what other documents did you
4 158 O
i Womack l
regularly receive from within your section?
2 l
3 A
None come to mind.
4 Q
What types of reports or memoranda
(.
5 did you receive on an irregular basis?
6 A
That's a very broad question.
Any 7
engineer or manager reporting to me was free to 8
report to me on any subject he wished.
9 Q
Were there some engineers reporting 10 to you who were more frequent correspondents 11 than others?
O 1
12 A
Yes.
13 Q
Who was one of your more frequent 14 pen pals, if I can use that colloquialism?
15 A
I couldn't tell you.
16 Q
Who ranked up there, who were some 17 of the people who liked to write a lot of memos 18 to you?
l 19 A
Well, my staff, certainly those managers who 20 reported immediately to me, would be the most 21 frequent.
I l
22 Q
Who would that be?
23 A
Mr. Labelle, Mr. Karrasch, Mr. Davis at 24 that time, Mr. Dunn, Mr. Carlton, Mr. Galford, i
25 and.Mr. Parks.
. _.-,,.f__,..-
159 I
Womack 2
Q What was Parks' role?
3 A
Parks is an advisory engineer.
4 Q
of the people who reported to those
(,
5 Unit Managers, which engineers tended to write 6
to you from time to time?
7 A
I can't recall specific and particular 8
engineers.
9 Q
Nobody stands out as being somebody 10 you used to get memos from?
11 MR. FISKE:
You asked him who stood 12
- out, Now you asked him who tended to write 13 from time to time.
14 A
At one time or another I have had -- I 15 probably had memoranda from -- between 30 and 50 16 percent of the engineers in the section either by 17 copy, much more frequently by copy then by direct 18 address.
19 (Continued on next page.)
20 21 22 O
24 25
/~'s i
Womack 160 V
i I
2 Q
Other than the monthly progress 3 ;
reports that you would send to Dr. Roy, were 4
there any other reports generated on a periodic 5
basis by your section that were sent elsewhere 6
within B&W7 7
A None come to my mind.
8 Q
What reports did you receive on a 9
regular basis from other sections or departments 10 or divisions within B&W?
I don't mean to be 11 restricted by those group titles.
I mean what n
(_)
12 periodic reports did you get from anybody in B&W 13 who was not in the Plant Design section?
14 A
I believe that I regularly received the 15 monthly reports of the other engineering sections 16 for the most part.
17 I also received copies of.Dr. Roy's 18 report to Mr. MacMillan and I also from time to 19 time would receive reports frcm the Project i
20 Management Department and from the International 21 Project Management Department.
22 Q
What other reports did you get?
)
rT 23 A
I may have received the Customer Service N]
24 Department's reports as well.
25 Those are the ones that come to my
,.-,.,-m.,-,-
't' 1
Womack 161 0('
2 mind.
l Q
What types of reports did you get 3
i 4
from the~ Service Department?
similar 5
A.
Monthly reports similar to the 6
to those files by other departments.
7 Q
Did.you get site problem reports 8
from the Service Department?
9 A
Site problem reports were rarely addressed e
10 to me.
11 Q
Did you get summaries of field
()
12 operation reports from the Service Department?
13 A
Yes.
14 Q
Did you get those on a regular basis?
15 A-Yes.
16 Q
Did you get reports on plant operational 17 status prepared by the Service Department?
18 A
Those were embodied in the same report.
19 Q
How frequently did you get those reports?
20 A
I think those reports actually came out 21 weekly.
22 Q
What would you do with those reports 23 on summaries of field operation and plant 24 operational status when you received them each 25 week?
I 1.
I 162
/
1 Womack i
3 A
Review them.
If an item of interest 3
appeared in them, I might make a special notation I
or ask someone about it and generally would then
.g i
pass it for routing to my staff.
5 G
Q What were you looking for in trying to identify items of interest?
7 l
A Looking for any information about the
~
8 operation of our plants which could help me do my g
t 10 job better.
11 Q
Like what?
(
12 A
Problems that might be causing plant 13 outages or forced shutdowns.
t.
Q Would failure to close a pilot i
15 operator relief valve be of interest if it had 16 shown up in these reports?
A Yes.
17 4
18 Q
Why?
A Because such a failure would cause a plant 19 outage.
20
(-
Q And it would also cause a loss of 21 coolant, is that right?
22 23 A
It would cause a loss of coolant from the C1 I
3; system, yes.
25 Q
And thrab's another reason why it
---,-v,
.-,,y..,
.163 1
Womack 2
would be of interest to you, isn't that right?
A Yes.
3 4
Q Who was the head of the Plant Service 5
Department at the time you were head of Plant 6
Design?
A Kosiba.
7 8
Q Since Kosiba was somebody that you knew from the AEC, did you remain in close touch 9
10 with Kosiba when the two c' you came to B&W7 11 A
Yes.
12 Q
Did you see him socially?
13 A
Yes.
14 Q
Do you still see him socially?
A Y.e s.
15 16 Q
Would you have lunch with him from time to time?
17 18 A
Yes.
19 Q
Did you discuss operational matters 20 with him during the period that you were the Plant Design Manager?
21 l
22 A
Yes.
23 Q
Did he discuss site problems and field 24 Operation and plant operational status with you?
25 A
Yes.
.~, _.__
164 Womack 2
Q And would yqu discuss-items of 3
interest in your Plant Design work?
4 A
Yes.
5 Q
To what extent did you have contact 6
as Plant Design Manager with personnel at utility 7
companies?
Let me make it easier for you.
8 What percentage of your time would you 9
say was occupied in communication with personnel e.
10 from utility companies during the time that you 11 were Manager of Plant Design and prior to the
()
12 Three' Mile Island accident?
13 A
Five percent, perhaps.
14 Q
Did you attend, prior to the accident, 15 meetings with owners' groups?
16 A
I don't recall attending such a meeting prior 17 to the accident.
18 Q
Did you attend, prior to the accident, i
19 any meeting with users' groups?
20 A
I can't recall.
If I did, it was perhaps 21 one such meeting.
thejdiffedence between the 22 Q
What is
..s 23 owners' group and th'd' users ' group?
l 24 A
> I am not sure I can define that for you
' 25 best, but one grobp represents both the utilities
[
-e L
165
(~N, I
Womack V
2 which own B&W -- which h, ave B&W operating' plants which have operating licenses and the other group 3
who 4
represents those people plus those who are 5
have B&W plants under construction, and I can't 6
right now tell you which is which.
7 Q
Are you positive that that's the 8
distinction between the two groups?
9 A
That's the distinction, to the best of my 10 understanding.
11 Q
Which group is which?
-~
12 MR. FISKE:
He just said he.didn't
^
13 know.
He also said he probably isn't the best 14 one to give you the information.
15 Q
Did you say that?
16 A
Yes, I did.
17 THE WITNESS:
Did I say that?
18 Q
In the halcyon days before,the TMI 19 accident, did you have any direct contact with 20 individual utility companies as opposed to meetings 21 with utility groups?
22 A
Yes.
s
('}
23 Q
Did you have any contacts with V
24 Met Ed?
25 A
During the period of kigust 7th to' the 28th s
a y
.w
t I'S 1
Womack y
2 of March '797 3
Q Yes.
Q 4
A I don't think I had direct contact about 5
Metropolitan Edison.
.6 6
Q Did you have any indirect contacts
?
7 with Met Ed?
8 MR. FISKE:
What is indirect?
9 MR. SELTZER:
Any contact that is 10 not direct.
I was just keying in on his 11 choice of that adjective.
12 MR. FISKE:
Do you understand th,d 13 question?
14 THE WITNESS:
I can answer it if he 15 is seeking clarification of my qualification, 16 A
Members of my staff and of the division 17 staff were in contact with staff of Metropolitan 18 Edison ~on a couple of -- well, I only remember 19 one matter.
20 Q
What matter?
21 As No, there were two that I can recall at 22 that period of time.
One was related to flow 23 indications in the primary system which appeared 24 to be slighly low and were leading the utility i
25 to operate the plant at a slightly reduced power
1 Womack 167 O
2 and we were trying to es,tablish whether these 3
indications were real or not."
4 The other was in the matter of the 5
injection of sodium hydroxide into the primary 6
system, sodium hydroxide is a caustic.
7 Q
Prior to the TMI accident and while 8
youkere acting as Plant Design Manager did you 9
visit any -- did you make any field visits to L-10 B&W supplied nuclear plants?
]
11 A
No.
Not that I recall.
12 Q
Prior to the TMI-2 accident, had,'you 13 ever participated in simulator training?
14 A
Yes.
15 Q
For how many days, if days?
16 A
Four or five.
17 Q
Were those four or five days together 18 or four or five days over a much longer period?
19 A
Together.
20 Q
when?
21 A
During the period of time I was Manager --
22 Program Manager for the Muelheim-Kaerlich plant.
i 23 Q
Who, if anyone else, was receiving O
1' 4
24 simulator training at that time?
25 A
It was a group of engineers from the BBR
.w-
-r..r, 4,-.
168 r
I Womack
- (
2 Company.
1 3
Q Was there classroom instruction 4
that accompanied your simulator training?
5 A
Yes.
6 Q
Who was in charge of that training d
7 progran?
8 A
I don't recall.
9 Q
Was Elliott in charge?
5 10 A
Elliott did not give these lectures, to my 11 recollection.
12 Q
Did you actually have hands-on 13 experience in the simulator?
14 A
The group had a limited amount of hands-on 15 simulator work, yes.
16 Q
Did you personally have any hands-on 17 experience in the simulator?
18 A
Yes.
19 Q
Were any plant transients simulated 20 while you were standing at the control panel?
21 A
Yes.
22 Q
How many?
/~%
23 A
Perhaps four or five.
l km 24 Q
How long did it take to run through 25 those four or five transients?
1 Womack 169
)
2.
A Well, the transients probably took, I I
I think we got about two hours of
~3 imagine 4
simulator time for each of the five days.
C 5
Q That's the whole group?
6 A
Yes.
7 Q
So the time spent by any one person 8
at the control panel handling a simulator 9
transient was less than the time for the total t
10 group, right?
11 A
I think your question may reflect.a 12 misunderstanding'of the training mode.
13 Q
Tell me.
14 A
The simulator training is done for a group 15 such as this as a group.
All members of the 16 training class participate simultaneously in 17 the simulator.
18 Q
How big was the group?
19 A
six, I think.
20 Q
Were any feedwater transients 21 simulated?
22 A
Feedwater control was simulated, yes.
r 23 0
were any loss of feedwater transients (x
21 simulated?
25 A
I can't remember whether that was one that
170 I-Womack
[ ))
'w 2
was or not.
3 Q
Was the failure of a PORV simulated?
4 A
I am relatively certain that it was not.
(-
5 Q
Do you think that would have stuck out 6
in your mind if you think back on it?
7 A
No, I don't think it would have.
8 Q
It's correct, isn't it, that to the 9
best of your knowledge the simulator was not then e
10 programmed to simulate a failure of a pilot 11 operator relief valve, isn't that correct?
12 A
I have been told that subsequently.
13 Q
You don't have any reason to doubt 14 it, do you?
15 A
No.
16 Q
So that's why you were able to state 17 fairly positively that you believe you hadn't 18 simulated a PORV failing, is.that right?
1 19 A
That's correct.
20 Q
You testified that in February 1980 21 you became manager of Plant Engineering, is that 22 right?
(~}
23 A
Yes,,I did.
V 24 Q
Is that just a shift in the title 25 of the section or a shift in the position that
I Womack
, 1.7 1 l (~'
2 you held?
i 3
A It's a shift in the responsibilities of the 4
section that I managed.
(.
5 Q
In February of 1920, was there l
still a Plant Design section?
6 7
A No.
8 Q
When did the Plant Design Section 9
become the Plant Engineering Section?
10 A
In February 1980.
11 Q
At that same time were the -
(
12 responsibilities of the section changed?
13 A
Yes.
14 Q
In the middle of July 1980, you 15 became the manager of Reactor and Fuel 16 Management Department, is that right?
17 A
That's correct.
18 Q
To whom do you report?
19 A
To Doug Guilbert.
20 Q
Who became the Manager of the Plant 21 Engineering Section?
22 A
Mr.
D.
E.
Lee.
s 23 Q
What had Mr. Lee's position been
\\_
24 previously?
25 A
Manager of Fluid and Mechanical Systems.
172.
'r'%
g Womack
( )
2 Excuse me.
At the time,of the February 1980 rganization change.some of these section titles 3
4 were changed.
I believe Mr. Lee's title was
.C 5
Manager Equipment Engineering.
6 Q
When was his title that?
7 A
At the time -- at July 1980.
8 Q
In terms of the organization of B&W 9
is your move in July 1980 a move to a comparable e
10 position as Manager of the Plant Engineering or 11 is it an elevation?
('
12 A
It's an elevation.
13 Q
What are your principal responsibilities g4 in your current position?
15 A
I am responsible for the management of 16 several business segments of our division, I am 17 responsible for the management of the, contracts 18 for nuclear steam supply systems with our so-called 19 backlog customers, these are the customers whose 20 plants do not yet have operating licenses, are not 21 yet completed, they are under construction.
22 I am responsible for the management of our 23 fuel supply business for all of our customers, this includes the operating plants and the plants 24 i
that are yet to be operated.
I am responsible l
2.r, l
4 A
/T I
Womack (f
2 for our international business and I have a unit 3
segment of my department which provides the 4
continuing support of the Babcock & Wilcox Company 5
to the General Public Utilities Corporation for the 6
recovery of the TMI-2 reactor plant.
i 7
Q What does that mean, recovery of the 8
TMI-2 plant?
9 A
Those operations which are being conducted E
l 10 by Metropolitan-Edison and GPU to cl'ean up the J
11 waste water and evaluateLthe components and b
12 potentially restore the plant to service.
g_j 13 Q
Do you have any involvement in the 14 proceedings to restart TMI Unit 17 r
15 A
No.
16 Q
Who has principal responsibility for' 17 that?
t 18 MR. FISKE:
You'mean within B&W7 19 MR. SELTZER:
Yes.
20 A
I believe the individual who has the lead 21 responsibility on the day-to-day basis is a 22 gentleman by the name of David Holt.
23 Q
what is his position?
\\%-
24 A
I believe he is in the Project Engineering 25 Section.
.O.
174 1
Womack 2
MR. FISKE:
,I think, Richard, when you 3
get to a convenient breaking point, I just 4
assume we not go too long.
He has this 5
cold, you know, finish whatever you are on.
6 MR. SELTZER:
Off the record.
7-(Discussion off the record.)
8 BY MR. SELTZER:
9 Q
When you were the Manager of the
(-
10 Design Section, did the section have files that 11 were maintained as the Design Section files?
()
12 A
No.
13 Q
Did each of the units or any of the i
14 units maintain unit files?
15 A.
Yes, I think some did.
16 Q
Do you know which did and which did 17 not?
18 A
No.
i 19 Q
Do you know if Bert Dunn's unit 20 maintained central files?
(-
21 A
I don't know offhand.
22 Q
What about Karrasch's?
23 A
I don't know offhand.
Each unit would maintain some files such as personnel records.
I 24 25 Presume you are looking for dasign files.
1 Womack 175 2
Q Design and operation files.
t 3 !
Did your section as a matter of l
4 routine send files to any central file location 5
within B&W?
6 A
Yes.
7 Q
Where was that central file location?
8 A
Physically?
4 9
Q Yes.
L 10 A
I believe they are located in the basement 11 of our rear building.
12 Q
What is that central depository. called?
13 A
Central Files.
14 Q
Had it generally been your practice j
15 as a Manager at B&W to maintain a chronological 4
16 file of your correspondence and memos?
17 A
Yes.
i 18 Q
From your familiarity with,B&W, do l
19 most Managers maintain a chronological file?
20 A
I can't confidently answer that question.
(,
21 Q
Does your friend, Mr. Kosiba, maintain 22 a chronological file, to the best of your 23 knowledge?
O
~'
24 A
I don't know.
4 i
25 Q
Among your unit managers from the time t
1 Womack 176
(~N v
2 when you were the head of the Design Section, 3
were you aware of whether some of them were 4
maintaining chronological files,for example, 5
did you ever have to go back and ask them for a 6
memo that they had written a while ago and find 7
the best way to get a copy was from their 8
chronological file?
9 A
I believe that some were, yes.
t 10 Q
Some were.
Do you remember which 11 ones kept chronological files?
(_/
12 A
No.
Perhaps they all did.
t 13 Q
Do you know whether Mr. Roy kept a 14 chronological file when he was Plant Design 15 Manager?
16 A
I believe he did.
17 Q
Do you believe that he still maintains 18 a chronological file as the head of the 19 Engineering Department?
20 A
I am not sure.
21 Q
Is it correct that your chronological 22 file was microfiched in substantial part?
23 A
That's correct.
24 Q
Were hard copies maintained of that 25 file?
1 Womack 177
(-
'%.J.
2 A
No.
I believe I threw them away.
g 3
Q When did you throw them away?
4 A
I don't recall exactly when I asked -- when 5
I had them microfiched but we needed more file 6
space and these old files were bulky and I had-7 them microfiched and with the specific intention 8
of removing the hard ccpies.
9 Q
When, just approximately when, was that 10 done?
Since the Three Mile Island ccident?
11 A
Yes.
(v 12 Q
Within the last half year?
13 A
No.
Earlier.
14 Q
In addition to your correspondence 15 files, what, if any, other files did you have 16 microfilmed or microfiched?
17 A
I don't recall.
There may have been some 18 others.
I don't recall what they were,specifically.
19 Q
Did you have any of your s ub j e c't 20 matter files microfilmed or microfiched?
(
i 21 A
I suspect so, yes.
22 Q
Did you throw away the hard copies of 23 those subject matter files after you had the v
24 microfilming done?
l 25 A
I am relatively confident that I did.
4
,_-,...,.m,
,_-__,,,.,--.s_
(~S 1
Womack 178 N.]
2 Q
Do you know whether others around 3
B&W have been economizing on filing space by 4
having their files microfilmed or microfiched?
C, x
5 A
No.
No, I don't know.
6 Q
This was just an E.
A.
Womack idea?
7 A
No, we urged people to utilize this as a 8
means of savings things that they felt they needed 9
to save.
t 10 Q
Is the secretary who is presently 11 with you the same secretary you had when you were
()
12 the Plant Design Manager?
13 A
No.
14 Q
What did you do with'your files when 15 you left what was the Plant Design Section and 16 became the Plant Engineering Section?
17 A
I reviewed them against the document request 18 which was at approximately that time being made to 19 us and sent those that I thought were responsive 20 to the document request to our Contracts Legal k.
21 Department.
The balance I either took with me 22 as personal reference material to my new job 23 location or left for my successor in Plant uJ 24 Engineering for his use.
25 Q
I take it you had a copy then of the
k Womack 179 ic 1
gS N) t 2
r' quest for production of documents served by 3
GPU on B&W7 1
4 MR. FISKE:
I am not sure he is talking u
about the same o n e..
If I understand this 5
6 correctly, he changed jobs in February of 1980.
7 8
THE WITNESS:
No.
MR. SELTZER:
No, he didn't, that was 9
i.
10 just a title change.
MR. FISKE:
Oh, I see.
I am sorry.
11 i
12 MR. SELTZER:
Off the record.
'J 13 (Discussion off the record.)
14 BY MR. SELTZER:
15 Q
You were talking about the potition i
16 change that you had in July of 1980, right?
17 A
Yes, that was the question you asked.
18 Q
That's right.
MR. FISKE:
I misunderstood.
I thought 19 20 yu asked him when he went from Manager
(-
f Plant Design to Manager of Plant 21 Engineering.
22 MR. SELTZER:
No.
I don't believe 23 he was confused by that.
24 25 Q
Were you?
("g 1
Womack 180 V
2 A
No.
.Because I did not physically relocate 3
at that time.
4 MR. FISKE:
Could you just read the 5
question back.
I want to make sure the 6
record isn't confused here.
7 (Record read.)
8 THE WITNESS:
I did answer the 9
wrong question.
t 10 BY MR. SELTZER:
11 Q
No, you knew what I meant.
What I O
t k~ej 12 meant was to be asking what I understood you 13 answered was when you left the department that was 14 the Plant Engineering Section that had changed its 15 name from Plant Design Section and you became the 16 Manager of Reactor and Fuel Mnaagement, you told 17 me you reviewed your files then.
18 A
Yes, I did.
10 Q
And you said that you reviewed them 20 in light of the request for production of.
(,.
21 documents in this litigation.
Right?
22 A
Yes, I did.
23 Q
Did you have a copy of the request for
\\,
s 24 production of documents which GPU had served on 25 B&W7
f'N I
Womack 181 U,
2 A
No,-I don't believe I had that actual 3
document.
4 Q
Did you have something that described 5
or purported to describe.what' was requested?
6 A
los.
7 Q
And you peraonally reviewed your 8
files to determine what you believed was 9
responsive?
t 10 A
Yes.
11 Q
The last question:
You said that in 12 the Plant Design Section's shelf files you would 13 have all the unit managers' monthly reports.
14 What else would have been kept or 15 was kept on the Plant Design shelf files?
16 A
Well, let's see.
References on computer 17 listing of scope of supply, standard proposals, 18 standard plant, general references of the sort that 19 might be useful to the Manager of Plant Design or 20 Plant Engineering or his secreatry.
21
(
By " secretary," you don't mean the 22 person who sits at a typewriter and types, do you?
('}.
23 A
Yes, that's what I meant.
NJ 24 Q
On the chart where it shows secretary, 25 that's a stenographer in GPU Exhibit 3 marked
1 4
1 Womack 182 v
i 2
for identification?
i i
3 A
The secretary to the Manager of Plant-4 Design in GPU Exhibit 3 is an office secretary.
5 She takes dictation and. types, keeps files, records, 6
makes travel arrangements and so forth.
l 7
MR. SELTZER:
Why don't we resume 8
tomorrow morning at 9:30, if that's 0.K.
9 MR. FISKE:
Fine.
t 10 (Time noted:
4:45 p.m.)
i
^
11 i
)
12
.)
4 13 l
14 15 Subscribed and sworn to before me 16 this____ day of____________,
1980.
17 18 t
i 19 20 l
L 21 22 i
24 i
e L
,, -..,. -. -.. ~,
- - -. - ~ -, -. -.. ~. - _ _, _. _. -. -
I 183 l
OV.
2 egRg1Fgeggg 3
STATE OF NEW YORK
)
Ss.:
1.,
4 COUNTY OF NEW YORK )
~ k,.,
5 6
CHARLES SHAPIRO, C.S.R.
3,
,a 7
Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9
op EDGAR ALLEN WOMACK, JR.
Was taken D'efore 5
10 December 8, 1980 me on 11 That the said 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 i
That I am not connected 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.
1
,[ ' (,,
IN WITNESS WHEREOF, I have hereunto set 20 VB my hand this II day of hE r.6(n Eta.
1980.
t-21 i
- 22 l
Ol X)M 23 1
24 CHARLES SHAPIRO, C. 5NIR.
25 i
~ _ _ _.. _ _..
-=
t' y
u'er e
- W--w
r--
m
w-
-w--e--'s e--y
- -----*-,-s.-a w
- '-r e
'e---+
--'r-e-a, e
ee -i e
_, ~.. -.
3P/
December 8, ~1980 184 e
I'N D E X i
Witness Page Edgar Allen Womack, Jr.
3 i
i rf o0o i
EXHIB I TS l
GPU FOR IDENTIFICATION PAGE I
1 Resume of E.
A.
Womack, Jr.
5 i
2 Excerpt from the NPGD 138 organization charts detailing the organization of the j
Engineering Group as of the
()
summer of 1978, showing"the chart for Plant Design Section headed by Dr.
E.
A.
Womack during that period.
3 Position description for 139 Section Manager, Plant Design Section, dated February 27, 1975.
l o0o O
1 i
7 O
O
-r.-pw<-
y,-w-,,,g*~t-v-g-ww--we-e*-
--v-'r'
--ve e e - + w we --w +e-e
..-w-m.
me,-gem----ee-W+ wee-e*N--w"e-*M-m--e-w--+--rm--e
i MORGAN, Lewis & BOCK!US COUNSELORS AT LAW (O
T 88 0 0 M S ta c tT, N.W.
E. A. WOMACK
/
WAs HINGTO N, D. C. 2 c o36 TE L E >=on t 202 872-5000 Caett ApostsseMORLC80CK Tr os a. 0 9-627
)
July 25, 1979 Winthrop A. Rockwell, Esq.
Associate' Chief Counsel President's Commission on the Accident at Three Mile Island 2100 M Street, N.W.
Washington, D.C.
20037
Dear Win:
This is to confirm the understanding that we reached during our telephone conversation on July 15, 1979 concern-ing two matters which arose out of Dr. Wor;ack's deposition.
First, on page 30 he indicated that nothing had been reduced to writing concerning Mr. Carlton's plan to implement the Power Systems and Controls Unit. ;After reviewing his deposition, f.,V)
Dr. Womack recalled that Mr. Carlton had reduced his plan to writing and that a draft task description to that.effect had been prepared.
In accordance with our agreement, we will make the task description available for inspection by the Commission in the office of the undersigned.
On page 90 of Dr. Womack's deposition, the uncorrected transcript contains a statement to the effect that' Dr. Womack believed that no Technical Review Committee materials had been reduced to writing.
After review of the transcript, Dr. Womack believes that this was not an accurate statement.
Moreover, in accordance with the agreement reached'in connec-tion with Mr. Taylor's' deposition, the information'regarding the Technical Review Committee work will be made available for inspection by the Comnission when it is com Accordingly, we have agreed to stipulate that the word "plete.
no" would be deleted from line 8 on page 90 of Dr. Womack'.s deposition.
(
Please advise if you have any questions concerning the foregoing.
Very truly yours, ecrge L dgar
suly lu, lysy E. A. WOM ACE ERRATA SHEET Jg( 19 1979
)
TO THE DEPOSITION OF EDGAR ALLEN WOMACK, JR.
s.
HELD AT LYNCHBURG, VIRGINIA, ON JUNE 30, 1979 CE,
PAGE
'LINE CHANGE 4
21 "primarilyengineers" should be "primarily engineers".
5 9
" presentation" should be " preparation".
5 10
'"of the customer" should be "for the customer ".
5 16
" unit" should be " unity".
t 6
12 35 '- "It-is" should be "It is not".
12 13-14
" Control and Analysis Unit" should be
" Control Analysis Unit".
()
15 6
"to" should follow " respond".
17 7
"perhaps" should be deleted".
18 5
"ccmprehensibly" should be ". comprehensively".
18 22
" Servicing" should be "Servic,e".
26 7
" Operational Division" should be " Operation of the Division".
28 13 "this is" should be deleted.
28 14 "I" should not start a new sentence.
29-4 "and" should be "with".
l 37 18-19 "and go beyond single failures" should be
(
deleted.
37 19
" operations" should be " operators".
I i
O
,.-----y
....---._--,-.-n, r
,.-r-.
,-_.,--.,m.---,,---cv
-..,----.r.,,,w-*-
,m..-
r----y
sury av,'Assy
.n's
~
ERRATA SHEET (p.2)
()
TO THE DEPOSITION OF EDGAR ALLEN WOMACK, JR.
PAGE LINE CHANGE 1
39 14
" plan" should be " plant".
.39 15 "which is" should precede " generally".
4 43 4
"Kasseba" should be "Kosiba".
55 11 Delete "In" and insert "These are in".
55 1,1 "Belafonte" should be "Bellefonte".
55 19
" find" should be "found".
4 55 21
" asked" should be " answered".
~
56 10 "the person" should be a person".
59 16
" unit" should be " item".
()
73 9
" Services" should be " Service".
74 16 "in,the" shoul* be "under".
75 14 "go" should be "do".
76 21 "SPC" should be "SPR".
78 21-22 "a conduit to" should be "the conduit for".
79' 10 "TM-1" should be "TMI-1".
79 18 "Belafonte" should be "Bellefonte".
80 5
"TM-1" and TM-2" should be "TMI-1" and TMI-2".
84 23 "as if affects" should be "for example".
87 3
" align" should be " guess".
1 i
87-a 7
" feeling" should be "failing".
m 6
9 t
e
,.,,.,,,--. - -,-..,--,- ~,
--..c.,
,-,.-w,__m.
---,,,,.--,..,,-,.,--_,.---,.-.mmm_.
-,,_c-
July 10, 1979 ERRATA SHEET (p.3)
O TO THE DEPOSITION OF EDGAR ALLEN WOMACK, JR.
PAGE LINE CHANGE
(,
90
'8 "no" should be deleted.
93 10 "technial" should be "t. echnical".
'95 9
" started" should be " chartered".
95 4
"Wanderling" should be "Wandling".
98 11
" budget" should be " project".
i 1
e O
L 1
e e
9 e
y H
O 6
e O
O