ML20072H847
| ML20072H847 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/11/1983 |
| From: | Frederick E METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-02, TASK-2, TASK-GB NUDOCS 8306290774 | |
| Download: ML20072H847 (89) | |
Text
t i
685 bt UNITED STATES DISTRICT COURT l (]
SOUTHERN DISTRICT OF NEW YORK C/
__--__________x GENERAL PUBLIC UTILITIES CORPORATION, 3
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, s
-against-80 Civ. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
s Defendants.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Continued deposition of Metropolitan O
Edison Company, by EDWARD R.
FREDERICK, taken by Defendants pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs.,
One Chase Manhattan Plaza, New York, New York, on Tuesday, May 11, 1982, at 9:15 o' clock in the forenoon, before Joseph R.
Danyo, a Shorthand Reporter and Notary Public within and for the State of New York.
4 8304290774 830511 PDR ADOCK 05000289 T
(~)
DOYLE REPORTING, INC.
O CERTIFIED STENOTYPE REPORTERS 369 LextNCTON AVENUE WALTER SHAPIRO, C.S.R.
New YomK. N.Y.
10017 CH ARLES SHAPIRO, C.S.R.
TALE PMo w s 212 - 867 822o 1
1 686 2
Appe arance s:
3 4
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs g
5 425 Park Avenue New York, New York 6
By:
RICHARD C.
SELTZER, ESQ.,
7 c
of Counsel 8
9 10 DAVIS POLK & WARDWELL, ESQS.
(
Attorneys for Defendants 11 One Chase Manhattan Plaza New York, New York 12 i
By:
ROBERT B.
FISKE, ESQ.3 13
-and-WILLIAM E. WURTZ, ESQ.,
14 of Counsel 15 16 17 KILLIAN & GEPHART, ESQS.
Attorneys for Edward R.
Frederick 18 Box 886 4
Harrisburg, Pennsylvania 17108 19 By:
KEVIN WALSH, ESQ.,
20 of Counsel 21 9
22 Also Present:
23 JONATHAN QUINN
'4 o
25
687
()
2 E DWARD R.
FREDE RI C K,
- resumed, 3
having been previously duly sworn by the 4
Notary Public, was examined and testified ll) 5 further as follows:
6 EXAMINATION (Continued) 7 BY MR. FISKE:
8 Q
You said at the end of the day yesterday 9
that when you learned that there had been no 10 emergency feedwater to the steam generators that that 11 helped you understand why the pressurizer level had 12 been increasing.
13 A
Yes.
14 Q
What did the absence of feedwater to the 15 steam generators have to do with an increase in 16 pressurizer level as you understood it at that time?
17 A
At that time'I was concluding that the 18 lack of feedwater meant that we weren't removing 19 heat from the RCS, so it heated up and the haat 20 caused expansion of the water, and that is what 21 filled the pressurizer along -- I was kind of 9
22 compounding the problem.
I was shooting water in 23 and the water was expanding.
That explained to me 24 why it came up faster than I thought it should have,
/~N d
i 25 because I had two contributors.
I had me shooting 1
1 Fredarick 688 2
in water and the expansion happening.
3 MR. SELTZER. When you say " shooting 4
in the water," you mean --
gg) 5 THE WITNESS:
High pressurs injection.
6 Q
So this is exactly the opposite, is it 7
not, of the type of cooldown that you described 8
before that causes a drop in reactor coolant system 9
pressure?
10 MR. SELTZER:
What is the type of 11 cooldown that he was' re ferring to before?
12 MR. FISKE:
The phenomenon withdrawn.
}
13 Q
The system dynamics that we have been 14 discussing for about three days now in this deposition i
15 under which pressure drops as a reault of the 16 contraction in the volume of water resulting from 17 a drop in temperature in the reactor coolant system.
18 Mr. Frederick, you have testified, 19 have you not, on numerous occasions during this 20 deposition that you understood that what caused 21 the drop in pressure in those incidents that have O
22 previously been described as cooldowns was the fact 23 that there had been a drop in temperature in the t
24 reactor coolant system which caused the volume of j
25 water to contract and thereby produced a drop in l
I Frederick 689 2
pressure.
3 Isn't that right?
4 A
That was one of the reasons, yes.
g gg) 5 Q
The analysis that you just went through 6
with respect to the increase in pressurizer level is 7
exactly the opposite of that, is it not, that is, 8
the volume of the water is expanding rather than 9
contracting?
10 A
Yes, but we are six or seven minutes d
11 into the transient.
We already went through the I
i 12 cooldown and now we are in a heatup.
()
13 When you heat up, you are going to expand.
{
14 That is true.
They are opposite e f fe cts.
15 Q
You learned, did you not, that there had 16 been no feedwater at all to the steam generator from 1
the time the reactor trip started during that entire 4
18 first seven minutes?
You knew that, didn't you?
19 A
N o.-
When we learned of the loss of 20 emergency f ee dwate r, it was in reaction to a 21 discovery of the loss of main feedwater.
You don't O
22 lose main feedwater on a normal turbine trip.
23 At this point we still didn't i
24 know -- somewhere in here in this five, six, or
\\
25 seven-minute time frame we discovered the loss of
i 1
Froderick 690
(
2 feedwater, the loss of emergency feedwater.
3 Q
Once you discovered that those valves 4
were closed, you knew at that point that there qg 5
had been no feedwater to the steam generators 6
from the time the reactor tr'p started up to that 7
point, isn't that correct?
8 MR. SELTZER:
Objection.
9 Mr. Frederick explainef yesterday that 10 there was feedwater in the steam generators 11 at the start of the accident.
12 Q
You said, did you not, yesterday,s that 13 yot concluded that during that period of time from 14 the time of the reactor trip to the time you 15 discovered that the 12's were closed, that the steam 16 gen e rators had been in the process of boiling dry?
17 Didn't you use that phrase?
18 A
Yes, I knew that they were boiling dry, 19 but I didn't know when we lost main feedwater.
20 That happened some time after the trip as far as 21 I knew then.
O 22 Q
I s n t it a fact that this process by 23 which there was less heat transfer from the primary 24 system to the secondary system resulting in -- withdrawn.
25 Didn't you understand that it was the
1 Frodarick 691
()
2 loss of heat transfer from the primary side to the 3
secondary side that had produced the increase in 4
reactor coolant systen pressure in the first place?
gg 5
MR. SELTZER:
What do you mean "in the 6
first place"?
7 Q
What caused the reactor to trip?
Did 8
it trip on high pressure or low pressure?
9 A
High pressure.
10 Q
What did you understand had caused the 11 increase in pressure that had caused the reactor 12 to trip?
13 A
Reduced steam demand due to the 14 turbine trip.
15 Q
When you discovered that the 12's had 16 been closed during the first eight minutes of the 17 accident, didn't you understand at that point that 18 the loss of heat transfer from the primary side to 19 the secondary side had produced the increase in l
20 pressure?
21 A
Yes, but you can't conclude that those 9
22 are in the same process.
Reduction.4i steam demand i
23 that I mentioned as causing high pressure and a 24 loss of heat are two different conditions.
O' 25 Q
Did you notice when it was that the i
L
1 Frederick 692 l
(_/
2 emergency feedwater pumps had first come on?
3 A
No.
4 Q
When you learned that the valves were lg 5
closed, did you look at the board to try to G
determine when the pomps had first come on?
7 MR. SELTZER:
Objection; no foundation.
8 Q
Did you take any steps to try to 9
determine when the pumps had first come on?
10 A
Working only on recollection now, 11 I don't remember going over there, but other people 12 have testified that I did.
/~~x
(,)
13 Q
What is your recollection now as to 14 whether, once you learned that the 12's were closed, 15 you made any effort to determine when the pumps 16 had firs.t come on?
17 A
I said I don't recall going over there 18 now, but other people tell me that I did.
19 Q
What point in time?
20 MR. SELTZER:
He just said he doesn't have 21 a recollection.
O 22 Q
Let's go back to your answer before 23 when you said that the increase in volume -- you i
I rx 24 attributed the increased pressurizer level to k) 25 an increase in volume of water in the reactor
1 Frederick 693 2
coolant system, right?
3 MR. SELTZER:
What point in time?
4 MR. FISKE:
The time he saw the increase lll 5
in pressurizer level.
Withdrawn.
6 Q
You said that after you learned that 7
the 12's had been closed for a period of time and 8
that there had been no emergency feedwater to the 9
steam generator, you said that that helped you 10 understand why the pressurizer level had gone up 11 because it indicated to you that there had 12 been an expansion of water in the primary system,
()
13 partly as.a result of a lack of emergency feedwater 14 to the steam generators, correct?
15 MR. SELTZER:
No.
He also said he 16 had been adding water to the system.
17 MR. FISKE:
I said " partly."
18 Let me just ask the questions.
19 MR. SELTZER:
All you are doing is 20 regurgitating what we already spent the 21 morning trying to get out.
Let's go on to k
22 something new.
23 MR. FISKE:
I am trying to lay a predicate 24 for the next question.
25 MR. SELTZER:
I want it to be a
0 1
Frodorick 694
(
2 complete predicate ~ then.
MR., Isms:
My euestion stanes.
3 4
Would you read it back.
5 (Record read back.)
6 A
Yes.
7 Q
And you knew, as you testified before,
g that an expansion of water in the reactor coolant 9
system was inconsistent with a cooldown, isn't 10 that correct?
11 MR. SELTZER:
I object.
This is 12 asked and answered.
You are going over the 13 same territory again.
14 MR. FISKE:
You are just slowing us 15 down with that.
16 MR. SELTZER:
I object also to your 17 interrupting me while I am in the middle of 18 talking.
I don't interrupt you,and your 19 partne r, Bob Wise, gets positively 20 vituperative if he thinks I am interrupting 21
.him.
O 22 MR. FISKE:
Go ahead.
23 MR. SELTZER:
Mr. Frederick already said 24 that it is not inconsistent with a cooldown, 25 that his understanding was that there was a
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g M
1 1
Frederick 695
(~'r
(,)
2 cooldown and then a subsequent heatup.
3 MR. FISKE:
Why don't you let me ask the 4
questions instead of trying to interject and gg 5
bail out the witness every time we get to 6
something important?
7 MR. SELTZER:
I think it is you who needs 8
to be bailed out.
If you would stop asking the 9
same questions over and over again.
10 MR. FISKE:
I think Mr. Frederick is 11 fully capable of understanding my questions.
12
'M doesn't need you to keep butting in and
( );
13 rephrasing prior answers that he has given.
14 MR. SELTZER:
I am not rephrasing.
15 I am giving them to you almost verbatim.
16 MR. FISKE:
Repeat the question.
17 (Record read back.)
18 A
You are asking if I thought about this 19 while this was occurring?
20 Q
Yes.
That was a basic understanding 21 that you had at that time, was it not, from your 9
22 knowledge of the way the system worked?
23 A
I think I already said that I expected 24 when the system cooled down it would contract, and s
(
\\
i 25 when it heated up it would expand, and that was
2 1
Frodorick 696
(}
2 consistent with what I understood.
3 Q
so to the extent during the first few 4
minutes of the trip there had been no emergency ll) 5 feedwater and that that had the effect of producing 6
an expansion in the reactor coolant system water,
(
7 that was inconsistent with a cooldown, isn't that 8
correct?
9 A
No.
The thought process I was going 10 through then was not a review of the first few 11 seconds of the trip.
I was thinking about where we 12 are now and how the loss of feedwater has explained 13 the solid or near full pressurizer that I had.
14 Q
When you learned that there had been 15 no emergency fe e dwate r, you were making an effort 16 to analyze what impact that fact had had on the 17 early minutes of the accident, were you not?
18 A
Only in the time from when I noticed 19 that we were filling rather quickly until a few 20 minutes late r when we were actually full.
I explained 21 that slope on the graph, pressurizer level graph, 9
22 by the fact that we had had a heatup.
The cooldown 23 that we had prior to that doesn't enter into that 24 thought process.
25 Q
Is it your testimony that knowing that
3 1
Frederick 697 2
there had been no emergency feedwater during this 3
entire period of time in the first few minutes of 4
the accident and going through a thought process lgg 5
that that loss of emergency feedwater contributed 6
to an expansion of weter in the reactor coolant 7
system during some part of that time creating an 8
increase in the pressurizer level, that you gave 9
no thought to the fact that that same loss of 10 emergency feedwater that would have -- that might 11 have that same effect in other portions of the early 12 minutes of the accident making the early minutes
()
13 of the accident inconsistent with a ecoldown?.
14 MR. SELTZER:
When you say "other 15 portions," what portions are you referring to?
16 MR. FISKE:
Mr. Frederick said that he 17 applied the lack of emergency feedwater to the 18 period of time in the first few minutes of the 19 accident when he saw the pressurizer level 20 beginning to rise, and he attributed that rise 21 in pressurizer level to an expansion of the 9
22 reactor coolant system water, attributable in 23 part to the loss of emergency feedwater.
24 I am asking him did he attribute did 25 he try to attribute that loss of emergency
4 1
Frodorick 698
(
2 feedwater and the impact of it to the portion f the accident sequence before the time that 3
4 the pressurizer level began to rise.
)
5 A
In my mind, I was already satisfied as 6
to how I understood the sequence at that time.
7 We had a reactor trips somewhere after that, we 8
lost normal feedwater, and some time after that 9
the steam generator boiled dry; and then we noticed 10 that there was no feedwater; so in the time in my 11 mind, looking back over the few seconds that had i
12 gone by since the reactor trip, because that is
()
13 all it seemed like to me, all those three things 14 had happened and for a very short time we had been 15 without any feedwater at all, and that is what I 16 attribut,ed to the rapid rise in pressurizer level 17 and then the solid or near solid condition I was 18 observing.
19 Q
You learned something new when you 20 learned that those 12's were closed, right?
That 21 is something that you hadn't known earlier in the 9
22 accident, right?
23 A
Yes.
l l
24 Q
When you learned that new fact, did you b)
N_
25 make any effort when you were analyzing the impact
f 5
I Frederick 699 i
2 of that new fact on pressurizer level, did you also I
l 3
make any effort to analyze the impact of that 4
fact on the drop in pressure in the early minutes lll 5
of the accident?
6 A
The drop in pressure was explained by l
7 the trip.
The fact that the pressurizer level came 8
up and the pressure didn't, I didn't apply that 9
to the emergency feedwater.
The injection 10 system had put a lot more water in the system, so 11 the pressurizer was cooled down, and it wasn't 12 capable of maintaining a high pressure any more.
(
13 You have to heat it back up.
14 Q
Is it your testimony then that at no 15 time after you realized that there had been no 16 emergency feedwate; during the first few minutes 17 of the accident, that at no time did you make any 18 effort to analyze the impact of that on the drop 19 in pressure?
20 A
The emergency feedwater condition i
21 entered into my thought process as explaining 9
22 one of the parameters I was viesing.
23 The other parameter that I was viewing, l
24 which was the pressure, was explained by the i
g-
\\_)
25 pressurizer level.
There was no reason to apply i
emergency feedwater to the pressure.
h
700 1B 1
Froderick is_,1 2
Q Did you stop and think whether or not 3
the drop in pressure could be due to a cooldown in 4
light of the fact that there had been no emergency ggg 5
feedwater going into the steam generators from the 6
time the reactor tripped?
7 MR. SELTZER:
No new feedwater?
8 MR. FISKE:
No new feedwater.
9 A
The initial drop in pressure was caused 10 by the cooldown.
I already explained that.
What we 11 are talking about is six or seven minutes into it, 12 what is causing the pressure, right?
()
13 Q
No, I am asking you, once you learned 14 that the 12's had been closed, did you make any effort 15 to determine whether or not the initial drop in 16 pressure was caused by a cooldown in light of the 17 fact that from the time the reactor trip occurred 18 on, there had been no new feedwater going into the 19 steam generators?
20 A
You don't understand.
It is not the l
21 feedwater that cools down the reactor coolant 22 system.
It is the steam flow through the safety 23 '
valves.
That is what is causing the cooldown.
The 24 fact that we are not putting any feedwater in there f3 25 has little effect.
You are removing 100 percent
I Frodorick 701 2
power and you have zero percent production.
So, 3
therefore, it is going to cool down.
4 Q
Is it your testimony that at no time ggg 5
during the first eight minutes of the accident did 6
you look at the gauge that reflected reactor 7
coolant system temperature to determine whether in 8
fact there had been a cooldown at the time pressure 9
was dropping?
10 A
No, I don't think I ever testified 11 that I never looked at it.
The gauge that I would 12 have looked at may not be the one you are talking
()
13 about.
The primary indicator for T-Av is the 14 digital indicator, and I don't recall taking the 15 time to pull the graph out of the panel which 16 indicate,s the time history of T-Av.
I would look 17 at the two-inch digital gauge.
18 Q
My question is, did you make any effort 19 after you learned that the*12's had been closed or 20 at any timo up to that point to determine what 21 the temperature had been at the time that pressure 9
22 dropped to the point where HPI became actuated?
23 A
I don't have a specific recollection 24 of looking at the gauge, but since I usually did 25 look at the gauge, I can't say that I did not.
m
l 1
Frederick 702 2
Q Let me go back to some questions that 3
we were asking yesterday about HPI coming on after 4
That is the subject.
I think the lll 5
exhibit that was marked from the Rogovin report 6
reflected I believe a total of 19 or 20 reactor 7
trips at Unit 2 in the year before the Three Mile 8
Island accident.
9 Is it correct that you can have a 10 reactor trip on high pressure and you can also 11 have a reactor trip on low pressure?
12 A
Yes, there are eight things that will
()
13 cause the reactor to trip.
14 Q
And one of them fr if pressure falls 15 below a certain level?
The normal operating 16 pressure is 2155?
17 A
Yes.
18 Q
And if the pressure drops down to some 19 level below that, it will cause a reactor trip, 20 right?
21 A
There are two separate low-pressure 9
22 trips.
23 Q
what is the pressure level for those?
24 A
one is called the variable low-pressure gs 25 trip and it is figured out by the computer.
It is
1 Frodorick 703
(
2 figured out and it varies up and down the scale.
3 The other is 1900 pounds.
4 Q
Conve rs e ly, if the pressure increases ggg 5
above 2155 to a certain level, that will cause a 6
trip on high pressure, right?
7 A
Yes.
8 Q
What is that set point?
9 A
2355.
10 Q
HPI is actuated at 1600, approximately, 11 right?
12 A
Yes.
13 Q
In any of your training at Met Ed on 14 any of these 20 reactor trips, did anyone ever try 15 to explain to you whether there was any more 16 likeliho.od of HPI coming on when there had been 17 a reactor trip at low pressure than there was if 18 there had been a reactor trip at high pressure?
19 A
No, the training that I received on 20 how to respond to a reactor trip, using the 21 procedure doesn't differentiate as to what causes 9
22 the trip.
You respond to them all exactly the same 23 way.
24 Q
You had no understanding from anything 25 you learned at Met Ed before the accident that
i l
i i
1 Frodorick 704 i
i
(
2 there was any more likelihood or less likelihood 3
of automatic HPI in a high-pressure trip than in 4
a icw-pressure trip?
gg 5
MR. SELTZER:
That is the opposite of 4
6 what your last question was.
7 MR. FISKE:
Read it.
8 (Record read) 9 A
No, I don't think that accurately 10 represents my understanding.
I can understand 11 that if there is a transient occurring that is 12 driving pressure down, you are more likely to have 13 HPI.
If you are discussing a scenario in which 14 low pressure is going to be the cause of the trip, 15 we had discussed things like that prior to the 16 accident.
i 17 Q
Automatic HPI on a high-pressure trip 18 would be a more unusual event than automatic 19 actuation on a low-pressure trip?
20 A
No, I don't think I said unusual or 21 usual.
What I said was that I can understand that 22 a low-pressure transient could easily cause l
23 high-pressure injection to be turned on 1
24 automatically.
It would jur require a few extra 25 steps to get there in a hig.. -pre ssure transient.
tlc 1
Frederick 705 2
Q In other words, it would -- there 3
would be a -- there would have to be a significantly 4
greater drop in pressure from a high pressure g
5 reactor trip than there would be from a low 6
pressure reactor trip in order to actuate HPI?
I MR. SELTZER:
I don't know what your 8
definition of "significant" is, but he 9
already testified as to what the numbers are.
10 Q
In the low pressure trip, the pressure 11 would have to fall approximately 300 pounds per 12 square inch, and in a high pressure trip it would 13 have to fall more than 700 pounds, correct?
14 MR. SELTZER:
You are just assuming 15 low pressure trip in 1900 pounds, not a 16 variable low pressure trip which could be at 17 a pressure other than 1900 pounds.
18 MR. FISKE:
I am talking of the 1900 19 pounds, yes.
20 A
That is not the way I was thinking about 21 it.
Actually, they are only slightly more than O
22 300 pounds apart, the starting point that you are 23 talking about, 1900 and 2355, so that to me isn't 24 very much difference, because it is less than 12 25 percent of the whole scale.
l
C 1
Frederick 706 2
Q But the drop is more than double, is 3
it not?
4 A
You are asking me about my understanding.
gg 5
I was picking a starting point and comparing the 6
two starting points, and if I can develop a scenario 7
that would get me to HPI, I could do it with either 8
one.
9 Q
It is a fact, is it not, that the loss 10 of any feedwater to the steam generators for the 11 first eight minutes of this accident had left the 12 steam generators in an abnormal condition?
<"(s) g3 A
A loss of feedwater to the steam 14 generators is an abnormal condition?
15 Q
Had left the steam generators in an 16 abnormal. condition.
17 A
A loss of feedwater was an anticipated 18 transient.
The blockage of emergency feedwater was 19 an unanticipated transient.
In that way.
20 Q
And you concluded, did you not, that 21 the steam generators in fact had boiled dry?
O 22 A
No.
23 Q
You never reached that conclusion at any 24 p-time during the accident?
25 A
Later on -- by "later on,"
I mean after
C 1
Frodorick 707 2
this point at which I was made aware of the 3
loss of emergency feedwater -- I engaged in some 4
discussion with Mr. Faust as he was having his llh 5
difficulties getting the system back in automatic, 6
and he was trying to decide whether the steam 7
generators had boiled dry or how he could conclude 8
that decisively one way or the other, so in that 9
way we did think about that a few minutes later.
10 Q
And you knew at that point that there 11 had been a sharp drop in pressure in the steam 12 generators and also a drop in level, isn't that 13 corre c t ?
14 A
The drop in level is a normal indication 15 of transferral of controls of the emergency feedwater 16 system.
That is what we were watching to make 17 sure that the emergency feedwater system was working.
18 I don't recall a sharp drop in pressure.
19 Q
I am talking about a drop in pressure 20 l right from the time that the accident started.
21 MR. SELTZER:
What is your question?
22 Q
Is it your testimony that you weren't 23 aware of any drop in pressure at that time?
I r3 24 l
A At the onset of the transient?
i b
25 Q
Yes.
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1 Frederi.ck-w is 708 s
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2 A
Pressure went up.
That is why tho J
3 safety relief valves opened.
t
'h'inp, yo u h a v'e 4
MR. SELTZ""-
to be
)
l gg 5
clear.
6 Are you talking of steaa' generator e,,
7 pressure?
s 8
MR. FISKE:
Yes.
~
do n,'.t th'in'k the re is 9
MR. SELTZER:
I 10 any foundation that Mr. Frederick was in a 11 position to be monitoring steam generator 12 pressure.
13 MR. FISKE:
I am just asking him.,
14 Q
Is it your testimony that you were not 15 aware of any drop in steam generator pressure in 16 the e arly minutes of the accident?
17 A
I thought that you were talking about 18 the onset of the transient where the turbine trip 19 occurred and the steam generator pressure went up.
20 That was the onset of the accident.
21 Q
After the reactor trip, did you become 9
22 aware that there was a drop in steam generator 23 pressure?
24 A
As far as I know, the steam pressure
(~)'
25 remained at a thousand to 1100 pounds for quite some
._ -~ _
1 Frederick 709 O ),
C 2
time.
3 Q
I show you a document which has 4
previously been marked as B&W 266, which is a graph 1lh 5
s ubmitted by GPU to the NRC as part of the LER on 6
this transient, and this graph reflects the steam 7
generator pressure and level.
The steam generator 8
pressure is reflected by the dash-dot line for 9
steam generator A and the dash line for steam 10 generator B.
11 Do you see the dash-dot line and the 12 dashed line on this chart?
()
13 MR. SELTZER:
Do you want to ask him 14 first whether he has ever seen this chart 15 before?
16 MR. FISKE:
Not particularly.
17 A
I see the dash-dot line and the dash line.
18 Q
Is it correct that those two lines 19 show on this graph a drop in pressure from above 20 a thousand pounds per square inch down to below 21 500 pounds per square inch for the period of time 22 from approximately one minute to seven and a half 23 minutes?
24 A
No.
g N.)
25 MR. SELTZER:
I object.
The document
.C:
1 Frodarick 710 (wim) 2 speaks for itself.
3 A
The characterization is incorrect.
4 Q
How is it incorrect?
jg) 5 MR. SELTZER:
I object.
6 The witness has not even been asked I
to testify if this is a document that he ever 8
saw be fore.
9 To call him as an expert to help you 10 read a document that he perhaps has never seen 11 before is entirely inappropriate.
12 Q
During the course of the first ten f~/}
13 minutes of the accident, were you aware of a drop t
14 in pressure in the steam generators as reflected on 15 this graph?
16 A
No.
This graph shows a drop from just 17 above a thousand pounds to just below normal 18 operating pressure down near 800 pounds, and then 19 re turning back to the post-trip set point, and I 20 wouldn't say that this was c. console indication or 21 that it is representative of what is displayed on O
22 the console.
23 Q
Is it your testimony that during the 24 first ten minutes of the accident, you were not
(
25
'~'
aware of any drop in pressure in steam generators
FC I
Frederick 711 2
from a thousand rounds down to the range of 800 3
pounds?
4 A
I was only aware of it through what ll 5
Mr. Faust would have been telling me from his 6
position at the feedwater steam generator controls, 7
and as we already established, I was on the other 8
side of the room.
9 Q
So based on your understanding of the 10 system ota the day of the accident, would you have 11 expected a drop in pressure in the steam 12 generators to have resulted from the fact that
(
13 there was'no emergency feedwater going into the 14 generators during the first eight minutes?
15 MR. SELTZER:
Would he have expected a 16 drop in what?
17 MR. FISKEt Pressure.
O A
I understood that we would see a decrease 19 in steam generator pressure if the steam generator 20 actually boiled dry.
And that there was a place for 21 the steam to go.
O 22 In othe r words, you have to exhaust the 23 water supply in the steam generator and then have 24 g-a place to vent off the pressure due to that boiling QJ 25 and then the pressure would go down.
I had no idea
~
C 1
Frederick 712
)
2 how fast it would go down or how it would recover.
3 Q
You did become aware during the course 4
of the accident sequence that the pressure came ll 5
back up again after the 12's had been opened, isn't 6
that right?
7 MR. SELTZER:
Objection.
I don't think 8
you have established a foundation that he knew 9
the pressure had gone down, so to ask him 10 "Did you know that it came back up" lacks 11 foundation.
12 g
Did you understand at any time in the
(
13 first ten minutes that the steam generator 14 pressure was anything other than normal?
15 A
During the time this was occurring, 16 I was no.t specifically made aware o f -- I don't 17 recall being aware of -- the numerical value of 18 the pressure.
19 Mr. Faust was having some problems with j
20 both the level and the pressure as a result of 21 the emergency feedwater situation, and he was 22 informing me about it.
He was talking to me as 23 we were trained to do, to talk back and forth and keep 24 each other informed, so that was the only sense in O
25 which I was aware of what was going on over there.
'C 1
Frederick 713 O'
2 He asked me questions or gave me 3
information, and, again, as I have said several 4
times before, this was only a very short time ll) 5 to me.
I felt only less than a minute had 6
gone by since the trip.
7 Q
There came a time after the 12's had 8
been opened when Mr. Faust was making efforts to 9
try to get the steam generators stabilized, right?
10 A
Yes, as I remember, it was a large 11 piece of time.
12 g
And there was a time when you and he 13 concluded that in fact the steam generators had 14 been returned to a stable condition, isn't that 15 right?
16 A.
Again, I don't recall any specific 17 discussions with Mr. Faust.
He has told me that 18 I went over there and talked to him about it,~but 19 I don't recall that.
20 Q
You did come to the conclusion, did you 21 not, at some point during the accident based on your 22 discussions with Mr. Faust or on whatever 23 observations you made yourself that the steam 24 generators had come back to a stable condition?
25 A
Yes, it was my impression that this upset
OC 1
Frederick 714 2
with emergency feedwater had lasted a short time, 3
a few minutes or so, and then we were back to normal.
4 Q
Let me just show you the graph again lh 5
that is Exhibit 266.
6 Do you have the other one that is 2687 7
MR. SELTZER:
If you give it to us, we 8
will.
9 Q
Looking at Exhibit 266 and on the 10 right-hand side of the page, when you see the two 11 lines for dash-dot and dash showing steam 12 generator pressure at approximately 30 minutes
)
13 A
On the first graph?
14 Q
Yes, Exhibit 266.
15 A
Yes, I see them.
16 Q.
-- is pressure for the steam generator 17 in that range considered to be normal, within normal 18 limits?
19 A
The normal pressure should be 1,010 20 pounds.
They are near that.
They are within 50 21 pounds of it.
I don't recall that there is a 22 window, a range.
23 Q
Looking at the second graph, Exhibit 24 268, which shows a pressure over time for the firs t 25 120 minutes of the accident, looking at the period
I k 1D 1
Frodorick 715 2
of time from, let's say, 20 minutes to about an 3
hour, the steam generator pressures for both 4
generators are in the vicinity of 940 pounds or lh 5
above.
6 MR. SELTZER:
On the graph, there are 7
supposed to be two lines, one solid and one 8
dashed.
Yet it looks like at the start there 9
are four lines.
Which of the lines are 10 you referring to and why are there more 11 lines than should be indicated?
12 MR. FISKE:
This is a GPU document.
()
13 All I can go by is what it says at the top, 14 steam generator A steam pressure is a 15 solid line,and steam generator B pressure is 16
- a. dashed line.
17 MR. SELTZER:
I wonder whether in the 18 photocopying of this, the sheet underneath 19 bled through to create a shadow of an 20 impression of another graph.
21 MR. FISKE:
I am only asking Mr.
22 Frederick about the dashed line and the solid 23 line in the period from about 20 minutes to
?
24 about 60 minutes.
(
25 (Continued on next page) b
+
- D 1
Frederick 716 O
\\_)
2 BY MR. FISKE:
3 Q
Do those reflect pressures for the 4
steam generators 940 pounds or above?
lh 5
MR. SELTZER:
I object.
No foundation 6
that the witness has seen this chart before 7
or on the day of the accident he was familiar 8
with this data since it was Faust who was 9
standing in front of the secondary side 10 panels.
Nor has Mr. Frederick prepared this 11 chart.
It speaks for itself.
12 Q
Did it come to your attention in any 13 way during the period between 20 minutes to 60 14 minutes into the accident that the steam generator 15 pressures were not within normal limits?
16 A.
The only way that I recall receiving 17 information about this is Mr. Faust telling me what 18 he was seeing on the panel.
I don't at this time 19 recall exactly what he said, but he said he was 20 having trouble with pressure and trouble with 21 level.
Whether that happened in the 20- to 60-22 minute time frame that you are talking about, I 23 don't recall.
24 (Discussion of f the record between the
}
25 witness and his counsel.)
I ID 1
Frederick 717
)
2 Q
Looking at this graph, which shows 3
pressure for both steam generators during that 4
period of time as being above 940 pounds per ll 5
square inch, does that refresh your recollection 6
that Mr. Faust was not having trouble with steam 7
generator pressure during that period of time?
8 MR. SELTZER:
What period of time?
9 MR. FISKE:
The period from 20 minutes 10 to 60 minutes.
11 A
No, this graph, with its apparent 12 inconsistencies and my inability to match up all
()
13 the information you are showing me here, doesn't 14 refresh my recollection about what Mr. Faust was 15 saying at all.
16 Q.
What are the inconsistencies on this 17 graph?
18 A
Just looking at it quickly, you can see 19 at the 30-minute mark, B generator was at something 20 between 950 and a thousand, and the A generator 21 was above a thousand.
Here they both look like 9
22 they are near 940.
There is a 60 pounds difference 23 somewhere.
24 Q
Do any of those pressures indicated
\\)
25 that you just read off for those time periods
- 18 1
Frederick 2
indicate to you or refresh your recollection that 3
Mr. Faust said that he was having trouble with the 4
steam generator pressures during that time period?
lll 5
MR. SELTZER:
Objection.
The witness 6
didn't indicate that he had any problems with 7
his recollection or that it needed refreshing.
8 Q
You can answer the question.
9 MR. SELTZER:
He already testified that 10 he has a recollection about what Faust was 11 telling him.
12 MR. FISKE:
But he testified he didn't
()
13 remember during what time period that was.
14 I am trying to show him these GPU graphs 15 showing what the pressures were in an effort 16 to perhaps refresh his recollection as to 17 during what time pariod Mr. Faust said he was 18 having trouble with the steam generator 19 pressures.
20 A
These graphs aren't helping my 21 recollection at all.
I would venture to guess that 22 these are B&W reactimeter data and not GPU graphs 23 as you stipulated.
24 Q
I will tell you, just to clear that up, J
25 these are graphs submitted by GPU to the NRC as
D 1
Frederick 719 2
part of the official LER for this accident.
3 MR. SELTZER:
They could still have 4
been prepared from a B&W-supplied and lll 5
installed and maintained reactimeter.
6 MR. FISKEi Wherever they came from, 7
GPU obviously endorsed them when they 8
submitted them to the NRC as their official 9
record of this accident.
10 MR. SELTZER:
GPU relied on a lot of 11 things that they have come to regret.
12 MR. FISKE:
I think we'll stand on the
()
13 fact that if GPU was -ready to submit B&W 14 data to the NRC as their official record of 15 this accident in September 1980, that we can 16 all draw appropriate conclusions as to the 17 significance of that.
If GPU chose to rely 18 on B&W a year and a half after the accident, 19 we'll all draw the appropriate inferences 20 from that.
21 BY MR. FISKE:
22 Q
Let me just see if we can move this 23 along.
Go back to the transcript of your interview 24 with the President's Commission people on May 10, 25 1979.
l 1
Frederick 720 2
I direct your attention to page 31, 3
the middle of the page.
This is referring to a 4
period of time after you discovered that the 12's lh 5
had been closed.
I will just read part of your 6
answer on that page and over to the next page.
7 "Mr.
F re de rick :
I stayed monitoring 8
the primary plant to see if anything had changed 9
that would give me a clue as to what was going on.
10 Everything remained the same.
The pressurizer 11 stayed full.
The temperature stayed high, and the 12 pressure stayed low, and I couldn't change
()
13 anything.
I couldn't get control.
I was waiting 14 for them to get control of the generator to bring 15 the pressure back up, to stop the rapid cooldown 16 that we,were seeing.
17 "Ms.
Dicker:
How long were you waiting?
18 You say
'a long time.'
19 "Mr.
Frederick:
This was a half hour 20 or more, okay?
It wasn't until a half hour or 21 more, a quarter to five or five o' clock or 9
22 something that they did stabilize the generators 23 and it had little or no effect on my side of the i
24 plant *.
So we are now in a position where our first 25 assumption of the generators wasn't our problem.
1 Frederick 721 2
That was wrong.
There was something else wrong, 3
so what we wanted to try to do was eliminate 4
variables here and there.
We were trying to h
5 pinpoint whe.r", the problem actually was. "
6 Did you give that statement to the 7
representatives of the President's Commission on 8
May 10?
9 MR. SELTZER:
This last sentence you 10 left out was "We didn' t have any direct 11 indication of what was causing our low 12 pressure; I don't know."
13 MR. FISKE:
That's right.
14 Q
Do you remember making that* statement 15 to the representatives of the President's 16 Commission?
17 A
No, but it does reflect the time 18 confusion I was having.
I didn't know whether 15 19 minutas or a full hour had gone by at thi's point, 20 and this is May 10.
21 Q
so you did make this statement on May 22 jo7 23 A
I don't remember making it.
24 Q
You are not telling us now that you
(-
25 didn't, are you?
I 4
8D 1
Frodarick 722
(,,
2 A
No, I just don't specifically recall.
3 Q
There was a time then, was there not, 4
during the accident sequence when you learned that lll 5
you did not have a problem with the steam 6
generator?
7 MR. SELTZER:
Say that again.
8 Q
This statement says, "It wasn't until 9
a half hour or more, a quarter to five or five 10 o' clock or something that they did stabilize the 11 generators and it had little or no effect on my 12 side of the plant, so we are now in a position
()
13 where our first assumption of the generators 14 wasn't our problem.
That was wrong.
There wa's 15 something else wrong."
16 All I am asking you is, there was a 17 point in time in the accident sequence when you 18 came to the conclusion that if you had thought i
19 there was something wrong with the steam l
20 generators, that that assumption had been wrong, 21.
that the' problem was somewhere else?
22 A
I don't remember coming to the 23 conclusion that there was something else wrong.
I 24 do remember that after this time went by, whether 25 it was 15 minutes or an hour or more or five l
l I
I 9D 1
Frederick 723
/
2 o' clock, somewhere along the line I began to think 3
that the steam generator was stable enough that it 4
was in a normal configuration.
lh 5
The other conclusions were not 6
conclusions I was making before the accident.
7 These are other conclusions.
8 Q
Let me read you testimony from the 9
Udall hearings, page 133.
10 MR. FISKE:
We'll mark that as B&W 662.
11 (P age 133 from the Udall hearings 12' marked B&W Exhibit 662 for identification, 13 as of this date) 14 Q
I direct your attention to page 133.
15 MR. SELTZER:
Take a moment to read the 16 surrounding testimony.
17 Q
I am reading a paragraph from the answer 18 that you gave in the middle of the page on page 133.
19 "When we got the steam generators 20 stabilized as far as level and feed rate, the 21 steam generators seemed to be masking what was 22 going on in the pressure cooling system.
For the 23 next hour or so, we worked on trying to stabilize 24 the steam generators, which we fintily did about
(
25 50 minutes in or so.
We eliminated the steam
TOD 1
Frederick 724 ik/
2 generators as being the cause of our problem."
3 Do you see that statement?
4 A
Yes.
ll 5
g Does that refresh your recollection 6
that in or about 50 minutes into the accident, you 7
eliminated at that point anyway the steam 8
generators as being a cause of the problem?
9 A
No, this is just a summary that I gave 10 to somebody.
It definitely includes postaccident 11 conclusions.
It doesn't reflect my recollection 12 today of this situation we are discussing at all.
f%
(._)
13 Q
Is it your recollection today that you 14 did not eliminate the steam generators as being the 15 cause of the problem in or about 50 minutes into 16 the accident?
17 MR. SELTZER:
Are you implying that at 18 50 minutes into the accident Mr.
Frederick 19 still thought that there was a problem?
l 20 MR. FISKE:
No, I am implying just the 1
21 opposite.
I believe what he said to the Udall f
22 committee was that 50 minutes or so into the 23 accident, they had eliminated the steam
(~T 24 generators as being the cause of the problem.
L,]
25 MR. SELTZER:
So you are not implying i
1 D
1 Froderick 725 2
that there is any other ongoing problem at 3
the time they solved the steam generator 4
problem.
That is not part of your question jll 5
to imply that?
6 MR. FISKE:
My question is what it is.
7 MR. SELTZER:
I thought it was 8
ambiguous.
Your saying~ it is exactly what it 9
is doesn't resolve the ambiguity.
10 MR. FISKE:
Would you read back the 11 question?
12 (Record read)
(
13 A
It is not my recollection that I made 14 that conclusion in or about 50 minutes.
It doesn't 15 seem consistent with my recollections or the graphs 16 that you showed me that we were stable in just ten 17 minutes.
It doesn't give me any new recollections 18 or anything.
19 Q
Do I understand your testimony to be 20 that your present recollection is that you may have 21 concluded that there was no problem with the steam 22 generators at some point earlier than 50 minutes 23 into the accident?
24 A
No, I can't say that, because we 25 continued having other steam generator problems for
ll 1
Frederick 726 2
several more hours.
We even isolated one at 5:30.
3 Q
I understand that there were later 4
events and we'll get to them later.
Indeed, I jll 5
tried to make that clear in one of my questions 6
before.
I am only talking about this period of 7
time now from the time th at the reactor trip 8
occurred up to this particular point in time that 9
you were discussing in your testimony before the 10 Udall committee, and I understand that at some 11 later period in time, indeed it is reflected on 12 the graph, there were some other problems with the
()
13 steam generators.
I am not getting to those yet.
14 I am talking just of the earlier period.
Do you 15 understand that?
16 A.
Yes.
My problem all along has been to 17 separate the times that we are talking about, and 18 because of the time confusion that I was having 19 during this accident in the first couple of hours, j
20 I just can't separate the events any more.
21 Q
That is why I thought it might be 9
22 helpful to go back to testimony you gave only a few
(
23 weeks after the nccident when presumably your I
24 recollection of what had happened during the Cs 25 accident sequence may have been a little fresher l
i l
l 1
Frederick 727 O
2 than it is today, three years later.
I am just 3
going to this question or this answer that you gave 4
to the Udall committee, which says lh 5
"For the next hour or so, we worked on 6
trying to stabilize the steam generators, which we 7
finally did about 50 minutes in or so.
We 8
eliminated the steam generators as being the cause 9
of our problem."
10 I am simply asking you now, isn't it a 11 fact that at some point up to 50 minutes into the 12 accident and maybe it was less than 50 minutes, you
(
13 had come to the conclusion --
14 MR. SELTZER:
Maybe even ten minutes.
15 g
-- you had como to the conclusion at 16 that poi.nt that the steam generators were not the 17 cause of your problem?
18 MR. SELTZER:
When.you say "your 19 problem," what problem are you referring to?
20 MR. FISKE:
I am referring to the same 21 problem that Mr. Frederick was referring to 22 in his statement to the Udall Committee when 23 he said, "We eliminated the steam generators 24 as being the cause of our problem."
25 MR. SELTZER:
Why don't you establish
I 1
Frod9 rick 728 (O
,j 2
then as a foundation that he recalls this 3
testimony, and if he does, what was the 4
problem he was referring to in this testimony.
lh 5
Otherwise, I object.
No foundation,what 6
problem you are referring to.
7 MR. FISKE:
Could you read back the 8
last question?
9 (Record read) 10 MR. SELTZER:
Are you going to ask him 11 what the problem is that is referred to here 12 and whether he recalls this testimony?
[)
13 MR. FISKE:
I will let him answer the
%J 14 question I requested.
15 A
I don't recall when or if I made the 16 conclusion that you are referring to.
It is 17 unfortunate that you are using this particular 18 section of testimony to try and refresh my 19 recollection, because this testimony is not based 20 on recollections.
This is a summary, which 21 includes many conclusions that I made after the 22 accident, and it is not really things that I 23 remembered.
So I am not going to be able to 24 remember now either.
73 t
i v
25 (Continued on next page)
i D
1 Frodarick 729 O
(_j 2
BY MR. FISKE:
3 Q
I take it then, even by that answer, 4
tht within six weeks or so after the accident, you lh 5
had learned that during the accident sequence the 6
steam generators had been eliminated as being the 7
cause of a problem within 50 minutes or so after 8
the accident started?
9 A
No, I can't say that I learned that.
10 The problem referred to higher up on the'page is 11 that we were generating steam, and that was 12 certainly caused at least in part by the loss of
()
13 heat sync.
14 Q
You said to the Udall committee, "For 15 the next hour or so, we worked on trying to 16 stabiliae the steam generators, which we finally 17 did about 50 minutes in'or so.
We eliminated the 18 steam generators as being the cause of our problem."
19 Who were you referring to when you used l
20 the word "we" in those sentences?
21 A
Everybody that was in the control room, 22 mostly Mr. Faust.
23 Q
Including yourself?
24 A
In the summary statements I was using n
V 25 in this testimony, I think that I was including
I 16D 1
Frederick 730 ry k,)
2 myself in the group that was in the control room.
3 Whether I actively participated in discussions or 4
made conclusions, it is certainly not stated in lll 5
this portion of the testimony.
6 (Recess taken) 7 BY MR. FISKE:
8 Q
Let me go back to this answer that we 9
were looking at before that you gave the Udall 10 committee back in May 1979.
In the sentence, in 11 the paragraph immediately before the one I read a 12 minute ago, you say, "But we attributed the low f) 13 pressure to the problems he was having with the G'
14 s te am generators."
15 Do you see that statement?
16 A,
- yes, 17 Q
"We" in that sentence refers to you, 18 among others?
19 A
I would only be assuming what it means 20 now.
I don't recall even saying it.
21 Q
The fact of the matter is, you were 22 aware of the fact in the first 50 minutes of the l
l 23 accident that you had a low reactor coolant system l
24
(
)
pressure, isn't that correct?
l s
i i
\\.
25 A
Again, tacking on the 50-minute l
7D 1
Fredsrick 731
(
2 qualifier, I wasn't really aware of the time until 3
after the accident we analyzed how much time had 4
gone by in each one of these incidents.
I had lg) 5 looked at the pressure indicator several times, 6
and I knew that the pressure was low.
Whether it 7
was 50 minutes or not, I can't say.
8 Q
Was there any time during the accident 9
sequence in the first two hours when you felt that 10 pressure was at a normal levol?
11 A
I remember feeling that it was under 12 control.
The fact that it was not in the normal 13 window was a consideration.
14 Q
Isn't it a fact that at some point you 15 were attributing the low pressure that you were 16 seeing on the reactor coolant system to possible 17 problems in the steam generator?
18 A
No, the connection I made was between 19 the pressurizer level and the emergency feedwater 20 situation.
21 Q
When you said to the Udall comuittee, 9
22 "We attributed the low pressure to the problems he 23 was having with the steam generator," who was the l
24 "he" in that sentence?
O'-
25 A
I think I said I don't remember saying
l
.D 1
Frederick 73 2 2
this.
I can say now that the "we" was probably i
3 everybody except the "ne "who I assume was Craig, but 4
I don't even remember saying this.
lh 5
Q Isn't it a fact that during this period 6
of time between 4:30 and 5:00 o' clock, you did not 7
see symptoms on the steam generator side of the 8
plant sufficient for you to conclude that you had 9
in fact a steam line break?
10 MR. SELTZER:
Objection.
No foundation 11 that Mr..
Frederick was aware of symptoms 12 on the secondary side since he testified and 4
()
13 he drew you a picture where he was standing 14 observing the primary side.
15 MR. FISKE:
I think if you listen to 16 the question, you should not have any 17 problem.
18 (Record read) 19 A
I remember that we considered the l
20 possibility of a steam line break sometime during 21 the morning, but again I can't isolate it to any 9
22 given time frame.
23 Q
And the fact that you told the Udall i
.4 committee that you "had eliminated the steam j
25 generators as being a cause of our problem 50
I 19D 1
Frodarick 733 I
(m) 2 minutes in or so, " does not help'you today to 3
remember when it was that you reached that 4
conclusion?
lg) 5 A
In the paraphrase of my testimony that 6
you just gave me, are you saying that the problem 7
that I was referring to here was a steam leak?
8 Q
I am asking you whether, isn't it a 9
fact that between 4:30 and 5:00 o' clock in that 10 period of time, you did not see symptoms in the 11 steam generators that would lead you to believe 12 that there was a steam leak?
['N 13 MR. SELTZER:
I object.
Asked and
'\\s' 14 answered.
He said it was considered sometime 15 in the morning, but he couldn't specify what 16 time.
17 A
That is the answer I gave before, yes.
18 Q
Did you unde rstand before the accident 19 that steam 'enerator pressure in the normal range g
20 was inconsistent with a steam line break?
l 21.
A No.
My understanding then is as it l
22
-is now, that a steam line break of up to a certain I
23 size will be manageable in the steam pressure 24 control system.
In other words, if the steam leak 75 is not of the size described in the accident l
OD 1
Frodorick 73 4 O(_/
2 analysis in the FSAR, smaller than that, some 3
degree, you will be able to control the system 4
pressure in spite of the leak.
lll 5
Q In other words, your testimony is that 6
a small steam line break was consistent with normal 7
steam generator pressures?
8 A
I understood that we could have a steam 9
line break and still maintain system pressure at 10 the posttrip level.
11 Q
In the case of a break size that you 12 described earlier?
()
13 A
Again, I don't recall any specific 14 break size.
It was just I would think something 15 smaller than a turbine bypass valve opening or one 16 or two turbine bypass valves.
17 Q
Did you understand that having 18 temperature in the normal range was inconsistent 19 with a steam line break?
20 A
Are we talking now about reactor 21 coolant system temperature?
22 Q
Yes.
T-Av.
l 23 A
Again, it depends on the size of the l
24 steam leak.
You can-control temperature with the
~
25 bypass valves or with a leak and the bypass valves.
i L
4 D
1 Frodorick 73 5
()
2 It all depends on the size of the leak.
3 Q
Were you aware that there were unique 4
symptoms in the LOCA and steam line break lll 5
proced,ures for identifying a steam line break?
MR. SELTZER:
What does that mean?
6 7
Unique?
8 MR. FISKE:
I think I am using the 9
words the procedure used.
10 A
I think you and I discussed that last 11 week with the LOCA procedure.
12 Q
Yes.
/~h 13 A
Certain unique symptoms listed in the
(_/
1 14 LOCA procedure.
15 Q
Yes, certain symptoms that were unique 16 to a steam line break, correct.
17 A
I think there were three different 18 symptoms.
19 Q
For a steam line break?
20 A
For three different types of -- unique 21 symptoms to separate you from three different 9
22 types of transients.
23 Q
And for the steam line break, weren't 24 there three symptoms in the procedure that were O
25 described as being unique to a steam line break?
~
1 Frodorick 736
(
2 A
I don't recall how many there were.
I 3
think we already discussed each one of them.
4 Q
Feedwater latch system actuation?
lll 5
That was one, was it not?
6 A
That was one what?
7 Q
That was a symptom unique to a steam 8
line break?
9 A
It was a symptom listed as being an 10 additional symptom that one could use to help 11 differentiate between those three types of 12 incidents, but I think we explained as we discussed 13 the LOCA procedure, in my mind none,of those
]
14 symptoms is unique to a given transient unless a 15 conclusion has been made, and all you are trying 16 to do is, look for supportive evidence.
17 Q
Did you see any feedwater latch 18 actuation in the first hour of this accident?
19 A
I am not aware that a feedwater latch 20 occurred.
21 Q
Another symptom that is described as O
22 being unique to a steam line break was a low hot j
23 well level.
Do you remember that?
l l
24 A
Again we discussed that one in the same 25 way.
It may not be unique to a steam line break.
73 7
.D 1
Frederick
()
2 Q
But it is a symptom of a steam line 3
break?
4 MR. SELTZER:
This is asked and llI 5
answered.
I thought we spent at least a half 6
hour on this earlier.
7 Q
Did you see a low hot well level in the 8
first hour of this accident?
9 A
I don't recall seeing one, no.
10 Q
Isn't it a fact that there was a high 11 hot level alarm in the first four minutes?
12 A
That I can't tell you.
I am not sure
()
13 that anyone in the control room was aware of that.
14 Q
Did you know that Mr. Zewe had left the 15 control room at about 4:40 to go to the turbine 16 room for the specific purpose of working on high 17 hot well level?
18 A
Again I recall that sometime during 19 the accident Mr. Zewe left the room and informed us
~
20 that he was leaving the room, but I don't remember 21 when that was.
22 Q
Did he tell you why he was leaving?
23 Did he tell you what he was going to do?
24 A
It was his practice to tell us what he g-(
25 was doing, just as we all told each other what
.D 1
Frederick 738
_()
2 each of us was doing, and I don't recall what he
-3 said now.
4 Q
Didn't he tell you that he was leaving lll 5
to go work on a high hot well level?
6 A
I don't recall what he said.
7 Q
On the day of the accident, did you 8
understand that a high hot well level was 9
inconsistent with a steam line break?
4 10 A
No, there is no reason to conclude that 4
l 11 a high hot well level is inconsistent with a steam 12 line break.
High hot well level can be due to
()
13 many, many contributing factors.
14 Q
You mean, so I can have your 15 understanding on the day of the accident, if you 16 have a p.rocedure which says low hot well level is 17 a symptom unique to a steam line break, but high 18 hot well level is not inconsistent with a steam 19 line break?
Is that your testimony?
20 A
I believe this is the same discussion 21 we had before and that the uniqueness of these 22 symptoms is not' obvious to an experienced operator.
23 You can attribute these symptoms to many different 24 causes.
They are listed there as an aid to the 25 operator in his reasoning process.
There is
.c
1 Frodsrick 73 9 2
certainly nothing black and white about the 3
appearance of one or another symptom.
4 Q
I don't think you have answered my lll 5
question.
6 MR. SELTZER:
I think he answered it 7
very well.
,You just don't like his answer.
8 MR. FIS KE :
I think it is a little 9
hard to follow, yes.
10 Q
Did you understand on the day of the 11 accident that if you had steam generator pressure 12 in the normal range, T-Av in the normal range, and
()
13 a high hot well level, that those three symptoms 14 in combination were inconsistent with a steam 15 line break?
16 MR. SELTZER:
What were the three 17 conditions again?
18 Q
Normal pressure, normal temperature 19 and a high hot well level.
20 A
In the 21 MR. SELTZER:
Normal temperature 22 where?
23 MR. FIS KE :
T-Av.
24 MR. SELTZER:
Normal pressure where?
25 MR. FISKE:
6D 1
Frederick 740
\\_/
2 A
The discussions that we have been 3
having about symptoms, we said that symptoms are 4
parameters that are not within their normal band.
lll 5
Certsinly normal pressure and normal temperature 1
6 would not in my understanding be considered symptoms 7
of anything.
They are again indications that I 8
will just enter into the thought process that I 9
have in coming to a conclusion of what is 10 happening.
The symptom of normal pressure and 11 normal temperature and high hot well level tells 12 the operator absolutely nothing except you have a
()
13 high hot well level.
14 Q
You mean those three things in 15 combination aren't of any use to the operator in 16 trying to decide whether or not he has a steam 17 line break?
18 A
Certainly they are, if he is trying to 19 make a decision about whether or not he has a steam 20 line break, but as I said before, I don't know when 21 I was trying to make that decision or if I was even 22 engaged in discussions at this time when these 23 parameters were exhibited.
24 Q
And the fact that you told the Udall
\\
25 committee that, "We stabilized the steam
t 27D 1
Frodarick 2
generators about 50 minutes in or so and we 3
eliminated the steam generators as being the cause 4
of our problem," doesn't refresh your recollection k
5 that in that period of time you had concluded that 6
there was not any steam line break?
7 A
Again, this reference to the passage of 8
the 50 minutes indicates to me that this is not a 9
thought process that I was actually going through 10 on the day of the accident.
This is a summary that 11 I am giving to somebody about what was going on on 12 the day of the accident.
This is my explanation of
()
13 what happened.
It includes all kindr of conclusions 14 that I made before and after the accident.
It is 15 just a summary.
That is all.
16 Q.
So what is the answer to my question?
17 MR. SELTZER:'
What was the question?
18 MR. FISKE:
Read it back.
19 (Record read) 20 A
That's right.
This testimony doesn't 21 include any recollections and doesn't refer to a 22 steam line break in any way, and therefore it 23 doesn't refresh my recollection.
24 Q
You said before that on the day of the O
25 accident you had memorized the symptoms in the
I D
1 Frederick 742 p)
(
2 various emergency procedures.
3 A
Yes.
4 Q
Including the symptoms in the lll 5
Pressurizer system failure procedure, correct?
6 A
Yes, I meant that to include all the 7
procedures.
8 Q
You knew that one of the symptoms of 9
an open pilot-operated relief valve was 10 temperatures of the discharge line above the 200 11 degree Fahrenheit temperature alarm, correct?
12 A
My understanding of that symptom was
(
13 that I would get the alarm window to flash, the 14 alarm'on the back of panel 8-A, if the temperature 15 was increasing due to the valve being open.
This 16 symptom.specifically says 200-degree alarm.
I took 17 it to mean increasing temperature, and then you 18 hit the alarm point.
19 Q
Did you look to see whether that alarm 20 had gone off?
l 21 A
When?
22 Q
Anytime during the accident?
Anytime 23 during the first two and a half hours of the 24 accident?
LJ 25 A
I don't recall looking at it.
I have
H 29D 1
Frederick 743 2
been told that I went back there, but I don't 3
remember going back there.
4 Q
Going back where?
llh 5
A To panel 8-A where the annunciator 6
alarm that is mentioned in this symptom is located.
7 I guess I should clarify that.
The 8
symptoms in this procedure refer both to the alarm a
9 on panel 8-A and the alarm that can come up in the 10 computer.
What I am talking about is the 11 annunciator.
]
Q Did you look to determine whether the 12 13 computer alarm had come up for the temperatures on 14 the discharge line?
15 A
I don't recall using the computer at l
16 all early in the day, because it was not an 17 instrument I used on transients.
i 18 Q
Were you aware on the day of the l.
19 accident that there was a means by which you could i
i 20 obtain readings from the thermocouples on the i
21 discharge line for the pilot-operated relief valve l
22 and the code safeties?
i l
l 23 A
My understanding wasn't as specific l
l 24 as you just related in your question.
25 I knew that temperatures in common l
l
. ~.
l 8
1 Frederick 744 i
2 discharge line of the three relief valves were 3
available in the computer, and if I took the time 4
to punch in the right numbers, I could read what h
5 those temperatures are.
6 (Continued on next page) 7 8
9 10 1
11 12 13 14 15 16 17 18 19 l
20 O
l 22 23 O
25 l-i
{
l
J45 1E 1
Fradarick 2
Q Did you know that at any time you wanted 3
to get them during the course of the accident 4
sequence, you could get them from the computer?
lll 5
A If you are asking me if I thought about 6
that transient, no.
7 Q
But before the accident, before the day 8
of.the accident, were you aware that the computer 9
had that capability?
10 A
The capability of displaying the 11 temperatures in the common discharge line?
12 Q
Yes.
'13 A
Yes, I think we took readings on that 14 almost every day.
or whenever we had the midshift.
15 Q
You referred t6 a common discharge line 16 in your.last answer.
Is it your testimony that you 17 understood on the day of the accident 9, es t all 18 three temperature reading devices were on the same 19.
discharge line?
20 A
Yes, I think I said before, I understood 21 that they all came together in a common pipe.
All 22 the discharges of the safety valves, the relief 23 valves, came together.
That is why they are common.
24 They are all hooked together.
No valves in between.
25 Q
I think we are talking of two different
1 Fredsrick 746
()
2 things.
I think you testified that you understood 3
that at some point the discharge from the PORV and from ei'her of the code safeties 4
the discharge c
lll 5
would all flow into a common pipe which went into 6
the reactor coolant drain tank, correct?
7 A
Yes.
8 Q
Is it your testimony that you 9
understood that the temperature reading devices 10 for each of these three valves were all located on 11 that common line, on that common pipe?
12 MR. SELTZER:
I don't understand that
(
13 question.
14 A
I didn't really have any idea where 15 each of the three detectors were located.
It is 16 like tha exhaust manifold on a car.
The pipes 17 come off the side of the engine and come together 18 in one pipe.
That is what it is like.
19 Q
Did you make any effort at any time in 20 the first two and a half hours of the accident 21 sequence to try to find out what the temperatures 22 were on the discharge line leading from the 23 pilot-operated relief valve?
24 A
No, I had no reason to go look at those.
O*)
25 Q
The pressurizer system failure
1 Frederick 747
)
2 procedure lists as a second symptom of an open 3
pilot-operated relief valve th Tt the reactor 4
coolant drain tank pressure and temperature are lll 5
above normal on the control room rad waste disposal 6
control panel 8-A.
Do you have that in front of 7
you?
j 8
A Yes.
9 Q
And you knew that symtom on the day of t
10 the accident, did you not?
11 A
Are you asking me if I thought about 12 that on the day of accident or if it is one of the
()
13 ones I memorized along with all the rest of the 14 symptoms?
15 Q
on the day of the accident, you had 16 that symptom memorized with all the others, did you 17 not?
18 A
Yes.
19 Q
Just one more question with respect to 20 temperatures.
Did you know before the accident 21 that in addition to being able to go to the 22 computer and ask for the temperature readings at j
23 any particular point in time, you could also have 24 thors readings put on a trend recorder so that you
)
/
25 could see the readings as they moved progressively
I g
1 Frederick 748 2
through a time period?
3 MR. SELTZER:
Objection.
No foundation 4
that he knew you could go to the computer and lll 5
get out the temperature readings for any 6
point in time other than a contemporaneous 7
reading.
8 MR. FISKE:
He just said that.
Maybe 9
my question isn't clear.
I am not trying to 10 build more into your last answer than you 11 intended, Mr. Frederick.
12 Q
You testified that you understood that
()
13 at any time-you wanted to, you could go over to the 14 computer and you could obtain from the computer a 15 reading at that point in time for tr.mperatures at 16 the discharge lines, correct?
17 A
Yes.
18 Q
Did you also understand on the day of 19 the accident that you could also go over to the 20 computer and obtain information via a trend 21 recorder which would give you the temperatures at 22 the discharge line for a continuing period of time 23 so that you could cee changes in temperature over 24 that period of time?
25 A
There is a limited availability for the I
~,
-...n..
~l
l 1
Fredsrick 749
(
2 use of four trend recorders in which you can put 3
any one of the 3,000 BOP points onto the trend 4
recorders.
There is a normal operating procedure jl 5
which I think is outlined in the power operations 6
procedures as to what four parameters should be 7
displayed on those graphs, and normally they were 8
in use and you have to erase one of those in order 9
to put another point on.
l*
10 Q
But you understood that you could do 11 that.?
It was possible to do that?
12 A
It was possible, but you have to
(}
13 consider stepping out of your normal operating 14 procedure in order to do that.
You are going to 15 lose normal operating information.
16 Q
Did you give any consideration to doing i
17 that during the course of the accident?
Putting 18 these temperatures at the discharge lines on that i
19 trend recorder?
20 A
No, I didn't even consider going to 21 look at the temperatures.
There was no reason to 22 look at them.
23 Q
Did you understand you could also get 24 that same kind of trend information through the O
25 utility printer without displacing any of these
_~
. _ _,. -,.. +, -
y
1 Fredsrick 750 A( )
2 other four readings?
3 A
The graph, you mean?
4 Q
Yes.
lll 5
A No, it is not available on the utility 6
printer.
7 Q
Do you understand I am not necessarily 8
limiting my question to the form in which it is 9
displayed, but simply, did you understand that 10 through the utility printer, you could obtain 11 successive readings over a period of time for the 12 temperatures at the discharge line so that you
()
13 would be able to see changes in temperatures over 14 a period of time?
15 A
Yes, we often used that time printer 16 for observing any number of points in the plant, 17 secondary and primary plant, but again, you have to 18 have some reason to call up an individual point 19 an'd then want to monitor it for a given length of 20 time.
21 Q
Did it come to your attention at any 9
22 point during thE first two and a half hours of the 23 accident that any one of the other operators had 24 obtained any information with respect to V
25 temperatures at the discharge line from the PORV7
,.-e
,---u
.rm, e
w
l F ro deri.ek 751 1
()
A Did it come to my attention that 2
- "" "9 3
4 Q
Yes, during the course of the first two lll and a half hours of the accident, that any of the 5
6 other operators had obtained that information?
A No.
7 8
Q I think we were about to start on the drain tank pressure and temperature symptom B-14 9
10 f the inoperative pilot-operated relief valve.
This symptom refers to drain tank pressure and gy 12 temperature as reflected on the control room rad
()
waste disposal control panel 8-A.
13 Could we look at the chart of the 14 control room that has the numbers of the panels on 15 16 it, which I think is 659-A.
Do you have that chart in front of you, 659-A?
17 18 A
Yes.
gg Q
Is panel 8-A the one on the far lower left of this chart?
20 MR. SELTZER:
It depends which way you 21 9
hold the chart.
22 l
23 MR. FISKE:
I am holding it what I I
assume right side up.
24 G'
MR. SELTZER:
If you hold it with the 25
l l
8E 1
Fredarick 752 2
page number at the bottom, it would be the 3
right-hand corner.
4 MR. FISKE:
I am holding it in the way 5
you can read it.
ggg 6
MR. SELTZER:
You can read it a lot of 7
ways.
If you hold it vertically, the 8
lettering across the top is printed from left 9
to right.
10 BY MR. FISKE:
11 Q
In reference to panel 4,
panel 8-A is 12 behind it and to the left, isn't that correct?
()
13 A
In reference to panel 47 14 Q
Yes.
15 A
Panel 8-A is behind it and to the left?
16 Q,
Well --
17 A
That is not true.
Panel 4 is near the 18 center of the control room.
You didn't mean 19 panel 4, did you?
20 MR. SELTZER:
If panel 4 is at twelve 21 o'cicek, panel 8-A is at nine o' clock.
O 22 MR. FISKE:
That is acceptable.
23 Q
What kind of instrumentation was there 24 on that panel that displayed pressure and O
25 temperature for the reactor coolant drain tank?
9E 1
Fredsrick 733
(
2 A
There are on that panel, among other 3
switches, dials and lights, three 3-inch partial 4
scale meters used to read normal operating band gg) 5 temperature, pressure, and level in a porston of 6
the tank.
The level would indicate a portion of 1
7 the tank.
Pressure and temperature would be the 8
whole thing.
9 Q
Was there any other instrumentation on 10-that panel related to pressure or temperature of 11 the drain tank?
12 A
The rest of the panel is a mimic 13 diagram of the coolant system and the drain system 14 for the tank and how it is connected to the rest 15 of the plant, and at the top of the panel, 16 actually,above the panel, is an annunciator board 17 similar to the ones loca'ted throughout the rest of 18 the control room.
19 Q
You mean with alarms?
20 A
The lights are there.
The noise that 21 it makes is the same as the alarm on the master 9
22 board up front.
i 23 Q
What lights are on that panel 24 reflecting alarms for the pressure or temperature O
25 of the drain tank?
10E 1
F redsrick 754 I\\
2 A
I think we talked about this before, V-3 and I couldn't remember the way the boxes are 4
labeled on top of the panel.
There are about a ggg 5
dozen alarms.
6 Q
was there an alarm for high pressure?
7 MR. SELTZER:
This was asked and 8
answered.
He said there is either a trouble 9
alarm or a temperature alarm.
He couldn't 10 remembe r which it was.
11 Q
Is that still your best recollection?
12 A
Yes.
I haven't reviewed any diagrams 13 of the control room.
I haven't been there in about 14 two weeks.
15 Q
Under normal operating conditions, what 16 was the pressure in the drain tank?
17 A
To the best of my recollection, it was 18 zero.
19 Q
Under normal --
i i
20 A
PSIG.
21 Q
What was the normal temperature?
22 A
I don't remember what the normal 23 temperature was.
It is listed right next to the 24 gauge, there is a sign that says what the normal 25 range is, so I never really memorized it.
I j ust y,-,--
-e--ew,
,e e
v.
m
,,-,,p e-
,y e.,
-mwm
,y---w.
e
.r.-
I i.
E 1
Frederick 755 2
referred to the sign.
3 Q
Do you know what temperature the 4
temperature alarm was set for?
What was the set lll 5
point for the temperature alarm?
6 A
Again I don't remember that it was a 7
separate temperature alarm or what the set point 8
was.
All of this is displayed on a little panel 9
in an information box that tells you what the 10 normal operating parameters are and what the set 11 points are.
I didn't use it that often, so I 12 didn't memorize it.
()
13 Q
All of that was there and available on 14 the day of the accident?
15 A
Yes, I think those notes have been 16 there for quite some time.
17 Q
Just so I understand your last answer, 18 that information that was displayed there on the 19 day of the accident would have shown what the normal i
20 temperature and the normal pressure was and it i
21 would also have shown you the point at which a h
22 temperature alarm would have been activated if 23 there was a temperature alarm, is that correct?
24 A-If you ask it that way, I think'as I O
25 recall it now, the alarm set points are displayed
. ~. -
l
,2E 1
Frodarick 756
()
2 in that information on the panel, and I think we 3
got the normal readings from the log sheet.
So 4
when we go back there, it would be to take logs on lh 5
it.
It tells you what it would be reading for days, 6
the last few hours and what the normal range is.
7 I am not sure that the normal range is shown on 8
the panel, but it is on the log sheet, I think.
9 Q
Did you understand before the accident 10 that it would be possible to obtain information 11 from the computer on pressure at the reactor 12 coolant drain tank over a period of time?
13 MR. SELTZER:
When you say "over a 14 period of time," you mean a trend recording?
15 A
That is a rather specific bit of 16 knowledge.
I knew we could call up any one of 17 thousands of points, and I think that is probably 18 one of them.
There are only a few parts of the 19 plant that were unobservable in the computer.
I 20 don't recall ever having done that particular point 21 or group of points.
22 Q
Did'you know it was possible to obtain 23 information as to the temperature in the reactor 24 coolant drain tank on a trend recorder?
O 25 A
In my previous comments, I said I don't a
L 1 hg i
Frederick 757 2
have recollection of specific points being 3
available on the computer, but I would assume that
)
4 is one of the points you could call up in the lh 5
computer.
l 6
Q And that was your understanding on the 7
day of the accident?
8 A
-Yes, basically if I wanted to call a 9
point up for any purpose, the way I would test it 10 to see if it is available, I would find it in'the 11 index and call it up and see if it actually I
12 displayed any numbers.
13 If it is not an active point, it would 14 give you question marks or some other indication 15 that it is not an observable point, so I didn't 16 really carry an index of active points in my mind.
17 I just would call it up and see if it was a good 18 point.
19 Q
Anytime during the course of the first 20 two and a half hours of the accident, did you make 21 any effort to obtain readings on reactor coolant 22 drain tank pressure or reactor coolant drain tank 23 temperature from the computer?
24 A
No, the place to receive that 25 information is on panel 8-A.
There would be no
I i
1 Fredarick 758 13V 2
reason to get it from the computer.
3 Q
To be more specific, did you make any 4
effort at any time in the two and a half hours of, lll 5
the first two and a half hours of th'e accident to 6
obtain from the computer analog trend recorder 7
information with respe ct to reactor coolant drain 8
tank pressure or temperature over a period of time?
9 A
No, I had no reason to go and get that 10 type of time-related information nor even call up 11 temperatures in the drain tank'or downstream in the 12 loop valves or anything, because I was not aware
()
13 that the relief valves were blowing.
That was 14 something that we discovered after the accident.
15 Q
You went to panel 8-A and looked at 16 readings for reactor coolant drain tank pressure 17 and temperature in the early minutes of the 18 accident, didn't you?
19 MR. SELTZER:
What do you mean by
{
20 "early"?
21 Q
Sometime in the first ten minutes?
22 A
No, I don't think that is true.
I just 23 went through the first few minutes of the accident 24 with you earlier, and I don't recall having left 25 the panel during that time.
I was told in other I
.,.. ~. -
E 1
Fredarick 759 1
()
2 testimony that I went back there at some point, but 3
I don't remember actually making the trip.
4 Q
Let's do this.
I think you testified lll 5
yesterday that you stayed at panel 4 at least 6
through the period of time when HPI came on 7
automatically and you assumed manual control and 8
then throttled back the flow, and we established 9
from the chronology that that last event, that is, 10 throttling back the flow, occurred at about four i
11 and a half minutes into the acci ent.
I think we 12 established --
()
13 MR. SELTZER:
Wasn't there an 14 excursion, as you called it, when he went 15 over to the secondary side board very early 16 in the turbine trip?
17 MR. FISKE:
'That's correct.
18 MR. SELTZER:
Within the period that 19 you just related where you said he stayed in 20 front of panel 4?
21 MR. FISKE:
Just so we understand, and 22 correct me if I am wrong --
23 Q
My understanding of your testimony is 24 that with the exception of the excursion that Mr.
25 Seltzer has just referred to, which took you over
l 6E.
1 Frederick 760 2
to the secondary side of the board to panel 6,
you I
3 were in front of panel 4 through at least the time 9
4 you throttled back HPI flow, and the chronology lh 5
filed by GPU establishes that that event occurred 6
at four and a half minutes, and so I am accepting 7
your testimony up to now that in the first four and 8
a half minutes you did not go back over to the 9
other side of the control room and look at the 10 readings on panel 8-A.
Isn't that correct?
11 A
My testimony so far is based on my 12 recollection.
I have given you where I was each
()
13 moment in time as best I can remember.
I don't 14 recall now ever having gone back to panel 8-A.
15 All I am saying is that in other' testimony people 16 have said I went back there.
I don't recall it.
17 Q
Didn't you yourself in testimony 18 shortly after the accident testify that you 19, yourself went back there and looked at the readings 20 for temperature and pressure in the early minutes 21 of the accident?
22 MR. SELTZER:
That is where I asked 23 you what you meant by "early minutes."
I 24 think there is'a problem of time compression C
4 25 that the witness has described for you quite
1 Frederick 761
()
2 a few different times today and yesterday.
3 Q
Without getting hung up for the 4
moment on the precise moment in time when this i
lll 5
happened, isn't it a fact that you did go back 6
and look at the pressure and temperature for the 7
reactor coolant drain tank sometime after the 8
accident started?
9 A
I think I tried to make it very clear 10 that I don't have a recollection of that particular 11 trip or any trip back to panel 8-A.
Whether I went 12 back there once or several times is not a part of 13 my memory at this time.
14 What I am saying is that previous 15 testimony and the relations of other people 16 indicate that I went back there, but things were 17 happening very quickly, and I just don't remember 18 that little trip.
19 Q
so your testimony is that a trip to the 20 reactor coolant drain tank --
21 MR. SELTZER:
The panel, you mean.
22 Q
Is it your testimony now that you draw 23 a blank on any trip to the reactor coolant drain 24 tank panel where you saw pressure and temperature 25 readings for the drain tank?
t
I 18E Frederick 762 V'O 2
A If you mean drawing a blank, that I 3
don't remember doing it, that's right, I don't 4
remember doing it.
h 5
Q I would like to refer to a document 6
which has been marked previously as B&W Exhibit 7
655, which is an interview of you conducted by a TMI O
team headed by T.
Van Witbeck on April 6,
- 1979, 9
approximately one week af ter the accident.
10 A
I have it.
11 Q
I would like to direct your attention 12 to page 5 of that interview.
Referring to the 13 bottom of the page, "The Teams where does your 14 makeup tank get letdown from?
15
" Frederick:
The suction of 1-A pump.
16
" Team:
I thought the drawing said 2-B.
17 I have to check that.
" Frederick:
We went through quite an 19 excursion in the reactor coolant drain tank.
I 20 ran behind the panel to make sure we weren't 21 recirculating coolant or anything, and I noticed 22 there was no level in the tank.
The temperature 23 was pegged high.
The pressure gauge was pegged 24 p
high.
It should have been coming down after the
\\
25 relief lifted.
I
1
_Frodorick 763 2
" Teams when did this occur?
3
" Frederick:
A few minutes after the 4
trip."
5 were you asked those questions and 6
did you give those answers to the TMI team headed 7
by Mr. van witheck on April 6, 19797 8
A I don't recall saying this.
This was 9
a meeting between myself and Mr. Van Witbeck and 10 another part of his group.
It was an effort to 11 try to reconstruct everything that happened on the 12 day of the accident.
It is not necessarily limited 13 to my own recollections.
I was selected to work j
f 14 with him, because I think I had been working with I
15 the training department and they said I had enough 16 time to.go with him.
I don't even know if he 17 interviewed anybody else.
18 Q
Le t ' s go back to my question.
19 were you asked those questions and did 20 you give those answers to the TMI team approximately 21 one week after the accident?
22 MR. SELTZER:
Could you read back the 23 first sentence of his answer?
i 24 (Record read) 25 A
That is true.
I don't recall saying
1 Frodorick 764 2
this.
3 Q
Do you have any basis today for 4
telling us that you did not make that statement lll' 5
to the TMI team on that date?
6 A
No.
Like I said, I don't have any 7
reason to doubt any of these transcripts of 8
discussions that I had with the various committees.
i 9
I just think it is fair that we characterize the 10 difference between testimony on recollection or 11 facts that I can recall and discussions that I had 12 in which I was relating general knowledge without 4
(
13 separating the two.
i 14 Q
I take it your testimony is that the 15 fact that you went back and looked at the pressure 16 and temperature readings for the drain tank and 17 the fact that you told this team a week after the 18 accident that you had done that are both blanks, 19 is that correct?
20 A
Without getting into any of the usual 21 word games of what I actually recollect and what 22 can be inferred from these testimonies, I would not 23 argue with anyone who said that I went back there 24 or that there was evidence that I went back there.
O 25 I am only trying to say I don't recall doing it.
1 Frodorick 765
()
2 Q
when you said to the TMI team on April 3
6 that the temperature was pegged high, pressure 4
gauge was pegged high, what do thore phrases mean?
lll 5
Pegged high?
6 MR. SELTZER:
You mean what did the 7
phrase " pegged high" mean, irrespective of 8
its use in this testimony?
9 MR. FISKE:
Yes, let's start with that.
10 A
The phrase as I use it means that a 11 meter or a gauge has reached its uppermost limit, 12 and that it is indicating the highest number that l (
13 it will indicate.
l 14 Q
What conclusion did you draw at the 15 point in time when you went back and saw that 16 both the temperature and pressure we re pegged high?
17 MR. SELTZERi You know that that is f
l 18 an objectionable, improper question, since 19 he has no recollection of going back.
You 20 haven't even asked him whether he recalls I
21 pressure and temperature being pegged high.
22 Q
I ask you this.
When you went back 23 and saw that the pressure and temperature were 24 pegged high for the reactor coolant drain tank, O
25 did the symptoms of an open PORV flash through
!E 1
Frodorick 766
(}
2 your mind at that point?
3 MR. SELTZER:
Objection.
No foundation 4
that the witness recalls going back and lh 5
noticing the pressure and temperature were 6
pegged high.
7 A
I don't have any recollection of 8
observing the meters, making conclusions about what 9
they were telling me, or applying those 10 conclusions to any specific emergency procedures 11 or enacting any of those emergency procedures.
12 Q
Did you go back to panel 8-A and look 13 at readings for the pressure or temperature of the 14 drain tank on a second occasion?
15 MR. SELTZER:
Objection.
No foundation 16 that he can recall going back at all 17 during the accident.
18 MR. FISKE:
He told us about his lack 19 of recollection in the first trip.
I am 20 asking if he remembers the second trip.
21 MR. SELTZER:
I think you asked him, 22 during the accident does he recall going back 23 there.
Why don't we get it all over with in 24 one throw.
See if he has any recollection O
\\~
25 of going back at all during the day of the
767 IE 1
Frodorick
()
2 accident in the first two hours of the 3
accident.
4 (Record read) llI 5
BY MR. FISKE:
6 Q
In the first two and a half hours of 7
the accident?
t 8
A I think I already stated that I don't 9
recall making any trips going back there to panel 4
10 8-A at all.
11 Q
Is it your testimony that as you sit 12 here today you don't remember having any information 13 at any time in the first two and a half hours of 14 the accident as to pressures or temperatures in 15 the drain tank?
J 16 A.
As I sit here today, I don't recall 17 the value or any information drawn from that panel 18 as entering into any of the thought processes that 19 I was engaged in on the morning of the accident.
i 20 Q
Did it come to your attention in the 21 first 45 minutes of the accident that the level in 22 the sump was increasing?
I
[
23 A
I only recall receiving one report, and i
24 that was that the level was high.
I don't recall O
25 receiving any report saying that it-was increasing.
1 i
I 24E I
Frodorick 768 2
Q Let me show you a document which we 3
will mark as the next exhibit, B&W 663.
4 (Diagram was marked B&W Exhibit 663 for lh 5
identification, as of this date) 6 Q
Do you have that in front of you?
7 A
Yes.
8 Q
Do you recognize this as a diagram 9
of certain portions of the TMI-2 plant?
10 A
I recognize the components and the 11 attempt to represent the configuration of the 12 TMI-2 plant, but it is a very simplified and not
()
13 very representative diagram of the layout.
14 Q
.Let me direct your attention to the 15 bottom of the reactor building where you see the 16 word " sump."
17 A
Yes.
18 Q
That is sort of a well at the bottom 19 of the reactor building, is that right?
20 MR. SELTZER:
Are you asking whether l
21 there is a well at the bottom of the reactor 22 building?'
l 23 MR. FISKE:
Yes.
24 Q
That is what the sump is, is it not?
1 25 A
The sump is actually about a four foot 0
l SE 1
Frederick 769
\\ _.)
2 by six_ foot cube, four by four by six foot deep.
s 3
It is located in the basement of the reactor 4
building.
It is actually below the rest of the lhI 5
floor level.
6 Q
Is it correct that the purpose of the l
l J
7 sump is to collect water that may be accumulating 8
in the reactor building?
9 A
No, the purpose of the sump is to 10 provide a water level that will submerge the pump 11 suction.
In other words, if a small amount of 12 water collects on the reactor building floor, it
()
13 may not be deep enough to provide suction for the 14 pumps, so they provided a little bit of a depression 15 in the floor so that the pump suction would be 16 submerged and allow it to pump even a small amount 17 of water out of the building.
18 Q
So that there is a certain minimum level 19 of water in the sump at all times under normal 20 conditions?
21 A
Ideally, the sump would be empty, but 22 due to the high humidity and the leak-off from 23 some of the primary valves and other sources of
("}
24 water, there is usually some small amount of water
'8~J 25 in there and it is a function of the sump pump to 0
a a
1 Frederick 77g O
2 remove that water accumulation automatically.
It 3
works on a level switch.
4 Q
And at what level of water is the pump lll 5
activated?
6 A
I don't know.
7 Q
Before the accident, did you have any 8
understanding that the level in the sump was higher 9
than it would be under normal conditions?
10 A
I wasn't aware of what the sump level 11 was.
The pumps are designed to maintain -- there 12 are two pumps in there, one normal and one backup, 13 and we don't even display that parameter in the 14 control room.
It is just an automatic function of 15 the pumps.
16 Q,
Is there an indicator in the control 17 room panel when the pumps come on?
18 A
No.
)
19 Q
Is there any way you can find out if i
20 you want to whether the pumps have come on?-
1 21 A
The pumps come on and go off 22 automatically.
It is a matter of routine.
The 23 auxiliary operator in the auxiliary building can
('N 24 observe the pumps going on and off, and he can 25 read the level on the rad waste panel on the
1 Frederick 771
(
)
2 auxiliary board, so if I wanted to know the status 3
of the pumps, I could call and ask him.
4 Q
You knew that you could call him and llI 5
ask him whether they were on or off, is that 6
correct?
7 A
If he was at the panel or if I asked 8
him to go to the panel, he could make that 9
determination for me.
10 Q
In other words, did you understand on 11 the day of the accident that if you wanted to find 12 out at any given point in time whether the sump (r')
13 pumps,were on, you could do that?
%/
14 A
As I sit here and think about it now, 15 as it was before the accident, you could call the 16 primary. operator, and if he was on that side, he 17 could go to the panel and look at the status lights 18 for the pumps and tell me whether they were 19 running or not.
20 I could also, if 1 had an instance 21 where I had to do it, I could go to the computer 22 index and find if those points for the pumps were 23 located in the computer somewhere, and there might 24 be a status whether the pumps were on or of f in 4
25 there.
It might only say whether they were in
= _ _.
l i
28E 1
Frederick 772 2
automatic or not.
3 Q
Did you understand on the day of the i
4 accident that you could find out, if you wanted to, h
5 how long the pumps had been on?
6 A
No, there is no way to tell how long i
7 they have been on unless you stand there and watch 8
the lights.
9 (Time noted:
12:05 p.m.)
10 11 EDWARD R.
FREDERICK 12 13 Subscribed and sworn to 14 before me this day of 15 1982.
16 17
)
18 19 20 e
22 23 l -
24 25
29E 1
773 CERTIFICATE STATE OF NEW YORK
)
3
- ss.:
j COUNTY OF NEW YORK
)
4 O
I, JOSEPH R.
DANYo
, a Notary 5
'Public of the State of New York, do hereby 6
certify that the continued deposition of 7
EDWARD R.
FREDERICK was taken Defore 8
me on
- ThESDAY, MAY 11, 1982 -
consisting 8
of pages 685 through 774 I further certify that the witness had been previously sworn and that the within 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 IN WITNESS WHEREOF, I have hereunto set my hand thin '/['
day of N/y
/ 7J@
2
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/) st 23 p,,,,,,,,,,,.,
o u
774 E
O INDEX WITNESS PAGE Edward R. Frederick (resumed) 687 EX H IB I TS B&W FOR IDENTIFICATION 662 Page 133 from the Udall hearings
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