ML20072H833
| ML20072H833 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/21/1982 |
| From: | Zewe W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-06, TASK-1, TASK-10, TASK-2, TASK-6, TASK-GB NUDOCS 8306290766 | |
| Download: ML20072H833 (126) | |
Text
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/ 'pk UNITED STATES DISTRICT COURT 122 SOUTHERN DISTRICT OF NEW YORK
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __x GENERAL PUBLIC UTILITIES CORPORATION, a h '
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-- a g air 6 s t-TSE BABCOCK G WILCC,X COMPAMY tin d J. M Y McDERMOTT s 00., INC.,
i 4
Defondants. t :
_ . . _ _ _ _- . _ .. _x a r .
Continur.d deposition of GPU NUCLEAR CORFOR5IION by WILLIAM H. ZEWE, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esgs., One Chase Manhattan Plaza, New York, New York, on Friday, May 21, 1982 at 10:20 o' clock'in the forenoon, before Harvey B. Kramer, R.P.R., a Certified Shorthand Reporter and Notary Public within and for the State of New York.
A b 8306290766 820521 PDR ADOCK 05000 DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LExlNGTON AVENUE WALTER SHAPIRO, C.S.R. NEw Yong. N.Y. 1C0!7 CHARLES SHAP!RO, C.S.R. TELEpNoNE 212 - 867 822o
1 -
123
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2 Appe aran c e s:
s 3
4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs
(- 5 425 Park Avenue New York, New York 6
BY: DAVID KLINGSEERG, ESQ.
i 7 ANDREW MacDONALD, ESQ., and STEVEN J. GLASSMAN, ESQ.,
t of Counsel i 3 l
i 10 t b I
! DAVIS POLK & NARDWELL, ESQS.
, 11 I{l Attorneys for De f end att ts <
I I One Chase Manhattan Plaza 12 Unw York, New York .
1;
{ -
} SY: ROBERT B. FISKE, ESQ.
I
-and-14 ! WILLIAM E. WURT7, ESQ.,
15 -
of Counsel 16 17 KILLIAN & GEPHART, ESQS. '-
Attorneys for the Witness -
! 18 Box 886 l Harrisburg, Pennsylvania 17108-
, BY: KEVIN WALSH, ESQ.,
20 i
of Counsel 21
( Also Present:
, JONATHAN QUINN and 23 ERIC ABRAHAMSON, Law Assistants 24 Davis Polk & Wardwell, Esqs.
I 25 -oOo-l f _.. _, . _ _ _ = . _ . . _ _ . _ _ - - - . . - --- -.- - - - ~ - - - - - ~ - ' - - - " ~ ' ~ ~ ~ " " ~' ~~'" "'
1 .
124
,J.
2 W I L L I AM H. Z E WE, having 3 been previously duly sworn, resumed ar; was 4 examined and' testified further as follows:
EXAMINATION (continued) f (3 5
- 6 BY MR. FISKE
- Q I guess you realise, Mr. Zevc, that yoa 1
6 *
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centinue under oath. '
4 5 1. Yen.
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10 Q And incond, on every resuned day of the i 11 deposition. ,
3,
, i c 1 -
1 12 A Ycs, I understand.
- i
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\_ 13 ci Q 1 would like to show you a document that 14 has been previously marked as B&W Exhibit 272. I i
15 ask you if you recognize that as the loss of reactor
-)
16 coolant / reactor coolant system pressure emergency.
17 procedure that was in effect at Unit 2 $n_the day of 18 the accident.
~
19 A Yes, it looks like it is the one that was 20 in effect that day. ~
21 Q You had had training on this procedure 22 both at Met Ed and down at B&W; isn't that correct?
23 A Yes. I did.
24 Q Now, I would like to have you look at 25 this for a minute. And if you want to look through
- l
1 -
Zewe 125 (D
L ). it quickly just to. refresh your recollection on it, 2
3 go ahead. Then I am going to ask some questions.
l 4 (Witne s s examining document) 5 Q could I suggest this, Mr. Zewe? I know I(;
6 you have been looking at that now for a few minutes.
7 I am going to be asking ycu questions about certain ,
8 p ?r ?. ions of it. I dcn't want to restrict your right 9 ;5 to look at it as long as ycu want before I start 10 asking the questiono, but I would be willing tc $
11 procacd and start at. king ques tions on a certain area, i
- 12 , and then if you wanted to atop se that pcint and (A ' l 13 ) study the procedure in ' hat particultr area befora P
14 you answer, titau's fine.
15 I am not going to ask you questions 16 about every single paragraph in that procedure.
17 MR. MacDONALD: Maybe you can.just skim i
18 through it.
~
19 A Give me another couple of minutes.
20 Q certainly. I want to give you as much 21 time as you want.
22 (Witness examining document) 23 A Okay.
[\
w) 24 Q Have you had enough time to look at it?
, 2.5 A I believe so, yes.
-3
J 1 -
Zewe 126 f
2 Q The procedure 1s in two parts,-as I read 3 it. Part A, captioned " Leak or Rupture Within 4 Capability of System Operation," and then Part B is, 5' " Leak or Rupture of Significant Size Such that
( ,
6 Engineered Safety Features Systens Are I.utomatically I
7F Initiated."
l 8 i Is that correct, that there are-those i
n 9$ two different sections?
Il I
10 4 Yes. Y l, .
11 Q What did you understand the phrase " Leak l 7
}
12 or Rupture Within Capability of Systen r.'peration" to I
( 13 , maan?
' a 14 MR. MacDONALD: You are talking ab out i 4
15 the understanding of the procedure before the 16 TMI accident.
-17 MR. FISKE: Yes.
18 A To me, it meant that you had a loss of 19 coolant from the reactor coolant system that was 20 - within the normal makeup capability of the makeup 21 system.
22 Q By that answer, do you mean that it would 23 be a leak that could be handled without the use of 3
f~)
%s 24 high-pressure in,j e ction ?
25 A That was my general understanding, yes.
- _ . - . _ - - - - - .- --- . . _ . , ~ . - - .
f 1 Zewe 127 O
(_j-2 Q' Now directing your attention, Mr. Zewe, 3 to Part B, which is captioned " Leak or Rupture of 4 Significant Size Such that Engineered Safety
( 5 Features Systems are Automatically Initiated,". do
, 6 you see that? It is on page 6.
4 7 A Yes.
8 " Engineered Safety Features S y s e.e m s "
Q ,
9 includes HPI, does it not?
j 10 l A Yes, it does.
- i ,
11 fl.
I Q Do you see under B there is a section tt 12 ' called "Syuptoms," 1.0?
7 j '
- 'u 13 A y e s -.
14 i Q And then there are: under " Symptoms" 4
1 15 eight separate paragraphs, are there not, setting 4
16 forth different symptoms of a leak of the size 17 described in Section B? ~--
18 A Yes.
19 Q Am I correct, Mr. Zewe, that it was 20 your understanding, based on your training, before 21 the accident, that it was not necessary to have all 22 eight of those symptoms in order to conclude that you 23 had a leak of the size described in Section B?
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( )g 24 A It was my training and understanding 25 that I did not have to have every symptom listed,
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1 Zewe 128 '
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2 but that I should use these in conjunction with my, i 3 primary plant instrumentation, alarm systems, p
4 computer systems, and knowledge of the plant in -'
.* / ;
5 order of formulating and making an evaluation of
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G what course of action to take. '
71 0 nid you have any understanding before 8 the accident, Mr._Zewe, that there was any set number ,
ul of these symphoms th3c you had to set before you ,
1 10 [ ,
could conclude that you he d a leak of tha size i
11 i desiribei in paragraph n?
l 12 A As I recall, there vere no set number. !
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/ 13 That yoa juct used these in conjunction sith the I; .
otbet things that I have mentioned, eno paratetori.
14 Ii
(
, Yp 1 .the alarms, what you were doing at the particular e 16 time which may account for a few of these symptoms.
/
17 Q You mentioned that you woul'd.'look at
. I-18 think the alarm symptoms and also you wou'ld look at 19 readings that you might obtain from the com'p u te r ;
20 didn't you just say that a few minutes ago?
21 A Yes, I did. From the console readings 22 themselves, from the computers and from the various 23 alarm systems ove rhe ad and on the computer, and I
f^
m 24 also the light and status indication of the various 25 components.
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l 1 .
Zewe 129 g {
^x (O~ 2 Q These eight paragraphs listed on page 6 3 under this heading " Symptoms" refer specifically 4 to various alarms, do they not?
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5 A Some of them refer to alarms and others 6 just refer to parameters.
L 7 Q Right. So when you said that you would 8 look for alarms, I take it that you would look for 9 the alarms that are referred to'in,these symptoms, a
10 A I would look at all the alarms that came -
11 in at any particular time and try to make a i 12 determination and evaluation based on all the alarms
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13 that I had, which may or may not include these 14 particular alarms. s\
They would certainly be t 15 included in that determination, yes.
16 Q Let's just make sure we are talkingx 17 about the same thing. It is certainly true, isn't 18 it, that in trying to determine whether~'or not you 19 had a leak of the size described in paragraph B, you 20 would look to see whether or not youthad the type 21 of alarms that are listed in these eight paragraphs 22 under " Symptoms"; isn't that correct?
23 A I think that it would be more correct to
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\J 24 say that when I received the alarmr, I am not 25 mind-set that I am looking for one part'icular group
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- - , , . . . , . . . . . . n .-
h a s.
1 . Zewes 130
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Q 2 of alarms in particular,-because I am still going 3 through the evaluation process of what I have, in 4 order to determine what corrective action to apply g 5 in that particular case.
- 6 It is true that if I am looking for a 7 r. ture, I would dwell on these particular ones, but 8 that isn't necessarily t'he case. Whatever alarms s
9 came up, that would be the preface. All right? The s
'10 alarms, the instrumentation and how the plant was ,
11 reacting, which would lead me into making a J< 12 determination of what procedure to use. Not the O, 13 reverse, I'm afraid. -
14 I don't say, well, I have a particular 15 event and I say, do I have alarms to support that 16 event? ,
~
17 That isn't the case. ,
18 Maybe I am misconstruing what you are
~
19 asking, but that's what I believed that you are 20 asking: that the alarms will be first and then that
- 21 will help me in the determination of what event.
22 Not the opposite.
23 Q Well, just stay with that for a minute
{ 24 and then I will come back to something else --
}
25 A All right.
1 -
Zewe 131
(~
v) 2 Q --
that arises from it. But just taking 3 it from where you just left it off, it is true, is
! 4 it not, that seeing any of the alarms that are listed 5 in paragraphs 1.1 through 1.8 would be an indication,
((
6 a symptom, of a break of the size described in 7 paragraph B7 S A They would only be a symptom in this 9 particular case --
all right --
if that is the 10 conclusion that I would draw from the avaluation 11 that I would make. Because there.are other events 12 that have similar symptoms that may occur for a b1
\/ 13 reason that I am well aware of, or a reason that I 14 myself have, caused from an action that I have taken.
15 So I would expect to have, say, low 16 pressure if I have an overcooling event, or that 17 I would expect to have low pressurizer level if I 18 have a cooling event, or if I had any number of 19 other reasons for various symptoms that are stated i
20 in this procedure.
21 So it is part of the overall evaluation.
22 But it does not dictate that if I have these 23 symptoms or any number of them, two, three, four,
() 24 what have you8 that it is just part of the evaluation 25 process and it does not lock me into this procedure.
l 1 -
Zewe 131A
)
2 Because there are a lot of other things that are 3 happening and action that is taken at any particular 4 time which could lead to these, regardless of part B 5 of the procedure.
((
6 Q I understand you are saying, with 7 respect to symptoms 1.1 through 1.8, there might be 8 events other than a leak of the size described in 9 paragraph B that might produce some of those same 10 symptoms. Right? t 11 A Yes.
12 Q I understand that. But my question is, 13 isn't it true that every alarm that is listed in 14 paragraphs 1.1 through 1.8 is a symptom of a possible 15 leak of the size described in paragraph B7 16 A, That is possible, yes.
17 Q Now, are there alarms other than the ones 18 that are listed in these symptoms that, if you saw 19 them, would indicate to you that you might have a 20 leak of the si=e described in paragraph B?
21 A Yes. Most definitely there would be a
~
22 lot of other related alarms. Because if you did 23 have a leak the size of section B here, you would
(
) 24 have a reactor trip, you would have a turbine trip, 25 and you would have the engineering safety features
1 .
Zewe 132
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2 actuation, and all of those components have their 3 own alarms, have their own indicating lights, have 4 their own status lights. ,
5 So there would be many, many more alarms
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i 6 and indications due to related things.
7 Q Apart from alarms that would come on 8 anytime you had'a turbine trip or anytime you had a i
9 reactor trip or anytime you had automatic ESFAS, 10 are there any other alarms that would be an 11 indication to you that you might have a possible 12 loss of coolant accident of the size described in I ( 13 paragraph B?
14 A I can't think of any other ones that are 15 not directly related to these eight, plus the other 1 .
16 alarms which we talked about for the actuation of 17 the components and the reactor trip, turbine trip 18 and all the related events.
~
19 Q If I understand that answer right, you 20 are saying you can't think of any other alarms in 21 addition to the ones that you have mentioned up to 22 now?
23 A Not at this time, no.
I 24 Q You mentioned also that you would look i 25 for readings off the computer. Do you remember that?
1 zewe 133 O
U 2 In helping you to determine whether or not you had 3 a leak of the size described in paragraph B.
- 4 A I would use the computer to the extent 5 where you could gain useful information, yes.
{.
6 Q What kind of information would you 7 attempt to get from the computer that would be 8 helpful in determining whether or not you had a 9 leak of the size described in paragraph B7 10 A In an event like this, which is a major 11 event where there is a great number of alarms on 12 the computer, I would basically use the computer s
(s '/ 13 utility typer more than the alarm printer to call 14 out certain parameters in the course of the event, 15 to check on other plant status which may not 16 indicate properly in my estimation or for a
~
17 further check of status of various components that 18 I felt were warranted.
19 Q What kinds of information would you be 20 able to get from the utility typer that would be 21 helpful in telling you whether or not you had a loss 22 of coolant accident?
23 A I am thinking more in terms of a 1 24 generalized approach, that if something was abnormal, 25 I could always use that as a further backup
1 . Zewe 134 o'
~
4 2 indication, with no real specifics other than as the 3 particular items came to mind that I felt that the 4 computer could give further -- clarify some events 5 further, then I would itse it. But with no'certain
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6 specifics. Because I have adequate console 7 indication available to me, regardless of the status i
- 8 of the computer, that in most cases should be enough.
9 Q So I take it your testimony, Mr. Zewe, 10 is that as you sit here right now, you>.can't think 11 of any specific piece of information that you would 12 obtain from the utility typer that would be helpful i
j s 13 in determining whether or not you had a loss of j 14 coolant accident? ,
15 A I would use it more as a backup as the 16 need arose, yes.
17 Q 'And by backup, you mean a bdckup to 18 information that was appearing on the console?
i 19 A Yes.
20 Q The first one of the symptoms that's 21 listed on page 6'is a rapid continuing decrease of 22 reactor coolant pressure, an~d then there is 1
23 reference under that to a low alarm at 2055 psig,
( 24 a' low-low alarm at 1700 psig, and safety injection 25 actuation at 1640 psig.
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1 .
zewe 135 i
- j.
2 Do you see that?
3 A Yes, I do.
4 Q Why did you understand that a drop in
5 pressure activating those alarms and actuated safety
(
6 injection at 1640 was a symptom of a loss of coolant 7 accident?
8 A Well, it was my training and 9 understanding, both at the island and at B&W, 10 Lynchburg, during the transient response, that 11 every time you had a loss of coolant accident, that i
12 pressure would be reduced, level would be reduced, e
N/ 13 and that if it got down low enough, you would 14 actuate the' engineering safety features system.
15 Q But in terms of the thermodynamics of 16 the plant, what was it about a loss of coolant I
17 accident that would produce a drop in tbe. pressure?
18 A Loss of reactor coolant system l 19 inventory.
20 Q And why did you understand that a loss 4
21 of inventory would produce a drop in pressure?
22 A The reactor coolant system is full 23 normally with an indicated level in the pressurizer r
(- 24 of approximately 220 inches. And if you would drain
! 25 out any water from the reactor coolant system, it i
i r
1 Zewe 136 N.
4
-'-)" 2 would reflect that level change in the-pressurizer 3 level. And since the pressurizer in itself is there 4- to maintain inventory and to act as the pressure 5 source for the reactor coolant system, if I would
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6 lose-inventory,.we would also lose pressure.
7 Q Is it your testimony that you understood 8 that the only reason that pressure goes down in the 9 course of a loss of coolant accident is because 10 level in the pressurizer goes down? t 11 A Level in the pressurizer going down is 12 the indication of loss of inventory from the system,
(
(/ 13 and that pressure will go down because you lose the 14 capability of maintaining the pressure which is 15 afforded by the pressurizer. So that when the 16 pressurizer level goes down and empties, you would 17 expect to lose pressure, yes. ',
18 Q Did you understand that if pressurizer 19 level went down from 200 to 150 inches in the 20 pressurizer, that the pressurizer would be incapable 21 of maintaining pressure above the -- withdrawn --
22 incapable of maintaining pressure at the normal
. 23 level?
24 A Prior _to the accident, I don't recall 25 thinking about that specifically, that if
1 Zewe 137 N .
2 pressurizer level went down by that amount, would it 3 be sufficient or insufficient to maintain normal 4 p re s s ure . I don't believe that I thought about it 5 in that sense.
({ '
6 Q Let me ask the question which I ma'y havo 7 just asked a minute ago, but I am not quite sure of 8 the answer.
9 Was it your understanding before the 10 accident that the only reason that pressure goes 11 down in a logs of coolant accident is because the re 12 may be a decrease in level in the pressurizer?
[h -
\'/ 13 A It was my training and understanding from 14 all the training that I had received, including --
15 the caly transient response that I had ever 16 received on LOCAs were at B&W, Lynchburg, and in 17 every case where we had a LOCA, we had a loss of 18 pressurizer level and they always accompanied each 19 other, and I was never t'old to try to evaluate or t
20 correlate that a certain level reduction would or 21 would not be able to hold the pressure or anything 22 of that nature.
23 Q Was it your training, whether at B&W or
(%.s') 24 Met Ed when you were trained on these various I
25 procedures, that in a loss of coolant accident, it is
1 zewe 138
N ~
2 a drop in pressurizer level which causes the drop in 3 pressure?
4 MR. MacDONALD: We are talking about 5 after a reactor trip?
(
6 MR. FISKE: Yes, we are talking about a 7 loss of coolant accident.
8 Do you want to hear the question again?
9 THE WITNESS: Yes, please.
10 MR. FISKE: Could you read 4it back. ,
11 (Question read) 12 A My answer is basically the same, that s/ 13 all of the training, including the transient response 14 training at Lynchburg, was that if I had a LOCA, I 15 was going to lose level and I was going to lose 4
16 pressure.
17 And I had a hole within the RCS 18 somewhere and I was losing that inventory, which was 19 , the main cause for the pressure going down~ 'was the 20 loss of inventory which was reflected directly and 21 always in the pressurizer level.
22 Q I think I understand that you said that.
23 My question is what your understanding
[d\- 24 was as to what it is that causes the drop in 25 pressure resulting from a loss of inventory. You
I I
2 1 Zewe 139 J. 2 have said, if I can restate your testimony, that 3 you understood that in a loss of coolant accident 4 inventory ^ escapes. So there is less inventory than g 5 there was before, and that as that happens, the 6 pressurizer level tends to come down.
7 Now, what I am asking you is, why did 8 you understand, by what process did you understand, 9 a drop in inventory would produce a drop in 10 pressure? More specifically, I am asking you, was 11 it your understanding that the thing that produces 12 the drop in pressure is a reduced pressurizer level? .
13 A As I recall, my understanding was 14 because of the loss of inventory caused by the 'l o s s 15 in pressurizer level. And the pressure would always 16 follow the pressurizer level down and they both 17 trend in the same direction. .
18 Q I think we may be confusing two things 19 here, Mr. Zewe. One is, what is an indication of 20 something, and wha t may be a cause of it.
21 And I think you have said several times 22 that when you had a loss of inventory, you would 23 have a loss of pressurizer -- a decrease in
() 24 pressurizer level. And to that extent, the decrease 25 in pressurizer level would be an indication that
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1 Zewe 140 r~% '
V. 2 there had been a loss of inventory. .
3 What I am asking is, what did you 4 understand caused the drop in pressure which resulted
( 5 from a loss of inventory?
6 Do you understand what I am trying to 7 find out?
8 A It seems like you are asking the very 9 same thing over and over again, and my response is 10
,_ the same. (
11 Q okay. Well, if your testimony is that 12 you understood that-the drop in pressurizer level es .
(N -) 13 was what caused the drop in pressure, then we can go 14 on.
15 A Right, the --
16 Q okay.
17 A -- pressurizer maintained pressure, and -
18 if I would lose level, I would reduce the pressure, 19 and they would both trend together; as I lost levels 20 I would lose pressure.
21 Q In any of the training that you had or l 22 in just any of the understandings that you may have 23 derived independent of your training during the i
( 24 entire time you have been operating nuclear reactors, 25 did the thought ever cross your mind that in the
b 1 Zewe 141 2 case of a loss of coolant accident, the drop in 3 pressure might result simply from the. fact that 4 there was a hole in the system and that pressure
( 5 would escape out the hole?
6 MR. MacDONALD: I object to the form.
7 A I think they are the same. That if I 8 have a hole, I am going to lose inventory, and along 9 with that I will have the reduction in pressure. But 10 it is really the inventory there that I,am losing.
11 It is so related to pressure that you can't separate 12 them in my mind.
(~% .
13 Q In other words, was it your understanding 14 prior to the accident that the reason that pressure 15 goes down when you have a loss of coolant accident 16 is somewhat comparable to the reason why pressure 17 goes down in a tire when you get a hole in the tire?
18 MR. MacDONALD: I object to that.
19 You can answer if you can.
i 1 20 I don't quite understand.
21 A I don't believe it is that simple.
l 22 Because in air pressure in a tire, you are not 4
23 changing the state like you are in a reactor coolant
! rh 24 system there where you are going from water to steam, j ()
- 25 where you are.having a phase change. Even though in l
L
, 1 Zewe 142
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2 the reactor that you are leaking steam instead of 3 water out of the hole, it is still the fluid whether i
4 the fluid be steam or the fluid be water, it is
( 5 still reactor coolant inventory that you are losing.
6 Q It is that inventory which when 7 m'aintained at its full ca.pacity sustains the 8 pressure; correct?
9 A Strictly in relationship to the RCS. If i
10 I can maintain inventory in the pressur,1zer and 11 maintain saturation conditions in the pressurizer 12 to control RCS pressure, yes.
i /~h l 13 Q Going to item No. 1.2, under the 14 " Symptoms," it says, " Rapid continuing decrease 15 of pressurizer level, resulting in, No. 1, low alarm 6
16 200 inches, No. 2, low-low alarm, 80 inches."
l 17 You may have answered this question 18 already, but why did you understand that a decrease i t l
19 in pressurizer level activating those two alarms-I 20 was a symptom of a leak of the size described in 21 paragraph B?
i 22 A It was my training and understanding, 23 particularly at the B&W, Lynchburg, where we had
[)
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24 the transient response training for accidents like 25 the LOCA,that.every time that you had a loss of
]
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1 Zewe 143
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2 coolant, that you would rapidly lose pressurizer 3 level and that you indeed would go below the alarm 4 points of 200 inches and 80 inches, depending ~ upon
( 5 the break size, but that pressurizer level would 6 always be rapid reduced.
7 Q Were you trained at B&W in Lynchburg on 8 the consequences of a cooldown in terms of its 9 impact on pressurt and pressurizer level?
10 A At my training at B&W, Lynchburg, we 11 did do cooldowns and we did follow the procedures 12 in dealing with the normal change in pressurizer '
s g
13 level due to a cooldown.
14 Q Well, putting it another way did you 15 learn in the course of your training at Met Ed or at d
16 B&W that you could have, following a reactor trip, 17 a drop in reactor coolant system pressure.and a 18 drop in pressurizer level resulting from any cause 19 other than a loss of coolant accident?
20 A As I believe I stated earlier, many of 21 these symptoms listed here or in the A section 22 could be attributed to other plant upsets which 23 could reduce pressurizer level and could reduce O)
(
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24 reactor coolant system pressure. And there are a 25 wide range of.these upsets which would cause this to
1 Zewe 144 s -
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2 happen.
3 Q And in the course of your training at
- 4. B&W or Met Ed, did you ever learn that there was any 5 upset, other than a LOCA, which would produco a drop
{
6 .in reactor coolant system pressure without also 7 producing a drop in pressurizer level?
8 MR. KLINGSBERG: Can we have that back?
9 (Question read) 10 MR. MacDONALD: I am going!to object to ,
11 the form. I don't think there is any 12 foundation. Any event other than a LOCA that 7
\- 13 would produce a drop --
14 MR. FISKE: I understand the objection 15 and I will rephrase the question.
16 BY MR. FISKE:
17 Q Up to now, Mr. Zewe, we have been I
18 talking about loss of coolant accidents. Now, you 19 just said in one of your last answers that 'you 20 learned that there were, as you put it, a wide range 21 of upsets which could produce a drop in reactor 22 coolant system pressure other than a LOCA. Right?
23 MR. MacDONALD: I will object. I think
( 24 it was more than that. And what his testimony 25 is, it is.
1 Zewe 145
( )
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2 A As I recall, I said drop in pressurizer 3 level and reactor coolant system pressure.
4 Q Well, my question is directed at this
( 5 group of upsets other than a LOCA. That is what I
! 6 am asking you about. -
7 Now, within that group of upsets, did 8 anyone ever tell you before the accident that any 9 one of those upsets could produce a drop in pressure 10 without also producing a drop in pressdrizer level?
11 A At this time I don't recall any of the 12 upsets that I am going over in my mind where I would 13 have a loss of reactor coolant system pressure and 14 not an accompanying loss of reactor coolant 15 p re s surize r level.
16 Q. The next symptom under section B is 1.3.
17 "High radiation alarm in reactor building."
18 First of all, did you have any 19 understanding before the accident as to which alarms 20 were referred to in that particular symptom?
21 A We had a couple of different radiation 22 alarms that monitored the reactor building, one of 23 which monitored the reactor building atmosphere, and
() 24 another one was near the dome of the reactor 25 building, and.we also had alarms that were on the
1 Zewe 146 O~ 2 fuel handling bridges. ,
3 And it was my recollection that it is 4 those alarms which we used in reference to this
( 5 6
particular symptom.
Q What would you understand the reason was 7 that a radiation alarm in the reactor building would 8 be a symptom of a. leak of the size described in 9 paragraph B?
10 A Radiation instruments are designed to 11 detect the presence of radioactive isotopes, and 12 that the reactor coolant system, even though it's O)
\_ 13 tried to be kept relatively low in activity, there i
i 14 is still enough present activity that if it is near 15 where the monitor is located or that the monitor 16 is monitoring that area, it should indicate that 17 increase in radioactivity.
18 Q In other words, do I understand your 1
19 testimony to be that there is enough radio'a'ctive -
20 material in the coolant so that if there is a 21 substantial release of coolant into the building, 22 that should activate a radiation alarm? I 23 MR. MacDONALD: What do you mean by i
f- 24 " substantial"? Do you want to quantify that?
25 MR. FISKE: I am not sure a definition
1 Zewe 147 n
2 of "
substantial" is crucial to my question.
3 MR. MacDONALD: The question stands. !
4 MR. FISKE: Do you want to read it back 5 to Mr. Zewe?
{
6 (Que s tio n read)
I A Yes, it should. But I think that that's 8
more of a broad sense, because the activity within 9 the reactor coolant system itself changes from time 10 to time. It actually starts out very,'yery low at 11 the beginning of a life, and then toward the end of 1~9~
a life, you typically have a higher activity.
13 So depending on the magnitude of the 14 leak and the amount of reactor coolant activity you 15 have in the location and s'ensitivity of the 16 instrument, this would really vary on how much you 17 would see. "
IO Q By " life," you mean life of the fuel?
19 A When I refer to life, I refer to from the 20 beginning of one particular refueling cycle to its 21 completion, to where you would refuel again.
22 Q Well, do I understand you to say then 23 that a leak of exactly the same amount of water I
24
( would produce more radiation near the end of the' 25 cycle than it would at the beginning of the cycle?
+-yy + -e.g... .. , w. ---w v -
l 1 Zewe 148
~
(~#'t
'~
2 A Generally speaking, that was true.
3 Because you have a certain small amount of failed 4 fuel to begin with that the plant is designed for.
5 And that as you run through a reactor core's cycle,
(
6 you have upsets and you have crud bursts, you have 7 some concentration of activity in a buildup of 8 fission products.
9 So that, generally speaking at the end 10 of that core cycle you would have a higher reactor 11 coolant system activity, yes.
12 Q And it would follow from that, wouldn't
(%
(_/ 13 it, that it would take a bigger leak to activate 14 the alarms at the beginning of the cycle than it 15 would near the end of the cycle?
4 16 A Magnitude here again depends on all those 17 factors. What it is, all right? Where'it is at.
18 How close it is to the monitor. Its sensEtivity 19 for that particular isotopes and the a c t i v'i t y ,
so 20 all of those things combined.
21 Q I understand. I am saying, everything 22 else being equal, it would take a bigger leak to 23 activate the monitors in the beginning of the cycle 24 than at the end of the cycle?
(
25 A Everything being equal, yes.
1 -
Zewe 149 sm
\' _-).
2 Q And you understood that the purpose of 3 having 1.3 in this LOCA procedure was basically to 4 tell you that seeing a radiation alarm in the reactor
( 5 building would be helpful to you in de.termining 6 whether or not you had a loss of coolant accident?
7 MR. MacDONALD: You are talking now about 8 the alarms mentioned earlier when you went 9 through this.
- 10 MR. FISKE: Yes. !
11 A It would be helpful, yes.
12 Q Now, you mentioned certain specific tm .,
t 13 alarms. One that measured the atmosphere, one near 14 the dome and one near the fuel handling bridges.
15 Who was it that told you that those 16 three alarms were the ones that you should be looking 17 for in-implementation of this symptom, 1.37 18 A I don't recall who in particular, but i
19 throughout my training at Met Ed and B&W it was l 20 brought out to my understanding in training that l
l 21 you would use the radiation instruments that you had 22 available in the reactor building.
t
! 23 Q Yes. Well, I would like to ask you this
( 24 question specifically, Mr. Zewe. Did anyone at B&W 25 tell you that in implementing section 1.3 of this i
1 Zewe 150 ,
( '
procedure, you should use only the three monitors 2
3 that you have just described?
4 MR. MacDONALD: Are you asking whether 5 he can recall a specific person?
(
6 MR. FISKE: No, I am not asking whether 1
7 he can recall a specific person. I am asking-8 whether anybody at B&W told him that in 9 implementing section 1.3, he should only use i
10 the atmospheric monitor, the dome monitor and 11 the monitor by the fuel handling bridges.
12 A As I recall, the instructors at B&W, D
k- 13 Lynchburg were involved in helping to train us in 14 the use of these p rocedure s and I am sure that the 15 subject of the dome monitor, 214 and 227, and the 16 bridge monitors came up. I don't recall any i 17 discussion restricting us to just those,~ but those.
18 were the main ones in my estimation that concerned 19 us in this portion of the procedure.
20 Q I know that that is what you have said 21 earlier, that those were the three that you looked 22 at. I am just trying to determine how it was that
~
23 you were instructed that you should look at those 24 three particular monitors, and I think you have 25 answered the question, I believe, as far as B&W is
1 zewe 151
~
2 concerned.
3 MR. MacDONALD: Off the record.
4 (Recess taken) 5 BY MR. FISKE:
{
6 g Mr. Zewe, where did you think you were 7 in this fuel cycle at the time of the accident in 8 March of 1979?
9 A I knew that we had approximately 100-10 effective full power days at that point.
11 Q And how many full power days are there 12 in,the life of or'in an ordinary cycle?
O
'- 13 A We can't consider this an ordinary cycle, 14 because they are all a little bit different. The 15 first cycle which Unit 2 was in was by far the 16 , longest. fuel cycle, of somewhere over 420 effective 17 full power days of operation. ,
18 (Continued on next page)
~~
19 20 21
~
22 23
() 24 25
hd1 1 Zewe 152 r~s ~
2 . Q Was it your understanding on the day of l 3 the accident, in terms of where you were in the fuel 4 cycle, that you could not have a leak or rupture of j '-
5 the size described in paragraph B without seeing one 6 of the alarms that you referred to earlier, one of the 7 radiation alarms that you referred to earlier?
8 THE WITNESS: Could you repeat that, 9 please?
10 MR. FISKE: Let me rephrake the question.
11 Q Did you understand, based on everything 12 that you knew up to the time of the accident, that you t' ' /-
13 could have a loss of coolant accident going on without 14 activating any of the three radiation alarms that you 15 described earlier?
16 A Are you bounding in any way the magnitude 17 of this loss of coolant accident? -
18 Q I was referring to the loss of coolant
, 19 accident as described in this paragraph B that we have 20 been talking about.
21 THE WITNESS: Would you read that back, L 22 please?
4 23 (The last two questions were read by the D 24
() reporter.)
25 A My recollection before the accident was k
-- -- ~. . _ = . - _ - .
1 Zewe 153 C\
I
(_/. 2 that if I had a leak of sufficient size to enter 3 part B, that I would expect to see a radiation alarm
- - 4 even at this point in the core life.
5 Q Was it your understanding that you could
((
i 6 have a leak as described in part A without activating i
7 any of those three radiation monitors?
8 A Yes, because this covers a pretty wide 9 spectrum of smaller leaks. And at this time in core 10 life, I believe I thought that it was possible to have 11 a minor loss of reactor coolant inside the reactor l 12 building and not have these alarms, yes.
, 1 -
13 Q Do you know whether any effort was made 14 by Met Ed to adjust the sensitivity of the radiation 15 alarms as the fuel cycle went on, so that the 16 sensitivity of the alarm would take into account the 17 increasing radiation that existed in the. fuel during i
18 its cycle?
19 A To my knowledge, such a program was not r
20 undertaken to change the sensitivity.
21 Q The next item or symptom, Mr. Zewe, is l 22 paragraph 1.4, " Reactor Building Ambient Temperature 23 Alarm."
Do you see that?
l
) 24 25 A Page 67 Yes.
r.
1 Zewe 154
(-sv). 2 Again, was there a particular alarm that Q
3 you understood that symptom referred to?
I 4 A We have temperature detectors inside the 5 reactor building which would activate an annunciator
((
6 alarm when it reached its actuation setpoint, yes.
t 7 Q And that is one particular alarm you are i
8 talking about?
9 A one particular alarm point, but it is 10 representative of one of a group of inyicators which, 11 when they exceed their alarm point, would cause 12 actuation of the alarm.
(^)
V 13 In other words, that particular alarm Q
14 goes off any time any one of a number of different i
15 indicators activate it?
16 A That is correct.
17 Q What did you understand what the reason 18 that high temperatures in the reactor building were 19 a symptom of a rupture of the size described in 20 paragraph B?
. 21 A Any loss of reactor coolant into the L 22 reactor building would release energy to the building 23 and it would take the form of heat to raise the 24 temperature of the building, and it was indicated by 25 the temperature detectors themselves.
.. . , _ .~ .- ._ - . -
o 1 -
Zewe 155 ' '
cg- .
' ^
). /
2 i Q The next one is "Hi Reactor Building Sump
.0,
, jj '
Leve1." ,
f
'4 Why did you understand that a high i
(( 5 reactor-building sump, level was a symptom' of a rupture 6 of the size described in paragraph B?
/,- '
- 7 - A -Loss of inventory from the RCS, wherever ,
- 8 it occurred inside the building, would ultimately 9 r e s u'I t in draining to the reactor bui'leling sump. So
,,)
10 the increased reactor building sump level can be used -
r . ?'
11 3 'to help determine that you have a leak or loss of 12 cool &nt from the RCS, *
/'
4 _
1 :
l 13 Q The next item, 1.6, is "Hi Reactor >
.; r 14 Building pr5ssure." r 15, why did you understand that high 16 reactor. building pressure was a symptom of a rupture 17 of the size described.in paragraph B? .
, 18 A The loss of inventory from the reactor 19 coolant system would go into the building, and it
- 9,0 wou'13 result in raising the reactor building pressure.
e; y
' .21 Q I guess my question is why.
22 MR. KLINGSBERG: Why what?
I I n _f Q Why would having coolant escape into the 24 reactor building raise the pressure within the 25 building?
~
r,'-
s 1 Zewe 156 C)
V.
N s
2 A You are releasing energy to the building. s b.
1 3
The building is confined and closed up. S5 you'are ,, j f, q 4 releasing this energy to the building itself .' ' So the['
'm
( 5 building will begin to pressurize.
6 Q The next item is a " Rapidly decreasing 7
make-up tank level."
8 Why is that a symptom of a rupture of 9 the size described in paragraph B7; .
\ ':
, 10 A Loss of inventory from the reactor
+;
11' coolant system would be reflected in a loss of v 12 inventory by . pressurizer; level. There is an -
p-)
t 13 automatic level control valve that controls and s 14 maintains pressurizer. level at or about 220 inches.
15 This valve opens _up as the pressurizer level goes .
16 down, and the makeup system then would take its
- 17. water from the makeup tank through the'makeuppumh i
18 and in through the pressurizer level con $rol valve i 19 to try and maintain and/or restore pressu'rizer le, vel
\v
.20 to correct the inventory problem that you have.
21 Q Is it a correct statement that symptom l 22 1.7 really doesn't tell you anything that you 23 wouldn't already know through symptom 1.2?
l ( 24 A Quite the contrary. The makeup tank 25 level indication is very useful in determining what '
1 -
Zewe 157
('
D) 2- the magnitude of makeup is, because the pressurizer 3 level control valve is opening up on a varying setpoint, 4 trying to maintain level. So pressurizer level going down, it would have gone down much more rapidly if
( 5 6 the pressurizer makeup valve was not opened up.
7 But all of the inventory being transferred s
8 from the makeup to the RCS and into the pressurizer I
i 9 would be reflected directly from the makeup tank, so 10 that I ebuld get an accurate count of how much water 11 was being transferred, which I could then relate to 12 leak size' in this case.
/~%.
t !
13 Q so what you are really saying is that t i 14 1.2 and 1.7 in a sense are cumulative, that 1.2 shows 15 you how far the level has gone down, and then 1. 7.
16 tells you that it has gone down that far despite the l
17 fact that there has been increased makeup, flow in a 1
18 certain quantity; right7 19 A I am afraid you are not phrasing it
(
20 .:right, despite the fact that that is a makeup, i
l 21 Q I think that is a possibility.
t s
! 22 A The total amount of the makeup that is
\ 23 required comes totally from the makeup tank during I
G) , 2[ this period. So the total amount of inventory that 25 you are replacing comes from the makeup tank. So i
l
-1 -
Zewe 158
~
O' 2 that should be the total amount.
3 From that, you still have to realize 4 that if pressurizer level started out at 220 inches, 5 you would then take that amount of inventory into
((
6 ~ account.
4 7 In that respect, yes.
8 But if you start out at 220, you can 9 then rely on the makeup tank as long as the makeup 10 valve was making up and maintaining 220 inches. -
1 1
11 Q If I understand you correctly, what you 12 are really saying is, whatever decrease in pressurizer
-O. 13 level you see under 1.2, you could assume that that 14 decrease would have been even greater had it not been 15 for the increased makeup flow reflected by 1.7.
16 MR. KLINGSBERG: I object to the form
, 17 of the question. .
18 You are always saying "What you are j 19 really saying..." as though "as though you 20 are a jerk, and I can really say it better than 21 you." I don't want that.
22 I think if you have a fact question that 23 you want to ask, you should ask the fact 24 question and not answer in a way that suggests
- s_J l
l 25 you are better at phrasing the answer than the i
l I
1 -
Zewe 159 bt
\>
2 witness is, and I think that is very misleading.
3 MR.FISKE: I certainly didn't intend to 4 suggest that I know'more about this than Mr.
l 5 Zewe. I think that would be a very improper 6 assumption on my part..
7 I was just trying to put it in a way 8 that made it clear to me. If you object to 9 the introductory phrase in the question,.I 10 would be happy to rephrase it, b,ecause I did 11 not intend anything along the lines of what 12 you suggested.
13 BY MR. FISKE:
14 Q To satisfy Mr. Klingsberg, Mr. Zewe, let 15 me put the question again.
16 Is it correct that the Acrease in 17 pressurizer level reflected in symptom 1.-2 would have 18 been even greater had it not been for the increased 19 makeup flow reflected in paragraph 1.77 l 20 A Yes, that is true. But 1.7 actually 21 addresses makeup tank level and not flow. We have a 22 separate makeup flow instrument.
23 Q o.K. I think this is clear enough so we
) 24 can proceed.
, 25 A O.K.
. .= . _.
t 1 Zewe 160 f~h
(_) 2 Q Symptom 1.8 says, "Both core flood tanks 3 levels & pressures are decreasing."
4 Would you tell us why you understood 5 before the accident that that was a symptom of a
((
6 rupture of the size described in section B7 7 A The core flood tanks are overpressurized
~
8 with a pressure of nitrogen to 600 pounds, and they 9 contain approximately 1030 cubic feet of water. And 10 during the LOCA described here, if thetinventory in ,
, 11 the reactor coolant was such th'at it was reduced and 12 the pressure went down to below 600 pounds, then the
{'T
\-
13 core flood tank check valves then w oul open up and 14 the core flood tank would discharge its water in 15 through the core flood nozzles and into.the core, 16 thus reducing their pressure and level as it did that.
17 Q Is it correct, Mr. Zewe, hat certain of 18 these symptoms that we have just been going through,
, 19 1.1 through 1.8 in this procedure, may also be symptoms 20 of an OTSG tube rupture or a steam line break?
21 A Some of these would be overlapping and 22 apply to those two cases. Not all of them.
23 Q Did you understand that the note under 24 1.8 was designed to help the operator distinguish 25 between a loss of coolant, an OTSG tube rupture and
1 Zewe 161
(~'i ~
V 2 a steam line break?
3 A Yes. The information contained after 4 that note were an aid in helping the operator make
( 5 the determination between various actions.
6 Q And is it correct in a general sense 7 that to the extent that the operator saw one or more 8 of the symptoms listed in 1.0 through 1.8 which might 9 be common to two or three of these different 10 transients, that the note at the botto'm was designed 11 to help him determine which one of the three he had?
12 A He would certainly consider these items N-'] 13 in his overall evaluation of the event, yes.
14 Q Now, the note says, "The operator may 15 distinguish between a loss of coolant inside 16 containment, an OTSG tube rupture ~ and a steam line 17 break by the following symptoms which are unique to 18 the aforementioned accidents." And number 1 is " Loss
( 19 of coolant inside reactor building - particulate, l
20 iodine gas monitor alarm on HP-R-227 ' Reactor Building
! 21 Air Sample.'"
k.
22 Could you tell us why you understood 23 that alarm was unique to a loss of coolant accident?
24 A You are asking me to compare that 25 particular statement in relationship to a loss of i
1 .
Zewe 162
,r\
N,-]
2 coolant accident versus the OTSG tub,e rupture and 3 main steam line break?
4 'Q Yes.
5 A As was mentioned earlier, I would expect
((
6 that with the primary system activity and its location 7 and the sensitivity of this instrument, that it 8 would be able to help to determine that you did have 9 a loss of coolant inside reactor building.
10 Q Did you understand that seeing that 11 alarm was inconsistent with a-tube rupture or a 12 steam line break?
' 13 A Yes, it was inconsistent with the OTSG 14 tube rupture or steam line break inside the reactor 15 building provided there was no other related 16 casualties.
17 Q Well, I am not sure I unde'rstand the l
18 significance of the last part of that answer.
19 What other casualties might make this i
20 particular alarm go off if you had a tube rupture or 21 a steam line break?
- (. 22 A You could have a combination of l 23 accidents. One may be the first thing that happened l
( 24 which may lead to another one, or you could have two i 25 simultaneous problems.
l
1 1 Zewe 163 r
p .
- V.
2 Q But one of which would:have to involve a 3 loss of coolant from the primary system?.
4 A Well, the OTSG tube rupture does result
( 5 in a loss of coolant from the primary system.
6 Q In other words, you are saying if you had 7 both a tube rupture and a steam line break, that could 8 result in the release of coolant from the primary 9 system sufficient to set off that alarm?
10 A Things of that nature, y e's .
11 -Q Number 2 says, "OTSG tube rupture." Then 12 it refers to " Gas monitor alarm on VA-R-748."
13 Why did you understand that that alarm
. 14 was unique to an OTSG tube rupture?
15 A VA-R-748 is the off gas monitor from the I
16 main condenser vacuum pumps. And under normal 17 conditions, without the existence of an OTSG tube 18 rupture, the condenser would not see any activity 19 that would cause that gas monitor to alarm.
20 Q Then you would not expect to see that
, 21 alarm in the case of a loss of coolant accident?
22 A I would not, unless it was a combination 23 of accidents.
24 Q Number 3 says, " Steam break inside 25 reactor building." And then it refers to two separate
1 - Zewe 164
[~ ~
(T) 2 symptoms. The first is " Low condensate storage tank l
3 level alarm - and or low hot well level alarm."
4 Let's take the first one.
(' 5 Why did you understand that a low 6 condensate storage tank level alarm was a symptom 7 unique to a steam line break inside the reactor?
8 A Water to feed the steam generator comes 9 from the hot well with its normal makeup from the two 10 condensate storage tanks. E 11 If you had a steam break inside 12 containment, you would lose pressure and level in the 73 k_ 13 OTSG and the feed and condensate syste or the 14 emergency feed system would feed water into the steam 15 generator, trying to maintain conditions within the 16 steam generator.
17 This would result in excessive water 18 coming from the storage tanks and from the hot well 19 level.
20 Normally, you feed the steam generator, 21 turn it into steam, and it goes through the turbine, 22 gets exhaust back into the hot well. So that you have 23 a closed cycle except for minor leakage and losses.
24 In this case the steam is going into the building.
25 It is not being recondensed in the turbine and brought
- --,-y y_yy -
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, _ _ . - , . , . , . . - - . - . _ _ , s... _.-._
1 Zewe 165 h '
[~J
\_ ,
2 back to the hot well. So you end up reducing your 3 inventory.
4 Q Would that also be true in the case of l 5 a steam line break outside the reactor building?
6 THE WITNESS: I am sorry. Would you 7 read that back?
8 MR. FISKE: I will rephrase it.
9 Q Would what you have just said about the 10 . level of the condensate storage tank and the hot well 11 in the case of a steam line break inside the reactor 12 building also apply in the case of a steam-line break f-)r
(
13 outside the reactor building?
14 A Yes, it would. Any case where you would 15 have the steam leaking'to atmosphere where you do not
~
16 return.it to the hot well, you would have an increased 17 usage of water and it would show up as a. reduced level.
18 Q Paragraph 2 refers to the "Feedwater 19 Latch System Actuation."
20 Could you tell us why you understood that 21 that was a symptom unique to a steam line break?
22 A Unit 2 has a designed automatic actuation 23 feedwater latch system whereby if the main steam x_/ 24 Pressure is reduced less than 600 pounds, then it 25 automatically. closes the feedwater valves from adding
-- . - - - . ~
1 Zewe 166
[\ '
- v. more water to the steam generators so that you allow 2
3 the steam generator to isolate itself so that you 4 don't continually put in water and allow the steam to escape either inside containment or to atmosphere if
( 5 i
6 it breaks outside.
7 p would that also apply to a steam break 8 outside the building?
9 A Yes, it does.
10 Q Mr. Zewe, let me show youta document that 11 has been marked as B&W Exhibit 418, which is a draft 12 procedure for TMI-1, which was prepared by B&W and O
13 sent to Met Ed on the date reflected on this document, 14 June 11, 1970.
15 Have you ever seen this document before?
9 16 A Not to my knowledge or my recollection.
. 17 (continued on next page) .
18 19 20 22 23 24 25
- - . . _ . . _ . . _ . _ . . _ _ . . . - _ . _ _ _ _ . , . _ . ._ . ~ _ _ - .-
pk 1 1 Zewe 167 n.
v 2 Q I would ask you specifically, Mr. Zewe, 3 whether in connection with any work that you did in 4 helping to prepare or finalize procedures for TMI-1 you ever saw this draft procedure.
l{ 5 6 A Not that I can recall, no.
7 Q Let me direct your attention to the 8 first page of this, and the paragraph 2, that says 9 " Description."
10 I would just like to ask you to read, if 11 you would, to yourself the first two paragraphs.
12 A Under "2. Description."
n\' - 13 Q Yes.
14 A All right.
15 Q Have you read that?
16 A. Yes.
17 Q I would just like to read t'o you the 18 last sentence of the second paragraph, which says, a -
19 "However, the operator should assume the cause of 20 the symptoms described above is a system rupture or 21 leak unless another cause can be immediately C 22 established."
i 23 Do you see that sentence?
I f( 24 A Yes, I do.
25 Q In the course of any training that you
1 Zewe 168
("%,
O.
2 received at Met Ed -- we will take that first -- did 3 anyone at Met Ed ever tell you that in the case where.
4 ' you had a rapid decrease in pressure and you weren't
(- 5 'sure what had caused.it, that you should assume that 6 the cause was a system rupture or leak unless
- 7 another cause could be immediately established?
O A I don't recall anyone ever making that 9
statement or even implying here that pressure going 10 down other than the sense of loss of p$ essure and 11 loss of level which was practiced at B&W, Virginia 12 during our transient training.
Li 13 Q Just so I understand, is the answer to 14 the. question I just put "No"?
15 MR. KLINGSBERG: I think the , question
- 16 was answered. The answer was, he doesn't 17 recall anybody ever saying it. I t' h ink that 18 I
is a complete answer. You can answer a .
19 question like that yes, no, or I don't recall 20 anyone. I think that is a perfectly adequate 21 answer.
- 22 Q That is your answer, Mr. Zewe?
23 A Yes. I don't recall anyone during my 24 training bringing up this sentence about that, no.
l 25 Whether or not they ever referred to that Q
,.% --..-% ., .y.-
-r-,- -._s_ . . . - - . . , , ,_ ,,,-9 ,,m-.-# ,- -n~~,,r,-%,,,,.y--,w.+---.,-..,--...,,4, . , - - - , -
1 Zewe 169
/~'T -
V particular sentence, did anyone at Met Ed ever
,2
~
3 express that concept to you?
4 A From my review of up above, it mentions l 5 Pressure going down, and I cannot remember any case 6 or any person instructing me or trying to train me 7 that I should assume that there is a system leak, 8 that pressure goes down, as it also addresses 9 inventory and pressurizer level.
10 Q Did anybody at Met Ed ever yell you that
- 11 if you saw - that in a situation where you saw --
12 pressure dropping and pressurizer level dropping, 13 that you should assume that that was because of a 14 loss of coolant, unless you were able to 15 immediately establish another cause?
16 THE WITNESS: Would you read that back, 17 please? ,
18 (Question read) 19 A As I recall, my training was such that 20 I would have to make an evaluation of how far 21 pressurizer level was falling and how far pressure L 22 was dropping and how rapidly the pressurizer level j/
23 was falling and how rapidly pressure was falling i 24 and what evolution was going on at that particular s'
25 time.
1 -
zewe . 170 rN -
- h. 2 But that certainly entered into the 3 overall evaluation, that if I had an uncontrollable 4 loss in pressurizer level and pressure, that it
( 5 would point to a loss of inventory.
6 Q Let me show you a document which has 7 been marked B&W 614, which is a copy of the volume 8 2, Nuclear Power Plant Operations Manual, Nuclear 9 Training Center, Lynchburg, Virginia, and it has on -
10 the cover " Fred Scheimann Limits and Precautions 11 Emergency Procedures," and I can tell you that that 12 is there because this was produced from Mr.
[\
V 13 Scheimann's file.
14 I would just like to direct you to the 15 first page of this.
16 A. May I ask what date is this document?
17 Q we will get the whole volume that this 18 comes with if you want to see that before we ask any 19 questions. That will be all right.
20 A I was just curious in knowing when this
. 21 was from or what time period this document referred L
22 to or was available, those sort of questions.
23 Q I assume it is some time period during
() 24 which Mr. Scheimann was in Lynchburg, but other 25 than that, I can't give you the specific --
pk 1 Zewe 171
~
%s 2 This has been marked B&W Exhibit 535.
3 The whole volume has been marked B&W Exhibit 535, 4 The whole volume was produced by Mr. Scheimann from his files.
( 5 6 It says on the first page that it was 7 prepared January 16, 1975.
8 I can also tell you, Mr. Zewe, if it is
- 9 helpful in answering the questions that are coming, 10 that this is the basic simulator procedure that was 11 used at B&W.
12 Now I would like to direct your
(' ) 13 attention to the first page , which says at the top, 14 " Loss of Reactor Coolant / Reactor Coolant System .
15 Pressure." Then there is a paragraph that describes
- 16 the purpose. Then there is a section that is 17 referred to as " Description." Do you see that?
18 A Yes, I do.
19 Q What I would like to have you do is 20 read the paragraph described " Purpose" and then also 21 the paragraph described " D'e s crip tion . "
i 22 A I have read it.
23 Q Now, " Description" says, "This procedure s
( 24 describes the ac' tion to be taken in the event of a 25 sudden and rapid unexplained decrease in RC system
1 Zewe 172
/~N b
2 pressure and pressurizer level caused by a leak or 3 rupture in the high-pressure envelope of the 4 primary system.
( 5 "The initial symptoms could be caused by 6 a malfunction of the makeup system or by a steam 7 line rupture as well as by a loss of coolant from 8 the RC system. The operators should assume the 9 cause of the symptoms described above is an RC leak 10 or rupture, unless another cause can be(immediately 11 established.
12 ' "This procedure applies to the Rb t
\~) 13 system leak rates greater than 30 gpm.",
14 My questi'on, Mr. Zewe, is whether at any 15 time you were in Lynchburg anyone in the B&W 16 training department told you that in the case of a 17 rapid decrease in pressure and pressurizer level 18 you should assume that the cause was an RC leak or 19 rupture unless another cause could be immediately 20 e s t ab lis he d'.
. 21 A I don't remember anyone from B&W making L 22 that statement. At the time frame of which this 23 was, 1975, we were using our own Met Ed procedur
! 24 and not the OFR unit procedures.
i %
i
(
25 Q On any occasion when you were at B&W in
1 -
Zewe 173
-s .
2 any of the times you went down there, did you ever 3 see' the B&W simulator procedure?
4 A Yes. We'used typically the B&W procedures for the balance of plant electrical and
( 5 6 for the main turbine, but by and large, all of the 7 procedures that we used in operating and handling i
8 the casualties presented were all by our own 9 procedures, which they either had or we brought along 10 with us. E 11 Q Is it your testimony that you never saw 12 the B&W simulator procedure for loss of reactor
\nJ 13 coolant / reactor coolant system pressure on any of 14 the occasions you were in Lynchburg?
i 15 A I don't recall using it or looking at it.
J 16 Q. In the course of the training that you 17 received at the Navy, at B&W, Met Ed, anytime up to 18 the accident, did anybody ever tell you that in the 19 case of a situation where you weren't really sure 20 what was happening, you should follow the course of l 21 action which was designed to prevent the worst
(. 22 possible situation?
23 A What are you referring to as the worst 7
f~)
')
~.
24 possible situation?
25 g The one that might cause the most damage
- . - . . . _ - . - . - - - _ _ _ _ , . . . . . . _ . . _ . , . . . . _ , . ,_, , _ . , , _ _ - _ - . , . , - _ _ - ~ _ _
1
- Zewe 174 f~
2 to the plant and the public.
3 A I recall in a general sense, yes, that-4 you should always be prepared for the worst, but
( 5 that you should try and evaluate what you have and 6 take action based on what you have.
7 Q But were you taught that in evaluating 8 which course of action to take, when confronted with 9 a situation that could be attributable to two 10 different causes, that you should assude that the 11 cause was the one that if uncorrected would produce 12 the most damage?
O'- 13 A As I recall, not in those terms. It was 14 more in the terms of: look at what you have.
15 Evaluate what you have. And determine the best 16 course of action for what you have. And always in 17 those terms. Look, evaluate, make a judgment, 18 proceed in that direction.
19 Q And with one factor in that analysis 20 taking the action which was the most conservative?
21 A only if the conclusion that I reached k..
22 from making the evaluation and. determination -- I 23 would take whatever action I felt was warranted at
[x._/ 24 that particular time, whatever it may be.
1.
25 Q Based on the training that you had up to
i 1 -
Zewe 175 ,
O N_ -
- 2 the day of the accident,-were you aware of any '
3 upset, as you put it, which could cause a rapid drop 1
4 in pressure which would produce more damage to the
, l( 5 plant and the public than a' loss of coolant accident?
-6 THE WITNESS: Would you read that again, 7 please?
8 (Question read) 9 A It has always been my understanding that 10 the worst accident that you could have with the E 11 potential of the most damage would be a loss of 1
12 coolant accident, but I cannot ever remember of 13 solely linking a rapid reduction in pressure with a 14 loss of coolant accident, regarding any of the 15 indicated pressurizer level. It was always one 16 used in. conjunction with the other in determining 17 the LOCA condition and -- -
18' Q And isn't it correct, based on your 1
19 prior testimony, that that was also true with i
20 respect to your analysis of every other upset that 21 you were aware of that could produce a drop in 22 pressure?
23 A Yes, but a drop in pressure would be 4
( 24 accompanied by a reduction in indicated pressurizer
- 25. level, which is a reflection of inventory.
1 -
zewe -176
) -
So that . a drop in pressure at'the same j 2 Q 1
3 time you had a high pressurizer level was no more 4
4 inconsistent with a LOCA than it was inconsistent 1
1
{. 5 with any of the other. types of upsets that could 6 have produced'a drop in pressure?
r
! 7 MR..KLINGSBERG: Can we hear the 8 question again?
?
4 9 MR. FISKE: Sure.
J 10 A I am afraid I don't underst,and it.
+ 11 Q Do you want to hear it again or would 12 you like me to-rephrase it?
/~T ,
'I 13 A I would like you to rephrase it, because
'14 I heard the words that you were saying, but it was 15 hard for me to follow it.
I 16 Q Well, why don't I just withdraw it, 17 because I think it is just a conclusion from other j 18 things you said anyway.
19 MR. KLINGSBERG: Can I have the witness' t
i l 20 last answer, or the one before that?
m 21 (Record read) 22 Q Am I correct, Mr. Zewe, based upon the
< 23 understanding that you had resulting from your
( )- 24 training and experience up to the day of the 25 accident, that a situation in which pressure was i
f
. -,,.-aw, . - - , -wa,-w v~- '
1 Zewe 177 f"NI -
t v'
2 dropping while pressurizer level stayed high was no 3 more inconsistent with a loss of coolant accident 4 than it was with any of the other types of upsets
(, 5 you were aware of which could produce a drop in 6 pressure?
7 MR. KLINGSBERG: I object to the form.
8 There are a lot of negatives and things. I 9 think we ought to have it back.
10 MR. FISKE: Fine. ',
11 (Question read) 12 MR. KLINGSBERG: I object to the-form.
~}
13 A I am afraid that is the third time I 14 have heard it, and I don't ~really understand what 15 you mean by "is no more inconsistent." All right?
16 Because.that was totally inconsistent with anything 17 else, when pressure went down and level did not go 18 down.
19 Q When you say it was totally inconsistent, 20 you mean that it was totally inconsistent with a
,. 21 LOCA and it was also totally inconsistent with any k
22 other kind of upset that could produce a drop in 23 pressure?
24 A Yes. From my experience and training 25 and transient response training in Virginia, it had
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e +-
1 zewe 178 h
(O 2 never been demonstrated nor did I ever see or have 3 any discussion about that pressure would go down and 4 pressurizer level would not go down.
( 5 Q And that, I take it, is true with respect 6 to all the training that you received, whether at 7 B&W or Met Ed?
8 A Well, you must understand that the 9 training on transient response and the action to 10 reduce pressure and changes in pressurdzer level was 11 done almost solely at B&W, Lynchburg.
12 Q You are talking about the simulator.
(D 13 A The simulator there, yes. .
14 Q How about training that you had had at 15 Met Ed based on real, actual live transients that 16 had occurred at TMI-2? Did you have any such 17 training? -
18 A We did have training and review of all 19 transients that occurred there in training at the 20 island, but it was more of a classroom type training
.. 21 on, here is the curves, here is what we think they 22 mean, but the actual transient response and 23 observation in looking at the transient and trying
() 24 to. combat a transient and its explanation and all 25 the things surrounding it in a transient learning
1 Zewe 179 O
Q)
- 2 respect were.all done at B &If , Lynchburg .
3 Q But in terms of sort of looking back at 4 past history of transients that had occurred so that l 5 you would know what types of conditions occur in a 6 plant in~different types of-transients, there were a 7 number of transients that had occurred at TMI-2 r
8 where such past history was available; isn't that 9 correct?
10 MR. KLINGSBERG: I object to the form of 11 the question on the ground that it seems to me j 12 there were two or three predicates at the f
\~'
13 beginning which are not necessarily related i
14 to the ques tion at the end.
15 If there is a single answer that would 16 encompass everything, it would create 4
17 confusion. -
18 MR. FISKE: I will stick with the 19 question.
20 MR. KLINGSBERG: Read it back.
21 (Question read) 22 A There was past history available of the 23 Unit 2 upsets or transients. And I reviewed most j 24 of, if not all of the information that was available.
25 Whether I gained a great deal of knowledge from that
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1 -
Zewe 180
.2 in knowing exactly what transpired or how to use that, 3 I really couldn't say.
4 Q Based on what you learned at B&W, 5 together with what you learned at Met Ed in a review
(
6 of Met Ed transients, isn't it correct that as of 7 the day of the accident, a drop in pressure with a 8 high pressurizer level was totally inconsistent with-9 any kind of upset that you were aware of which would 10 produce a drop in pressure? I 11 A That is true. Pressure and level would 12 always trend together.
6b
\/ 13 MR. FISKE: This is probably as good a 14 time as any to break for lunch.
15 (Lunch recess taken at 12:50 p.m.)
16 17 ,
~
18 19 20 21 22 23 25
1 -
181 u( \
2 AF TE RN OON S E S S I O N 3 2:00 p.m.
4 W I L L I AM H. Z EW E resumed 5 and testified further as follows:
{
6 EXAMINATION (continued) 7 BY MR. FISKE:
8 Q Mr. Zewe, turning once again to the 9 LOCA procedure that we had been looking at before 10 lunch, referring to section B, it is correct, is it j 11 not, that HPI comes on automatically when pressure 12 drops to 1640 psig?
G 13 A Yes.
14 Q Now, in addition to the high-pressure 15 injection pumps, there are also low-pressure 16 injection pumps; right?
- 17 A Yes, .there are. ',
18 Q In the course of a transient which 19 produced a continuing drop in pressure, was there a 20 point in time at which the system was designed so 21 that the low-pressure injection pumps would start 22 putting water into the system?
23 A The system was designed like that, yes.
Can you tell us approximately what the
( 24 Q 25 pressure was at which the low pressure injection
._.. .- _ . , ~, _ - _ -. _ _ . _ _ _ _ _ . _ . . , _ . . _ . . _ _ . _ _ . _ _ _ _ _ . - , ._
1 Zewe 182
, 3 ,
\_
2 pumps would start bringing water into the system? '
i 3 A Approximately 200 pounds RCS pressure.
4 Q So do I understand that if the pressure 5 started-to drop and got to 1640, HPI would come on;
(
6 and if it got down as low as 200, the low-pressure 7 injection pumps would start putting water into that 8 system?
9 A That is correct.
10 Q What did you understand was,the rate at 11 which the high-pressure injection system would put 12 water into the system when it came on automatically?
i
\/ 13 A 1
Full system design, assuming two makeup j
! 14 pumps available, would be a thousand gallons a 15 minute total flow.
16 Q. And how many legs are there?
17 A That would be divided into Iour legs.
18 Q Now, looking at this section of the LOCA 19 p rocedure , part B, you see after " Symptoms," the 20 next section is "Immediate Action"?
21 A Page 7. Yes.
22 Q Right. And section 2.1 refers to 23 automatic action, and then 2.2 refers to manual n
(
} 24 action. Right?
25 A That is correct.
.. -- ,-, - - ~ - _ - - -. - - - .
[-
T 1
' /
1 -
Zewe 183 cm- -
\'
.'2 j Q One of the items of automatic action is' 3' l ,
that safety injection is initiated at 1600 psig RCS
'4' _ pressure or 4 psig reactor building pressure?
( 5 " ., A Yes.
6 .Q' The next section after the "Immediate
-l 7 {.'s Action section is a section called " Follow-up s i
8 l Action," which appears at page 9 under 3.0.
t 9 A' Yes.
1 10 Q Am I correct in understanding that 11_ section of this' procedure as --
c 12 A "Tha~t section" referring to follow-up-("%
13 ac[ ion?..
, 14 Q Yes.
s 15 A okay.
16 Q, Is it correct there is nothing in that 17 part of the' procedure which allows throttling back i - .
18- high-pressure injection below a rate which would 19 produce 250 gallons per minute per leg until the .
20 point comes where pressure has gone down to the 21' point where the low pressure injection starts k
22 putting ~ water in?
l 23 MR. KLINGSBERG: Objection to the fv 24 reference to the word " allows."
25 MR. FISKE: I will rephrase that question.
-~_ . _ _ _ . _ . _ _ . _
. 5-
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i
.s 1 Zewe ,
184 , ,
,m -
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2 Q Is there anything in this section , q i.
't '
1 3 captioned " Follow-up Action" w!iich provides fortthe s s ;
4 reduction in HPI flow below 250,g)21ons per minute
(
5 per leg until the time is reached'when the, pressure 6 has gone down low enough so that the low-pressure 7 injection system starts putting water in?
8 A I would like to take'a few minutes --
9 Q sure. s
, J 10 A --
and read through the follow-up -
11 actions. '}
- s 12 (witness examining., do cumen t) ,
() '?, ' "'
g:
V 13 (Mr. Glassman entered the deposition T
~
> s 4
.s 4 14 room) , ,
. .V -
15 THE WITNESS: Could you repeat the '
l 16 question, please? '
V -
, s .
x 17 (Que stion read) .
s 18 \ ,
A In my review of the pr6cedure, I don't - , .
\
- s .
19 see any other place where it allows you to.do that, '
20 but there is one point I wouleh lik'e' to make , which '
s 21 is that in the use of these procedures there are 22 other governing things that also come into play, 23 namely, technical specifications. And we do have a technical specification bas,ed on high pressurizer
^
24 V '
q t 25 level. '
= J
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- - - +- - ' * * * ~ ~-- ^'~ "# * ' ' ' ' ' ~ ' ~
4 % h 4 .
- l' Zewe 185 s
2- And depending on what mode you are in at 3 the particular time, the 885 inches is still.
f 4' applicable as' a high pressurizer level. And it was b
l
( 5 my training and understanding that I would throttle 6 high-pressure injection based on not exceeding 885 7 inches. .
- , -8 ,
Q Did you have some understanding, Mr.
l 9 zewe, that if there was a conflict between technical 10 , specifications and procedures, that you were
, 1 -
3 11 supposed'to follow tilie technical specifications in 12 ' every case?
s .s
. i, *
- ' 13 A My training ud experience taught me to
.. u , o 3
i , 14
,a1w$ys follow, if I could, the limiting case. If
! 15' the procedure was more'liuiting, follow the s
e a
! M .16 p ro c e d'ure ; and always not to violate the tech spec.
' \. T
- . 17 ,
Q You mean if the tech spec was,more -
s .c -
18 limiting, you would; follow the tech spec?
t
! ) '
j I:
19 A In most instances --
and-I cann'ot think '
r l 20 Jof many examples of this, but the procedures should 2
i 'W always be more limiting than-the spec so that.you do 21 s T
'
- r ?? n t exceed the technical specifications.
i 23 g what do you'mean by "more limiting"?
- [7 24 A Well, if you had a procedure, for A-
, t '- 25 instance, that asked you to take one course of w .
T r
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1 Zewe 186
~
b(~h 2 action which would cause you to violate a technical 3 specification, you would not just arbitrarily do 4 that. You would try to stay within the confines of
( 5 your tech specs.
6 Normally all of our procedures were 7 written such as they were within the bounds of a 8 technical specification so that, if you followed 9 those, that you would not reach your technical 10 specification limit.
- 11 Q Did you understand that you had the 12 discretion, in the course of a transient, to violate
/~h 13 the tech spec if you thought that that.was necessary 14 in order to prevent a serious accident?
15 A Prior to the accident, as I recall, I 16 was aware that I could deviate from procedures in 17 order to take emergency action which I deemed were'.
18 appropriate in a particular event that was ongoing.
19 But I don't believe that I thought that 20 in terms of exceeding a technical specification
- 21 in order to carry out an evolution at the plant.
22 I really didn't think in terms of violating tech 23 specs, but I knew that I could go beyond a procedural r^g
() 24 requirement.
25 Q In other words, your testimony is that
- - - _ _ - .- ___ _. . _ _ _ _ _._ _ _ . . . _ . . . _ ~ _ _ .
1 Zewe 187 O
V
.2 up until the day of the accident, the thought had 3 not occurred to you whether or not you would be 4 allowed to exceed a technical specification.in order
( 5 to prevent a serious accident?
6 MR. KLINGSBERG I don't think that was 7 the testimony. I object to the question.
i 8 MR. FISKE: I thought his last answer was 9 unclear enough so that I would like to have an 10 answer to the last question. E 11 MR. KLINGSBERG I don't mind if you 12 ask the question and say "Is this correct" or i
13 "Is this a fact," but I don't think it is
- 14 fair to characterize the prior answers.
15 MR. FISKE: All right, then I will just 16 rephrase the question.
17 BY MR. FISKE: .
18 Q Is it a fact, Mr. Zewe, that up until 19 the day of the accident, the thought had not 20 occurred to you at any time whether you would be
~
21 allowed to violate a technical specification if that 22 was necessary in order to prevent a serious accident?
23 A It is my recollection that I would have i
() 24 done whatever I thought was necessary in trying to 25 control an event, but I had never thought in terms of I
L
l
)
1 Zewe 188 f~g .
y, .
2 exceeding a technical specification in relationship 3 to that. I always thought that any action that I 4 could conceive of taking would still be within the
](' 5 bounds of the technical specification, but it may 6 exceed an operating procedure.
7 Q Let me put it to you the other way, just 8 so we are sure it is clear.
9 Is it correct that on the day of the 10 accident, you did not have a positive dnderstanding 11 that you were not allowed to violate a tech spec if 12 that was necessary in order to prevent a serious 13 accident? ~
14 MR. KLINGSBERG: I am very confused,by 15 that. "That you could not have an 16 understanding that you were not allowed - "
17 MR. FISKE: Yes. .
18 MR. KLINGSBERG: I object to the question.
19 MR. FISKE: Read it again so Mr. Zewe 20 can hear it and listen to it carefully and be
- 21 sure he understands it.
L 22 (Question read) 23 MR. KLINGSBERG: I really have to ask you 24 to rephrase that. If that were answered yes or 25 no, it would defy anyone's attempt to figure
1 Zewe 189 r -
V 2 out wh,at the answer meant.
3 BY MR. FISKE:
4 Q Is it correct, Mr. Zewe, that on the day
{ 5 o f the accident, you did not have an understanding 6 that you were not allowed to violate a tech spec, 7 even if that was necessary to prevent a serious 8 accident?
9 MR. KLINGSBERG: He has already 10 testified to what his understandi,ng was.
11 Q Well, is it correct you didn't have an 12 understanding one way or the other on the day of the
(\ ,, .
13 accident?
14 MR. KLINGSBERG: I think he testified.
15 A Let me say I felt on that day I would 16 have taken any action that I felt I should take to 17 combat any problem that arose, but I didn.'t link I
18 that with or restrict it by tech specs. I just 19 didn't think in those terms. I always felt in my 20 mind that whatever action I took would still be 21 within the confines of the tech spec.
22 Q It may be easier to deal with this 23 question later on.
b)
%d 24 A Okay.
25 Q Let's go back to part A, Mr. Zewe, of
.. =. . - - -. ._ - - . . . .
i 4
i~
1 Zewe 190
~
, OT 2 this' loss of reactor coolant / reactor coolant system i
3 pressure emergency procedure.
4 Part A refers to the lea k or rupture j l( 5 within capability of system operation.
{
6 A Yes, it does.
7 Q On page 2, under " Manual Action," it i 8 refers, among other things, to a manual initiation j 9 of the sa'fety injection system. Do you see that?
F~
10 A 2.2.5? .
, 11 Q Correct.
12 A Yes, it does say that and give criteria O
4 13 for when you would initiate safety injection j
14 manually.
15 Q Right. And then the next section is ,
i 4
16 3.0, " Follow-up Action."' Do you see that?
i.
i 17 A Yes.
- t
- j. 18 Q Now, you did receive training on the use
.19 of this part of the procedure, both at Met Ed and at 20 B&W7 l>
21 A Yes, I did. I received training at Met L
22 Ed on the precedure and the practical application 23 at B&W, Lynchburg.
- 24 Q Do you see the section that says "3.2, i
25 safety Injection Manually Initiated"?
l l
\ .- ,,,,. , - ,. - -. - - ,~.. - ,.- - __,-. -.._.-,,_ . - - - _,.,, _ _ - . - .-. - - ,.. - . _ _ .
I 1 Zewe 191 2 A .Yes, I do.
3 Q The first item, 3.2.1, says, " Verify 4 that the makeup pumps and decay heat removal pumps 5 start s ati's f acto rily . " Right?
((
6 A Yes.
7 Q The next item, 3.2.1.1, says "Close
- 8 MU-V12 and MU-V18." Right?
9 A Yes.
10 Q Which valves are those? E 11 A MU-V12 is the valve between the makeup 12 tank and the suction to the makeup pumps. MU-V18
('-}/
13 is the isolation valve on the normal makeup line in 14 the. discharge of the makeup pumps.
15 Q Item 3.2.2 says, " Bypass the safety 16 injection by depressing the group reset pushbuttons 17 and throttle MU-V16A/B/C/D as necessary to maintain 18 - 220-inch pressurizer level and not exceed 250 19 GPM/HPI flow leg."
20 What did MU-V16A/B/C/D refer to?
J
' ~
21 A They are the high-pressure injection 22 control valves for each of the four high pressure 23 injection legs.
() 24 Q And it is those valves that determine the 25 rate of flow into each leg?
1 Zewe 192 2 A They controlled the rate of flow in each 3 leg.
4 Q Now going over to the next page, do you
( 5 see where it says 3.2.57 It says " Caution.
6 Continued operation depends upon the capability to 7 maintain pressurizer level and RCS p re s s ure above 8 the 1640 psig safety injection actuation setpoint."
9 Do you see that sentence?
E 10 A Yes, I do. .
11 Q And under that there are two paragraphs.
12 No. 1 says, "If pressurizer level can be maintained
(,s i ,
13 above the low-level alarm point and the RCS pressure 14 above the safety injection actuation po' int, then 15 proceed to step 3.2.6." Is that correct?
16 A. Yes.
17 Q And does 3.2.6 then describe the 18 procedure for initiating plant shutdown and 19 cooldown?
20 A If you are within'those limits, then it 21 has you go to a normal plant shutdown and cooldown 22 procedure, yes.
23 Q So did you understand the meaning of O)
(, 24 this part of the procedure that if pressuriser level 25 can be maintained above the low-level alarm point
1 Zewe 193
^h ~
- (V 2 and the pressure above the safety injection actuation 3 point, then you can proceed to a shutdown and 4 cooldown?
l 5 A Are you asking me if I understand what 6 that says or --
7 Q Was it your understanding before the 8 accident that that was the effect of that particular 9 section of the procedure?
10 A Yes. !
11 ~Q Again referring to your understanding 12 before the accident, paragraph 2 in 3.2.5 says,
' (~s
\) 13 "If pressurizer level cannot be maintained above the 14 low-level alarm point and the RCS pressure above f
15 the safety injection actuation point, then the 4
16 plant has suffered a major rupture and operation 17 should continue according to part B." -
18 Do you see that?
19 A Yes, I do.
20 Q And was it your understanding before
. 21 the accident that if you could not maintain L
22 pressurizer level above the low-level alarm point 23 and the pressure above the safety injection actuation
( 24 point, then you had to go to part B of this 25 procedure?
.,.4.- . , . _ . . . , , . , - . . _ . . - _ . , _ . -.-e , _ - _ - , . - . . , . . , , - _ . ~ , _ . . _ _ . , , _ - - . . - _ . .
1 Zewe 194
(~xs_-]
2 A Yes, that you had to be able to maintain 3 pressurizer level above the low-alarm point and 4 pressure above the high-pressure injection point.
l 5 Q Right, and unless you could do both 6 those things, then you had to proceed to part B.
7 A My understanding before the accident was 8 that they would never be other than the same, level 9 and pressure would trend together, and all my 10 training and experience on the use of this procedure 11 always reflected level being as the most important
, 12 thing and that they would be trending together.
13 I was taught that way and displayed that 14 way and we trained that way at transient response 15 at B&W, Lynchburg.
, 16 Q. Right, and you did understand, pursuant 17 to that training on this procedure, that unless 18 both of them were above the low-level alarm point 19 in the case of the pressurizer and the safety 20 injection actuation point in case of pressure, then 21 you had to go to part B?
22 MR. KLINGSBERG: He has already answered 23 that. I will let him answer it again.
24 A Of course.
25 MR. FISKE: He just did.
1 Zewe 195
\
2 ,
MR. KLINGSBERG: What?
3 MR. FISKE: I thought he just did.
4 MR. KLINGSBERG: Did you say something?
( 5 THE WITNESS: I was"about to say that my 6 training did not stress, other than the sense s
7 that pressure and level were the same and they 8 were always used in the same reference, and 9' that the real key was pressurizer level, and 10 that pressurt would always trend t with it.
11 So you never had to look at level and 12 pressure; you looked at level and pressure.
~' All right?
13 They were always together, they 14 always trended together, particularly in the 15 rererence to a LOCA, which is the portion of 16 the procedure that we are in, or a leak, no 17 matter how big or how small. .
18 BY MR. FISKE:
19 Q Are you telling us, Mr. Zewe, that in 20 the course of your training at B&W,that they didn't 21 tell you that it was important to maintain pressure L
22 above the actuation point for HPI?
I i
23 A I am not saying that at all.
24 Q They never told you --
25 A Let me finish, a second.
1 -
zewe 196 r~s -
N_ .
2 Q All right. Sure.
3 A I am saying that we are referring here 4 to a leak which is within the capability, now, of
( ,5 the makeup system. And any reference that was 6 implied or taught or actually demonstrated always 7 dealt with pressurizer level as being the key, and 8 that reactor coolant system pressure would follow 9 the pressurizer level trend.
10 And in this case you are de'aling with a 11 reduced inventory which is a reflector of pressurizer
, 12 level. The pressure would also go down as the O 13 pressurizer level went down. That is what my 14 training and understanding was and actual transient 15 response training.
16 Q Nobody ever told you at B&W that you 17 didn't have to pay any attention to pressure, just 18 watch the pressurizer level, did they?
i 19 A Here again, they always used them 20 together. They did not single out and say, " Don't 21 believe pressure, only believe level." But 22 "Believe your level and pressure. Believe the 23 indication," and that they would trend together.
A
(_) 24 Q What did you understand was the function 25 that high-pressure injection played in the course
_ _, ~ ,.- -._ _ , _
I 1
Zewe 197
[~')i 2 of a loss of coolant accident?
3 A To replace the lost inventory in the 4 reactor coolant system and to restore pressurizer
]( 5 level-6 Q Did you understand that high-pressure 7 injection had any function to play in a 8
depressurization transient which was not a loss of 9 coolant accident?
10 A It was my training and understanding that i
11 every depressurization transient fell into the type ~
12 i
O that pressurizer level would also be affected, and k/
! 13 that it again would restore the inventory and 14 indication of coolant inventory as indicated by the 15 pressurizer.
J 16 Q. Did you understand that high-pressure 17 injection had, as one of its purposes, -
18 increasing pressure in the reactor coolant system?
19 A I did have an understanding that if the 20 high pressure injection system was initiated and if ~
~l a
21 the break size -- if you are referring to a LOCA --
22 that you could add more inventory to the reactor 23 i
coolant system than what was coming out the break, i
[D
\_/
24 you indeed would restore inventory and level and 25 then you would indeed recover pressure.
. _ _ _ _ _ _ . . _ , _ _ - ._ .~ . _ _ . , . . . - _ , _ _ _ _ _ _ . __ - . - _ .
1 Zewe 198 J
/.
2 Q I would like to show you, Mr. Zewe, a 3 copy of the Unit 2 emergency procedure 2202-1.5,
,4 Pressurizer System Failure, which has been previously i
( 5 marked B&W Exhibit 305.
6 Do you have that in front of you?
7 A Yes, I do.
8 Q Would you like to take a minute to look 9 at it?
10 A Yes. t 11 Q Have you had a chance to look at this, 12 Mr. Zewe?
13 A Yes. Yes, I have.
14 Q Directing your attention to the first 15 part of this section A, it refers to a leaking 16 pilot-operated electromatic relief valve. I would 17 like to start with A.1, Symptoms. .
18 No. 1 says, " Relief valve dis harge line 19 temperature exceeding the normal 130 degrees 20 Fahrenheit, alarm 200 degrees Fahrenheit."
21 What instrument did you understand 22 measured the relief valve discharge line temperature?
23 A Thermocouple that was attached to the
( 24 discharge piping.
- 25 Q Did you understand that there was a f
, , ..-.w, ,,- - - -- ~,, , e - , , , , . . , - - - . . . - . . . , - - ,m.. .-,_~p- , _ - - ~ . * , - - - _.
1 Zewe 199 g~s
(_
2 thermocouple for each of the code safeties as,well?
3 A Yes.
4 Q Did you know the location of those
{- 5 thermocouples prior to the accident?
6 A General location only.
7 Q Why did you understand that a 8 temperature at the thermocouple for the PORV 9 exceeding 130 degrees was a symptom of a leaking PORV?
10 THE WITNESS: Read that again, please.
11 (Question read) 12 A The discharge line thermocouple should
( '~
13 read ambient temperature conditions on that 14 relief line. And if you have any leakage from the 15 valve, you would have an increase in temperature on 16 that line that would be sensed by the thermocouple.
l 17 Q The manual action prescribed in l .
18 section A.2 for a leaking pilot-operated electromatic 19 relief valve is to close the electromatic relief 20 isolation valve; isn't that correct?
21 A That is the manual action that is steted 22 here in the procedure.
23 It was my further understanding that
[ 24 the reasons for closing this would be twofold, one 25 being that we would close it if the leakage past the i
l
1 Zewe 200
[')
V 2 valve would exceed any of our operating limits. This 3 would allow us to isolate that leakage.
4 The other reason was that if we would
( 5 check to see or to try to differentiate if one of 6- the code valves, RC-V1A or 1B or the RC-V2 was 7 leaking and to narrow it down to see if it was 8 RCR-V2 or the codes, we could close the valve and 9 then make a determination if it was leakage from a 10 code valve or from the RCR-V2. And if'(it was not --
11 Q Well, let's just --
3 12 A And if it was not, and even if it was
'~
13 verified that RC-V2 was leaking, we would then 14 reopen up the block valve. Because as long as we 15 could stay within our cofines of our procedures, we 16 would still continue to operate.
[.
' 17 So this manual action, even though it 18 says "Close the valve," it does not infer that we 19 may close it, that we could not reopen it up again.
f
[
20 Q Mr. Zewe, taking those one at a time, 21 you referred to leakage within operating limits?
22 A Yes, I did.
l 23 Q And by that, do you mean that under the
() 24 tech specs you did not have to shut the plant down
'25 unless there was leakage that exceeded a certain i
o
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P--e-p g -- -e2e-
)
1 Zewe 201 2 amount?
3 A That is right. The plant did have 4 specifications that we could continue to operate as l( 5 long as we were within certain leakage limits.
6 Q And they specified that if you exceeded 7 those leakage limits, then you had to shut the plant 8 down; right?
9 A Right, you had to reduce less than that 10 leakage, and if you could not do that dithin a 11 certain time frame, then you would need to shut down.
12 And what was the amount of the leakage Q
(~)
13 that you were allowed before you had to shut down?
I4 A Leakage specs vary. All right? It 15 deals with unidentified leakage and identified 16 leakage.and controlled leakage and steam generator 17 tube leakage. '-
18 The one that would apply in this case, 19 since we know that it is leaks from the code valve 20 or the PORV, that we could then -- it is identified, 21 so the leakage spec would be ten gallons a minute.
k_
22 Q So is it your testimony that so long as 23 the leakage from the pilot-operated relief valve O
(j 24 was less than ten gallons per minute, you did not 25 have to close the block valve?
. . _ _ ~ . _ _ . _ - , _ _ . . _ . . - . _ _ - _-. .~ . . _ . _ _ _ _ _ _ . . , . . . _ - , _ - . _
1 Zewe 202
(- -
\, .
2 A That is not what I said.
3 MR. KLINGSBERG: I object. That was not
,4 his testimony.
l{ 5 Q I thought the first thing you said was 6 that you didn't feel you had to close the 7 electromatic relief isolation valve as long as the 8 leakage was within operating limits.
9 A That is true. But we make a further 10 determination -- all right -- that is a,ade by the 11 plant staff. All right? We wouldn't always go 12 right up to our limit before we would take action.
O ..
13 We use that as the bounding end point.
14 Anything greater than ten, you would need to take 15 action. All right? Which would require you to get e
16 within the limits within four hours or to be in hot 17 standby within the next six hours and chid shutdown 18 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. I am referencing page 4 19' under " Follow-up Action." C.3, 1, where it talks 20 about RC system identified leakage. Since I don't 21 have the tech specs here, I am referring to that.
22 Q That is in the section of the procedures 23 that refers to a leaking code relief valve; isn't
( 24 that correct?
25 A Correct, but it identified the leakage
1 Zewe 203 r^s -
k_ .
2 spec that I feel was focused upon at this point.
3 Q What rate of leakage in terms of gallons
.4 per minute did you feel that you had to have before
(. 5 this section A of the procedure became applicable?
6 A something less than ten gallons a minute, 7 without further qualification there. All right?
8 Becaust I knew that the system was designed to 9 handle leakage up to our limits, because we had 10 designed the cooling system for the re(ctor coolant 11 drain tank based with that in mind.
12 As long as the leakage was not an O 13 operational problem, we could make that determination 14 that somewhere before we would exceed our upper 15 limit, that we would take some action.
16 Q. Is it your testimony that you didn't 17 understand before the accident that there.was any 18 reason to stop leaking through the pilot-operated 19 relief valve other than possibly allowing a leak 20 rate in excess of operating limits?
21 MR. KLINGSBERG: Objection to the l 22 question. "Is that your testimony?" I didn't 23 think that was his testimony.
l [/
x_ 24 MR. FISKE: That is what I am trying to 25 find out. I am not suggesting it has been up
1 -
Zewe 204 O- 2 to now.
3 MR. KLINGSBERG: I have a problem with 4 that.
( 5 Do you want the question read?
6 THE WITNESS: No.
7 A I answered the previous question based on 8 the amount of leakage from the valve in relationship 9 to my limit.
10 There are other considerations that are 11 made that go into determining how much leakage you 12 can in fact live with or is desirable from a plant s
(~l
'- 13 standpoint. That is one of them: total leakage.
14 Q What was the numbe,r of gallons per i
15 minute that you felt, before the accident, was 16 permissible before you had to close the block valve?
17 A As I have stated before, I don't recall 18 having a set number, other than not to exceed our 19 limits. I knew that there was some leakage from one l 20 of the three valves or a combination thereof, and
, 21 ' management was aware of that also. And we were L 22 monitoring it day by day. And I really didn't have i
23 an upper limit other than that I would not exceed
() 24 the upper limit spec.
, 25 Q What was the rate'of leakage that
1 Zewe 205 f~% ~
2 existed prior to the accident?
3 A I don't recall the exact rate of leakage 4 that we had calculated from the valve on the day of
( 5 the accident. I don't recall the exact figure.
6 Q Well, is it your testimony, Mr. Zewe, a
7 that someone at Met Ed determined what the amount 8 of the leakage was and then made a judgment that 9 that amount of leakage did not require closing the 10 block valve, even if the leak was from%he PORV7 11 A That day of the accident I was aware of 12 what the calculated leakage was. At this time, h -
f~J
\- 13 however, I don't remember that number, but I knew it 14 that day.
15 Q Were you one of the ones at Met Ed that 16 reached that conclusion on that day?
17 A That conclusion? Could you --
18 Q The conclusion that the rate of leakage 19 on March 28, 1979 was not high enough to require you
' e 20 to close the block valve, even if the leakage was 21 coming from the PORV.
22 A That was my judgment.
23 Q Who else to your knowledge participated Ih 24 in that decision?
\d 25 A That particular day?
I l
1 j 1 -
Zewe 205A
~
~
2 ,
Q Yes. That is a good day to pick.
3 A I don't recall having much'of a 4 discussion about it or taking a vote. It was my
(' 5 responsibility and my decision.
.l 6 (continued on next page) 7 8
i 9 10 t l 11 12 13 14 15 i *.
16 4
17 ..
i .
18 e e 19 20 21-4 22 i
i 23 0 24 25 1
4
,_,av,_,,,,,,,,,-~-m,,e. e- me ,_ --+vn,,w.,< nr-w
t 1 Zewe 206 m _
e r 2
Q I want to go back to a question that
. 3 I had asked you before.
4 Were you aware prior to the accident
([ 5 of any other reason why it might be important to 6 p re ve n t leaking through the pilot operated relief 7 valve?
8 MR. LINGSBERG: Other than what?
9 Q Other than preventing a leak rate in r
10 excess of operating limits.
~
11 A Yes.
12 s Q What was that reason?
O 13 A one reason was that any leakage past a 14 valve will, over time, erode the valve seat.
15 Q What are the consequences of eroding 16 the valve seat?
17 A The valve would not be leak tfght.
18 Another reason would be that we would have 19 abnormal boren concentration differences between the 20 pressurizer and the reactor coolant system.
21 And her reason would be the capacity of 22 the reactor coolant drain tank to handle the fluid 23 and to keep it cool and to transfer it to an RC l 24 bleed tank so that we could reuse that water.
I 25 And you were aware of all those reasons Q
1 Zewe 207 1
i 9
2 on the morning of the accident?
3 A Yes, I was.
4 Q Were you also aware, before the
( 5 accident, that leakage through a valve could increase 6 the potential for the valve failing?
7 A What do you mean by " valve failing"?
8 Q .I mean by "failing" a situation where 9 the valve had not worked the way it was supposed to, 10 including the possibility that once it bpened it 11 might stick open.
12 MR. KLINGSBERG: That is very confusing.
(~h
%.) 13 A Are you asking me this only.in relationship 14 to ileaking through the pilot operated relief valve?
15 Q No, I am asking you, weren't you aware 16 before the accident that one of the reasons to 17 prevent leaking through a valve is to prevent --
is 18 the possibility that leaking through the valve may 19 increase the possibility that the valve will fail?
20 A No. As I stated earlier, a valve that 21 leaks through, you could have and you will have 22 erosion of the seat. All right? Whereby the valve 23 will not be leak-tight when it is closed. But I 1%
(j 24 did not mean to infer that that would cause the 25 valve to fail to close or to subsequently fail open.
. - . ~ . . - - . ,_ __ _ __ _,
1 Zewe 208 f~h
'd -
2 It will not be as leak-tight as it would be 3 without the valve seat eroded. But it does not infer 4
that its- operating mechanism would not work or 5
([ T that it would fail in any position. It would not 6 be leak-tight.
7 And in my own mind, a valve that is 8
not leak-tight indeed has failed to a varying degree, 9 that it does not isolate completely. That it 10 leaks high. -
11 That is why I asked to cla ri fy . Valve 12 f ailur'e to you and to me may be di f fe re nt . ,
.i 3 Q Maybe I can move this along by showing ,
14 you some testimony that you gave before representatives 15 of the Senate Committee on the Environment and Public 16 gorks, the so-called Hart Committee. I am referring 17 particularly to testimony that you gave on November 18 15, 1979 at pages 33 and 34.
19 MR. FISKE: I guess you had better mark 20 it since it has not been marked, as the next 21 B&W exhibit.
22 (Testimony of Mr. Zewe be fo re the 23 Hart Committee on November 15, 1979 marked 24
() B&W Exhibit No. 740 for identification as of 25 this date.)
1
1 Zewe 203
(-)
2 Q What I want to read to you starts at 3 the middle of 33 and goes to the bottom of 34, but i
4 if you want to read any more before I start
({ 5 doing that, you are perfectly free to do so.
6 A Give me a minute then.
7 Q Sure.
8 A (Witness examining document.)
9 0.K.
10 Q Starting at page 33, questibn by 11 Mr. Recktenwald starting at the top actually, lir. e 12 3.
/ 'N 13 "Mr. Recktenwald: Now, prior to the 14 accident, were you aware that one of the relief 15 valves on the pressurizer was leaking?
16 "Mr. Zewe: Yes, I was.
17 "Mr. Recktenwald: And how long had that 18 condition existed?
- 19 "Mr. Zewe: Couple of minutes at least."
20 Let me stop there.
21 Were you asked those questions, Mr. Zewe, 22 and did you give those answers to Mr. Recktenwald?
23 A I was asked there how long that condition
(% )) 24 had existed. My answer is incorrect. It should 25 be a couple of " months" at least, not " minutes."
1 Zewe 210 2 MR. KLINGSBERG: It may not be your answer 3 is incorrect. It might be a typographical 4 error.
([ 5 THE WITNESS: I just meant my answer as 6 appears here is incorrect. To my recollection 4
7 at all, I would never have said a couple of 8 " minutes."
9 Q Anyhow, the fact is that it was a 10 couple of months? \
11 A That is what should appear there, as 12 I I recall now, rN
()-
13 Q Continuing with the questions, 14 , "Mr. .Recktenwald: And at'tha't time, were you aware 15 li of the possibility that leakage through a valve 16 could indicate or could increase the potential for 17 that valve failing? -
18 "Mr. Zewes Yes.
19 "Mr. Recktenwald: And did you ever, 20 i .
yourself, think about the potential for one of a
. 21 those valves failing, or --
first, let me ask that.
22 "Mr. Zewe: Did I ever think about
- 23 potential for the valve failing?
I
,( 21 "Mr. Recktenwald: As a result of that
- - 25 leakage.
- i. .
4 r #
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"Mr. Zewe I believe 'it crossed my
~
L > .
3
\ s.
mind, yes." ~
x
'4 Were you asked those questions and '
i
( 5 did you give those answers? < 't i
6 A '
I remember the general line of questions s
I and answers, yes. g h'
' ~~'
8 '
Q Is it your gtestimony y that when you 9
referred to the poten'tial 'for the valve failing F
i 10 in those answers, you were refer ~ ring only to the '
11 possible erosion of the valve seal?
s ,
,N t!
, A As I recall, that'is exactly what I was 'g$
i s ,
13 re fe rring to.
14 Q Le t me con titiue , Mr. Zewe, with a 3 15 '
ques tion and answer on the next page , page 34.
q ,
16 "Mr. Recktenwald: But you don't recall' s g
17 -
- i anyone e'rer explicitly saying to you, be ,
, s
! 18 e6 sbi or be aware that one of these valves might. t
, s .
. rs i,.
'- \ %
i 19
' 4 t u .s i
l
( 20 "Mr. Zewe: I think that it's generically 21 l .
, expected that if you do have leakAgd that the 99 '
~~
possibility exists, bat not specifically with 93 - '
no."
3 those particular valves, 24 Were you asked that question and did 25 you give that answer to Mr. Recktenwafd?
4 i
s
.t %
\ , _ _ _ _ _, , . - . . , - . . ., . , - - ---~~~L-*' ~ ~ ~ - ' " - ~ ~ ~ ' ~ ~ ~ ' '
', l;
- g. ,
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g a 1 N Zewe 212 Y
- sa .
. Q , ;' ,
2 A i, 4 As I recall, that is accurate for what l ,~~
', 3 I had said,4 yes, f[-
4
14 MR. FISKE: I am referring to the answer 15 Mr. Zewe gave to Mr. Recktenwald where he 16
- said, "I think it is generically _ expected 17 that if you do have leakage that the-18 ,
possibility exists."
19
- THE WITNESS: Now I have lost it.
, r
! .. . 20 woul'd you repeat it again? I am sorry.
x, 21 I lost my concentration.
-\ 22 (Question read again. )
N 23 ' [" E A
, As I re call , we may have here went back l
f: and forth between failing and sticking and leakage.
A, 1 s
= . ., j 25 As I remember now, my thoughts were that l' . -.'
I
1 Zewe 213 2
the valve certainly would fail due to leakage, 3 based on leak-tightness. Not that the valve would 4 fail open or would stick in any particular position.
(, 5 I don't remember thinking about how 6
the operator itself in controlling the opening or I
closing of the valve is affected by the steam going 8 past the valve seat.
9 Q It is correct that you told Mr. Recktenwald 10 back in November 1979 that it is generibally 11 expected that if you have leakage, that the 12 f possibility exists that a valve might stick?
V 13 A Here again, I see the words, but I don't 14 have a very accurate recollection of exactly what 15 I was trying to convey to him. All right?,
16 And as I look now, that's what I thought 17 that I was trying to convey, and I am afra'id that's 18 as far as I can remember. ,
19 Was there anything about the pilot Q
20 operated relief valve that made a generic expectation 21 that leakage might cause valves to stick inapplicable 22 to the pilot operated relief valve?
23 A Not that I can recall.
24 I remember thinking about the leakage 25 that we experienced in Unit 1 during the first i
- - , , . - . - - - - , - - . . - . . , - , , . - , , -n- . - - . - - -,--,n.-e- , , ,
1 l
l I
Zewe 214 V(~\
2 refueling cycle in Unit 1. And we operated 3 throughout that cycle with one of the valves leaking 4 by. And again there I don't remember the concern
({ 5 for a valve to stick or to fail open because of 6 that, thinking more it would erode the seat and that 7 the leakage would only get worse.
8 , (Recess taken.)
9 BY MR. FISKE:
10 Q It is correct, isn't it, Mrl, Zewe, that 11 for a period of several weeks before the accident 12 you had been seeing temperatures on the thermocouples
13 for all three of the pressurizer relief. valves'up in 14 the range of 190 degrees?
15 A Yes.
16 Q Is it correct also, Mr. Zewe, that 17 prior to the accident you really did not have any 18 reason to believe that the leaking was coming 19 from one of these valves any more than another?
20 A As I recall, I knew that one of the 21 code safety valves -- I believe it was the B 22 valve -- had a little bit higher temperature. And 23 I leaned in that direction, thinking that possibly
) 24 it might be a code safety valve more so than the 25 A valve or the PORV, but not with any
t
~
I Zewe 215 O
b 2 conclusive -- if you understand what I am trying 3 to convey here.
4 Q Right.
( 5 A I thought it might be that one more 6
because it was the highest, but nothing conclusive 7 about that. It very well could have been any of 8 them.
9 Q You were not aware prior to the accident 10 of any investigation that had been made.that had 11 determined that the leak was not coming from the 12 PORV; isn't that correct?
O 13 A I was unaware of any conclusions from 14 any group saying that conclusively it was not 15 coming from there. That is true. I was not aware 16 of anything like that.
17 Q Did you realize that it might'have been 18 helpful, in determining whether or not a leak was 19 coming from the PORV, to close the block valve?
20 THE WITNESS: Read that back again,
. 21 please.
L 22 (Qu e s tion read back.)
23 A Operationally, no. Because I did not f
) 24 think at the time, nor do I now, that it was 25 prudent for us to close the block valve. I felt
1 Zewe 216 l3 U 2 that the operable PORV to perform its intended 3 _ function was valuable, and that closing the block 4 valve and proving that it was the valve that 5 leaked, I felt that we wouldn't gain that much
({
6 from it and that I would re-open it again anyway.
7 But from the standpoint of future repair 8
work on the valve, it may have been helpful to say 9 for sure which of the valves it was. But it was 10 my understanding then that we were prep'aring at 11 the next. outage to work on either of the PORV or 12 one of the code safety valves themselves.
Ci i
N/ 13 Q Was it your unders tanding b.e fore the 14 accident that it wasn't important-to try to find 15 out whether there was a leak through the PORV?
16 A As I stated, operationally I don't 17 believe it made a lot of dif fe rence. And-knowing 18 that they were preparing to work on either the PORV 19 or a leaky code safety, I didn't feel that it 20 made a great deal of difference.
21 Q Going back to your testimony before L 22 the representatives of Senator Hart's committee, 23 ; I would like to refer you to an answer. to a l
/~S (v; 24 i
question and answer at the bottom of page 34, top
! 25 of page 35. Question by Mr. Rectenwald: "Now, 1
1 '
Zewe 217 uj 2 is it correct that if you'd isolated the block valve 3 on the PORV you could have told whether it was a 4 PORV that was leaking?
( 5 "Mr. Zewes Yes."
6 1
Were you asked that question and did you 7 give that answer?
8 A Yes, I did.
9 Q How long would you have had to 10 leave the block valve closed in order tb be able 11 to determine whether the leak was coming from the 12 PORV7
)
x/ 13 A As I re ca ll , I did not have.any particular 14 time frame in mind to determine accurately if that 15 was it or not based on the leakage that we were 16 experiencing. So I really didn't know how long we 17' would have to keep the block shut. I didn't think l 18 of it in time frame.
19 But as I read further here, it brings t
j 20 to mind some other thoughts that I had about closing 21 the block valve itself for a period of time and the 22 concern that maybe the block valve would fail shut, 23 stick shut.
(w 24 Q Maybe we will get to that in a minute,
, 25 A. All right.
1 Zewe 218
[h v
2 Q Sticking with the subject we are on 3 right now, how did you think that closing the 4 block valve would help you determine whether the
( 5 PORV was leaking?
6 A If in fact it isolated the leak that 7 we suspected from one of the three valves, we 8
should be able to determine that by doing a leak 9 rate calculation and possibly also by observing 10 the drain tank temperature and level ank the discharge 11 line from the tailpipe thermocouples.
12 Q one way you could tell would be if you
[
13 closed the block valve and the leak rate decreased 14 or stopped entirely; that would indicate that the 15 leak had been coming through the PORV, wouldn't it, 16 in whole.or in part?
17 A It would be a pretty positive' indication 18 of that, yes.
19 Q And how long do you think you would i 20 have had to have the bloc'k valve closed in order to
, 21 be able to make that kind of determination from 22 the leak rate calculations?
23 A As I recall, the leak rate procedure at (O ,j 24 that time required that we have a one-hour time 25 limit in determining the leak rate.
1 Zewe 219
~
.)
2 Q What does that mean?
3 A That means that whenever you instituted 4 the leak rate, that you would take data at time zero,
( 5 and in one hour later it would compare the data at 6 that one-hour point in making its computer calculation 7 on what your actual identified or your unidentified 8 le a;. ag e was.
9 Q Didn't you understand that you could 10 have done one of those calculations with the block 11 valve open and then close the block valve and 12 have done another one of those calculations?
f%)
\'~'
13 A That's what I am saying, yes.
14 Q And reach the determination, within a 15 matter of a few hours after closing the block valve, ,
16 whether or not there was a leak through the PORV?
17 A I don't disagree with that, nd. It 18 would take that long.
19 Q Now let me,go ahead and read the 20 rest of the testimony that you. referred to a moment 21 ago, Mr. Zewe, picking up again with a question 22 and answer on the bottom of 34 and continuing on 23 into page 35.
[V) 24 "Mr. Recktenwald: Now, is it correct 25 that if you'd isolated the block valve on PORV you
' ~
1 Zewe 220 v
2 could have told whether it was a PORV that was 3 leaking?. i 4
"Mr. Zewe: Yes.
( 5 "Mr. Recktenwald: And why wasn't that 6
done prior to the March 28 accident?
7 "Mr. Zewe: Well, the temperatures that 8
we monitored every day on the discharge pipes of 9
all three of the relief valves were inconclusive 10 where, which one was the leaky valve, and it was 11 accepted generally, I think, that we really 'did not 12 have any reason to believe that~ it was more one O 13 valve than another valve. That the one ~ code valve 14 had been consistently, at least a few degrees higher 15 than the other valves. ,
, 16 "So, I don't know why we didn't 17 ~
isolate it, and just count it from that point.
10 I really can't say that the logic wasn't there to 19 do that, just to eliminate it.
20 "Mr. Recktenwald: Could you have done 21 this on a shift yourself?
22 "Mr. Zewe: Yes, very easily.
23
, "Mr. Recktenwald; Was there any concern
\
C 24 that if you did that, the isolation valve might 25 stick?
1 Zewe 221 f).
s 2 "Mr. Zewe: Yes, there was, but that 3 wouldn't have prohibited us from doing it if we 4 thought that it was a problem, but the concern i
( 5 always is in a high-tempe rature fluid system in a 6 high-termperature atmosphere that the valve could 7 remain shut and we would lose the inability of having 8
that relief valve.
9 "We have had other valves on the '
10 pressurizer that were motor operated iso,lation valves 11 similar to that one that have had failure modes in 12 that direction."
13 Were you asked those questions and did 14 you give those answers to Mr. Recktenwald?
15 A Yes, I did.
S 16 Q And it is correct, is it not, then, 17 Mr. Zewe, that any concern about possible'* sticking 18
- of the block valve would not have prohibited you 19 from closing it if you thought that there was a 20 p roblem?
21 A Absolutely. Like I stated earlier, i 22 that I would have taken whatever action I felt was 23 warranted. .
i
() 24 Q Have you ever had a situation before in 25 your experience where the block valve for the PORV
~
1 Zewe 222 GY 2 had been closed and it stuck shut?
3 A My recollection is that there has been 4 p roblems with the block valve for the PORV cticking
({ 5 shut and also other isolation valves on the pressurizer, 6 particularly on the spray line, for another one that i
7 co me s to mind.
8 Q Let's just talk about the block valve 9 for the moment specifically.
. 10 Were there specific instances in 11 which the block valve had been closed and then it 12 stuck shut?
b)
\' 13 A.
As I recall, there were.
14 Q On Unit 27 15 A I cannot accurately recall whether they 16 were on Unit 1 and 2, just Unit 2 or Unit 1, but 17 at Three Mile Island. '
18 MR. FISKE: I would like to hear the 19 answer.
20 (Answe r" read back. )
21 (Continued on next page.)
22 l
23 24 25
( . . _ _ _ _ _
c 1 1 Zewe 223
(~ '
U} 2 Q As you sit here today, can you recall 3 any instance in which the block valve stuck shut on 4 Unit 27 4
5 A I have to give the very same answer 6 right now. I want to say yes, there was on Unit 2, 7 but I can't recall exactly when it was.
8 Q How frequently in the course of the 9 operation of Unit 2 would the block valve have been 10 shut?
- 11 MR. KLINGSBERG: When you are saying 12 " shut," you mean --
t '
\ 13 Q Just to make my question clear, Mr.
14 Zewe, under what circumstances in the operation of 1
15 Unit 2 would you close the block valve?
16 A. We have as part of our heat-up 17 procedure -- as I reme mb e r , we had it then also --
18 was that we would periodically cycle block valves 19 on the pressurizer at certain heatup temperatures 20 in order to insure that they were still moving freely 21 on the heatup.
22 Q This would be during the testing of it?
23 A This was during any heatup, whether to s
24 return to normal operation, for testing or whatever.
n- J 25 It was a portion during the normal heatup 4
- . , , . . , - . , , . . ~ , - -~~-n-,.-,-,-,nn,------, , . - - - - - - - - - - . - - - - - - . .~- . - - - - - - - . , . - - - - , .-
l' Zewe 224 2 procedure.
3 Q Were there any other circumstances in 4 the operation of Unit 2 where you.would.close the l 5 block valve?
6 A For testing.
7 Q Pardon me? Is that an answer?
8 'A For testing.
9 Q For' testing what?
10 A 6 Periodically we do planned paintenance 11 on our valve operators. After_ the regular 12 maintenance would be done or even if the valve 13 itself had been worked upon as part of.its 14 surveillance, we would then cycle the valve, check 15 the running current on the motor, make sure th at 16 'the limit switches were accurate or the indication, 17 make sure that everything was as it shobbd be after ~
18 the surveillance or planned maintenance was completed.
19 Q what action was taken at TMI-2 in any i- 20 case where the block valve shut and remained shut 21 or stuck shut? Just go on operating?
i 22 MR. KLINGSBERG: That assumes that there l
23 was such a situation.
i
() 24 Q Well,-let me broaden it to include any l 25 situation _that you can recall in which the block J
i
, i 1 Zewe 225 V
, 2 valve shut and then stuck shut. What. action was 1
- 3 taken at that point to deal with that situation?
4 A If the block valve had been shut for
( 5 whatever reason and had failed shut through its 6 control from the control room, we would have a I .
7 couple of different courses of action.
8 One would be to have an operator go in 9 on top of the pressurizer and manually crack the 10 valve off of its seat and then allow the remote 11 operator to operate the valve.
12 If in fact we could not do that, we 13 would then shut down the plant or remain shut down 14 if it was found to be stuck in that condition, and 15 then somehow repair the valve and return it to an 16 operable status.
17 Q Do you remember any case where the plant 18' had to be shut down because of a block valve that 19 was stuck shut that could not be manually cracked 20 open?
. 21 A I do remember -- just that block valve 22 you are referring to.
23 Q Yes.
O( j 24 , A I can't recall again, like I stated 25 before, with much certainty. But I believe that the
t
- Zewe 226 (x
2 time I am thinking about we were at hot shutdown 3 conditions and we did not need to shut down the 4 plant and then cold down, but we did stop from
( 5 bringing the plant up to power, and then stop and 6 repair the valve.
7 Q This is TMI-2?
8 A TMI-2, yes, as I recall.
9 Q And the valve that we are talking about 10 is the block valve for the PORV? ',.
~
11 A RC-V2 in Unit 2.
12 Q What records in the ordinary course of t'^%
i .
13 business would be created at Met Ed to reflect the 14 fact that the plant had to be shut down in order to i
15 repair a stuck-shut block valve?
16 A- I would think that the shift foreman's 17 log and the control room operator's log would 18 reflect that, i .
19 Q can you give us your best recollection 20 as to the approximate date of this incident?
21 A I'm sorry. I can't, no.
22 Q Would you expect that the shift foreman's
, 23 log and the control room operator's log would
(%s 24 reflect any instance in which the block valve had 25 been shut and stuck shut?
1 227 Zewe
( )
ui 2 THE WITNESS: Would you read that back?
3 g Let me put the question again.
4 You said before that one of the purposes
( 5 of the shift foreman's log and the control room 6 operator's log was for the shift foreman and the 7 control room ope rator to record any incident that 8
occurred during their shift that they considered 9 significant.
10 I am asking you, would you expect that 11 if there had been a block valve which was closed and 12
, then stuck shut during a shift, that that kind of 13 information would be reflected in those two logs?
14 A I thought I answered to that effect 15 previous. You had asked me where I thought the ,
16 record would be if this in fact happened, and I 17 mentioned that it should be reflected in ~the control 18 room operator's log and the shift foreman's log.
19 I just wanted to make sure we were on Q
20 the same wave length. Because the question that I 21 had asked you that you answered referred to the 22 incident where the plant had been shut down because 23 the block valve had been stuck shut. My question is 24 broader.
25 A I see.
, _ . _ . - - . _ _ . . - - _ _ _ - _.___ _ _ _ . - . _. _. - _ _ _ _ . . ~ . . . .
1 zewe 228 fy V
2 Q Whether you would expect the control
, 3 room operator's log and the shift foreman's log to 4 record any instance in which the block valve
( 5 closed and then stuck shut.
6 A I would expect it to be there also.
7 Q And would you expect the control room 8 operator's log and the shift foreman's log to 9 reflect any incident in which any of the 10 motor-operated isolaticn valves which you referred 11, to in your Hart testimony stuck shut?
12 A Are you referring to the Hart testimony f_
13 that talked about generically or --
14 Q It was the last sentence of the 15 testimony that we went over a moment ago. It said, 16 "We have had other valves on the pressurizer that 17 were motor-operated isolation valves similar to 18 that one that have had failure modes in that 19 direction."
20 And I assume by that answer you were 21 referring to other motor-operated isolation valves 22 that had stuck shut. Is that correct?
23 A That is correct, and I would expect that 24 to be reflected in the control room operator's and 25 the shift foreman's log also.
_, , - _ - . - . _ . . - - . _ _ _ . _ _ . . . . - . . . _ _ ~ __ __ - _ - _ _ . . . _ .
7 1 Zewe 229
/~N ~
2 Q Can you identify for us the particular 3 motor-operated isolation valves that you were 4 referring to in that answer?
(, 5 A The two that come to mind are RC-V3 and 6 RC-V1.
7 Q Have they got names?
8 A Yes, sir. RC-V3 is the isolation valve 9 for the spray valve. RC-V1 is the spray valve.
10 Q Referring again to the pressurizer a
11 system failure procedure, section C, page 4, do you 12 have that in front of you?
13 A Yes, I do.
14 Q Under the paragraph that says, "C.3, 15 " Follow-up Action," paragraph 3 reads, " Place code 16 relief discharge line temperatures on analog f 17 trend recorder." Do you see that? .
i A
18 A Yes.
19 Q What is an analog trend recorde'r?
20 A We have the availability on the plant 21 computer in the control room to trend up to four 22 points. There are four analog trend recorders that 4
23 are available on the computer. We could then trend I 24 any particular point that we would like to, and it N.D
)
25 has to be an analog point, that it would then read
l 1 Zewe 230 O
E s
%)
2 out and record on strip chart paper the particular 3 point of interest.
4 Q On the morning of the accident, were
( 5 the code relief discharge line temperatures on 6 an analog trend recorder?
(
7 A They were rio t .
8 Q Had they bebn placed on an analog trend 9 recorder anytime after'it was determined that the 10 temperatures had been up in the 190-dedree range?
11 A Anytime that they were?
12 Q Did you know of any time in the weeks, I
-V 13 several weeks before the accident during which the 14 temperatures were up in the 190-degree range, when 15 the code relief discharge line temperatures were 16 placed on an analog trend recorder?
17 A I don't recall if they were or not.
18 Q From where, Mr. Zewe, did you get the 19 understanding that even though you had'the symptoms 20 of a leaking pilot-operated relief valve described 21 in the procedure --
22 A What page are you on now?
23 Q 1.
N q,) 24 A Okay.
25 Q -- you didn't have to close the block r -
+-t-- - - e-, - . , . _ . -
l 1 -
Zewe 231
~' ~
.(v) 2 valve unless the leakage reached some particular 3 level?
4 THE WITNESS: May I have the first part
(, 5 of that back, please?
6 (Question read) 7 MR. KLINGSBERG: Excuse me. Are you 8 implying in your question that there has been 9 previous testimony to that effect or are you 10 asking if he had such an understdnding and if 11 so --
12 MR. FISKE: I will back up a little bit
(~#)
13 if you like. _
14 BY MR. FISKE:
15 Q You testified earlier, didn't you, Mr.
16 Zewe, that on the day of the accident, it was your 17 understanding that even if there was a leak through 18 the pilot-operated relief valve, it was not 19 necessary to close the block valve unless the 20 leakage reached some specified level in terms of 21 gallons per minute; isn't that correct?
22 A Or if there was another evaluation along 23 with that to determine that to reach the conclusion,
( 24 yes.
25 Q I didn't hear the second part of your
1 -
Zewe 232 u 2 answer.
3 A I believe I said before that there were 4 other things that we considered, not just the
( 5 maximum amount of leakage. That was one part of it.
6 There were other things that we had considered. All 7 right?
8 Remember, I said that we could go up to 9 a certain amount of leakage, at which we would take 10 I action.
}
11 Q Yes. That's right.
12 A All right.
/]--
k 13 Q That's the testimony I was referring to.
14 A Okay.
15 Q Now, there is nothing in the pressurizer 16 system failure procedure which says that you do not 1
17 have to close the electromatic relief i olation 18 valve unless the leakage reaches a certain level, is 19 there?
i 20 A There is not.
21 Q My question is, from where did you get
( 22 the understanding that you did not have to apply 23 the action specified in this procedure unless the l
24 leakage reached a certain level?
25 MR. KLINGSBERG: He has testified now
, . , . - . , n -., - , . , . , - . . - --,-,,e , ., . . . . ,,,..,,,,--y,--, . . - , - , . - - .
1 Zewe 233
[
~' '
,2 twice, once a few minutes ago and one before, 3 that there were other things which were 4 evaluated besides the leakage rate. And you l 5 keep limiting it to the leakage rate.
6 Q Are the other thin,gs that you felt 7 should be evaluated contained in this procedure, 8 Mr. Zewe?
g A Yes. I mentioned before that we do take 10 into account the differential boron codcentration, 11 which is listed in the procedure here, and that the 12 failability of the RC drain tank to handle the A a ,
\l 13 leakage and to pump the leakage from the drain tank 14 back to a bleed tank so that we could_put it back 15 to the makeup tank and not create a water problem.
4 16 Q. Is there anything in this procedure that i
17 refers to the capability of the drain tank?
18 A A.1, 2 lists that the "RC drain tank 19 p res s ure above normal -" It does indicate there 20 that it has some reference to the RC drain tank, 21 but that is the only place.
22 Q And that indicates that if you see 23 pressure above normal in the drain tank, that is a 24 symptom o f a leaking PORVs correct?
25 A Could be a symptom.
1 zewe 234 p
2 Q Yes.
3 A Yes.~ So what is your question then?
4 Q I think you answered it before.
( 5 A ch.
6 Q Is the reference to boron concentration 7 symptom A.1, 4?
8 A It does mention that, yes.
9 Q And that indicates that boric acid 10 concentration continually increasing in.the 11 pressurizer is an indication of a leaking PORV; 12 correct?
d("N 13 A Yes, it is.
14 Q And did you see an increase in boric 15 acid concentration in the pressurizer before the 16 accident?
17 A Yes, we did. -
18 Q Let me ask the question again.
19 From where did you get the understanding 20 that even though you had symptoms indicating a 21 leaking pilot-operated relief valve as specified in 22 this procedure , you could take into account the level 23 of the leakage in making a decision whether or not
() 24 you had to close the block valve?
25 A As I recall, I obtained that
1 -
Zewe 235 (R
i -
2 understanding, one, from plant management; two, 3 from our operational experience in cycle 1, Unit 1, 4 with the leaking relief valve; and also from my 1
j( 5 understanding and operation of Unit 2.
6 Q From whom in plant management did you 7 obtain that understanding?
- i. 8 A The supervisor of operations.
9 Q That was Mr. Floyd?
10 A Mr. Floyd. ';
11 Q Anyone else?
i 12 A I could only assume, though not
! - 13 directly, that other management people were involved 14 in that knowledge and agreement.
15 Q Going to section B of this procedure, e
16 Mr. Zewe, that refers to an inoperative pilot-operated 17 electromatic relief valve; correct? .
I 18 A Yes, that is correct.
19 Q At the top of the page it says, "B.1.
20 symptoms." Do you see that?
21 A Yes.
22 Q No. 2 says, "RC system pressure is d
23 below 2205 psig and RC-R2 fails to close."
Is 2205 psig the pressure at which the
( 24 25 PORV was supposed to close?
1 Zewe 236
['
L-)T -
2 A Yes.
3 Q Going to paragraph 3, "RC-R2 discharge 4 line temperature is above the 200-degree Fahrenheit
( 5 alarm," did you understand that to be a symptom of 6 an open PORV?
7 A I understood that to be a symptom of an 8 open PORV, but there were also other things that 9 could cause that alarm to be greater than a hundred 10 degrees. If the valve had lifted and kad shut or if 11 one of the code safety valves had lifted or shut or 12 if the valve began to leak a lot, I would expect s
13 to have the alarm. .
14 Q There is a' ref e rence to " Computer Point 15 (40 2) . " What does that refer to?
16 A. That is the actual analog point on the 17 computer. That is the point that is ascigned in 18 the computer that you could ask for that would 19 print up the RC-R2 discharge line temperature.
20 Q 'W a s it possible to put that particular 21 temperature on a multipoint recorder?
22 A It was not. You may be confused 23 between a multipoint recorder and an analog
( 24 recorder.
25 Q That suggestion has just been made to me
l' Zewe 237 T'N '
(_) 2 on our side of the table. , I
~3 You said.before, Mr. Zewe, when we were 4 talking about section C.of this same procedure and l 5 the part of it.that talks about placing the code 6 relief discharge line temperatures on an analog 7 trend recorder, did you understand before the 8 accident that it was possible to put the RC-R2 9 discharge line temperature on that kind of an analog 10 trend recorder? ",
11 A Yes.
12 Paragraph 4 says, "The RC drain tank Q
'O
\~/ 13 pressure and temperature are above normal on the 14 control room rad waste disposal control panel 8A."
15 Do you see that?
16 A. Yes.
17 Q I take it that also is a symptom of a 18 PORV which has failed to close?
19 A It would be one of the symptoms if the 20 valve would fail to close along with if the valve 21 had cycled or if one of the code relief valves had 22 cycled.
23 Q You were familiar with the layout of the
[)
u-24 control room in Unit 1 as well as Unit 2?
25 A Yes, I was.
\-
~
~
-1 Zewe 238 p '
%_)
2 Q .Was there a differe'nce in the location 3 of the instrumentation for drain tank pressure 4 and temperature between the Unit 1 control room and
-( 5 the Unit 2. control room?
6 A Yes.
- _7 Q Was the drain tank pressure and J
- 8 temperature in the Unit 1 control room more 9 accessible to the operators than the same information I
10 ir. the Unit 2 control room? ,
11 A Would you define "more accessible"?
,s m . 12. Q Well, withdrawn. I will put it
/ T
(/ 13- differently.
4 14 Did you have any view prior to the 15 accident that the operators were any better able to
'1G determine drain tank pressure and temperature at 17 Unit 1 than they were at Unit 27 -
18 THE WITNESS: Would you read that back, 19 please?
20 (Question read)
, gi A Yes. Unit 1 had a level recorder as s
22 part of its instrumentation for the RC drain tank.
. 23 Unit 2 only had a level instrument.
()
(~m.
24 Q Was there any other respect in which you 25 felt that the operators at Unit 1 might be better s.
-- - _ _ - _,J _e - - - - - - . _ . _ , , . _
\
1 Zewe 239
~
ks
,2 able to determine drain tank pressure and 3 temperature than the operators of Unit 27 4 A The RC drain tank panel in Unit ; --
( 5 directly behind and to the right of the operator.
6 In Unit 2, it was a panel that was 7 facing the west wall of the control room and the 8 operator would have to walk around behind the panel 9 in order to look at the instruments.
10 In Unit 1 he would just turn around and 11 walk toward the panel and view the instruments. It 12 was a little closer at hand.
, /~T 13 Q was there any other respect prior-to the 14 accident in which you felt that the ope rato rs of' 15 Unit 1 might be able to more easily determine drain -
16 tank temperature and pressure than the operators at 17 Unit 27 .
i 18 A The alarm indicating lights for the RC 19 drain tank were located at the same locat(on as the 20 level instruments and pressure instruments, and they 21 were closer and more visible to the, operator at the 22 console.in Unit 1.
23 In Unit 2 they would need to walk -back to the panel and observe the alarns there.
( 24 25 Q In other words, the alarm's were cin the e _ _ . . _ - . , , , . - , . . _ _ , .
-, , m., , . - . _ , . - . . . . . , . . , . . , , , _
.' L i
1 ,
Zewe 240 g~ l
\ !
same place in each case as the instruments?
l2 3 A Yes.
4 Q But both were closer to the operators at l 5 Unit 1.than Unit 27 6 A Yes.
,7 Q Any other respects in which it might
~8 .have been easier,.in which you felt it was easier 9 w for the Unit 1 operators to determine temperature 1 10 and pressure than the Unit 2 operators?,
11 A Not that I can remember, no.
12 Q Did you ever express 'to anyone at Met
(~% ,
k- 13 Ed, at any time before the accident, any of the 14 thoughts that you just expressed here?
15 A Anytime prior to the accident?
'16 Q. Yes.
17 A I remember making overall general 18 comments about the layout of the control room. I 19 had been more familiar with Unit 1 than Unit 2 at 20 that stage when the Unit 2 control room was being
, '21 put together and I remember making general comments 22 about the layout, and some things I thought were s
23 better in Unit 1. Some things I thought would be better in Unit
'[v 24 2. But I don't remember exactly 25 who that was or what the actual things were, other I
R 1 Zewe 241
~
., O(~%
2 than this, that, and the other thing.
3 Q Let's take them one at a time.
4 Did you ever tell anyone at Met Ed before
(' 5 the accident that you felt that the Unit 2 control 6 room should have a level recorder for the drain 7 tank?
8 A I don't recall ever making that.
9 Q Did you ever tell anyone at Met Ed at 10 any time before the accident that you delt that c 11 the instruments and the ' alarms indicating drain 12 tank pressure and temperature should be closer to 13 the operators than in fact they were?
14 A Not that I can recall.
15 Q When you refer to a level recorder, e
16 what did you mean by " level"?
17 A RC drain tank. -
t 18 Q The level of the water in the drain tank?
, 19 A Yes, the RC drain tank level recorder 20 that is in the Unit 1 control room.
21 Q What is the difference between a level 22 recorder and a level instrument?
23 A A level recorder has a pen-and-ink
[)
-Q 24 recorder on chart paper and actually records what 25 the level is.so that you could go back and review
._ _ . . - . . . _ . ._ -._,-. .~. . . . . _ . _ _ , . . _ _ _ __ _ - . . _ . _ _ - ~ _ . . - .
_ _ . - . .-. - - _ . _ . . . - . --- ~ _ _ _ _ . _ _ - . - - - = _ - . . . - - . _ _ . . . - . _
1 Zewe 242 2 where it has been over some time frame.
3 An instrument just reads out what the 4 present level is at that particular time you are
('
i 5 reading it, and if it changes from the last five
- 6 minutes to the next five minutes, all that you can i 7 do is just read what it reads at that point in
f 8 time.
- 9 (continued on next page)
' t 10 .
4 I 11
, 12 O 13 14 4
15 4
16 17 .
18 l 19 4
20 t
i 21 22 23 24 4
25 l
L_..--....-----___....-._..--. .
- =.- . ._ , . _ _ _ _
t 1 Zewe 243 2 Q From your post-accident analysis of 3 what happened on March 28, 1979, do you believe it 4 would have been helpful to have had a le vel
(' 5 recorder at Unit 27 6 MR. LINGSBERG: Hold it. Can we have 7 the question?
8 (Ques tion read back.)
9 MR. KLINGSBERG You are not asking i
10 him for his recollection of someth,ing.
11 You are asking him to now give an opinion?
12 MR. FISKE: Yes.
13 MR. XLINGSBERG: Can we go off the record 14 for a second?
j 15 (Discussion off the re co rd. ) .
16 . MR. FISKE: Wc had better put on the 17 record that following colloquy off the record.
18 I have agreed that the question will not be 19 pressed at this time.
4 20 BY MR. FISKEs 21 Q Mr. Zewe, is there any difference 22 hetween the way drain tank pressure and temperature 23 we re reflected in the control room on Unit 1 and
- \
O 24 Unit 27 25 A' They are both indicated in each unit
-. . _ ._. . ~ . . . _._._,___ .
1 Zewe 244 O, .
v 2 by a temperature and pressure indicator.
)
3 Q The same kind of indicator?
4 A I can recall Unit 1 exactly. It is a
( 5 pointer-type indicator for temperature and the
- 6 other for pressure.
7 Unit 2 is very similar, but I don't 8 recall exactly.
9 Q What was your understanding on the day of the accident as to your capability of. obtaining 10 11 inf o rma tion concerning reactor coolant drain tank 12 pressure over a period of time?
I
\- 13 A Before the accident, you are asking 14 this.
15 Q Yes, or on the day of the accident.
16 A As I recall, I don't believe thinking 17 about the problem of needing to determine ~the pressure I
18 changeover, over a period of time.
19 Q Then lot's divorce it for the moment 20 from the day of the accident and just ask for your
~'-
21 general understanding of the control room and 22 so forth.
23 what understanding did you have 24 prior to the accident as to the capability of the 25 computer and the instrumentation that were available
1 28We 245 2
to you to give you information as to the drain tank 3 pressure over a period of time?
4 MR. KLINGSBERG: I thought he answered l 5 that. But he can answer again.
6 MR. FISKE: No, I don't think he' 7 answered that.
8 A It was my understanding that I could 9 use the computer to print up what the value was 10 t of the pressure in the RC drain tank. -
11 Q At any particular point in time?
12 A f3 As I remember, yes, at any particular 13 point in time. -
14 Q Was there a mechanism by which you 15 could obtain what the pressures were over,a moving 16 period of time, like the analog trend recorder, ,
17 for example? '
18 A .As I recall, I should be able to use the 19 i
analog trend recorder for that purpose also.
20 Q Did you have an understanding, prior 21 to the accident, as to capability of the 22 instrumentation and the computer to give you 23 drain tank temperatures over a period of time?
I
) 24 A As I recall, I had the same capability 1
25 for drain tank temperature as I had for drain tank l
- ... =- =. - . .- .. . . - . . . .
Z*""
246
!O 2 pressure.
i 3 Q And did you have that same capability 4 with respect to drain tank level?
I
(, 5 A I believe I did.
4 6 (Time noted: 4:40 p.m.) :
7 i
WILLIAM H. ZEWE 1
8
- 9 subscribed and sworn to 10 before me this day t 11 of , 1982.
j 12 13 i
14
- . 15 16 1
f
^
17 .
18 l-19 i
i 20
- 21 k 22 23 24 I~
25
,e--ye -re-*e, - .
...-y-t.- ,+ev, ,,.e.+vreve-em.,,,, w,--, .-e-. -y,-m--m.,-
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g
[] -
247 I
CERTIFICATE !
2 !! :
t:
- I! STATE 0F NEW YORK ) .
3 '
l' : ss.: i COUNTY OF NEW YORK ) ,
4 0( ' ,
D I, HARVEY B. KRAMER, RPR, CSR , a Notary Public of the State of New York, do hereby certify that the continued deposition of WILLIAM H. ZEWE Was taken Defore 8
me on May 21, 1982 consisting of pages 246 t 122 -through ; ,
I further certify that the witness had been previously sworn and that the within
( ).
13 transcript is a true record of said testimony; l That I am not connected by blood or 14 marriage with any of the s' aid parties nor interested directly or indirectly in the matter in controversy, nor an I in the employ of any of the counsel.
18 l
19 IN WITNESS WHEREOF, I have heraunto set my f
l 20 F
!! hand this ('ib day of June , 1982. I l
( 21
~ ., I 33 l
_ j w .- s :s/C t u a t. - ;
hv ! HARVEY B. KRAM R, RPR, CSR ;
e4y t
et l!. -- . .
k i !
t I i' 248
- 5 i
h I
i INDEX ,
t WITNESS PAGE -
4 1
u' William H. Zewe 124
~
i I
1 i
+
EXH I B~I T S a
l-
+-
e B&W FOR IDENT. ,
5 l 6
740 Testimony' of Mr. Zewe before 208 the Hart Committee on Novemb.er t 15, 1979 " '
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