ML20072H834
| ML20072H834 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/26/1981 |
| From: | Womack E BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-06, TASK-6, TASK-GB NUDOCS 8306290767 | |
| Download: ML20072H834 (164) | |
Text
-
na 643 v.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs,
-against-THE BABCOCK & WILCOX COMPANY, and J.
RAY McDERMOTT &
CO.,
INC.,
Defendants. :
x q
s_-)
CONTINUED DEPOSITION of THE BABCOCK &
WILCOX COMPANY, by EDGAR ALLEN WOMACK, J R*.,
taken by plaintiffs, pursuant to Notice as adjourned, at the offices of Kaye, Scholer, Fierman, Hays & Handler, Esgs.,
425 Park Avenue, New York, New York, on Monday, January 26, 1981 at 9:30 o' clock in the forenoon, before Charles Shapiro, a Certified shorthand Reporter and Notary DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 8306%
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PDR DR NEW Yoms. N.Y.
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2 Public within and for the State of New York.
3 4
-1 5
APPe ar anc e s :
6 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 7
425 Park Avenue New York, New York 8
BY:
RICHA RD C.
SELTZER, ESQ.,
9
-and-ANDREW MacDONALD,'ESQ.,
10 of Counsel 11 12 s.
d DAVIS, POLK & WARDWELL, ESQS.
13 Attorneys for Defendants One Chase Manhattan Plaza 14 New York, New York 15 BY:
RQBERT F.
WISE, ESQ.,
I
-and-16 RODMAN W.
BENEDICT, ESQ.,
l 17 of Counsel l
18 l
l
.g 19 Also Present:
i l
l 20 DAVID TAYLOR
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22 23 I
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3 having been previously duly sworn by a Notary 4
Public, resumed, and continued to testify as 5
follows:
6 EXAMINATION (continued) 7 BY MR. SELTZER:
8 Q
Dr. Womack, you are aware, are you not, 9
that your testimony today continues to be under oath?
(
10 A
Yes, I am.
11 Q
When we suspended your deposition some time 12 ago, we were in the middle of discussing parts of V
13 GPU Exhibit 20 which was a memorandum from Rosztoczy 14 to people at the NRC of which a copy'was hand delivered 15 to you.
16 After the last session of the deposition 17 have you had any occasion to look at GPU Exhibit 207 18 A
No.
10 Q
Have you discussed GPU Exhibit 20 or its 20 contents with anyone since the conclusion of the
(
21 deposition?
22 A
Yes.
23 Q
With whom?
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24 A
I mentioned this, that this memorandum had b'een 25 introduced to Mr. Taylor at a social occasion immediately
1 Womack 646 bV 2
following the deposition of which I described briefly 3
to him what we had been doing.
-4 Q
What did you and Mr. Taylor say to one 5
another about GPU Exhibit 207 1
6 A
Not much beyond the fact that you had introduced 7
it and we had discussed Mr. Rosztoczy and that we had 8
discussed this particular point with respect to, I think -
9 it had to do with two-phase flow through the pilot 10 operated relief valve.
11 Q
In other words you mentioned to Mr. Taylor f~g 12 that'in the course of the d'eposition during our 13 discussion of this memorandum we were talking about 14 two-phase flow through the relief valve?
i 15 A
Yes, that's my recollection.
I met,Mr. Taylor 16 at a social occasion immediately after the deposition 17 and the conversation briefly turned to the~ deposition 18 and I mentioned that this was a part or what we 1
1 19 discussed.
20 Q
what else did you tell him about the
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21 deposition?
22 A
I don't recall that we said very much else.
I 1
23 may have
-- I may have mentioned that we spent some
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24 time on the ATOG program but I can't recall.
25 Q
with whom else have you discussed the i
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2 deposition?
3 A
well, to the extent that the deposition occurred 4
and was going forward I have undoubtedly mentioned
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5 it to Dr. Roy, to my boss, Mr. Guilbert that I have 6
had.
7 But I have had no significant discussion of 8
substance relating to the deposition.
9 Q
Have you discussed the deposition since 10 the last session with any attorney for B&W7 4
11 A
of course I have also discussed it briefly with J
12 my counsel.
%]
13 Q-with whom?
14 A
Mr. Nelson and, of course, Mr. Wise and 15 Mr. Benedict.
16 Q
How much time have you spent with counsel 17 for B&W since the conclusion of the lasb session of 18 your deposition in order to get ready for today's 19 session?
20 MR. WISE:
I object to that question and 21 direct him not to answer.
(-
22 MR. SELTZER:
Mr. Wise, I think that's 4
23 i
fairly standard to ask a witness the amount of I
24 time that he spent in preparation, 25 MR. WISE:
I disagree.
4.-
1 Womack 648 a
2 Q
In meeting with counsel to prepare for 3
your deposition resuming today did you go over any 4
documents with counsel?
(
5 A
No.
6 Q
Did you go over any points previously i
7 covered in your deposition?
1 8
MR. WISE:
I object.
I direct him not to 1
9 answer.
10 Q
Were any non-lawyers presenE.at your l
11 meetings with counsel other than you?
12 A
In matters relating to this case?
\\j 1'
13 Q
Yes.
14 A
No.
15 Q
Do you have a copy of GPU Exhibit 20 in IG front of you?
17 A
Yes.
18 Q
Do you know who sent you a copy of GPU j
19
' Exhibit'20?
t 20 A
I believe Mr. Taylor sent me this copy or sent 21 me a copy.
22 Q
To the best of your recollection, and you i
l 23 may refresh it from looking at the document, about I f)\\
t 24 when did Mr. Taylor send this to you?
i 1
l 25 A
Sometime in June 1979 to the best of my recollection t
I 1,
Womack 649
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Q When GPU Exhibit 20 was sent to you, were 3
you asked.to do anything with regard to it?
4 A
I can't recall.
5 Q
Did you do anything with regard to it?
6 A
I don't recall specifically doing anything with 7
it.
8 Q
Do you have any recollection whatsoever of 9
doing anything with respect to GPU Exhibit 207 recollectibn of doing 10 A
At this time I have no 11 anything specifically with GPU Exhibit 20.
12 Q
Do you know whether B&W prepared any D
13 response to the NRC with regard to points raised in 14 GPU Exhibit 20?
i 15 A
No, I do not know for sure.
16 Q
Did you assign anybody to analyze GPU 1
17 Exhibit 207 18 A
That I don't recall.
a 19 Q
Would you turn to page 4 of GPU Exhibit 20.
20 Do you see the heading Roman Numeral III?
21 A
Yes.
22 Q
The first sentence in that section states, 23 "The information presented in the Midland SAR is i
3 p
qj 24 obviously not sufficient to show compliance with 25 existing regulations."
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What do you understand the reference to 3
Midland SAR means?
4 A
I understand that the reference to Midland SAR I
5 means the safety analysis report for the Consumers 6
Power Company Midland plant.
7 Q
Is that a safety analysis report that is 4
8 presented to the NRC in aid of getting licensing for j
I 9
the plant?
s 10 A
Yes.
11 Q
And it would be submitted in order to get l
' 12 either a construction permit or an operating license?
13 A
Yes.
14 Q
To the best of your knowledge staff at 15 B&W assisted in the preparation of the Midland SAR,
)
16 did they not?
17 A
Yes.
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18 Q
You read GPU Exhibit 20, did you not, when i
19 you received it?
20 A
I presume I did.
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21 Q
When you read the sentence that said, i
l 22 "The information presented in the Midland SAR is i
23 obviously not sufficient to show compliance with O)
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24 existing regulations," did that cause you to ask i
25 yourself what information was not in compliance with
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existing regulations or what information was not 3
sufficient to show compliance?
'4 A
I can't recall that it caused me to ask myself 5
'that beyond interest in what this memorandum might 6
have to say.
7 Q
What do you mean beyond what this memorandum 8
might have to say?
9 A
Well, I simply can't recall any special reasoning 10 process or process for' action that spra g from reading 11 that sentence.
/T 12 Q
Do you recall whether you questioned the V
13 validity of that sentence?
s 14 A
No, I don't recall.
15 Q
Do you have any recollection of asking 16 anybody to determine whether that sentence was accurate?
17 A
Not specifically, no.
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18 Q
You keep using the word specifically.
Do 19 you have any general recollection of asking anybody 20 to check the validity of that sentence?
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21 A
Well, this of course was a time at which this 22 memorandum was connected with a task force effort that 23 the NRC had undertaken and so we were obviously interested i..
I 24 in the findings and views of the NRC as expressed 25 through their formal documentation to our licensees.
1 Womack 652 CsI.
2 This was not a piece of formal documentation to a l-3 licensee.and as such would not necessarily have 4
triggered a need for a particular response.
5 Does that help you?
6 Q
Do you have any general recollection of 7
asking anybody to determine whether this statement by 8
a specialist at the NRC was accurate or not?
9 A
Not this particular statement.
I don't have r:
10 a specific recollection of that, no.
The Midland SAR 11 was a piece of work which Consumers Power Company had 12 in progress with us and I believe it was in -- there
'J 13 was work going on even at the time of the Three Mile 14 Island accident with respect to the Midland SAR and 15 since the Three Mile Island accident there has been 16 work on the Midland SAR.
So, at any particular time 17 the opinion of a specific NRC staff member' that the i-18 Midland SAR might not be fully in compliance with 19 the then current regulations was not necessarily a 20 surprise.
(
21 The Midland SAR was the Midland construction 22 permit is quite old, the plant contract was initiated 23 in 1968 with us and over the years the regulations
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24 have changed almost continually from those s tip ula't e d 25 in the original contract and we find that we are doing
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l Womack 653 OV 2
with the utility work quite regularly and continually 3
to respond to apply to specific requests or changes in l
4 regulations that the Nuclear Regulatory Commission may 5
make.
6 Q
At or about the time that you received 7
GPU Exhibit 20 who is the individual at B&W who would 8
have been or who was most responsible for developing i
9 any-B&W response to an NRC document like this?
10 A
Mr. Taylor.
11 Q
He was the head of licensing?
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Yes, sir.
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13 Q
Is he still.the head of licensing?
14 A
Yes, sir.
15 Q
Is there anybody who you know, Taylor 16 would rely upon, did rely upon for the preparation of 17 a response to GPU Exhibit 207 18 A
No single person.
There were many people 10 within the engineering and service, the rest of the 20 organization on whom Mr. Taylor could call.
(
21 Q
Do you know of any person other than 22 Taylor who was principally responsible for preparing 23 B&W's response to GPU Exhibit 207 k_.
24 A
I think I earlier said I couldn't recall that a 25 response had been prepared to B&W Exhibit 20.
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1 Womack 654 S
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Q And that is still your testimony?
3 A
Yes.
There may have been work done but I -- at 4
this distance I can't recall what the work would have 5
been, what might.have transpired.
6 Q
Do you recall attending any meetings that 7
were convened for the purpose of discussing the 8
implications of GPU Exhibit 207 9
A Not specifically for.GPU Exhibit 20, no, I don't 10 recall attending such meetings.
We wer in this 11 period of time attempting to review all the information 12 which came to us from'the NRC and other, sources and 13 prepare ourselves to respond in ACRS' hearings and 4
14 in assistance to our customers to many such analyses 15 as this but primarily those which had received the 16 formal and official stamp of NRC and so meetings 17 certainly were held to further that purpose, but I
~
18 don't recall at this time attending a meeting that 19 focused on GPU Exhibit 20.
20 Q
What about a meeting that focused on the
(
21 substance of GPU Exhibit 20?
22 A
Well, insofar as the substance of GPU Exhibit 20 23 r,
was one of a number,I gather what were a number of k
i 24 l
inputs to the NRC's task force and finding, there x
25 were meetings that did focus on those areas.
1 Womack 655 rV 2
Q So you did have meetings focusing on 3
the response of B&W reactors to feedwater transients?
4 A
Oh, yes.
5 g
Would you look at page 7 of GPU Exhibit 20.
s 6
Would you read to yourself the first full paragraph 7
beginning with the words'"The present NRC policy."
8 Do you recall discussions that you had 9
with others at B&W concerning the substance of that 10 paragraph?
11 A
I recall in a general way discussing the response 12 or the PORV's testing for two-phase flow conditions.
13 MR. SELTZER:
I am sorry, could you read 14 that back, please.
15 (Portion of the record read by the reporter.)
1G Q
I don't understand that answer.
What 17 do you mean you remember discussing the response?
18 A
I' remember discussing I remember having heard 19 discussions about what the qualification level of 20 these valves was with respect to two-phase flow.
I
(
21-think I answered in my testimony last time a question 22 that you asked, asking whether these valves were 23 qualified for that.
I believe it was my understanding f\\_-
24 that they had not been tested for that, I think you 25 asked that question.
i 1
Womack 656 g
]-
2 Q
If the pilot operated relief valve fails 3
to reclose under the dynamics of the B&W reactor, 4
the valve will see two-phase flow; isn't that right?
5 A
That's not necessarily true, no.
6 Q
It's highly likely to see two-phase flow; 7
isn't it?
8 MR. WISE:
What is highly likely?
9 MR. SELTZER:
More likely than not.
10 A
No.
It depends all together on whether or 11 not the block valve is closed.,
I2
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Q If the block valve is open,. will a p,i lo t 13 operated relief valve which has failed to reclose see 14 two-phase flow, experience two-phase flow?
15 A
It's possible.
16 Q
In a trip of the turbine from full load 17 with the block valve open, would a PORV that has 18 failed to reclose experience two-phase flow?
19 A
I don't know.
20 Q
What would you have to know to answer
(
21 that?
22 A
Most of the circumstances of the plant and its 23 conditions and the duration of time that the valve was f~
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24 l
open.
l 25 ~
Q Let me say the duration is that it's t
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1 Womack 657
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2 going to stay open indefinitely, What would you 3
need to know about plant conditions?
4 A
Then it's possible it could see two-phase flow.
5 Q
Is it highly likely that it would see l
6 two-phase flow.
7 A
I am not sure what you mean by highly likely.
8 Q
I mean that a prudent engineer would 9
assume it would see two-phase flow?
t 10 A
If the valve remained open indefinitely without 11 any blockage of the leak that was so created, I think f-]
12 it's likely that it would see two-phase flow.
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13 Q
A prudent engineer would assume it would 14 see two-phase flow; isn't that right, under those 15 conditions?
16 MR. WISE:
I will object to the words l
17
" prudent engineer."
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t 18 Q
A B&W engineer like yourself, you would l
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l 10 assume it is a fact, isn't it, that you would i
20 assume under those conditions the valve would see
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21 two-phase flow; is that right?
l l
22 A
If the valve was indefinitely open, that's l
23 correct.
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24 Q
Based on all your knowledge, how long 25 would it take before the valve would see two-phase flow?
l
1 Womack 658 n
%d-2 A
That would depend on the conditions preexisting 3
the failure of the valve in the open position.
4 Q
If the valve fails in the open position 5
within the first two minutes after a trip from full 6
load, how soon to your knowledge would the pilot 7
operated relief valve experience two phase flow?
8 A
Again that would depend on other information 9
that you haven't provided me.
10 Q
What other information?
11 A
What the pressurizer level was, what the 12 temperature in the pressurizer was.
It would take N/
13 several minutes at least if in normal conditions it 14 would take a-number of minutes.
15 Q
Under normal --
16 A
I would expect it to take.
17 Q
Under normal operating conditions you 18 are talking about?
19 A
Yes.
20 Q
When you say it would take a number of 21 minutes under normal operating conditions, what is
(
22 the range of minutes that you have in mind?
23 A
Five to fifteen, twenty.
-s 24 Q
Dresser supplied the pilot operated relief ss 25 valve which was at the Three Mile Island plant, the day of
1 Womack 659
"\\_/
1 2
the accident, right?
3 A
That's my understanding.
4 Q
That valve was supplied by Dresser to B&W 5
pursuant to a B&W purchase specification; is that 6
right, to the best of your knowledge?
7 A
I don't know, but that would be the best knowledge 8
I would have.
I would say yes.
9 Q
To the best of your knowledge B&W did
(
10 not specify that that valve be tested for or qualified 11 for two-phase flow; isn't that true?
12 A
That's my understanding.
g-L, 13 Q
Based on that understanding do you agree 14 with the statement on page 7 that, "The valve 15 should be assumed to fail unless it was designed 16 and tested for these conditions," referring to 17 two-phase flow?
18 A
No, I don't agree with that.
19 Q
Why do you disagree?
20 A
Because the paragraph, it seems to me, makes
(
21 an assumption that during the postulated feedwater 22 transient that the valve will see two-phase flow or 23 water solution and the postulated feedwater transient 24 or the anticipated operating occurrence may -- should 25 not in fact expose the valve to that kind of two-phase
1 Womack 660 4
2 flow.
3 In the example that you gave earlier you asked i
4
.me to make the assumption that the valve had already 5
failed and I believe that under that condition it's 6
possible that the valve would see two-phase flow.
l 7
Certainly this is something that we have I have 1
8 thought about a great deal since the accident and 9
indeed I can understand shortly after the accident thbs 10 how Dr. Rosztoczy might have_come to conclusion 11 but in thinking about it over the months since the 12 accident it seems to me that the anticipated operating g
AJ 13 occurrence which is discussed here in which the 14 valve is~ intended to perform by opening for a few 15 seconds to release pure steam and reclose,thereafter 16 does not expose it to two-phase flow and therefore 17 there is an additional failure that one ha's to assume 18 something else must be wrong in order to expose the 19 valve to that, condition.
20 Q
Are you saying that the valve has to
{
21 have-already failed to reclose before it will see i
22 two-phase flow?
23 A
Yes, I believe in any anticipated operational 24 -
occurrence that would be the case.
And that was i
25 what you asked me to postulate in the earlier questions E.
/
1 Womack 661
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2 you asked me.
3 Q
Based on your thinking and studying the
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4
. problem, what, l'f any, conclusions have you reached C
5 about what caused the pilot operated relief valve 6
yat Three Mil.e Island to fail to reclose?
7'
'A I am afraid'that I haven't really reached any 8
conc 16sions with respect to what night have caused 9
that valve to f, ail that I_know.
I am not a valve e
10 expert.
11 Q
Have you discussed with anybody at B&W 12 or read any reports that have discussed the possible
'%J 13 events which may have led to the valve _not reclosing?
14 A
Well, if you mean the particular environment 15 to which the valve was exposed, the answer to your 16 question is certainly yes.
If you mean the particular 17 in terms of the valve internals and the kind of ways 4
18 that the valve might fail in the open position, I 19 don't recall specific discussions for this valve.
20 Q
Wha't possibilities are you aware of of 21 what may have caused the pilot operated relief valve
(
22 at.Three Mile Island to fail to reclose?
23 A
I really don't think I am knowledgeable enough ta T,)
24 to -- o'f the valve details to represent alternatives s
25 to you.
I have understood that in previous failure of
. _ - _. - _,~
1 Womack 662 2
these kinds of valves that corrosion might have been 3
- involved in some of the parts but I really don't know 4
that I know what alternatives might there might 5
be for this particular valve.
6 Q
Other than corrosion are there any other.
7 possible causes of the valve failure at Three Mile 8
Island that you are aware of?
.1 9
A I don't know.
10 Q
You don't know of any others?
11 A
I just don't know -- I am just not that much fw 12 of a valve expert to tell you whether there are other
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i 13 alternatives.
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14 Q
In other words'you don't know of any other
+
15 alternatives?
16 MR. WISE:
Mr. Seltzer, you have asked l
17 that question three or four times ri}ght now.
I 18 He told you he is not a valve expert.
1 19 MR. SELTZER:
And I am not trying to i
l 20 make him into one.
He is the man that is the
(
21 head of the Design section so I am trying to 22 find out whether he believes there are any 23 other alternatives other than corrosion.
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I l
24 MR. WISE:
And he told you three times i
25 he doesn't know.
Let's go on to another question.
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2 MR. SELTZER:
If that's what he wants to 4
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tell me, that can be his swor, testimony.
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4 A
Is'your question do I believe there are oth.er x
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Q 1ea.
7 A
Well, there are.
-3 8
Q What are they?
9 A
I can't enumerate those for you,o It's a 10 complicated valve and in the sense that,it involves l
11 a pilot, it involves an electrical control system 12 and certainly in 'he whole scope of what might cause t
~
13 the halve to fail one would have to loo.k at the entire 14 s triiig o f equipment that operates the valve as well 15 as the valve itself.
i s
16 Q
From your own thought process, from 17 discussions with othe'rs or reading that you have done, 18 abe.you aware of any other alternative causes of
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19 A..alvs faliure ot! er than corrosion?
20 A
Generally aware of any other alternative causes 21 of-failure of this kind of' valve?
2 22 Q
Yes.
23 A
or -- or events that would lead to the stay open.
24 MR. WISE:
I will say, Mr. Seltzer, that n.
25
~ question has.been asked and answered.
You already 1
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asked him and he testified he is, Re said he 3
can't enumerate.
He said there are but he 4
can't tell you what they are.
You keep asking 5
the same question again.
6 MR. SELTZER:
In the past we have been -
7 very successful and we begin to get answers and 8
part of it may be just semantics.
If I 9
rephrase the question, it gets a responsive cord whereas my first phrasingmahnot 10 have 11 gotten a responsive cord.
12 MR. WISE:
I don't object to your trying 13 MR. SELTZER:
Thank you.
14 MR. WISE:
But I think we have been 15 through this on several questions and we ought 16 to move on to something else.
17
~
the THE WITNESS:
Would the reporter read 18 question back.
19 Q
I will restate.
I want to know what other 20 alternatives you are aware of from your own thinking
{
21 from reading and from talking with others that may 22 have caused this valve to fail?
23 MR. WISE:
You want him to enumerate or 24 to tell you whether or not he knows of other 25 alternatives?
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I Womack 665
.d 2
MR. SELTZER:
He said he knew of other 3
alternatives.
I want to find out which ones 4
he specifically is aware of.
5 A
There is an important distinction between the 6
question as I thought you asked it a few minutes ago 7
and as you just asked it.
When you say "this valve,"
8 do you mean this particular valve?
9 Q
This type of valve.
10 A
okay.
This type of valve.
Well -there 11 certainly -- I have understood failures of this kind 12 q
of valve which have been introduced -,have been D
13 caused by its control system,by power supplies to 14 its control system as well as failures which have 15 involved mechanics of the valve itself.
16 Q
From anything that you have read or heard 17 do you have any reason to believe that thdre was a 18 failure of the power system to the valve that caused 19 the failure of the Three Mile Island valve?
20 A
On March 28th, 1979?
21 Q
Yes.
22 A
No, I don't believe I have read anything or 23 heard anything that indicates that.
/~'T 24 Q
What possible mechanical failures are you 25 aware of that could have been responsible for the failure
I Womack 666
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2 of this-valve on March 28, 19797
{
3 A
Well, the valve has a pilot and it has, as I 4
understand the valve, it has a pilot and a moving 5
disk (indicating).
Presumably some failure within 4
6 that entire structure caused the disk not to move back 7
to its closed position.
Now, if we laid the drawing i
8 on the table you and I could speculate together and 9
you probably as adequately as I about what might t
10 have caused that to happen.
But I am not sure what 11 you are after, Mr. Seltzer.
12 Q
cince G
13 A
I am not trying to withhold anything from you, 14 let me assure you.
15 Q
Since the March 28 accident what work, 16 if any, are you aware of at B&W to analyze the causes 17 of failure of a valve like the pilot operated relief 18 valve at Three Mile Island?
10 A
Well, since the March 28th accident the -- certainly i
20/.
after the accident previous failures of similar valves 1
i
(
21 were reviewed, we obtained some information, additional t
22 information with regard to failures of these kinds of 23
' valves, the EPRI, that's the Electric Power Research 24 Institute, initiated a qualification and testing i
25
' program on the general area of pilot operated relief I
1 Womack
(_s)
~
667 2
valves and our customers were participating and 3
I believe we, although I am not thoroughly familiar 4
with this, we also are participating on behalf of 5
our customers.
Pilot operated relief valves generally 6
have been, I think, examined again in the light of -- in 7
the light of the importance of this accident and 8
operating experience and we have pilot operated relief
~
9 valves elsewhere in the plant.
In recent months e
10 we have been doing some test work for so~me valves yet 11 to be installed on some of our backlog plants.
I2 (V~}
Q Is there a particular unit at B&W that 13 is doing analysis on causes of failure of pilot 14 operated relief valves?
15 A
I don't know whether they are doing such analysis 16 or not.
17
~
Q Since the accident are you aware of any 18 unit at B&W'that has been doing such analysis?
19 A
I don't recall specific analysis of this knowing 20 about specific analysis of this sort.
There may have
[
(
21 been some.
22 Q
You are saying to your knowledge no one at 23 B&W has been doing analysic within B&W on causes of 24 failure of the pilot operated relief valve, the type 25 that is in the Three Mile Island plant; is that right?
).
1 Womack O
~
668 2
A I said I didn't know.
There is a unit which 3
has responsibility for valves.
We have had te s timo ny 4~
on that in previous sessions of this deposition and 5
it would not be an unreasonable speculation that 6
they have that they examined causes of failure and 7
go beyond that.
8 Q
But you have absolutely no knowledge of 9
their actually doing that; is Khat right, is that your 10 testimony?
11 A
Well, I am well aware that they exan.ined causes 12 of failure with valves including failures that might p
13 occur during testing but I don't I took the thrust 14 of your question to be some sort of a special 15 examination, a general examination and I don't know 16 whether such a thing has been done or not.
17 Q
So you know of no special or general 18 examination of the causes of failure of a pilot 19 operated relief valve like the Dresser valve at Three 20 Mile Island that's been done since the TMI accident;
{
21 is that right?
22 A
The closest thing which comes to mind is with 23 respect to a different valve of a similar type.
We 24 have recently had some design review work for pilot 25 operated valves at TVA but it's not a pressurized
? _.,
,.. - ~
I Womack
,<y 669
)
'w) 2 relief valve.
That's what I know about.
As I say, 3
there may have been other work.
4 Q
Do you know whether any work of this type 5
was subcontracted out to anybody other than B&W?
6 A
I don't recall.
I just don't remember.
7 Q
Do you know whether B&W has asked Dresser 8
to do any analysis of this?
The "this" is, do you 9
know whether B&W has asked Dresser to do any analysis t
10 of the causes of failure of a pilot operated relief 11 valve of the type that failed at Three Mile Island?
x 12 A
No, I don' t know whether they have or not, whether 13 B&W has or not.
14 Q
Do you know whether Dresser has done any 15 such analysis?
16 A
No, I don't.
17 Q
You said that there are others at B&W who 18 would be more knowledgeable than you about causes of 19 failure of a valve of the type in Three Mile Island.
20 Who, to your knowledge, would be most
(
21 knowledgeable at B&W about what may have caused the 22 Three Mile Island pilot operated relief valve to fail i
23 to reclose?
24 A
Well, I am not sure that I can name a person for i
25 you, but in our previous session you asked me what group
.R
1 Womack 670
(~)
( J.
2 at B&W would be -- would be responsible for valves 3
and valve specifications and performance and I think 4
we identified the Equipment Engineering section of (E
5 the Engineering Department.
I would assume I
)
6 would certainly myself think that that group would i
'7 contain the knowledgeable people, 8
Q Is there any person particularly in that l
l 9
group that you would have a high degree of confidence t
10 would be knowledgeable about this?
11 A
I think the manager of that group at that time
^3 12 was -- would certainly have been knowledgeable and --
13 Q
Who is that?
2 14 A
I believe at that time it was managed by 15 Mr. Doug Lee.
16 Q
Is he still at B&W?
p 17 A
Yes, he is.
~
18 Q
Did he continue to be the head of that '
19 unit for some time after the accident?
20 A
Yes, he did.
(
21 Q
For how long after?
22 A-About 15 months.
23 Q
Where is Doug now?
fY
\\
24 A
He is managing another engineering section.
25 Q
Which one?
e
1 Womack 671 mU 2
A Plant engineering.
3 Q
Is that your old shop?
4 A
Yes, he succeeded me.
(
5 MR. SELTZER:
I would like to mark for 6
identification as GPU Exhibit 21 a memorandum 7
from Al Womack to C.W.
Tally.
The subject, 8
PORV Reliability Study, July 19, 1979.
This is 9
not a very legible copy.
Do you have a better u
10 one?
11 Q
Dr. Womack, I won't apologize for the 12 difficulty that you are having reading it.
This is d-13 the best copy that your lawyers gave to us.
14 Would you have access to any version of 15 a memorandum that you had written to Tally on this 16 date that would be clearer than this if you were back 17 in your office?
18 A
I suspect we could find one if I were back in 19 my office, but 20 Q
Where would you look?
21 A
I would probably go to the document room and
{
22 find the original from which this was photographed.
23 (Memorandum from Al Womack to C.W.
Tally
(
24 l
dated July 19, 1979, subject, PORV Reliability 25 Study, marked GPU Exhibit 21 for identification, l
L
1 Womack 672 2
as of this date.)
3 Q
What document room is that?
-4 A
The document room that is being collected -- where 5
documents produced for this case are being collected.
6 Q
Is it your understanding that a microfiche 7
version would not be the only version in which B&W 8
has maintained a copy of this document?
/9 A
No, that's not my understanding but I wouldn't 10 be surprised if a hard copy version might be found.
11 Q
To your knowledge, have hard copy versions 12 of any documents that you have created since the 13-accicient been thrown out or destroyed as part of a 14 systematic document retention or destruction program?
15 A
No, not as a part of a systematic program.
I, 16 within the limits of the requests that were made for 17 this case and the document retention requests that 18 were made by the NRC shortly after the accident I 19 otherwise retained or discarded documents to suit my 20 convenience.
21 I did at one point attempt to reduce or to
{
22 increase filing space by microfilming, by substituting 23 microfilm retention for hard copy retention of my 24 personal chronological files for some period of time.
25 That's the only systematic thing that has been done.
1 Womack 673 7-U 2
Q When you did that did you destroy the 3
hard copies or did you just send them somewhere else 4
for storage?
'5 A
No, for the most part I pitched the hard copies 6
because my objective was to reduce the volume of filing.
7 Q
Were you throwing out or destroying 8
documents created since the accident?
9 A
I don't remember what period was covered, but t
10 I might have been doing so, yes.
But certainly it 11 was not destroying the only record of anything 12 because the microfilm was done.
s 13 Q
Have you ever had to get hard copies of 14 documents that you have microfilmed?
15 A
I may have on a couple of occasions used 16 microfilm retrieval.
But generally back referencing 17 isn't that common.
~
18 Q
Are you able to get copies that are 19 better than GPU Exhibit 21?
20 A
I don't think I have enough statistics to say,
(
21 Q
Frankly, I am very concerned because 22 looking particularly at the handwriting on the 23 attachment there are portions that are almost, if
)
24 not completely, illegible.
25 MR. SELTZER:
Off the record.
_ =_
1 Womack
(_)/
674
(~
1 4
2 (Discussion off the record.)
1 3
Q Have you had a chance to review the 4
contents of GPU Exhibit 21?
5 A
Not entirely but let's proceed and review it 6
as you identify your interest in it.
7 Q
Why did you send this memorandum to 8
Tally?
9
.A Well, I was reviewing a draft that Tally had 10.
written of some work'looking at the probability from 11 a system level that a pilot operated relief valve 12 might fail to open, 13 Q
What do you mean from a system'levrl?.
i 14 A
Well, harking back to your. previous series of 15 questions the focus of this work was not on the t
]'
IG mechanistic means within the valve by which the valve i
I' 17 might fail to open but what kind of system conditions 18 brought on by the kind of additional failure we 19 discuseed might create conditions in which the valve 20 would be exposed beyond what we had intended or
(-
21 expected to be exposed to in the design and that 22 might lead to failure and then using phenomenal 23 logical data to try to estimate the probability of O*
^
24 failure.
25 Q
Would you look at your paragraph 5 on the i
I
_ _ _ _ _., _, _. _,.,. ~ _... _ - =
I Womack 675 2
first page,.please?
Do you see the second sentence
.t beginning with "Because delayed auxiliary feedwater..."?
4 A
Yes.
(
5 Q
You stated to Tally, "Because delayed 6
auxiliary feedwater will cause rapid multiple cycling 7
of the PORV and ultimately lead to passage of two-phase 8
fluid through the valve, it is nonconservative to 9
assume'that the probability of PORV failure, given 1
the operatin(g experience t
10 that event, is the same as t
' ll for which the PORV opens only once, releives steam, 12 and then recloses."
i 13 A
Yes.
J i
14 Q
What,-in your jargon, does the word 15 "nonconservative" mean?
16 A
It means that if one wants to design for this l-17 particular event in a conservative way, a way-which 18 tends to' view the world as bad as it could reasonably
' 19 be or worse, that one should follow the prescription i
20 I have given at the bottom part of that paragraph.
i
((
21 Q
Are you saying it was not a reasonable 22 conservative assumption to assume that in the event l
23 of delayed auxiliary feedwater, the valve would merely I
['h
(_)
24 be called upon to open once?
25 A
That's correct.
In the event that the feedwater u
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was significantly delayed the valve would be called 3
upon to open more than once.
4 Q
Therefor it would have more than one 5
opportunity to fail, right?
f j
6 A
Yes.
7 Q
That was the point you were making in 8
that sentence?
9 A
Yds.
t 10 Q
And a reasonable conservative analysis 11 should assume that the valve will have more than one 1
j 12 opportunity to close in a delayed auxiliary feedwater 13 event?
14 A
Yes.
If the delay is long enough.
4 15 Q
In the next sentence in that same third 16 paragraph of GPU Exhibit 21 y'o u state, "For the case i
17 of delayed auxiliary feedwater, to be conservative
~
18 we must assume that the probability is unity, that 19 the PORV wili fail, especially when faced with 20 two-phase flow conditions."
I
(
21 when you say "we must assume that the i
j '-
22 probability is unity," what does that mean?
23 A
I am representing my opinion in that case that l
l
(_j 24 we don't have a lot of phenomenological data in
{
25 which to conduct this study,that if we really want to
1 Womack 677 m
2 get at the worst case of what might happen here, if 3
the feedwater is long delayed and the valve is faced 4
with many, many cycles of operation, or faced with C
5 two-phase flow, the conservative thing to do is to 6
assume that it fails open.
7 Q
What did you mean you didn't have 8
phenomenalogical data?
9 A
Well, as I explained to you a few minutes ago, I
E 10 we were not trying to estimate from analysis of the 11 valve's design or structure what its probability of 12 failing was.
We were rather trying to estimate from
(-]
A/
s 13 the frequency of failure of the valve in the open 14 position simply from the number of times it was 15 challenged.
We didn't have awfully good data on that 16 and so when one doesn't have awfully good data, 17 sometimes one chooses the conditions which will 18 produce the negative outcome in design and that was 19 what we were doing here.
20 Q
Did you believe at the time you wrote
(
21 GPU Exhibit 21 that it was a reasonable conservative 22 assumpt4on to assume under these conditions that the 23 I
probability of valve failure was unity?
24 A
Under the conditions of rapid repeated cycling 25 for some period of time and passage of two-phase flow
1 Womack 678
~s r
2 I think it was conservative to assume that the valve 3
might fail.
4 Q
When you say it would be conservative, 5
are you saying that under the de' sign criteria that 6
B&W sets for itself you believe that the assumption 7
of valve failure under these conditions is one that 8
B&W should make?
9 A
I meant that in the particular instance of
(
10 what we were trying to do here, which was to estimate 11 the probability of valve failure, and where in the
^x 12 light of what we were trying to do here it was important 13 that if we -- that any uncertainty of the estimate 14 led to a higher rather than a lower probability, that 15 it was conservative to do what I said.
16 Q
I understood that from your last answer.
17 When you say that the probability is 18 unity, you are saying that you would be conservative 19 to assume that the valve will always fail under these 20 condi tio n s, right?
(
21 A
For the purposes of this study, yes.
22 Q
Are you saying that for design purposes if 23 B&W were going to be using this analysis an engineer 24 would be conservative if he assumed the pilot operated 25 relief valve would always fail when exposed to these
1 Womack 679 2
exact conditions?
3 A
I don't think I was making a statement more 4
general than I made.
5 MR. SELTZER:
Why don't we take a break.
6 (Recess'taken.)
7 BY MR. SELTZER:
8 Q
When you wrote GPU Exhibit 21 you said 9
that the subject was PORV Reliability Study; is that i
10 right?
11 A
That was what I entitled the memorandum.
12 Q
Let me ask you a housekeeping question.
~s 13 Is this a copy of a memorandum which you 14 wrote in or about'mid July 1979 in the regular course 15 of business?
16 A
Yes.
17 Q
What was the purpose as you understood it 18 for B&W conducting a pilot operated relief valve 19 reliability study?
20 A
our customers had asked us to conduct such a
(
21 study in response to an NRC request.
22 Q
What is your understanding about why the 23 NRC was requesting such a study?
24 A
I believe they requested such a study from all 25 licensees.
That doesn't answer your question.
I merely 4
- ~,,,,
,y
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1 Womack g-680 V
2 assume it related to focusing on as many aspects as 3
they could of the accident at Three Mile Island and 4'
this having been an aspect of that accident they 5
wished to focus on that.
6 Q
The Technical Review Committee said that 7
the failure of the pilot operated relief valve to 8
close was a significant contribution to the accident.
~
9 Do you agree with that?
t 10 A
That was a significant event in th'e accident.
11 Q
On page 2 of GPU Exhibit 21, Item 5b, 12 m
you stated, " Delayed auxiliary feedwater following a G
13 loss of normal feedwater event has a high likelihood 14 of producing a PORV opening and failure to reclose."
15 What did you mean by the phrase, "a high 16 likelihood"?
j A
The same thing I meant when I testif)ed earlier, 17 18 that if you create a situation in which you, cause 19 the valve to cycle many times and/or put two-phase 1
20 flow through it, it is reasonable to assume that it
(
21 might fail, it has a high likelihood.
l 22 Q
When you say it is reasonable to assume l
23 that it would fail, you mean it would be reasonable
(\\
t
\\~/'
24 for B&W engineers to assume that it fails?
25 A
Yes.
Or anyone concerned with the performance of
1 Womack 681 4 - (3 2
pilot operated valvus.
3 Q
Would you turn to the attachment to your 4
memorandum, specifically page 4 of the attachment?
5 A
Is this a page which begins with a number 2 in 6
the upper left-hand corner?
7 Q
Yes.
8 A-And then it says "The probability of the PORV
^
9 opening," et cetera?
(
10 Q
Yes.
11 Whose handwriting is on this?
Is that 12 yours?
es Nm 13 A
I can't be sure that it's all mine.
Some of it 14 looks like mine.
4 15 Q
which of it looks like yours?.
.16 A
I think the handwriting at the bottom.
17 Q
"This is valid only for steam relief"?
18 A
Yes.
19 Q
That's your writing?
20 A
I,believe so.
(
21 Q
You say "This is valid only for steam 22 relief, and only for one-cycle operation;" is that 23 what you said?
O(_)
24 A
That's that appears to be what it says.
25 Q
what do you say after that, to the best you
l 1
Womack 682
(~V)
~
2 can make out your writing?
3 A
I think it says "Not conservative to assume 4
this" and then I can't read it, but I think the i
5 thrust of that handwritten comment is the same of the 6
thrust of the paragraph we have been discussing on 7
the first page of the memorandum covering this.
4 8
Q Do I understand you correctly then to be 9
saying that to assume only four failures out of 146 10 cycles is not conservative?
11 A
No, that may be perfectly correct, to assume i
12 four, failures out of 146 cycles, the thrust of the 7-(_)
13 note is count all the cycles.
14 When you are looking at a hypothetical event 15 and attempting to assess the likelihood that the 16 PORV may fail, and the event itself creates more than i
17 one cycle, you should look at the number of cycles.
18 I think that's the thrust of it.
10 Q
In the paragraph at the bottom of the 1
20 page it says that there is a probability of the pilot
(
21 operated relief valve failing open which can be stated 22 by the fraction 4 over 146; is that right?
23 A
Yes, that's what it says, i
24 Q
Does that mean that based on operating i
i 25 data the pilot operated relief valve had failed in
....m
__.m
,,v.
1 Womack 683
(_)
2 the open position four out of 146 times, that the 3
valve had been actuated during a reactor trip event?
4 A
Those are apparently the data that the engineer 5
had.
6 Q
And it is data showing failures to close 7
during 146 reactor trip events in which the PORV had 8
been actuated; is that right?
I just want to make 9
sure your understanding of this is similar to mine.
10 A
That is what the next sentence says so I don't 11 have any reason to question it.
12 N
Q If it failed to reclose four out of 146 13 times, does that mean that approximately 1 out of 14 every 36 or 37 times the pilot operated relief valve' 15 failed to reclose after it had been actuated during 16 a turbine trip event, a reactor trip event I mean?
17 A
Well, those data would indicate that but as 18 the engineer continues in the next sentence he himself 19 recognizes conservatism due to the fact that some 20 of these trips did involve multiple openings which
(
21 of course were not counted in the 146 of the PORV and 22 also, because the records and data which was available 23 to him did not allow him to count into the denominator
((_3) 24 of this fraction those events in which the pilot 25 operated relief valve opened and prevanted through
i f
I 1
Womack 684 x
2 the other actions of the control system the necessity 3
to trip the reactor and so I am inclined to believe 4
that this number is a fairly conservative offer 5
estimate of the number -- of the likelihood of failure 6
on a single opening.
7 Q
Have you seen any other statistics on 8
probability of failure of a pilot operated relief l
9 valve?
(
10 A
Yes.
I can't recall specific docu'ments, but I 11 have seen numbers discussed, I believe that are somewhat t
I2 lower than this and I am not sure that.we did not get 13 better numbers later when we finally published this I4 study.
So, I suspect that the answer to your question 15 is yes.
i 16 Q
When you say this study was finally 17 published, what do you mean by published?,
18 A
I believe we released the results of this study 19 sometime after this to the customers in some form.
{
20 Q
Whom would you contact to get a copy of
(
21 the final report?
22 A
Again I think I would try the document room.
23 Q
other than the document room, who would
/3 N-)
24 have created that report or kept a copy of that report?
25 A
It might also be in the records of the Customer i
l
{-
a
1 Womack 685
(~%
()
2 service Department which finally had transmitted it 3
to the customers.
4 Q
The study showed a probability of failure f
I-5 of four out of-1467 6
A
- Yes, 7
Q But you said that you believed it would be 8
conservative to assume thr.t the probability of failure 9
is unity for delayed auxiliary feedwater events of 10 certain durations right?
11 A
Yes.
12 Q
For what purpose did you believe that the 13 probability of failure should be conservatively assumed 14 to be one?
15 A
For making an estimate which would be likely to 16 yield the highest expectation of a failure.
17 Q
I didn't make myself clear.
18 For what purpose would such an estimate 19 of failure be used or useful?
20 A
In this particular case to answer the question l
21 of expectation of PORV opening and expectation of
'N.
22 PORV failure, in the context in which we understand 23 what we wanted was an estimate which would tend to
(~%
t,,)
24 be on the high side rather than on the low side.
25 Q
You couldn't have picked a higher probability
~.
1 Womack 686 s
V)
/
2 than one, could you?
3 A
Not for that particular set of conditions, no.
J.
4 Q'
For any set of conditions could you ever 5
pick a probability that is better than one?
6 A
No, that's'the maximum probability.
7 Q
- Okay, 8
For what purpose did you believe it was 9
appropriate to recommend that the appropriate 10 probability of failure should be viewed as one for a 11 pilot operated relief valve?
12
('T A
For the purpose of this study and_in the context V
13 of the conditions that are enumerated on the front 14 page of this memorandum.
15 Q
Who was going to apply this study and to 16 what were they going to apply it?
17 thos}equestions, A
I am not sure of the answers to 18 but the study was to be provided to the Nuclear
]
19 Regulatory Commission ultimately, the results.
20 Q
When you said that you believed it was
(
21 conservative to assume that the probability of failure 22 is one, in other words assume it is always going to 23 fail under delayed auxiliary feedwater events of
('T kl 24 certain duration, does that mean that somebody applying 25 your conclusion would'have to assume that in a delayed
1 Womack 687
('
(.N) 2 auxiliary feedwater event of certain duration they 3
can't count on the pilot operated relief valve closing?
4 A
Yes, I think that's correct.
If it were 5
important for you to count on the valve closing, you 6
should question whether it would or not under those 7
conditions.
8 Q
In fact, you should assume it won't close, 9
right, under your conservative a s sump tio n?
s 10 A
That would be reasonable.
~
~
11 Q
What is a delayed auxiliary feedwater 12 event?
13-A
, An event in which the auxiliary feedwater is 14 not supplied within the specified, I think it's 15 about 90 seconds, to the once through steam generator 16 following an interruption in the normal feedwater.
17 Q
Why does delayed auxiliary feedwater cause 18 cycling of the pilot operated relief valve 7 19 A
Because it leads to an interruption in heat 20 removal from the reactor coolant system.
(
21 Q
In order for the valve to cycle, am I 22 correct that the pressure in the reactor coolant
- 23 system would have to exceed the pilot operated relief w
\\._
24 valve set point and then fall below that set point and l
25 l
then exceed it and then fall below it and then exceed it?
1 Womack 688 rU it could 2
A Yes.
Or alternatively it could be 3
be cycled by the control system itself if there were 4
some defect in the control system.
5 Q
When you assumed that delayed auxiliary 6
feedwater would lead to cycling of the PORV, which 7
assumption were you making?
8 A
The former of your -- of the two cases we 9
discussed.
10 Q
Were you aware at the time you wrote 11 GPU Exhibit 21 of instances in which electrical or 12 mechanical failure had led to the cycling?
Os 13 A
I don't recall whether I was or not..
14 Q
What led to the cycling at Davis-Besse in 15 September of 19777 16 A
It's my understanding that that was a control 17 system problem.
Incorrectly wired controlled relay.
18 Q
So you were aware when you wrote GPU Exhibit 19 21 that there had been mechanical failure leading to 20 cycling or electrical failure?
(
21 A
I don't recall at the time I wrote this memorandum 22 whether I had that in mind or whether I have learned 23 that subsequently.
I don't think it's important, but f
k 24 I do understand that that was a factor in the 1977 25 PORV failure at Davis-Besse.
I Womack 689
{Y
\\
.I 2
Q How would delayed auxiliary feedwater 3
lead to the pressure going above the pilot operated 4
relief valve set point, then falling below and then 5
rising above the set point?
6 A
If feedwater is not supplied to the steam I
generators then heat removal by the steam generators 8
~
is interrupted.
If heat removel from the reactor 9
coolant system is interrupted, the continued production t
10 of heat by the shut down reactor core as' well as the 11 other sources of heat in the system will cause the 12 temperature of the reactor coolant system to increase.
13 i'n reactor This in turn -- this average increase 14 coolant system temperature causes the coolant to 15-expand, the expansion of the coolant in the closed 16 system causes the pressure in the gas space in the 17 pressurizer'and indeed throughout the syst.em to 18 increase.
This pressure increase can lead,to a system 19 pressure which is equal to or greater than the 20 pressure at which the pilot operated relief valve
(
21 opens.
22 When the pilot operator relief valve does open 23 pressure relief from the gas space of the pressurizer O.
ldoesoccurandthepressure then may drop again below 24 l
25 the closing pressure.
If by this time the heat removal
1 Womack 690 0
2.
has not again been restored to the primary system, 3
the cycle may repeat itself.
This can continue 4
. indefinitely.
(
5 Q
Did you make any assumptions as you say 6
about any make up flow to the system?
7 A
No, I am not making a particular assumption about 8
make up flow.
9 Q
In what you said is make up flow occurring i
10 or not?
11 A
I am assuming in what I said that the system is 12 in tact, closed and that there is not another leak of g-J' 13 size elsewhere in the system and in that instance I think 14 that the general features of what I described to you 15 don't really depend upon the make up flow.
A 16 '
Q In other words, it would cycle whether 17 there was make up flow cr not?
~
18 A
I believe it would.
19 Q
If the system continued to have a loss 20 of auxiliary feedwater, would it be a fact that 21
. eventually the pilot operated relief valve would be
(
22 subjected to two-phase flow?
23 A
Yes, I think we went through that this morning 24 and I said it was highly likely that it would.
Given 25 that no action was taken to close the block valve or
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m r
g<
Womack 691 l
~
2 to rostore secondary heat removal.
a 3
Q If secondary heat removal were not restored, i
6
+
4 and the block valve were-closed, wouldn't that lead g
. 5 to challenging the ASMs-dafety valves?.
6 A
I suspect that it would, yes.
I suspect that 7
it would.
8 Q
The ASME or code safety valves had a 9
history of not reseating correctly; isn't that right?
^
10 MR. WISE:
Have we establis ed that they s
- 11 are supposed to. reseat or how they_are supposed Ps 12 to reseat?'
(
)
x_)
l' 13 Q
'I t is a fact that after the precsure 2
14 recedes, a code safety valve is supposed to'reclose;
~
15 isn't it?
16 A
They are designed to do that, yes.
17 j x ;s 5
-Q And it is a fact, isn't~ it, that the i
18 pilo t op e'ra ted relief valve was placed in the design 8-I 19 in order to' prevent challenging the code safeties; 20 isn't,that right?
t
(
21 A
That was one of its purposes to avoid challenges 22 to the code safety as I understa nd. it.
23 Q
It is correct, isn't it, that.the reason C
'1
(
k - i, t, 24 -'
it was thought by B&W to'be desirabl'e to avoid i
25
' challenging the code safeties was'because of the f -
4
_,.p,
1 Womack 692
/'
- \\s.
2 possibility of the code safety failing to reseat 3
adequately; isn't that true?
4 A
I 5
Q Is that your understanding?
6 A
-I can conjecture but I guess that would be a 7
good design objective to have an isolatable valve 8
to avoid challenges to these non-isolatable valves.
J 9
Q If auxiliary feedwater flow had not been t
10 restored, were you suggesting that it would be an 11 appropriate procedure to close the block valve?
/~
12 A
If the auxiliary feedwater had not been restored, O}!
13 I think it would have been appropriate -to have 14 closed the block valve, yes.
15 Q
Wouldn't that lead to challenging and 16 opening-the code safety?
f 17 A
Yes.
But the reactor is designed td continue 18 safe cooling in either condition.
19 Q
Under what circumstances would you 20 recommend closing the block valve, the delayed feedwater
'(
21 event?
22 A
I am not sure exactly where we have come down i
23 on that particular recommendation because I am not 24 sure that it matters tremendously if you assume that l
i 25 - '
there is going to be no auxiliary feedwater indefinitely,
1 Womack 693 t
%s 2
which is a very out.of design condition but if you 3
assumed that I think in the long term that it would 4
be just as well to have the block valve open since 5
in that case you would be supplying make up water from 6
the high pressure injection system to cool the reactor.
7 That is really not a design condition of the 4
8 reactor.
We have thought about that considerably 9
since the accident.and have worked with our customers t
10 on that capability which exists in this ' reactor system.
11 Q
Yes.
("N 12 A
Because of the high pressure injection, because
%_)
13 -
of special design features of the high pressure 14 injection system.
15 MR. SELTZER:
I would like to. mark as 16.
GPU Exhibit 22 a memorandum from Rosztoczy, 17 subject, Comments on " Generic Assess' ment of i
i 18 Feedwater Transients in Reactors Designed by 19 ~
Babcock & Wilcox," April 25, 1979 with a copy 20 marked for E.A.
Womack.
(
21 (Memorandum from Rosatoczy dated April 15, 22 1979, subject, Comments on " Generic Assessment 23 of Feedwater Transients in Reactors Designed by
(' N 4
24 Babcock & Wilcox," with a copy to E.A.
- Womack, 25 marked GPU Exhibit 22 for identification, as of I
1 Womack 694
[
\\s/
2 this date.)
3 Q
Is GPU Exhibit 22 a copy of a document 4
which you received in or about. June 1979?
5 A
It appears to be.
6 Q
Did you attend any meetings with Zoltan 7
Rosztoczy in May,' June or July of 1979?
8 A
Yes, I believe I attended a meeting or perhaps 9
meetings during that period of time.
I am not sure 10 exactly when.
11 Q
You attended. meetings at which Rosztoczy 12 was present?
(~)
%)
13 A
Yes, sir.
14 Q
Where were those meetings?
15 A
In Washington and at least in one ca,se in 16 Lynchburg.
17 Q
Was he the senior representati've of the 18 NRC at those meetings?
I mean senior in terms of 19 responsibility, not age.
20 A
That was not always well clear to me.
21 Q
Who else from the NRC attended those 22 meetings?
l 23 A
Well, in trying to recall the series of meetings 24 in which Dr. Rosztoczy was present, I can recall 25 briefings of the Nuclear Regulatory Commission itself,
1 Womack 695
., ~
(a\\ '
2 or a briefing, such a briefing, I can recall attending 3
ACRS meetings at which I believe Dr. Rosztoczy was 4
present.
I can recall a meeting in Lynchburg which 5
related to small brake operating guidelines in which 6
I believe Dr. Rosztoczy attended, and I can recall a 7
meeting with members of the staff at which Dr. Rosztoczy 8
was present.
9 Q
Members of the staff of what?
10 A
of the Nuclear Regulatory Commiss'on.
i 11 Q
What part of the staff was it, do you know?
12 A
Well, I think most of the people present were
'~
13 part of the Nuclear -- of the office of Nuclear-14 Reactor Regulation, but there were various segments 15 of the staff represented and I doubt I can recall 16 all the organizational functions.
17 Q
At any of the meetings with Rosztoczy did 18 B&W ever discuss with Rosztoczy or the re resentatives 19 of the NRC Rosztoczy's allegations that there were 20 basic design deficiencies in B&W reactors?
21 A
I don't remember whether the discussion was 22 connected to those to that series or to that 23 particular subject matter in that way.
(O
, )
24 Q
I am not talking about in any particular 25 way.
I am just asking whether any of the meetings that
1 Womack 696 2
you attended involved the discussion of what 3
Rosztoczy has called in GPU Exhibit 22 basic design 4
deficiencies of B&W reactors.
5 A
Let me look at what he has called basic design 6
deficiencies.
7 These meetings did involve discussions of the 8
subjects under that heading in this letter.
9 Q
Which meetings of the ones you have 10 enumerated were particularly addressed to the basic 11 design deficiencies described by Rosztoczy in GPU 12 Exhibit 227 gSN]
13 A
Well, I think that to one or another of the 14 subjects discussed under item 2 most of the meetings 15 I have described touched on one or more of those 16 subjects.
17 Q
Who was the principal technica}1 representative 18 from B&W responding to these charges of basic design 19 deficiencies?
20 A
I don't believe these meetings were conducted
(
21 in the context of charges of basic design deficiency.
22 I think I said that an my earlier answer.
t 23 Q
Who was B&W's principal technical i
[
\\_s 24 representative who spoke with regard to these alleged 25 design deficiencies?
,..~
1 Womack fg 697
)
2 A
It depended upon the-particular subject and 3
the way it was being developed.
At times it was me, 4
at times it was Dr. Roy, at times others.
5 Q
You said, "At times it was me."
6 Which particular subjects were you a B&W 7
spokesman on?
8 A
I generally would serve as the broad technical
.i 9
coordinator on system or system design issues with 10 technical specialists speaking to particular points, j
11 Or Dr. Roy might serve in that function.
("%
12 Q
Are you aware of any memoranda or any 13 other writing at B&W which responded to the basic 14 design deficiencies listed in Roman Numeral II on 15 page 1 of GPU Exhibit 117 16 A
Yes, I believe there are memoranda which deal 17 with these points throughout this period.,There 18 are certainly writings which deal with these points.
19 Q
Well, did you, Roy, Taylor or anybody 20 else ask for or have created a memorandum or any other
(
21 writing that responded specifically to these points 22 so that you could get ready for a meeting with the NRC?
23 A
I don't know chether we did or not.
It is r
N~
24 i
certainly possible that we did.
4 25 Q
Do you know whether there is such a
1 Womack 698
- ('h
'w) -
2 memorandum or other writing?
3 A
I don't know.
There probably is.
You have all 4
the documentation and I am sure you would have it if 5
there is.
6 Q
That is very constructive of you to assume 7
that we do, but we have been receiving box loads of 8
supplementary-production and just last Friday we got 9
another box load of supplementary production so we 10 don't have everything.
The letter that.we got on 11 top of last Friday's box load said there is more 12 still to come.
So I am asking you questions about s-13 what you understand would exist in writings so that 14 we can know what we should look and ask for.
15 A
I appreciate that explanation and in response 16 I hope you will understand my memory certainly does 17 not call forth the individual memoranda at this period 18 of time very well.
19 Q
Do you recall reviewing a writing at 20 3&W which responded to the points raised by Rosztoczy 21 in GPU Exhibit 22?
22 A
I don't recall whether I did or not.
23 Q
The first basic design deficiency listed (O
,/
24 on page 1 of GPU Exhibit 22 is, "The second fission 25 product barrier, the primary coolant system pressure
d i
Womack 699 v
2 boundary is not single failure proof."
3 What is the second fission product barrier 4
as you understand it?
5 A
As I understand his meaning here I believe he 6
intends to mean the primary coolant system pressure 7
boundary.
8 Q
In that system of classification, would 9
the-first fission product barrier be the Zircalloid e
10 cladding?
11 A
I believe so.
s
(~
12 Q
And what you and I are referring to is
\\s) 13 the cladding on the fuel rods themselves; right?
14 A
Yes.
15.
Q What is the phrase "not single failure 16 proof" mean to you?
17 A
To me it means that there is some single failure 18 which could cause the second the primary coolant 19 system pressure boundary to be opened.
20 Q
That is all it means?
(
21 A
That is all it means.
22 Q
At what point in the pressure boundary 23 did you understand Rosztoczy was saying that the s/
24 boundary was not single failure proof?
25 A
I don't know what Rosztoczy meant specifically here.
I
_,_e we, r
=,. --
w e-
1 Womack 700
'v 2
Q I am asking you what did you understand 3
he was referring to when you read this?
4 A
I don't-know that I can remember.when I read
.(
5 that what I understood, but I can tell you today if 6
you like.
7 Q
What is your understanding?
8 A
I would imagine that he was focusing on 9
pressurizer relief valves since that was the main 1
10 focus -- I think that was the main focus of this 11 general task force.
12 Q
So you believe that the author of GPU v'
13 Exhibit 22 is saying that the pilot operated relief 14 valve which is part of the primary coolant system 15 pressure boundary is not single failure proof; is 1G that right?
17 A
I would imagine that that was part -}-ofwhat 18 was behind his statement.
19 Q
Have you seen anything in writing at i
20 B&W that takes issue with that statement by Rosztoczy?
'2I A
I don't recall having seen anything.
22 Q
Item b in the list of basis deficiencies 23 of B&W reactors in GPU Exhibit 22 states, " Uninterrupted O'-
24 natural circulation is not possible following 25 depressurization events, like steam line break, small
1 Womack 701
' (
\\
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2 break, small break LOCA, steam generator tube rupture, 3
so on."
4 In what way did you understand the author 5
of this memorandum meant that uninterrupted natural 6
circulation was not possible?
7 A
I believe that he meant.that in certain 8
circumstances which led to a reduction in volume of 9
liquid primary coolant, that might be associated with t
10 accidents such as these,.that liquid flow natural 11 circulation might be temporarily interrupted from
/'N 12
'the reactor core to the steam generators to the 13 secondary heat sicnal.
Natural circulation I understand t
14 to refer to a circulation of primary coolant driven 15 by thermal convection.
16 Q
Do you know of any writing that exists 17 at B&W that disputes the accuracy of that' item b?
18
(
A Not specifically that disputes it.
Certainly 19 this question of item b has been the subject of 20 wri ti ngs.
(
21 Q
Do you know of anything in writing that 22 confutes it?
?
23 l
A Please define confute?
24 Q
something in writing that takes a contrary 25 point of view.
l J
1 Womack 702 I')
\\
2 A
The writings of which I am. aware would tend 3
to be -- will focus more narrowly to specific 4
conditions under which liquid flow thermal convection 5
circulation might be interrupted and in that sense 6
.they would tend to be more narrow than a broad statement 7
to say that that is not possible more specific than 8
that particular statement of Dr. Rosztoczy, if_that 9
is a confutation.
there depressurization bvents 10 Q
Are of i
11 the type listed in item b for which uninterrupted 12
,3 natural circulation would not be possible?
\\v)
~
13 A
Yes.
We believe that there are.
14 Q
Are there events of the type enumerated 15 in item b for which natural circulation would not be 16 a successful means of cooling the core?
17 A
If the meaning of natural circulation is expanded 18 to include two-phase heat transfer from the reactor I
19 core to the steam generators, I don't believe that we 20 are aware of any events in which natural circulation
{
21 would not be ultimately successful in attributing to 22 cooling of the core.
23 Q
Are you saying that there is no event of.
O)
(_
24 the types listed in item b for which natural 25 circulation would not be able to produce effective core
!i-l 1-Womack 703 2-cooling?.
3 A
Yes, that is what I am saying.
Of course I am, 4
in making that statement, assuming operation of the
~
5-reactor within its design intention and that would 6
include not permitting significant core uncovery j
-7 and generation of hydrogen in the primary system 8
Q Are there any breaks listed in item b l
9 that could lead to core uncovery that would therefore E
10 preclude effective natural circulation?'
11 A
Not that I am aware of provided that the 12 operator -- that the reactor is operated as designed.
13 Q
In any of the meetings with Rosztoczy 1
14 did anyone take issue with his statement in item a?
)
15 A
I don't recall.
16 Q
So then you'certainly wouldn't recall the 17 name of any person at B&W who took issue with item a I
l 18 at a meeting with Rosztoczy; is that right?
19 A
I don't recall, yes, anyone taking issue on I
20 that particular point.
(
21 MR.. WISE:
Ju:t for clarification, do I 22 understand your question to be as to whether or 23 not anybody took issue with the statement that 24 is made in subparagraph a or whether anybody took 25 issue with the statement in subparagraph a as i
1 Womack 704
. m 1
J%)
2 being a " basic design deficiency"?.
3 MR. SELTZER:.Either.
4
'A well, I did not answer your question in the
'5' meaning'of "either".
I answered it in the sense that 6
I couldn't recall whether anyone had taken issue 7
specifically with the statement of item II-a.
8 Q
Did anybody tell Mr. Rosztoczy in your
~
9 presence that it was B&W's position that the fact t
10 that the primary coolant system pressurd-boundary was 11 not single failure proof didn't mean that the reactor 12 n-had a basic deficiency?
v 13 A
I don't recall whether anyone did~or not.
14 Q
Have we handled both. sides of either/or 15 raised by Mr. Wise to your satisfaction?
16 MR. WISE:
Well, I don't think he can answer that.
Why don't you just asl$,~him 17 some 18 questions.
19 MR. SELTZER:
I just did.
20 MR. WISE:
I don't believe that's a proper 21 question.
Whether or not something has been 22 answered to Mr. Womack's satisfaction is, I 23 l
don't think relevant.
O/-
24 A
I think that apropos of that we discussed earlier 25 that I didn't recall specific discussion of what was
'l Womack 705
/
i LJ 2
and wasn't a basic design deficiency so in that sense 3
I don't have particular recollection that anybody 4
undertook a particular discussion of that with 5
Mr. Rosztoczy.
It may have happened.
6 Q
Did you take any notes at the meetings 7
with Rosztoczy?
8 A
Yes.
9 Q
Did you have your notes typed?
t 10 A
That I can't recall.
11 Q
What is your best recollection of what 12 you did with your notes after the meeting?
gs
\\
13 A
They would either have been thrown away as of 14 no further value or used subsequently.
They might
_15 have been filed in my folder on that particular meeting 16 if I kept one.
17 Q
Where would you keep such a folder?
18 A
In my desk.
10 Q
Did you produce files from your desk?
20 A
Yes, I did.
I testified to this.
And I produced I
(
21 all such folders that I kept to the best of my ability.
22 Q
To whom did you produce them?
23 A
To our counsel or representatives of our counsel.
i (D
l
\\m) 24 Q
Did you personally hand them to the 25 representative of your counsel?
I
1 Womack 706 A
6
%d 2
A No.
3 Q
Who did?
'4 A
I boxed them up and asked my secretary to see 5
that they were delivered.
6 Q
Rosztoczy says in item c on the first 7
page of GPU Exhibit 22 that, " Instrumentation is not 8
available to assure adequate safety in case of 9
anticipated operating occurrence and accidents."
10 Do you see that?
11 A
I see it.
12 Q
What instrumentation did you understand V
13 he was referring to?
14 A
I don't know.
15 Q
Do you have any understanding today of 1G what instrumentation he was referring to?
17 A
No.
18 Q
After you received GPU Exhibit 22, did i
19 you make any attempt to find out what instrumentation 20 he was referring to?
{
21 A
I don't recall that I did.
22 Q
Will you turn to page 2 of GPU Exhibit 22, 23 please, item III at the top of the page is headed, (h
(_)
24
" Shortcoming of Plant Safety Evaluation."
25 What plant safety evaluation do you y
e
.me
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understand he was referring to?
3 A
I do not know.
4' Q
Did you make any attempt to find out what 5
safety evaluation he was referring to?
6 A
I don't recall whether I did or not.
7 Q
Did you consider that the safety evaluation 8
that Rosztoczy is referring to might be the SAR?
9 A
I don't recall.
E 10 Q
Did you discuss this memorandum with 11 anyone?
12 A
I don't recall that either.
("j.
w s
1
~
13 Q
Do you see item IV on the second page of 14 GPU Exhibit 22?
15 A
Yes.
IG Q
It is headed " operator Training and 17 Emergency Procedures."
~
l 18 Item b under that says, " Operators are i
19 not trained properly to handle multiple events, 20 events complicated by additional failures and
(
21 operators errors."
22 Do you recall whether that subject was 23 discussed in any of your meetings with Rosztoczy?
24 A
well, I have mentioned to you that Dr. Rosztoczy l
25 came down in connection with preparing small break
.,. ~_.
/
1 Womack g-)
708 LV 2
operating procedures.and while I don't remember 3
particular discussions, it is certainly possible.
4 Q
Do you have any recollection who on behalf
~
5 of B&W was your company's spokesman in presenting 6
B&W's views on this matter?
7 A
Which matter?
8 Q
Whether operators are properly trained to
~
9 handle multiple events.
t 10 A
other than the suggestion that we'made regarding 11 the ATOG program I don't know that B&W has made an
~T 12 (d
expression on this matter.
It seems to.,go much more 13 broadly than B&W's scope of effort, ope'rator training e
I4 is a much broade'r issue than certainly what I participated 15 in.
16 Q
Do you know if there was anybody at B&W
'17 who spoke up at meetings with Rosztoczy and discussed 18 the question of whether operators were not properly j
19 trained to handle multiple events?
20 A
I don't remember that there was.
(
21 Q
Item e under the heading Roman IV says i
22 that, "Most likely, the instructors training reactor
.23 operators are not properly trained either."
f)
\\'
24 Is there anything in writing at B&W that 25 you have seen that analyzes whether prior to the
1 Womack O
709 dU) 2
- accident B&W was performing its training function 3
properly'in order to prepare operators to handle 4
multiple events?
5 A
I don't recall seeing such a writing.
6 Q
At any of the meetings with Rosztoczy, 7
do you recall anyone taking issue with his statement 8
that most likely the instructors are not properly
~
9 trained either?
t 10 A
Frankly, I don't recall discussing'the statement 11 or discussions of that particular statement.
12 Q
So you don't recall anybody telling N/
13 Rosztoczy that he was all wet for making that statement; 14 is that right?
15 A
I den't recall that, no.
16 Q
Rosztoczy has a section headed Roman V 17 at the bottom of page 2 of GPU Exhibit 22 that is 18 headed " Lessons Learned from the TMI-2 Incident,"
19 He said in item a, "The TMI-2 incident 20 could have been avoided if the design and licensing
(
21 of the plant would have followed NRC requirements."
22 In what respects did you understand 23 Rosztoczy was saying the design of the Three Mile t
O
(_
24 Island Unit 2 plant did not follow NRC requirements?
25 A
I don't know.
.< eau'-*
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~
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w
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1 Womack 710 f%
V 2
Q Did you ever take any steps to find out 3
what aspects of the B&W design he might have been 4
referring to?
5 A
well, in the context of following up on the formal 6
report that was issued out of this task force, certainly, 7
but I am frankly not aware within the context of 8
the TMI licensing process of an exception where the 9
plant did not follow the NRC requirements.
I am not nok aware of any 10 aware of any outstanding NRC -- I am 11 outstanding NRC condition or -- to the license that 12 existed that would indicate that the requirements 13 had not been,followed.
14 Q
You began your answer by saying that you i
15 had focused on some of the statements that were made 16 in the report that followed this letter.
17 Wore you referring to NUREG 5607 18 A
If that is the so-called Tedesco report, yes.
19 Q
Does that report contain statements that 20 there were areas in which the design of the Three 21 Mile Island Unit 2 plant did not follow NRC requirements?
22 A
I don't believe it does.
But I would want to 23 review the report.
But I don't believe it does.
s j
q ),
24 Q
In item b under " Lessons Learned" the 25 author of GPU Exhibit 22 states, "The TMI-2 incident
---c-
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I 1
Womack 711 n/ -
A.
2 could have been avoided if operating experience 3
. would have been promptly' factored into the licensing 4
process.
During the previous three years B&W plants 5
experienced three loss of coolant accidents similar 6
to the TMI-2 event."
7 What are the three loss of coolant accidents 8
similar to the TMI-2 event that Rosztoczy is referring to-?
9 A
I couldn't tell you.
L 10 Q
What did you understand he was referring to?
11 A
I don't know which specific events he was 12 referring to.
I would presume that he saw the Toledo (g
-V 13 Edison PORV failure as similar and I don't know what 14 the other two were, 15 Q
Did you ever make any attempt,to find out 16 what events he might be referring.to?
~
17 A
As far as what he was referring to specifically 18 here, I don't believe I did, no.
l 19 Q
At any of your meetings with Rosztoczy l
20 did anyone from B&W take issue with his statement
(
21 that the Three Mile Island accident could have been 22 avoided if operating experience had been promptly 23 factored into the licensing process?
[\\
\\/
24 A
I don't think that was -- I don't recall that 25 being a subject of discussion in these meetings.
.9
,r._
s__.<
1 Womack 712
%J-2 Q
So your answer is you don't?
3 A
I don't recall anybody treating this.with 4
Dr. Rosztoczy.
5' Q
You don't recall anybody treating with 6
Dr. Rosztoczy?
7 A
No, treating with this subject with Dr. Rosztoczy.
8 MR. S_E LT ZE R :
Off the record.
~
9 (Discussion off the record.)
10 MR. SELTZER:
I would like to mark as 11 GPU Exhibit 23 a memorandum from D.H.
Roy to 12 Engineering Department Section Managers, subject 13 Top 10 Lessons Learned - TMI-2,' dated June 14, 14 1979.
15 (Memorandum from D.H.
Roy to Engineering 16 Department Section Managers, subject, Top 10 17 Lessons Learned - TMI-2, dated June 14, 1979 18 marked GPU Exhibit 23 for identification, as of 19 this date.)
20 Q
In the upper right-hand corner of the
(
21 first page somebody has delicately inscribed "EAW."
22 Is GPU Exhibit 23 a copy of a memorandum 23 which you received in the regular course of business i
FN i
i f\\~'/
24 on or about June 14, 19797 25 A
Yes, it appears to be.
I Womack 713
.s 2'
Q Who is Mr. MacMillan referred to in the 3
first sentence?
. 4 A
I believe that is John H.
MacMillan.
5 Q
He was at that time-the head of NPGD?
6 A-He was the general manager of the Nuclear' Power i
7 Generation Division'at that time.
8 Q
What is he in charge of now?
9 A
He is the senior vice president for the Nuclear 10 Group within Babcock & Wilcox?
11 Q
Has he been succeeded by somebody else
N 12 as the head of NPGD?
_]
13 A
Yes.
14 Q
.Who?
15 A
Douglas Guilbert, spelled G-u-i-1-b-e-r-t.
1G Q
That is your boss?
17 A
Yes, sir.
18 Q
The first sentence of GPU Exhibit 23 19
- says, As a result of Mr. MacMillan's review of the 20 candidates for the top ten lessons learned from
(
21 the TMI-2 incident, Engineering has been assigned lead 1
22 responsibility for four major categories."
23 Who had submitted candidates for MacMillan's 24 review?
l 25
. A As far as I know his staff submitted candidates, i
,w,
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1 Womack 714 O
U 2
I believe.
3 Q
I take it for some period before June 14 4
nominations were open?
5 A
I take it.
6-Q Did you submit a' list of candidates?
7 A
I was not on Mr. MacMillan's staff so I did not 8
submit candidates to Mr. MacMillan.
9 Q
Who was on his staff at that time?
10 A
If you can resurrect one of the earlier 11 exhibits that we talked about in day one I believe I
/'s 12 might be able to answer that question for you.
(_)
13 MR. SELTZER:
Off the record.
14 (Discussion off the record.)
15 Q
Who was on MacMillan's staff who you 16 believe would have been submitting nominations for 17 the top 107
~
18 A
At that time I believe on MacMillan'.s staff 19 was the manager of Quality Assurance.
20 Q
And the names?
(
21 A
Who I believe was DeCarli, manager of Purchasing, 22 whom I believe was Jim Slagic, manager of Contracts-Legal 23 who I believe was Jim Jones, manager of Personnel and 1
24 Employee Relations who I believe was Jim Hubbard, 25 the controller, who was Larry Brinegar, the manager
1 Womack 715 f'h
_Y 2
of the Nuclear Parts Center -- let me come back to 3
that.
The manager of Marketing and Business Planning 4
would have been Mr. Embry, manager of Project 5
Management would have been Mr. Deddens, manager of 6
General Services would have been Mr. MacKinney, 7
manager of Engineering would have been Dr. Roy, manager i
8 of Nuclear Service would have been Mr. Kosiba and j.
9 manager of International Program Management would t
10 have been Mr. Berger.
I will have to search my 11 memory for the manager of the Nuclear Parts Center.
12 The gentleman who was the manager of the Nuclear V
13 Parts Center is since deceased so it may not be 14-terribly important.
15 Q
You mean because he is dead we should 16 forget about whether he proposed any top 10 candidates?
i 17 A
No, sir.
I did not mean that.
18 Q
Why did you think it was unimportant what 19 his name was?
20 A
I thought perhaps if you were thinking of
(
21 calling him he would be unavailable.
I will certainly 22 get to his name for you.
23 Q.
I agree with you on that.
I certainly O
3,)
24 would not try to depose him.
l 25 A
Well, as you might have Owen Glendower's powers.
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2 Q
Have you seen copies of the nominations 3
for top 10 lessons learned that were submitted by 4
MacMillan's staff?
5 A
Yes, I think I have seen some of them, 6
Q To your knowledge has MacMillan collected 7
them in one place?
8 A
I don't know.
9 Q
Where did you see some of them?
e 10 A
I believe some of them were the subject of 11 discussion with the Kemeny Commission and I think I 12 may have seen them in-connection with that discussion.
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13 Q
How well do you know John MacMillan?
14 A
How would you like for me to characterize my 15 acquaintance with Mr. MacMillan?
16 Q
Since I don't know the answer I would have f
17 a difficult time telling you how to characterize it.
18 A
I know him as a superior and as a colleague.
19 I do not I did not have a long-standing relationship 20 with him prior to -- I had no relationship prior to
(
21 my coming to B&W and I don't have a social relationship 22 with Mr. MacMillan.
23 Q
During the period immediately following 24 the accident during April, May and June 1979, how 25 '
frequently did you see Mr. MacMillan?
1 Womack 717 t(~%I
~
\\_./
2 A
Perhaps once every two weeks, perh ps once a f
3
- week, 4
Q Did he ever call you in to talk with you 5
'about the lessons learned from the TMI-2 incident?
6 A
Not that I-recall, 7'
Q Did you ever participate in any discussion 8
with him regarding the lessons learned from the TMI-2 9
incident?
10 A
'Yes.
11 Q
Who, if a nyone else, was present at that 12 discussion?-
13 A
I believe-I recall later I think of the time 14 period I-believe you are interested in, I believe I 15 recall having attended a staff meeting which had 16 -
soma feedback of the of the Technical Review 17 committee report.
That was a meeting of Mr. MacMillan's 18 staff which I think' I was representing Dr. Roy.
So, 19 others of his staf f-would have been presen 20 Q
~ Was MacMillan himself present?
21 A
I believe he was, yes.
22 Q
Did you have any meetings with MacMillan 23 other than that that you discussed what were or what
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24 should be the top 10 lessons learned?
l
%/
l 25 A
.I can recall another meeting in which Mr. MacMillan L
1 1
Womack 718 2
was preparing his testimony for the ACRS in which 3
he -- which we helped him in that effort.
I wouldn't 4
characterize that meeting as focusing on the top to 5
lessons learned but obviously the issues of the 6
accident were important.
7 Q
After the first sentence in GPU Exhibit 8
23 Dr. Roy says that, "These categories are to be 9
broken into specific tasks which will address i
10 instrumentation, analysis, procedure, etc., needs 11 for each of these categories."
12 What is your understanding of the O
13 relationship between these specific tasks and the 14 lessons learned from the TMI-2 incident?
15 A
well, in order for us to follow up on any 16 thoughts that might have been generated by this effort 17 or any other effort, it was necessary for'us to 18 consolidate a plan for implementing any action that 19 we wanted to take and in particular since almost all 20 '
of these efforts involved determining whether our 21 customers wanted us to do these things, putting 22 together plans which could be discussed with our 23 customers for doing this, these tasks would provide 24 the kind of outline and initial planning which would
'25 allow us to do that.
4 1.
[
l' Womack 719 j
'M_
_7 2
Q What is'the relationship between these 3
specific taska and the lessons le4rned from the 4
TMI-2 incident?
5 A
Ocher than the relationship that seems to be 6
represented l'n this memorandum, I am not sure that I 7
know of any.
8 Q
What is the relationship represented in 9
this memorandum?
f,.
10 A
As I understand it he has taken some of the itens 11 which were -- which did apparently result from th a t 12 review of lessons learned and broken them down into 7
l
)
' ~
13 sub items and asked for attention or consideration 14 of those sub items for possible implementation.
i 15 Q
What do you mean items which resulted
. i
- 16 from the lessons learned, what does that mear@
as surp'tiod on wha t 17 A
To me, I am again making an s
18 he says, I see human engineering, r bility of 19 systems, containment isolation, plant design review j 20 were somehow related to MacMillan'sisorting out of
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i 21 what he got from his staff.
.i s
22 Q
To your knowledge did each of the people 23 whose initials appear in the righ t-hand colum o f 24 various pages prepare task descriptions?
yj s
25 A
I don't know.
s t
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1 Womack 720 0
~
2
-Q Did anyone besides you, to your knowledge, 3
prepare task descriptions?
4 A
Yes,.I believe I have seen task descriptions 5
prepared by others.
6 MR. SELTZER:
Off the record.
7 (Discussion off the record.)
'8 (Luncheon recess taken at 12:15 o' clock P.M.).
9 t
10 I
11 4
4 12
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14 i
i 15 16 i
l 17 18 i
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20 21
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22 23 24 25 s
1 Womack 721 A
k 2
AFTE RNO ON S E S S I ON 3
(1:45 o' clock P.M.)
4 MR. SELTZER:
I would like to mark for 5
identification as GPU Exhibit 24 a document 6
probably written by E.A.
Womack, the title 7
" Operating Plant Design Review Board, Task 8
Description," June 18, 1979.
9 (Document dated June 18, 1979 entitled 10
" Operating Plant Design Review Board, Task 11 Description," marked GPU Exhibit 24 for 12 identification, as of this date.)
O'
'~
13 E D GA R A LL E N W O MA C.K, J
R.,
14 resumed, having been previously duly sworn, 15 and continued to testify as follows:
16 EXAMINATION (continued) 17 BY MR. SELTZER:
18 Q
Is GPU Exhibit 24 a copy of a memorandum 19 which you prepared?
20 A
Yes, I think I in substance prepared this.
21 Q
Did you prepare it in or about mid June 22 1979 in'the regular course of business?
23 A
The date would indicate that, yes.
24 Q
Am I correct that this is a task description 25 which you prepared in response to the task, one of
1 Womack 722 2
the tasks outlined in Roy's GPU Exhibit 23?
3 A
I don't know whether it was specifically in 4
response to GPU 23 or not but it was -- it would be 5
reasonable to assume that it was.
6 Q
In the section entitled " objective," you 7
wrote, "To perform a complete review of the design of 8
the B&W Operating Plants, particularly with respect 9
to issues and concerns which have been raised in 10 the wake of the TMI-2 incident of March,28, 1979."
11 Is that a correct statement of what the 12 objectives of the operating Plant Design Review Board
%./
13 were?
14 A
That's the correct statement of the objective 15 of this task as then conceived.
16 Q
Was any board formed having this objective?
17 In other words, did you ultimately form the board or 18 anything like the board described in GPU Exhibit 247 19 A
No, I don't believe we formed a board exactly 20 as conceived here.
21 Q
I didn't ask about exactly.
Did you ever
{
22 form a board that was anything like the board 23 described here to perform the review described in 24 GPU Exhibit 24?
25 A
We did part of the function conceived here I
1 WomAck 723
{
\\
2 think under the Technical Review Committee.
We also 3
at a later time formed a kind of an ad hoc working 4
group on the sensitivity question and -- but a board 5
exactly or pretty much explicitly described here I 6
don't think was ever formed.
7 Q
on page 2 in the third full paragraph you 8
wrote that, "It is important, in my opinion, to have 9
objective consultants from outside B&W on this board."
10 Were there outside consultahts on the 11 TRC?
12 A
It depends on what you mean by outside.
If 13 you mean outside the Babcock & Wilcox Company, I 14 don't think there were.
15 Q
Was there ever a board or investigatory 16 group formed by B&W to review the design of your 17 plants with particular regard to issues and concerns 18 raised in the wake of the Three Mile Island accident 19 that had members from outside B&W7 20 A
I can't recall such a board.
21 Q
You said you thought it was important to
['
22 have people from outside B&W on the board.
Why did 23 you think that was important?
24 A
Because so many of the concerns that were raised 25 here went outside the B&W scope of supply in the
1 Womack 724 n.
(
)
-v 2
traditional business that B&W had been operating in.
3 They were affected in areas which traditionally were 4
areas which the utilities and B&W customers and their 5
other subcontractors took the lead.
6 Q
At the time you wrote GPU Exhibit 24 7
MacMillan had already formed the Technical Review 8
Committee, right?
9 A
That's correct.
10 Q
So at the time you wrote GPU Exhibit 24 11 you were proposing a board that would exist in 12 addition to the Technical Review Committee', right?
O 13 A
,That's correct.
14 Q
How far along in the planning for the 15 board described in GPU Exhibit 24 did you get before 16 the idea was killed?
17 MR. WISE:
I will object to the 18 characterization " killed."
19 Q
Do you know what I mean?
20 A
Well, I also feel that your characterization is 21 incorrect.
How far along did we get?
We discussed 22 it, Dr. Roy and I discussed it after this task 23 description and the thrust here was to add some sort
\\
(_)
24 of an additional effort efforts already underway 25 or being undertaken separately or most of these areas,
1 Womack 725 L
4 7s
- v) 2 that effort would have had its primary benefit, it 3
seems to me, as noted in the second full paragraph 4
under background with regard to refuting some of 5
the -- the impressions, some of which I think were 6
and are incorrect with regard to the B&W design 7
relative to other' designs as it might effect the 8
future marketing of B&W nuclear steam systems in 9
the United states.
10 In point of fact as you and I dis' cussed in an 11 off the record discussion earlier today, there is 12 little or no market in the current time for nuclear 13 steam systems from any s'upplier in the. United States 14 and so the undertaking of such a board above and 15 beyond what I believe were very and are very responsible 16 activities to address the specific considerations 17 here had little justification.
18 Q
Under background you stated, "In the wake 19 of the TMI-2 incident, a number of criticisms of 20 the B&W plant design have been raised, particularly 21 in the following areas," and then you go on to list 22 five areas.
23 The first areas is " quality of guidance C\\
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24 to operator for off-normal operation."
i 25 Did you feel that there was another group i
L
1 Womack 726 3
\\-)
2 already studying the quality of guidance to operators?
3 A
Not so much studying the quality as addressing 4
itself to the question of guidance for off-normal 5
operation and we have discussed that extensively in 6
connection with, I think, another task description 7
entitled " Abnormal Transient Operating Guidelines."
8 Q
Are you saying the so-called ATOG program 9
was already addressing the question of quality of 10 guidance to operator for off-normal ope'ation?
r 11 A
At least it had been, I believe, conceived at 12 this time and was the subject of another task description 13 like this.
I think we went over that in the earlier 14 part of this deposition.
15 Q
So has it become your view that you didn't 16 need a separate board to review the quality of 17 guidance to operators for off-normal operation because 18 the ATOG program was going to take care of that?
19 A
well, I think that the board was not particularly 20 intending to review the quality of guidance.
This 21 was background for what had been discussed.
The
{
22 intention of the board was to decide what more we 23 and B&W and,the industry as a whole might do with
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(_)
24 respect to our particular design for our particular 25 customers in that general area and I believe the ATOG 1
1 Womack 727 2
program does'indeed do that.
3 Q
The next item in which you said there 4
had been criticism of B&W plant design following the 5
Three Mile Island accident was, " sensitivity of the 6
B&W plant system parameters to variation under upset 7
conditions, particularly following reactor trip."
8 Is that the type of sensitivity which 9
you said was being studied by an ad hoc group?
10 A
I think I mentioned that we set uk an ad hoc 11 group to follow the general issues that were being 12 raised under the fairly poorly defined heading of O-13 sensitivity and this is the kind of thing that that, 14 that group, during the period that it was active, did 15 address itself to.
16 Q
Who was the head of that group?
17 A
Well, I think we had Dr. Roy and Mr.- Smotrel, 18 I believe we had Jim Taylor in that group and who 19 was the head of it?
I think Don Roy chaired.
20 Q
Did that group end up writing a report?
21 A
Not to my recollection.
That group was 22 primarily for coordinating a number of activities in 23 this area which were going on already by -- within r~
d/
24 the line organization.
25 Q
What, for example, is a B&W plant system
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1 Womack 728 O
2 parameter?
3 A
Pressurizer level.
4 Q
Am I correct that one of the criticisms 5
of B&W plant design is that the once through steam 6
generator system makes.your plants more sensitive to 7
variation than competing PWR's?
8 MR. WISE:
I'm going to object to that 9
question.
Q That is one of the criticisbs that you 10 11 were referring to in GPU Exhibit 24?
12 A
The I am not sure exactly what you said, 13 but let me say --
14 Q
Would you like him to reread it?
15 THE WITNESS:
If you wish.
16 A
Will you please repeat the question?
17 (Question road by the reporter.)
18 A
The statement you made is basically correct if 19 you had said variations to feedwater disturbances 20 and interruptions to feedwater.
21 Q
Is it correct that interruptions in j
22 feedwater cause more rapid changes in temperature 23 and pressure in the primary coolant system in a B&W 24 pressurized water reactor compared with its domestic 25 competitors?
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Womack 729 2
A I think that it is probably not possible to 3
answer that question simply.
I understand that 4
there are competitors plants at least from what I have 5
understood from staff work which is done by the ACRS 6
which by definitions of sensitive, the feedwater 7
variations are more sensit'ive than the B&W system.
So 8
I can't give you a simple yes or no answer.
9 Q
Whose plants are more sensitive than 10 yours?
11 A
Well, I am not sure I can recall exactly which 12 plant was covered in this report.
I believe it may O.
13 have been one of the Combustion plants.
14 Q
one particular Combustion plant?
15 A
Well, the report used the plant as an example.
16 I don't know whether it is generic to that plant or i
17 whether it is a particular plant.
~
4 18 Q
Who prepared the report?
19 A
A member of the advisory committee on reactor 4
20 safeguard staff.
{
21 Q
Do you have a copy of the report?
22 A
I think there is a copy at B&W.
I 23 Q
When did the report come out?
24 A
Sometime toward the end of 1979 or beginning of 25 1980, approximately, I believe.
1 Womack 730 h
- kJ.
2 Q
What was the title of the report, as best 3
you can recall?
4 A
This is going to be a very poor recollection, 5
but it would have been something to do with sensitivity 6
of B&W or sensitivity of pressurized water reactors 7
to control system variations or something.
8 Q
Why.did you list these five criticisms of 9
B&W plant design?
10 A
I don't remember why I chose thosd.five.
Probably 11 because they seemed to be the most frequently noted 12 in documents that I may have been reading at the time.
G' 13 Q
What kind of documents are you referring to?
14 A
I would have imagined early versions of the 15 Tedesco report and perhaps even including the kind 4
16 of things we have been discussing this morning.
These 17 Rosztoczy's copies.
18 Q
Rosztoczy's memos?
19 A
Yes, although I don't think this influenced 20 this strongly.
I think the Tedesco report was 21 pecbably a stronger influence.
. 22 Q
You are referring to Mr. Tedesco of the 23 NRC?
g
(,,/
24 A
Yes.
Oh, also I think I would have to include 25 things such as the NRC's 7905 B&C bulletins.
1 Womack 731 g
. ms 2
Q What does 7905 B&C deal with?
1 3
A I think B was the one which -- one or the other 4
of those I believe dealt with transient type events 5
and requested information on transient type events 6
from various licensees and there were also there 7
were also meetings with the NRC in which the kinds of 8
information they had received were discussed between 9
the NRC staff and our licensees and ourselves, 10 Q
Were any members ever appoi'nted to serve 11 on the board which you described on GPU Exhibit 247 12 A
I don't believe so.
s
)
\\
Q Who, if you know, made the, decision not 13 14 to create the board described in GPU Exhibit 24?
15 A
I think Dr. Roy and I mutually came to the 16 conclusion that this was not a very high priority 17 activity to add to,the other things we had already 18 gotten underway.
19 MR. SELTZER:
I would liWe to mark for 20 identification as GPU Exhibit 25 21 A
Excuse me.
There was one thing further I should
{
22 add to this which do'
- onnect directly but might 23 be connected here.
(O,)
21 There was also seriod of time a look at some work being done as a look at the standard 25 the
1 Womack 732
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V 2
as what we called the standard plant which was -- which 1
3 would have been the basis of the future offering by 2
4 B&W nuclear steam systems under Mr. Quale and I l
5 don't think he did this by means of a board but 6
rather simply by looking at selected areas that had 7
underway efforts to look at some selected areas and 8
this ultimately was concluded that to be an activity 9
which was also not a very high priority and I don't 10 know where it was finally terminated, bbt it was not 11 carried through to conclusion.
12 Q
What, if any, group at B&W was working on
/~T 2
13 criticism c, namely, " ability of the B&W plant to 14 handle small reactor coolant system breaks safely"?
15 A
I think the prime focus of that particular 16 matter has always been in the Emergency Core Cooling 17 System Unit.
18 Q
Bert Dunn's unit?
19 A
Yes.
i 20 Q
What, if any, group was working after 21 June 18, 1979 on criticism that you have listed under 22 d,
namely, the " reliability of certain plant systems 23 and components, including the integrated control A
.t 24 '
system"?
25 A
It would depend on the particular plant systems
1 Womack 733 O0.
2 and components.
3 Q
What about the integrated control system, 4
who was working on the reliability of that?
5 A
The integrated control sys' tem design, performance, 6
after this period of time was primarily focused within 7
the power systems and controls units under Jim Carlton.
8 MR. SELTZER:
I would like to mark as 9
GPU Exhibit 25 a memorandum by E.A.
Womack dated 10 June 18, 1979, " Response to TMI-2 Concerns, 11 Task Description, Verification of As-Built Input."
12 (Memorandum by E.A.
Womack dated June 18, g-U 13 1979, entitled " Response to TMI-2. Concerns, 14 Task Description, verification of As-Built Input,"
l 15 marked GPU Exhibit 25 for identification, as of 16 this date.)
17 Q
Is GPU Exhibit 25 a copy of a memorandum 18 which you prepared in the regular course of business 19 in or about mid June 1979?
i 20 A
I don't know whether I prepared it or not.
I 21 may have.
22 Q
Is it a document which you either prepared 23 or reviewed for accuracy?
24 A
Yes, I believe so.
25 Q
You were very busy churning cut memoranda
f 1
Womack 734
'N (G
2 bearing the date June 18, 1979,.
3 MR. WISE:
I will object to that, 4
Q-Was anybody assisting you in mid June C
5 doing all this writing?
6 A
Yes.
I-7 Q
Who?
8 A
Probably most of the members of my staff.
[
9 Q
Do you have any recollection who helped 10 you draft GPU Exhibit 25?
11 MR. WISE:
He testified he doesn't know 12 whether he drafted it or not.
Are you now s,
I
~
13 assuming that he did?
i 14 MR. SELTZER:
I am not making any assumptions.
15 A
Mr. Karrasch is listed as the responsible engineer 16 here.
He might have helped with the preparation of 17 this task.
~
\\
18 Q
Karrasch was head of what unit?
19 A
Plant Integration.
20 Q
How long has Karrasch been with B&W?
21 A
I don't know.
{
22 Q
Longer than you?
23 A
Yes.
s,_/
24 Q
How old is he?
25 A
He is in his late 30's.
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1 Womack 735 1
I j.
2 Q
Do you know where he went to school?
3 A
No.
4 Q
Is the task which you described in GPU 5
Exhibit 25 a task which was subsequently assigned the 6
people to work on?
7 A
The essentials'of this task have become a part 8
of the abnormal transient operating guidelines program 9
in the sense that the program begins its analytical i
10 portion with a verification of the as-bb,ilt 1
11 configuration of the plants.
12 Q
When you used the phrase as-built O
V 13 configuration of the plants, what does that mean?
1 14 A
That really was intended to mean the configuration 15 of the plants as they exist today and as they are 16 Operated today including all changes which may have 17 been made at any time during the life of the plant 18 by any party.
19 Q
After a p2snt is initially designed changes 20 can be made during construction or after construction og in the configuration of a plant; is that right?
22 A
Yes.
23 Q
As a result the original designs may not
(
24 reflect the as-built configuration of the plant; is 25 that right?
1 Womack 736
(/
(-
2 A
Yes.
3 Q
Is that why you felt that it would be 4
useful to verify the as-built configuration of B&W 5
plants?
6 A
Well, that in conjunction with the fact that i
7 under other tasks for our customers we were being 8
asked to extend system analysis for these plants, as 9
an integral part of other tasks, and that I wished 10 that these systems analyses would be of.the best 11 accuracy that we could provide.
12 Q
When an NSS is delivered and installed 7g
(.,
13 for a B&W plant, does BsW make certain modifications 14 in the configuration of each of the plants so that i
15 there is no one plant that is exactly like another 16 even at the point of completion of construction?
17 A
This is not something that B&W initiates to 18 produce differences if that was the thrust of your 19 question.
20 Q
That wasn't the thrust.
21 A
That was or was not the thrust?
(
22 Q
Was not.
23 A
If your question is can B&W, in response to N
24 requests or directives from the customer, produce 25 differences from plant to plant, I think the answer to
1 Womack 737
(~h N) 2 that question is yes.
3 Q
And in fact the B&W plants are different 4
one from another; isn't that right?
5 A
We have differences in particulars, yes.
6 Q
When you say in the second sentence 7
under " Background & Problem Definition," that "The 8
original input data and assumptions used in 177 FA 9
plant system analysis may not. accurately or 10 conservatively reflect the as-built configuration 11 of the plant," whose original input data and assumptions 12 were you referring to?
d 13 A
Those that were used by the systems the past 14 systems analysts.
15 Q
At Babcock?
16 A
At B&W or anywhere.
But primarily here I was 17 referring to B&W.
~
18 Q
You state at the beginning of the background 19 section, "The accuracy and applicability of analytical 20 results is highly dependent upon the models, inputs, 21 and assumptions used."
22 What analytical results are you referring to?
23 Transient analyses for one?
24 A
It could be a transient analysis, yes, or it 25 could be a steady state analysis.
W
1 Womack 738 0
2 Q
When you say it is dependent upon the 3
assumptions used, is one of the assumptions the 4
as-built configuration of the plant?
5 A
No, that wasn't, I don't think, what I had in 6
mind when I said assumptions here, 7
Q You said that the input data and assumptions 8
used may not accurately or conservatively reflect the l
9 as-built configuration.
10 What in the input data were the assumptious 11 you would need to reflect as-built configurations?
12 A
Virtually all of it would need to reflect
\\, J 13 as-built configuration if it was an important input 14 into the analysis.
If you are looking for an example, 15 the actual output flow from an auxiliary feedwater 16 pump could be important, the pressure drop in piping 17 could be important which is related to the amount of 18 piping actually laid, which could have been changed 19 at the time of installation by the architect engineer 20 who installed it and so forth.
~
21 Q
You concluded the background section by 22 saying, "Without a complete and careful verification, 23 any additional system analysis on these plants r~s
(,)
24 cannot be properly quality assured."
25 What did you mean by "cannot be properly
/
1 Womack 739
(~
.V) 2 quality assured"?
3 A
I meant that in order to assure the accuracies 4
or quality with respect to accuracies of new systems
(
5 analyses we might undertake for these plants we would 6
need to check to make.sure that our inputs were up 7
to date.
8 Q
And if they weren't up to date, then you 9
would have no assurance the analysis was valid for the 10 plants for which it was being performed;. is that 11 right?
12 A
If they weren't up to date, we would have to U
13 assess whether or not analysis which was,done with 4
14 other inputs was valid for its expected purpose.
It 15 could very well be valid for its expected purpose, if 16 it was something that was being done for conservatism.
17 Q
If it was something being done for what?
18 A
If it was something that was being done to 19 be conservative and the change which had been made 20 didn't affect the conservative outcome it could be 21 perfectly valid to keep the existing analysis.
It 22 would depend on the purpose of the analysis and the 23 nature of the change and the sensitivity of the result 7-l
( _/
24 of that change.
25 Q
As a result of the ATOG program or any
1 WomAck 740 0
2 other program, has B&W made changes in its analyses 3
to reflect verified as-built configuration?
4 A
Yes.
5 Q
In the action plan you estimated that the 6
work you described would be completed within six 7
months; is that right?
8 A
I estimated that it could be completed within 9
six months.
10 Q
Was the as-built verificatibn done after 11 June 18, 1979 for the 177 FA plants of B&W7 12 MR. WISE:
Which ones?
You mean -- is
.O 13 your question -- are you asking was it done I
14 for any of them or all of them or some of them?
15 Q
Was it done for all of the ones that you 16 are referring to,in the action plan first sentence?
17 A
I don't think that the program as described in 18 this early conception was carried out in exactly 19 this way, no.
20 Q
For what plants was this work done?
21 A
The work that -- related to this which has been 22 subsumed under the ATOG program will be done for all 23 plants which are members of that program which, to 24 the best of my knowledge is all Bsw plants, however, 25 the work on as-built input is not all being done for i.
1 Womack 74J 2
all plants at one time.
The work is being done one 3
plant at a time with some overlap and at the front 4
end of the work under the ATOG program important 5
inputs and current configuration information is 6
gathered and verified.
7 Q
Is there somebody who is the head of the 8
as-build configuration verification program?
9 A
well, as we have gone over in earlier testimony, 10 Mr. Kelly is the project engineer for tite AToG program 11 and I believe he has he has people who help him 12
,q in gathering and verifying this information.
V 13 Q
You referred earlier to an analysis being j
14 done by EPRI of the performance of a pilot operated 15 relief valve under two-phase flow.
16 Do you recall that?
17 A
Did I say analysis or testing program?
18 Q
I am not sure which you said.
19 A
I believe the EPRI program is primarily a i
20 testing program.
21 Q
Isn't a testing program one way of analysing 22 something?
Yes or no?
23 A
Yes, I suppose we could look at it that way.
24 Q
Has EPRI prepared any reports on its 25 testing of pilot operated relief valves?
i m
..,,v,
c 1
Womack 742 nU 2
A I don't know.
l 3
Q You haven't seen any?
4 A
I don't believe I have, no.
5 Q
Who at B&W is the principal individual 6
who has neen following the EPRI testing program on 7
valves?
8 A
At this time?
9 Q
Yes.
10 A
I think Mr.'Fahland would be the most conversant 11 through the period with that program, although there 12 are others who have followed it.
f_s U.
13 Q
What is Fahland's area of e,xpe r ti s e ?
14 A
Mr. Fahland is the manager of the Equipment 15 Engineering section at this time.
16 MR. SELTZER:
I would like to mark as 17 GPU Exhibit 26 for identification a memo from i
18 D.G.
Newton to his friend "Distribu lon," subject 19 Review Draft Proposal, March 12, 1980, with a 1
20 copy to E.A.
Womack.
21 (Memo dated March 12, 1980 from D.G.
22 Newton to Distribution, with a copy to E.A.
23 Womack, subject, Review Draft Proposal, marked
)
24 GPU Exhibit 26 for identification, as of thi's 25 date.)
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1 Womack 743 s
2 Q
Is GPU Exhibit 26 marked for identification 3
a copy of a memorandum which you received in or about 4
mid March 1980 in the regular course of business?
5 A
It appears to be.
6 Q
Does this describe the assignment to 7
EPRI of the testing program for pilot operated relief 8
valves under two-phase flow condition which you 9
described earlier?
10 A
No, I don't think so.
I think th$s is a request 11 from EPRI for B&W to propose against a specific task 12 which is probably related to that program.
-~g i
13 Q
What do you mean?
i 14 MR. WISE:
I think his answer was pretty 15 clear.
16 A
The attachment appears to be an invitation from l
17 EPRI to request B&W to propose, to perform some 18 specific work in support of the overall safety and 19 relief valve program of the EPRI.
l 20 Q
Did 3&w subsequently propose that work be
{
21 done?
22 A
I don't recall whether we did or not.
23 Q
Does Exhibit 26 describe the testing or 24' analysis of relief valves sticking open that you i
25 recalled EPRI had performed?
l
-- =.
. _ =.
t 1
Womack 744
-/~N 2
A Let me just read it and see.
3 As I read it the exhibit alludes to the test 4
program but does not describe it.
5 Q
okay.
6 MR. SELTZER:
I would like to mark as 7
GPU Exhibit 27 a letter from Dresser Industries I
8 to GPU with a copy to an outfit in Lynchburg 9
called Babcock & Wilcox, dated April 1,
- 1980, 10 (Letter from Dresser Indust'ies dated r
11 April 1,
1980 to General Public Utilities Corp.
12 with a copy to Babcock & Wilcox in Lynchburg, 13 marked GPU Exhibit 27 for identif.ication, as 4
14 of this date.)
15 Q
Do you know Don Woods?
16 A
Yes.
17 Q
Is he really the manager of Purchasing at 18 B&W7 19 A
No.
20 Q
What is he?
21 A
He is I believe his title is Senior Purchasing 22 Agent.
23 Q
Is he, or people who report to him,
(~\\
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24 respons'ble for procurement of B&W systems?
i 25 A
Yes.
.~ _.,-. _ -. _... _..
s 1
womack 745 2
Q Dresser says in the fourth paragraph of 3
GPU Exhibit 27, "Any application of pilot opa. rated 4
relief valves or ASME code safety valves on relieving
(
5 service that u t'ili z e s a flow media other than saturated 6
steam may be an improper application of the product."
7 were you aware that Dresser, the manufacturer 8
of the Three Mile Island relief valve, has taken the 9
position that using that valve for service other than 10 saturated steam may be an improper appil, cation of the 11 valve?
12 A
At what time?
You mean today?
O
, 13 Q
At any time before today, 14 A
Yes, I think I had understood that Dresser had 15 indicated'that subsequent to Three Mile Island.
16 Q
Has B&W ever expressed to Dresser any 17 contrary view?
18 A
I don't know.
19 Q
To.your knowledge has B&W ever obtained 20 any test results that showed whetner the pilot operated 21 relief valve of the type in Three Mile Island is 22 capable of successfully handling two-phase flow?
23 A
There are a lot of problems with that question, b)
(_
24 The short answer is I don't know.
25 Q
what are the problems with the question?
1 Womack 746 2
A well, when you say successfully handling 3
two-phase flow, do you mean handling -- passing 4
two-phase water and then performing all of its 5
functions exactly as it did before?
If that is what 6
you mean by success, that is one thing.
If you mean 7
passing two-phase' flow and remaining in tact as a 8
valve, that's another question.
9 Q
Let me ask you a third question.
10 Have you seen any report thkt indicates 11 the Dresser valve can successfully handle relief of 12 saturated steam?
13 MR. WISE:
Again, what is the definition 14 of successful?
15 MR. SELTZER:
With a high degree of 16 reliability.
17 A
I don't know that I have personally seen any
- 18 such report.
I believe Mr. Dresser's -- or Mr. Tacy's 19 letter indicates that they manufactured them for that 20 service.
21 Q
Grumman also manufactures the flexible 22 bus for carrying passengers but that doesn't mean 23 that it's successful for that application.
24 MR. WISE:
It depends upon your point of 25 view.
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,/, Q You said you don't believe,you have-ever
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seen a report that demonstrates tha' the relief valve
.ls; I
i f
t s-the type that is in Three! Mile Islanci can liandle 4.y l *, o f s
5 relief of saturated steam with a nichderjree 1f reliab,lity; is that right?
h' 6
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'7, ;Ar,][I.,said I don't believd',I)parsonally have seen gyy [
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That wou'd not norn. ally -
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9 no rmall,'y. in the courset.of my responsibilities,
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4 /' Q Has anybody ever told)you that such a'
,o rc; r
- 11 report exists?
j 12 A
I don't [ecall whether I have-beenitold that
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.' 14 7 Q
, Year ago thV;" AE C
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q ur,yJto.have standar.ds?
.i part..of the s
./
t comisonents which were 1 #
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for reliability for t'
~y 9~
0 ;/. 6 safety system ii.31nu clear. plant s.-
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Are6you if amiliar with AEC requ'irements t
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component which is
' hat would say a partidular I'< )
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, s,
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.ic' le s s than a threshhold number?
s/ 3 ~.;
7 j
P 211 A
Well, such requirements, qualitative requirementi x
dl,
V i is'r.'u e d earl'y.
1 wi@ cut' a specific quan'titative goal were
, 22
.. s
'23 l' ink that qua n ti t a ::ive requirements would n o.t Itave Q,a al'ong'out o f i,th a t portion o'f the.AEC which is
- 74 '
come 3,
1w 25
'r e spo c sible for regulations as I understand it, until' 7
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1 Womack 748 v
2 the time of the first regulatory guides.
3 The other arm of the AEC which I was more 4
f amiliar during that period issued standards for 5
plants that it constructed itself but these were not 6
applied to the commercial industry.
7' Q
what failure rate or non-failure rate has 8
the NRC required for safety equipment?
9 A
I don't believe the NRC has stipulated general 10 failure rates for safety equipment.
11 Q
well, for example, the NRC requires on-site 12" power at all nuclear plants; isn't that right?
J 13 A
I think that is right.
14 Q
And the reliability with which that on-site 15 power has to function is something that is also 16 specified by the NRC; isn't that true?
17 A
I believe you are correct that there is a 18 reliability target for on-site-power supply and a 19 reg guide that. deals with that subject.
20 Q
And there are reliability guides for the 21 functioning of various ECCS systems; isn't that right?
22 A
I think we might find one, yes, I think that's 23
- right, f3
(,/
24 Q
one of the reasons that manufacturers 25 of nuclear equipment provide backup components is to
1 Womack 749 i
.p
'k_)
t 2
increase the reliability with which emergency 3'
equipment will functions isn't that right?
4 A
Yes, I would say th a t' ' s right.
5 Q
When you say that the levels of reliability 6
are specified in reg guides, what do you mean by 7
reg guides?
8 A
The Commission staff issued a series of numbered 9
regulatory guidelines in the 1970's defining goals, 10 objectives, guidelines for various parth 11 of the nuclear power industry.
These guidelines were 12 not intended as regulations per se but as guidance on 13 what the staff would find acceptable generally in a 14 particular area.
15 In other words, compliance with the regulatory 16 guide was not the only resolution of a particular 17 concern, however, it was thought by issuing regulatory 18 guides that a high degree of consistancy amongst 19 solutions to particular needs in the nuclear power 20 industry could be found and reduce the effort of 21 design and regulation in these areas.
22 That's what I meant by reg guides.
23 Q
For components that are required to function 24 in'an emergency, what are the levels of reliability 25 that the NRC has generally required?
1 Womack 750 V(~%
2 A
I don't believe that there is a generally 3
established guideline for a category of components 4
that would be classified as components required to 5
function in an emergency., Specific areas such as the 6
examples you mentioned, I think have been the subject 7
from time to time of reliability standards or guidelines, 8
but generally prior to Three Mile Island the Nuclear 9
Regulatory Commission did not make heavy use of 10
- quantitative probabilistic risk or probibilistic 11 failure guidelines as a basis for licensing.
12 Q
Didn't they require before Three Mile 13 Island that manufacturers prove that if. called upon 14 to operate an emergency core coolant pumping system, it 15 would operate with a high probability?
4 16 MR. WISE:
Could you read that question 17 back, please?
18 (Question read by the reporter.)
19 MR. WISE:
Do you mean manufacturers or 20 utilities?
21 MR. SELTZER:
I mean the people who supply 22 the equipment.
23 A
I don't know that they did not make such 24 requirements on licensees prior to Three Mile Island-2 25 and in some license applications.
Certainly I do not
1 Womack 751
\\.i
~
2 believe that was a quantitative requirement from 3
the very beginning of designs of the vintage of TMI-2.
4 Q
Are you saying that you don't know or that 5
you don't believe there were such requirements?
6 A
Actually I think I said both.
I think I said 7
that I don't believe 8
Q That's what I thought you said.
9 A
-- I could not -- I am not sufficiently possessed 10 of information to know that they did no't require that 11 in some licensing applications from some utilities.
12 To the best of my knowledge it was not a requirement 7-t s
13 on TMI-2 although it may have been.
14 MR. SELTZER:
I would like to mark the 15 B&W specification for the Three Mile Island 16 Unit 2 pilot operated relief valve dated 17 January 7,
1970.
18 (B&W specification for the Three Mile 19 Island Unit 2 pilot operated relief valve dated 20 January 7, 1970 marked GPU Exhibit 28 for 21 identification, as of this date.)
22 Q
At any time either before the Three Mile 23 Island accident or in the aftermath of the accident, 24 have you ever taken a look at B&W's specification for 25 the pilot operated relief valve?
1
.Womack 752 2
A I don't recall having done so.
I may have, but 3
I d n't recall it.
4 Q
Do you recognize GPU Exhibit 28 as being 5
the format of B&W specifications?
6 A
Yes.
7 Q
It says that it was prepared by M.
J.
8 Bennette.
9 Is he still around?
10 A
I don't think I know an M.J.
Bennette.
That 11 might be Bernette.
I know an M.
Bernette.
12 Q
Is he still with the* company?
13 A
I know of an N.
Bernette.
14 Yes, I believe he is somewhere within B&W.
15 g
would you turn to the last page of Exhibit 16 28.
17 A
That is the page headed " Appendix"?
18-Q Yes.
19 Do you see where the service co'nditions 20 are listed?
21 A
Yes.
f
(
22 Q
Opposite fluid the service condition listed 23 is " saturated steam."
Do you see that?
f'N
(.
24 A
Yes.
i!
25 Q
Do you have any reason to believe that
'I 1
Womack 753
(~%.
G'.
2 B&W specified any other fluid for the service conditions 3
for the Three Mile Island pilot operated relief valve 4
other than saturated steam?
(
5 A
I don't have any knowledge and therefore I don't 6
have any reason to believe that this didn't, did or 7
did not.
8 MR. SELTZER:
Off the record.
9 (Discussion off the record.)
10 (Recess taken.)
11 BY MR. SELTZER:
12 Q
What is the life expectancy of a B&W 177 NA 13 plant?
14 A
I think they are normally designed for a 40-year 15 life.
16 Q
None have lived that long as yet, have they?
17 A
No.
I presume you mean by life, has been in 18 service that long.
19 Q
Right.
20 As originally designed with PORV setpoints 21 where they were prior to the Three Mile Island 22 accident, approximately how many times during the 23 life of a B&W plant was it expected that the PORV would 24 be call'ed upon to act?
25 A
I don't know what the expectation of the designer
1 Womack 754 f\\
U 2
was.
3 MR.-SELTZER:
I would like to mark as 4
GPU Exhibi. 29 for identification a document 5
from the files of one of the top engineers at 6
-B&W, E.A.
Womack, entitled, " Events that 7
Initiate PORV Operation."
8 (Document entitled " Events that Initiate 9
PORV Operation" from the files of E.A.
- Womack, 10 marked GPU Exhibit 29 for identif'i, cation, as of 11 this date.)
12 Q
Is GP'J Exhibit 29 a copy of a document g,
N) 13 that you have seen before?
14 A
Yes.
15 Q
can you identify what it is?
16 A
I believe it is material that was prepared in 17 the spring, late spring of 1979 in connection with 18 evaluation of alternatives which we were considering 19 when our licensees were under pressure from the 20 Nuclear Regulatory Commission to take steps which 21 would reduce or eliminate the expected actuation of 22 the pilot operated relief valve in their operating 23 plants.
24 Q
In order to evaluate the ramifications of 25 that you needed to know all the different types of
_,,.. _ _... _ _ _ _ _,. _.. _ _ - ~,.
. _ _ ~ - _ __
1 Womack 755
(~h V
2 events that could lead to actuation or opening of the 3
pilot operated relief valve; is that right?
4 A
That was one of the factors, 5
Q Are all 16 of the events listed on the 6
first page of GPU Exhibit 29 marked for identification 7
transients that would lead to the opening of the pilot 8
operated relief valve?
9 A
I think these 16 events were identified by the 10 safety analysis group as events which could initiate 11 PORV operation.
I don't know that PORV operation is 12 an inevitable result of every one of these events.
OG 13 Q
what is an inadvertent closure of MSIv?
14 A
The MSIV is the main steam isolation valve 15 and an inadvertent closure of the main steam isolation 16 valve would be the equivalent of interrupting the 17 normal load for the steam generator secondary side.
1 18 Q
The main steam isolation valve is between 19 the steam generator and the electric turbine; is that 20 right?
21 A
Yes.
22 Q
So if the isolation valve slammed shut, 23 it leads to a turbine trip which could then produce
(~)
(j 24 an actuation of the pilot operated relief valve; is 25 that right?
--,.,e-,
..-,7 y
1 Womack 756
'O
\\m/
2 A
I don't think that the turbine trip would 3
necessarily have to happen to actuate the pilot 4
operated relief valve.
The closure of the main steam k
5 isolation valve would upset the heat removal from 6
the steam generators substantially.
7 Q
The turbine normally functions as the 8
primary heat sink for the steam?
9 A
The turbine is normally the load for the steam 10 generators when the plant is in normal p,ower operation.
11 Q
Would it be possible to determine the i
12 anticipated frequency of each of these 16 events?
()
13 A
Probably.
14 Q
Would that lead to some estimate of the I
15 frequency with which the pilot operated relief valve
]
16 would be called upon to operate?
i 17 A
Not without more work.
18 Q
What would you have to do?
19 A
I think you would have to look at the various 20 possible scenarios under each of these event headings 21 which might lead to PORV operation and you would have 22 to determine what the probability or the frequency of 23 expectation for each of those scenarios was as opposed as opposed to any event which might have 24 to the 25 that title or have that identification.
1 Womack 757 O
2 Q
Do you know whether anybody at B&W has 3
ever done that?
4 A
I don't know whether we carried this particular
(
5 work out that far.
I think we looked at the events 6
which were both more frequent on this list and more
~
7 commonly expected to occur and in conjunction with 8
which PORV operation was more commonly expected to 9
occur.
10 Q
A turbine trip is an event that certainly 11 has to be anticipated in the design of a nuclear 12 steam system, right?
\\
13 A
Yes, it is.
14 Q
In the B&W system, does a turbine trip 15 from full load generally lead to actuation of the 16 pilot operated relief valve?
17 A
As it was designed to operate as of-March 28, 18 1979 or as it exists today?
19 Q
As it was designed prior to the Three Mile 20 Island accident.
21 A
Yes.
22 Q
Would a loss of external electrical load, 23 which is item 9 on GPU Exhibit 29 marked for I(,)
24 identification, generally lead to actuation of the-25 pilor operated relief valve prior to the Three Mile
I womack 758
~V 2-Island accident?
3 A
It would depend on how rapidly the load was lost 4
and the power level at which the plant we,s operating-5 Let's just say that it might lead to a PORV actuation.
6 Q
The more sudden the load rejection, the 7
more likely it would be that the pilot operated relief 8
valve would be called upon to function?
9 A
All else being equal, that's correct.
10 Q
Would a rod withdrawal eithbr as a group 11 or as a single rod result in the pilot operated relief 12 valve opening?
7g Y.
13 A
I think that would depend a great. deal on the 14 withdrawal rates and the circumstances at the 15 initiation of the event and what the control system 16 may have done in response to it.
That is one of a 17 number of events on this list which I think is in 18 that category that would not inevitably lead to a j.
19 PORV operation.
20 Q
In the course of an average year of 21 operation for a B&W nuclear plant was it your 22 understanding before the Three Mile Island accident 23 that the pilot operated relief valve in such a plant n(,j 24 would be called upon to operate several times?
25 A
I don't believe that before the Three Mile Island i
1 Womack 759 g
- y)
.2 accident that I had ever.given serious consideration 3
so as to have an impression about the frequency of 4
challenges to the pilot operated relief valve.
5 Q
Would it be fair to say that since the 6
accident you have given a lot more consideration to 7
the frequency of operation of pilot operated relief 8
valves than you gave before the accident?
9 A
Yes, it would be fair to say that about me 10 personally, yes.
11 Q
Would it be fair to say that about a lot 12 of people at B&W7 i
i
~
N 13 A
I am not sure at all that that's true.
14 g
si*nce the accident have-you formed the 15 understanding that under the modes of operation which 16 were in effect before the accident, the average B&W 17 plant would be challenging its pilot opera'ted relief 18 valve more than once a year?
19 A
Yes, I believe that the historical records would 20 indicate that B&W plants were challenging their pilot 21 operated relief valves one or more times per year
(
22 prior to Three Mile Island.
23 Q
Do you have any recollection what the
(~)
(j 24 average frequency of challenge to the pilot operat'ed 25 relief valves was for a B&W plant prior to the Three Mile 1
e
.-m,
...___m.
l Womack 760
)
%_/
2 Island accident?
3 A
That was a difficult number to get for the 4
reasons we have discussed earlier today because not all
(
5 the events which might challenge the pilot operated G
relief valve were recorded.
We made estimates a,nd 7
you have seen some of the estimate data that were 8
in the earlier exhibits introduced.
9 Q
Do any of those exhibits to your recollection 10 describe how many times per year the avb, rage B&W 11 plant would see its pilot operated relief valve 12 operate?
A(sl 13 A
Doesn't the exhibit that had the draft attached, 14 which is GPU number...
15 Q
217 4
16 A
I don't seem to have a copy of that anymore.
17 MR. WISE:
It's this one here.
18 (Handing document to the witness.)
19 A
Doesn't this have something in it about rates?
20 Q
Where?
l 21 A
Let me see.
22 Well, I don't -- quickly, I don't spot the 23 number.
However, in the paragraph which you were
(
24 asking me about this morning it is noted that the 25 data of 146 events spanned 32 reactor years of
1 Womack 761 7-) ^
(.) -
.2 operations or -- and includes 64 loss of feed events 3
or an average of two per year.
4
-Q Where were you reading?
(
5 A
In GPU Exhibit 21 at page 5 in the first full 6
paragraph on that page.
7 Q
You would say that that data showing 64 8
loss of feedwater accidents is conservative because 9
not all loss of.feedwaters would be reported?
what).
10 A
Conservative with respect to 11 Q
With whether the number is low or high, 12 A
Which number?
13 Q
64.
14 MR. WISE:
I am afraid I have lost the 15 thrust in where we are in the questioning.
16 What piece of information are we now attempting 17 to derive?
18 MR. SELTZER:
The sentence that Dr. Womack 19 read said there had been 64 loss of feedwater 20 accidents in the data assembled by B&W, right?
21 MR. WISE:
For this report that is 22 reflected in GPU No. 21, that's correct.
But 23 what --
(,j 24 Q
Do you agree that that is correct, Dr. Womack, 25 since you are the only one who is sworn?
1 Womack 762 s) 2 A
I agree the sentence says what I said it says.
3 I am no t su e where we are here.
I am with Mr. Wise, 4
perhaps it would be good to refresh, if you would for
(
5 us, refresh the question and let me see if I~can be 6
sure my answer to_you is the most accurate I can give.
7 Q
The author of the attachment reports based 8
on-B&W data that there had been 64 loss of feedwater 9
accidents spanning 32 reactor years; right?
s'id his data 10 A
Yes, in the data that he had he a
11 included 64 loss of feed accidents.
12 Q
To the extent that there has been i
s
\\m/
13 under reporting to B&W there might be more loss of 14 feedwater events than the ones he is reporting?
15 A
Yes, there might have been, yes, if these 16 accidents or incidents were not fully reported in, 17 this data, that's right.
18 Q
You have indicated that in ad ition to 19 loss of feed accidents generating challenges to the 20 pilot operated relief valve there are many other 21 events that would cause a pilot operated relief valve 22 to be actuated; right?
23 A
There are other events, yes, which could cause
.O
(,j 24 its actuating, i
6 25 Q
Now, since you have pointed out the data
-...~
, -.... ~. - - -.... - -....,.. -
1 Womack 763 2
in GPU Exhibit 21, let me ask you, just looking at 3
loss of feed accidents those would generate at 4
least two challenges to a pilot operated relief valve k
5 per year at the average B&W plant; right?
6 A
Th'is appears to be what those data say about 7
that historical operation of the plants, yes.
8 Q
And since there are perhaps 15 other 9
categories of events that create challenges to the 10 pilot operated relief valve it follows,t.does it not, 11 that the average number of occasions on which a 12 pilot operated relief valve was called upon to operate
.\\'~'/
13 in a B&W plant before the Three Mile Is. land accident 14 is something greater than two per year; right?
15 A
something greater.
It might not be as great as 16 the proportion between the one type of event and the 17 16 that might lead you to believe.
18 Q
I wasn't suggesting that it was 16 times 3 19 A
okay.
20 Q
Is that what you were afraid I was 21 suggesting?
22 A
Sometimes one might gain that impression if i
23 you didn't carefully look at the events and the
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(_)
24 other considerations that would surround this.
25 Q
Do you recall any absolute number of pilot
i i
1 Womack 764
(~\\
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l 2
operated relief valve challenges being discussed 3
at B&W for the set points that existed before the 4
Three Mile Island accident?
~
5 A
Yes.
I do recall discussing absolute numbers 6
for PORV challenges.
7 Q
And what is your.best recollection of the 8
average number of challenges per year?
T 9
A I don't know, again, how valid those data are, 10 but-it might be something between 2 and,10.
11 Q
'If it were 10 per year, that would be 400 12 over the life of a plant; is that right?
w 13 A
_Yes, it could be 400 over a 40-year lifetime.
14
- Q When you said it might be between 2 and 10, g
15 were you meaning that there was somewhere between 2 16 and 10 initiating events or transients that would 17 call upon a pilot operated relief valve to function?
18 Is that what you meant?
19 A
Basically.
I am saying that my best guesstimate 20 of what the challenge rate would probably be would 21 be somewhere between 2 and 10.
{
22 Q
Okay.
23 A
It might be different.
24 Q
It might even be more?
i 25 A
I don't know.
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2 Q
What did you mean when you said it might 3
have been different?
4 A
It could conceivably be'more.
It could
(
5 conceivably be less, although it is not likely to be 6
less than the two represented there.
i 7
Q So your testimony is that during the 8
course of an average year there could be an event 9
such as a loss of feedwater transient which would 10 cause the pilot operated relief valve to,have to 11 function somewhere between 2 and 10 or perhaps more 12 times; is that right?
13 A
That appears to be the record as we found it 14 on review after the accident as I found it on review 15 after the accident, 16 Q
And if one of those initiating events 17 caused the pilot operated relief valve to cycle 10 18 times, you would still call that one initiating i
19 event; is that right?
20 A
. With the degree of specificity in the data that 21 we had, we would have called that, it would have 22 probably been unable to tell except maybe in one or 23 two events the difference between that and a single
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24 opening but I am not sure what the thrust of your 25 question is.
2
~ - - _ _ -.,, _.,,
1 Womack 766 2-Q When you estimated that the valve would be 3
called upon to operate between 2 and 10 or more times 4
a year,-you would just call it one' time that it was
(
5 called upon to operate even if it cycled 10 times 6
during an event; isn't that right?
7 A
I am not sure my estimate has that degree of 8
precision in it.
My guesstimate is that that would 9
be the number of challenges.
I. don't think that 10 there were very many events in which thk pilot operated 11 relief. valve was called upon to perform cycling 12 service.
~
13 Q
Does cycling service subject the valve 14 to different stresses than single requests that it 15 operate?
1 16 A
I don't know.
I.am not sufficiently.an expert 17 in valve analysis to tell you.
18 MR. SELTZER:
I would like to mark for 19 identification as GPU Exhibit 30 a memo from 20 E.A.
Womack to J.D.
Carlton, subject, Control 21 Failure Position for Pilot Operated Relief 22 Electrical Circuitry, May 15, 1979.
23 (Memo dated May 15, 1979 from E.A.
Womack
(,j 24 to J.D.
Carlton, subject, Control Failure 25 Position for Pilot Operated Relief Electrical
1 Womack 767 s
(
)
v 2
Circuitry, marked GPU Exhibit 30 for 3
identification, as of this date.)
4 Q
Is GPU Exhibit 30 a copy of the memorandum
(
5 which you sent to Mr. Carlton in the regular course 6
of business on or about May 15,-1979?
7 A
Yes.
8 Q
You state in there that, "In May of 1978 9
TMI-2 experienced a transient in which a power failure circu'try control 10 to some portion of the electrical i
1 11 resulted in a failure of that valve in the open 12 position.
When I learned of this, I asked Service I,_ li
\\
13 to review the status of the other operating plants 14 to determine whether similar failure might occur in 15 those plants.
The response from Tom Fairburn is 16 attached."
17 You say when you learned of the TMI-2 18 transient you asked somebody to do something.
19 When did you learn of the 1978 TMI-2 20 failure of electrical circuitry controlling the PORV7 21 A
I don't know the precise day, 22 Q
About when?
23 A
sometime during the spring of
'79.
'(Oj 24 Q
Before or after the Three Mile Island-2 25 accident?
1 Womack 768 tv$
2 A
After March 28th.
I believe I did not know 3
about it before then.
4 Q
So it is not that Fairburn was taking
(
5 a long time to get back to you, you just didn't know 6
about the 1978 failure until the spring of '797 7
A I don't believe I knew about the May '78 failure 8
until the spring of
'79, that's correct.
9 Q
Can you read the note that is on the i
10 bottom of the last page?
11 A
On the bottom of the last page?
12 Q
Yes.
[/
}
\\-
13 A
I don't have a note on the bottom of the last 14 page.
4 15 Q
The bottom of the second page?
16 A
Not very well, i
17 Q
Here is the copy from which the exhibit I
18 copy was made.
Can you read that?
19 (Handing document to the witness.)
20 A
Yes.
21 Q
Who is that a note to?
22 A
Me.
23 Q
From whom?
()
24 A
I'believe that's Don Roy.
%~-
25 Q
What does Don say to you?
1 Womack 769 iV 2
A It looks like, "It looks like a mixed bag 3
here with some question as to the best position to i
4-take.
Please examine what the plant design position is
(
5 on power failure to the PORV and prepare a recommendation 1
6 to Customer Services."
7 Q
Did you do that?
8 A
This was this memorandum initiated that action.
9 Q
What action was taken?
10 A
I am not sure what was finally seht to the 11 customers or whether it was finally taken in the form 12 envisioned here, but as a result of this work and
\\
13 other work some of which we have already discussed 14 today, the customers were all informed with respect 15 to the fact that one way to open a pilot operated 4
16 relief valve and have it remain open would be for 17 failure of the control circuitry and since portions of 18 that control circuitry were outside the B W/NSS scope, 19 each customer was asked to examine his circuitry and l
20 provide assurance that control failures would not 21 lead to the opening and remaining open of the pilot 22 operated relief valve.
23 Q
So the recommendation was it should fail
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24 shut, not open?
l 25 A
That it should not fail open.
I don't remember t
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1 Womack 770 I^l 2
whether we said if it was open that it would fail to 3
the shut position.
I am inclined to believe we did.
4 Q
You are inclined to believe you what?
(
5 A
I am inclined to believe we did say that, but 1
l 6
I do'have a recollection that we asked each customer L
i 7
to determine that=his valve would not open in response 8
to control system failures and power interruptions.
9 Q
When you pursued this assignment, was 10 that the first time that anybody at B&W.had canvassed 11 B&W's customers to see how their valve would fail 12 open or shut following a power loss?
A\\)
~
13 A
I don't know.
14 Q
Do you have any knowledge of anybody else 15 doing such a survey?
16 A
I don't know.
17 Q
When you say you don't know, you don't 18 know of anybody else doing such a survey?
19 A
That's right.
20 MR. SELTZER:
I would like to mark as
(
21 GPU Exhibit 31 a memo headed " Actions Needed Q
22 Based on Lessons from TMI-2."
It has in the t
23 upper right-hand corner the initials "EAW,"
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24 June 7,
1979.
f 25 (Memo dated June 7,
1979, entitled " Actions
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Needed Based on Lessons from TMI-2," marked 3
GPU Exhibit 31 for identification, as of this 4
date.)
5 Q
Can you identify what GPU Exhibit 31 is, 6
please?
7 A
Not with great certainty I can't, 8
Q Do you know who wrote it?
9 A
I am not sure.
It may very well be something 10 that I wrote and gave to Dr. Roy as par'% of his 11 request to get input from his staff.
12 Q
In other words, Roy asked the people who
~~g Q.)
13 reported to him to give him lessons learned lists?
14 A
Yes, he did.
15 Q
And is this list of nine categories 16 something that you believe you may have prepared as 17 your contribution?
18 A
I believe that is what it could be, yes.
19 Q
And these are actions needed in order to 20 respond to lessons learned from the TMI-2 accident; 21 is that right?
{
22 A
These are my thoughts at that pa r ti c ula r time 23 about some of the things that seemed to me to be
(,N actions based on those issues that were
/'
/
24 desirable 25 getting a high level of attention both in my mind
1 Womack 772 2
and the minds of others after the Three Mile Island 3
accident of March 28th.
4 Q
After the accident and because of the 5
accident; is that right?
6 A
Yes, I think largely because of the accident.
7 Q
Are these listed in any order of priority?
8 A
I don't believe so.
i 9
Q The first item that you list is, " Improve 10 operating staff capability to recognize'.and handle 11 off-normal conditions safely."
12 The " operating staff" refers to people
(,
13 in the control room of the nuclear plant?
14 A
Yes, all those that are involved in operating.
15 Q
I take it the four items that are listed 16 under what I just read are areas in which you believed 17 improvements should be made?
18 A
There are areas in which I believe improvements qualifi$d expert 19 might help.
Certainly I was not a 20 in that area, so I was giving Don a highly variable 21 series of impressions as far as the quality of my 22 knowledge and thinking was at this particular time.
23 Q
oh,-you are too modest.
(
24 A
Thank you.
v 25 Q
You said that you thought there should be
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Womack
.773 O)
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2 expanded procedures for handling off-normal events.
3 Do you see that?
s.
4 A
Yes.
t 1
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A 5
Q )'s What do you mean by expanded procedures?
6 More procedures?
s t
s 7
A W e ll,' ' I think that most of this has worked throuhh 8
protqy well, we have govered it pretty well in 9
discussing the off-normal transient operating guidelines.
10 As far as I am concerned the discussion that we.have N
11 had and the material that's been introduced on that 12
(~g program followed in almost all of these discussf5ns, t
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i 13 almost all the'sh items. with a few exceptions, of s
s 14 N
course.
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What did you mean when you said youl t S
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16 thought there should be expanded procedures?
~
17 A
I don't know now what I specifically~ meant by w
18 that other than what I have just said.
19 Q
By the phrase " expanded procedures" did 20 you mean there should be more procedures, more 21 extensive procedures?
22 A
I think expanded again as I have said, I don't 23 know what I specifically meant here other than to D(_
24 direct you to the more"comple'e discussion of this t
.t 25 area undar the ATOG framework.
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I Womack 774 i
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Q Well, I don't mind if you want to refer 3
to that.
Under the ATOG framework are you proposing 4
that there should be more procedures and more specific k
5 procedures for handling off-normal events?
6 A
I think the ATOG program proposes procedures 7
which couple additional explanation under guideline 8
under a guideline type format and could be said to be O
expanded in that way.
10 Q
To be specific, the procedu',es that you r
11 have proposed under ATOG would contain more explanation 12 of why certain actions were called for and would also tell f
)
~
13 operators both what to do and what no t.t'o dos isn't 14 that right?
15 A
Those were some of the elements of the program 16 that we mentioned and have discussed before, yes, sir.
17 Q
And those are areas in which the proposed 18 procedures would be expanded from the types of procedures 19 that existed before the Three Mile Island accident; 20 isn't that right?
21 A
To the extent that I knew the types of procedures 22 that existed before Three Mile Island which is quite 23 minimal.
'[
24 Q
You suggested that there should be 25 increased drill in off-normal conditions on simulators.
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More drill?
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Just more drill.
9
.i 5
Q By simulators y,-'arefinclucing the B&W
/
6 simulator used to train Three Mile Island operators?
7 A
Yes.
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itm props.Nd'as an acti6n
[i 8
Q Your second e
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9 s.needed based'on the lessons from the Three N
Mile Island
,J-p design / operating bacip fyr-J 10 accident is, " Improve the e'
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11
);.o,f f-no rmal, ope ra tion, and u.ahe it visible to the l
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[', ;12 operator and licensne."
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Q
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' 13; 3 What did you mean when'you.said "make it,
3,7 s
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'visiblo"?
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,15-sys eci fically the kind of cco nne c tio n to qui;!elin'es
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16 that.is 6,entemplated?in'the a b'n c r m a l transient I,!
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Q.
17 operating guidalines.pyogram, making that'informationl,
/
l' 3;
o 18 more readily accessible to more of the people who
/
19 will be involved in.opearting plants.
-c 3
20 Q
' speqificpily whrt _
you proposing be ^
were
.?
that inf orma tion /more availabic?
21 done to make 22 A
Including th c.t -k-i r. d o f.i n f drma ti o n in the r
s
.j 23 guidelines f or. ope ra ti'on.
ja
'y
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bl 24 Q
_Your first '. tem under-Arabic 2 is,
'1 s
s
" Mechanist 3Mh..eva'luationof system response "
6 25 w-
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- 9 k d
d' #
p i
1 Womack 776 2
What does that mean?
3 A
It is essentially the same discussion we had 4
about the second day of this deposition regarding the 5
use of realistic as opposed to bounding or conservative 6
calculations in preparing descriptions of system 7
response.
8 Q
You were proposing, as I understand it, 9
that B&W perform realistic analyses rather than just t
10 bounding analyses?
11 A
I was proposing that that might help in improving 12 the understanding of the operator.
.O 13 Q
The next, item you list is,," Designer should 14 perfdrm systematic evaluation of the effects of 15 off-normal equipment and operator response; how to 16 recover."
l By designer" you meant B&W; is that right?
17 18 A
B&W or whoever the designer of the system was.
f 19 Q
In the case of a B&W 177 plant that is i
20 B&Ws right?
l 21 A
No, I think that's a little bit too broad.
In 22 the case of B&W supplied equipment on 177 plants that l
I-23 -
would be B&W.
24 Q
Okay.
25 A
Unless the utility has assumed the design I
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1 Womack 777
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2 responsibility, which in essence, is something that is 3
really done when modifications are made subsequent 4
to the start up.
(
5 Q
what were you proposing should be performed?
6 A
To kind of look at off-normal equipment and 7
operator response which is contemplated in the event 8
tree portion of the abnormal transient operating 9
guidelines.
10 Q
To what extent would that be,different 11 from the valuation that B&W had.been doing before 12 the Three Mile Island accident?
13 A
I am not sure I can tell you the answer to that 14 question because I don't know the history of all of 15 this.
16 Q
Well, what action did you believe you 17 were proposing be taken that B&W hadn't been taking 4
18 before you wrote this?
The fault tree analysis?
19 A
Well, the specific fault treefor, excuse me, event 20 tree analysis that is described in the abnormal 21 transient operating guidelines, some of which might 22 have been done previously at B&W and I don't know what 23 percentage would have been, but by pulling it all 24 together with current information and at one particular 25 time and by extending it to consider -- to go outside i
,.-_.______._.._.____,,.m.m..
1 Womack 778 4
2 the normal design requirements of the plant, to make 1
3 it more. comprehensive and more systematic than it 4
might have been in the past.
4 5
Q What does the phrase "how to recover" 6
add to what you were proposing?
7 A
of course the plant has a considerab'le amount 8
of flexibility and capability beyond those minimums 9
which are designed in as a contract requirement and 10 the operators of course know a lot of this.
The j
11 thought here was that that a systematic look at 12 those kind of capabilities would be of benefit again 4
13 in a comprehensive look of the sort'that the ATOG 14 program represents.
15 Q
The next item that you have is also listed i-16 under Arabic 2.
.It states, " Additional analysis, 17 where necessary, to assure system phenomena are 18 understood."
4 19 What additional analysis did you believe 20
-might be necessary in order to understand system 21 phenomena when you wrote this?
i 22 A
Oh, analysis which might help the designer and 23 the operators participating in this program to l
)
24 understand how system parameters would vary in 25 particular sequences of events even though those
1 Womack 779
/.
(
I L/
2 sequences of events might,from the standpoint of 3
overall system s a.* s ty, b e adequately enveloped by 4
some more straightforward and large r event, for
(
5 example, an analysis of interrupted natural 6
circulation which I think we discussed earlier today.
7 Q
You believe that there were areas in 8
which B&W could do additional analysis that vould 9
help operators understand what was happening in the 10 system?
11 A
I thought there might be and that's the reason 12 for the clause "where necessary."
,_()
13 g
You proposed next, "Guideli.nes for operation, 14 written at the level of understanding of the operators."
15 when you wrote that, did you believe that 16 there was currently operating information or procedures 17 that were not written at the level of understanding 18 of operators?
19 A
No, I don't think that that was that was the 20 thrust of that remark.
I think it was simply intended 21 to particularly modify the clause following which 22 talks about basic material on system behavior and 23 reminded any reader that that kind of basic material p()
24 on system behavior should be written to be readily 25 understood by its intended audience.
L
1 Womack 780 2
Q Do you think the level of understanding 3
which the operators of B&W plants have is generally 4
high enough for being able to operate B&W plants
(
5 successfully?
6 A
I don't know the answer to that question.
I 7
am not qualified to assess the level of competence of 8
operators.
9 Q
Do you also not feel qualified to assess 10 the level of understanding of operatorsV, 11 A
Let me say that I haven't attempted to make such 12 an assessment.
13 Q
In item 3 you talk about closing the loop 14 which is an ATOG buzz phrase; isn't it?*
15 A
Yes.
I think you could say that.
Unkind of 16 you, but I think you can say that.
17 Q
I apologize.
I certainly didn't mean to 18 be unkind to the author of the phrase.
19 A
In the sense that buzz phrase is pejorative.
20 Q
You proposed as part of closing the loop 21 to " Expose system design engineers to plant operator 22 training."
1 23 Why did you think that would be a good N
24 idea?
25 A
Because some system design engineers work
- ~
1 Womack 781 0
2 strictly with software inputs to their analyses which, 3
while they may be accurate, doesn't necessarily give 4
them a feel-for the total plant, particularly when 5
they work in a specific specialized functional area 6
and I feel that cross-fertilization between functional 7
areas in the context of looking at how a plant might 8
be operated can be of value to a technical specialist 9
at a certain point in his career.
i 10 Q
Has B&W instituted a system,for giving 11 plant operator training to its design engineers?
12 A
Yes.
13 Q
How did the design engineers react to that?
14 A
They like it, in general.
15 Q
Do they get to operate the simulator?
16 A
A little bit, yes.
They get to do some of that.
17 Q
Do any of them have any trouble doing it?
18 A
I couldn't couldn't answer that.
I don't 19 know.
20 Q
Have you ever operated a control room
(
21 simulator?
22 A
Yes.
23 Q
Do any of the B&W design engineers have 24 NRC operating' licenses?
25 A
Yes.
1 Womack 782
(~h NJ 2
Q Who?
3 A
I think a number of then have at times possessed 4
operating licenses.
I believe Kelly has now or has 5
possessed a senior operators license for example.
6 Q
Anyone else?
7 A
Well, I think John Bohart has, I think Dave 8
Downtain has, I think Ed Kane has an OL.
There are 9
a lot of them.
10 Q
It's not a prerequisite for designing a 11 nuclear plant that one be licensed to operate a 12 nuclear plant; is it?
(~%
\\~)
13 A
No, it's not a prerequisite for working on the e
i 14 design, that's for sure.
15 Q
I quess that works in both directions, 16 it's not a prerequisite for operating a nuclear plant 17 if you know how to operate one?
18 A
I ?uess that's also true, i
19 Q
One of those reversible equati ns.
(
20 You said that " Operational transients 21 must be reviewed for consistency with design
{
22 expectation and for proper equipment and operator action."
23 What does that mean?
How do you review 24 an op'erational transient for consistency with design 25 expectation?
1
1 Womack 783 2
A You look at what happened.
You ask a designer 3
to look at what happened and see if he detects in 4
the course of the information that he has on the 5
transient anything which he finds unexpected or 6
indesirable from the standpoint of the way he expected 7
the equipment and~the operator to perform in response 8
to the conditions that existed or were presented.
9 Q
What was there in the Three Mile Island 10 accident that suggested this as a useful, action?
11 A
Well, I think the operator's termination of 12 the high pressure injection system among other things.
g3U
^ 13 Q
What other things?
14 A
Another thing would have ebeen the operator's e
15 not closing the block valve.
16 Q
What other things?
17 A
Well, I don't know that I can come up with a 18 list off the top of my head.
Those two stand out in
[
19 my mind.
20 Q
What about the rise in pressurizer level 21 while reactor coolant system pressure fell?
(
22 (Continued on next page.)
23 24 25
i 1
Womack 784
/~N U
from what standpoint?
2 A
As far as l
3 Q
Is that someth' ag that could usefully 4
have been reviewed for consistency with design
(
5 expectation prior to the accident?
6 A
I don't know.
I think that the experts in 7
that area _would have said that was consistent with 8
their expectation.
9 Q
On the other hand in terms of closing 10 the loop,that is not an expectation t h'a t had been 11 well communicated to people involved in training 12 and operations isn't that true?
(_)
13 A
I don't know.
14 Q
You have no knowledge that it was effectively 15 communicated, do you?
4 16 A
I don't know to what degree it was ccmmunicated 17 by the people in operations.
18 Q
Has anybody told you that it was 19 communicated?
20 A
Anybody in what context?
21 Q
Has anybody at B&W ever told you that in
.{
22 the course of training operators B&W explained to 23 operators before the Three Mile Island accident that 24 they wo'uld'see transients in which the pressurizer 25 water level rose while reactor coolant system pressure
1 Womack 785 b)
%J 2
fell?
3 A
I don't believe that anyone at B&W has ever 4
told me that, no.
(
5 Q
Item 4 in your list of actions needed based 6
on lessons from TMI-2 is headed, " Improve the 7
information interface between the plant and the plant 8
operating staff."
9 What does that jargon, interface, mean?
10 A
I suppose I was trying to avoid the use of the 11 words human factors engineering, but I think they 12 are probably interchangeable.
Did I avoid it O
13 elsewhere?
Let me answer your question" seriously.
14 Q
Thanks.
.15 A
The information interface between plant and 16 the plant operating staff is pretty much exactly 17 wha t is described by those words, everything that 18 flows from the plant to the staff which operates it 19 and presumably what the operating staff doAs by its 20 command and maintenance functions back to the plant.
21 Q
So wher fou say between the plant, the 22 plant is the inanimate --
23 A
Equipment, yes.
24 Q'
-- equipment and the plant operating 25 staff are the human beings that are supposed to know
1 Womack 786 ry 2
what's happening with the equipment and run it 3
correctly?
4 A
Yes.
5 Q
In the first item that you list under.4 6
you say, " Indications to the operator should be based 7
on best evidence 5f function (e.g. stem position 0
indication on critical valves rather than demand 9
signal) and backed up by diverse confirmatory trulybritical, 10 indication where'the function is as 11 in the case of primary system boundary valves and 12 safety system functions."
13 What you have said in those fivt lines 14 would apply to evidence of the position of the pilot 15 operator relief valve; right?
16 A
The pilot operator relief valve would be subject 17 to that recommendation, yes.
I think it nie e t s it.
IO Q
You said that the indications to the 19 operator should be based on the best evidence of 20
- function, e.g.
stem position indication.
21
" Stem" is what?
22 A
The pilot operated relief valve doesn't have a 23 i
stem, it doesn't have mechanical connection between 24 that portion of the valve, the disk, which opens and 25 closes the port which allows the valve to relieve an i
. ~. -
= -
l 1
Womack 787 2
outside pressure boundary so there is no sten in 3
that particular. case.
The best evidence of function i
was provided which was a demand i
4 was probably what
(
5 signal in this particular case.
6 Q
Isn't it a fact that B&W has recommended j
7 that its operating utilities install better evidence 8
of function of the PORV than the demand signal?
9 A
I think we have offered to our utility customers 10 additional diverse confirmatory indicat1on to --
4 11 additional to that which was already there in the 12 form of sonic sensors.
Ov 13 Q
sonic sensors would detect noise of 14 rushing steam or water?
15 A
Yes, in the case if the valve was open and so j
16 it would supplement the thermocouples.
I 17 Q
And if the valve was closed it would 18 show little or no noise, right?
19 A
That's the intended function of the sonic 20 sensors, yes.
21 Q
So it would sense both opened and closed?
22 A
Right.
23 Q
What is a demand signal?
)
24 A
A demand signal is the command to the valve 25 from the electrical control system in the case of a e
,v-.
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I Womack 788
( ))
2 motor operated or pilot operated valve which tells 3
the motor or pilot what to do, if its electromagnetic
'4 it tells t h'e electromagnet to open, energize or not
(
5 to energize.
6 Q
That is the signal that w a.s connected into 7
the control room at Three Mile Island Unit 2 on 8
March 28, 1979, right?
9 A
As I understand it, that's correct.
That was 10 the signal from the PORV which was displayed on the 11 control panel as I understand it.
12 Q
And at the time of the accident you
%)
13 believe that was the best evidence of valve function?
14 A
Well, with respect to what this says, stem i
15 position is not readily available for pilot operated 16 valves, so I think that's right.
17 Q
The next, skipping down, you have got as 18 the third item, " System level design attention should i
19 be given to the manner in which the information 20 given to the operator is presented to him, the 21 simplicity with which it can be understood, and the 22 potential for information overload is a rapidly 23 evolving sequence of operations."
(i 24 A
I'think that preposition "in" a rapidly 25 evolving sequence of operations.
1 I
Womack 789 l
2 Q
Okay.
3 Are you saying that there is a need to 4
develop a better system for giving information to 5
operators?
6 A
I was saying that the designer might have 7
something further'to offer in this regard, in this 8
area which hus generally been m:naged to the particular 9
desires of the utility.
10 Q
And the architect engineers.--
11 A
And the architect engineer in the way that the 12 co..rol panels are designed.
13 Q
Since the accident and as
- a. result of I
14 the Three Mile Island accident, has B&W been taking 15 steps to involve itself more in the presentation of l
16 information in the control rcom?
4 17 A
We offered help to our customers in-this area.
18 The question of control room reviews is very much 19 with the NRC and the utilities at this time.
20 MR. SELTZER:
Off the record.
21 (Discussion off the record.)
22 Q
Turning to the next page, you have listed 23 as item 5 an action to be taken as a result of the 24 TMI-2 experience, " Designers and licensees should have 25 an agressive program for recognizing and correcting y---v e
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2 unacceptable performance by equipment or in operations."
3 You then list five suggested actions.
4 The fifth is, "PORV and code safety valve reliability 5
should be. improved."
6 That's a recommendation that you were making 7
in June of 1979; is that right?
8 A
Yes.
9 Q
Do you know what, if anything, has been 10 done to improve the reliability of relie,f valves 11 in the primary system?
12 A
Well, I think most valve manufacturers have O,
13 become more conscious of the importance.of high 14 reliability performance valves.
I see some evidence 15 of that and I think that the EPRI test program is 16 an example of an industry initiative which has that 17 as its ultimate goal.
18 Q
You said that the valve manufacturers 19 have been taking steps to improve the reliability of 20 relief valves; is that right?
21 A
I think I said that they -- I believe they 22 have become more sensitive to it.
I don't know the 23 specific steps that they have taken.
(
24 Q
I take it you would hope that it would-25 follow from greater awarnness of problem of reliability
1 Womack 792 2
were substantially made prior to this particular 3
accident looking forward to future plants.
I don't 4
believe that there have been any significant changes
(
5 to valve specifications in those plants which we are 6
presently completing to the operating license stage.
7 For the most part the pilot operated relief valves 8
for those plants have been delivered or have already 9
been manufactured.
We have looked at alternative ways 10 to perform pilot relief f unction using 'other than 11 relief valves.
I think we have got an alternative that 12 I believe Consumers Power Company requested.
O-13 Q
What is that?
14 A
I believe it's -- I think it's a stem type of 15 valve.
I will have to -- I will have to plead lack 16 of in depth knowledge here.
17 Q
You proposed that "The ICS/FMEA should be 18 extended to the auxiliary feedwater syste the pressure 19 control systems for primary and secondary side and 20 the inventory control system including the ECCS 21 systems."
22 What is ICS/FMEA?
23 A
That's the integrated control system failure modes (m
(_)
24 and effects analysis.
It is a systematic study of 25 the kinds of failures which can occur within the
_,. ~. _ _.. _,
1 Womack 793 O
2 boundaries of the integrated control system and their 3
effects.
It also included in this particular case 4
an examination of actual plant operating experience
(
5 relating to such failures.
6 Q
You said that that analysis should be 7
extended to the auxiliary feedwater system and several 8
other systems.
9 Is this failure analysis something that 10 had been going on before the Three Mile. Island accident?
11 A
No.
12 Q
When was O
ISC/FMEAinitiated}
13 A
I don't know the precise date.
14 Q
Sometime after the accident, before June 7,
15 19797 16 A
Apparently.
17 Q
And you are proposing that it should be 18 extended to studying auxiliary feedwater pressure 19 control systems and inventory control systems?
20 A
That's right.
That's what this proposes.
21 Q
Was the analysis extended?
22 A
The tools of that analysis were extended to i
23 those systems, yes.
The auxiliary feedwater system 24 was the subject of reliability studies.
The other' 25 systems have been studied from the standpoint of what
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1 Womack 794 OUI 2
has been called a mini probabilistic risk study at 3
the plant level by the licensees.
4 Q
Ycur sixth proposal of action to be taken
(
5 based on lessons learned from Three Mile Island's 6
accident was, "The design and information for handling 7
and understanding of all reactor coolant systems leaks 8
should be upgraded."
9 Under that you proposed that "The operator 10 should be provided with continuous readlng information 11 on the margin desaturation in his primary system."
12 A
I believe that's a typographical error, n#
' 13 Q
What should it say?
14 A
I think that was -- must have been a transcription 15 from dictation.
.I t should have said " margin to 16 saturation."
17 Q
In other words, he should know how close 18 he is to saturating the primary system?
19 A
Well, he has that information available to him.
20 This suggests additional equipment to give him 21 additional continuous read out.
22 Q
Is that now provided by the Tsat meter?
23 A
We offer it to our customers.
It's their
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24 privilege to determine whether or not they want it.
l 25 Q
Have some of your plants taken it?
1 Womack 795 2
A Yes, some have provided it from another source.
3 Q
Do all plants now have some kind of 4
continuous read out of saturation conditions?
(/
5 A
I don't know for sure.
6 Q
Do you know of any that does not have it?
7 A
I don't know for sure.
I don't know of any 8
that doesn't.
9 Q
When documents talk about maintainint.' 50 10 degrees subcooling, does that refer to 'th e margin to 11 saturation?
12 A
Yes, it does.
13 Q
Does it mean that a 50 degr.ee rise in 14 temperature would result in saturation?
15 A
Yes, it does, at the particular pressure.
If 16 the pressure is unchanged it means that a 50 degrees 17 rise in temperature would bring the system to the 18 boiling condition.
19 Q
You proposed in the fourth item in 20 number six, " Faster running analytical methods for 21 the evalua tio n for small break phenomena are needed to 22 assure the full range of investigation of the 23 sensitivity of this class of accidents can be (n
24 completed."
25 What does that mean?
I womack 796 pC 2'
A The analytical methods which are used for loss 3
of coolant analyses are among the most sophisticated 4
methods used in the nuclear industry, they require
(.
5 very heavy consumption of computer time because they 6
solve many, many, many equations and for small break 7
phenomena where the periods of simulated accident time 8
are long, an analysis of a small break accident can
]
9 take hours literally of the central processing unit E
10 time on the largest computers.
11 Q
That's fantastic.
12 A
With the techniques that are presently available.
U 13 Q
Is that because the program requires the 14 computer to check out every branch of an event tree?
15 A
No.
It's because the programs and analytical 16
-methods that are used were generally developed for 17 evaluating the larger loss of coolant accident and 18 they consider pressure and dynamic effects which are 19 appropriate to that accident and time steps which were 20 appropriate to that accident and if you are familiar 21 with this area, you know that the large loss of 22 coolant accident,particularly a large pipe break, tends 23 to -- the exciting part tends to be over in, at most, 24 a few minutes.
25 In a small break loss of coolant accident you
1 Womack 797 bV 2
may be interested in system performance for many, many 3
minutes and therefore the time steps and the number 4
of occasions solved for the kinds of approved 5
analytical methods for this purpose are not necessarily 6
the most efficient which could be devised for small 7
break analysis.
8 Q
So you were proposing coming up with more 9
efficient equations for analyzing small breaks?
10 A
That's correct.
It's not a questi,un of not 11 being able to analyze small breaks, it's a question 12 of the efficiency for which -- with which it can be 7-N.)
13 done.
14 Q
And the more quickly it can be done the 15 more small break phenomena B&W would have time to 16 analyze?
17 A
The more easily you can answer hypothetical 18 questions that a customer might raise for particular 19 purposes that he may have.
20 Q
Your last suggestion under item six is, 21 "For the long term, an alternate independent means
{
22 to depressurize the reactor primary system smoothly 23 and reliably in the event of a small reactor vessel 24 break to the point at which the decay heat removal /
25 low pressure injection system can be operated needs
1 Womack 798 N]_)
/
2 to be added to PWR designs."
3 Why is that an action that you were 4
proposing based on the Three Mile Island accident?
5 A
I am not sure that that recommendation sprang 6
exclusively from the Three Mile Island accident nor 7
am I sure today that that's really something that I 8
feel strongly about.
I am not sure how strongly I 9
felt about it at that particular point in time.
10 It seems to me that continued higk pressure 11 cooling with the kind of diversity that the B&W system 12 has is a very reasonable means to assure core cooling.
~
13 But certainly this is something that has been discussed 14 and I mentioned at this particular time as a suggestion.
15 Q
Item eight has you proposing "An active 16 program to reduce system upset transients should be 17 undertaken."
18 Do you see the action that you propose 19 that begins "Means to improve"?
Do you see that?
20 A
Yes.
21 Q
You say that "Means to improve virtual
(
22 system thermal enertia should be considered to allow 23 the system to be more tolerant of secondary side s
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24 upsets."
25 What do you mean " virtual system"?
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. ell, the once through steam generator is W
3 responsive to the way you supply feedwater to it, it is j
4 different in that respect to the recirculating 5
generator which contains within its volume a large 1
6 pot of water and so it's immediate response to 7
feedwater changes may be slightly.-- may have more 8
enertia to it or may be slower acting, certain kinds I
9 of upsets.
i s
10 The primary system never needs to'.know that if I
11 the feedwater supply is reliable and well controlled 12 in the face of feedwater upsets and means which can O
13 be used to make that feedwater supply reliable and 14 well controlled are what I had in mind when I wrote 15 that sentence.
16 Q
Your last proposal under item eight is l
17 "A rigid and thorough going auxiliary feedwater system 2
i 18 performance standard should be sent through B&W. BOP 19 Criteria and imposed without exception due to the 20 importance of this system."
21 BOP Criteria is balance of plant criteria; 22 is that right?
23 A
Right.
24 Q
Prior to the Three Mile Island accident 25 did Babcock have balarca of plant criteria?
r 1
Womack 800 2
A Yes, for some contracts?-
3 Q
Did you have balance of plant criteria 4
for TMI-27 5
A There certainly was communication to the 6
utility and his other subcontractors about balance of 7
plant requirements and needs, but I don't believe 8
there was a formal document called balance of plant 9
criteria for TMI-2.
10 Q
Do you know whether Babcock.has developed 11 rigid auxiliary feedwatar system performance criteria 12 since the Three Mile Island accident?
rD) 13 A
We have, at the request of one of.our customers, 14 helped him develop an auxiliary feedwater system 15 upgrade requirement specification.
This is a back fit 16 on an operating plant and not exactly what was 17 intended by this.
We certainly have done work in 18 that area to help some of our customers.
19 Q
Has B&W worked with Metropolitan Edison 20 on back fitting THI-1 in the area of auxiliary 21 feedwater system performance?
22 A
Yes, I,believe we have.
23 Q
Your last action item in response to D)
(
24 lessons learned from TMI-2 is, "The feedback of new 25 engineering knowledge to the operational design basis
-4
1 Womack 801
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2 for operating plants should be rapid and should take 3
the same path as the feedback of knowledge gained 4
from operational experience."
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5 I don't understand what you are contrasting.
6 You have operational experience on the one hand and 7
what is on the other?
8 A
New engineering knowledge and in this case I g
was thinking of the kind of information which comes 10 out of research and development programs, that may be 11 conducted for example at government laboratories.
12 The kind of information, and I think of examples'in 13 the last two years, I think-that there was an NRC 14 bulletin regarding the results of heat transfer 15 performance testing done at the Oak Ridge National 16 Laboratory pertaining to the heat transfer between 17 fuel and clad and the claddings capability to withstand 18 the stress in loss of coolant accident.
That's the 19 kind of new engineering information I had in mind.
20 Q
When you say it should take the same path 21 as the feedback or knowledge gained from operational k.
22 experience, what path were you referring to?
23 A
Well, I don't think the path -- I think the
(
24 path was intended to be created.
25 Q
I see.
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womack 802 i
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think in an earlier 'recymmendation I had
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4 I. don't know whe ther~ I '-- whe ther. I suggesteda(
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feeding bac' operating experience, one can also
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communications channels.
9 Q
Would an example.of operational'* feedback c
s 10 be what should have been done following.'the ~ September o
11 1977 Davis'-Besse transient?
i 12 MR. WIst:
I object to the form of the w
)
13 question.
14 A
An example of operational feedback would be 15 feedback of operator -- or designers' evaluations or '
j 16 ope ra tor s '-e valua ti ons on any transient.
j m.
17 Q
It's a fact, isn't it, that there was i
4 18 no t f as t enough feedback from the September 1977 19 Davis-Besse transient into operator recommendations?
[l i
20 A
I don't know what you mean by fast enough.
l 21 Q
B&W didn't get a suggestion out to its
~
L 22 operators fast enough based on the ope ra tional 23 experience in September of 1977 at Davis-Besse; isn't 24 that right?
25 MR. WISE:
I object to that.
The witness' i
I womack 803
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2 question as to what you mean,-you didn't answer.
3 Q
As fast as you believe is prudent.
4 A
In retrospect, certainly I would like to see 5
operational information be distributed as rapidly as 6
possible.
That may have been as rapidly as that 7
information could reasonably under the circumstan;es
~
8 have been distributed in the context of the arrangements 9
that existed then.
e 10 Q
Do you believe based on everything that 11 you know that the information and lessons from the 12 Davis-Besse September 1977 transients
[~~ h wyre distributed
%)
13 to B&W customers as fast as it could have been?
14 A
If the question is was that information distributed 15 as fast as it could have been, I am sure the answer to 16 that would have to be no.
17 If someone had undertaken to assess'the sources 18 of that information through the information distributing 19 channels that existed in the industry at the time, I 20 am sure they could have gotten it pretty quickly, i
21 Q
B&W could have sent it out pretty quickly, 22 couldn't it?
23 MR. WISE:
Sent what?
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24 MR. SELTZER:
Information to operators 25 about the S ep tember 1977 transient at Davis-Besse.
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I suphhis e anything is possible.
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MR. 32LTZER:
Shall we resume at 9:30
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THE WITNESS: 7 Fine.-
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EDGAR ALLEN WOMACK, JR.
11 l
Subscribed and sworn to before me i
12 I
day of 1981.
this 13 4
14 15 16 1
17 18 19 i
20 1.
21 22 23 24 v
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805 e
v CERTIFICATE 2
STATE OF NEW YORK
)
3
- ss.:
COUNTY OF NEW YORK
)
4
(
I, CHARLES SHAPIRo a Notary Public of the State of New York, do hereby certify that the continued deposition of EDGAR ALLEN WoMACK, JR.
was taken before Jauan 26, 1981 me on consisting 643 804 of pages through I further certify that the witness had been previously sworn and that the within O
i V
transcript is a true record of said testimony; 13 That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any sel.
18 IN WITNESS WHEREOF, I have he$eunto set my 19 gy hand thi's {2 da:, of FEGQUAAV
,1981.
20 21 22 23 (3
CHARLES SHAPIRo, C.
.R.
)
24 25
January 26, 1981 806 I ND E X s
cf WITNESS PAGE
~ Edgar. Allen Womack, Jr.
(resumed) 645 v.
Y :-
c, E XH I B I TS y
'.. GPU EXHIBIT NO.
FOR IDENT.
1 7- -
21 Memorandum from Al Womack to 671 C.W.
Tally dated July 19, 1979, j
subject, PORV Reliability Study 22 Memorandum from Rosztoczy dated
- 693, April 15, 1979, subject, Comments l
on " Generic Assessment of Feedwater Transients in Reactors
(
Designed by Babcock & Wilcox,"
with a copy to E.A.
Womack' -
'23 Memorandum from D.H.
Roy to 712 Engineering Department Section Managers, subject, Top 10 Lessons Learned - TMI-2, dated June 14, 1979 4
24 Document dated June 18, 1979-721 entitled " Operating Plant Design
-Review Board, Task D e s c rip tio n "
25 Memorandum by E.A.
Womack dated 733 i
June 18, 1979, entitled " Response i -
to TMI-2 Concerns, Task Description, Verification of As-Built Input" 26 Memo dated March 12, 1980 from 742
(--
D.G.
Newton to Distribution, with a copy to E.A.
Womack, subject, Review Draft Proposal
~
2,7 Letter from Dresser Industries 744 l
l dated April 1,
1980 to General Public Utilities Corp. with a copy to Babcock & Wilcox in L-nchburg
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January 26, 1981 807 I
O E X H I B I T S
. GPU EXHIBIT NO.
(continued)
FOR IDENT.
l i
1 28 B&W spe,cification for the Three 751 i
.c Mile Island Unit 2 pilot operated relief valve dated j
s January 7, 1970 i
t s'.
29 Document entitled " Events that
, 754 Y
Initiate PORV Operation" fron
.the files of E.A.
Womack 30 Memo dated May 15, 1979 fron 766 E.A.
Womack to J.D.
- Carlton, subject, Control Failure Position for Pilot Operated Relief Electrical Circuitry
(
31 Memo dated June 7,
1979, entitled 770
" Actions Needed Based on Lessons from TMI-2" J
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