ML20072H841
| ML20072H841 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/27/1981 |
| From: | Womack E BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-06, TASK-11, TASK-6, TASK-GB NUDOCS 8306290771 | |
| Download: ML20072H841 (142) | |
Text
. _.
i 808 A jr 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, apd J. RAY MCDERMOTT & CO., INC., ~., :
Defendants. :
_ _ _ _ _ _ _ _x Continued deposition of THE BABCOCK & WILCOX COMPANY, by EDGAR ALLEN WOMACK, JR., taken by Plaintiffs pursuant to notice and l adjournment, at the offices.of Kaye,
, Scholer, Fierman, Hays & Handler, Esqs.
f 425 Park Avenue, New York, New York, on f ,
Tuesday, January 27, 1981 at 9:40 a.m.,
s
' l) 1 DOYLE REPORTING. INC.
CERTIFIED STENOTYPE REPORTERS 8306290771 810127 389 LEXINGTON AVENUE PDR ADOCK 05000289 NEW You. N.Y. 1o017 T PDR TE t.E P Ho N E 212 - 867-8220
1 809 I
2 before Charles Shapiro, a Certified 3 Shorthand Reporter and Notary Public 4
within and for the State of New York.
5 6 * *
- 7 .
- l 8 Appear anc e s : .
i 9
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 10 425 Park Avenue New York, New York .,
11 \
s BY: RICHARD C. SELTZER, ESQ.
12
-and-Q\._/ ., 13 ANDREW MACDONALD, ESO.,
of Counsel 14 >
15 DAVIS, POLK & WARDWELL, ESQS.
Attorneys for Defendants 16 One Chase Manhattan Plaza New York, New York 17 ,
BY: ROBERT F. WISE, ESQ.
18
-and-RODMAN W. BENEDICT, ESQ., -
19 of Counsel i
i 20 21 Also Present:
22 DAVID TAYLOR 1
23 24 * *
- 25 i
e L
1 810
('
v)
~
2 EDGAR ALL E N WOMAC K , J R . ,
3 having been previously duly sworn, resumed, 4 was examined and testified further as
( 5 follows:
6 EXAMINATION (Continued) 7 BY MR. SELTZER:
8 Q Dr. Womack, you realize you continue ,
9 to be under oath?
10 A Yes. (
11 Q Dr. Womack, I think that either there 12 was an error in transcription or I misspoke in the
)
13 second day of your deposition.
14 I would like to show you page 261 and 15 262 where we were discussing the ability of
- 16 reactor coolant pumps to continue to operate with 17 a very high void fraction. You were telling me 18 that there were experts on the engineer staff at
)
19 B&W who knew that, and I said, "And th[re were 4
20 such experts on -" I believe I said or I meant to g 21 say March 28, 1979, the day of the accident.
L.
22 Is it a fact that there were engineers 23 at B&W on March 28, 1979 who knew that under O)
\/ 24 emergency conditions the reactor coolant punps.
25 can continue to operate with a very high void
-, ,- w -- wr--- ,. y --,-rv e-.e--i + ----* - . -e-,- w , -t-m- -- --r w- - -- * -v * - = - -
1 Womack 811
/~T I J
%d 2 fraction?
3 A Let me just review that.
4 Your question is were there such i
( 5 experts on March 28, 1979, and my answer would be
- 6. yes.
7 Q There was one other point that I wanted 8 to clarify.
9 At Three Mile Island during the 10 March 28th accident the high pressure injection 11 pumps actuated early in the transient, right?
12 A That's my understanding.
t
13 And they were substantially throttled Q
l 14 back but not completely shut off by the control 15 room operators; is that right?
d 16 A That's not entirely clear. There has been, 17 to my understanding, a degree of speculation on 18 whether they were completely shut off or --
excuse i
f 10 me -- whether the flow war completely s5ut off or 1
20 whether it was allowed to continue at a very low 21 rate, so I really can't define that for you.
22 Q In GPU Exhibit 7, which is the final 23 report of the Technical Review Committee that you
((~w) 24 served on, at page 4-9 there is a heading just i 25 above the middle of the page which is " Plant i
1 Womack 812
(~)
2 Status at 150 Minutes."
3 would you take a look at the second 4 paragraph that appears under that. (Handing I k 5 document to the witness.)
6 Q That paragraph says " Reactor coolant 7 makeup Pump A was running with high pressure 8- injection valves throttled. This high pressure 9 injection condition has existed essentially since 10 two minutes into the transient.". >
11 At the time that the Technical Review 12 Committee wrote that, does that indicate that
~/ 13 their understanding was that the high pressure 14 injection was throttled but not completely shut off?
15 A As before, it's difficult for me to, or 16 impossible,for me to testify as to the understanding 17 of the Committee or all of its members. I will 18 be glad to give my understanding of the word
~
19 " throttled."
20 g okay.
21 A My understanding of the word " throttled" is 22 that it can mean a reduction in flow by the use 23 of the valve which could be anywhere from zero to 24 something less than full flow. Throttled could mean
[s..>\
25 entirely -- the flow entirely cut off, to me.
1 Womack 813 2 Q' So that paragraph doesn't clarify the 3 situation or refresh your recollection that the 4 valve remained somewhat opened?
( 5 A No, and it's not my testimony that'the 6 valve did not remain somewhat opened. I simply 7 don't'think we know exactly where the valve wds.
8 We have the testimony of the response of the ,
9 system and we have, as I understand it, the 10 operator had debriefed, he mentioned,himself that 11 he had cut back on the valve (indicating), I guess 12 while he had been debriefed.
(~T .
~
13 Q Even if the operators had closed the 14 valves completely so that there was no high 15 pressure injection into the system, if the primary 16 coolant pumps had remained on up through the point 17 at which the block valve was closed, is it your 18 understanding that there would have continued to 19 be a sufficient void fraction in the reactor to 20 continue to cool the core effectively?
21 A I simply don't know.
22 Q Have you ever seen any analysis of 23 that?
24 A No.
25 Q It wouldn't be difficult to perform
_ , . ~ . . _ _ _ _ - _ _ _ . _ . ~ . _ _ . . _ _ . . - _ _ - - - _ _
1 Womack 814
(^)%
\.
2 the analysis, would it?
3 A It would not be difficult to perform an 4 analysis; however, the assumptions and methods C. 5 in that analysis might be sub]ect to question.
6 A key parameter would be the rate of Q
7 flow of coolant through the open PORV, right?
8 A That would be among the key parameters, '
9 Q What would you have to know to determine 10 that flow? -
11 A The flow of coolant through the PORV? You 12 would have to know the quality of the coolant at 13 the entrance to the PORV, the thermodynamic 14 con'ditions, pressure and temperature and the 15 discharge coefficient applicable to th.e PORV.
16 Q From the studies that have been done 17 since the accident there is empirical data to show 18 what the flow was through the valve during the 19 accident, isn't there?
20 A I am not sure there are empirical data.
21 You haven't seen it or you don't recall Q
22 seeing it?
23 A I don't recall empirical data.
O i ,) 24 g What kind of data have you seen?
25 A These data are -- these estimates, as I
- p. ag +w-g ,,--,-w - , . - - - - e ,my,-.an y. -mg ,-,y +,_ , -p---m.,- --m----~,,----g- - - -p-----
l 1 Womack 815
~
(~
L /.
2 understand it, have been made based on empirical 3 work done prior to the accident and generalized to 4 the particular case of the pilot operated relief l- 5 valve at Three Mile Island.
6 Q Who would be the person most knowledgeable 7 at B&W about rate at which coolant would be lost 8 through a s'all m break? .
9 A I would confer with Mr. Dunn or one of his 10 senior staff. *.
11 MR..-SELTZER: I would like to mark for 12 identification as GPU Exhibit 32 a report 13 entitled " Safety Aspects of the Mulheim-Karlich 14 Plant in View of the Three Mile Island-2 15 Accident," May 1979.
16 (Report entitled " Safety Aspects of 17 the Mulheim-Karlich Plant in View of the Three .
18 Mile Island-2 Accident," dated May 1979, was i 19 marked GPU Exhibit 32 for identif[ cation, as .
i- 20 of this date.)
l l 21 Q Is GPU Exhibit 32 a copy of a document 22 which you received in the regular course of business t
23 and have previously reviewed?
t I[} V 24 A It appears to be a copy of a document which l
25 I received in the regular course of business and i
1 Womack 816 O
N '
2 have reviewed in part.
3 Q Did you review any parts of it prior 4 to its final dissemination?
5 A I don't recall whether I did or not.
J 6 Who prepared GPU Exhibit 327 Q
7 A A team of people, most of whom were or are 8 members of our internal project -- management internal-9 project engineering group, and I believe working 10 directly with engineers at the company BBR.
11 What engineers at B&W worked on it?
Q 12 I am not sure I can identify all the names.
gg e <
A~
13 Mr. Bohart was part of the team, I believe. Also 14 I believe Mr. Jenkins was a part of the team.
15 Q Do you know who headed it f,or B&W?
16 A I think that Mr. Bohart was the principal 17 team leader for B&W. ~
18 Q What is Bohart's area of expertise?
19 A Bohart is'a reactor systems engineer and 20 engineering manager.
21 Q What is a reactor systems engineer?
22 A Well, he would be concerned with design and 23 operation of systems such as makeup systems and O
k ,l-s 24 reactor coolant systems and the like.
25 Q For what purpose were you reviewing
. . . ____. __ . . . . _ _ _ _ _ _ . _ , _ _ , - . . ~ . ._. _ , _ . _ _ , _ _ . _ , _
1 Womack 817 O
U 2 GPU Exhibit 327 3- A At what time?
4 How many times have you reviewed it?
Q
'S A I can't --
I can't really say how many times 6 I reviewed it, but the thrust of my question was 7 are you -- you asked me a moment ago did I review 8 it before issue, and let me answer that if I did .
9 review it before issue, it was because it was 10 prepared by people who were working w'ithin the 11 plant design section. Mr. Bohart was a member of 12 my staff.
13 Yes.
Q 14 A And so he may have asked me to look at parts 15 of it either before or after its issue. .
16 was that what you were looking for?
17 Why were you looking at it?-
Q 18 A Well, because I had a general interest in 19 the kinds of things my section produced and of 20 course we were heavily involved at this time in 21 all aspects of the TMI-2 accident.
22 You also had some personal involvement Q
23 in the MK Plant, didn't you?
24 A Yes, I had additionally I had the background w / --
25 of some involvement with the Mulheim-Kaerlich Plant.
1 Womack 818
! C/
4 2 Q If you had seen things in the report, 3 GPU Exhibit 32,which you believed were inaccurate, 4 would you have let the authors know that you thought
( 5 they had made a mistake?
6 A I certainly hope so.
7 Q What particular portions of the report 8 did you read? ,
9 A Well, let me look at it. I think I have at 10 one time or another looked at genera 1ly at the E
11 description of the accident area, at the comparison
, 12 of TMI-2 and MK and some of the appe dancies, perhaps
( 13 at other parts as well.
14 Q Did the people who were preparing the 15 report consult you for information that they then 16 incorporated in the report?
17 A I don't believe that there was any significant 18 consultation on my part with -- relative to this 19 report, certainly relative to the contents of this 20 report prior to its release. I was particularly 21 busy at the time with domestic concerns related e
22 to the accident. This report was --
I don't recall 23 what the date was, but it was published very, very b)
(, 24 quickly after the accident and I don't think I r
25 had much consultation, if any, prior to its
1 Womack 819 O 2 Publication.
3 Q was the report accurate, to the best of 4 your recollection?
( 5 MR. WISE: As of the time that it was 6 written or as of what he knows today?
7 Q When you read it.
8 A I think that there are some inaccuracies'in g the report. One that I' remember having spotted in 10 -particular I think is somewhere in this report 11 says that -- mentions a certain number of PORV failures 12 which I believe probably reflected the best knowledge
%/ 13 that these people had at the time, but it -- I think 14 we subsequently learned that there were a different 15 number of failures.
16 Q There were more, right?
~
17 A There were more than are noted in,here, and 18 I believe there are probably other points in
^
l 19 which the report may have incomplete information
- 20 or may have opinions based on incomplete information 21 or opinions based on specific ideas of the people 22 who wrote it which have not been thoroughly reviewed .
23 within B&W for a rango of consultation.
r Are there any opinions in here that you l
l
[J)
\~
24 Q 25 believed when you read it were wrong?
1 Womack 820
~
J("N 2 MR. WISE: First of all, he said he only 3 read part of it.
4 MR. SELTZER: Yes.
]( 5 MR. WISE: He would only be able to 6 . testify to that portion that he read.
7 MR. SELTZER: Fine.
8 A My recollection is that there are some thoughts 9 expressed in here which I would question. I think, 10 again, it's been a while since I have looked at 11 this, but I think that some of the judgments made 12 by the authors with regard to the kinds of failures 13 and those failures in the context of the 14 German licensing code KTA-3501 probably deserve 15 a further review and there may be other examples.
16 As I said, it's been a while since I have read it.
~
17 If you like, I will be happy to try to l- ~
18 read it and pick the specifics out, but it's going I ..
19 to take me some t'im e .
20 Q Have you ever advised anybody in B&W 21 in writing that you believe there were portions
/
l
(
22 of this that deserved further consideration?
23 A I don't remember whether I have or not. I
[ 24 proba'bly have not but I don't remember whether I
%)
25 have or not.
i j.
1 Womack 821 f'O 2 Q Do you recall specifically whether you 3 advised anyone at B&W orally that you believe there 4 were portions of this report that deserved further C. 5 review?
6 A Again my recollection is not good enough to 7 give you a positive yes or no on that.
8 g okay.
9 ( Section 4, which you said you believed 10 you did read, is called " comparison of TMI-2 and 11 MK."
s 12 Would you turn to page 4.2-4.
(. I!! MR. BENEDICT: What is the microfilm 1 .
14 number?
15 THE WITNESS: Yes, I am having trouble 16 finding it.
i 17 MR. SELTZER: E-5671.
- 18 MR. WISE: Off the record.
19 (Discussion off the record.
20 MR. SELTZER: I would like to mark for 21 identification as GPU Exhibit 33, a memo from
('
22 G. E. Rambo to Messrs. Womack and Taylor, 23 subject: Proposed B&W Positions Regarding i 24 High Point Vents, Water Level Measurements, 25 and void Fraction Monitoring, December 20, 1979.
1 Womack 822 n
2 (Memorandum from G. E. Rambo to 3 Messrs. Womack and Taylor, subject: Proposed 4 B&W Positions Regarding High Point Vents, l( 5 Water Level Measurements, and Void Fraction 6 Monitoring, December 20, 1979, marked GPU 7 Exhibit 33 for identification, as of this 8 date.)
9 Q Is GPU Exhibit 33 a copy of a memorandum 10 which you received in the regular course of business 11 in or about late December 19797 12 A Yes, it does appear to be.
(3
\- 13 Q Just for the titillation of people who 14 might want to understand this, what are hot legs?
15 A The expression " hot leg" is used in reactor 16 system jargon to refer to those poritions of the 17 primary piping system which carry the heated water, 18 coolant. water exiting the core to the heat exchanger 19 or the steam generator.
20 Q For those who view this thing more 21 orally, what would your definition be of candy cane?
22 A In the B&W NSS configuration, the hot leg 23 piping is connected to the reactor vessel which A) i v
24 holds' the core,.and after coming out horizontally for 25 a short run, makes a 90 degree turn and has a
1 Womack . 823 l}
C' . ,
2 vertical run to the top of the steam generator 3 and slightly above. At that elevation the piping 4 makes a 180 degree turn in order to carry the
( 5 reactor coolant into the upper plenum of the 6 once-through system generator. This configuration 7 with a long vertical rising leg and 180 degree bend 8 at the top resembles a candy cane and it's sometimes 9 called that.
10 Q Are hot legs and candy ca'nes synonymous?
11 A In the B&W system pretty much so.
73 12 Q I think it has to follow pretty logically e )
, 's.J 13 that if the hot leg is taking water into the steam 14 generator, the cold leg must be taking water out of 15 the steam generator?
16 A Yes. The cold leg is that portion of the 17 piping system which leads the water from the 18 primary -- water from the cold part of the steam 19 generator back to the inlet of the core --
the inlet 20 of the reactor vessel.
21 Q How long does it take for water to 22 move through one complete cycle?
23 A I don't know that number exactly. It takes
((~)N 24 a num'ber of seconds. If you are speaking. about the 25 condition in which the plant is running with the
1 Womack 824 2 reactor, main reactor coolant pumps operating, 3 I don't know the number exactly.
4 Q Is it less than a minute?
k 5 A My recollection is that it's a little bit 6 less than a minute, but I would like to not have 7 you use that number for purposes of designer safety 8 calculations before I check it.
9 Q will you look at the page numbered '09 10 6 in the right-hand margin, please. ,
11 Primary system water is the same as
- 12- reactor coolant system water, right?
13 A Yes.
14 Q The heading on this page is " Proposed 15 B&W Positions Regarding Primary System Water Level 16 Measuremehts."
l-l 17 Is what is set forth here a proposal 18 for adding instrumentation to the B&W d sign in 19 order to measure the level of primary system or
[
20 resetor coolant system water?
21 A Yes.
22 Q This is equipment which was not in B&W 23 plants at the time of the Three Mile Island accident, fy right'?
. t, j 24 l 25 A Yes. This equipment is not -- was not in
1 Womack 825 v
2 B&W plants at that time.
l 3 Q Near the top of the page it says that 4 "The purpose of the reactor coolant system water
( 5 level measurements is to provide: 1. The reactor 6 operator information to follow the course of an 7 accident, so that he will know whether he is losing 8 primary system inventory."
9 " Inventory" is a fancy way of saying 10 waters is that right? E 11 A Yes, the total volume -- generally liquid 12 water is referred to.
O
\# 13
- Q "2. An indication to the. operators on 14 when to operate and secure the primary system vents."
15 What are the primary system vents?
16 A I believe in the case of this staff 17 recommendation, he is referring to the vents that 18 he discusses in the just preceding page of his 19 recommendation.
20 Q Those are proposed vents to be added 21 to the hot leg?
22 A Yes.
23 Q Are the pilot operated relief valves
( 24 on th'e pressurizer sometimes also referred to as 25 vents?
1 Womack 826
^
(~h
\v/ .
2 A They may be referred to in that way.
3 Q If an operator knew that he was losing 4 primary system inventory, would that also be an 5 indication to the operator that he should secure 6 the block valve behind a pilot operated relief 7 valve?
8 A Yes.
9 MR. WISE: Do you mean if he knew that 10 it was the PORV that was the leak, or do 11 you mean if the candy cane broke open?
- 12 Q Looking down at the last paragraph under v 13 the heading " Proposed B&W Level Measurement Po s it io n , "
14 it states there, " Safety grade water level indication 15 on each of the hot legs with control room read out 16 is necessary to satisfy the purposes stated above."
17 What did you understand was'being i
18 identified by the phrase " Safety grade water level 19 indication," what kind of indication was being 20 proposed for each of the hot legs?
21 A I believe Mr. -- Dr. Rambo referred in_this
(
22 proposal to instrumentation which would basically
! 23 show the level of liquid water in the hot legs
[ (~T 24 assuming the water was not in forced flow.
(- \_/
25 Q Not in forced flow?
. < , -,- .~, . ,m-. ,. , . . - - - . - . _ - - - - , - -, -- ,- ,- ,- -w--y - - . - - - - , - - . - . . .
1 Womack 827
(,)
\ ,/
2 A Yes, not in forced flow, three words.
3 Q In other words, if the primary coolant 4 pumps are shut off, then the only source of water
( 5 flow through the hot legs would be natural convection; 6 is that right?
7 A Yes, that would be the source of flow through 8 the hot legs and cold legs.
9 Q If there were no water flowing through 10 the candy cane hot legs, that would Indicate that 11 there had been a loss of water or, as peoplo sometimes 12 say, inventory from the reactor coolant system,
'~' 13 right?
14 A Not necessarily. It would indica'te only that 15 the circulation had teen interrupted.
(
16 Q If the system has its normal inventory, 17 am I wrong in having assumed that the whole reactor 18 coolant system is solid except for the top of the 19 pressurizer?
20 A No, you are not wrong.
21 Q Well, then, wouldn't the hot legs be 22 filled with water?
23 A Yes, they would.
24 Q If the hot legs were not filled with 25 water, wouldn't that mean that there had been some
1 Womack 828 A,
\_] 2 loss of reactor coolant water system inventory?
3 A It would indicate some loss of liquid 4 inventory, yes.
( 5 Q Isn't that what I asked you before?
6 A I thought your question was if there was a 7 lack of flow would that indicate a loss of liquid 8 inventory.
4 9 Q. So if there is not water in the hot 10 legs, it would mean that there had been a loss of 1
11 liquid inventory from the reactor coolant system, 12 right? -
(D
\- A Yes. I am answering all these questions with 13 14 respect to volumetric inventory. The r'eactor 15 coolant can and does change its specific density 16 with temperature, and some people use the word 4
17 " inventory" to refer to mass inventory.. One can 18 change the volumetric inventory without changing the 19 mass inventory.
20 All these questions have been answered 21 with respect to volumetric inventory.
22 Q Has B&W designed equipment to measure 23 reactor coolant system water level?
)
{m A Yes, we have such equipment. The specific
(_) 24 25 equipment referred to here, however, I am not sure
1 Womach 829 h
.J 2 where it stands with respect to design. I have 3 some reasons to question the feasibility of the 4 proposal as well as its necessity.
5 Q' why do you question the feasibility?
6 A The -- for part of the objectives that 7 Dr. Rambo states here, the conditions in which one 8 might conceivably want to utilize this instrumentation 9 to measure the level or the volumetric inventory in 10 the hot legs might make it difficult or impossible 11 to interpret a conventional level measurement in a
-s 12 way that would be sufficiently unambiguous to give V
13 the kind of guidance to the operator.that -- the 14 additional guidance to the operator that Dr. Rambo 15 proposes.
16 In point of fact, I think we believe 17 that there are better ways already available to 18 the operator for making the key decisions which 19 need to be made to operate his plant, and so we i
20 have some questions about this NRC imposed i
21 requirement.
{
22 Q Could you just put a manometer on the 23 side of the vesel?
24 A You could put a manometer on the side of the 25 vessel, but you would have to ask yourself what
1 Womack 830 x) 2 such a device would be measuring in the condition 3 that you are interested and presumably in that 4 condition you would have substantial amount of 5 heat being passed from the core into the quiescent 6 water, and that heat would be creating vapor in the 7 water and a lot- of the water in the hot leg might 8 be mixed single phase, two phase. You would have 9 something of a frothy mixture.
10 Q So the quality of the coojant in the 11 manometer would not be representative of the quality i
12 of the water in the reactor coolant system?
(D
\~'<
13 A You would have to, I think, understand quite 14 thoroughly what you were measuring before directing 15 operational decisions based on it.
16 Q You said before that you thought that i
17 there were better ways to measure primary system
. 18 water level of reactor coolant system inventory l
19 than what Rambo was proposing in GPU Exhibit 33.
20 A I hope I didn't say exactly that because if 21 I did I misspoke. I thought there were better
{
22 ways based on already available indications to the 23 operator of making the operational decisions, that i
) 24 he ne'eds to make, I thought I said.
25 Q Could you be more specific?
1 Womack 831
/~
-k 2 A well, with respect to knowing whether or not 3 he is losing primary system inventory for the purpose 4 of the actions that he should be taking when he is 5 losing primary system inventory, I feel that the 6 thermal hydraulic measurements of temperature and 7 pressure compared to the saturation line of water 8 give him information sufficient to take the actions .
9 needed to assure that the loss of inventory does not 10 jeopardize the cooling of the core. 'That information 11 already is readily available to him.
12 Q Is it possible to have saturation b)
%s 13 without a , leak?
, 14 ' A Certainly. But it's a condition you would have 15 to basically create by bringing the pressure down 16 through the normal pressure control system to the 17 saturation pressure at the temperature of the 18 coolant you have in the reactor at that particular 19 time. saturation in fact' will exist normally in 20 any -- unless the pressurizer of the reactor coolant 21 system is functioning as it's designed to function.
22 MR. WISE: Could you read back that 23 last answer, please.
f x_, 24 (The record was read.)
25 A Let me add something to that because it is 4
i y _ . , . . - - . , - . . _ _ . _ . ..g. . , , _.- , , -, y. ,, - , . . . - . , , . - - , - ,
4 1 Womack 832 2 possible to be confused by that answer.
i 3 The pressurizer is intended to provide 4 a pressure higher than saturation pressure for the 5 particular operating temperature and, therefore, 6 maintains subcooling in the reactor.
7 Q The heaters in the pressurizer maxe 8 sure that the water is kept at a subcooled level; .
9 is that right?
10 A The heaters in the pressurizer'are designed 11 to raise the temperature of the water in the 12 pressurizer above the temperature of the water in O
v 13 the balance of the system. The water in the .
14 pressurizer is thus saturated, if you will, at a 15 higher temperature and therefore creates a pressure 16 which is transmitted throughout the system which 17 makes the rest of the system subcooled.
18 Q so the heaters in the pressurizer are 19 not intended to transmit heat to the rest of the 20 reactor coolant system, but are a device for 21 controlling pressure and it's the pressure from the 22 pressurizer that is transmitted to the rest of the 23 reactor coolant system?
24 A Yes, sir, that's why it's called a pressurizer.
25 MR. SELTZER: Off the record.
-.- -w - - . , , r --,*.<-*---# -- -
.-me , . -,, ,
i Womack 833 r"N t
i
/
2 (Discussion off the record.)
3 (A recess was taken.)
4 BY MR. SELTZER:
( 5 Q What has happened to the proposal for 6 a direct measurement of primary system water level?
7 A I frankly don't know where~ it stands right 8 at this moment. The NRC,as this exhibit indicates, ,
9 had asked for the addition of this kind of 10 instrumentation to all pressurized wajer reactors, 11 and their recommendations were fairly prescriptive.
12 However, they have changed their requests and 0) 13 recommendations a number of times. .
14 For our part we have, since this staff 15 recommendation was made and during the period of 16 time that I was still on a basically continual 17 involvement with design engineering, we. reviewed i 18 the needs here and reviewed the potential for l 19 providing reliable additional information and the 20 need for reliable information and basically 21 concluded that with the operational decisions that L
22 needed to be made, that the best instrumentation 23 was probably already on the reactor.
O
( j 24 That does not mean that in response 25 to a customer request or an NRC directive we might
1 womack 834
, ~ . -
Iv) 2 not have gone forward to attempt to provide 3 additional information that they demanded.
4 Q If operators at a B&W plant realized C 5 that a loss of coolant accident had commenced 6 sometime earlier, is there any instrumentation 7 that would tell them how much inventory had been 8 lost? -
9 A Yes, to a certain level of accuracy it's 10 possible to tell from quantitative measurements of 11 what has come out of the reactor coolant system; f- 12 for example, pump level instrumentation can give
(_) the operator a guide.
13 Also, if he has been 14 supplying injection water from one of the sources 15 of injection water, the makeup tank or the borated 16 water storage tank, the volume in those tanks can 17 give him a guide. -
18 Q The sump does not have an infinite -
19 capacity, does it?
20 A No.
21 Q In fact, it has a rupture disk that 22 opens when its level is exceeded.
23 MR. WISE: You mean the sump or --
-s
( 24 A Perhaps there is some confusion here between 25 the reactor coolant drain tank or, as it is sometimes
1 womack 835
. ,m
%s 2 called, a quench tank into which the pressurizer 3 relief valves discharge and the sump which is the 4 area in the basement of the reactor building into 5 which overflowed water from the primary coolant 6 system actually finally ends up.
7 The reactor coolant drain tank does 8 receive discharge water from the vent valves if .
9 any is produced until it's filled, and then it will 10 overflow through a rupture disk or s o'm e other 11 arrangement and finally the water makes its way
._ 12 into the basement of the reactor building, and a 13 that's what I meant when I said the sump leve1. ,
14 Q I see.
15 A You are quite right, though, in the 16 implication of your question that in considering, 17 in counting the inventory one would also look at 18 the reactor coolant drain tank volume level.
19 Q Are there read-outs in the control l 20 room for water level in the sump?
21 A Yes, I believe there are. I think this is 22 BOP instrumentation and it probably varies from 23 plant to plant, but I feel fairly safe in saying f%
( (,) 24 that there is some indication of sump water level 25 in all plants.
1 Womack 836 O) c .
2 Q I asked you this before and I apologize-3 for asking you again. How many B&W plants.have 4 you been in?
5 A Of those plants which now have an operating 6 license?
7 Q I will start with that, fine.
8 A Let me think aloud. I have been in the .
9 Davis-Besse plant before it was started up. I 10 have been at TMI-1 after its operatioh and at 4
11 TMI-2 before its operation. I have visited the
- 12 Crystal River Unit 3 plant. I have visited the
(_) 13 Bellefonte plants under construction. I have 14 visited the Washington Public Power Supply System 15 plants under construction, and I have visited the 16 Mulheim-Kaerlich plant under construction. I have 1
17 visited the Midland plant of the Consumers Power 18 Company under construction.
19 Let's see --
20 Q which of those --
21 A I think that's the list.
22 Q Which of those plants did you visit
- 23 before the Three Mile Island accident?
( 24 A Davis-Besse, TMI-1 and TMI-2, Bellefonte, 25 Mulheim-Kaerlich.
. - ,. ._. ,_ ._. ... _ _ ..__ - _. __,, . . _ - . . _ . . , . _ _ . _ , _ . _ . _ _ _ . _ _ . . _ . . , . . ~ . _ , . _ _ _ . . . .
I 1 , Womack 837 A
~
2 Q Were you in any of those plants before 3 the Three Mile Island accident while the plant was 4 generating electricity?
( 5 A I don't recall what the status of the plant -- the 6 operating plant that I visited before TMI on the 7 B&W system was.
8 Q Do you recall any of the plants that you 9 visited before the Three Mile Island accident were 10 critical at the time you visited? t 11 A No, I don't.
12 Q Did you visit the control rooms of A
-) 13 those plants that you saw before the Three Mile 14 Island accident?
15 A Generally, yes, to whatever extent the control 16 rooms were completed or constructed.
17 Q Had fuel been loaded at an'y of the 18 plants that you visited before the Three Mile Island 19 accident?
20 A Yes.
21 Q But at those which fuel had been loaded 22 you don't recall whether the reactor was critical; 23 is that right?
() 24 A No, I don't recall whether the reactor was 25 running at that time or critical.
I Womack 838
<~ .
%/
- 2 Q Did you spend any time talking to 3 control' room operators at any of the plants that 4 you visited; and if so, at which plants?
5 A I don't recall to what extent the people to j 6 whom I spoke,were control room operators. I may 7 have had some casual conversation with control room 8 operators, but it's hard for me to say. ,
9 Q You don't have any recollection of 10 having any technical conversations wi'th control 11 room operators before the Three Mile Island accident?
i .
fg 12 A In visits to B&W plants?
13 -Q Right.
14 A I don't recall having had technical 15 conversations specifically with control room 16 operators while they were operating.
17 Some of the people with whom I spoke 18 at various plant tours were people who were involved 19 in operations and may have been either hhen or later i
20 control room operators.
21 Q 1 hen you say, "may have been," you don't
{
) 22 know whether they were or not?
23 A That's correct.
24 Q Prior to the Three Mile Island accident 25 did you ever have any technical discussions with I
2 y , ---,-,,.--,.,.~,--,-.--y,-y., . , - - - , , , , .ym,,--,, --,..m-,- ,,--,,7,,_y,,,--,-.,---.,.v,,,m,. -
,-.-.-y..,,-_--..-,--.-,-.y-y-- --y-,--.
4 1 Womack 839 O}
V 2 control room operators who were attending training 3 courses at B&W in Lynchburg?
4 A I think the answer to that question is 5 generally no, to the best of my recollection. I 6 may have had some discussions but they don't stand 7 out in my memory.
8 Q Prior to the Three Mile Island accident ,
9 did you ever review the content of the courses 10 offered by B&W to train control room '9perators?
11 A No, I don't recall ever having done that 12 except as I participated myself in a brief one-week
%)
13 session which is really an executive session, as I 14 understood, a summary session, not necessarily for 15 training operators, along with some of my colleagues 16 from the BBR Company. There may have been common 17 material presented in that session. -
18 Q Are you saying it's not your belief
.19 that the course that you were given in that brief 20 training session was the same as the content of the 21 course given to control room operators who come to 22 B&W?
23 A I can say it more strongly than that. I can 24 say while there may be some common material,that that 25 is not the course, that the course that is given to
~
l Womack 840
. %.)
2 control room operators would be more extensive is 3 my understanding.
4 Q After you took the brief executive
( 5 training course, did you give Mr. Elliott any 6 advice on how he could improve the B&W training 7 program?
8 A I don't know whether I gave it to Mr. Elliott ,
9 or not, but I am sure that I gave,during the course 10 of the course, comments and feedback'which I recall 11 as generally positive to the instructors.
12 Q Did you have any suggestion for 13 improvement in the training program which you passed 14 along to Elliott or any of his staff?
- 15 A I don't recall. I may have had some, but 16 they don't stand out in my mind as being 17 earthshaking. -
18 .Q Before the accident at Three Mile 19 Island, did Elliott ever ask you for your assistance 20 in developing or improving the training of operators?
21 A I can't recall such a request in the generic 22 way you ask it. We, in the Engineering Department, 23 did provide, on request, technical specialists to
(~s) 24 lecture as a part of training contracts at the 25 request of Mr. Elliott, and I would work with i
1 Womack 841
~
/~S U
2 Elliott or a member of his staff in selecting these 3 kind'of people to give these lectures and try to 4 get people who would give the best possible
( 5 information and lectures.
6 Q Before the Three Mile Island accident, 7 did anybody from the training department ever ask 8 you to review whether the B&W training program was .
9 adequate?
E 10 A I don't recall such a request. ,
11 Q Did anyone from the training department
_ 12 ever ask you before the Three Mile Island accident 13 to assign anyone from your department to review 14 whether the training program was adequate?
15 A Except as I have already noted, I don't 16 recall such a request.
17 Q You say except as you already noted.
18 A In the sense of the direct contribution that 19 I discussed in an answer to your previous question.
20 Q None of the people that you supplied 21 were being supplied by you for the purpose of doing 22 a review of the training program to see if it was 23 adequate, were they?
On 24 A I don't recall that that was the case, no, sir.
( ,/
25 Q Prior to your development of the
1 Womack 842
/^s b
2 abnormal transient operating guidelines program, 3 are you aware of any other program at B&W that 4 was intended to involve design engineers integrally 5 in the development of a training program?
6 Did I say development of a training 7 program?
8 A Yes. .
9 Q I want to focus on the development of I
10 the program. ,
11 MR. SELTZER: Please repeat the question.
12 (The question was read.)
O 13 A Well, let me ' comment first. I.would not 14 characterize the abnormal transient operating 15 guidelines program as the development of a training ,
16 program. I think that goes beyond the characterization 17 that I would make. -
18 Let me see if I can answer the question 19 then as --
the following question, did I -- am I 20 aware of any program in which design engineers were involved in the development of the training program.
{ 21 22 I am not personally aware of this, that 23 I can recall at this time.
l 24 Q since the Three Mile Island accident 25 have you had any technical discussions with control t
i
1 Womack 842-A
[h Qj-2 room operators?
3 A Yes.
4 Q Which ones?
( 5 A Well, I visited the control room in Crystal 6 River-3 and spoke with the operators there after 7 the February 26, 1980 transient at Crystal River-3, 8 sometime after. I have talked with control room 9 operators on a casual basis on several occasions 10 in visits to the simulator area; and,",,of course, 11 on the day of the accident I talked with some of 12 the GPU operators who were at the simulator.
' \/ 13 With whom did you talk?
Q 14 A I think Mr. Floyd is the only name I remember, 15 Jim Floyd. I think I testified to that in an earlier 16 deposition.
17 MR. SELTZER: I would like to mark as 18 GPU Exhibit 34 for identification a memorandum 19 from R. E. Braumiller to Messrs. ateman, i
20 Hamilton and Dowling, subject: New 21 Idea - Subcooling Margin Indicator; Ball and 22 Womack, October 11, 1979.
23 (Memorandum dated October 11, 1979 from 24 R. E. Braumiller to Messrs. Bateman, Hamilton
, 25 and Dowling, marked GPU Exhibit 34 for i
1 Womack 843 2 identification, as of this date.)
3 Q Is Exhibit 34 a copy of a memorandum 4 which you received in the regular course-of business
( 5 on or about October 11, 1979?
6 A Yes, it appears to be,
'7 Q And-does it refer to a' bright new idea 8 that you were a co-author of?
9 JL I will accept your characterization.
10 What was the idea? (
Q ,
11 A The idea was for a means of electronic 12 implementation of a device which would detect l 13 and measure the loss of subcooling and the margin 1
{ 14 of subcooling in a hydraulic loop. .
15 Q And is one of the hydraulic loops for 16 which you developed this new idea the primary
(
l 17 coolant loop of a B&W NSS? .
l l 18 A It would be applicable there, yes.
19 Q Have you applied for a Unit [d States
! 20 patent on this?
l-l 21 A I believe a patent application is in process.
(_
22 Q It has not been issued?
- l. 23 A No, I don't think it's been issued.
l
) 24 Q Do you have a copy of the patent l 25 application?
l
1 Womack 844 l9 V.
2 A I don't think I do.
3- Q You signed the patent application, 4 'didn't you?
5 A I don't remember. I probably did.
6 Q You applied for patents before, haven't 7 you?
8 A No, this will be the first patent I will 9 ever have applied for. It is novel for me.
10 Q Did Ball apply for the patent with you?
11 A Yes, I believe he did.
12 Q Have you assigned any rights in the O 13 patent to B&W7 14 A Yes.
15 Q Who is processing the patent on your 16 behalf?'
17 A B&W has a central patent organization, and I
, 18 can't remember the names of the individ$als right 19 now, but they are handling the patent application.
l 20 Q Is that handled out of Lynchburg?
21 A No, I think that office is either in
- 22 New Orleans or in Barberton.
l 23 Q Has a prototype of your invention been
~
24 constructed?
25 A Yes.
. ~ . - . - . - . . - - --- - - . . - . - .-.-
1 Womack 845 2 Q How does it work?
A superbly.
3 4 Q Has it been offered for sale?
5 A Yes, I believe it has.
6 Q Has the world been beating a path to 7 B&W's doorstep?
g A Would you define world beating a path to 9 B&W's doorstep?
10 Q Have any customers linedSup to get one 11 of these new inventions?
s 12 A I think examples of this device or its C)\
\.
evolution have in fact been sold by B&W. There are 13 14 other companies which offer similar devices also.
15 Q Is what you have devised a computer-16 assisted saturation meter?
17 A It could be called that, although-the device 18 is not based on a general purpose computer. It's l 19 based on dedicated digital logic in which the same 20 way that a digital watch is based on dedicated f
21 digital logic to perform a single function or 22 group of functions.
23 Q Is this device of yours a Tsat meter?
O A Some people call this kind of device a
(/ 24 25 Tsat meter.
l
1 Womack 846 A
\ )
2 Q would you understand it to be a Tsat 3 meter?
4 A Yes, perfectly well.
5 Q Are you familiar with the competing 6 Tsat devices?
7 A Not very, no.
8 Q Has the Three Mile Island accident 9 increased the salability of Tsat meters?
10 A I believe it has, yes. _
11 Q Do you know whether any of your 12 competitors had Tsat meters on the market prior to 1
1 13 the Three Mile Island accident?
14 A I don't know.
15 Q why do you believe that the occurrence 16 of the Three Mile Island accident has increased the i
i 17 salability of Tsat meters? -
18 A Because among the indications which were
{ 19 available to the operators during the Three Mile l
! 20 Island accident, of a disturbance and possible 21 leak in the primary system, was the saturated
{
22 conditions of the reactor coolant system fluid.
23 Q I take it it's the function of a Tsat 24 meter to bring immediately and forcibly to the 25 operator's attention the existence of saturated e ,e- c - - - - -rrum - - -
,e -w p s, -,nm o e >,----g- r ,-o- e- -rc- p r w n -- ,w ,e- --r-s,w-o. ..v- ,-v v~~w--va~, - - --
1 Womack 847 i
\..)
2 conditions?
3 A It would serve that purpose, yes.
4 Q In fact, you recognize that that's one 5 of the, if not the primary purpose of the Tsat 6 meters isn't it?
7 A Yes, that would be the purpose, part of the 8 purpose it would serve. It also measures the 9 margin of saturation if that's of interest at a 10 particular time. ,
11 Q Is the Tsat meter which you have invented 7, 12 capable of being'used in a safety grade installation?
/ )
'~
13 A Well, I know of no reason in theory why it 14 should not be used; however, I am not sure that 15 the version that B&W has prototyped necessarily 16 meets all the requirements of safety grade 17 instrumentation. ,
18 Q In the fifth page of Exhibit 34 your 19 co-inventor, Ball, cays, "The only prior art which 20 would apply to this system that I know of would be 21 the use of a book of tables (Keenan and Keyes) or 22 the use of a computer which has a look up table or 23 computes the right answer with some special ry
() 24 algorithm."
25 Kennan and Keyes is the standard e
1 Womack 848
[\
V 2 reference work on saturation?
3 A Yes, Keenan and Keyes is the standard 4 reference work in the United States on the properties 5 of water in thermodynamic systems.
6 Q Are there charts in Keenan and Keyes 7 that show steam lines?
8 A Yes, I believe there are.
9 Q Have you worked with Keenan and Keyes?
10 A To some extent, although this kind of 11 information is available from.many, many other 12 references. It's very common information.
13 Q Do you know of any B&W pla,nts that have 14 installed your invention?
15 A I am not sure where that stands. I know a 16 number of B&W plants -- excuse me, I know at least 17 one B&W plant, I believe there is more ,' which I 18 implemented this kind of saturation meter. I 19 believe the NRC imposed a requirement for a device 20 something like this after --
at some point after the 21 Three Mile Island accident, and it may be that 22 compliance with that requirement has caused all 23 plants to have some equivalent to this.
! ( ,) 24 Q What are they putting in in Unit 1, do 25 you know, TMI-1?
I 1 Womack 849
/~N i )
~'
2 A No, I don't know offhand.
3 MR. SELTZER: I would like to mark as 4 GPU Exhibit 35 a memo entitled " System Dynamic l 5 Response / Response to TMI-2 Concerns Task 6 Description."
7 (Memorandum entitled " System Dynamic
~
8 Response / Response to TMI-2 Concerns Task 9 Description," marked GPU Exhibit 35 for 10 identification, as of this date.) ,
11 Q Is GPU Exhibit 35 a document which you 12 prepared?
13 A I was just trying t.o figure that out. I don't d
14 think I prepared it.
15 Q was it prepared under your supervision?
16 A I really can't -- I really can't place it.
17 I am not sure. .
18 Q Is it a document that you think you 19 have seen before?
20 A well, I think this is my handwriting on the 21 document, at least some of this is my handwriting, 22 the marginal notes on the document.
23 The answer, I think, to that question is b
v 24 yes.
25 , Q I see.
1 Womack 850 7s 2 A But when, I am a little --
I-am at a loss on. -
3 Q Under the heading " Background" just 4 above the middle of the first page of GPU Exhibit 35 5 it states, "There are several' main issues that have 6 been discussed and reported in ACRS recommendations, 7 NRC staff positions, and NUREG -
0560. The key 8 words describing the issues are:" and then it lists 9 six phrases.
10 The first phrqse is "Buc' king Bronco."
11 What does that phrase connote?
12 A Well, I am not sure who invented that phrase, kJ 13 but, as we discussed earlier in this. deposition, 14 the coupling between the primary and the secondary 15 system via the once-through system generator in a ,
16 B&W plant is tight, meaning that the primary system 17 responds to secondary system dynamics fairly quickly, 18 and I think someone of the NRC staff who was given 19 to colorful language, it may have been Dr. Ross 20 who is himself a Texan, I believe, probably thought 21 that would be a colorful way to express the fact 22 that this coupling is tight and that the system is 23 responsive to changes in the secondary system s ,,) 24 dynamics.
25 g In other words, the primary system in a
1 Womack 851 2 B&W plant responds very quickly to upsets in the
- 3 secondary system; is that right?
4 A Yes, that's true.
5 MR. SELTZER: Why would that be 6 picturesquely described as a bucking bronco 7 effect?
8 MR. WIS'E: Are you asking him now?
9 Q' What did you understand was the basis 10 for that? ",
11 MR.' WISE: What did this witness i 12 understand whoever the unidentified person O 13 was that may have made up that , phrase?
14 MR. SELTZER: Yes.
15 A Beyond the connection that I have constructed 16 to you, I don't think I can add anything.
i 17 g The next phrase that's listed there 18 is " Pressurizer Size."
, 19 Am I correct that if there were a l
20 larger pressurizer or larger pressurizer inventory, l f 21 that the pressurizer could act as a buffer?
i
(
22 A The pressurizer does act as a surge tank for 23 changes in primary system temperature. One could
- /7 j (_j 24 incre'ase the size of the pres,surizer and increase l
l l 25 the range of primary system temperatures for which I
w- - .-- *y--y , w v y - - - -
- w. ev -ew y+w,"s-wn'*- ---w---'w- =t='v w w w -m wwwP w ='---yer-rwP etw-w- v -7Y'F-t*W7F"-'t-
+
1 Womack 852 O
D l. 2 the pressurizer would act as a surga tank.
I 3 Q When the pressurizer acts as a surge 4 tank, is it dampening the bucking bronco effect?
( 5 A well, I think we ought to get off the bucking 6 bronco effect. If you would be more specific in 7 what you are asking me technically, I will be happy 8 to try to answer.
9 Q As you have explained the bucking 10 bronco syndrome, it's that the primary system is ,
11 responding very quickly and directly to upsets in 12 the secondary system, right?
O O 13 A Right.
14 Q The fast response of the primary system 15 means that it may show sudden rises in temperature 16 or rises in pressure in response to upsets in the 17 secondary system, right? .
18 A Yes, that can happen.
19 Q If you had a larger pressurizer in a 20 B&W plant, the larger pressurizer could dampen or 21 reduce the sympathetic response of the primary 22 system, couldn't it? -
23 A Yes. That's -- but that's simply a matter
( 24 of s c'a l e . It already d'oes --
serves that purpose; 25 and if you have a larger pressurizer, presumably
1 Womack 853 VO -
2 you could possibly dampen the larger dynamic variations s
3 on the secondary side or in the primary side.
4 Q So if you had a larger pressurizer, it 5 would reduce the rise in temperature or rise in 6 pressure resulting from upsets in the secondary 7 system, right?
8 A No, I don't think that would be the effect 9 of first order. A larger pressurizer would simply 10 be able to supply more water to a dec'reasing temperature 11 transient and there might be some dampening effect s 12 on pressure responsiveness of the larger pressurizer 13 on pressurizing transients.
14 Q So it would reduce a pressure rise; 15 is that right? A larger --
16 A In theory, a larger pressurizer with a larger 17 gas space might reduce the rate of pressure rise
! 18 to the same presenting transient. I think it would 19 do so, yes. -
20 Q The third item is " Loop Seal in Surge 21 Line."
22 What is the issue described by those
. 23 words, as you understand it?
[~)
\,,e 24 A It's been pointed out that the surge line l
25 which is a length of piping which connects the i
1 Womack .854-5 s_ .
, 2 pressurizer tank to one of the reactor coolant 3 system hot legs comes down from the pressurizer 4 and then rises back up to go to the hot leg 5 somewhat similar to the trap underneath a sink
, 6 drain. This is sometimes called a loop seal, 7 although I do not understand that it was installed 8 for that purpose.
9 It was asserted shortly after thd TMI 10 accident in some of the studies that khe dynamics 11 of the pressurizer water level behavior might have 2
12 been affected by that particular line construction O.
\_/
'13 as opposed to a line which would comc. horizontally 14 or even with a downward slope from the pressurizer 15 to the hot leg. (Indicating.) .
16 I believe now that those who asserted 17 that now all believe that it would have made no 18 material difference to the pressurizer's essential 19 response during the course of the accident had the 20 line been simply sloped downward or horizontal.
21 (Indicating.)
22 Q In other words, the water level rise 4
23 which occurred in the pressurizer during the Three
]\g 24 Mile Island accident would have occurred in the 25 same manner regardless of the configuration of the
1 Womack 856 S
Q. loop seal surge line?
2 3 A I believe that conclusion has been reached 4 by those who felt at first this might have something 5 to do with it.
6 Q Do you have any opinion on that?
7 A I believe it would have behaved in the same 8 way. ,
9 Q The next item is " Auxiliary Feedwater E
10 Initiation & control." ,
11 I take it that since the Three Mile 12 Island accident, B&W'c engineering staff has taken O)
\
'~'
the position that B&W ought to become more involved 13 14 in directing the control that is appropriate for 15 auxiliary feedwater initiation and control?
16 A Certainly among the many things that came 17 after -- came from the broadened thinking about all 18 plants in this primary to secondary interrelationship 19 area, which came after the Three Mile Island accident, 20 although not necessarily clearly related to the t
21 accident sequence, the performance of auxiliary 22 feedwater systems was an important matter, and that
, 23 I believe all licensing utilities and all pressuri=er b
(j 24 water reactor and I think also the boiling water 25 reactor vendors have looked at auxiliary feedwater
I Womack 857 i
(~' .
t .
2 systems since the accident.
3 Q When you say they have looked at them --
4 A Well, for example, I think all plants have
'5 been surveyed for auxiliary feedwater system 6 performance reliability.
7 Q They have been looked at by the NSS 8 vendors for that purpose? .
9 A Well, the NRC did some studies itself, it 10 directed its licensees to do some studies. We i
11 assisted our customers at their request in NRC-directed 12 studies.
13 Q What is the significance of the words 14 " Inadequate Thermal Capacity"? What issue does that 15 relate to?
, 16 A I am not sure at this point what issue that 17 relates to. It may relate to a comparison of the 18 inventory of water in the once-through steam I
19 generator to recirculating steam generators which 20 is a thermal capacity of the system. I would not 21 characterize that as inadequate, so I don't really
(
22 know. ;
23 Q B&W's once-through system generator 24 has less thermal capacity than the competitors' 25 recirculating steam generators; is that right?
- _ . . , - - - - . . _ - . . _ . _ - ~ . , . . - . - . _ . - . , . . . - . . - - _ . _
- 1. Womack 858 2 A That depends on your definition of thermal 3 capacity.
4 Q They have less water within the steam
( 5 generator, right?
6 A There is generally -- they're generally 7 operated with less stored water within the steam 8 generator; that's correct. .
9 Q What does the phrase " Post Trip 10 Inventory control" mean? ',
11 A My best recollection of that is it relates 12' to the pressurizer size issue we discussed before.
13 After reactor trip, the r.eactor coolant 14 system bulk average temperature decreases', and this 15 causes the coolant to shrink literally, and the 16 shrinkage lowers the level in the pressurizer and 17 in some reactor systems which have a less than full 18 range of pressurizer level instrumentation, this 19 low level on a slightly below normal trip will 20 approach the bottom end of the instrumentation range.
< 21 I believe that's what this refers to.
k 22 MR. SELTZER: I would like to mark as 23 GPU Exhibit 36 for identification a memorandum
('
24 entitled " Response to TMI-2 Concerns, Task 25 Description, System Dynamic Response, Post
1 Womack 859
~
O 2 Trip control," indicating as lead section 3 manager, E. A. Womack.
4 (Memorandum entitled " Response to 5 TMI-2 concerns, Task Description, system 6 Dynamic Response, Post Trip Control," marked 7 'GPU Exhibit 36 for identification, as of this 8 date.) ,
9 Q Is GPU Exhibit 36 a copy of a memorandum L
10 which you prepared? ,
11 A Again, I can't -- I don't know for sure whether 12 I prepared this or not.
O 13 g If you didn't prepare it, is it something 14 that would have been prepared under your supervision?
15 A That's likely. Although not necessarily under 16 my direct supervision.
17 Q Item 3 is headed " Problem Definition."
18 It states there in GPU Exhibit 36, "The NSS l
19 performance for various initial conditi ns is not 20 in accord with the design assumptions."
21 What various initial conditions do you 22 understand this is referring to?
l 23 A well, I think the focus of this particular 24 task was that issue that I mentioned to you briefly 25 just a minute ago, and perhaps if I described it in I
i 1- Womack 860 O
l \-)
2 a little more detail, that would help.
j 3 Certain of the B&W plants were provided 4 with pressurizer level indication which did not
( 5 span the full height of the pressurizer tank. The 6 pressurizer level indication did span the range 7 which the design engineer thought was adequate for 8 the pressurizer level variations that would be ,
9 experienced under nominal conditions in reactor 10 trip to meet the design criteria. ,
j 11 Q Excuse me, what are nominal conditions?
12 A Well, the nominal conditions would be the 13 expected nominal operating conditions of steam 4
14 pressure, steam temperature, the settings of the 15 steam relief valves, the nominal flows of auxiliary 16 feedwater, the normal auxiliary feedwater initiation
. 17 times and so forth. Those are the kinds of things v
18 I mean.
19 TMI-2, as I understand it, by the way,
, 20 was not one of these plants, but nonetheless because 21 these plants had an indication range for pressurizer 22 level of only 320 inches as opposed to the 23 approximately 400 inch range of indication which
() 24 was available at other plants, if certain aspects
' 25 of the plant equipment did not function exactly
,w ,, --a .e -- m- r- -,,-n-4 -g 4 - ,w---y ser u----e -wrww -- y ,e ,<ar, ,,. ---,r,.m- v,- y, w ,w. ww
I Womack 861 b("N 2 in -- as expected in nominal conditions after a 3 plant trip, the pressurizer level indicated to the 4 operator,which normally falls in response to 5 a plant trip and then is restored,could appear 6 momentarily to go to the zero level of the indication 7 range.
8 The fact is that this in the first -
9 instance does not indicate that water is entirely
(
10 absent from the pressurizer since there are some 11 40 inches of water level below the lower instrument 12 tap in the pressurizer in any case, and also because 73 6 ,
t
%)
13 of the dynamics of the pressurizer level measurement, 14 it will tend in these circumstances to' read about 15 25 inches low.
16 Nonetheless, as far as the operator's 17 view of this transient, his indication has dipping 18 down to or near zero, and the main thrust of this 19 particular task was to address means whereby we 20 could correct those control variables such as steam 21
( safety valve relief pressures to be more nearly 22 as assumed in the original design analysis and 23 eliminate this optical problem.
((~s)
,, 24 I think it is primarily an optical problem 25 and not a problem of great substance.
av--- -
r - - - -+--<w*- - - - - - - r---- r-,3 --vw -
1 Womack 862 2 g Are you saying that the whole problem 3 that's defined here is an optical problem not an 4 NSS performance problem?
5 A It's an NSS performance problem in the sense 6 that the NSS performance what is being discussed here.
7 However, in terms of addressing questions of a
8 adequacy of water inventory after trip, questions 9 which might, you know, lead to other concerns, we 10 did not find that that was --
that t h'o s e kinds of 11 questions were really at issue here.
3 12 What we wanted to'do was to be able to a lj3 help these operators to be able to see more clearly
, 14 that they did in fact have the water which was 15 a c t u a l l y t h e r e . a n'd .t o - - a n d to conserve as much 16 of it as possible by achieving as much as possible 17 nominal performance or even perhaps some additional i
18 margins.
19 Q What, if anything else, was included 20 in the task of post-trip control other than getting
{ 21 a better reading of water level in the pressurizer?
22 A well, another way to shrink this water, of 23 course, is to overcool the plant with auxiliary
(~h
(_) 24 feedwater,and I believe attention was to be given 25 here to any further steps that might be taken to l.
t 1 Womack 863 O.I 2 make this overcooling less likely, overcooling with 3 auxiliary feedwater or main feedwater, I should have 4 said.
5 Q In the action plan, Item B is " Improve 6 PT-IV model for trip and post trip low power 7 analysis."
8 What is a PT-IV model?
9 A That's a Roman numeral. It's an abbreviation 8
10 for analogue computer model which goes by the name 11 Power Train IV, being the fourth addition of that p 12 particular analogue computer model, and it is a
\ -
~
13 simulation'which we use in the design of control 14 equipment and it's used primarily for the design and 15 tuning of control equipment in the powe.r operating 16 range, the integrated control system, for example.
17 And what was suggested here'was making 8 some additions to that model which would make its 19 accuracy at very low powers which would be 20 appropriate for after shutdown analysis better.
21 Q When you say "after shutdown," would that
{
22 include during an unanticipated trip from load?
23 A Yes. When the heat production in the reactor 24 core was essentially at the decay heat levels.
25 Q C under the action plan is " Define
.o 1 Womack 864
/\
N~ -
2 target post-trip control criteria."
3 What were the target post-trip control 4 criteria?
( 5 A These would have been criteria which would have 6 said the variations in such parameters as pressurizer 7 level and pressure in the primary system should not 8 be greater than some value given another range of 9 abnormal or off normal behavior of the secondary 10 - system equipment. That's the kind of, criteria that 11 were envisioned there, I believe.
12 MR. SELTZER: Will you please repeat
\.
13 that.
14 (The record was read.)
15 Q Have those criteria been developed or 16 defined since this document, GPU Exhibit 36, was 17 written? -
18 A Let me think. I believe in follow-up tasks 19 related to this general area we"have tried to 20 suggest some possible criteria,so the answer is yes.
/ 21 Q What follow-up tasks?
Q 22 A I believe we have done an owners' group task 1
23 related to auxiliary feedwater control which addresses
) 24 part of this general subject. (Indicating.)
25 Q Is there a name to that program or task?
1 Womack 865
~
,e \
U 2 A Probably Auxiliary Feedwater Control Task or 3 Auxiliary Feedwater Control Upgrade.
4 Q Do I understand what you are saying 5 to be that for this auxiliary feedwater upgrade 6 you've postulated that there can be a secondary 7 side upset caused by loss of auxiliary feedwater; 8 is that the first step?
9 A That is a good first step to consider, yes, 10 in most cases. t 11 Q Then after the loss of auxiliary feedwater 12 B&W has defined post-trip control criteria that c) 13 should be observed in the primary side of the NSS; 14 is that right?
15 A Well, the criteria would be set as objectives 16 for a task which was attempting to make some 17 performance changes in the --
in the system itself.
18 These would be new criteria as objectives for change.
19 Let me see if I can make this a little 20 bit more clear for you, if you like.
(A. 21 The auxiliary feedwater system is a 22 system which has redundant equipment in it and -- but 23 like most redundant systems, individual elements of
( 24 the system may be sized to provide all the cooling 25 that is really needed in the. event that one of the y - - ~ . , ,
, ., en .- re,. ,- e ,-
1 Womack 866 fg
() . 2 other elements of the system is for any reason 3 inoperable.
4 In most cases, when a redundant system 5 is called upon to work, all its elements operate, so 6 you may'be then supplied with two times or three 7 times as much cooling as you really need. In such 3
8 a case unless you take some other action to reduce 9 the auxiliary feedwater flow, you will tend to cool 10 the primary system more than you really need to, and 11 there is nothing really bad about that; but if you 12 wish to dampen it or reduce the variations in r
t ,%'/
13 primary system parameters that the operator sees in 14 response to, say, an initiation of auxiliary feedwater 15 system, you can add additional control equipment 16 which will in effect recognize that you have got 17 more flow than you need and reduce it. .
18 Q You are postulating the suebessful
~
19 initiation of all the trains of auxiliary feedwater, 20 right?
21 A Yes.
22 Q I think you were telling me a moment 23 ago that another part of this task performed for
) 24 B&W, ' users group examined loss of auxiliary feedwater; 25 isn't that right?
1 Womack 867 e s
%') A 2 That was a different task and I would not 3 connect that task with this one.
4 Q Has B&W defined target post-trip control
( 5 criteria for loss of auxiliary feedwater?
6 A I think the answer to that question is yes.
7 Loss of main'feedwater, excuse me, the loss of s
8 auxiliary feedwater is not intended to be a design ,
9 condition of the reactor. The auxiliary feedwater 10 system is the backup system to the md,in feedwater 11 system and it is redundant.
12 so, while we have done some investigation
[)
\# 13 at the customers' ' request of a total loss of f'eedwater, 14 that's not a design condition we define ~ for the plant.
+
15 Q Since the Three Mile Island accident, 16 B&W has designed substantially upgraded controls for 17 the AFW, haven't you? Auxiliary feedwater?
18 A We have designed some upgraded controls for
, 19 some customers and we have conceived sone potential 20 upgrades that have the effect that we discussed a 21 minute ago with regard to reducing variability in 22 feedwater.
23 g What do you mean the variability?
Ii
%.d' 24 A That's back to the discussion I gave you 25 about the number of redundant trains that come on
1 Womack 868
--)
2 and the amount of water supplied.
3 Q Item F was " Prepare interim report."
4 Has an interim report on this task been i
l 5 prepared?
t i 6 A I believe that an interim report regarding the 7 auxiliary feedwater control has been prepared and 8 discussed with the customers. I am not sure where -
9 we stand on secondary side pressure control today.
10 MR. SELTZER: I would like to have i
11 marked for identification as GPU Exhibit 37 a
- 12 memorandum entitled " Response to TMI-2 i %Y 13 concerns, Task Description, Main Feedwater 14 System Reliability," led by the eminent 15 section manager, E. A. Womack. ,
j 16 (Memorandum entitled " Response to TMI-2 17 Concerns, Task Description, Main Feedwater 18 System Reliability," marked GPU Exhibit 37 i
19 for identification, as of this date.)
20 Q Is GPU Exhibit 37 a document either 21 prepared by you or under your supervision?
{
22 A Yes, it appears to be.
]
23 Q Is this a project that went forward
' 1
(._/ 24 beyond its formulation in GPU Exhibit 377 25 A It went forward to the point of being offered
. . . _ . , _ _ ~ _
_ . - - . _ . _ _ ~ - - _ - - . _ - . _ . - _ _ _ . ..__ - . _ . . - . - - _ . _ . . _ - _ _
1 Womack 869 D 2 to the customers. I am not sure that any of the 3 customers have undertaken this project with B&W.
4 The main feedwater system is balance of plant scope.
( 5 g Under the section entitled " Background" 6 it states that "NRC/ACRS Post TMI-2 incideht review 7 of feedwater systems and their reliability indicate 8 that upsets in the main feedwater systems of B&W ,
9 plants result in more frequent and more serious 10 challenges to the RPS and safety systems than in 11 PWR competitor plants. Results to date from the 12 operating plant data indicate that there are a (3
G 13 large number of feedwater system upsets (64 of 246 ,
14 reactor trips analyzed) that lead to reactor trips 15 and challenges to the safety system."
16 Have you seen any data that is 17 inconsistent with the NRC/ACRS indications that
.i 18 upsets in the main feedwater system of B&W plants 19 result in more frequent and more serious challenges 20 to the reactor protection system and safety systems 21 than in PBR competitor plants?
22 MR. WISE: I will object to the form 23 of the question. I don't see how he could r~s
() 24~ possibly answer that without knowing what.was 25 in the mind of the NRC and the ACRS and
-yr- . - - . + , . - - ~
r_.-- - - . . . . . . . ---,7-.---,r
.y--- - - -
1 Womack 870 y -
(J 1_
2 whatever they said, and I also don't know 3 what you mean by data that is inconsistent
. 4 with whatev'er they may have meant.
l 5 MR. SELTZER: They are making a simple 6 comparative statement that there is more 7 frequent and more serious challenge in the 8 B&W plants than in competing PWR plants. ,
9' BY MR. SELTZER:
10 Q You understand that's whd,t is written 11 in this memo that you either wrote or had written 12 under your supervision, is it?
\ 13 A That's what is written here.
14 Q I am asking you if you have seen any 15 data that is inconsistent with that conclusion.
16 MR. WISE: I will object to the form 17 but I will permit the witness to answer.
18 I will want my objection noted for the record.
19 MR. SELTZER: Obviously, it is noted.
20 He writes down everything you say.
21 A The more frequent observation, of course, is 22 an objective observation and it would depend on 23 vhat plants you looked at at what period of time.
()
fm 24 I am sure there are data, I believe I have seen.
25 data, I can't put my finger on it, that would
, , , - - , , -, , .-~ - - - - , . , , . ~ , . - - - , , - - - - - - - - , - - , - - - - - - - . , - -
. . .- . -. = . -
i 1 Womack 871
- 2 indicate that some non-B&W plants might have more 3 loss of feedwater events or feedwater events in a 1
4 given period than some B&W plants, so I think that 5 would have to be looked at in terms of statistics.
1 6 The question of what is more serious is 4 7 considerably more subjective and I don't --
I am l
8 really not sure.how to answer your-question. ,
9 The B&W plant responds differently to 10 feedwater system upsets than competit'or plants and *
- 11 it responds to a number of feedwater upsets in a way 12 which I consider to be less serious because it avoids,
- O 13 it was designed to avoid, challenges to the reactor 14 protection system.
i -
15 Q We have previously talked about the J ,
f 16 bucking bronco syndrome, and because of the reduced i
f 17 thermal capacity or size of the steam generator in 18 a B&W plant, isn't it a fact that a feekwater i
19 transient will tend to disrupt the primary system 20 more than in a competing PWR plant?
l 21 A Again, that ' depends on what you mean by i .
'. 22 disrupt more. I have previously told you that the 23 system is tightly coupled through the steam generator;
) 24 however, all feedwater transients cause disruption 25 in the systems of which they are part.
i
,,--r----_m,_. , .-- , _ _ . - _ ,.%,%,_. ,._,,,,_,,_,_...._,c .,,_ry.er,m_.... -.-.,,..,...r-,.,py.y ,.,,m,.w.y_r__,,,.-4-,,.r,---,.-- .,-.w.., ,, -, -
1 Womack 872 gs -
t !
V 2 The B&W plant is designed to take 3 advantage of the responsive coupling between the 4 primary and the secondary system and avoid reactor k 5 protection system challenges to certain kinds of 6 upsets. For that reason it has a different or had 7 a different safety system to deal with this 8 occurrence than some of the competitors' plants .
9 and, therefore, it responded differently to 10 situations in which the safety system was challenged.
11 Q Let me ask you this specifically:
12 Do you consider the pilot-operated relief valve
.s i
\/ 13 part of B&W's safety system?
14 A No, I do not.
15 Q so that a frequent challenge to the 16 pilot operated relief valve would not be a challenge 17 to the RPS or the safety systems? ,
18 A No, the -- challenging the PORV is not 19 necessarily a challenge to the defined shfety 20 system of the plant.
21 Q How is it that a pilot operated relief 22 valve, which is part of the primary pressure boundary, t
23 is not part of the safety system?
, m
) 24 A Well, in the sense that the pilot operated l
25 relief valve's integrity as a part of the pressure l
1 Womack 873 p -
N.
2 boundary is concerned, it is a part of the pressure 3 boundary, but the safety systems, the active systems 4 which are provided on the plant to assure that the 5 defined safety criteria are met, do not call upon 6 the pilot operated relief valve for venting or 7 relief. They do not require its function for that 8 purpose. And those systems which are provided to -
9 deal with leaks, such as a failure of that 10 pilot operated relief valve might produce, are well 11 designed to handle that result also.
12 Are you saying that the systems which
,q Q b 13 are designed to handle a failure of the pilot operated 14 relief valve are safety systems in the B&W design?
15 A The systems which are designed to handle 16 leaks, leaks or losses of coolant accidents, are 17 indeed safety systems, yes.
18 A block valve isn't a part of the safety Q
19 system, is it?
20 A The block valve is not considered part of the 21 safety system and the operation of the block valve 22 is not necessary to assure safety core cooling.
23 The controls for the pilot operated Q
24 relief valve are not part of a 3&W safety system, 25 are they?
I Womack 874
(~\
V 2 A They are not considered part of a B&W safety I
3 system, correct.
4 Q And the controls for the block valve l .(
- A 5 are not considered part of the B&W safety system?
6 A That is correct,.as of the design as it was 7 originally prepared, yes. I think that there may 8 have been some NRC-directed changes to these -
9 control systems, and I don't know where they stand 10 today. .
11 Q Those are NRC-directed changes.as a-12 result of the Three Mile Island Accident?
7s U 13 A They follow the Three Mile Island accident; 14 presumably they have some connection.
15 Q At the time that you or people working ,
16 under your direction wrote GPU Exhibit 37, were you 17 - aware that there were certain upsets in the main i
18 feedwater system in plants, in B&W plants that i
r 19 result in more frequent and more serious challenges 20 to the reactor protection system and safety systems 21 than in PWR competitor plants?
22 A We were aware that that conclusion or conclusions 23 to that effect had been reached by the NRC, and we, r~N
(_) 24 for our part, felt that the frequency of these 25 occurrences was an area which would.be to the benefit
, .wm w a , --.-
. ye w y-w,w- -ei-+i.- w g+.--3,-wwv:-m-yr -+++ m ------emy e =a-n
i 1 Womack 875 2 of the industry to reduce.
3 Q Has B&W ever assembled data which would 4 demonstrate that the NRC/ACRS conclusion about 5 relative frequency and relative seriousness was 6 incorrect?
7 A Let me take this separately.
8 Again, relative frequency, we have .
9 tried to assemble data on that to some extent, and 10 I think that has for the most part been presented 11 in ACRS testimony.
12 Q Since you are breaking it up into parts, (f
%d s) 13 does that data refute the NRC or AEC. understanding 14 that B&W plants have more fre'quent challenges to the 15 reactor protection system and safety systems as a ,
16 result of main feedwater upsets than occur in PWR 17 competitor plants? -
18 A I would have to go back to my earlier answer, 19 Mr. Seltzer. I have the feeling that for certain 20 periods of time in certain plants that statement 21 would not be true, simply not be true; but for other 22 times or other selections of plants it might well 23 be true.
O 4
x,_) 24 Feedwater system reliability or feedwater 25 system performance is what's being addressed here.
1 Womack 876 2 Feedwater systems are designed by and at the direction 3 of the. utilities by a wide variety of architect 4 engineers and they'are different from B&W plants 5 so their performance can be expected to be different.
6 g Well, your staff had found from 7 operating plant data, "there are a large number of 8- feedwater system upsets (64 of 246 reactor trips .
9 analyzed)."
10 A Yes, that's correct. ',
11 Q Now, that is data from B&W plants, right?
12 A Yes, that is the data we had a this time,
.V ,
13 yes, sir. And I think that the conclusion that 14 there are a large number of feedwater system upsets 15-is a conclusion which has'not changed. ,_
16 Q And those feedwater upsets are not 17 upsets that-just occurred on one or two B&W plants; 18 isn't that right?
19 A That's correct.
20 g Wh'en it says that those upsets have led 21 to reactor trips and challenges to the safety. system, 22 what kind of challenges to the safety system are
-23 being referred to here?
24 A A reactor trip is a challenge to the safety 25 system. The reactor protection system which trips
1 Womack 877
~ '
u-2 the reactor is a safety system.
3 Q I see. so --
4 A so it's kind of a redundant statement.
k 5 Q Where in B&W is data on causes of 6 reactor trips assembled?
7 A well, various organizations within B&W have 8 assembled it for different purposes. These particular.
9 data I believe were assembled within the Power Systems 10 and controls Unit. (
11 g Do you ever receive reports that show 12 annual summaries of causes of outages to B&W plants?
s (G 13 A- Yes, from time to time I receive such reports.
14 Q What are those reports called?
15 A Well, they might be called availability 16 summaries or outage summaries. I don't know that 17 I know of a particular name that they would all 18 characteristically have.
19 Q How frequently do you get these reports?
20 A Well, I haven't received one for some time, 21 but I think that they have been produced with 22 varying frequency, perhaps once a quarter, once 23 every six months, maybe once a year.
f~h
( j 24 Q You took over as manager of the plant 25 design section in August of 1978. At the time you
1 Womack 878
. )
2 took over, unit managers were preparing monthly 3 reports which they sent to the head of the design 4 section, right?
( 5 A Yes.
6 Q They had been preparing them before you 7 became head?
8 A Right. As I understand it, that's right. .
9 MR. SELTZER: Let me state now so that 10 I don't forget later, Bob Wise was kind enough 11 to send me a letter on January 22nd responding 12 to nine items of information or documents that
(
\-~, we had requested after the last session of 13 14 Dr. Womack's deposition, and for some of the 15 categories you indicated, Bob, that the shelf 16 files contained substantial material which you 17 said, "We have not been able yet to review.
18 We are willing, in any event, to make them
~
19 available to you for review in Lynchburg on 20 reasonable notice."
21 You also gave us " copies of certain 22 periodic reports found among the shelf files."
23 We found the periodic reports that you 7_
( ,) 24 gave us were only for the years '79 and '80, 25 even though this witness took over the section
i i
1 Womack 879 C)
\,J .
2 in '78 and indicates that there were reports 3 prepared even before he took cver, the 4 periodic reports. And there are also central 5 files that you identified which you say you 6 believe they are duplicative of hard copy 7 produced. I am sure you wouldn't represent 8 that they are absolutely duplicates or that 9 they're not responsive documents in the 10 central files that were not duNlicatesof 11 files you have produced.
12 MR. WISE: There is no way I can make O .
13 such a representation. I haven't read all 14 of that material. I understand it's marsive .
15 and it's on microfilm.
16 MR. SELTZER: Right.
17 MR. WISE: Or fiche. -
18 MR. SELTZER: We certainly appreciate
~
1
' 19 the difficulty of reading fiche and microfilm 20 and getting legible copies from fiche and 21 microfilm.
22 We will endeavor promptly to travel 23 to Lynchburg to review the substantial volume A
(_) 24 of shelf file material, and we will work out 25 a date with you that is mutually agreeable.
, , , - , . ,,- -v-- ,g-. .-
1 -
Womack 880 2 We also want to get the periodic reports 3 going back in time before 1979, and we will 4 vant to have access to the central files.
( 5 We will finish this afternoon our 6 . examination of Dr. Womack; and if you want to 7 cross-examine him on anything that we have 8 examined on, feel free to. We, of course, 9 can't foreclose ourselves from some later time 4 10 that I don't anticipate now, asking for another 11 opportunity to depose Dr. Womack to ask him
- 12 questions about documents that we just haven't V
13 had access to previously. .
14 MR. WISE: I think we will just have to 15 proceed and see what happens. I can't tell 16 you the Court would not perm'it you to continue 17 the deposition of Dr. Womack. We will just 18 have to take that up if the time omes.
19 MR. SELTZER: I am not asking you right 20 . now. And if we did need to recall him, it 21 would only be because we felt we couldn't get
{
22 the information from somebody else who has 23 not yet been deposed. This is not going to 24 be our last deposition in the case.
25 MR. WISE: Are you at a convenient spot?
- - - . -. - - ~ = _ . _ _ - = , - . _ _ . - . . . - . - - . . - . . . - - . - - . - . - .
i 1 Womack 881 1
t 2 MR, SELTZER: Yes. Why don't we
- i 3 break for lunch and --
4 MR. WISE: We will meet back here --
b [
\ 5 MR. SELTZER: Off the record.
1 6
(Discussion off the record.)
{ 7 (Lu'ncheon recess taken at 12:20 p.m.)
8 i
9 * *
- E 3
10 .
11 12 4
- ' 13
), .
14 i i
15 t
0
! 16 17 -
, 18 19 i
l 20 i
21 22 23 i
( 24 1
25 l
t.
l
, . . , , - . . . :.--. . - - , - . , . . - .,-,,,n-__.-,_____-.._, ._ - , , - - -
f 4
1 Womack 882 2 AF TE RNOON S ES S I ON l 3 (2:15 p.m.)
4 EDGAR ALLEN WOMACK , JR , ,
5 resumed, was examined and testified further 6 as follows:
7 EXAMINATION (Continued) 8 BY MR. SELTZER:
9 Q I think you have in front of you now a
] 10 complete copy of GPU Exhibit 32, the ' report on 11 safety aspects of the Mulheim-Kaerlich plant in view
- 12 of the Three Mile Island-2 accident, right?
I,. '
I
~' 13 A I presume it now to be complete.
14 Q I have directed your attention to the 15 page that is numbered at the bottom 4.2-4. Do you 16 have that?
17 A Yes. .
18 Q There is a reference at the beginning i 19 of that page to "The relief (or blowdown) valve at i
20 MK."
21 Is blowdown a word that is synonymous 22 with relief for certain purposes?
23 A I think that's correct, yes.
24 Q Blowdown means it's relieving or letting 25 down pressure?
1 Womack 833 2 A Yes.
2 l
3 g when it states on this page, "The relief 4- (or blowdown) valve at MK is also a PORV (Figure D-8).
5 while it is a different design from the one used 6 at TMI-2, the possibility of failure of the valve 7 to close properly cannot be eliminated nor can 8 failure of its control circuits. However, the MK l
I 9 design has pressure tap connections which make 10 possible a more direct indication of proper closing 11 of the valve." What do y'u understand is meant here 12 by pressure tap connections"?
4 CE) 13 A I don't really know what's meant by pressure l
, - 14 tap connections here. I presume that this would ,
15 mean some auxiliary connections to the valve other ,
16 than the main flow connections.
! 17 g would the pressure tap as'you understand 3
18 it be downstream of the valve?
l 19 A I don't know.
20 Q If it were going to indicate flow i 21' through.the valve, wouldn't it have to be downstream i
l 22 of the valve?
23 A well, if the intention here is to indicate l
) 24 that'there is a -- that there is a pressure drop 25 type flow indicator in the line of this valve, it
-~v- ,- - - - - - ~e- , , --,,rw , , , , , , . - w,-w -,-w- -wr----, en,w- m-- g- w mam rw ,,wg--m,-nwen~.g-, n uw-n-e vr.-en------m-m - - , -
1 Womack 884 O
V.
2 could be really pl' aced anywhere because the flow 3 into the valve and the flow out of the valve has 4 to,be the ;
same when a-the valve is actually passing 5 flow, so it could be either place.
'~,
- - 6 Q So you are saying that.the pressure 7 ',,B tap which would'make possible a direct indication 8' of proper closing could either be in the valve or
. f ,,
r -
9 dow,nstream of the valve?
r - 10 AS> It ' s p o's'sibl e , yes. ',
v ,
,g
',, 11 Q' Is,there any other place it could be?
r 4,
12 Ae If the pressure -- if one were to undertake
\ f
<\) ,
13-
?
to provide a p'ressure drop type flow measurement, 7 , ,
i 14 one could put it i across the valve or.one could put 15 it in any of the lines which lead into or out of 16 ths valve along with the necessary additional 17 equipment to make it function, I suppose.
18 Q Were you aware prior to reading this 19 report, GPU Exhibit 32, that there was a pressure 20 tap connection on the MK plant that made possible a 21 more direct indication of closing of the PORV?
22 A I don't know whether I was or not. I don't 23 recall being conscious of that specifically.
+
(~)
(_) 24 Q The text on page 4.2-4 continues, 25 "Furthermore, the PORV block valve is controlled by
1 Womack 885
/'N r 4
~
2 the RPS rather than depending on operator 3 recognition and action."
4 What does it mean that the block valve
( 5 is controlled by the RPS?
6 A I understand that to mean that the e16ctrical 7 control equipment which is considered a part;of the 8 reactor safer _y or protection system includes the 9 control of this valve at Mulheim-Kaerlich.
10 Q Under what circumstances *would thc' 11 safety or reactor protection system actuate a 12 closing of the block valve?
4
'- J 13 A well, I am not sufficiently up.to date on a
14 the details of this to know, but my recollection is
- 15 that those control variables were described elsewhere 16 in the report.
17 Q would'you'take a look at page 5.4-1 18 also numbered in the margin E-5690.
19 Is this the description that you recalled?
i 20 A Yes, I think this is the description that I i
21 recalled.
22 Q And on this page it described the 23 conditions in the reactor coolant system which would 24 signa'l automatic closure of the block valve?
25 A Yes, that appears to be correct.
1 1
1 Womack 886 O
V 2 Q On page 5.4-1 the authors have described 3 the function of the PORV in the MK plant.
4 Do you see that?
5 A Yes.
~
6 Is that function substantially the Q
7 same as the function of a PORV in the Three Mile 8 Island Unit 2 and in other B&W plants constructed 9 in the United States?
t 10 A As I understand it, those valves serve these 11 same functions in the United States.
12 (g Q And the functions that are described
%.)
13 here are, one, reducing the frequency of challenge 14 to the code safety valves, and, two, reducing the 15 frequency of reactor trips; is that rig.ht?
16 A Yes.
17 On the same page where it describes Q
18 the circumstances under which the block valve would 19 be signaled by the reactor protection system to 20 close, are there system conditions listed which would 21 have signaled the TMI-2 block valve to close if
{
22 this kind of protection system had been installed 23 in TMI-2 the day of the accident?
A
- 24 MR. WISE: Could you read that back, 25 please.
1 Womack 887
.J 2
(The record was read.)
3 MR. WISE: I am afraid I am not sure 4
I understand your question. Are you asking 5
the witness to assume certain conditions at 6
TMI-2 based on what he has read? What are 7 you'asking'the witness to assume in order to 0
answer that question?
9 MR. SELTZER: There are five conditions 10 under which the reactor protection system 11 would signal closure of a block valve.
12 MR. WISE: In the MK plant.
13 MR. SELTZER: Right. And those are .
i '
14 listed on page 5.4-1.
15 Q Right, Dr. Womack?
16 A Yes.
17 Q I am asking you, to your knowledge, 18 which if any of those five conditions existed in 19 the Three Mile Island Unit 2 following the failure 20 to close of the pilot operated relief valve on 1
( 21 March 28, 1979?
22 A well, the conditions which are designed into 23 the automation of this particular valve in this O
(_) 24 particular plant are listed here qualitatively 25 except for one temperature set point. I am not --
I
--r--. , ,,,-n-. -,n -. - .-. , - . . _ , , , . . , . - -
1 Womack 888 O
N/
2 have not reviewed this or studied it sufficiently 4
3 to know which of these conditions would have 4 existed when. However, I believe it's asserted
( 5 elsewhere in the report that one or more of these 6 conditions might have been encountered in a similar 7 accident in this plant.
8 Q When you say, "this plant," which plant 9 do you mean?
10 A Mulheim-Kaerlich. .
4 11 Q And did the system actuate automatic 12 closure of the block valve?
l 7x N_
13 A No, I think that I meant that in hypothesizing 14 a similar accident from Mulheim-Kaerlich I believe 15 the authors assert that these conditions would ,
16 have been reached.
i 17 Q In other words, in hypothesizing the 18 occurrence of the TMI-2 accident in a plant having 19 Mulheim-Kaerlich's reactor protection system, one 20 or more of these points calling for automatic 21 closure of the block valve would have been reached?
22 A I believe that's asserted in this report, yes.
23 Q Let me ask you to turn to page 5685.
24 Does that page contain the statement 1
f l 25 that you were just referring to?
l l
I - - - _ , --_.,,m. . _ -
1 Woma,ck 889
.(~h G
2 A Yes, I think that's the statement that I 3 remember, 4 Q In other words, according to this 5 report in GPU Exhibit 32,the reactor protection 6 system that is in the Mulheim-Kaerlich plant would 7 have generated a signal to close the block valve 8 at two minutes into the accident?
9 A Yes, that's what is asserted here.
10 Q In other words, at least hne of the 11 five conditions listed on page 5.4-1 would have 12 been reached by two minutes into the Three Mile t
\J 13 Island accident?
14 A That's an extrapolation of what's said, but 15 I believe that's a fair extrapolation.
16 Q The statement on page 5685 also 17 numbered 4.2-9 is as follows:
18 "The TMI-2 PORV block valve has no r
19 automatic function. It is equipped with a remote 20 actuator and can be repositioned by the operator 21 from the control room.
22 "The corresponding MK valve is 23 automatically closed by the RPS in response to 24 appropriate signals to ensure that a failed relief 25 valve is isolated in a timely fashion. At TMI-2,
1 Womack 890 m s 2 this valve was closed at approximately 140 minutes 3 after the start of the accident. The MK protection 4 system would have closed the valve at 2 minutes 5 into the accident."
6 Looking at the list of five conditions 7 which would call for automatic closure of the block 8 valve, there is a certain amount of redundancy -
9 built into that list, isn't there?
10 A There appears to be some redundancy, but 11 presumably they were designed to cover different p 12 functions. ,
N- .
13 At TMI-2 during the accident on Q
14 March 28th, reactor coolant pressure fell, didn't 15 it? ,
16 A so I understand.
17 Reactor coolant hot leg temperature Q
18 fell, didn't it?
19 A Yes, as I understand it.
20 Q Containment pressure went up?
( 21 A I understand that also happened, yes.
22 Q It's also true that containment 23 temperature rose; isn't that right?
24 A That I think that happened to some degree, 25 yes.
1 Womack 891
(
'%s 2 Q So depending on what the trip points 3 were for automatic closure of the block valve, any 4 of those four conditions might have called for 5 automatic closure under the MK reactor protection 6 system, right?
7 A Depending on what the initiation set points 8 were. -
9 Q Is there anything in this report that 10 indicates what the initiation set points are?
11 A I don't remember.
s 12 According to this report, if the Three Q
( )
\/
13 Mile Island plant had been equipped with the t
14 Mulheim-Kaerlich reactor projection system, the 15 core uncovery that ensued at Three Mile, Island 16 would not have occurred; isn't that correct?
17 A I don't think that's a conclusion ^that this 18 report makes. This report makes the conclusion that i 19 a TMI-2 type accident in this Mulheim-Kaerlich 20 plant would have had certain automatic actions 21 because of the particular design and design
{
22 philosophy of this plant which would have, in the 23 hypothetical case treated here in the comparison, 24 led to different plant performance.
j 25 Q one of the differences in plant
1 Womack 892 i
L/
2 performance would be that the block valve would 3 have been closed, right?
4 A That is asserted here, yes.
5 Q The Three Mile Island --
6 MR. WISE: Excuse me.
7 What is asserted here?
I 8 THE WITNESS: That the block valve would - '
9 have been closed in a similar hypothetical --
in 10 a hypothethical accident similar to the TMI-2 11 accident should it have occurred in the es 12 Mulheim-Kaerlich plant.
s 13 A That's what I understood you to mean, right?
14 Q Correct 15 A Good.
16 Q There is no doubt in your mind, is there, 17 that if the block valve had been closed *at TMI-2 18 at two minutes into the accident, other things 19 being unchanged, there would not have been an 20 uncovery of the core; isn't that right?
21 MR. WISE: I will object to that as
{
22 hypothetical and does not give the witness 23 enough facts in order to enable him to answer.
O
\_/ 24 I will permit him to go ahead and answer as 25- best as he can, but my objection is noted.
1 l
l 1 Womack 893 N~)- l 2 A I believe that all else being unchanged, an 3 early closure of the block valve at TMI-2 should 4 have prevented the loss of cooling to the core.
5 g certainly closing the block valve at 6 two minutes into the accident would have preserved 7 effective core cooling; isn't that right?
8 MR. WISE: I will make the same objection..
9 A I think that with the same qualification, my 10 answer would be the same as I made bdfore.
11 g Namely, yes?
- 12 A Earl'y closing of the block valve would have
(_) 13 preserved core cooling.
14 Q All I am trying to establish is that 15 two minutes is early.
J 16 A Oh, I would agree that two minutes is early.
17 g on page 4.2-4, which is also numbered 18 5680, the last sentence states, "The existence of 19 such a valve control on TMI-2 would have significantly 20 changed the course of the TMI-2 accident."
21 In light of what we have just been
{
22 discussing about how the MK plant's reactor protection
~
23 system works and that it would have closed the block 24 valve at two minutes into the accident, if 25 hypothetically such controls had been in place, do
1 Womack 894
~
(l). you agree with the sentence that I just read?
2 3 THE WITNESS: Could you read that back, 4 please.
5 (The record was read.)
6 A I think I would simply say again what I said 7 earlier, that an early closure of that block valve 8 with all else being ecual would have led to or should ,
9 have led to the preservation of cooling, in cooling, 10 and I would say that would have been'a significant 11 change in the course of the accident.
7s 12 Q If the block valve had been closed at
~ 13 TMI-2 at two minutes into"the accident, from your 14 knowledge of the sequence of events, would the 15 valve have even begun to pass water as opposed to 16 steam?
17 A Which valve? .
18 Q The PORV or the block valve.
19 A I don't really know.
20 Q so it's conceivable that if the block 21 valve had been closed at two minutes, there might
{
22 not have even been water in the drain tank?
23 A It's conceivable, although the drain tank t
o t
s_) 24 would condense into the steam that is passed.
25 since steam is water and it condenses, there probably
I 1 Womack 895
~
(~h R.)
2 would have been water in the drain tank.
3 Q From your knowledge of the MK system, 4 if the block valve is closed two minutes into the 5 accident and everything else functions as it's 6 intended to, would the reactor even be tripped 7 off line?
8 MR. WISE: Under what circumstances? .
t 9 A In what set of circunstances?
10 Q A loss of feedwater trans'ient.
11 A In which you -- are you making the further
,_ 12 assumption that the pilot operated relief valve I' ')
13 remains open?
14 Q Remains open, right.
15 MR. WISE: And this is a loss of all 16 feedwater or the loss of only the regular 17 feedwater? -
18 MR. SELTZER: I guess we better 19 hypothesize loss of all feedwater.
20 A The reactor would have been tripped off 21 line at Mulheim-Kaerlich.
22 Q Why wouldn't the PORV keep relieving 23 pressure so that the system did not reach the 24 pressure trip point for reactor scram?
25 A The PORV is not sized to relieve sufficient
r 1 Womack 896
[)
~
quantity of gass to significantly delay the reactor.
2 trip.
3 4
Pardon the split infinitive.
( 5 Q will y u take a look'at page 2.3-5, 6 please, which is numbered 5523.
7 A 5523.
g Q This is in the section of GPU Exhibit 32 .
9 called " Description of the TMI-2 Accident."
10 In the middle paragraph, do you see the 11 sentence that begins, six lines down, "Also starting 12 at 1 minute"?
13 A Yes, I see such a sentence.
14 Q It states there, "Also starting at 15 1 minute, indicated pressurizer level starts to 16 increase and goes off scale (400 inches) at about 17 6 minutes, presumably going solid shortly thereafter."
18 Am I correct that the pilot operated 19 relief valve is at the highest point in 'the pressurizer" 20 A I believe that's correct.
21 Q Up until six minutes, according to this, 22 the TMI-2 pressurizer had not gone solid, right?
l 23 A That's what this says, yes.
Q Therefore, up until six minutes the 24 25 pilot operated relief valve was only experiencing
1 Womack 897
-.Q:[)
2 steam flow, right?
3 A- well, that is a conclusion you can draw from 4 this.
5 g would you draw it? I am more interested 6 in what you would draw from it than what I would 7 draw.
8 A I think I would want to look more carefully -
9 than this, but as I think we discussed earlier, it 10 is certainly possible that and proba$1y likely that i
11 the PORV passed steam only in the early portion, l
~
12 early minutes of this transient.
13 g ,
In other words, up-until.the time when 14 the pressurizer went solid, it was passing steam
, 15 and after that it was passing water? .
16 A well, one of the problems I have with this is i 17 the definition of the term'" going solid." I think
[ 18 we must imagine the pressurizer as containing, 19 particularly in its upper portions with a --
with 20 an open valve in the top, containing a mixture of l
21 liquid and vapor, and the definition of " going
{
22 solid" th'erefore is, if you will permit a pun, a f 23 little bit frothy.
8
- q,) 24 g If this description is accurate, would .
I 25 this refresh your recollection that at two minutes i
t
I womack 898 h(J -
2 into the accident the pilot operated relief valve 3 would have been passing just steam and not water?
4 A It is likely that, as I said earlier, it's
( 5 likely that at two minutes the pilot operated 6 relief valve is still passing steam. That's very 7 possible.
8 Q Frca your work at B&W and on the MK plant , .
9 when, to the best of your knowledge, was the reactor 10 protection system for automatic closure of the ,
11 block valve designed?
12 i A I don't know when the design that included O)
\
13 these features was actua11y'put into. place.
14 Q Just to give somebody a sense of 15 scale, by what date would you say it was certainly 16 done before this date?
17 A I am really not sure. The reactor protection 18 system design requirements from the German customer 19 are of course substantially different from those 20 in the United States, and I suspected that --
I 21 suspect that the design,which was to a large extent 22 done in Germany, departed early from the design of 23 U. s. customers, but I really don't have a time f
) 24 scale in mind. I don't recall myself becoming aware 25 of this specific difficulty we have discussed much
4 1
Womack 899
,ex
\
2 earlier than the time period around TMI-2.
3 Q When was your last day-to-day involvement 4 in the --
( 5 A Mulheim-Kaerlich plant?
6 Q -- Mulheim-Kaerlich plant?
7 A I had a day-to-day involvement in the 8 Mulheim-Kaerlich plant as a project manager up until 9 I took the plant engineering section in August of 4
10 1978. .
11 Q How long prior to August 1978 had the s
12 principal design work on the NSS been completed?
f-
' I
\_
13 A Which NSS7 14 Q Mulheim-Kaerlich, 15 A Oh, I think design work to meet evolving i '
16 German requirements and customer needs was going 17 on continually in the period with which I was 18 affiliated with the project.
i 19 g who was principally responsible for 20 development of the reactor protection system?
21 A BBR.
22 Q Is there any gentleman in BBR who you'd 23 say would be the most knowledgeable person on 24 features of the reactor protection system?
25 A Yes, there are several such people. As an
l 1 Womack 900
/~'s ~
U 2 overall management level engineer I think Dr. Peter 3 Wirtz would have been knowledgeable.
4 Q If you wanted to find out more about 5 the design of the reactor protection system to close
'6 the block valve automatically on the MK plant, who i
7 is the person that you would get in' touch with?
8 A Probably Dr. Wirtz.
9 Q Is he still with BBR?
10 A Yes, he is. t i
11 Q Where is his office?
12 A In Mannheim.
O b 13 Q, . Does he speak English?
14 A He speaks English.
15 Q Have you ever spoken with anybody about 16 the fact that the MK plant has provision for 17 automatic closure of the block valve? -
18 A Yes.
19 Q Who?
20 A I have spoken with counsel.
21 Q Anyone else?
22 A I have probably mentioned it in casual 23 conversation with others. I don't have specific 0) g
, 24 recol'lection of those conversations.
25 Q Have you ever discussed it with Dr. Roy?
, . , - - - . -.- -- .- , , , -- .., ,-- ---,.c--a- u. - - , ,, , . - . ~ - ,
1 Womack -
901
\_
2 A I can't recall.
3 Q Have you ever discussed it with John 4 MacMillan?
( 5 A I can't recall.
6 Q You mean not to the best of your 7 recollection?
8 A Not to the best of my recollection; not to 9 exclude that it might have happened.
10 Q Do you have any idea whed in time the 11 decision was made to include automatic closure of
- 12 the block valve in the reactor protection system
%./
13 for the MK plant? .
14 A I really don't. I believe the differences in 15 design requirements existed early in my familiarity 16 with the project. So, it could have been at any time.
17 Q Are there other features in the 18 Mulheim-Kaerlich plant which if they had been 19 installed in Three Mile Island-2, other things being i
20 equal, would have prevented the accident from 21 proceeding to the point of core uncovery?
{
22 MR. WISE: I will note for the record 23 an objection to the form of the question. It f3 Am ,/ ' 24 has not been established that the block valve 25 actually would have prevented a core uncovery.
1 Womack 902
(~)
\.)
2 A There are certainly --
3 THE WITNESS: May I answer?
4 MR. WISE: You may.
( 5 A There are certainly other different features 6 of the Mulheim-Kaerlich plant springing'from the 7 different requirements of the German customer with 8 respect to the role of the operator in transients.
9 Some of tnene might have affected the course of a 10 similar accident or an accident initiated by a 11 similar set of circumstances had it occurred in 12 the Mulheim-Kaerlich plant.
(- -
13 g, That's exactly what I want you to focus 14 on.
15 What is it in the MK plant that would 16 have prevented the gory consequences?
17 A I don't know that I can focus on specifics.
18 I think that's the thrust of this report and 19 perhaps you can call out other areas of this report 20 which discuss that. But the general difference in 21 philosophy that exists in Germany has to do with the
{
22 philosophy of the operating utility in Germany 23 with respect to the role of the operator, which we 1 24 have discussed earlier in this deposition, and that 25 philosophy requires,at his request,a higher degree w-e n2 --ge o m- -
?
1 Womack 903
~
(N LJ 2 of automation than is preferred and desired by 3 utility customers in the United States, specifically 9
4 a requirement that accidents proceed to a 5 conclusion without taking credit for operator 6- action during the first 30 minutes of the accident.
- 7. A That is a criterion for design of 8 German plants?
9 A Yes. Which leads to design differences between 10 German plants a.id plants designed for. united States 11 utilities who seem to have a different view about 12 their desires with respect to the operator's
(
N- ) 13 involvement.
14 Q How do you know they seem to have 15 different views? Whose views are you reflecting ,
16 when you say that?
17 A Based on the --
based on my interaction with 18 representatives of our utility customers where the 19 questions of installing automatic equipment versus 20 the questions of -- versus allowing the operator to 21 make judgments are concerned, the utilities with 22 whom I have interacted generally prefer to allow 23 the operator the freedom of taking the actions
. O -
l t ,/ 24 and which may be needed in a reasonable time to 25 terminate transients.
_ _ . _ . _ ___ . _ _ _ _ . ~ . ,__ _
s 1 Womack 904
-s \ -
(
2 Q It sounds like you get into a very 3 Miltonic discussion with people about free will and 4 controlling human destiny.
5 A I don't think it's necessary to get into a 6 Miltonic discussion. It's only necessary to look 7 at the degree of automation which is achieved in the 6 industry for pressurized water reactors.
9 Q Let me ask you specifically, can you 10 identify the utility official with whom you were 11 speaking who told you that he preferred to have 12 operators be able to intervene to arrest a transient O'" 13 rather than have equipment automatically arrest a 14 transient?
15 A Well, I am not so sure I can identify a 16 name and a subject. That is an opinion formed by 17 a number of interactions plus interactions with 18 others of my colleagues.
19 Q Are you saying that you cannot name a 20 single utility official who has espoused that 21 point of view?
22 A I am not saying that I cannot name such a 23 person --
b6
(_) 24 Q I would like you to, then.
25 MR. WISE: I would prefer that you
i 1 Womack- 905 ey -
,V -
2 would let the witness finish his answer 3 before you interrupt him with another 4 question, Mr. Seltzer.
(- 5 MR. SELTZER: It's the same question.
6 MR. WISE: It's not, and I would prefer 7 that you not interrupt my witness when he is 8 speaking.
9 A I haven't tried to test my menory in this 10 general area, and I will spend some time thinking 11 about it.
12 Q Please do. But I want to know, just O 13 focus your thinking, I want to know the name of a 14 utility official who has told you that he would 15 prefer to have the operators free to intervene to 16 arrest a transient rather than having equipment 17 there automatically to arrest a transient.
18 MR. WISE: The witness neve testified 19 that anybody said that to him in those words.
20 He testified to an opinion that he has formed 21 over a period of time in the course of his 22 employment interacting with various officials.
23 If you want something more than that,
( 24 you may pose a question and see if the witness 25 can answer it. He is not required to
1 Womack 906
,en .
N 2 necessarily come u'p with a name of an individual who 3 said specifically the words that you put into
'4 somebody's mouth.
( 5 A I think in the course of replying here the 6 best thing that I could do to illustrate what I 7 have been talking about is simply point to the 8 difference between a standing written rule in 9 Germany which requires automation out to this 30 10 minute period and the absence of such.a rule from 11 the regulatory authorities in the United States, 12 and a certain degree of discussion over the years 7s t i
, t) 13 in industry groups and with the regulatory authority 14 about what is a period of time at which operators 15 should -- operator action should be credited in 16 safety actions.
17 Now, I would have to go back and 18 research to some extent the industry written record 19 on this subject, but I am quite confident that that 20 research could be done.
21 Q Are you saying that as you sit here now, 22 you cannot identify a single manager from a 23 United states utility who has said in words or O
(_, - 24 substance what I asked you to recall?
25 MR. WISE: Identify by name, rank and
1 Womack 907 2 serial number; is that your question?
3 MR, SELTZER: I don't know whether he 4 has a serial number and I wasn't even asking 5 for rank. I don't think your snide comment 6 helps.
7 MR.' WISE: I object to that sort of 8 comment.
O MR. SELTZER: I withdraw it.
10 A As I said, an illustration of t'he sort that 11 you are requesting with the precision that I would 12 want to have in order to mention a person's name
' O 13 doesn't come to my mind, but I have no question 14 that, as I said, that the written record of industry 15 discussions on this subject will bear out what I 16 have said. -
- 17 Q Where would you look for this written 18 record of industry discussions?
19 A well, I think I would look at standards 20 groups, which have discussed operator role, which i
21 have discussed periods of time for taking credit 22 for operator action in response to accidents. I 23 would look, if I wished to look farther, I would 24 look with -- at the whole series of contract 25 discussions with all -- between all vendors and i
- - _ - . - - - , - . - . . , ~ , , - - . _ _ , . - _ - - - - _ - , - . - - - - . - - . - , _ _
1 Womack 908 y-m
\_/-
2 their utilities. I would look at the control rooms' 3 designs which have resulted in the industry and I
4 their degree of automation.
5 g Would there be names written in the 1
6 control room,who proposed this?
7 A The names of the people who had those 8 responsibilities and who made decisions associated 9 with that certainly are traceable for those plants.
10 Q Well, do you know for a ipet that B&W 11 has ever offered to an American utility the type of 12 automation of control of transients for the first s
13 half. hour that is installed in the Mulheim-Kaerlich
- 14 plant?
15 A No, I don't know that for a fact.
- 16. Q Have you ever had a discussion with 17 any American utility prior to the Three Mile Island I 18 accident regarding the possibility of installing i
19 controls that would handle all transien s for the 20 first half hour without human intervention?
l i
21 MR. WISE: I don't know that it's been 22 established that Dr. Womack was in a position l
23 prior to the Three Mile Island accident to
/~
(_T) 24 have had that sort of discussion. With I
f 25 that qualification I will permit the witness
i l
l 1 Womack 909 2 to answer, if you just want whether or not 3 he personally has had such a conversation.
4 A No, I don't believe I had such a conversation.
.( 5 Q Have you had a conversation with anybody 6 at the NRC regarding the desirability of installing 7 automated control of transients that would obviate 8 the need for human intervention during the first t
9 half hour of any transient?
4 10 MR. WISE: This is at any time up until 11 today?
12 A As a general criterion? I think I have
/O
- \J 13 mentioned in the course of conversation with NRC 14 colleagues. perhaps this difference in design 15 philosophy which exists in Germany to the extent 16 that I believe that this is well known to the -- to 17 at least some of'the Nuclear Regulatory _ Commission, 18 because they do have a continuing dialogue at the
~
19 highest levels with the German regulatory authorities.
20 -With respect to specific conversations which I might og have made such a declaration, I don't recall having 22 made such a declaration.
- 23 g With whom at the NRC have you had such e nyersations?
(O.) 24 i 25 A Well, I can't be sure that I could, you know, i
d
- , - - , - . -, , . . . , , - , _. r-~ .- e ,- ,- ,n. - - , ,
1 1 Womack 910
-~ -
2 focus individual conversctions; however, the 3 German Reactor Safety Committee, representatives 4 of the German Reactor Safety Committee, which is
.( 5 . the German counterpart of the NRC's Advisory 6 Comnittee on Reactor Safeguards visited the
, 7 United States not long ago and they had conversations 8 covering the broad range of subjects with members 9 of the NRC staff-and members of the ACRS and in my 10 presence at least with -- one member!of the --
or 8
l 11 one member of the ACRS.
12 -
Q Michaelson?
13 A No, Michaelsen is not a member of the ACRS.
14 Mr. Ebersole.
15 Q During that discussion in your presence 16 was the. desirability of having the plant automatically 1
17 control a transient for the first half hour discussed?
18 A Not explicitly in that way, but I think that 19 there were --
I believe there were discussions --
there 20 was discussion of differences in approach, which 21 would go to this fairly fundamental approach to i 22 automation.
i \
23 Q Have you had any such conversation or
( 24 been p~ resent at any such conversation regarding 25 completely automated control of a transient for the d
--,-w,. .,w%- ,.. --r,,,., -,-,...e--,- ...4 -~. .,- -- m . ,.--r.--.,e-,,.- . . - . -
1 Womack 911
~
[)
U 2 first half hour?. Have you had any conversation 3 like that with anybody from the NRC or its predecessors 4 prior to the Three Mile Island accident?
. 5 A I don't recall having had such conversations 6 or nuch a conversation.
P 7 Q Have you discussed with anybody from the 8 NRC the fact that Mulheim-Kaerlich has provisions in _
g its reactor protection system for automatic closure 10 of a PORV block valve? (
11 A I don't recall whether that's been explicitly 12 discussed with the NRC or not.
(~h .
\-) -
Q Do you know whether prior to the Three 13 14 Mile Island accident B&W ever offered.such automatic 15 control of the block valve to any of its United states 16 customers?
! 17 A No, I don't know. .
l 18 Q Do you know whether since the Three 19 Mile Island accident B&W has offered such control I
20 to any of its United States customers?
21 A Yes, as a follow-up to NRC requests in this 22 regard or suggestion in this regard in order to 23 restore,.or as a part of the program to restore
( 24 the pilot operated relief valves to the operational 25 bjectives which allow it to help to avoid
I 1 Womack 912 2 challenges to the reactor protection system we 3 have suggested automatic block valve closure.
'4 Q Where does that recommendation stand 5 now?
6 A I can't tell you today. I believe it's been 7 given to our utilities and certainly has been 8 discussed with the NRC. .
9 Q Did BBR take a more assertive role in 10 the design of the emergency feedwateE, system for 11 the MK plant than B&W took in the design of 12 emergency feedwater for the Three Mile Island Unit 2?
, 13 MR. WISE: I don't know it's been 14 established that this witness has any 15 qualification to speak about what role B&W ,
16 took with respect to the design of the i
17 emergency feedwater system at TMI-2. I don't
, 18 even think he was employed by B&W at that time.
19 MR, SELTZER: I think he has come to I
20 know.
21 MR, WISE: I don't know whether he has 22 or not.
23 A No, I don't really feel qualified to answer 24 the question exactly as you asked it for the reason 25 that counsel has stated. BBR has a different
1 Womack 913 2 contracting arrangement, however, than B&W with 3 respect to the Mulheim-Kaerlich plant.
4
- Q Are you aware that the emergency or 5 auxiliary feedwater systemifor MK is classified and 6 designed as a safety system?
7 A Yes, I am.
8 Q The emergency feedwater system for -
9 TMI-2 is not designed as a safety system, is it?
10 A I am not exactly sure what requirements 11 and how classified the system was at that time.
19 I believe, however, that the classification and 13 design of these sys'tems did become a practice and 14 requirement in U. S. industry,after the TMI-2 s
15 design was complete'.
1G Q In the design of the MK plant there are 17 provisions, are there not, that would prevent an 18 operator from easily overriding emergency safeguard 19 systems?
20 A Yes, I believe I have been told that. It may 21 not be so much provisions as an outgrowth of again 22 the strategy which relates to,the operator's s
23 .
response to transients.
- i k,m,) 24 (Continued on following page.)
I f
6
i 1 Womack 914
~
O 2 g Do they have anything like a key lock 3 pass to limit the circumstances in which an operator i
4 ! can override the systen?
5 A I don't recall that detail. It may be in 6 this report.
7 MR. SELTZER: I would like to mark for 8 identification as GPU Exhibit 38 -- -
3 9 MR. WISE: Off the record.
10 (Discussion off the recoNd.)
11 (A recess was taken.)
12 BY'MR. SELTZER:
n,-
13
'. Q The last time we were together you were 14 enlightening us that SMUD was not a dirty word but 15 the acronym for ene of B&W's estemed c u,s t om e r s ,
16 right?
17 ' A SMUD is an acronym for the Sacramento 18 Municipal Utility District which is the utility 19 that owned a B&W reactor.
20 MR. SELTZER: I would like to mark for 21 identification a memorandum from E. A. Womack, 22 the new Manager of Plant Design, to B. A.
23 Karrasch, Manager of Plant Integration, i
d yj 24 subject: SMUD Rapid Cooldown Transient, y s 4 25 August 21, 1978.
1 Womack 915 2 (Memorandum dated August 21, 1978 3 from E. A. Womack, Manager, Plant Design, to 4 B. A. Karrasch, Manager, Plant Integration, 5 marked GPU Exhibit 38 for identification, 6 as of this date.)
7 Q Is GPU Exhibit 38 a copy of a memorandum 8 which you sent to Mr. Karrasch in the regular course .
9 of business on or about August 21, 19787 10 A Yes, it appears to be.
11 Q what was the initiating event in the 12 SMUD rapid cooldown transient?
f3 13 A I think this was a power supply failure and 14 brought about by a, if I am placing the right 15 transient here, I think this wt.s brought about by 16 a short caused by an operator who was performing 17 maintenance, I think changing a light bulb in the 18 instrumentation system.
19 Q He dropped a light bulb and it shorted 20 out the panel?
21 A That's my recollection of this.
22 Q You state in the first sentence to your 23 manager of plant integration, " Based on our discussion
/O
(_f 24 last week, I understand that you will put together 25 a small group of key designers to review the SMUD
i 1 Womack 916 (m
2 rapid cooldown transient and brainstorm what could 3 have been done or what could be done in the B&W 4 NSS/ Plant Design to reduce the likelihood or limit 5 the consequences of such an event in the future."
6 You went on to say, "As we discussed, 7 I believe that events such as this and the 8 Davis-Besse 1 blowdown contain important feedback .
4 9 for us regarding our designs."
10 Is it correct that the Da'vis-Besse 1 11 blowdown that you' referred to is the September 1977 s 12 transient?
13 A It probably was, yes. I am not sure which 14 one -- what it was, but it probably was that one.
5~
15 Q And the September 1977 transient was 16 when the pilot operated relief valve cycled several 17 times and then failed open?
18 A Yes, I now know a great deal more about it 19 than I did then.
20 Q what did you mean when you told Karrasch 21 that you believe that events such as this SMUD and
(
22 the Davis-Besse blowdown contained important feedback 23 for us regarding our designs?
24 A well, I meant simply that by looking at the 25 kind of abnormal things that might be happening in
, _ - _ , - -. _ - . . - _ _ _ . . _ _ , , , _ _ _ , , , , _ - ,, , , , _ , , , . . ~ . . , ,, ,,,y-.-_ _ . - - , , _ _ . , - -,,
f 1 Womack 917 78 -
2 our plant and by really trying to understand them 3 and seeing what could be sifted out of them, there 4 I was something that we might learn,that there were
' 5 things that we could conceivably learn which could 6 help us to make our future plants operate better.
7 It's a view I have always held.
8 And you prefaced that second sentence Q -
9 with the words, "As we discussed, I believe,"
10 et cetera. -
11 A Right.
12 Q Is this something that you had previously 13 discussed with Mr. Karrasch?
14 A Apparently. The idea of trying to have key 15 designers look at particular events in the future 16 I think was what was discussed.
17 You asked Karrasch to put together a Q
18 small group of key designers --
19 A Yes.
20 Q -- to review and brainstorm.
21 Did Karrasch put together such a group?
{
22 A No, I don't believe that prior to the work we 23 did in the midsummer of 1979 that this really followed p)
(, 24 up, that this idea was really followed up.
25 Unfortunately, this was a number --
one of a number
,~w . - - - . - c, r-w.~- - .e--, --- . - - -
~
1 Womack 918 s -
2 of ideas and which -- for which we did not have 3 direct support from our customers to do, and so it 4 came into the category of initiatives to try to get
( 5 underway and we undoubtedly would have gotten it 6 underway in any. case, but we did in fact put in 7 place something like this, a transient assessment 8 program in 1979. .
9 Q Under what circumstances do you believe 10 you first learned of the Davis-Besse blowdown or
~
11 loss of coolant accident through its PORV7
~ 12 A I learned of the transient when I was working U,s 13 on the Mulheim-Kaerlich responsibility as a project 14 manager.it had caused some, and I believe I 15 recall it had caused some damage in the insulation 16 because of the actual expulsion of the steam, and 17 I think at the time it was of interest to some 18 of the -- our German counterparts, and I may have 19 been the conduit to pass information from some of 20 our people to the German -- to my German colleagues 21 at that time.
22 At any event, about that time was when 23 I learned of the transient.
24 Q How soon after the September 1977 25 occurrence of the transient did you learn of it?
J m . . , . - ~ - - - - , , - - - - ,-----c, -.,e,. - - - - = ,,-,g.
a 1 Womack 919
~3 2 A I don't recall.
3 Q How did you learn of it?
4 A I don't recall that either. Probably through 5 conversation.
6 Q Did you ever follow up on your memo 7 to Karrasch, GPU Exhibit 38, to see whether 8 Karrasch was pursuing your requests? -
9 A I am not sure whether I did or not. If I 10 did,in any event, we didn't get it high enough on 11 priority until the dates I mentioned to have
_ 12 achieved the objective here.
('3 13 Q In the last paragraph of.GPU Exhibit 38 14 you wrote, "I believe we may find by regular review 15 of serious operating incidents and operational 16 problems which have become serious because of their 17 frequency in our plants that feedback resulting in 18 a more excellent product will result."
19 I take it that was a view t at you held 20 at the time you wrote this and that you continued 21 to hold throughout the time you were manager of 22 plant design?
23 A And that I hold today.
((,f 24 Q Yes, you held it then, you continue to 25 hold it, and you still hold it?
l 1 Womack 920 2 A Yes.
3 Q And you intend to continue holding 7
4 that view?
( 5 A I found nothing in recent experience to 6 divert me from that view.
7 Q You~ concluded by saying that, "I look 8 forward to a session on the SMUD rapid cooldown 9 transient."
10 You looked forward to it'so that you 1.
11 could review the operational problem?
12 A No, that was simply.the final line in a iO
- . 13 memorandum which kind of summarized the action
, 14 that I expected that Mr. Karrasch would take when 15 - he could get to it in his other duties.
16 -Q Did you ever castigate Karrasch for 17 not putting together the group of key designers 18 and having the brainstorm sessions that you had I
19 asked for? I 1
20 A I don't know whether " castigate" is the right i
21 word. I -- my -- my inkling is that I did discuss it 22 with Karrasch and again at some later time got l
. 23 going on this idea, but I can't recall whether that
( 24 was b'efore or after TMI or whenever.
25 Q what did he say to you?
J
--4. , . --,v-,--. , , ,, ,,,,,_ _. .. . ,,,,.y ,, . , , . ,,,,__,_,..,-,,,,,_,_,m.m.,,,, __.._,-%_,m_m..__,,,,_,mm,,m,,,,,,__. . , ~ . , .
1 Womack 921 O .
d 2 A He said he was very busy and it was on his 3 list, I think, is the best of my recollection.
4 Q Is there now institutionalized within 5 B&W a program for regular review of serious 6 operating incidents and operational problems?
7 A Yes, ther~e is.
8 Who is responsible for that?
Q 9 A well, I am not sure right at the moment who 10 has the lead in this transient assessment program, 11 but it's a program which we do in cooperation with g 12 our customers.
13 MR. SELTZER: I would like to mark 14 as GPU Exhibit 39 yet another memorandum 15 from E. A. Womack, this time to K,o s ib a ,
16 Manager of Customer Service Department, 17 subject: Recommendation for " Quick Look" 18 Evaluation of'All Reactor Trips, August 30, 19 1979, 20 (Memorandum dated August 30, 1979 21 from E. A. Womack to Mr. Kosiba, Manager of
{
i 22 Customer Service Department, marked GPU 23 Exhibit 39 for identification, as of this
(_) 24 date.)
l 25 Q Is GPU Exhibit 39 a copy of a memorandum i
_ _. ._ - . _ ~ . _ - _ . . . . - _ . - - - -
~l 1 Womack 922
<w -
t 1 V
2 which you wrote in the regular course of business 3 sent to Kosiba in or about August 30, 19797 4 A I
Yes. I may have h'ad assistance in authoring
( 5 the memorandum, from the staff.
6 Q Is that your signature on the last 7 page, page 47 8 A Yes, it is.
9 Q At the time that you wrote GPU Exhibit 39, 10 B&W was getting ready to institute its quick look 11 evaluation of all reactor trips; is that right?
,- 12 A Oh, this was a recommendation to institute
^
k such an evaluation.
13 14 Q Was it subsequently instituted?
15 A After some time, yes, it was subsequently 16 instituted.
17 Q In your summary at the top of page 1 1
18 you s a y ,. "This memo describes a program to evaluate 19 the performance of the B&W NSS during reactor trips 20 at all operating plants. This analysis will produce 21 a " quick look" report which describes the cause of
{-
22 the upset, the overall plant response, and 23 recommended corrective action or further analysis 24 to prevent recurrence. Plant Design -" I presume 25 that means your group --
._ ?
1 Womack 923 fs 2 A Section.
3 Q "-- recommends that this program be 4 initiated immediately and be funded by B&W until f 5 such program is sold to the 177 Owners Group."
6 In evaluating the performance of the
'7 B&W-NSS during reactor trips, were you looking at 3 it,. were you proposing that the company should be .
g locking at it to determine whether improvements 10 should be made in the product being supplied by 11 B&W7
,_ 12 A Yes, or'in the manner in which the plant U 13 was operated or in portions of the plant which were 14 not supplied by B&W. I think that a more mature 15 understanding of this would have caused me to write 16 the performance of plants which have B&W NSS during 17 reactor trips because in many instances,a narrowing 18- of focus to the NSS doesn't produce what one would 19 like ultimately to learn from.
20 Q You said in the introduction on page 1, 21 "One of the most important lessons learned from the 22 TMI-II incident and its aftermath is that B&W must 23 be more aware of the operating characteristics and 2.
(g/ 24 problems of the NSS. The evaluation of the B&W.NSS 25 performance during transient and steady state I
.~;
1 Womack 924
[
t 2 conditions can lead to several advantages for 3 both B&W and the customer."
4 Is the primary focus on the B&W
( 5 hardware in this analysis?
6 MR. WISE: It assumes there is a primary 7 focus.
8 MR. SELTZER: Right. ,
9 Q If there is a primary focus, is it on 10 the B&W hardware? (
11 A No, I don't think so. I think --
the words
_ 12 as written here would perhaps tend to focus the 13 B&W hardware, and indeed that's the hardware we can 14 influence at least to some degree on future plants; 15 but as far as improvi'ng plant availability for 16 existing operating plants and the like, I think one 17 has to broaden the focus to other parts.of the -
18 plant and other areas of responsibility.
19 Q Why did you believe that B&h should fund 20 such a program immediately?
21 A well, I thought that it was novel to the 22 extent that our customers had not typically asked 23 for or expected this kind of response or assistance 24 from B&W, particularly the operating customers,-and 25 that we would need to fund the program in its early
1 Womack 925
(~'i
(_/
2 stages in order to provide examples of what we 3 might be able to do, hopefully so that the customers 4 could see some value in our doing it. I think 5 that proved to be the case.
6 One of the things that was perhaps 7 naive about this earlier memorandum and perhaps 8 to some extent this memorandum also is that funding .
9 alone is not sufficient to make such a program work.
10 It requires a willingness and a willing cooperation 11 and interest on the part of the utilities who are 12 operating and are responsible for the plants, and f)
(_/
13 there was no, by no means, immediate_ agreement on 14 'the part of the utilities that they wanted B&W to 15 participate in this kind of an evaluation in this e
16 way.
17 Q How do you know that? .
l 18 A Because of discussions with their representatives 19 and owners group meetings subsequent to this.
20 Q At the owners group meetings did B&W 21 ask the utilities to pay for this?
{
22 A Yes, B&W did ask the utilities to pay 23 for this since it was certainly an area for which C
(,)\ 24 we had no existing contract commitment with them, 25 but --
1 Womack 926 t'~N
\_] Are you a lawyer?
2 Q 3 A- I beg your pardon?
4 Q Are you a lawyer?
5 A No, I am not.
6 MR. WISE: Mr. Seltzer, I wish you would 7 stop interrupting this witness. Let's go back 8 to where he was in his answer, and why don't ,
g you let him finish one question before you ask 1
10 another. ,..
11 MR. SELTZER: Fine. I thought he was
, 12 finished, but if he.is not, he can continue.
/,ss N_ MR. WISE: Will the reporter read back 13 14 to the point where Dr. Womack was interrupted.
15 (The record was read.)
16 A (Continuing) I think what I was going to 17 add was that there were issues,other than funding 18 which were involved in the early discus ion of this 19 program with utilities.
20 Q When you say that B&W had no existing 21 contract commitment --
22 A That was my best understanding.
23 Q You say in the point 2 of the introduction 24 that " Potential safety problers can be pinpointed 25 and corrected before serious incidents occur."
1 Womack 927 l
2 Do you see that?
3 A Yes.
4 Q That was going to be one of the
, 5 purposes of this program, right? -
6 A That was a hoped-for goal, yes, sir.
7 Q Are you rendering the opinion that B&W 8 has no existing contractual commitment to address -
9 potential safety problems and correct them before 10 serious incidents occur? \
11 MR. WISE: I don't think that was the 12 witness' testimony at all.
3 13 MR. SELTZER: I am -asking him now.
14 MR. WISE: Well, I don't think it was 15 the witness' testimony and I don',t think that 16 your question is a fair one. I think you ought 17 to rephrase it. '
18 MR. SELTZER: I won't because he said i.
19 that for this particular program which had as 20 one of its purposes pinpointing potential 21 safety problems and correcting them before 22 serious incidents occurred, he said B&W had i
23 no existing contractual commitment. I want l
s.,) 24 to find out if that's really what he meant
! 25 to say.
i l
i 1
1 Womack 928 f\
2 MR. WISE: That's a mischaracterization 3
f his testimony and I object to it. The 4 witness' testimony stands the way he stated k 5 it and that is not what he said.
6 MR. SELTZER: He can answer my question.
7 MR. WISE: I am afraid I have lost 8 track of what your question was at this point.
g BY MR. SELTZER:
10 Q Is it your view, Dr. Womack that B&W f
11 has no existing contractual commitment to' spot 12 any potential safety problems and correcting them
\' 13 before serious incidents occur at B&W plants?
14 MR. WISE: I will object to that on 15 the grounds that he has not been qualified i 4 16 as an expert in the various contracts that 17 B&W has. It is quite different ~from the 18 question you asked him earlier, and the answer 19 that he gave concerning whether or'not B&W had
(
i 20 under contract an obligation to provide a 21 program such as is outlined in this particular l 22 memorandum which has been marked as GPU 23 Exhibit 39. That particular program, the
[) 34 witness has said, he did not understand B&W N.e i
- 25 had a contractual arrangement with its customers
1 Womack 929
( 2 to provide.
3 Now you are asking something very 4 different. You are asking what B&W's k 5 obligations were with respect to safety 6 concerns. I think that's an extremely 7 different question and one which he has not 8 been qualified here as an expert on, so that .
9 he could give an answer.
10 MR. SELTZER: Mr. Wise, I,think you are 11 not recalling my question correc.tly because
_. 12 my question previously was did B&W ask the t'
13 utilities to pay for this program, and it 14 was in response to t' hat question that the 15 witness volunteered the answer that B&W had 16 no existing contractual commitment.
17 MR. WISE: For this program?
18 THE WITNESS: For this prog am.
19 MR. SELTZER: Yes.
20 MR. WISE: That answer stands. That's 21 in the record.
L 22 MR. SELTZER: Well, one of the purposes 23 of this program was point 2 in the introduction, 24 and I want to find out a little bit more about 25 what this witness meant by no existing
... .. -. - ... - -, . -- - . = , . .- - . - ,. _ . --
1 Womack 930
'h (b 2 contractual commitment, and I want to find 3 out --
4' MR. WISE: I don't think you are asking
( 5 questions that this witness is qualified to 6 answer. -
7 MR. SELTZER: Fir.e , if he wants to 8 volunteer that, he may. .
9 MR. WISE: He has answered with respect
, 10 to this program. ',
11 MR. SELTZER: Good. Now I want my 12 question answered.
[1 -
U 13 MR. WISE: He had no contractual 14 commitment to do this program.
15 THE WITNESS: Please restate your 16 question.
17 BY MR. SELTZER: -
18 Q Is it your view based on the same 19 knowledge on which you have answered prior questions 20 this afternoon that B&W has no existing contractual 21 commitment to pinpoint potential safety problems
{
22 in its nuclear plants and correct those safety 23 problems before serious incidents occur?
-O \
(_/ 24 MR. WISE: I object to that question 25 until you lay a proper foundation for it.
1 Womack 931 rN 2 I direct him not to answer.
3 -
Do you want to establish what this 4 witness' knowledge was of contracts that are
( 5 relevant to this case? You may do so and 6 then ask him a question based upon that 7 knowledge.
8 BY MR. SELTZER: ,
9 Q Are you aware of any existing contractual 10 commitment that B&W has to pinpoint dotential safety 11 problems in B&W nuclear plants and correct them before 12 serious incidents occur?
13 A I understand commitments under a 10-CFR-50 14 on active NSS contract for which we --
for which are 15 now active and certain other commitments more 16 generally under 10-CFR-50, part 50, 55.-E and 17 10-CFR-21 with respect to potential safety problems.
18 Q But what is the commitment ith respect 19 to potential safety problems under thos regulations?
20 A To report those which meet certain criteria 21 defined in those regulations.
22 Q When you were the head of the design 23 section and in your present position of responsibility, O( j , 24 was it your understanding that B&W had a continuing
- 25 responsibility to purchasers of its plants to
1 Womack 932 f^% -
U 2- identify potential safety problems and correct 3 them before serious incidents occurred?
i 4 MR. WISE: His understanding as to C 5 what, contractual commitments or --
I don't 6 understand the import of your question. Are 7 you asking him for a legal opinion as to 8 whether or not --
9 MR. SELTZER: No, not a legal opinion.
10 Whether he felt it was B&W --
11 MR. WISE: Whether he felt it was a
,. 12 good thing to do or what?
13 MR. SELTZER: What is my question?
14 (The record was read.)
15 MR. WISE: My problem with the question 16 is when you say " identify potential safety 17 problems." Are you including or are you 18 asking this witness whether he th nks B&W 19 had an obligation to go out and demand 20 information from utilities or are you talking 21 about information that might come to B&W from 22 time to time through reading the newspaper?
23 MR. SELTZER: We,will get to all those 24 possibilities. I am asking this witness --
25 MR. WISE: I think I am entitled to
1 Womack 933 75 2 have the record clear so we have a clear 3 question posed to the witness and we don't 4 introduce the ambiguity into the record here.
k 5 BY MR. SELTZER:
6 Q Did you feel that B&W had any 7 responsibility to identify safety problems and 8 correct them before serious incidents occurred on .
9 plants that you had already_ sold?
10 A Responsibility, as I hav e stated, was what 11 I understand and understood under those regulations 12 to report safety problems or evaluate and report d 13 safety problems that came to our attention under 14 those criteria.
15 Q After a plant has been issued an 16 operating license, do you understand that those 17 regulations impose any continuing obligations on 18 B&W with respect to those plants?
19 A only as information which might meet the test 20 of those criteria that might come to our attention 21 in the course of business.
k 22 Q What is the threshold criterion?
23 A Those criteria are complex, and I am not 24 thoroughly enough versed to quote the,m for you.
25 Q But you are refreshing my recollection
1 Womack 934 (q
~)
2 that there is something about a serious nuclear 3 incident has to be reported to the NRC; isn't that 4 right?
5 A Again I am not going to -- I don't think 6 my memory would serve us well for me to try to 7 quote.
8 Q I didn't ask you to quote. Are you .
9 familiar with --
10 MR. WISE: He just said he is not 11 familiar enough to answer the question you 12 have asked.
C./ 13 MR. SELTZER: He said he.is not familiar 14 enough to quote.
15 MR. WISE: I think in the context of i
16 the two or three previous questions you have 17 asked he has told you the sections of the CFR.
18 We can all go look at them and argue as to 19 what they say.
20 Q Is it your understanding that B&W's 21 continuing responsibilities are limited to what is 22 spelled out in 10-CFR?
23 A That and its responsibilities that it undertakes k,_)g 24 jointly with its customers by some agreement, 25 contract or whatever.
i e , . - , - - , - -
1 Womack 935 2 Q Do you have any sense that a nuclear 3 plant is such a complex and potentially dangerous 4 instrumentality that a manufacturer of such a plant
( 5 has a continuing obligation to make sure that the 6 plant has been safely designed?
7 MR. WISE: I am going to object to that 8 question and direct him not to answer. You 9 are out of bounds now.
10 MR. SELTZER: What is ths, ground for
- 11. your instruction?
12 MR. WISE: The grounds are you are (2) 13 asking legal questions that are more 14 appropriately addressed to the District Court 15 and perhaps other courts.
16 MR. SELTZER: I am entitled to know 17 what the man who was head of the design 18 section believes are B&W's responsibilities.
19 MR. WISE: You and I have a disagreement, 20 Mr. Seltzer. It won't be the first time, and 21 I am sure.it won't be the last.
22 I don't think what this witness believes 23 the responsibilities were is relevant. I
() 24 think that a court of law will eventually 25 determine what the responsibilities were.
1 Womack 936 t
[/
\_
2 And if you want to ask him questions about 3 what the practice was in the industry, what 4 he understood other competitors were doing 5 and what he understood utilities believed, 6 I am perfectly willing to have those questions 7 asked; but if you want those conclusions and 8 opinions on what B&W's responsibilities were g legally, I think you are out of bounds.
10 BY MR. SELTZER: (
11 Q As.a matter of practice, has B&W felt
- 12 that it was its role to continue to examine its V' 13
~
designs to determine whether there are potential 14 safety problems and correct those problems before 15 serious incidents occurred?
16 MR. WISE: I will object to the form of 17 the question, but given the objections that 18 I have stated earlier, I will permit'the i
19 witness to answer if he can. But I do object a
20 to the form of the question.
21 If y u want to take your chances with
{
22 it, you can.
23 A To the best of my knowledge, as a matter of 24 pract' ice, B&W has always attempted to make its 25 designs respond to the needs of nuclear safety
l Womack 937
~h (G
2 as we saw them, as our customers saw them and as 3 the Nuclear Regulatory Commission saw them.
4 Q Has it been B&W's practice, to your 5 knowledge, to attempt to locate safety problems 6 in plants that have already been designed 7 constructed, licensed and placed in operation?
8 A To attempt to locate safety problems --
9 Q Safety problems affecting the design 10 of the plant. ',
11 A In the course of continuing design work and 7s 12 given similarity of design, I think the answer to t 1
%,)
13 the question would have been -- would be that we 14 have, to the best of my knowledge, always given 15 that kind of attention. To the extent that we have 16 been asked by customers to assist them in doing that 17 kind of thing, I think we have also done it.
18 I don't recall specific examples of 19 that. I am not sufficiently knowledgeable.
20 MR. SELTZER: I would like to mark for identification as GPU Exhibit 40 a memorandum
( 21 22 from D. H. Roy to EAW, the subject, Analysis 23 of Loss of Main Feedwater Flow for 177 & 205
[)
y, 24 FA Plants, dated April 5, 1979.
25 (Memorandum dated April 5, 1979 from
4 1 Womack 938 2 D. H. Roy to E. A. Womack, marked GPU 3 Exhibit 40 for identification, as of this 4 date.)
k 5 Q Is GPU Exhibit 40 marked for 6 identification a copy of a memorandum which you 7 received in the regular course of business in or 8 about early April 19797 9 A Yes, it appears to be.
10 Q Is that your handwriting'9n the last 11 page?
12 A on the last page?
7-U 13 Q I mean on page 15.
14 MR. MAC' DONALD: 1350. -
15 A No, I don't believe so.
16 MR. SELTZER: Let me correct the record.
17 off the-record. .
18 (Discussion off the record.)
19 A Your question was, was that my handwriting on i 20 page 1350?
21 Q Yes, that is the question.
- 22 A No, I do not believe it is.
. 23 Q Do you know whose it is?
((~j) 24 A No, I don't.
4 25 Q Roy wrote to you saying that the recent 4
, ., -, - - - , , , , , , ,n . -,e . , , , , , , , , .-,, , n , y ,, ,n,-----.--,-nr-m- --m- -,,.,--,,,.w~ - _..,~ , ,.- a-.. ,
4 ,
1 Womack 939
(^h
- \_J 2 accident at Three Mile raised a number of questions.
3 The first question he asked you was, >
4 "If auxiliary feedwater flow had been initiated as
( 5 normally analyzed in our FSAR's, would the operator 6 have been confronted with a filling or filled 7 pressurizer and possibly been prompted to terminate 8 high pressure injection flow if it has been initiated 9 as a consequence of a stuck open electromagnetic 10 relief valve." (
11 There is some handwriting immediately i
- 12 after that. Is that your handwriting?
13 A Yes, I believe that is my handwriting.
14 Q What did you answer?
15 A Yes, I thought that in the circumstances --
1 16 circumstance of the question I believe he was 17 asking, I had indicated apparently that we had some 18 computer analysis which would have indicated that 19 pressurizer level would probably have risen in 20 either case.
21 Q In other words, the loss of auxiliary 22 or emergency feedwater did not affect the filling 23 of the pressurizer during the Three Mile Island
'. /~N (s_- ) 24 accid'ent; is that right?
25 MR. WISE: Had no affect at all? Is
a7, I- <:
I Womack 940
- g "m s l-
- h ,, v 2 that your question?
,, e a A:
b9 3 MR. SELTZER:- I will let
!- 4 No, the question is the loss of i
Q 5 auxiliary feedwater or emergency feedwater is not 6 what caused the filling of ~ the pressurizer,'right?
7- A I don't believe that the filling of the f,'
J, 8
pressurizer would have been, averted with the 9 supply of normal feedwater. I think that's the
/ ..
' 10 sense of the question he asked, and I believe
,, 11 apparently we had some analhsiswhichindicated 12 that the pressurizer level would have, increased 13 with feedwater flow from the auxiliary feedwater
< 14 system. ,
15 g , The ne,xt question.ithat syour, boss, asked 1
16 was, " Assuming <auxiliahyf feedwater flow was delayed 17 in accordance with the TMI-2 event sequence log, would l 18 the sequence of' events have led to a. covered core et f- 19 all times if the electromagnetic relief valve had
'i 20 seated properly." ,
{
- 21 And you answered that; 'is', tha t right?
22 A .Yes, there is the note that i s o't. here which e ,,
23 again I think is in my1 handwriting, and that's wit 24 , e' ithe understan ing that the electromagnetic relief
! il 4
i 25 valve would have~ reseated and re -- contained the
( -
U < +
n
- a 1 Womack ,
941 v) 2 reactor coolant system pressure at the end of 3 whatever series of actuations it might have 4 undergone due to the extensiYe delay in auxiliary 5 feedwater.
6 Q There was an eight-minute delay before 7 auxiliary or emergency feedwater flow was restored; 8 is that right?
~
9 A That's what I understand, yes.
10 Q And you are saying that n'o twith s tanding 11 that eight-minute delay in achieving auxiliary
, 12 feedwater flow, if the electromagnetic or 13 pilot operated relief valve had closed properly, 14 the core would not have been uncovered, other 15 things being equal?
16 A At the end of that eight-minute delay if the 17 electromagnetic relief valve had^ closed properly,
^
18 I believe the answer to the question that he asked 19 is yes.
20 Q Yes, the core would not hav'e been i 21 uncovered?
l 22 A That's my best guess, yes, other things being 23 equal.
[)
(j 24 Q His fourth question to you is, "Would 1 '
25 raising the bottom of the pressurizer above the
l\
1 Womack 942 f-)
U 2 elevation of the surgeline nozzle on the candy cane 3 make a material difference in the sequence of events 4 as they occurred at TMI-2. Would making this change
( 5 in elevation of the pressurizer provide significant
- 6 additional margin in avoiding going solid during a 7 loss of main feedwater event."
8 Is it correct that the location of the 9 pressurizer is such that in a loss of coolant 10 accident the inventory of water in the pressurizer 11 does not drain by gravity into the reactor vessel?
12 A No, I don't think that's entirely correct.
O
\;
i '/ 13 Q Is there something incorrect?
14 A' Yes, I think that the -- if the pressure 15 within the loop side of the system, the main side 16 of the system is allowed to equalize with pressure 17 in the pressurizer, the water will seek.its level.
18 ' It will drain down to a certain point and there 19 may be some water left in the U or loop portion 20 of the surgeline. You would have to define a
- s 21 particular set of conditions.
p 22 Q Is the bottom of the pressurizer above 23 the top of the core?
() 24 A Yes, I believe it is.
25 Q Is the bottom of the steam generator s
1 Womack 943 f~
b 2 above the top of the core?
3 A No, it is not. I don't believe it is.
4 Q In some of the B&W plants is the
( 5 bottom of the steam generator above the top of the 6 core?
7 A It has been raised in some of the B&W plants, 8 and the exact relative elevation on the top of the 9 core and the steam generator I don't recall. We 10 can check. ',
11 Q In the plants in which the steam 12 generator has been raised, do those who were in the O' 13 know call those raised loop plants,7 14 A Yes.
15 Q And for cognoscente the plants in which 16 the steam generator bottom is lower than the top of 17 the core, those are called lowered loop-plants?
- 18 A Yes.
19 Q TMI-2 is a lowered loop plant?
20 A Yes.
21 Q Davis-Besse-1 is a raised loop plant?
22 A Yes.
23 MR. SELTZER: Can we take a short 24 recess, please?
25 MR. WISE: Sure.
1 .
Womack 944
~
~T (G 2 (A recess was taken.)
3 BY MR. . SELTZER:
4 Q Dr. Womack, during the earlier session
(, 5 of your deposition you referred to B&W operating 6 specifications for its customers' plants.
7 I wrote a letter to your esteemed 8 counsel asking him could he please provide a copy 9 of the operating specifications that you had 10 referred to, and I got a letter back ',from him saying, 11 .A further check with Dr. W. reveals some uncertainty 12 in his own mind as to what documents he meant during
'- 13 his testimony. You may wish to explore this further' 14 with Dr. W. during the remainder of his deposition.
15 MR. WISE: I would like to note that 16 my letter was not phrased "Dr. W." With that 17 exception your question can stand.
18 MR. SELTZER: But for your having said 19 that the reporter would have type [ Dr. Womack 20 anyway.
21 MR. BENEDICT: I hope not.
l 22 Q Is there some uncertainty in your own 23 mind regarding what documents you meant?
.a
) 24 A Yes, there is. I hope that I properly
( 25 qualified all those answers that I made about I
f
1 Womack 945 f3 k~ 2 operating specifications and related matters or 3 operating documents prior to-the ATOG program when 4 we discussed that.
(, 5 I have a general understanding born
)
6 of listening to discussion, a series of discussions 7 that were kind of compressed together in my own 8 mind about B&W's relationships in its NSS utility 9 contracts to support the utilities in preparing 10 operating procedures,and I thought at one point in ,
11 time that I had understood that a concept of 12 operating specifications was used.
I
/'T -
b -J 13 I gather than an attempt was made as 14 a result of my comment to you to find such things 15 that drew -- that really was not the way that it 16 had begun, so I can only apologize to you for my l 17 lack of information in that regard and for misleading j 18 both you and Mr. Wise with respect to f nding those
~
19 things, and suggest that perhaps a better qualified j 20 person than myself might be able to enlighten you I
21 more specifically.
22 Q Is there some other document that you I
l l 23 believe does exist that B&W used for the same purpose?
f 24 A Having said all I have said, I feel very l 25 reluctant to speculate. With regard to consistency,
1 Womack 946
~
h
-2 contract to contract, I believe I have understood 3 that in the past B&W has assisted utilities in 4 various ways in preparing operating procedures,
( 5 and the degree of that assistance and the documents
)
6 produced I don't really have knowledge really good 7 enough to be talking about.
8 Draft procedures may be a part of what 9 is exchanged. I think I have heard that term. But, 10 again, I think you have readily availgble to you 11 better sources of information than I.
12 Q Okay. I am glad I explored that further C.-
'- with you.
13 14 A I hope you will accept my apology. If that's 15 the only question of that uncertainty in this record, 16 I shall be very surprised.
17 Q You don't have to apologize,
! -18 MR. SELTZER: I have no fur $her questions 19 at this time. If further documents demonstrate 20 a need to recall Dr. Womack rather than being l
21 able to ask other witnesses to explain them,
! 22 we may have to recall him.
I 23 We will also consider whether there is
[)
x./
24 a need to recall Dr. Womack to answer some of l 25 the questions on which he was instructed not i
i 1
Womack 947 2 to answer, but other than those contingencies
. 3 we have no plans to recall Dr. Womack.
4 Do you want to cross-examine him?
( 5 MR. WISE: I would like to take just
,}
6 ten seconds and go off the record.
i 7 Off the record.
8 (Discussion off the record.) .
9 MR. WISE: We have no questions at this .
10 time and we will consider the deposition s.
11 closed subject to obviously your right in 12 the event that you wish to make any motions O 13 concerning objections that were made during 14 the course of the deposition. As to documents 15 that may be produced during the remainder of 16 this case, we will simply have to take that r
17 under advisement when the time comes.
~
I IO (Continued on page 947A.)
l 19 l
20 i
i 21 l
l 22 23 24 .
l 25
-g,--c - -
. . - - - - - - - . . - --rr _- , . - , . + - - , .e.- - - - - - -
_r ,. ,.y--~-.,---+,r.--,,---,-------,r----- ---
1 1
1 Womack 947A 2 MR. SELTZER: Fine.
3 Dr. Womack, thank you very much. Nice 4 meeting you.
5 THE WITNESS: Thank you.
>r
)
6 (Time noted: 4:10 o' clock p.m.)
7 8 EDGAR ALLEN WOMACK, JR. ,
i 9 10 Subscribed ano sworn to before me t 11 this day of , 1981.
12 13 14
! 15 i
f I 16 17 I
18
.W l 19 l
4 20 21
{
' 22 23 l
24 25
- 1. .-...-.. . - - - - - . , - . . . . . - . . - . . . . , . , . . - . . - . - - - , . , . . - . - _ _ , , . . - , - , - , , . - , , , - , , . - - . , . . - , . ,
1 948 m
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 _,
me on Tuesdav. Januarv 27. 1981 Consisting 9
of pages 808 through 947A ;t ,
I further certify that the witness had been previously sworn and that the within 13 transcript is a true record of said testimony; 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 of the counsel.
18
~
10 IN WITNESS WHEREOF, I have hereunto set my TH hand this I8 day of IC EGR U 4/l y ,1981.
20 22 e'
u,m tA w%
CHARLES SHAPIRO, CER O u 25
,, -w --r- - + - - - . , , . , ,---,-m ., -,-------n > . - - . , , .,.,--e-,-r,-- , - - - - - - , -
949 Tuesday, Jcnuary 27, 1981 i '-
- >, , IN D EX I 4 WITNESS PAGE 1
Edgar Allen Womack, Jr. (resumed) 810 i
i E X H I B I T S -
GPU FOR H
IDENTIFICATION "
i 32 seport entitled " Safety Aspects of the Mulheim-Kaerlich Plant in View of the Three. Mile Island-2 Accident," dated May 197i 815 33 Memorandum from G. E. Rambolto Messrs. Womack and Taylor, subject: Proposed B&W Positions Regarding High Point Vents,, Water Level Measurements, and Void
, Fraction Monitoring, December 20, 1979 '
822 1
A.
- 34 Memorandum dated October 11 f 1979 from R. E. Braumiller to Messrs. Bateman, Hamilton and Dowling 842 35 Memorandum entitled " System
- Dynamic Response / Response to TMI-2 Concerns Task Description"
{ 849 36 Memorandum entitled " Response I to TMI-2 Concerns, Task
- , Description, System Dynamic Response, Post Trip Control" 859
+ J c ., V ;t ,
l he ~ , dS-.bikN?;i - a-' >
'~
a- :!G : ~., %
_ . _ _ =__
950 l 1
Tuesday, January 27, 1981 l
~
EX H I B I T S
, Continued F- v GPU FOR IDENTIFICATION PAGE -
37 Memorandum entitled " Response i'
to TMI-2 Concerns, Task Description, Main Feedwater ~
System Reliability" 868 .
4 38 Memorandum dated August 3l, t 1978 from E. A. Womack, Manager, Plant Design, to B. A. Karrasch, Manager, Plant Integration 915 39 Memorandum dated August 3,0 , ,1979
, from E. A. Womack to Mr. Kosiba, Manager of Customer Service, Department
- 921 40 Memorandum dated April 5,.1979 from D. H. Roy to E. A. Womack 9.37 l
c 4
(
t A
- h, , , g h .' ~ *
' l& 6. C Z~~k . = s $$$,j::)d n '<O ~.'_,
'_ '; 'y ,
s s,; > . ~ ~? e 0 5 ** ** * * ' ' ' * **~
,-