ML20072H865
| ML20072H865 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/04/1981 |
| From: | Labelle D BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-06, TASK-07, TASK-10, TASK-11, TASK-2, TASK-6, TASK-7, TASK-GB NUDOCS 8306290785 | |
| Download: ML20072H865 (89) | |
Text
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UNITED STATES DISTRICT COrURT
)-
SOUTHERN DISTRICT OF NEW YOEK s
A
-x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
{
(R.O.)
-against-1 i
THE BABCOCK & WILCOX COMPANY and I
J.
RAY McDERMOTT &
CO.,
INC.,
Defendants.
x i
Continued deposition of The Babcock &
l
.~
8.tm)
Wilcox Compa A by DANNYa W.,- LaBELLE, taken by i
Plaintiffs, pursuant to adj ournment, at the offices of Kaye, S cito le r, Fierman, Hays &
j l-Handler, Esqs., 425 Park Avenue, New York, l
New York, t.- Thursday, the 4th. day of Junen 1981(,globot0 l
gcommencing at 9:40 o' clock in the l
forenoon, before Joseph R.
Danyo, a I
Shorthand Reporter and Notary Public within
,j and for The State of New York.
t l
r.
I!
8306290785 810604 l [
PDR ADOCK 05000289
)
T PDR l !
ll DOYLE REPORTING. ' N C.
CERTWlEo STENOTYPE REPORTERS 369 LtxlNGTON AVENUE WALTER sH APIRO, C.s.R.
Nrw Yonx.
N.Y.
Ico17 ll
'I
i 1
253 2
Appe a ra n c e s
(
3 4
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
5 Attorneys for Plaintiffs 425 Park Avenue 6
Byi STEVEN J.
GLASSMAN, ESQ.,
8 of Counsel.
J 9
10 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants i
11 One Chase Manhattan Plaza l
12 f
By:
ROBERT F.
- WISE, JR.,
ESQ.
II 13
-and-WILLIAM E.
WURTZ, ESQ.,
j
! I()
14 of Counsel.
4 1
i i 15 1
16 17 Also Present:
18 DAVID TAYLOR 19 20 21 I
l 22 23 24 25
\\
l
[p 254 1
2 DA N N Y W.
LaBE L LE resumed as a witness and, having been previously duly 3
4 sworn, was examined and testified further as 5
follows:
6 MR. GLASSMAN:
I would like to have marked 7
as *GPU Exhibit-29 2 for identification a
[19050 0 l
8 memorandum dated 5/4/'/9A from D.
W.
LaBelle to l
l 9
J.
H. Taylor with a multi-page attachment.
10 (Memorandum dated 5/4/79 to J.
H.
Taylor 11 from D.
W.
LaBelle, with attached documents, f
12 was marked as GPU Exhibit N 292 for I
(flobsD l
13 identification as of this dateg) 14 EXAMINATION (Continued) 15 BY MR. GLASSMAN:
16 Q
'.*. show you what has been marked as GPU 17 Exhibit-29 2 for identification (handing document to 18 the witness).
Did you send that document to Mr.
19 Taylor in the ordinary course of business?
20 A
As best I can recall, yes, I did.
21 Q
I show you now a copy of what has been i
22 previously marked as GPU Exhibit-103 for identification I
i 23 and ask you if GPU Exhibit-10 3 is the reference f
l 24 contained in GPU Exhibit-292, the letter from J.
H.
25 Taylor to R.
J.
Matson, subject:
Bh @ Company OY30)
Commitments 4/30/79"47 t
r
L 1
LaBo11e 255 2
A As best I can recall, it is.
O 3
Q GPU Exhibit-292 refers to materials Qem-li.6.I) (rtemC.6.ha-G 4
addressed in Items Roman Numeral II.B.1, 2,
3, 4,
5 g
g 4
3 3
@ m-lIS~L
(,'CIPM I'b, 5
and Roman Numeral II.E.
6 I would like you to look at GPU Exhibit-- f 03 7
ko and tell us whether that efers to the items I
l page-B.ll0)
Page-6.lll) j 8
found at Pages
.1104and B.llig o f G P U -10 3 under the l
9 heading "CADDS Analysis."
I 10 A
There is a mention of Roman Numeral-II.E for i
11 which I do not know the specific reference.
I i
j 12 believe that that may be a typo referring to III.E I
l!
13 of GPU Exhibit 103.
- ! r%
14 The other references appear to be consistent s-l
. 11 0 )
(hye-l/l) 15 with Pag 110 and Illy of GPU Exhibib-103.
16 Q
In referring to re f e r en c e -III, Roman 17 Numeral-III.E on GPU 103, are you referring to the 18 reference on Page-B.lli of that document?
19 A
Yes, I am, but I could not state with any 20 assurety that the correspondence is correct between 21 Roman Numeral-II.E and. Roman Numeral--III.E.
I I
, i l
22 Q
Do the references to Items II.B.1, 2,
3, i
23 4,
5 and III.E on GPU Exhibit 103 in turn refer to I
I 24 CADDS studies identified on Page-B.65 contained s_/
25 further on in GPU* Exhibit 1037 4
0
[
^
-~..._.n.
1 LaBelle 256 2
A I don't recall.
3 Q
Do the~ safety evaluations contained in 4
GPU Exhibit-292 address the items which are contained 5
on Page-B.65 of GPU Exhibit-1037 6
A They very well may, but I could not state with
'j 7
any assurety.that they do.
l 8
Q I show you what has been marked previously
'i 9
as GPU Exhibit-dO9 for identification (handing e
10 document to the witness).
Have you seen that document i
11 before?
{
12 A
Yes, I have.
I l
13 Q
Was the safety.uvaluation supporting the
,\\
14 CADDS analysis commitments which are contained in GPU i
l 15 Exhibit-279 in any.way used as input to what is 16 marked as GPU Exhibit-109?
17 A
Portions of the analysis could have been.
18 Q
Who performed the analyses and evaluations 19 which are contained in GPU Exhibit-492?
20 THE WITNESS: Could you repeat the question, 21 please?
f 22 (The pending question was read by the l
23 reporter.)
24 A
I cannot recall who specifically performed each
'v) 25 analysis that is described in Exhibit-29 2.
i a
n
% m u._. -........
1 LaBello 257 2
Q Was the work done by the Safety Analysis 3
(
Unit?
3 4
A Yes.
5 Q
was it done under.your supervision?
6 A
Yes.
7 Q
Did Mr. Banwarth do any of this work?
8 A
He could have.
3 I
9 Q
I would like you to refer to Page 3 of i
10 GPU Exhibit-492 which begins'.with the heading "3.0 4
11 LOFW Safety. Evaluation."
Did this evaluation include (AFit])
12 the effect of auxiliary feedwaterA delay?
13 A
Yos, there is a section within Section-3, Loss
(~/)
6.oFun N_
14 of FeedwaterASafety. Evaluation, which appears to 4
i 15 address auxiliary.feedwater delay.
16 Q
Which section is that?
l 17 A
Section-3.2.4.2.
l l
18 Q
Is there a page number on the upper right-c 19 hand corner that contains that?
20 A
E-14485.-
l l l
21 Q
Are you referring to the page beginning i i I
ll 22 with the heading " Parametric Study for AFW Delay"?
23 A
Yes.
r l l l
24 Q
What is meant by "the realistic model" 25 as those terms are used on Page-E-14485, the page to 4
y-,c.-
,y-e.---
,---,.-,---4, y
e,
= -
a-
1 La3elle 258 2
which you were just referring?
MR. WISE:
Can you tell us where on the 3
4 Page that is?
i 5
MR. GhASSMAN:
That is at the fifth line 6
of the text.
7 A
" Realistic model," in the sense used in the t
8 fifth line o'f Section-3.2.4.2, refers to the use of i
g the best available information on generic operating (l oFtD) 10 characteristics for a loss of feedwaterg transient 11 which was analyzed with the CADDS code.
i
-i 12 Q
Are the pressurizer sprays assumed to l!
13 Operate normally.for the realistic model used in this 14 analysis?
j 15 A
The CADDS code has the capability of providing 16 the function of the pressurizer sprays.
I could not i
17 recall whether that option was even necessary in terms 18 of an expncted actuation durf ng the analyses which i
19 were done as described in Section--3.2.4.2.
20 Q
The end of the paragraph to which you 21 were just referring has a reference to Table-3.2-3 i
}
e-22 which is contained on Page-E-14479.
I l
23 I would like you.to review that table and
- t l
24 tell us whether that refreshes your recollection as 25 to whether the pressurizer sprays were assumed to
1 La3ollo 259 2
Operate normally for the realistic model?
A As I understood your question, you are 3
4 referring to a Tab l e-3. 2 - 3 as described in the last sentence of the first paragraph of section-3.2.4.2.
5 6
This table occurs on Page-E-14487, and it is a
$06) 7 sequence of eventsA table.
4 (rable-5.24 8
Q There is another table labeled 3.2-3A g
which is contained on Page-E-14479 which bears the i
10 heading " Differences.Between Realistic Model and 11 conservative Model."
l 12 could you review that table, please, and
- i 13
- t. ell us whether that refreshes your recollection as
!{i N
!l 14 to whether the pressurizer sprays were assumed to be 15 operating normally for the realistic model in the i
hM 16 study.for auxiliary.feedwat.r delay?
a t
17 A
No, I could not.
)
18 Q
Is there anyone within the Safety Analysis 19 Unit who would be familiar with the assumptions made 20 in the study for auxiliary feedwater delay?
21 A
Not that I would know.
j 22 Q
If you wanted to find out what assumptions i
I l
23 were made for the realistic model in the auxiliary f
!f 24 feedwater delay, how would you go about it?
!!O 25 A
I refer eo the ca1cu1ae1ona1 eocument.
h
IL _..
.___..m____
1 LcDollo 260 2
calculational file supporting the analysis.
( 'S s
)
ks' Q
Is there a separate calculational file 3
((lfl0]
4 supporting the study for auxiliary feedwaterA delay?
A I cann t recall whether a separate file exists.
5 6
Q Is there a calculational file supporting GPU Exhibit-292?
7 g
A I would expect that there is.
l 9
Q Would that file be assigned a number?
10 A
Yes, it would.
I would also like for the record 11 to show that there could be calculational files, not 12 necessarily one calculational file.
13 Q
Where would such file or files be
./~
if 1(j 14 located?
I 15 A
These would be in the central files of the B &
(AlPG-D) i t'
W Company, Nuclear Power Generation Division.
16 A
g 17 Q
How would you go about finding such a 18 file or files in the central files?
I 19 A
one would look for calculational file number and i
I 20 subject title for that calculational file.
l 21 Q
Are these calculational files indexed by i,
I 22 number or by subject or both?
I i
23 A
They would have an index which included both 24 the number and the title of the file, i,m l(
\\
( _,/
25 Q
Returning once again to P ag e-E -14 4 61 of l!li
y
- - x 1
LcDelle 261 2
GPU Exhibit _.29 2 with the heading "LOFW Safety O
Evaluation," can you tell us whether this analysis 3
4 took into account the effect of failed open PORV's?
5 A
As best I can tell, the only failure of the 6
PORV to perform its operation properly is considered j
7 in Section-3.2.3.3, which is the TMI-2 incident i
j 8
benchmark, referring to the incident of March 28th, fo328) 1979@,asperformedwiththeCADDS computer code.
i g
4 E
figureJ~3. l-0 10 Q
I would like you to refer to (f6Ur8-3* l-2) f?rg-Wf3 I
11 3.1-1 and 3.1-2-contained on Pagep-E-14462 and 446g, g
j 'i l
12 which are the very.next pages after the heading i
13 "LOFW Safety Evaluation."
N 14 Do those figures contain event trees?
15 A
These figures contain event trees of major h102) 16 milestones during a sequence of eventsAas described
\\
fL0ful) l 17 for several loss of feedwathrA transient scenarios.
18 Q
Do those scenarios include a postulated i
19 PORV failure in the open position?
20 A
As stated on the figures in several of the 1
21 branches of the event tree,'the=PORV is considered to i
-}
l 22 fail open as an assumption.
I, 23 Q
Did the analyses made in support of the i
24 loss of feedwater safety evaluation provide for the h0 25 situation both with and without reactor coolant pumpsg e
3
-m..
--+
y*.--...1.
L
~. -.
1 Ln3cllo 262 2
running?
f^;
fft ure--3.I 0 3
I A
The event trees as defined in figuresg
.1-1 3
dqyore-3.I-a) and 3.1-2Aexamined operation with RC pumps and with 4
1 ss of RC pumps.
5 g
Q When was the work on these event tree 7
analyses' begun?
8 A
I believe you are maksag an assumption that the 9
analyses presented in the document were intended to 10
. follow various branches of the event trees as 11 described in these figures.
I 12 I would like to clarify that as saying that the l
13 event trees were requested and reviewed by the i ' s_,/
14 Nuclear Regulatory Commission 4and that any subsequent l
15 analysis of branches or portions of the event trees I
li 16 was as requested by the Nuclear Regulatory Commission.
I l
17 Q
When was that request made?
i
[Whichrequest?
18 MR. WISE:
I 19 MR. GLASSMAN:
The request of the Nuclear
, i
. l 20 Regulatory Commission.
21 MR. WISE:
He talked of several requests, I
i 22 Which one are you talking about?
j 23 MR. GLASSMAN:
A. request for the analyses I
i 24 contained on 3.0-LOFW Safety Evaluation.
i /' ',
(_)
25 MR. WISE:
I thought we covered that on 4
e I
a
1 LcBolle 263 2
one of these previous axhibits.
Maybe I am On (ms/
3 wrong.
4 BY MR. GLASSMAN:
5 Q
If you would refer to GPU Exhibit-103 6
for identification, particular1* to Page-B.108, there 7
is a ref erence to commitments from BChCW/NAC meeting 1979(774'//7) 8 on April 17th, 3
I i
9 Is that the meeting to which you rafer l
10 or the request to which you refer?
11 A
That very.well could be the meeting.
I do not 12 recall the exact date.
l 13 Q
Was the work on this analysis for LOFW
()
14 Safety Evaluation begun immediately after the NRC 15 request?
16 A
I have no recollection that it was or was not.
17 Q
I would like you to refer to Page-E-14476 l
i 18 of GPU Exhibitg@79.
19 Under the heading.3.2.4, Accident Analysis, r
20 followed by the subheading 3.2.4.1, PORV and High I
l l 21 Pressure Trip Set Point Study," there is a listing of
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(5 #fYa!?S/BWO i
22 five anticipated transientsgof concern.
l 1 1
23 I would like you,to review each of those 1
r 24 five anticipated transients of concern and tell us
(;)
23 whether each or a11 of these anticipated transients l
I s
l 1
LnBollo 264 2
of concern can result in actuation of the PORV.
l~
(,)
MR. WISE:
What time are you talking 3
4 about?
Are you talking about after some 5
changes that the NRC required following the hf&Eb r,
accidenta or are you talking about before the 7
. accident, because those set points have been 8
changed and they are different on many plants, i
9 I don't see how he can answer it unless t
10 you specify what you ara talking about.
11 BY MR. GLASSMAN:
12 Q
Prior to the TMI-2 accid 9nt and prior to i
13 the change in set points to which you have testified, l ;,-,i 14 can you tell us whether any or 11'of the anticipated
.m i
15 transients of concern listed here can result in 16 actuation of the PORV?
l 17 A
No, I could not.
The anticipated transients 18 listed here have a potential for actuation of the 19 PORV.
l 20 Q
Do all of the anticipated transients of i
i 21 concern listed on this page have a potential for l
I f
22 actuation of the PORV?
,i 23 A
I could not say with assurety that that is the 24 case, no.
i i
![
25 g
If you wanted to determine with assurety
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i
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1 Lahallo
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- whether that was the case?, who,in B dh 'would you as b
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sure'tbItNth$ ; people within.;b' & W 3
A I am not even Q
<7 s
4 could answer your question *with}a'lf ihmr e spoa n e,, t.ha t ',
e j Q
.- ej.
5 each of these events would actuate a PORV.
' /.~J, 2
'7
./
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Q Have,aty, analyses been performe'd withih n
~
to? determine whetheri,or not'these anticipated
'7 B & W
~3 7, ' -
l would or.could.'ac;tuate,the 8
tran s ie. hts PORV?A
.i 3
- s
/*7
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MF/. WISE:
Now'yob.hct/s' asked two 9
.i-r, i
t f
v 10 questions.
Let us separate-tho3e'out so th;,e 1 :
i
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t s
9-4 11 record wi'll b<s; clear.
There. is onel. question
?
f,, ' < :./
c/
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i 12 as to whether it would astd there is-another e
4 i
a i
l
,13 questiorJts, to whet,he,r it could.
4
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/
3
,v) 14 HR. GLASSMAN:
Is wasDhopingf to save time s
i 15 if the answer was the same.;,I thought the o.
i s i,
p f '/
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3 16 witness was, capable'of; answering it this way.
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17 MR. WISE:
I think the question is of
," l
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/, q 18 enough importance that/it shouldn't.be sloughed ^
?
y a
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19 over in an attehpu to save time twoland-a-half i j<
' (as-dags) 7 days 4 nto the deposition.
7 20 1
f t
MR. :;GLASSMAS :
-I thought I was asking the 21 h
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i, 22 questiong..
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MR. GLASSMAN:
Could you please read back 2
A q
. 'I[,
and type into the record the question first I "',/ ;.
.y jf j
with the word "would"?
1
(
2, u
~
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',L. y ',' {,.p' (The question referred to was read by y
' je i
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the reporter as follows:
- f W,' a #
" Question:
Have any analyses been
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f Performed within ((W to determine whether or 8
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not these anticipated transients would actuate
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/ u the PORV?")
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, 10
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MR. WISE:
Again, we are talking of a time
'f/h,
l'f i
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12 '
e Prior to the accident?
>)/
MR. GLASSMAN:
At any time.
Id. >' -
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.'(g MR. WISE:
At any plant?
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MR. GLASSMAN:
At any. time.
,h
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'fj gg MR. WISE:
We are not going to have at 3
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g b
f 17 any time.
Things have changed over time.
,f -
/
ig MR. GLASSMAN:
Let us find out.
I asked l*
f Id the question.
Ll[f
_?/
I l
MR. WISE:
Is your question now at any 20 v
I time at any plant has any study been performed to 21
}
l 22 this witner,s's knowledge regarding any of five, t
t 23 different things listed here in this memo?
24 MR. GLASSMAN:
The question is very clear.
25 You asked that it be separated into "would" and 4
l i
1
u-1 LaBelle 267 2
"could."
I have-been willing to go along with O
that.
The question is very plainly on the 3
record.
I would like to have an answer.
4 MR. WISE:
Your question is neither plain 5
6 nor clear.
I' object to it as to form, but I wiIl permit the witness to answer if he can.
7 t
8 A
It is certainly possible..
I i
i 9
Q Do you know if any such analyses were i
6 96335) 10 Performed prior to the TMI-2 accident {
11 A
In terms of analyses which were performed 12 specifically with[an examination of PCRV operation, no, I
i 13 I do not.
N_)
14 Q
Were any.such analyses performed subsequent 15 to the TMI-2 accident?
16 A
Yes.
r I
17 Q
Who performed those analyses?
N 18 A
A portion of those analyses are described in 19 Exhibit 7292.
20 Q
What pages of Exhibit 292 are those 21 analyses found on?
I 'I k
[l 22 MR. WISE:
Do you want him to look 23 through the whole exhibit now?. This is getting i
24 a little silly.
We have been over this fs
- ()
25 document.
6
ww
,-=
~ _ _ _....
1 LaBelle 268 2
A To the best of my knowledge, the PORV operation O
is considered throughout the analysis presented in 3
292.
4 GPU Exhibit 7 5
MR. GLASSMAN:
I would like you now to 6
read into the record the question originally j
7 Posed with the words "would" and "could," this i
i 8
time with the word "could."
i
[
g (The question referred to was read by 10 the reporter as follows:
1 11
" Question:
Have any analyses been i
12 performed within B{)[W to determine whether 13 or not these anticipated transients could O
14 actuate the PORV?")
15 BY MR. GLASSMAN:
16 Q
Referring in this question once again to 17 the anticipated transients listed on Page-E-14476.
18 A
Again, your question is addressing the time 19 frame before the TMI-2 incident?
20 Q
This is at any time.
21 THE WITNESS:
Could you reread the l
22 question?
I I
23 (The question referred to was read b,y
,t 24 the reporter as reque*ted4) 25 A
It is certainly possible.
1 LaBelle 269 2
Q Were any such analyses done prior to the O
accideng{190325)
Tar-2
?
s_j 3
A I don't know.
4 5
Q Were any.such analyses done subsequent to i
6 the TMI-2. accident?
A There war,e some analyses. (
7 g
Q To what analyses do you now refer?
A The analyses which I am familiar with which 9
10 are those described in GPU Exhibit-279.
1 t :
11 Q
I.would like you to ref er to Page-E--14494 i
e 1l-12 of GPU Exhibit-T92, which has the heading "3.2.4.3
' I i}
13 Anticipatory. Reactor Trip."
14 Can you tell us whether the study of the i'
15 effect of. anticipatory. reactor trip as contained in l
16 this section of GPU Exhibit 279 assumed a realistic 17 model?
l 18 A
I don't know.
l 19 Q
If you wanted to find out, would you go i
20 to the calculational file or. files for GPU 2927 21 A
It is possible that one could determine from i
I
- ~i 22 a calculational file if it exis+s that there were l
i 23 realistic analyses done in the sense that we have i
- ff 24 previously, defined " realistic."
l:
25 Q
If you wanted to find out whether realistic e
4 6
i -
1 LeBalle 270 I
2 analyses were used in this study relating to I\\_/
3 anticipatory. reactor trip, how would you go about 4
finding out that information?
5 A
I would look for the calculational file which 6
supports the material.
7 Q
If there were no calculational file or the 1
8 information was not contained in that file, how would j
9 you attempt to determine that 1. formation?
i 10 A
I may.not.be able to determine that information.
11 Q
Is there anyone within the Safety Analysis l
12 Group that you would ask in order to attempt to l
13 obtain the information?
14 A
Only if I were aware of who had performed the 15 analysis.
16 Q
Are you aware of who performed that 17 analysis?
I 18 A
yo, 19 MR. GLASSMAN:
Please mark as GPU Exhibit EliU 20
-2SIfor identification a May 8th, 1979h9660 4
i
+
21 memorandum from D.
W.
LaBelle to E.
A.
Womack; I
22
Subject:
OTSG Dry Out.
lirl 23 (Memorandum dated May 8, 1979 to E.
A.
e 24 Womack from D.
W.
LaBelle was marked as GPU
\\
,(
Exhibitwo)k293 25 for identification as of this l
t
L
^^
^^- ~ ~ ^ ^
^^
i I
LaBelle 271 3
date.)
l
\\'
BY MR. GLASSMAN:
3 4
Q I show you what has been marked as GPU 5
Exhibity293 for identification (handing document to 6
the witness).
7 Did you send that document to Dr..Womack i
8 in the ordinary co'urse of business?
- l 9
A Since my signature appears on this document I l
i 10 presume that I did.
I 11 Q
What is the significance of "OTSG dry out"?
i 12 A
Would you explain what you mean by "the l
13 significance"?
14-Q Is OTSG dry out a problem or potential (fBS) 15 problem in the operation of reactor coolant syste5{
16 A
As I understand your question, you are asking 17 is " dry out" a problem.
I think one should look at I
18 inventory in the generator as being an operational 19 consideration that one considers in the design of l
($h 20 the steam generator and heat removal via the steam
.l 21 generator.
l I
l 22 Q
can you tell us how OTSG dry out relates 23 to heat removal?
24 A
I don't think we have established yet for the 25 record what' " dry out" refers to.
___y L_
+
1 LnBelle 272 2
Q We appreciate your objection to the
\\
3 question.
4 MR. WISE:
Perhaps the witness doesn't 5
understand what you mean when you speak of 6
" dry.out.."
. {.
7 BY MR..GiASSMAN:
j 8
Q Can you tell us what you understand by
}
g the term "d ry.o u t ". in th3 sense of OTSG dry out?
I i
i.
10 A
"OTSG dry.out" to me refers to reduction in SGl) l 11 the inventory.within the steam generato 4
12 Q
Are you talking about an inventory of i
13-liquid?
I
(\\_
14 A
Yes.
15 Q
How does OTSG dry.out relate to heat l
16 removal?
Wh7 17 A
The inventory of feedwaterg n the steam generator, i
1 l
18 secondary side,-is one means of removing heat or 19 energy from the primary coolant system.
i 20 Q
Does dry out refer to reduction of liquid i
)
21 inventory to zero or just to any reduction?
-)
l 22 A
I would consider dry out to be a consideration f
i 23 of reduction in heat removal as the inventory in the r
i l
i i 24 steam generator is reduced, not that one would have to
! [ ')
l
\\/
25 have complete zero inventory in the steam generator, r
I i.
~
-..._. _._._ _.., _ _.~._. _ --. _ _.-._.
__m.
1 LaBelle 273 2
Q If there is a dry out in the OTSG, what effect does that have on the heat on the primary 3
4 side?
i 5
MR. WISE:
When you say " heat," are you 6
using that synonymously.with temperature?
7 MR., GLASSMAN:
Yes.
8 A
It depends on what other operations are' going 9
on within the rest of the system..
(1,oFd?
10 Q
If there has been a loss of feedwater4,
,11 what is the effect of.OTSG dry out on the temperature i
j 12 on the primary. side?
13 A
I could not respond to that without some 14 indication as to a point in time that you are 15 considering.and what other operational characteristics 16 exist.
17 Q
What.is the effect of OTSG dry out on (l-inin Lifb 18 temperature on the primary side in the first oneAor (J2-M)(10f62D 19 two minutes 4 following loss of feedwater?
20 MR. WISE:
Now I am confused.
Are you 21 asking him after the dry out occurs or after the
\\^
]
22 loss of feedwater occurs?
What does the one to i
23 two-minute delay refer,to?
24 BY MR. GLASSMAN:
25 Q
In the first sentence of GPU Exhibit-g29 3, a
i i
L l' ;
1 LGBollo 274 i
l f fnlnUk}
fj-MWUfe}
the one4 o two-minuteAfigure refer to one to t
2 does (h0RO)
O) tw minutes following the loss of.feedwater?
(
3 j
A The information that is related in the first 4
sentence of Exhibit 293 refers to the general effect 7
5 steam generatorg(SS steam generator inventory, 6
of 7
during and following.a loss of feedwater transient, i
8 and the anticipated time to steam off the majority of I
~
f g
the inventory,before losing heat removal from the i
t l
10 Primary. system for both steam geierators having started 11 with their complade operational inventory at one hundred (l00-feYC6Mf) i 12 PercentApower.
13 Q
Can OTSG dry,out following the loss of
()
14 feedwater result in an' increase in temperature on the 15 Primary side?
16 A
During portions of'such a transient, yes.
t 17 Q
During what portion of such a transient?
$l 18 A
During the approach to reactor trip which is a
19 very early, normally.during: a comp.lete loss of fj 20 feedwater condition.
21 Q
Can OTSG dry,out following the loss of l
h
[j 22 feedwater result in increase in pressure on the t
23 primary side?
24 A
Maybe we should come back and again clarify the 25 dry out that is being approached during the loss of
,;,m 4
.y
,._,.._m_
IL...
1 LEOGllo 275 (10 fn1Ftb) 2 feedwaterg type event.
The loss of main feedwaterg
/"'s
(_/
3 results in a reduction of inventory addition to the Ge>
(1t2D 4
steam generatorsA n a pressurized water reactorgwhich i
5 will res' ult in reactor trip, normally on high system 6
pressures.
7 Prior to dry out of the steam generators 8
in 'the sense of their having lost complete heat removal, f
9 there is actuation of emergency.or sometimes referred
{hVUb 10 to auxiliary.feedwatergto provide inventory to the 11 steam generators for heat removal.
12 Q
I repeat the question:
Can OTSG dry out l
l 13 following a loss of feedwater result in increase in lgS(,)
14 pressure on the primary side?
i 15 A
If.the generator was to lose its heat removal j
l 16 capability, yes, you could have an increase in primary 17 system pressure.
18 Q
Could this result in actuation of the
[1963Af 19 PORV during the period prior to the TMI-2 accideng?
l 20 A
You are saying is it possible that if no heat
}
21 removal was provided by steam generator following a
i h
22 loss of main feedwater in a period of time prior to i
f 23 the TMI-2 incident, if this could have resulted in 24 increases in system pressures to the point that the
! /O 25 PORV would be actuated. Yes.
) l \\,)
b
1 LaBelle 276 8
yg 2
Q The second sentence of GPU Exhibit 7293 U
3 reads as follows:
4 "In the past, Safety Analysis had not.
5 been concerned with this issue in that time 6
appeared available for operator action to (8fl0) l 7
provide auxiliary _ f eedwater4 (if not auto-l 8
initiated) prior to loss of sufficient RCS 9
inventory.to uncover the core."
j 10 How much time appeared available for 11 operator action as described in this sentence?
12 A
There is no particular time here associ'ated with i
13 operator action.
f
\\'
14 Q
Were any analyses performed by W[A3W b
(190529) 15 prior to the TMI-2 accidentArelating to the time that 4
16 would be available for operator action to provide 4
17 auxiliary feedwater if not auto-initiated prior to 18 loss of sufficient RCS inventory to uncover the core?
19 A
The analysis that is provided for the loss of feedwate(LoFIO)
^
20 rAtransient for inclusion in the Safety (84M j
21 Analysis Report f
A or plants does not, nor is it
+
l hY$
22 required by the Nuclear Regulatory Commission include g
(
23 the delay of au'xiliary feedwater to the steam 4
i hY 04 generators. A
-s g ks 25 g
Is it correct then to state that the I
i' 1
+
.- - - - =-
ww 1
LcBello 277 r
GoflL analysisprovidedby$[(]Wforloss of feedwatera 2
(9 As/
transients for inclusion in the SAR for B & W 3
4 designed plants does not include a delay of auxiliary (AFW)
(SG.1 5
feedwaterato the steam generators?
g 6
A Beyond the delay time which is provided in 6AR 7
Safety Ahalysis Repor hich is on the order of Glo-sesends) 8 about forty seconds 4 rom the time of loss of main f
g feedwater.
10 Q.
Is it correct to state then that aside i
11 from the forty-second delay provided in the SAR, the 3
12 analysisprovidedbyg[)[yforlossof feedwater I
I i
13 transients for inclusion in the SAR does not include
. (,
g, 14 any other delay.of auxiliary feedwater to the steam 15 generators?
i 16 A
That is correct.
17 Q
Has.any.such analysis been made l
18 subsequent to the TMI-2 accident?
19 MR. WISE:
Could I have read back not the 1
20 last question but the one before?
21 (The question referred to was read by the j
22 reporter as requested")
e 23 MR. WISE:
I thought we spent the better i !
24 part of this morning going over Exhibity292.
O
(,/
25 That is basically what that exhibit is about.
1 f
l f '
~
, _ _ _ _ _ _. - _. - _ _. _. _ _, _ _.. ~,
N' 1
LaBelle 278 2
.MR.
GLASSMAN:
If so, let us just get
'l the answer yes and go on.
3 4
MR.. WISE:
We did spend a good part of 5
this morning going over this.
6 MR. GLASSMAN:
I am just trying to get an 7
answer.
8 A
There have been some analyses.
The ones I am 9
familiar with are the ones presented in Exhibity292.
l' t
i 10 Q
How long does it.take to uncover the core (AFuD
.i 11 if auxiliary feedwateg is not available?
12 A
I don't know.
I 13 Q
How long does it take to uncover the than the if auxiliary)feedwater is delayed more 14 core (YO~ Secorb6 f
15 forty. seconds 4provided in the SAR?
16 MR. WISE:
Isn't that the same question?
17 A
To me, it would be the same question that you 18 asked previously.
19 Q
Do you know the answer to that question?
20 A
No.
I 21 Q
Were there any. analyses performed.by
)
&qo329)
B(k)RpriortotheTMI-2accidentgwithr'egardto the l
22 23 time it would take to uncover the core if auxiliary l-feedwater were delayed beyond the forty seconds 94 25 provided in the SAR?
4
- a.
..--~.-m 1
LaBelle 279 2
A Y'ou are referring here again to the loss of (l.0Y 3
feedwaterAanalyses presented in the Safety Analysis (6A N) 4 Reporg?
5 Q
I am referring to any analysis.
~
6 A
I don't know.
7 Q
'If you wanted to fi~d out whether any such 8
analyses were performed within B[f]W, how would you 9
go about it?
I^
~
10 A
I would consult the analysis units.of the plant 4
- j 11 design section or the plant engineering section as it AI II 12 is presently. called.
Il
{I 13 Q
The next sentence of GPU Exhibitg480 reads b
'. (_s/
14 as follows:
15 "This was not considered, however,. based 16 on plant operating data, to be a high frequency hb/)
17 occurrence nor that pressurizer relief valvea
?
18 challen'ge and failure would be as frequent."
I i-19 When you used the words "as frequent" in l'
20 that sentence,, what were you intending by those
'l 21 words?
As frequent as what?
l-l h
- l 22 A
I, don't know what I was referring to at the time
!l
- j 23 this was written.
I think in retrospect " frequent" may l!
I 24 not have been the proper word, that the fact that
((()
25 there had heen cha11enges to the goRv which has 1ed to
- 1
m-
.._.m 1
LaBello 280 2
failures in operation would have been more appropriate.
3 Q
The next sentence reads:
4 "In the wake of the TMI-2 accident, this 5,
component of our safety philosophy is no longer 6
appropriate."
7 To what component of your safety philosophy are you referring in this sentence?
ii 8
i l
9 A
I cannot recall specifically what the reference i
l 10 of this component was to.
I presume it was to 11 Previously written material here, but I could not state 12 with any assurety what this component actually meant, 13 actually.means at this time.
'.O
,ks 14 Q
What do you now understand that to mean?
m 15 MR. WISE:
I think ne just said that in his 16 last answer.
l l
17 A
I don't know.
18 MR. WISE:
The document speaks for itself.
l 19 BY MR. GLASSMAN:
i l
l 20 Q
The first sentence of the next paragraph l
21 of GPU Exhibity-29 3 begins :
l
't 22 "It is my conclusion that q[h[W must l
l t 23 enforce as a new safety criteria that both underline 24 operating and future plants must"
- Ps "have a turbine trip initiated by j
s.
25 "must" l
l-l
_x
._ x.
.- =
1 LaBelle 281 (J.0 f a 1 ss of feedwatergindication," and it 2
O ntinues.
3 How could ()()W enforce such new safety 4
criteria?
5 3
6 A
The use of the word " enforce" is intended.to
,j 7
mean that my opinion was one which would be that B & W lI 8
should support such additional criteria.
4 9
Q How would such additional criteria be 10 communicated to the plants?
i j j 11 A
You have to keep in mind that the utility is 12 responsible for the operatijn of' its plants and, as J '
- i 13 such, B& W can only offer recommendations that we 14 feel would be appropriate.
It would be up to them to
~!
15' make the. determination of whether.to adopt the 16 suggestion into their operation.
i l
17 Q
has B.& W recommended to operating plants
-18 that there be new safety criteria as described in 19 Paragraph-2 of GPU Exhibitg493?
20 A
Referring again to GPU Exhibit 292 which we A
(
21 discussed earlier, results were presented of which I j;
22 am aware within Safety Analysis and provided to the r i 23 B & W owners group for those' owners to consider the l}
24 use of the suggested areas in this paragraph in their Ii
.t i
25 plant operation.
i
..m.-
h LnBella 282 1
(-ff()3Zh Q
Prior to the TMI-2 accident iid BC&{k 2
[
S
\\ _,/
recommend safety criteria to operating plants?
MR. WISE:
Any safety criteria?
4 MR. G ASSMAN:
Yes.
5 A
I c uld not say that we didn't.
There are 6
certainly design safety.and. balance of plant 7
recommendations that are provided to the plant owners, i
8 and it is up to.them as the owner.and the licensee of 9
10 the power plants.to make a. decision on which ones they desire to accept and also that they would be 11 12 responsible for the licensing of those designs or hY Y 13 criteria with the Nuclear Regulatory Commissiog.
i
^
l f )T l(
14 Q
In what form does B & W provide design recommendations and balance of plant criteria to i
15 l
16 operating plants?
17 A
I don't know.
18 Q
If you wanted to find out, who would you 19 ask within B & W7 i
20 A
Your question is a ve y broad question in that i
21 there would be the potential for plants in operation, k
i 22 plants in design or plants in marketing such tlat one 23 would consult the appropriate project site manager or l
24 possibly marketing manager with respect to those
- ,3
! _,)
l P ants.
\\
25 l -
[
l
L --.
1 LcB@llo 283 2
(Recess taken.)
(,/
3 BY MR. GLASSMAN:
4 Q
At the bottom of GPU Exhibityp93 there is 5
a reference to TMI owners group, is that correct, in 6
handwriting at the very bottom?
l 7
A Yes.
i 8
Q Is that your handwriting?
t i 9
A It appears to be, yes.
1 10 Q
Is there a separate file relating to TMI 11 owners group?
12 A
The identifier is for my secretary, to alert 13 her that this would be placed in my TMI-2 chron files i(, m i v) 14 relating to owners group activity following the l
15 Three Mile Island incident, the Three Mile Island-2 I
16 incident.
17 Q
Are there more t.han one TMI-2'chron f.iles 18 which you have maintained?
l 19 A
Not more than one chron file.
Th'ere 'are subject i
I l
20 categories within that chron file.
i
}
21 Q
What other sort of categorie.s can you now I
h 22 recall?
l (fC l
23 A
There was one on sequen.ce of events one on g
l 24 background materials, one on accident analysis, one l,/~.)
25 B'l'h owners group, and I don't recall others, l(
on LV o
L 1
LaBelle.
284 2
although there could be others.
(/
3 MR. GLASSMAN:
I would like to have 4
marked as GPU Exhibibg294 for identification 5
a multi-page document, the cover page of l
6 which is a handwritten memorandum from JHT to
[$C010%)
7 D.
W.
LaBelle, bearing the date 1/8/80.4 l
8 (Multi-page document, cover page being i
i 9
dated 1/8/80 to D.
W.
LaBelle from J.H.T.,
was 10 marked as GPU Exhibit No.
294 for identification 11 as of this date.)
i 12 '
BY MR. GLASSMAN:
T
{
13 Q
Did you receive what has been marked as
(
14 GPU Exhibit 294 in the ordinary course of business e
15 (handing document to the wi'.nass)?
l 16 A
I can recall receiving portions of GPU Exhibit 17 294, the exception being a page-C-15-85 37, which I do 18 not recall, and the preceding page, C-15-8536.
h6 19 Q
I would like you to ref er to Pages4 8$ Toy C
d
)
q ep 8540,page-e-w-gre't, an pge4/5-150 (41, and
?
42, which are the last three pages o 20 f
i l
21 GPU Exhibit 294 for identification.
Can you tell us what those pages are?
I I
23 A
These pages contain a draft abstract of a paper ll i!
l 24 prepared for presentation at the American Nuclear i
t
g-m.,
1 i
I 1
LaBelle-285 2
myself.
3 Q
could you tell us who Mr. Gharakhani is?
4 A
Mr. Gharakhani at the time of the writing of 5
this paper was an engineer working under my. supervision 6
in the Safety Analysis Unit.
7 Q
Who is Mr. K u d l.i n, K-u-d-l-i-n?
I i
('
8 A
At the time that this paper, this abstract of a g'
paper was written,.Mr. Kudlin was a unit manager.
!'I 10 within the technical staff.section of the engineering
/VfSh of the Nuclear Power Generation Divisio(ng 11 department iI l
12 Q
What is meant by the term " overcooling
.Iil 13 ev e n t." ?
14 A
An overcooling event.is an overcooling event.
15 Q
How is such an event initiated?
e J
16 A
It could have any number of sources of t
l 17 initiation.
(
18 Q
What are some of the sources of initiation i
i i
19 of an overcooling event?
h 20 A
Increased feedwaterA low.
f il
!i 21 Q
Could both increased main feedwater and l'
)
auxiliary.f eedwate(AFl@
l 22 rAbe initiating events for an 23 overcooling event?
l l
I 24 A
If that combination was credible, it would lead t
25 to overcooling, yes.
- i f
i
{
k
E 1
LaBell@
286 2
Q Could excessive auxiliary feedwatergalone initiate an overcooling event?
3 A
You have to keep in mind the system's operation 4
'b that has occurred previously which has led to what 5
6 you have hypothesized as an actuation of auxiliary feedwater and perhaps potential cooling of auxiliary 7
1 i
i 8
There are certainly some event scenarios in j
g in which auxiliary.feedwater could lead to overcooling, 11 yes.
12 Q
Are there any other events that can 13 initiate an overcooling event?
gs
(,,,)
14 MR. WISE:
Other than what?
l 15 BY MR. GLASSMAN:
(FuD 16 Q
Other than excessive main feedwater or g
18 A
There are perhaps others, yes.
19 Q
In an overcooling event, what actually 20 happens to the temperature on the primary side?
l I
21 A
The nature of the overcooling event is decrease 22 in temperature of the primary system.
i 23 Q
Can pressure also decrease in an overcooling
- t 24 event in the primary side?
!('8
(
)
25 A
Yes, it can.
v-l
k
^
. ~ _ _... ~
1 LaBallo 287 2
Q Can pressure drop below 1600 PSI?
7 p
~
A For some scenarios it could, yes.
3 t
4 Q
Is 1600 PSI the acgation point for (flb 5
hi9h Pressure injectiong l
6 A
The set point for high pressure injection can l
7 vary from plant to plant.
8 Q
In an overcooling event can the pressure 9
in the primary side drop below the high pressure 10 injection actuation point, whatever it would be?
11 A
There are some scenarios involving overcooling 12 that could lead to actuation of high pressure l
13 injection system, yes.
6i ;g3i l(_'
14 Q
Has such an event actually occurred at 15 q[k[N designed plants.at which the pressure in the l
l 16 primary side dropped below the high pressure injection l
17 actuation point in an overcooling event?
18 A
I could not say that it had not occurred.
I t
19 don't have any recollection of such.
I l
20 Q
I would like you to review the abstract or t
21 draft of an abstract of a paper which is contained l
fage-C~lf-85Yo, fage-e-/5-gf4b fage-6-15-M&
22 at Page s-C 8 5 4 0 -through -4 2 and ask you whether g
i 23 that refreshes your recollection as to whether any such 24 events have occurred at B & W designed plants.
f^s,
, l(,)
25 A
No, it does not.
The abstract and paper that i
i
- ---.- = _
~m 1
LaBello 288 2
was presented addressing what are termed non-LOCA
\\~s' vercooling events.was based upon a generic study of 3
4 several event scenarios, none of which are particularly 5
related to an actual operating ccurrence at a site 4
s with a WCy[W designed water-pressurized reactor.
7 Q*
Are you aware of any actual overcooling I
i t i
8 events on B & W designed plants where HPI was f
9 actuated?
i
- i 10 A
There may.have'been some, but I don't recall.
l (766000) 11 Q
Did such.an event occur at TMI-2 in 19787 4
12 MR. WISE:
You can c'onduct this examination i
13 any.way you want to, but it seems to me we are 14 taking a lot of time.
Is there a point to this?
q i
15 Do you want to tell the witness something has i
16 happened and get some information from him?
t i
17 He doesn't obviously know of the event.
18 If there is something specific of an event, why 19 don't you tell him and let us get on.
This is 20 fencing with the witness.
l 21 MR. GLASSMAN:
We can get done with it if h
oll 22 we can get an answer.
If he knows, he knows.
I 23 If he doesn't know, he.doesn't know.
We are I
24 just trying to find out.
()
25 THE WITNESS:
Can you repeat the question?
(
i r
--e
" ' ' ' ~~
~'~ "
g_
2__
1 LaBalle 289 2
(The pending question was read by.the l
rep rter.)
3 A
I don't know.
4 i
5 Q
In an vercooling event, if pressure drops
/
6 below the HPI actuation point can the pressure stabilize'below that point?
l 7
I I
8 A
Could'you explain what you mean by " pressure i
f 9
stabilize below that point"?
I 10 MR. WISE:
This is the problem you get i
11 into with a hypothetical question.
I haven't 12 been objecting, but I am going to start pretty 1.
- i i
13 soon.
4 i
'N
)
/
14 MR. GLASSMAN:
I am just trying to J
15 understand the operation of this kind of event.
s l
16 MR. WISE:
You are asking it through a 17 series of hypothetical questions which have the f
i 18 problem that all hypothetical questions do, and l
19 the witness is obviously starting to respond by 20 asking you for more information.
i 21 We are going to be here all day trying to f
I I
i 22 hypothesize an event.
These are very complicated 23 analyses that are done.-
If you have read any 24 of them,you are familiar with that.
4 hs 25 MR. GLASSMAN:
I would just like to ask a
)
(---
~..._-- ____,..._..._,. - _-..
1 LaDella 290 few questions.
I think I'can clarify w hat the 2
w rd." stabilize" means.
I have no doubt that 3
the witness can understand shat it means very 4
shortly.
5 BY MR. GLASSMAN:
6 7
Q-In an overcooling event after,the pressure 8
has dropped below the HPI actuation point,can the
'i'j 9
pressure on the primary side level out at a pressure 10 below the HPI actuation poiat?
11 A
Depending on what is taking place during the
!l 12 event, there is certainly a possibility one could have
!i 4
13 periods of stabilization of pressure below the high i ()
14 pressure injection point.
15 Q
Are you aware of any such events which have f
16 occurred at ()()W designed plants?
17 A
No, I am not.
i 18 Q
In such an overcooling event where i
19
-pressure drops below the HPI actuation point and i
i 20 stabilizes below that point or levels out at a point i
l 21 below the HPI actuation point, will the system refill I
i) 22 and the pressurizar level recover, if HPI is still on?
t-t-
23 MR. WISE:
I object; hypothetical.
I 1
l 24 object to the form of the question.
The witness
{()
25 is permitted to answer it.
J h
t 1
LaBello 291 2
A You are starting to get into areas'where one must know the conditions that surround the particular 3
circumstances that you are imposing upon,the system.
4 i
It would not be possible to give you a specific
~
5 i
6 origin.or response to your question.
l 7
Q I will only.ask one or two more questions i.
8 in this area.
fi i !'
9 Assuming that there is no break in the "l
i 10 system, in an overcooling event after. pressure has
{!
E i 11 dropped below the HPI actuation point and ' stabilized 12 below that point,. if HPI is still on',will the system refill and pressurizer level recover or can itlrefill
- O 14 and recover?
s i
15 MR. WISE:
I make the same, objection to s
16 the question.
i' 6sysc) 17 A
If the head on your high pressure injectionA L
18 pumps..is sufficient to push aga..nst the pressure of l
19 the system, it is certainly possible that the fluid L
20 inventory that one is adding to the primary system I
21 will fill the system, yes.
22 Q
If the pressurizer lyrel then goes up, fl ii f
23 is it proper for the operator to terminate high i
24 pressure injection?
l 25 MR. WISE:
I object to the question on the i
r
-m
---w-
,--,m.+
-,,na, - - ~-
-n-
,n---,-
,--m--,,----,,.mm,-~,--,,
,,,---e--
-,v,--,-
,n,,,,
e w,r---om,,,,
p+-r,-,-
[
~
M -~~ ~ ~ P m
.__m_.
1 LaBello 292 x
,s 2
grounds that it is hypothetical, and you failed O ?,,.
iv; ' '
3
.to give the witness anywhere near..enough information for him to be able to answer.
, 4,
't 5~
A I would have to agree that there is just I
'l~
6
'nsufficient'information to be able-to provide you i
I j
7 l' with a proper response.
i lt
.\\
N
8 Q
What other information would you need?
s 1
, gg
- i 1
s't"~.-%. 'a
,A
'I don't know.
You have to just have much greater L
s i
.+
\\
'T '
l
.l..,
1, the entire transient-type s'i tua tio n ' '
10 knowledge of s
t_.
In.gn overcooling event where the s
11
-Q.
4 i
e
\\
lh press'trizer level has first goneyaown below' the HPI N
i A
- s s I
13 actuatio'n,poinecand than rises again, cankit'be '
1' N
t u ?
/
14 app rop riate ' t'or, 3
an operator to terminate HPI under --
s i
T t
4 15 with any additional criteric, under any critemia?
3 16
, M'R"%. WISE:
I object to that question-on l
s I
/
t i
17 the grounds it is hypothetical and also thht it y
a _y
~.s 18 is virtually unintelligible.
g
{
s y
k 19 A
There is duct no' way I could respond to your s
[x
\\
]
20 question as it is'9hrased.
-i
,]
21 Q
Are y'on aware ofsany events'at QW I
I i
I 1
22 designed plants involvirig overcooling events where it ',1, u
y~
s l
r i
\\
23 was appropriate f or the 'op'erators to terminate high g
i-,
l 24 pressure injection?'
i I
\\
v i
25 MR.'hISE':
I object.-
You have ask'ed that
.N l
N w
ew N
-(
s
\\
{
g A
i '
b g
, c-
-e.
=y w
y c
,f
-7 '
s~
j,
., 7
- 1 p
l LsDelle' 293
' ',6 y j
,?
/
t o',!
question and he aos-[e2ad 'iit at lagsti three oc i
t
2 i
,:,s, r,
3 O
.s 9-'
]j' four' times tich respect to,whethcr'he'wgs aware 4 -
/
s
.s d W plant and.then
~
,of overcooling avents at q
4
- t i
p i
j.~ we,went through even spe23fic events,#and he'r '
-i
(;3
-t
- 9 e
\\
told you seYeral times he doesn'tiknow of thdse
' - 6
, ' ', events.
t
,7 y
r asking the question.
Now yctr are 7
I i
g LY MR. GLASSMAN:
[.
't 7
.s.
, I; '
9
- Q I would. likaja yes or no answer.
1 I
~
10 t
~
10 A
Your previous question had asked if I was aware r ',
s clf any. overcooling,eidnts which, had led to high 11 fff-inj ec tio(n4ac tuation,
and the answer to that 12 Pres.yure
'e 13 is no.
l
- [
y 14 In terms of am I aware of events which'b97'e led
/
15 to overcooling at operating.' plants with B & W nuclear (g6SS) 16 steam supplier systemg, the answer would be yes.
17 MR. WISE:
That was not the' question that 18 was asked.
The question was asked whether you 4
19 had knowledge of someone terminating after HPI
)
20 had come on, and you earlier said you weren't 21 aware of such events.
I i
22 So I don't ses how he could possibly be i
- I 23 aware of events where
- .it was terminated if he 24 wasn't aware of events where it came on in the 25 first place.
1 e
d 3
~ _
h-.
1 -
1 LaBollo 294 2
BY MR. GLASSMAN:
O Q
To which overcooling events are you 3
e 4
referring that you knew of?
A I don't know.
What I have stated is that I have 5
6 an awareness of overcooling events, j
7 Q
Any particular overcooling events of which 8
you are aware?
h 9
A No.
I 4
MR. GLASSMAN:
I would like to have 10 N
.f v
11 marked as GPU Exhibitp 95 for identification a
{
12 multi-page document bearing the date April 12th, 1
f 1979('f70Y/h from D.
W.
Fairbrother to Distribution,
'l-13 f%
14
Subject:
Summary of Pressurizer Level t
]
15 Investigation / Instruction #196.
16 (Multi-page document dated April 12th, 17 1979 to Distribution from D.W.
Fairbrother, 18
Subject:
Summary of Pressurizer Level i
19 Investigation / Instruction #196, was marked as 20 GPU Exhibit No. 295 for 14entification as of l
21 this date.)
h T
ll 22 BY MR. GLASSMAN:
23 Q
Did you receive a copy of GPU Exhibit 295 i
24 for identification in the ordinary course of business?
)
i
\\_/
25 A
I have no recollection of having received the
-a y
1 LaBelle 295 2
memo from Mr. Fairbrother to Distribution of April O
(196413) 3 12th, 1979.4 4
Q Is your name listed as being on 5
distribution of that memorandum?
6 MR. WISE Yes, it is.
7 A
Yes.
I 8
Q I would like you to refer to attachment-/
NO N to this memorandum which is contained at Page-g 444k of.GPU Exhibit-295.
10 Your name is indicated as 11 being on Distr.ibution.
Did you receive a copy of i
12 that memorandum?
13 A
The memo from E.
A. Womack to Distribution (190$b A ooks familiar, but I don't recall 14 of April 6th, 1979 l
15 having received it, no.
16 Q
Item MoY-6 on Page-3541 speaks of an 1
17 assessment being made or that an assessment should be i
18 made of actual versus indicated pressurizer level 19 throughout the TMI-2 transient, and your name appears f
20 after that.
i 21 Did you make or participate in any such
!l I
{.
22 assessment?
I 4
23 A
I don't recall what action was taken with respect i
24 to Item 5.
O 25 Q
I would like you to refer to Page[jb3543 1
?
i
L
- =
1 LGBolle 296 2
of this exhibit and ask whether you received a copy of
(~)
(t7'040f)
N
the April 6th, 1979 memorandum from E.
W.
Swanson to A
3 yourself.
A N thing other than a vague r6 collection of 5
G having seen such a document.
7 Q
I would like you to re f e r to P ag e-D--3 5 5 2 ind' cates carbon copy to 8
of GPU Exhibit-295, which i
9 yourself on the following page.
Did you ever receive 10 a copy of this document?
11 A
I can recall only a vague recollection of having 12 seen this document.
4 l
13 Q
Can you identify for us who Mr. Hudson f~)
i (%)
14 and Mr. Snow are?
l 15 A
At the time that this memo was written,IMr.
4 I
16 Hudson and Mr. Snow were engineers in our components t
17 group of the engineering department.
I 18 Q
Do you know their current positions?
I l
19 A
I don't know either their current positions or l
j 20 the current units to which they are attached.
I l
21 Q
Can you identify for us Mr. Tornow, Mr.
l I
22 Mitchem and Mr. Burke?
23 A
At the time that this memo was written I believe i
i 24 that these gentlemen were unit managers within the i cs
)
l( /
25 components area.
l e
li
y LcBolle 297 1
2 Q
Do you know their current positions?
O A
.o.
Q Do you know their current units?
4 A
No.
5 6
Q The second sentence of PageyDg3552 reads i
as follows:
7 I
t i
8 "The only design requirement that we can
,I i
j 9
positively. identify is that the surge line/
10 pressuriser arrangement must be such to allow 11 Pressurizer draining and maintenance while l,
coro il 12 keeping the core covered and decay heat 3 13 operating."
14 I would like you to review the April 10th, h40tl10)
(fb e-Q-35SA)
(ftge V-55$-?
1979 memorandum contained at Pages D 552jthrough 534 15 A
16 and tell us whether you ever discussed the design 17 requirements for the surge line/ pressurizer arrangement 18 with anyone at (3(3W.
i 19 A
I have no specific recollection.
20 Q
Do you have any general recollection?
i of having been involved in discussions.
21 A
Just I
I
- l 22 Q
Would you tell us with whom you discussed 23 that question?
24 A
I can recall discussions with Mr. Dunn of the 25 ECCS Unit which would have no particular bearing on 4
L 1
LaDelle 29S
,r~ '.
2 the information presented in this particular memo.
<I s
3 Q
What was the nature or substance of your 4
discussion with Mr. Dunn?
5 A
I don't recall.
/
6 Q
Are you aware of any requirement for the 7
surge line/ pressurizer arrangement other than that 8
stated in the second sentence on that page r o-05527 t
9 A
The particular design requirement cited is not i
10 one with which as manager ol'the Safety Analysis Unit 11 I would have had to have dealt with, nor would I be I
12 aware of any other design requirements of that nature, i
13 no.
,m i f
- (
/
14 Q
Who at B[)CN would be most familiar with l
15 the design requirements for the surge line/ pressurizer i
i l
16 arrangement?
17 A
I think you would have to ask Mr. Hudson and Mr.
18 Snow.
I I
19 Q
I would like you to ref er to Page-D-3558 of l
l 20 GPU Exhibib-295 for identification.
Did you and Mr.
l I 21 Charakhani forward this document to Dr. Womack in the I
22 ordinary course of business?
23 A
Since I am listed as a co-author, I would presume 24 that I did.
t, ~s
'l
)
25 Q
Would you please review " Final Conclusion l[
t kI li i
on x,
1 LaBelle 299 2
Nov-which is listed on P age-D-3 5 5 9, which is the
[fGj6 0 (190Y10) 3 second pageAof the April loth, 1979,jmemorandum from 4
yourself and Mr. Gharakhani to Dr. Womack.
5 Can you tell us the basis of that 6
conclusion?
j 7
A No'.
I t
8 Q
Was any analysis done within the Safety 9
Analysis Unit to support that conclusion?
10 A
Not that I am aware or, i'
11 Q
Did you discuss that conclusion with 12 anyone at B[hCN?
13 A
Not that I can recall.
14 Q
Under the heading " Recommendations" on 15 that same page, there is a recommendation that:
16 "A task group should be originated to 17 look into the following:
18 "No.71.
The origin of the current B & W 19
. surge line design."
t I
20 Was that ever done?
4 21 A
I can only recall that it was examined and that I
l 22 may be addressed elsewhere in your Exhibit-29 5.
i 23 Q
Do you know who examined that question?
lt 24 A
N o '.
(3_,/
25 Q
Do you know if recommendation Nor-2, which
/
l l
o
/
e.,
,y
---,-,,+---,,r---
-e.-,
=
1 LnDolle 300 2
is contained on the following page, M D4560, was G
ever implemented?
3 4
A No, I do not.
5 Q
If you wanted to find out, who would you s
ask?
i 7
A I cannot recall anyone specifically that I 8
would consult.
l l
9 Q
Do you know if anyone within BC D looked 10 into the items listed as Recommendation
--G o n 11 Pag e-D -3 5 6 0 7 l
12 A
I don't know.
f 13 Q
If you wanted to find out, who would you 14 ask?
15 A
I would not know who to.ask within the working 16 levels at B & W.
17 Q
Is there anyone you would ask above the i
18 working levels?
[
19 A
The engineering departme'nt manager.
20 Q
Do you know if anyone withi,n B & W looked 21 into the recommendation M 4 or did any work relating h
22 thereto?
I 23 A
I have no specific recollections, although I can 24 recall that there were studies that have been done (1VO3A iQ prehMI-2 incidentg as well as after.
25 g
LcDollo 301 1
2 Q
To what studies are you referring?
3 A
I have no recollection of what those studies t
4 would be specifically.
5 Q
Who performed those studies?
6 A
There were some studies w: ich were performed 7
prey MI-2 incident within Safety Analysis Unit and l
8 in conjunction with our instrumentation people.
9 Q
If you wanted to find out the results of 10 those studies, how would you go about doing it?
I 11 A
I would not know where to look.
12 Q
Would there be a calculational file i
l 13 relating to some of the techniques to measure 14 pressurizer level?
15 A
I don't know.
16 Q
Do you know if anyone at @ has looked into or done any, work relating to recommendation k 5 17 18 which appears on Page-D -35607 19 A
No.
20 Q
If you wanted to find out whether any i
21 such work had been done, how would you go about i
22 finding that out?
4 i
l 23 A
1 would have to consult the engineering f
24 department manager.
I 25 MR. GLASSMAN:
I would like to have marked m
k___-
1 LaCollo 302 (E/b/b/f~)
2 as GPU 296 for identification an April 5th, 4
/n, (7 % / o 9 1979 mem randum fr m Mr. Swanson to Mr. Kane
( p) 3 A
with a carbon copy to a number of people 5
including Mr. LaBello.
6 (Memorandum dated April 5,
1979 to Mr.
7 Kane from E.
W.
Swanson was marked as GPU i
Exhibit No71-296 for identification as of this 8
j g
date.)
10 BY MR. GLASSMAN:
11 Q
I show you what has been marked GPU l
12 Exhibit 296 for identification (handing document to 13 the witness).
Did you receive a copy of that document?
s 14 A
I have no recollection of having received this (v) l 15 document.
I 16 Q
The document speaks of a proposed 17 operating instruction.
I would like you to focus on 18 the proposed operating instruction and in particular k
j 19 review the second paragraph of GPU Exhibit 296 marked 4
f 20 for identification.
21 Did the Safety Analysis Unit have any 22 input to formulation of this proposed o - ating l
23 instruction?
A Not that I recall.
24 l
+,m l(( /)
25 MR. GLASSMAN:
I would like to have marked
=
l' LaDolle 303 2
as GPU Exhibity297 for identification an April p) 1904of
\\
3
- 8th, 1979 memorandun, subject: Operating 4
4 Instructions for Stuck-Open PORV.
5 (Memorandum dated April 8th, 1979 to G.
6 T.
Fairburn from D.
G.
Newton and L.
R.
Cartin 7,
was mark 3d as GPU Exhibit No)C297 for i
8 identification as of this date.)
I t
9 BY MR. GLASSMAN:
I 10 Q
I show you what has been marked as GPU 11 Exhibit 297 for identification ' handing document to 12 the witness).
Did you receive a copy of this 13 memorandum?
i 14 A
I have a vague recollection of having seen a 15 similar-type document, yes.
16 Q
Did you ever conduct a review of that 17 document or the operating instruction attached thereto?
18 A
I cannot recall that a specific review was 19 provided for GPU Exhibit 297 20 Q
Did you ever discuss an operating i
21 instruction for a stuck-open PORV with anyone at $[(3N?
h I
j 22 A
Yes.
j l
23 Q
With whom did you discuss it?
l 24 A
I cannot recall.
- i
( )
25 MR. GLASSMAN:
I would like to have
w 1
LaBelle 304 2
marked as GPU Exhibit-298 for identification O
G9sw) this document dated April 8th, 1979-12:57 a.m.,3 3
4
Subject:
Operating Instructions for Stuck-5 Open PORV.
6 (Memorandum dated April 8th, 1979 to 7
E.'A. Womack from D.
G.
Newton was marked as 1
i i
8 GPU Exhibit td[b-29 8 for identification as of i
I g
this date.)
I t
I 10 BY MR. GLASSMAN:
11 Q
I show you GPU Exhibit 298 marked for r
I 12 identification (handing document to the witness).
I i,
13 would like you to review the first paragraph of that 14 documeat and tell us whether that refreshes your
~
15 recollection as to any discussion you had with anyone 16 at ([()N regarding operating instructions for a stuck-i 17 open PORV7 l
18 A
No, it does not.
19 Q
Do you know if anyo e else in Safety 20 Analysis Unit had any. input to an operating i
21 instruction for a stuck-open PORV subsequent to the I
(1 @ 33 0
!l l
22 TMI-2 accidengf I
23 A
No, I do not, with the-exception that Exhibit R97 24 IShreferstodiscussionswhichwereheldwithMr.
(::)
2e
.onoca.ho..s.orming 1n ehe..,eey An.1ysis enie ae l
1 LaBelle 305 2
the time.
3 Q
Does that refresh your recollection as to 4
whether Mr. Bonoca provided any input to formulation 5
of Operating instructions for.a stuck-open PORV?
6 A
Ho-i 7
Q Did there come a time after the TMI-2 i
acciden t(A when19033 9 individuals in the Safety Analysis Unit l
8 9
considered changing the set point for the PORV?
i 10 A
I am not sure I understand what is referred to t
11 as changes in set point being considered by Safety j
12 Analysis.
13 Q
Did there come a time after the TMI-2 m
14 accident when individuals in the Safety Analysis Unit 15 reviewed advantages or disadvantages of changing the i
16 set point for actuation of *ae PORV?
17 A
I believe this subject has been previously i
18 testified to, yes.
19 Q
The answer is yes?
20 A
Yes.
l, 21 Q
Do you recall at this point how soon after
'l h
22 the accident that was considered?
M A
No.
I 24 Q
Do you know whether it was considered 25 within a week after the accident?
m
,. ~
y 9
~..
1 LaBelle 306 2
A I don't recall, but I would add that the s
subject of the set point change became an issue which x'
3 4
was very much of concern to the Nuclear Regulatory 5
Commission i
6 Q
Do you know when the Nuclear Regulatory first communicated to ([(]W7 i
7 Commission's concern was
{
8 A
No.
9 Q
Did anyone in the Safety Analysis Unit of 10 B & W consider the advantages or disadvantages of i
11 changing the PORV set point before the NRC expressed 12 its concern to B & W?
i !
13 A
No.
(
14 MR. GLASSMAN:
I would like to have marked i
15 as GPU Exhibit 99 for identification an April
[1kofd7/
1979(4 memorandum, subject:
Operating 16
- 9th, 17 Instructions for Stuck-Open Power Operated 18 Relief Valve.
19 (Memorandum dated April 9th, 1979 to 20 E.
A.
Womack and G.
T.
Fairburn from E.
R.
Kane 1
4 was marked as GPU Exhibit Ndb--299 for 21 h
e i
(}
22 identification as of this date.)
l i
l 23 BY MR. GLASSMAN:
i i
! {.
24 Q
I show you what 6as been marked as GPU l :
~s
)
25 Exhibit 299 for identification (handing document to x,
1 LaBolJ e 307 2
the witness).
Did you receive a copy of that l ' ]
! (
d cument?
3 4
A Not that I can recall.
MR. GLASSMAN:
I would like to have marked 5
300 for identification a multi-G as GPU Exhibit7 7
page document bearing the p ag e-n L 29 D-4 6 9 5 6--
8 through 696'8 and having a written indication
{
g "D.
W.
LaBelle" on the front page.
10 (Multi-page document bearing page numbers 11 D 46956 through D 46968 was marked as GPU i
Exhibit N 25-300 for identification as of this l
12 i
f 13 date.)
)
14 BY MR. GLASSMAN:
1 15 Q
I would like you to review what has been l
16 marked as GPU Exhibit 300 for identification (handing 17 document to the witness).
Tell us whether you can 18 identify that document.
19 A
The document is familiar to me.
20 Q
can you tell us what it is?
21 A
It is a summary of information which was l
I i
22 prepared for a meeting with the Nuclear Regulatory commission)g$0)
(
23 24 Q
Who prepared GPU Exhibit 3007
(';)
25 A
There were many different people involved.
L m- - -
~
_m 1
LaBelle 308 e'S 2
Q Who was responsible for supervising the U
preparation of this document?
3 4
A I don't recall specifically.
5 Q
what unit was responsible for preparation 6
Of this document?
7 A
I don't recall that any specific unit was I
- I 8
responsible for the documentj?
l 9
Q' What units participated in the preparation i
10 of.this document?
11 A
Other than Safety A'nalysis Unit, I don't know.
!,[
12 Q
Who in the Safety Analysis Unit participated l
'i 13 in the preparation of.;is document?
14 A
At least myself.
15 Q
Anyone else within the Safety Analysis Unit 16 that you can recall who participated in the preparation I
17 of this document?
18 A
I doh't know.
19 Q
Do I correctly understand that this 20 document represents a summary of information prepared i
21 for an NRC meeting?
l !
22 A
Yes.
h j
23 Q
dhat back-up information can be found l f I
24 within q]&^W relating to this document?
]
25 A
I don't know.
t 1
4
-r,- -- _,
L _,
\\
1 LaBelle 309 2
Q Was there other information prepared for O
3 this meeting with the NRC?
4 A
I don't know.
5 g
If you wanted to find out, where would
,p 6
you look?
b 7
A One would have to check with the individuals l
8 that provided the information to determine that.
- 6,{
9 Q
When did this meeting with the NRC take l
10 place?
i 1
f; 11 A
I don't recall the specific date.
j 12 Q
Approximately when did it take place?
5
$03A$5
,i 13 A
Some time after the TMI-2 inciden O
14 Q
Within a month after the incident?
l 15 A
I don't recall.
4 16 Q
Can you identify for us the words that i
1 17 are written at the bottom right-hand corner of this j
18 exhibit?
19 A
You are referring to the TMI/2 anal Beq'?
20 Q
Yes.
Do you know what that refers to?
f 21 A
Yes.
t 22 Q
What does it refer to?
23 A
That is an abbreviated indication to my 24 secretary that this is to be placed in my TMI-2 chron i 1'0 s
ll file with the subject title " Analysis Sequence."
25
!l f
li
[
__z.
_.___m-
^-
i i
LaBelle 310 I
o Q
From whom did you receive this document?
A I have no specific recollection.
3 4
Q P ag e--1 o f this document, the second full 5
paragraph, discusses a number..of. alternatives which were 6
considered in developing proposed actions.
Were these alternatives considered by the Safety Analysis 7
}
g Unit?
i 1
l 9
A As best I can recall, the Safety Analysis Unit I
10 participated in suggestion and review of alternatives.
11 Q
What work did you personally do with regard i
l 12 to this document?
l i
13 A
I don't know.
A 14 Q
Was this document j' its final form
-t 15 prepared in the plant design section?
16 A
I don't recall.
17 Q
There is a paragraph on Page-1 of Exhibit-d87 18 E&h which reads:
19 "An analysis of the impact of these
! t 20 various alternatives and their contribution i!
21 to assuring that the PORV will not actuate for h
[j 22 the class of anticipated transients of concern i
- 23' has been completed."
f i
I 24 Where can that analysis be found?
l!
25 A
Any analysis that was performed by the Safety l
L--y 1
LaBolle 311 2
Analysis Unit would be found in the files of the
)
3 Safety. Analysis Unit, I would presume.
4 Q
How would you find those files?
5 A
By referring to the calculational files for 6
any, calculational materials.
l i
7 Q.
If analysis of the impact of these various 8
alternatives and their contribution to assuring that l'
the PORV will not actuate were performed by the ECCS
'j g
i If 10 Unit,. where would that be found?
I 11 A
I think you have to keep in mind that the
] t-e 12 alternatives that are dealt with here cover a very i-il 13 broad range of suggested changes in reactor protection,
()
14 PORV operating' set point and other types of
' I i
15 combinations, so it is difficult for me to be able to
]
16 site any. references beyond input that is provided by i
17 the Safety Analysis Unit.
l 18 Q
Did EC()W arrive at a conclusion as to i
19 which of these alternatives were the most appropriate?
I 20 A
No.
These were presented to the Nuclear i
I 21 Regulatory Commissiong and the last page of the h
e i 22 document summarizes some of the pros and cons of one
'. l s
23 alternative which was presented.
t lj 24 There were other pros and cons which were 25 considered by the Nuclear Regulatory Commission and d.
t L
g m.w.____-=-
_ - _ _. ~
y 1
LaBelle 312 2
B(M)W was instructed as to which alternative the Wh Nuclear Regulatory Commission (a ished w
to be placed into 3
i 4
effect at the operating plants.
5 Q
Does this document contain B & W's 6
assessment of the advantagee and disadvantages of each
,l 7
of.the four proposed alternatives?
g I
^
8 A
As best I can recall, it presents portions of I
1 t
9 information which may pertain to advantages and
!i
}
10 disadvantages.-
,I j
11 Q
What was the highest level of B & W 12 management that reviewed this document or the proposed 13 recommendations or alternatives?
l s_/
14 A
I don't know.
15 Q~
What is the highest level that you are i
16 aware of?
{
l 17 A
At least my immediate s up eri s o r.
18 Q
That was Dr. Womack?
i l
19 A
Yes.
t 20 Q~
Are you aware of whether any level of B-&&)
f 21 M management above Dr. Womack reviewed this document fi h
22 or the alternatives presented?
I!
23 A
No.
24 MR. GLASSMAN:
I would like to have 25 marked as GPU Exhibitg301 for identification a I.
a
L
~
- - - - ~<
- - -. ~
LaBalle 313 1
(-1406H)
June lith, 1979pmemorandum,
Subject:
Plant 2
Computer Post Trip Req *2irements.
3 (Memorandum dated Jh.te lith, 1979 to p
4 R.
I.
Lutz from D.
B. Fairbrother was marked
.f 5
as GPU Exhibit +dQP-301 for identification as of i
6 this date.)
l 7
!l l !-
8 BY MR. GLASSMAN:
9 Q
I show you what has been marked as GPU i
s 10 Exhibit-301 for identification (handing document to ij i!
11 the witness).
Did you receive a copy of this i !
.t 12 document?
(I!
13 A
The document seems vaguely. familiar, yes.
!.s 14 Q
Can you read for us the handwritten 15 notation at the bottom of the first page?
16 A
Other than TMI-2, no, I cannot.
I 17 Q.
Are you f amiliar with a TMI-2 equipment s
18 design file?
I 19 A
The handwriting would indicate that it is my f
20 writing and that this would be in one of my TMI-2 i
21 subject files.
h i
I ?
i, t 22 Q
Do you have a TMI-2 subject file which j
{-
\\
l 23 is called TMI-2 equipment design?
I
?$
24 A
I could.
I don't rec 111.
l l
I f
25 Q
I would like you to refer to the third i f
- 1 t~i r
1
1 LnBollo 314
(.2 2
pageg of GPU Exhibit-301 for identification.
Tell us
[\\
whether this document, these next two sheets labelled 3
[D'/bVOR)
D-4 69 01 and 02, whether these pages were prepared by 4
5 anyone in the Safety. Analysis Unit.
6 A
Not that I am aware of.
7, Q
Do you know who prepared them?
i 8
A No.
(~-l) l 9
Q I would like you to review the first pagea i
10 of GPU Exhibit 301.
The third sentence in Paragraph-[
refers to:
11 12 "The comments from afety Analysis i
13 (attached)... "
l s
\\
14 I would like you to review that paragraph 15 and tell us whether that refreshes your recollection 16 as to whether the attached two pag r
prepared by i
17 anyone within Safety Analysis.
I i
18 MR. WISE:
Couldn't we have done this i
19 earlier?
Was it necessary to go this long route f
20 to get to this?
21 MR. GLASSMAN:
I don't know what long
.j h
l 22 route you are talking about.
We haven't spent l
l 23 so much time on this document.
l,
I l
24 A
No, I have no recollection of this.
lb l !\\ms/
25 MR. GLASSMAN:
I would like to have marked I
i 1
n
_w -- - -
1 LaBelle 315 as GPU Exhibit 4-302 for identification an April o
~T y' ')
ODYAS) 25th, 198 ' memorandum, subject:
Reliability 3
4 of ESFAS II, with an attached memorandum of (fQlA0h 5
December 7th, 1979g, subject:
P S C--3 6 - 7 9 6
" Reliability of ESFAS-II."
i 7
(Memorandum dated April 25th, 1980 to 8
E.
A.
Womack from J.
H.
Taylor, with attached g
memorandum dated December 7th, 1979 to J.
H.
k 10 Taylor from D.
W.
LaBelle, was marked as GPU l
11 Exhibit Md7 -30 2 for identification as of this 7
{
12 d a t e.-)
13 BY MR. GLASSMAN:
m t
14 Q
I show you what has been marked as GPU 15 Exhibit-402 for identification (handing document to I
t 16 the witness).
Did you receive a copy of this document 17 in the ordinary. course of busin ss?
18 A
Yes, I did.
19 Q
Did you prepare and forward to Mr. Taylor l'
i 20 the December 7th, 1979 memorandum that is annexed to l!
i!
21 the April 25th, 1980 cover memorandum?
h l
22 A
Yes.
I e i copy of PSC 36-79 23 Q
If you wanted to ' find a 1
(10lAOO l
24 which is referenced in the December 1979 memorandum, A
l l 25 how would you go about finding it?
Ii
.l t
l t
E...
-, -. ~.......
1 LaBollo 316
/^x 2
A I would check with the licensing organization.
I
)
'~'
3 Q
Does the Safety Analysis Unit maintain a 4
file of PSC's?
5 A
I may have a chron file that has PSC information 6
in it.
i 7
Q Can you tell us what is meant by ESFAS II?
7 l
8 A
This would be the second in a series of ESFAS 9
. designs.
10 Q
What does ESFAS stand for?
11 A
Engineered Safety. Features Actuation System.,
i 12 Q
What is meant by the term of " acceptance i
! (-
13 criteria" as contained in the first sentence of this
\\
't IV 14 memorandum?
l 15 A
You are on Pageg-l?
l l
(19w1) l 16 Q
Referring to the DecemL s 7th, 1979a l
17 memorandum, Page72 of GPU Exhibitz302 for l l l
l 18 identification.
19 A
Acceptance criteria is an acceptance criteria.
20 Q
Could you describe that for the benefit 21 of a layman?
22 A
You have certain criteria by which you provide i
l l
23 a design.
l i
l 24 l
Q Would acceptance' criteria include failure
,_4
' a it l\\ /
25 rate?
i I
1 LEDelle 317 2
A It could.
3 Q
At the end of the paragraph which we are 4
reviewing the following words appear:
5
"...I am concerned that B[)CW has not 6
defined reliability goals for its safety systems 7
and' is not presently designing to such criteria."
8 What safety systems are you referring to?
l 9
A To all safety systems.
10 Q
Would the term encompass high pressure h6) 11 injectiong r i i
12 A
Yes.
13 Q
Would the term encompass auxiliary fh W
l l d 14 feedwate i
15 A
Yes.
16 Q
Would the term encompass integrated control hp66 17 systey 1
18 A
It could.
19 Q
Would --
20 A
But the integrated control system is not 21 presently considered a system that is necessary for plant; g
f 22 safety.
i t
t 23 Q
Would the term safety system encompass the i
j I
24 PORV?
l('s l
[
25 A
It could;.although the PORV is not presently i
l
^
I i
1 LaDollo 318 e nsidered a safety system.
2 Q
In what respect could the PORV be considered a safety system?
4 A
If it was deemed to have safety significance.
5 l
Q
.as the,oRv deemed to have safety j
significiince?
7 I
A It has,to date,not been classified as a safety 8
system..
g Q
when you refer to a piece of equipment or 10 component being deemed to have safety significance, 11 12 what do you mean?
A whether it is necessary.for core protection or 13 to meet any.other criteria that have been established 14 15 for Plant safety.
You are getting into an area 16 where there are many different considerations that 17 have to be accounted for, and these are only a few of 18 them.
19 Q
The next paragre.ph of the December 7th,
(?@fA0Th 1979 memorandum contains a reco-mendation regarding 4
20 the definition of reliability.gaals forallB))
21 22 system designs.
Do you know if this was ever done?
23 A
No.
24 Q
Did you ever discuss this recommendation O-25 with Mr. Taylor?
n i
_ _ - ___ - _ - -- -__-__ - _ _ _ __ ___-_ _ _ - - _ ___-__ U
,n s
f 1
LaBelle 319 2
A Yes.
Q could you tell us what you said to Mr.
3 4
Taylor and what he said to you?
t.
i 5
A I have no recollections of our discussion.
6 Q
Do you recall the nature or substance of 7
your discussion?
8 A
Nothing other than the subject described here.
9 Q
Did Mr. Taylor say anything to you in that i
10 regard?
s 11 A
Not that I can recall.
12
.Q Did you have any discussions with r,apard' N
C ' '--
13 to this recommendation with Dr; Womack?
D.
O 14 A
Yes.
15 Q
Do you recall the nature or substance of s
16 any s'uch discussion?
17 A
Nothing other than the subject described here.
18 Q
Did Dr. Womack say anything to you? [
19 A
Not that I can recall.
S 20 MR. GLASSMAN:
I would like to have i
s 21 marked as GPU Exhibitg303 for identification a
-g forom 22 May 2nd, 197 memorandum, subjects, Preparation 23 of a document on the safetygaspects of MK-A f-24 in view of the TMI accident.
1 i
I 25 (Memorandum dated May 2nd,' 1979 to
(
.I o
1 m
=
s 4
..: x n.
1 LaBolle 320 s
s-g~
2' Disstibution from J. R.Bohart was marked as I
- s t
'3 GPU Exhibit 'No -3 0 3 for identification as of 4
this da.t e. )
N 5
.BY MR. GLASSMAN:
s 6 I N,9 I show you what has been marked as GPU o
g
\\,.
's s
s s
Mxhibit 303 for identification (handing document to, 7
\\
q i
b '4 th<c. witne s s ).
Have you ever seen a copy of this x',
-(
i
'i 63 document?
I,y i
,i s.
(',
i 10 A
Not that I can recall.
s.
.3 11 Q
There is a reference under the
.s s
4 12 Distribution heading of this document to a T.
W.'
b i
1 13 LaBelle.
Do you know if there is any other LaBelle
'O s
14 at B @ other than yourself?
, y-
\\
~
1 c
A no.
~ l 3';5 s.
I 16 Q
AttLhe boti:om right-hand corner of the i
17 first page of CPU Exhibit 303 there is a reference 18 to bBR TMI-2, followed by what appears to be the t
19 number-70 which is circled.
Do you know what that l I i I
( ;
20 refers to?
\\
l
?
{
/ g.?,
-21 A
Yes; this is an identification to my secretary l
i i
s
'\\, 2 to file this in my BBR chron file.
2 i
O I
..,3-l
'n r s
o 23 i Q
Does that appear.in your handwriting,,that j-
)
- r I
24 identification?
s
' ]q i I 25 A
- yes, 3
r t
'N
L
=, -
- - - = --
--~v q
l 1
LaBelle 321 2
Q What is the 70 with a circle around it?
}
3 A
The specific chron file number.
4
~
Q Are all.of your chron files numbered?
5 A
No.
1 6
Q Did you have any particular practice 7
regarding when you assign a number and when you don't?
i I
8 A
Normally, a major file such as TMI-2 would not 9
carry.a number because of the amount of information.
10 It would have been filed in notebooks instead of i
11 folders.
a,
12 Q
Would a chron file rf yours which contains i
13 a number indicate a chron file contained in a folder l
l 14 rather than a notebook?
}
15 A*
Not necessarily.
)
16 Q
Can you tell us who G.
G.
Ziph is, Z-i-p-h?
17 A
At the time of this memo Mr. Ziph was chairman
+hD 18 of the board of Babcock's Wilco Company.
19 Q
Do you know if he is still with $3h3W?
i 20 MR. WISE:
Mr. Ziph is no longer the I
21 chief executive officer.
We can provide you g
1 l
22 with this information at some point.
l 1
I 1-23 BY MR. GLASSMAN:
i t 24 Q
Would you identify for us the positions of I
- i
![
25 each of the B & W persons indicated under Distribution 1
1 4
k L
LaBolle 322 g
I f'1 2
n this document?
G A
Are you referring to current positions or positions at the time the memo was written?
4 Q
I would like you to identify both of those, if.y u know.
6 A
Mr. Jenkins, Mr. Lexa, Mr. Warner and Mr. Henig 7
were a part of the International Project Engineering g
Unit within the plant desigr. section at the time of 9
the memo being written.
10 To the best of my knowledge, these gentlemen 11 d
12 are in our project engineering area for the international
, /~';
13 program at the present time, but I don't know the
, L.)
g4 specific name of their section.
t 15 B.
B.
Eanes and R.
H.
Rhodes I do not specifically l
l 16 recognize.
1 i
17 Q
Can you tell us if you know the positions 18 at BBR of the individuals listed under the Distribution (1$0$0}0 j
19 listed for BBR, those positions of May 2nd, 19793and 20 their current positions if you should know?
f
(
i 21 A
I do not know Mr. Thomas's position title.
Mr.
g 22 Caspar, at the time of this memo and to the present 23 time as far as I know, is th'e manager of what would
.i 24 be termed plant integration.
l l(']/
j
, s 25 At the time of the memo Mr. Day and Mr. Beebe I
l
.c r-l h=
1 LaBelle 323
)
2 Probably reported to Mr. Caspar.
3 Q
Do you know the functions or the 4
responsibilities of Mr. Thomas?
i.'
5 A
Not specifically, no.
f 6
Q Do you know them generally?
7 A
Other than to say.that he is in high level
'I 8
management at the BBR.
! i I
g Q
Referring to Page 4 of GPU Exhibitz-30 3, 10 the end of.the fifth full paragraph, there is a 4
11 reference to a Bob Warner.
Do you know who he is?
i 4I!
12 A
He is an engineer at ([k]Norhewasan
}!
13 engineer at B & W.
('
i 14 Q
Do you know what section he works or i
15 worked at?
I i
16 A
He was with the International Project I
t 17 Engineering Organization.
I 18 Q
The next full paragraph on Page 2 of z
f 19 GPU Exhibit 303 reads as follows:
I 20 "I would like to ask Peter Caspar and l i 21 Danny LaBelle to work together in prepae].ng f!
g (S&ons-)
[j 22 the sections in4 2.0 on differences in safety j
i l!
and operating philosophy and Section-3.0 on
'l 23 l
I
! #~D 24 the existing BBR analysis which supports the I N.J theTMI(AT/H1~4) 25 argument that the occurrence of
,l l
i l
mm.-
-_m_..m...---
m
~
m 1
LaBelle 324 g
39039 @
I accidenthon MK-A i's very vnlikely."
O
~
Did you do any work in this regard?
3 A
As best I can recall, I did.
4 5-Q Can you descr'ibe for us the work you did?
A Nothing other than the general subject matter 6
that is presented here.
7 8
Q Can you describe for us generally the role that Peter Caspar played in this work as compared to 9
10 the role you played?
A No.
I have no recollection of that.
l 11 12 Q
Did anyone else in Safety Analysis work on 13 preparing sections of the requested report?
A Yes.
g4 15 Q
Who was that?
16 A
Mr. Bonoca.
17 Q
Anyone else in Safety Analysis Unit do l
[18 work on this report?
l i
19 A
Not that I can recall.
20 Q
Did you supervise the work of Mr. Bonoca?
21 -
A Yes.
I h
i 22 Q
Did Mr. Bonoca e.ctually work with Peter I
i 1
l 23 Caspar in preparing certain sec.' ions of the report?
i 24 A
I don't recall.
iIb 2V 25 Q
Did you actually work with Peter Caspar ll'
- ~....... - -. ~.,.....
1 LaBelle 325 3
in preparing sections of the report?
A I just do not recall.
3 4
(Whereupon, at 1:10 o' clock p.m.,
a 5
luncheon recess was taken.)
i 6
j 7
I 8
i 3
9 i
10 11 12 AFTERNOON SESSION i
2:25 P.M.
l 13 14 DANNY W.
LaBE LL E resumed 15 as a witness and, having been previously duly 16 sworn, was examined and testified further as 17 5
follows:
18 EXAMINATION (Continued) 19 BY MR. GLASSMAN:
l 20
,2 l
l Q
Referring again to GPU Exhibit-393'for l
l 21 in particular Attachment,-l'jto that identification, and 4
l 22
,/
l j
exhibit at Page -D 9269, does the handwritten notation l
23 t,
i i
on the right ide of that page contain your handwriting?
24 f
A It could be.
9$
i e
a W'
__._-._._.u r _ -- -
3-1 LaBelle 326 2
Q Can you attempt to read.that for us?-
(
the next word looks like 3
A "MK-A designed to" 4
" prevent, TMI-2," and then there is something else 5
there.
I can't tell.
G The next line reads, " safety systems," and in 7
parentheses " anticipatory trips."
D' 8
j The next line says " Single failures" and two l
/
9 k-sub topics, " safety" and "non-safety systems."
i-
/
/
10 '
The next line says " Mitigative systems 11 availability."
l Go-m}n te) 12 The next line says "Thir ty-minut eA op'e rato r l
! (
13 action," and the last word looks like it might be ig i
14
" criteria."
15 The next line reads "Syst-ns; independent."
16 The next line reads " Control systems," and the 17 last line reads "I.
C.
Limitation."
18 Q
Does your handwriting appear on the left l
19 side of that page?
I i
20 A
The left side of the page does not appear to be 21 my handwriting.
,/
g
,/'
=
i 22 Q
Does Attachment %1
~
GPU Exhibib-290 i
/'
t i
23 refresh your recollection s to any work you did in
}
l l
("N 24 connection with preparation of safety aspects of l
lk_]
i l
25 the Muelheim-Kaerlich plant in view of the Three Mile l
i
y
---n~+_,-_.,--.,
1
/
LaBelle 327 s',
N 2(Mf'ccident?
T 2
Island t
JL Not by.itself,.no.
3 4
Q Does it refresh your recollection as to.
5 whether you did any. work in connection with such a 6
report?
ij 7
A-I'was involved in support of the preparation of tj
- 8 this report, yes.
I L
g.
Q_
.Do you now recall the nature or substance
()
10 of your involvement?
i t-ilI 11 A
No, I do not.
/
/
12 Q
-I would/like you to refer to the next page 4i 'j 13 of GPU 2xhibit 3 3 for identification.
The name i
form on that. document.
LaBelle appy rs in handwritten lj 14 l
15 I would like you to review that sheet of paper and 16 tell us whether that refreshes your recollection as l
4 17 to the nature or substance of any work you did in 4
l 18.
support of or in relation to the safety aspects of il f
l i.
19 the Muelheim-Kaerlich plant in view of the Three
- I 20 Mile Island 2 accident.
- 1. !
21 A
No, not by itself, it does not.
Ii f
22 Q
If you wanted to refresh your recollection i
a the. work j
23 with regard.to the nature or' substance of 24 you did on safety aspects of the Muelheim-Kaerlich S
- i
)
!, j 25
. plant in view of the TMI-2 accident, are there any i
l' b
i i !
-._..m_.,
1 LaBelle 328 2
documents to which you would refer?
A I could refer ~to the document itself that is 3.
described.in outline form here, yes.
4 5
Q I show'you what' has previously been 6
. marked as GPU Exhibit 2 for identification (handing i
I 7
document to the witness).
can you identify that I
8 document for us?
i 9
A As best I can recall, it appears to be the
/
10 document which is cited in GPU Exhibitp290(
11 Q
I would like you to revie what has been i
12 marked as GPU Exhibit 32 and tell u if that refreshes
~
13 your recollection as to the nature or substance of 14 your involvement in the preparation of this report.
l l
15 In particular, as you go through that report, if f
l IG there are any particular pages which refresh your 17 recollection would you please note them for the record.
18 A
I will state in general lthere are certain pieces f
19 of. background information that may have been referenced 20 in preparation of the report as taken from Safety i
21 Analysis Unit files.
22 I could not state.that I can recall writing l
i 23 any portions of the report.
~There are graphs and l
- p 24 tables and certain sections of words that appear to IV
[
25 have been generated in the Safety Analysis Unit I
t
g- -.
LaBelle 329 1
3 outside of the specific preparation of this document.
U("3 There was background information that was taken 3
from old calculations that were performed, or reports.
4 5
Q Is that the only. work you recall being as input to this 6
performed by the Safety Analysis Unit 7
report?
I 8
A You refer to work being performed as input to l'
9 the report.
I understand this to mean the supply,of i
10 information that had previously been available for 11 inclusion in the report.
12 Q
From what sources was information 13 gathered by the Safety Analysis Unit or anyone in the 14 Safety Analysis Unit for inclusion in the report?
15 A
I could not identify specific sources from my 16 recollections.
17 Q
If you wanted to find out that information, 18 where would you go?
)
To safety analysis unit calculationAI files or 19 A
files which were/ maintained by i
20 to perhaps the chron
-N)
(7 21 myself for Three Mile Island 3p.
l g
l 22 Q
To what calculati nal files.would you go?
l i
23 A
I don't know which specific calculational files l
l 24 I would go to.
l
! \\.
25 Q
If you wanted to find that out, how would i
%~
l LaBelle 330 2
you go about it?
3 A
I would have to identify who the author of the 4
calculational file would have been.
5 Q
Are there any calculational files in 2
6 existence which relate specifically to information 7
provided for inclusion in this report?
8 A
There could be.
,j l
j 9
Q If you wanted to find out whether there 10 were such calculational files, who would you ask?
I 11 A
As I said previously, I would have to know who i
12 the individuals were that were involved in the g
13 calculations.
l(%]
14 Q
If you wanted to find out who the 15 individuals were, how would you go about it?
i 16 A
I would have to rely on my recall from which I 17 could not specifically identify who those individuals l
18 would be.
19 Q
Are you referring to individuals within j
I l
20 the Safety Analysis Unit?
4 ;
f
)
21 A
Yes.
i
/
22 Q'
ArI there any particular portions of GPU j/'
{
i i
23 Exhibit 0 for which the Safety Analysis Unit or 7
l (~}
24 anyone within the Safety Analysis Unit provided j(/
i 25 information, whether in the form of graph, tables or i
i i
I LaBelle 331 "fiti"97 2
A I c uld only respond just for-those materials of 3
which I am familiar.
I could not respond as to what 4
5 contributions may have been made by others in my G
unit for which I have no specific recollection.
Q' Did you review the information provided by
[
7 g
others in the Safety Analysis Unit before it was
- I g
provided to the writer or writers of this report?
10 A
I should have, but I could not recall that I
.I 11 did.
I-12 Q
Did you prepare any written notes or
,I!
13 comments with regard to information supplied by j
l.4 members of the Safety 7.nalysis Unit as possible input I-15 to this report?
16 A
I have no recollections that I did.
17 Q
If you had prepared such documents, where j
18 would you find them?
19 A
They would be in the BBR personal chron file.
- ;i
/ I would like you to review the report, GPU 20 Q
j ExhibitjI232 for identification, and tell us what g
21 i
/
'i
/
\\
22 information contained therein you recall as being i
(
i i
23 provided directly or indire,tly~by the Safety Analysis
}
l 24 Unit.
3 I
25 MR. WISE:
I will note for the record i
4 I
{
L 1
LaBello 332 that the report is,.I would guess, about an 2
(~)
v inch-and-a-half thick.
I don't know how many 3
4 pages.
Much of it is typed material, and then 5
l 6
there are_a number of graphs.
I don't know that 7
it'is a particularly. fair question to ask him 8
to look at'a document tha* size and separate 9
out page-by-page where the information came 10 from.
11 To the extent Mr. LaBelle can, by a i
12 reasonable perusal of the document, identify t
l 13 something specific that he knows came from his
!O 14 unit,.I have no objection.
l.
15 But the record should be clear that the
.itness is being asked to look at a very good-16 w
17 sized document and I think it is fair to ask 18 him to do the best he can in a reasonably short 19 time, but I don't think it is at all fair to l
20 ask him to.go through it on a line-by-line basis I
21 to separate out specific pieces of l
g l
22 information that may have come out of his unit.
i i
l 23 MR. GLASSMAN:
Mr. LaBelle did respond to
-j 24 an earlier question by saying this document would 25 refresh his recollection, or he thought it would,
1 LaBelle 333 3
and Mr. LaBelle already turned the pages and reviewed the entire document in some manner 3
4-while we have.been sitting here waiting for 5
his answer.
I think we can therefore proceed 6
without it taking too much time.
}
7 MR. WISE:
You are right.
You did ask 8
him before to go through it.
He will have to go i.
j g
through it on a page-by-page basis again.
If l
10 there is something specific in here that you are 11 interested in, you might wish to focus your 12 questions on that, rather than have him go I
13 through the whole document.
O'-
14 BY MR.-GLASSMAN:
15 Q
Did Safety Analysis, provide. input in all 16 of the sections of this report, as far as you recall?
17 A
Not that I am aware.
18 Q
Did Safety Analysis provide inpu't to the l=
19 introduction of the report?
I 20 A
Let me clarify your word " provide."
The way I e
j-g 21 would understand " provide" would mean whether we i
22 generated information to go into the report versus j
i 23 whether information was gener'ated by others from t
j 24 information that they had collected from correspondence
!v 25 from the Safety Analysis area or subsequent reports u
h 1
LaBelle 334 2
that may.have contained Safety Analysis information O-3 that had been generated by. Safety. Analysis.
The 4
latter is more indicative of the documentation that 5
will be found in this report.
/
6 Q
I would like you to go through'the table
./
j 7
of contents, please, found on Pag 75504, and tell us
~
j 8
whether the Safety Analysis Unit or anyone therein f
g provided any. input or forwarded any background i
l 10 information,. writing, graphs or tables, with regard 11 to each of.the sections listed there.
12 A
I could not do that based on the table of 13 contents alone.
'O j
14 Q
/I would like you.to review Pages-E-5671
/
15
--throug 685 of this report, which bears the heading "No
/ omparison of TMI-2 and MK-A," and tell us 16 C
1
(
17 whether Safety Analysis or anyone in the Safety l
l l
18 Analysis Unit provided any_ input whatsoever, 19 background information, graphs or tables or writing, I
Ii l
20 to prepare this section of the report.
i l
}
21 A
As best I can recall, Mr. Bonoca of Safety i i I
22 Analysis worked with Mr. Casg,ar of BBR in preparation 1
of Sectiong.1 of Chapterf4 within the pages that you 23 i
I lO 24 have identified.
I 25 other than that, I recognize no portions which Iq-t
.,-..,-.---.-.e
m_
. - -. - - -. - - - -. -. ~..
n==a l
LaNrilr 335 1-t are readily_ identifiable as having input provided by 2
the Safety Analysis Unit.
3 4
Q I next would like you to review Section75
/
of.this report which bears the heading " Safety Ashects 5
/
g of the MK, Plant," which is found on Pages 5686-
/
[
7 through/5708.
/
l 8
/
I would like you to review those pages, 9
please, and tell us whether anyone within the Safety 10 Analysis Unit provided any, input to the preparation of i
11 that portion of the report, whether by way of I
l 12 background information, graphs, tables or writing.
I, 13 A
I do not recognize any portions of the pages 14 that you have described as having been based on 15 background generated by the Safety Analysis Unit.
,/
IG Q
I would like you to review next Appendip,ec
/
17 of this report which is found beginning at Page 732 18 and tell us whether anyone within the Safety Analysis j
19 Unit provided any input to the preparation of this
.I
~ report, whether by background information, writing, j
20 e
t j-
)
21 graphs or tables.
i l
22 A
No.
l.
j 23 MR. GLASSMAN:
i'have no further questions t'
i 24 of this witness at this time.
t
.I'f.
25 MR. WISE:
I have one or two quick i
p
_. =
l t
LaBelle 336 questions.
2
. \\,./
EXAMINATION BY 3
MR. WISE.
4 g
During your examination the other day by 5
/
Mr. Glassman you were asked about your activi e's on.
6 DjO A0 the day.of.the accident, March 28th, 19)9g I would 7
~
8 like to focus your attention to the time.-when you lI arrived at the project control rpdingand there was a g
10 discussion occurring with Mrs Dunn present and the i
11 subject of superheat came up.
j 12 Mr. Glassman, I believe, asked you l
13 whether at that time you had any opinion whether the 10 14 existence of superheat in the system was a good or bad 15 thing.
16 Could you explain for us the circumstances 17 at the time you entered the room and the reason for 18 the answer that you gave to Mr. Glassman?
i 19 MR. GLASSMAN:
I object to the form of.the i
20 question.
21 A
The time I spent in the-project control center, l
22 as best I can recall, was a very short period of time I
I.
23 which did not allow me very l'ong to grasp the complete i
24 surrount'.ings of the discussions that were being held O
25 with respect to superheat.
i......
g LaBelle 337 2
Q.
In general, do you have any opinion as (v ).
to whether or not the existence'of superheat in a 3
f(,MN) 4 pressurized water reactorfis a good or a bad thing?
/
A It would have been of concern to me since one 5
6 does not desire t o-. b e in saturation during operation lt 7
or shutd6wn, much less to be in superheat conditions.
8 MR. WISE:
I ha,e nc further questions at j
9 this time.
- t
,t 10 MR. GLASSMAN:
I have no further redirect 11 questions at this time.
12 (Time noted:
3:10 p.m.)
!i
.l 13 l
14 i
15 16 Subscribed and sworn to 17 before me this------day 18 of-------------.,
1981.
I i
19 i
I 90 i
I l
l g
21 l
i l
22 I
s i
23 24 25
t 1
33g CERTIFICATE 2
STATE OF NEW YORK
)
3
- 33,:
COUNTY OF NEW YORK
)
4 I
I, JOSEPH R.
DANYO
, a Notary
(
5 Public of the State of New York, do hereby 6
certify that the continued deposition of 7
l DANNY W.
LaBelle Was taken Defore 8
me on June 4th, 1981 consisting 9
of pages 252 337 10 through t
I further certify that the witness had 11 been previously sworn and that the within i'
transcript is a true record of said testimony; 13 4'}
That I am not connected by blood or 14 j
marriage with any of the said parties nor i
15 interested directly or indirectly in the matter in controversy, nor am I in the employ of any I
l 18 IN WITNESS WHEREOF, I have hereunto set my 19 i
hand this~ M [
day of u#e
/ /f/,
l h
F 20 s
21 i
i Y
- -74
,l 23
,g g g g33pg
~
,f
't 24 s
M
b -- -
m y.
_m.
339 I ND E X Witness Examination by Page Danny.W. LaBelle -
resumed Mr. Glassman 254 Mr. Wise 336
't E X H I B I T S GPU Exhibits For gg /])
Identification g
(
292 Memorandum dated S/J/794to J.
H.
Taylor from D.
W.
LaBelle with attached documents g) 254 hkO i
'293 Memorandum dated May-8, 1979Ato E.
A. Womack from D.
W.
LaBelle 270 294 Multi-page document, cover page being dated 1/8/804to D.
W.
fromJ.H.T.($ bold $)
284 LaBelle 295 Multi-page document dated April r7 fog /R) 12, 19794 to Distribution from D.
W.
Fairbrother, subject:
Summary of Pressurizer Level Investigation /
Instruction #196
) 294 296 Memorandum dated April 5,
1979A to Mr. Kane from E.
W.
Swanson 302 1904'o8 297 Memorandum dated April 8,
1979 to 4
G.
T.
Fairburn from D.
G.
Newton
()
and L.
R.
Cartin 303 i
340 INDEX OF EXIIIBITS CONTINUED GPU Exhibits For Identification Page 298 Memorandum dated April 8th, 19794 to E.
A. Womack"from D.
W.
Newton 304 790409) 299 Memorandum dated April 9t 19794 to E.
A. Womack and G.
T.
Fairburn from E.
R.
Kane 306 300 Multi-page document bearing page numbers Dp6956 through D-4 6968 307 (fgff/)
301 Memorandum dated June 11, 1979 to4 R.
I.
Lutz from D. B..Fairbrother 313 (10c#1) 302 Memorandum dated April 25, 19804 to E.
A. Womack from J.
H.
- Taylor, with attached memo dated December j$/$d 7, 1979ato J.
H.
Taylor from D.
W.
LaBelle 315 190foA y
303 Memorandum dated May 2,
19794 to Distribution from J.
R.
Bohart 219 mee O
_