ML20072H879
| ML20072H879 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/22/1982 |
| From: | Lind J NUS CORP. |
| To: | |
| References | |
| TASK-01, TASK-1, TASK-GB NUDOCS 8306290792 | |
| Download: ML20072H879 (185) | |
Text
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK i
....--.----------x GENERAL PUBLIC UTILITIES CORPORATION, s
( JERSEY CENTRAL POWER & LIGHT COMPANY,
( 'c a METROPOLITAN EDISON COMPANY and :
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
[ -against-THE BABCOCK & WILCOX COMPANY and -
J. RAY McDERMOTT & CO., INC., 2
( f Defendants. , a I -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - -x Deposition of JOHN ALBERT LIND, a non-v -
party witness, taken by plaintiffs pursuant to notice, at the offices of NUS Training Corp., 1350 Piccard Drive, Rockville,..
Maryland, on Tuesday, June 22, 1982, at 8:50 o' clock in the forenoon, before Nancy.A. Rudolph, a Shorthand Reporte'r.
's .-
9306290792 810622 !
PDR ADDCK 05000289 1 T PDR I O s i.J ~ DOYLE REPOFkTING. INC.
CERTIFIED STENOTYPE REPORTERS 369 Lax NGTON AVENUE
, WALTER SHAPIRO, C.S.R.
NEW Yong. N.Y. 10017 CHARLES SHAPIRO, C.S.R.
t TELEPHONE 212 - 867-8220
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2 A p p e a r-a n ce s:
(*
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys - for Plaintiffs 4 425 Park Avenue New York, New York I
5 By: RICHARD C. SELTZER, ESQ.
6 -and-JULIE NEISSER, ESQ.,
7 of Counsel
( 8 9 DAVIS POLK & WARDWEk.L , ESQS. '
Attorneys for Defendants 10 I One Chase Manhattan Plaza New York, New York E 11 ~
By: ROBERT F. WISE, ESQ.
12
-amd-KAREN WAGNER, ESQ.,
- 13 *
-of Counsel 14 -
15 Also Present:
16 DAVID TAYLOR '-
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, [ 2 IT IS HEREBY STIPULATED AND AGREEb by 3
and between the attorneys for the respective 4
parties hereto that the sealing, filing and 5
( certification of the within deposition be, 6
and the same hereby are, waived; that the 7
transcript may be signed before any Notary 0
Public with the same force and effect as if 9
signed before the Court, 10 i
IT IS FURTHER STIPULATED AND AGREED that e
11 all objections, except as to the form of the 12 question, are reserved to the' time of trial.
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(} . MR. SELTZER: Mr. Wise, will you agree
(
3 to have Nancy Rudolph administer an oath 4 in Maryland?
5 MR. WISE: Yes.
(
6 JOHN ALB ERT L IN D, having been 7 first duly sworn by Nancy Rudolph, Notary 0
Public of the State of New York, was examined
~
9 and testified as follows:
10 L
EXAMINATION BY MR. SELTZER:
t 11 Q Would you state your full name, please?
12 A John Albert Lind, Jr.
} 13 Q What is your address?
14 A 18640 Queen Elizabeth Drive, Brookville, 15 Maryland 20832.
16 Q Who is your present employer?
II A NUS Training Corporation. -
, Q What, most succinctly, are your principal 19 responsibilities at NUS? -
20 A I am the lead training specialist for 21 the simulator projects group.
22 Q How long have you been working for NUS?
23 A Seven weeks.
24
(^}
LJ Q Where did you work prior to that?
25 A Quadrex Corporation.
l l
i- i 1 Lind 5 2 Q What were your principal responsibilities V} .
3 with Quadrex?
4 A I was a technical service engineer 5 involved with supplying training services for the
(
6 Beaver valley Power Station.
7 Q Who was the NSS vendor for that plant?
( 8 A Westinghouse.
9 Q So that was a Westinghouse pressurized 10 water reactor?
e 11 A Yes. ~
12 Q Where did you work prior to joining
- 13 Quadrex? -
14 A I worked in Midland, Michigan for Babcock 15 & Wilcox.
16 Q Did you leave B&G voluntarily to take a 17 position at Quadrex?
18 A Yes. .
~
19 Q How long were you employed by..B&W, 20 from when to when? -
21 A April 1976 to August 1st, I think that 22 was 1980; yes, 1980.
I M MR. SELTZER: I would like to mark as l 24 GPU Exhibit 560, _ a resume of J..A. Lind, Jr.
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N 25 (Resume'of.J. A. Lin d , Jr. was marked
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(
1 Lind 6
() ~ 2 as GPU Exhibit 560 for identification, as .-
3 this date.)
4 Q Do you recognize this as a copy of your
( 5 resume that was marked at a ' deposition which you gave 6 before the Kemeny Commission?
7 A I don't remember specifically but I o
8 remember that I did have a resume presented to me 9 as an exhibit at the Kemeny Commission. This could
, 10 be it.
( -
3 11 Q Can you look at it long enough to tell 12 me whether it is an accurate resume through the
( ) 13 period that you were employed by B&W7 14 A It is accurate for the period.
15 Q During the time that you were an
^
16 instructor in the B&W training center, to whom did 17 you report?
18 A I reported initially to Bill Street and 19 then when Bill Street was replaced by Walter Perks, 20 I reported to Walter Perks.
21 Q Were Street and-Perks successive lead 22 instructors?
23 A Yes.
(" 24 Q What, generally, were your
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25 responsibilities as an instructor?
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1 Lind 7 l 2 A Preparation and presentation of a
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3 classroom on simulator instruction. My primary 4 responsibilities as far as specific utilities were 5 Crystal River and I did quite a bit of work with 6
German instructors and operators during that period, 7 so I was lead instructor during that time for
( 8 Crystal River and for the BBC, BBR, RWE Utilities.
9 I also did some work on the simulator during that 10 time as f a-C as helping with simulator upgrades for t
11 models, things like that.
12 Q When you said you were the lead instructor
- 13 for Crystal River, you were not at that point the 14 lead instructor overall, were you?
15 A No, it is terminology. There is a lead 16 instructor that is responsible for superv'ising the 17 activities of a11 the instructors and then each 18 instructor is essentially a'ssigned certain 19 responsibilities, one or more utilities, that he 20 interfaces with directly for the lead instructor,
- ~
21 and then other peripheral tasks, 22 Q When the crews came in from Crystal River, 23 were you the instructor who had principal g- 24 responsibility for their training?
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25 A Yes.
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2 Q Is.the German plant for which you were E
3 responsible for training the Mulheim Kaerlich plant?
4 A MK, 'that's correct.
g 5 . Q You. succeeded Walter Perks as B&W's 6 lead instructor, right?
4 7 A Yes.
1 8
, Q What were your responsibilities as lead 9 instructor?
10 A I was responsible for all scheduling of I
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utilities as far as how to fit them into the weekly 11 1
12 training schedules. I was responsible essentially for L[ 13 the conduct of all instructors. I also did some work 14 in terms of developing proposals and then supervising 15 projects such as development of training manuals' 16 . and things like that for utilities upon t' heir request.
17 I d.id not always directly develop daily. schedules 18 but I approved scheduling of instructors and contents 19 - essentially of all the weekly schedules for each 20 utility. I.was also the-primary interface between J
21 the instructors and' programmers and helped coordinate 22 maintenance'and upgrade periods on the simulator. 'I 23 also later on during my tenure as lead' instructor es 24
- becameinvo{vedwiththe'ATOGprogramand the B&W.
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- 25' swat team, I guess you. call: it, the emergency G
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{) response team.
3 Q Both of those last two activities were
- 4 ones that you engaged in after the Three Mile Island
( 5 accident?
6 A That's post TMI, that's correct.
7 .Q I notice from your resume, GPU 560, that .
I 8 you are a graduate of Boston College. Is it correct 9 that it was not a prerequesite for becoming an
(
10 instructor at B&W that someone have a college degree?
11 A That's correct.
1 12 Q Many of the instructors had not graduated
(( ) 13 from college; is that right?
14 A That's correct.
15 Q Before the Three Mile Island accident,
(
- 16 from where did B&W get most of its traine'rs ?
17 A There were really two principal sources, q 18 . the Navy and operators from utilities. -
19 Q What is your understanding, if any, as 20 to why B&W hired utility control room operators to be 21 trainers?
.22 A Probably really two considerations.
One j 4 ! !
is the fact that they have quite a bit of experience l
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24 which they can bring to the training of other s-1 25 operators. .There is really no-substitute for 1
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f l, 2 hands-on practical experience. he otha one was >
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3 probably just a very practical consideration that '
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4 in order to conduct certain types $f tra'ining at '
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( 5 B&W, we were required by the NRO to hhve eitne.r held j ,;
j-6 or hold a. senior reactor operator's license an6
, s 7 it was probably a lot easier in most cases to go r.
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8 ahead and have someone come. into the training ,
9 department to work who was already ja senior reactor ,
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10 and qualified rather than bring a Navy operator in !
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, t 11 who would then have to be trained and would '
12 essentially be lost as an- inntructor; for .some of the C
13 period of time that he was qualified, where -
14 essentially you had to work with him a little bi t' to 15 build in teaching b st the technical expertiva of' '
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16 several plants is already there. '
17 Q Tho' trainers that you got from utilities' i <
( 18 had alreacly had iraining as' operators. both at the 19 utilities and from the vendors?, i 20- _A Yes. ,
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~i 21 ,Q Were the utility operators that were
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22 hired as B&W traine! rs people who.came from plants.
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'y While you were w 4 lh', the B&W training.; - .; i,,fs ?
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/ o department, were there any B&W trainers who had been *
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4 Three Mile Island plant?
~5 A Walter Perks , and Ted Book.
. - 6 Q Coming from Met Ed, were they as well
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, . 7 prepared to be B&W trainers as training personnel 1,
'b 8 whom B&W had hired from other utilities?
,[ g A I am trying to remember. I believe that i
10 they were the only two. I don't think we had anybody ( , t
, #i 11 from -- no, Harry.
- They were qualified, yes.
,A 'd 12 Q Prior to the Three Mile Island accident,
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( ~13 you not only* administered simulator training but as . $ . J' / 14 lead instructor, you were responsible for
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15 coordinating simulator training; is that correct? O ' I
. 16 A That's right. '
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Operators who came to Lynchburg for the
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- 18 training, right? -
F 19 A For the simulator training, yes, s- ./ - 20 Q And, essentially, they would go into the
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simulated control room and operate the console i
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L l') i' 22 during simulated nuclear plant casualties; is that ' i% d'h > r'
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25 y l Q Were reactor trips a casualty that was
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shown on the simulator? 3 A Yes. 4 Q When the operators were trained on a ( 5 casualty such as a reactor trip, were they working 6 with the procedures that were in effect currently 7 at their own home plants? ( 8 A Yes. 9 MR. SELTZER: I would like to mark as 10 GPU Exhibit 561, the Three Mile Island (' 1 11 Unit 2 reactor trip ' procedure. I't is the 12 revision dated October 25, 1978. ( 13 (Three Mile Island Unit 2 reactor 14 trip procedure, revision dated October 25, 15 1978, was marked as GPU Exhibit 561 for 16 identification, as of this date.) ' 17 Q You had worked with training of
, 18 operators on reactor trips, right?
( - 19' A Yes. .. 20 Q Is GPU 561 typical of the reactor trip 21 procedures that were being used for 177 fuel assembly 22 plants before the accident? l 23 MR. WISE:
, I am going to object to s 24 that question on the grounds that I don't see 25 how showing this witness this procedure and ve - -
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, 13 2 never even asking him whether he has read it 3 before this morning, without showing him the 4 other procedures that were in use at other g 5 utilities, is going to be at all helpful or 4
6 relevant. 7 Q Take a moment if you would like to 8 review it. 9 MR. WISE: Have you ever seen this 10 procedure before today? ( l 11 THE WITNESS: Yes. It has been & number 12 of years but I can say that I have seen (( } 13 probably all the reactor trip pro'cedures for 14 4 all the B&W units at one time or other. 15 MR. WISE: I am going to continue my ( , 16 objection on the grounds that I dont know 17 what is meant by " typical" and I don't know 18 ( what kind of comparison you are'asking him i 19 to make, whether you are asking him is it 20 identical. 21 Q Does the form and content of GPU 561 22 appear, to the best of your recollection, to be 23 similar to-the form and content of reactor trip
- -] 24 procedures.that were in effect for 177 plants prior
- v' 25 .to the accident?
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( 1 Lind 14 2 MR. WISE: I am going to continue my C 3 objection on the basis that I don't know what 4 you mean by "similar." . g 5 Q You may answer the question. 6 A The general arrangements of these 7 procedures is standard, As to whether or not each I 8 specific instruction here is the same.as each 9 specific step in all the utility procedures, I can't 10 answer that as a "yes" but the general format and ( '- 11 layout as far as symptoms, immediate actions, manual 12 actions, that is a standard layout for a B&W ( 13 plant, emergency
- procedure.
1 14 Q During the time that you were instructor 15 and lead instructor at B&W, were you aware that B&W (
- 16 had supplied draft procedures for the owners of its 17 nuclear plants?
( 18 A Yes. -' 19 Q Was training on reactor trips a 20 frequently employed casualty during simulator 21 training? 22 A We would normally generate a few reactor 23 . trips, just straight reactor trips, as training. The m majority. of the training on trips came.as a result 24 V 25 of other problems inserted into the machine so that
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( 1 Lind 15 l 2 there might be a number of trips during the week. ( 3 very few of them would be just a plain symptom trip 4 initiated by the instructor, but yes, we did training ( 5 on, specifically, reactor trips. Very little in 6 requalification. Doing a straight trip would be mere 2 7 likely the type of training you would do for I 8 licensed candidates. 9 Q What immediate effects does a reactor 10 trip have on the reactor coolant system in a B&W ( t 11 reactor? 12 A Assuming that it is just a manual (( , 13 initiated trip when the plant is operating in a - 14 steady state condition, the major impact,on the 15 primary system is a reduction in reactor coolant ( , 16 system temperature and also a reduction In reactor 17 coolant system pressure and pressurizer.-level and ( 18 reactor power. 19 Q In the design of B&W reactors--there was
- 20 a high pressure reactor trip setpoint; is that i,
21 right? 22 A Yes. I 23 Q What would be the subsequent response of the reactor coolant system following a reactor trip r3 24 ( U L 25 on high pressure?
.(
1 Lind 16 i
/~' 2 MR. WISE: What are you positing !
( 3 initiated the high pressure condition or does t 4 that make any difference to your question? ( 5 Q Is there an initial period of time 4 6 following an automatic reactor trip on high pressure 7 when there are certain expected follow-on responses ( 8 that exist irrespective of the initiated condition? 9 A A response is going to be genera ~lly 10 similar, independent of the event, based on the ( 1 11 initiating action that causes a trip. We are really 12 talking about magnitude and duration of changes. ( 13 Trends are assentially going to be the same.
)
14 Temperature -- what you will normally come-down to 15 after a trip, how.far it comes down, how fast it ( , 16 comes down can vary depending on the initiating
-17 event. Pressure is expected to come down. How fast
( 18 it comes down, how far it comes down depends to a 19 large extent'again on the initia' ting action. 20 Q Pressurizer level also comes down? 21 A Yes, it routinely would, and again 9 22 qualified by initiating events, how fast, how far. . 23 Q You mean depending on,the initiating 3 24 event, it-might come down faster or it might come
\.)
25 down farther, but it would -- ____.r v.- --
( 1 Lind 17 l ' I'N 2 A Initially come down, yes. (b 3 MR. WISE: I assume that you meant not 4 only chat it might come down faster or farther g 5 but it might come down slower and less. You 6 are not just trying to trap him in one 7 direction. ( 8 MR. SELTZER: Well, it always goes down 9 after a reactor trip. 10 A ( It could be faster or slower. It could 11 come down f urthe r or less. 12 Q 7 Is the system response following a reactor (( ) 13 trip sometimes referred to as a cooldown? 14 A Well, it is a cooldown. It was normally 15 not -- the term "cooldown" normally applies to a ( 16 different evolution than that occurring a'fter a trip. 17 Q What happens to the reactor coolant t 18 inventory, in other words, the mass of water in the ~ 19 reactor coolant system when there is the cooldown 20 following a reactor trip? 21 A The final effect is that the mass in the 22 system will be increased as the system cools and l l 23 contracts and the system drops below its normal rx 24 pressurizer level setpoint. The control system will 25 inject water automatically in an attempt to hold
i l ( i 1 1 Lind 18 l 1 2 the level up so that in fact there is more mass in 3 the system following a trip than there is prior to 4 the trip, unless, of course, the trip was initiated g 5 by something like a leak, but if we are talking 6 about no breach of a system boundary, either a 7 relief lifting or a system leak, the mass starts I 8 increasing as soon as it trips because of the action 9 of the makeup system. 10 Q Initially, you said there is a contracting 11 of the water in the reactor coolant system. That 12 contracting causes pressurizer water level to drop; (( 13 is that right? 14 A Yes. 15 Q Following a reactor trip, were the s , 16 operators trained to initiate high pressure injection-17 or start the makeup pumps? ( 1,8 MR. WISE: Which is the questi~on? You 19 asked two. - 20 MR. SELTZER: Initiate high pressure 21 injection, f 22 A They were not trained specifically to 23 initiate high pressure. injection. Were~they trained to manually initiate 24 Q. d 25 'the makeup' pumps? y y , ~ n, - .-- -e . . . . y w --
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( 1 Lind 19 2 A Depending upon the utility, they were ( 3 normally trained to either open a valve to allow 4 a better flow path into the system to deliver more ( 5 water or in the case of some utilities to start an 6 additional pump and open an additional flow path into 7 the system. ( ' 8 Q From GPU 561, which is the Three Mile 9 Island Unit 2 reactor trip procedure, what was the 10 train'ing instruction that was given to Three Mile 11 Island operators? 12 MR. WISE: I am going to object to (() 13 that unless you establish that Mr. Lind was 14 involved in the training of those operators. . 15 s We can all sit here and read this procedure , 16 and draw whatever conclusions we wish from 17 reading it but I don't think you hav,e
- 18 established that he personally had ahy knowledge 19 of the training that was given to'thi TMI people 20 on how to use this particular procedure. If you 21 want to lay a foundation for that, that's fin.e.
22 MR. SELTZER: I will take my chances. 1 23 Q Do you remember the question?
~
24 A. Would you repeat the question?
%J 25
-(Record read.)
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( 1 Lind 20 [ 2 A I can't give you a detailed answer on ( ' 3 that. The training instruction was to follow the 4 procedure. ( 5 Q What does the Three Mile Island Unit 2 , 6 procedure describe? . 7 MR. WISE: Are you asking him now to* C 8 read this thing? 9 MR. SELTZER: Read it to refresh his 10 recollection, since he said he had seen it 11 when he was an instructor at B&W, and then 12 answer it. (( } 13 A The instruction says to start a second 14 makeup pump and open MUV-16B as necessary to 15 maintain 100 inches in the pressurizer. . 16 Q So the Met Ed operators were instructed 17 both to start a second makeup pump and to open the ( 18 valve to admit additional water into the reactor 19 coolant system? .. 20 MR. WISE: I object again. 21 MR. SELTZER: All right, your objection 22 is noted. 23
>. MR. WISE: You are continuing to f"s 24 O mischaracterize his testimony and I continue. -
25 my objection based on a lack of foundation as I -
( 1 Lind 21 ( 2 to whether Mr. Lind was involved in the 3 instruction of any of the TMI operators. 4 I object to the question on the grounds of (_ 5 form and cubstance. 6 Q You may answer the question. 7 A Per the procedure, that's true. ( 8 Q You referred to the MUV-16B valve. 9 That is a valve on the high pressure injection system,
,. 10 right?
t
- 11 A I believe so. It's been a kong time but i -
l 12 I think that is'an injection valve, yes. ' L() 13 MR. WISE: Well, do you know or don't 14 you? l 15 TEE WITNESS: No, I don't know. I don't
- e 16 remember specifically.
17 Q In the Three Mile Island plant, based on 18 your recollection, was it your understanding that 19 . the makeup pumps at Three. Mile Island Unit'2 were the 20 aame pumps which operated as high pressure injection . 21 pumps? 22 A' That's correct. 23 -Q So when the. instruction says to start 24 'second makeup pump, the operators were being directed 25 to start' manually a. pump which is the same' pump as
( 1 Lind 22
- (') 2 the high pressure injection pump? .
(V A That's true. 3 4 Q What was your understanding before the ( 5 Three Mile Island accident as to why it was important 6 for'the operators to maintain pressurizer level 7 following a reactor trip? 8 A The pressurizer and its associated 9 auxiliaries are the mechanisc normally used to 10 maintain reactor coolant system pressure, to maintain {. t 11 the system subcooled, and in order to dIo that, a 12 certain water inventory has to be retained in the L(} 13 pressurizer, and also, the operation of the 14 auxiliary systems associated with the pressurizer 15 itself have to be continued and this includes the 16 operation of the heaters, so that maintenance o f-17 adequate level in the pressurizer was required so 18 that the inherent pressure maintaining characteristics 19 of the pressurizer could be continued and.so that 20 the heaters could in fact come on if required. 21 Q At what level in the pressurizer did 22 the heaters begin to uncover? 23 MR. WISE: s.t all B&W plants, or
, -N., 24 Three Mile Island, or which one? -
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25 Q Do you know at what level they would
( 1 Lind 23 ( 2 begin to uncover at the Three Mile Island Unit 27 t 3 A I can't recall a specific number where 4 you actually would in fact begin to uncover the ( 5 heaters. ' 6 Q Do you recall at what level the heaters 7 had an automatic shutoff? C . 8 A 80 inches. 9 Q With an automatic shutoff of the heaters i
, 10 at 80 inches, it was important for the operators 11
. to maintain a pressurizer level above 80 inches, 12 is that right, or above 80 inches by some discrete C() 13 margin? ^ 14 A If you wanted the heaters ~available, you 15' ~ had to maintain the level above 80 inches or if it , 16 fell below 80 to restore the heaters. 17 Q And it was part of B&W's-ins'truction to 18 maintain a pressurizer level i above the heiters' 19 shutoff point; isn't that right? 20 A Yes. 21 Q Following a reactor trip, there# 7, the 22 operators were trained to initiate the 3 s of i
.1 23 water into the reactor coolant system to n ir")
b 24 pressurizer level in order _to keep the heatel- in. . 25 operation? 4 , - . , . -a- . - ,w-.,,,.,sv - . - , - . - . , . . , ,
l 1 Lind 24 ('N 2 .MR. WISE: I object. That is not what [b 3 he said before. You are mischaracterizing his l L 4 testimony. You are now excluding the 5 integrated control system? 6 Q You can answer the question.
- 7. A The general training would be consistent
( 8 with the instruction, which is an as-necessary 9 instruction. If it was required to inject additional 10 F water to maintain the pressurizer water above the s 11 heater cutoff, the operators would do that per 12 the operator instruction. If the transient was such
; 13 that the level didn't appear to be falling rapidly 14 enough or far enough to get into a situation where the 15 heaters might be uncovered, the operators probably 16 would not add additional water.
- 17 Q' Is it also your recollection of the 18 training before the accident that there was a 19 pressurizer water level at which operators.were 20 trained to start a third injection pump?
21 A I don't specifically recall a lot of 22 mention about another level where an additional ' l 23 pump would be started, i 24 O Q Would you take a look at GPU Exhibit 561, ' V 25 manual action 2.2-1.
l l ( 1 Lind 25 2 Does that refresh your recollection that ( 3 at least for Three Mile Island Unit 2, the procedure 4 that you were familiar with before the accident 5, instructed the TMI-2 operators to start a third pump 6 and open an additional HPI valve in order to increase 7 pressurizer level? I 8 MR. WISE: I am going to object again. 9 A The instruction calls for that action 10 to be taken. J ... 11 After the operators had manually initiated Q 12 the injection of additional water into the reactor 13 coolant system, what was the training on when they 14 should throttle or terminate the addition of water? 1 15 A Well, the training.would be consistent 16 with the procedure which says maintain 100' inches. 17 Q '. other words, when the water level was 18 restored to 100 inches in the pressurizer,'they would 19 throttle or terminate high pressure injection? 20 MR. WISE: Why don't-you read through 21 the procedure, if you -wish, if that is what you 22 are basing your answer on. 23 THE WITNESS: Yes. Let me see if there 24 is anything else here. .
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25 A Well, based on the instruction, assuming L - j
( ! 1 Lind 26 2 that the level had in fact gone below 100 inches 3 at sometime during the transient and the operators 4 had followed the procedure and put in additional g 5 water per this instruction, yes, once they got to 6 100 inches they would begin to, per thi's 7 instruction, close down on MUV-16B to maintain f 8 100 inches. 9 Q Close down on MUV-16B means reduce the 10 a flow of water into the reactor coolant, system? 11 A Through that valve, yes. 12 Q Why were the operators trained to 13 throttle back on the additional water going in? 1'4 A Generally, for any of these utilities F 15 or any plant, addition of water beyond 100 inches 16 following the trip is water that would just have'to
^
17 be subsequently removed from the system and stored 18 and processed, so that getting back to 100 inches 19 was important in terms of guaranteeing correct-20 operation of' pressurizer but that.more water than 21 that essentially didn't enhance the operation'of the 22 pressurizer and in fact was mass that.just would 23 subsequently haveoto be removed from the system and 24 7- possibly be ocessed'later on. V 25
.Q :Is it correct that following a reactor e
I c 1 Lind 27 2 trip, the operators were trained to look at ( 3 pressurizer water level first to determine whether 4 they needed to initiate additional flow of water g 5 into the system? , 6 Let me delete the word "first" from 7 that, but is it correct that on a reactor trip
;I 8 the operators were trained to look at the pressurizer
~
9 water level to determine whether it was necessary 10 to add additional water to the reactor coolant C . e 11 system to maintain pressurizer level? 12 MR. WISE: As the only thing they
. 13 were supposed to look at?
14 MR. SELTZER: No, not the only thing. 15 A That's true. 16 Q And were the operators also trained to 17 look at pressurizer water level to determine when 18 they had reached the appropriate level for throttling 19 or terminating high pressure injection? .. 20 MR. WISE: As the only basis for 21 terminating it? 22 MR. SELTZER: Yes. 23 l A Per this procedure,-no, because there I 24 is also instruction regarding monitoring of system - l 25 pressure prior to a follow-up action regarding
.t i 1 Lind 28
(} 2 control of pressurizer level, so that per this - ! 3 procedure, the initial control of the additional 4 water to the system was based on level and ( 5 reestablishment of level but further along in the 6 procedure there is also a mention of returning the 7 system to normal operating pressure before there
'(
8 are some final statements made concerning control of 9 the level. Again, this is from the procedure. I I 10 Q what you are looking at regarding 11 pressure is in the follow-up action section? 12 A That's correct. L 13
.Q That section is after the manual action 14 section, right?
15 A That's correct. l 16 ' Q The manual action section is also 17 sometimes referred to as the immediate action 18 section? ' 19 A That's correct. ~ 20 Q _ Earlier, you said that' instruction 2.2-e 21 told the operators to open the MUV-16B valve as 22 necessary to maintain 100 inches, 'and you said that 23 the operator would understand that as an instruction 24 to throttle back'on HPI once 100 inches had been ' 25 restored: is'that right?
l 1 Lind 29
~
2 MR. WISE: I don't think that is what C V 3 he testified to. The last time around I think 4 you showed him the procedure and we were all i g 5 sitting here and saw Mr. Lind turn the page 6 to the follow-up action at the time you asked 7 him about throttling and I very clearly saw I 8 him reading from the follow- up action. - 9 MR. SELTZER: But then he testified, I 10 believe, as I just stated, isn't that right, C ( . 11 with respect to immediate and manual action? 12 MR. WISE:
- I think it is unclear now. I
'( , 13 think you better clarify the record one way 14 . or the other.
15 MR. SELTZER: Do you remember the ~i+ ' 16 question? , 17 THE WITNESS: I don't remember the 18 original question concerning specihicallythe 19 exact wording of the question. - 20 MR. WISE: He is asking -- 21 MR. SELTZER: I will ask the question. 22 Q Isn't it correct that as an immediate , 23 manual action, the operators would initiate ! 24 additional flow into the reactor coolant system and '
. 25 i
then terminate additional flow into the reactor
l 1 Lind 30 2 coolant system as necessary to maintain the 100 ' ['dD ( x_) 3 inches level into the pressurizer? 4 MR. WISE: I object to that. We have ( 5 been over this and he gave you very clear 6 testimony and you are now changing it in an 7 attempt to seek a different answer than you ( 8 got the first time. 9 MR. SELTZER: I think if we went back I 10 we would see what it says, but you know this 11 is a perfectly proper way to proceed. 12 MR. WISE: I would be happy to leave the
, 13 record the way it is but I don't want you to
}
14 put words in his mouth that he didn't say. If 15 you want to ask him where in here he finds 16 the part that involves throttling $PI or m'akeup 17 pumps, I would be perfectly happy-to have you 18
- ask that question rather-than attempt to do it 19 in a backhand manner in a convoluted question.
20 Why don't you ask him in a straightforward 21 question. That would clear the question up. 22 MR. SELTZER: Can you go back and read my 23 question. _fs 24 (Question read.) N] [ 25 A I would say that is correct but I don't nn ,- m
I
.(
1 Lind 31 (') g%/ 2 especially like the word " terminate." I would prefer 3 the word " throttle" or " control." 4 Q Throttle means reduce as necessary? 5 A Reduce if necessary, yes. 6 Q The pressurizer heaters are used to 7 control pressure in the reactor coolant system; E 8 isn't that right? 9 A They are one of the pressure controlling ' 10 mechanisms, yes, f k . 11 Q .If the pressurizer level fe'11 below 12 80 inches, the heaters would automatically be shut
', 13 off? e 14 A Y e's .
15 Q If that happened in a cooldown following 16 a reactor trip, there would be a further reduction 17 in pressure as a result of the loss of the heaters, 18 right? - 19 A The heaters' influence during..the initial 20 temperature decrease, system contraction pressure 21 reduction is minimal, very little effect. Their 22 main influence would be on the restoration of the 23 system pressure back to normal level. 24 Q If level had fallen below the heaters' O
. 25 cutoff point, _ how would pressure be restored?
g - - - -e, , - - , - - - . < , , - - - -o
l l 1 Lind 32
- ~
( (s). 2 A You are assuming that the level is not 3 brought back up above the heaters? If the level 4 falls below the heater setpoint, you would bring ( 5 the level back up above the heater cutoff and 6 energite the heaters. 7 Q And do you also use pressurizer spray ( 8 to restore pressure? 9 A No. There will be some restoration of 10 the system pressure jurt due to reestablishment of 11 the level. In other words, as you begin to refill 12 the pressurizer, the inherent characteristics of 1( ) 13 the pressurizer, independent of the heaters, would 14 help restore the pressure. 15 Q When I was asking you earlier about 16 the di~f f e rent types of casualties on which operators 17 were trained, you said that sometimes reactor trips 18 would occur in conjunction with other cashalties; 19 is that right? " 20 A That's correct. 21 Q For some of the casualties involving 22 reactor trips, if the operators failed to act quickly 23 !' enough to start the additional supply of water to the (')
-V 24 reactor coolant system manually, would there be an 25 automatic actuation of high pressure injection?
e
( 1 Lind 33 2 A For certain transients, yes. 3 Q Are those sometimes called overcooling 4 events? ( 5 A Yes. 6 Q What types of transients were operators 7 trained.on before the Three Mile Island catastrophe ( 0 that produced overcooling? l 9 A It is two basic categories. One would be ( 10 excessive steam relief or steam leax, which would 11 . tend to cool the system down, or an excessive amount 12 of plant water for the plant conditions , which would 13 tend to cool the system down further than normal.
~
14 Q -When you talk of a steam leak, that is 15 a secondary side breach in the steam pipes; is that, 16 right? l 17 A Either a breach or a malfunction or a 0 18-failure or an incorrect reseating of a steam relief , 19 valve. It would not necessarily have to be a 20 physical breach in the piping. It could be a valve 21 malfunction. I 22 Q It is the secondary, side,.not the primary 5 i 23 ' side'that is leaking or open; is that right? ( 24 3' 'That's correct. 25' Q once high pressure injection had e
. -. .. . .= . . - . . . . . . ..
( 1 Lind 34 (~'j 2 automatically actuated during an overcooling event,
. (V' .
3 the operators would have to throttle back on high 4 pressure injection eventually; ' is that right? g 5 A once the overcooling accident had 6 terminated, there would eventually come a time after i 7 the termination of the overcooling where high ( 8 pressure injection would have to be throttled. 9 Q An overcooling transient -is not a loss-10 of-coolant accident; is it? 1 ( t 11 A No. i 12 ,g so there'is no loss of water from the ( 13 reactor coolant system during a casualty that is 14 just an overcooling event? 15 A That's correct. e 16- Q As with the cooling down foll'owing a 1 17 reactor trip, the overcooling event produces a 18 ( contraction in the' water that is in the reactor . 19 coolant system? - i 20 ,A Yes. 121 Q And that contraction produces, among 22 .other things, a drop in pressurizer water level? 23 A' Yes.
-k 24' Q .Following overcooling events, were the ~
s/ 25 ~ operators trained'before the Three Mile Island (: _-
- -- - . . . , _ I - _ _ , , , . _ , - - - . . - .. . - - . . . _ . , - , . . . , , _ . . _ . . . _ ~ . . . . . . . . . . - -
f 1 Lind 35 () 2 accident to throttle high pressure injection based 3 on pressurizer water level? 4 A You are asking if level was the only C 5 thing that they based their throttling actions on, 6 no, but that was one of the indicators at which 7 they would base their determination on whether or ( 8 not to begin to throttle high pressure injection. 9 Q It is correct, isn't it, that before the 10 Three Mile Island accident, there was training on ( 11 the simulator for how to deal with steam line breaks? 12 A Yes. () 13 Q You told operators that in a cash like 14 that, they should terminate the high pressure 15 injection before taking the pressurizer solid; isn't 16 that true? 17 A That would be one of the considerations ( 18 for timely termination of high pressure injection. 19 Q You said that in an overcoolin~g event 20 there was no loss of water from the reactor coolant 21 system. Was the training of operators in terms of 22 what level to restore and maintain in the pressurizer 23 the same as it had been for the reactor trip? 24 MR. WISE: Could I have that reread. (
~
25 (Question read.) 9
( 1 Lind 36 ( (') 2 A I can't remember a specific number in 3 terms of level to be checked. Training was such 4 that level before termination of high pressure ( 5 injection, of throttling, that you would want the 6 level back up at least to the 100-inch point again, I recovering the heaters, but as far as a specific ( 8 number for termination of the HPI, I don't recall 9 a specific number being utilized but at a minimum 10 I am confident that instructions were to at least i 11 get the level back to a point where the heaters will 12 recover. (( } 13 Q without recalling a specific number, is 1'4 it correct that the training was that there w a's some 15 ( level within the pressurizer that the operators were 16 instructed to restore and maintain following an
,~
17 overcooling? ( 18 A It would require restoration 6f level on 19 the operating range before termination, ye's. 20 Q In an overcooling event such as caused s 21 by a major steam line break, there would be a 22 greater contraction of a reactor coolant system than 23
' in the normal cooldown following a reactor: trip;
.- 24 isn't that true? .
25 A yes, 1
~
1 ( 1 Lind 37 2 Q That would'cause a greater drop in 1 3 pressurizer water level, right? 4 A Yes. g 5 Q As a result, in the system recovery 6 from an overcooling event, there would be more water 7 that would have to be restored to the pressurizer I 8 than there would have to be to restore level in a 9 cooldown; isn't that right? 10 A That's not a question that could be 11 answered yes or no, specifically. 12 Q If the contraction is greater in an ( 13 overcooling event than in a normal cooldown, more 14 water is going to be sucked out of the pressurizer at 15 the start of the transient; right? ( , 16 A Yes. 17 Q Doesn't it follow that in the 18 ( restoration of pressurizer level after th&t initial 19 contraction, there is going to have to beucre water t 2 40 pushed back into the pressurizer to recover from an 21 overcooling event than has to be pushed back into the 22 pressurizer to recover from a normal reactor trip 23 cooldown? _ ,q ' 24 ' A. No. e
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25 Q Why not? s
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2 A. Becsuse if ycr,haire an overcooling event (Q . , and you l'e t.i the plant.' restore to the pc,at trip T - 7.v , 3 4 the level is 'goinry to go back to the sams Fiace,,, - I haven't been as clear-as I should have f 5 Q 9
# V, # # '
6 been. I am not saying that: you h'aveit'o. add more ,, !' 7 high pressure injection or makeur . water to .'the' systeng , -f 8 and I think that was the impresr. ion.that'Iiwas-giving_ 9 you. t: [< , Theres is a surge lin a ' 3t.t 3c hed.. tot :he bo ttom - ' 10 of the pressurizer, right?- ( .i ,1 gv .-, ; s-11 A Yes. h / "
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12 Q' Jhe' surge line : s ' connected tb fone of the
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14_ A Yes.
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reactor coolant' system, the contractilon has tih'e . _ j , . , 8 - . 2' 2 j t',, 17 ef f act- cf evacuating witer from the press :-4Eizqr s
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';through the surge line into :the, hut feg, iti gh t ?, -
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- - s 19 A Yes.
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f W O F q + 21 takenfout of the pressurizar thro'fgh..the! surge,line " y 22 into: the hot, leg than in a ~r.orthlebooldown transient; _, < > :) n . .c s /, O, - 23 ., 'right? r '" r r y< ; ~. *; ;, -
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f :[ 7 2 more water has to flow back through the surge line
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i*t 3 into the pressurizer to recover pressurizer water ll ~ p& < n ~ e
, f4 level than has to flow back to the surge line
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', . e and into the pressurizer to recover from a normal 79
, > P'T 6 cooldown following a reactor trip; isn't that right?
e 7 . A You are still talking about restoration
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[ n{f m 9[ y a function of the temperature that the system is at i< , ( o, f "10 8 at the time you restore the level, so that no matter t it U , { ' 1!}/j s 11
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Wi how far the system contracts, if you now let the
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, 13 . independent of how far you cool down. The level is
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- j Me 15 temperature restore. If you are attempting to tj~, ; ~y.
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16 restore the level at a lower temperature, .in other t .i ? m
; - ,17 words, if you stabilize the temperature'1,ess than the
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s./ ( 18 ,y As y h ' post trip T-Av, then you have to have mor'e water come y Ig7 19 back into the pressurizer to restnre it because each ~ p,' '
#~- 20
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< pound mass of-water takes less room so more pounds
~ *" 21 mass have to flow back into the pressurizer to bring
..~
22 the level back to the same indicated point. It is 23 not just a-mass addition.
.. It is very much dependent S 24 on the temperature at which you are attempting to
.(V
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25 -restore 100 inches of level.
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( i 1 Lind 40
/
2 Q Water has some amount of compressability s c 3 that is a function of temperature and pressure, 4 right? ( 5 A Yes. 6 Q I am not talking about that 7 compressability of water. I am looking at a grosser ( ' 8 phenomenon and I am asking you, if more water has 9 left the pressurizer, in a gross sense, in an
, 10 overcooling event than leaves in a
( coogdown accident 11 does more water have to come back into the pressurizer 12 in the recovery? (( ) 13 A Oh, that, right; if you go'10' inches 14 below cutoff or 20 inches below cutoff, obviously 15 C in the 20-inch case more water has to come back in, 16 yes. . 17 Q so in an overcooling event,"more water has to ( 18 flow back into the pressurizer during the' recovery 19 of pressurizer level than has to flow back in in ~ 20 the recovery from a cooldown following a reactor 21 trip? 22 A Yes. I think the use of the word ! 23 "added" clouded that discussion comewhat. (~} 24 )Ut. WISE I don't think the word
~
v 25 " flow" helps very much either. I think 1
1 Lind 41 2 . Mr. Lind has very effectively described the 3 effects of water on temperature and pressure. J 4 I think that may be adding to the difficulty. 4 g 5 ~(Recess taken.) 6 Q Water in the pressurizer is normally . , 7 maintaihed hotter than the water in the rest of the I 8 reactor coolant system, right: 9 A Yes. 10 Q There is a-differential about a hundred 11 degrees normally between T-Av temperature in the 12 reactor coolant system and the pressurizer temperature? C( ) 13 A 70 degrees approximately. 14 Q When the pressurizer refills following 15 an overcooling event, it is refilling with the (- 16 relatively colder water from the reactor ' coolant 17 ' system, right? (' 18 A ,y.., . 19- Q The more severe the overcooling, the-20 more water that is going to have to go back-into the 4 21 pressurizer from the reactor coolant system to 22 restore pressurizer level, right? 23 A .Yes. g 24 Q The more-of the relatively colder water fY N. 25
;that'goes back.into the pressurizer, the-longer it
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- 1. Lind 42 2 is going to take for the pressurizer heaters to 3 restore reactor coolant system normal pressure; is 4 that correct?
.-( ,
5 A Yes. 6 Q On a recovery from an overcooling event, 7 the operators are going to reach the point of r 8 normal pressurizer level before they have restor'ed 9 normal reactor coolant system pressure; isn't that 10 true? t_ s. 11 A That's a little more -- that's a little 12 more complicated question to answer than with a yes (( ) 13 or no answer. 14 Q Why don't you explain what the answer is? 15 A As you refill with the cooler water, you
, (
^ .
16 are in fact compressing the steam bubble above the 17 water space and you can, if you are bringing water (- 18 back into the pressurizer fast enough, ree'stablish 19 normal-system pressure even though the actual water 20 space below it is. cooler, and a lot of that would be !4
-s 21 a function of rate, so the initial restoration of i 22 the pressure would be largely a function of the rate 23 at'which the water is flowing back into the grN: 24 pressurizer. Then the stabilization of that pressure. -
> -\
)
25 would become a function of the heaters heating the
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2 ( water up so that it was essentially the same 3 temperature as the steam space above it. 4 Q Wouldn't the operators have to fill the ( 5 pressurizer close to solid with water in order to 6 restore pressure jt st by using pressurizer level? 7 A No. Well, I will ask you a question. ( 8 4 What do you mean by "nearly solid"? 9 Q Substantially above normal pressurizer 10 operating level, t 11 MR. WISE: What is "substantially"? 12 I don't think you have helped him. Do you
!() 13 want to give him a number?
14 MR. SELTZER: Let me withdraw that. 15 C Q When level is coming back in the e 16 pressurizer following a severe overcooling event, the 17 operators were trained to throttle high pressure
; 18 injection based on a restoration of pressurizer .
19 level; isn't that true? 20 MR. WISE: It has been asked and answered 21 and you have mischaracterized his testimony, 22 but I will let him answer it again. Level is 23 one of the considerations for throttling the (~h 24
\! HPI following an overcooling accident.
25 Q Given the fact that they have got.a lot
, ~ e , , - a
1 Lind 44 1s (). 2 of cooler water in the pressurizer following an 3 overcooling event, what, if anything, is your 4 recollection of the training before the accident t
; 5 regarding whether operators were explicitly
- 6 instructed to wait for reactor coolant system 7 pressure to be restored to its normal range before 8
- they throttled high pressure injection?
9 A i Generally, instructions regarding 10 e pressure were characterized more by pressure 11 behavior rather than a specific number, so that 12 indications of control of pressure were utilized
~( )
. 13 more than a specific number for' making a specific
~ 14 determination of throttling HPI.
15 Q In other words, pressure did not have to 16 be back to_its normal level before the operators 17 throttled high pressure injection in an oyercooling 18 event; isn't that-what you are saying? 19 A .. That's correct. . 20 Q What did you mean by " control of: pressure 21 level"? 22 MR. SELTZER: Read back the next to the-
. 23
'. last answer. , jr' ' _ 24 (Record _ read.) . 25 -A Control in.that case would. indicate that 2
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1 Lind 45 2 the operator had the ability to control.the pressure 3 rather than the pressure was basically behaving as 4 a function of what was being done in the system due 5 to the accident. 6 Q You testified a moment ago that in the i 7 recovery from a major overcooling event, yo'u would 8 tell the operators to terminate high pressure 9 injection before they take the pressurizer solid. 10 What was that instruction given? t 11 A Filling the pressurizer solid is not a 12 desired condition for operation of the plant.
. 13 Why is it not desired?
Q - 14 A Well, there are a number of 15 considerations. It depends on the temperature / 16 pressure relationships of the plant at the time 17 that you go solid, like the higher temperatures, one
.; 18 of the major problems would be essentially a breach 19 of the system integrity by lifting the pilot operated 20 relief valves or the pressurizer safety valves 21 which would then relieve coolant directly to the 22 containment. One should be in a dropped coolant 23 temperatures operating the system at high pressure 24 S_ combined with low reactor coolant system temperature ~
( (f 25
. begins to approach problems of overstressing piping 9
.c
-1 Lind 46
{ ) 2 and reactor coolant system pumps in addition to the ( 3 breaching of integrity to the system. 4 Q Was there also a concern 'aefore the
- (_ 5 accident that if the pre _ssurizer went solid, the 6 operators would lose one means of pressure control?
7 A It becomes very difficult to control 8 system pressure when the system has taken fill. 9 Q Was that another reason why the
. 10 operators were instructed not to let the pressurizer 11 go solid? -
12 A That's another consideration for not going 5( ) 13 solid, yes. , 14 Q 'While you were an instructor at B&W, did 15 B&W give exams to the plant operators who came for 16 training? 17 A Yes. 18 Q What did you understand was the purpose 19 of administering those exams? 20 A some of the exams that were given were 21 actually part of the licensing process; the start-up 22 certification exams were a required portion of the 23 actual testing to qualify a person for his license.
./ ) 24 In addition to the start-up certification, we also -
, QJ; 25 did audit testing or certification testing for 4
- um - ,. 7 , , - - . - . , . - - , < r , - , . e-- - -
1 Lind 47 2 candidates for cold licenses. 3 Q By " audit testing," you would check i 4 whether they had gained sufficient knowledge to be
; 5 prepared for NRC licensing?
6 A Yes. l 7 Q Did B&W grade the exams that B&W I 8 administered? 9 A Yes. 10 Q Did you sometimes do grading as an t 11 instructor or lead instructor? 3 12 A I conducted certification exams. I can't +
,( } 13 specifically remember grading any cold license 14 examinations. We would'also conduct examinations; 15 if we gave classes, different types of training at 6
16 utilities, one might just give examination's as a check. 17 I did grade exams like that. - 18 Q I would like to show you a B&f training 19 center in L*/n chburg , Virginia plant operations exam, 20 which I w'.11 mark as GPU Exhibit 562, and ask you if 21 you recognize.this as being the format in which 22 exams were being administered.by B&W while you were 23 .an instructor. 24 (Document entitled " Babcock & Wilcox, -
-O\
25 - Nuclear Training Center, - Lynchburg, Virginia, i. 1
, _ , , , , , - ,, w,n - - , - - - - - - , -~n , . -
I-1 Lind 48 l 2 Plant Operations Exam" was marked as GPU 3 Exhibit 562 for identification, as of this 4 date.)
-5 (Question read.)
6 A This would be a format for an exam we 7 might give, yes, 8 Q Take a look at question 9, please. 9 A O. K. 10 Q Question.9 in this B&W exam asks, " What 11 are the immediate actions on a reactor trip?" 12 Was an operator in answering that i 13 question expected to describe what appeared as the 14 manual actions in GPU Exhibit 5617 4 . 15 A l Discussion of the manual actions would be 16 ' part of the answer expected on that question. - 17 Q Including both the initiation and 18 r, throttling of high pressure injection based on 19 pressurizer-level? - 20 A A complete answer ~would include listing
.21 a through j, which would be considered a complete 22 answer.
23 Q EBy."a-through j," you mean subparagraphs (~ . 24
.a through j of section.2.2 of GPU^ Exhibit 561?
~
%_/
25 A That's correct.
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i ' 1 Lind 49
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2 ' , (v_)/ Q Would you take a look at question 6 in r 3 the same B&W exam, GPU Exhibit 562. Question 6 4 asks, "What is the purpose of the pressurizer?" 5 Under that, it has two subquestions: "What happens 6 during an increasing pressure transient? What happens l 7 during a decreasing pressure transient?" l* 8 Taking the first subquestion, what 1 t 9 happens during an increasing pressure transient, l 10 was part of the right anawer to that question that 11 pressurizer water level would rise? 12 A There is really no way that I can answer
"; ( ) 13 what the expected complete answer is on this question.
14 Q I wasn't saying what would be the complete 15 answer. I was saying something slightly different. i. 16 Would part of a correct answer to that question,
.17 what happens during an increasing pressu~re transient, 18 be that the pressurizer water level would' rise?
19 MR. WISE: I am going to object. 20 Q The context is that question 6 is a 21
. question about the purpose of the pressurizer and the 22 subquestion under it is what happens during an
.- 23 increasing pressure transient. I am asking you as a r~N
(,) 24 former instructor and lead instructor whether on a 25 B&W question like this, would part of a correct answer
)
i I
.t l 1 Lind 50 (j 2 be that pressurizer water level rises during an
( 3 increasing pressure transient? 4 MR. WISE: I object on the ground that [. 5 you are asking him for part of an answer 6 when he said he doesn't know what the complete 7 answer would be; therefore, I think the ( 8 partial answer would be misleading. He has 9 not been a B&W 1ead instructor for several
, 10 years and he has been out of this particular 11 set of exams for some time. I note tha t-12 the particular exam that you are showing him
,() 13 is dated November 3, 1974, which is dated 14 almost eight years.ago.
4 , 15 Q You may answer. 16 A I don't feel that an increase in level 17 would be necessarily part of the answer-to this 18 question. ' 19 Q If somebody being trained as an operator-
'20 by B&W edid that as part of what happens during 21 an increase in pressure transient, pressurizer water rises, would that be graded as an incorrect response?
22 23 MR. WISE: I am going to object. That 24 is hypothetical and you have not established ~ 25 that this particular witness gave this p , , _ ..y w-
j 1 Lind 51 ( 2 particular exam and what grades he would give 3 for which particular answers. I think you 4 are-really now asking him just to speculate g 5 based on a document you put in front of him. ' I 6 i He said he recognizes the format but now you 7 are getting quite specific about how particular I 8 answers would be answered on particular 9 questions. I think you have really gotten into 10 a hypothetical area. 11 A You asked me if it would be graded as 12 correct or lncorrect?
,'( )
13 Q Would the answer be graded correct. In ' 14 5 other words, would a student who had written as one 15 L part of his answer during an increasing pressure 16 transient, pressurizer water level rises, would 17 that part of his answer be graded as an~ incorrect 18 s, response to the question based on the training that 19 had been going on in Lynchburg before the Three Mile ~~ 20 Island accident? 4 21 MR. WISE: I continue my objection 22 for the same reasons. 4 - 23 A
. That's kin'd of a cart-before-the-horse I
24 situation. {V~} Increasing pressure doesn't necessarily 25 increase the level. They are essentially positing I l g ywyy - ym- - 1 -----gu ee74----w'r.*- >>t- t +--
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'Lind 52
- (
() ~ 2 , an undefined situation which results in an increase j 3 in pressure and looking for a response in the 4 system or the control system, and the fact that level q-- 5 is going up or down or staying the same really has 6 nothing to do with'the answer to the dynamics of 7 the pressurizer during an increasing transient. ( 8 because we are talking -in part pressure control 9 characteristics and control system operation during
, 10 an increase in pressure. \ Level really has nothing 11 to do with either of those.
12 Q Prior to the Three Mile Island accident, L( ) 13 whenever the operators saw an increade in pressure 14 transient on the B&W simulator, pressurizer water 15 level rose; isn't that right? 16 A Yes. 17 Q And prior to the Three Mile"I.sland
- r. 18 accident, whenever the operators saw a debrease in 19 pressure transient on the B&W simulator, [ressurizer
'20 water level fell; isn't that right?
i 21 A on rapid transients, yes. Increasing 22 the level tends to increase pressure. Decreasing 23 ' the level, unless it is done fairly quickly, doesn't 24
} necessarily decrease the level fairly quickly, ~
25 b u't a decreasing transient, yes,'the level'in the
~
4
1 1 Lind 33 l 2 pressurizer will decrease. 3 Q I think we have talked somewhat about 4 this already in earlier answers on automatic g 5 actuation of high pressure injection. Let me return a 6 for a minute. Other than a loss-of-coolant accident, 7 what were operators being taught before the Three b 8 L Mile Island accident were causes for automatic 9 actuation of high pressure injection?' 10 A < The other major mechanism besides a LOCA 11 would be some type of overcooling accident. 12 Q Before the accident, were operators ( (() 13 trained on the simulator to see automatic actuation
, 14 of high pressure injection for reasons other than 15 the loss-of-coolant accidents?
16 A Yes. 17 Q You have testified earlier t'o, day about
- r. 18 control of high pressure -injection following manual 19 ~
initiation and automatic actuation. ^ When the 20 operators came ', to Lynchburg-for simulator training, 21 how frequently were transients shown to them on the 22 simulator which required them to throttle high 23 pressure injection?
.(~ 24 A I can't give you specific numbers'out of .
\J 25 :
weeks' training without looking at a schedule, but y n ,. ~7 .
.,..,.,,..,-,...g., _ ,, .n.., ,,.,n. wn,, m.,m. --- ,.
1 Lind 54 2 ,Q f') I would think that there would be in comparison to ( 3 the total number of transients run, relatively few. 4 Q Every time a casualty called for high
, 5 pressure injection actuation, the operators had 6
training on throttling it, though; isn't that true? 7 A For overcooling accidents.
$ 8 MR. WISE: That was not the question 9 he asked you. He wants to know about every 10
! time that HPI came on as shown at the
~.
11 simulator. 12 Q If HPI were actuated manually or 13 automatically at some point in the casu'alty, it had to 14 be throttled, didn't it? 15 A Not necessarily. 16 g For everything except a loss-of-coolant 17 accident, that is true, isn't it? 18 A If it was carried out far enou~gh. 19 g were there casulaties that involved 20 actuation of high pressure injection that were not 21 loss-of-coolant accidents for which the casualty 22 was not carried out to the point where-high pressure 23 injection would be throttled?
,g 24 A L] .
we-would periodically, and again, I can't . 25 recall specific instances, but periodically there l l i
1 Lind 55 (~h 2 were demonstrations given at different types of
,O 3 transients where we would not necessarily carry 4
them out as far as you would if you were actually 5 running the transient for; specifically as a drill 6 on a demo, we might not carry it out that far, 7 depending on what we were trying to utilize a demo i 8 to show. 9 Q Talking about the real world, not life d 10 inside the old Forest Road simulator, let me ask i 11 this question. During the operation of a nuclear 12 plant, is actual high pressure injection actuation,
, 13 either manual or automatic, more frequently the 14 ~
result of a loss-of-coolant accident or an overcooling 15 event? 16 A ' overcooling event. 17 Q Why do you say that, sir? 18 A There have not been that many ' loss-of-19 coolant accidents severe enough to actuate-high
~
20 pressure injection.- Fairly mild overcooling 21 accidents can initiate high pressure injection
-22 fairly easily.
23 Q Before the Three Mile Island accident,
-m . 24 I take i.t you were not aware of very many loss-of- -
V 25 coolant accidents causing high pressure injection
.C I
Lind 56 2 actuation on B&W plants; is that right? ( . 3 A That's correct. 4 Q So high pressure injection actuation as ( 5 a result of a loss-of-coolant accident was a highly 6 infrequent event before the Three Mile Island 7 accident? 8 MR. WISE: You keep moving along little 9 bit by little bit, Mr. Seltzer. First it is 10 ( "very many," then it is " highly infrequent." 11 You are just trying to get a characterization 12 from this witness without any foundation that I( 13 he has done any statistics and k ows exactly 14 how many LOCA events there were versus how 15 many overcooling events there were. We can get 16 the actual statistics on that if you want but 17 this is not the witness to do it. He has
- 18 .
already said -- 19 MR. SELTZER: Why do you have to make a 20 speech if you have an objection. Why don't i 21' you just state it, because we are trying to 22 finish expeditiously. If there is an objection, 23 just state it.
/~'
b) 24 MR. WISE: When you made objections 25 during.Mr. Miller's examination, I was polite t .- - -, , , .-e- , . , , - ,. -- ..-
1 Lind 57 2 enough to let you finish your objections and
)
3 not cut you off. I would appreciate it 4 if you would show'me the same courtesy and 5 . not be rude and interrupt me. 6 Why don't you go ahead with your I examination. t 0 MR. SELTZER: I certainly apologize if 9 I was being rude. 10 BY MR. SELTZER: ( 11 Q When you were an instructor and lead 12 instructor at B&W, was it your understanding that !t 13 high pressure injection actuation as a result of 14 a loss-of-coolant accident was an extremely 15 . infrequent event? ~ 16 3 y,3, 17 ~ Q High pressure injection actuation as a 18 result of an overcooling event was a more common, 19 more likely occurrence; isn't that right? 20 A I wouldn't say " common." 21 Q More common and more likely is what I had 22 said. 23 A Less highly infrequent. I don't like to
\s 24 -
. imply that it was a commonplace type transient. '
25 g You are aware that the operators at B&W .~
( l Lind 58 p 2. facilities that h.id been in operation for several I c% 3 months tended to see overcooling events causing high 4 pressure ~ injection actuation; isn't that true?
- g. 5 A I can recall being aware of specific 6 incidents where there were overcooling accidents that 7 ' occurred at plants, yes.
8 Q Operators had firsthand experience with 9 that transient occurring at their plants; isn't 10 that true? C. g 11 A Yes. 12 Q Were you at Crystal River after that ( V) 13 plant had gone critical? 14 A Yes. , 15 Q How long were you there while the reactor u 16 was cri tical? 17 A I don't remember the exact date for ^ 18 criticality. ( I believe it was December, January. 19 It's hard to remember, but I was there up through 20 declaration of commercial operation, which was in
-21 May, June.
22 Q Did they have any overcooling transients 23 while you were there? h- ' 24 A Yea. . L)
' 25 -Q Did they result in high pressure.
r - w , -.
1 Lind 59 ( 2 injection actuation? 3 A Yes. 4 Q Did it happen more than once? 5 A I can't specifically recall. One 6 incident leaps to mind very quickly and that is 7 the only one I can recall with any degree of clarity. 8 Q You can clearly recall one incident 9 where there was an overcooling that resulted in 10 automatic actuation of high pressure injection? 11 A Yes. 12 Q I may just not have been focusing as
'( }
13 clearly as I could have. Was the period of time 14 that you were at Crystal River between criticality 15 and commercial operation a six-month period? 16 A Approximately. I don't remember the 17 exact date of criticality. 18 Q In the training at'B&W before$the Three 19 Mile Island accident, operators were trained on loss-
~
20 of-coolant accidents; is that correct?
~
21 A Yes.- 22 Q During that training, was pressurizer 23 level always shown going down during a loss-of-
^
24 ss coolant accident while the accident was in progress? 1 25 A For larger leaks, yes. i e
1 l l' Lind 60
-p 2- Q By "large leaks," do you mean leaks that c/ N 3 were greater than the capacity of one makeup pump 4 to overcome the flow of' coolant out of the system?
5 A (L That would be a characterization of what 6 I meant in that case, yes. l 7 Q So for breaks of that size, decreasing L 8 pressurizer level was taught as a symptom of a lost-of-coolant accident? 9 10 A Yes.
.( '
11 Q For breaks of that size, were operators 12 ever shown a loss-of-coolant accident by B&W where 13 they did not have decreasing pressurizer water level? 14 A For breaks of which size? 15 Q Greater than the capacity of one makeup 16 pump. ' 17 A specifically, I don't recall ever
. 18 demonstrating a leak like that. ~
19 Q Do you recall any other instructor 20 telling-you th'at.he had demonstrated-a break like that?
- 21. A No.
'22 Q Were the operators ever shown any 23 transient 1on th' e simulator where pressure 9 and-24
- pressurizer level-moved =in opposite directions?.
25 A we would periodically run exercises e
. [- 1 Lind 61
,v] (' 2 involving instrument malfunctions where we would --
(- 3 the most common one was to cause a malfunction or a 4 small leak on a pressurizer level indication which 5 would result in a level not accurately reflecting 6 what was specifically occurring in the system. 7 Q When you f ailed a pressurizer level r 8 meter, would that one failed meter give an apparent 9 indication of pressurizer level going in an opposite i 10 direction from reactor coolant system pressure? 11 A Depending on specifically how it was 12 failed, it might.
'( 13 Q By your answer to my question, the one 14 previous, were you saying,that it was only for a 15 failed instrument that operators would have been 16 exposed to pressure level going in opposite directions '
17 before the Three Mile Island accident? 18 A Yes. ' 19 Q When operators were being trained on a 20 casualty involving a failed pressurizer level 21 instrument, the simulator had three pressurizer level 22 indications; right? 23 A That's correbt. gS 24 Q And the casualty that you would -
.Q)
-25 illustrate would have one of the three instruments S
ln- .
- 4. . .. . .. .. . . , . .
( 1 Lind 62 2 fail to show the true pressurizer level; isn't 3 that true? 4 A That's correct. I 5 Q The exercise for the students was to 6 determine that one of the three level indications 7 was not reliable and to learn that he'should rely on f 8 the other two level indications for true pressurizer l 9 level reading? l 10 A one of the expected responses would be 6 s. 11 to check the other indications to verify. If that 12
. was not done, then as the casualty would progress, ; 13 the lesson that would evolve out of that would be 14 to watch both level and pressure to make a 15 determination of the nature of the malfunction , a 16 very simple casualty if transmitters are " switched 17 immediately, probably a more valuable lesson down the 18 road if that is not done. -
f-19 Q As the casualty got down the road, you 20 said that the operators would learn something by 21 watching pressure and pressurizer level. Is that 22 because if pressurizer level continued to fall while 23 the spurious pressurizer level indication was showing 24 rising level, they would be expected to deduce from '
.v 25 the falling pressure that there could be something 3
1 1 Lind 63 t ()
,v 2 . wrong with their pressurizer level indication?
3 A Generally, the scenario is one where 4 the level'would indicate low, it would begin to
- p 5 decrease. It would essentially simulate a leak in 6
the transmitter piping, which would reflect a 7 decrease in pressurizer level. The operator did not 8 check his instruments. The normal action now 9 ultimately was to perhaps manually initiate high 10 pressure injection. If he continued to just watch 11 the pressurizer level, waiting for a response, 12 eventually he would wind up on an extremely high
- ( } 13 pressure condition because he was in fact keying 14 on the level instead of watching both the pressure 15 and the level.
16 Q The operator could have avoided getting 17 into that situation you just described if'he - 1 18 initially noticed that the one pressurizeb level 19 indication that was showing low was inconsistent with 20 the other two that were showing correct pressurizer 21 level? 22 A or that, in fact, the only symptom he had 23
. was just the level, whereas in fact the general (N 24 training is not to, again, key on one indication or ~
( 25 one symptom but to insure that by looking at enough O
f' 1 Lind 64
/G 2 parameters, that in fact you are in a certain ' (b 3 accident.
4 Q Prior to the Three Mile Island accident, 5 was the re any instruction at B&W regarding a 6 possibility that pressurizer level could go up during i 7 a loss-of-coolant accident? s ( 8 A Actual pressurizer level? i 9 MR. WISE: Right. * ' t 10 A Not that I recall.
/ t H 11 Q That wasn't part of any routine lesson 12 plan that you had reviewed?
s
; .; -- A No. -
14 Q It wasn't part of an established 15 curriculum that you had reviewed? 16 A No. ' 17 Q As head instructor , lead instructor, you 18 didn't'tell the instructors under you to discurs that 19 with-their classes? -
~
^20 A Prior to TMI?
- 21 Q Right.
22 A No. 23 t Q. You understood before the Three Mile ; l
~
d 24. Island accident, didn't you, that the only place ir
~s
%J 25 where operators would have experienced the plant
- ~i 1 t 3- Lind 4
65 i 1 l 2 responses to a loss-of-coolant accident was on the 4 L t
't v
3 B&W simulator; isn't that true?
- r. N s 4 MR. WISE:
I am going to object to
~
,- 5 that question.
t 6 Q ..Except for-a crew that had actually e 7 ' experienced a loss-of-coolant' accident at its + C 8 functioning planh, isn't it correct that the only 9 place where operator crews handling B&W plants would k '" ! 10
, , have experienced the plant response to a loss-of-1 11.
coolant accident would be on the B&W simulator r 12 ? in Lynchburg? i, 13 MR. WISE: You are excluding anything 14
- g. he may have seen in the Navy or anything they 45 may have seen if they worked for another
'w 16 s
company such as one that ha'd a West'inghouse 17 ' or a ombustion ngineering plant and you are 18 excluding all their experience on B&W plants u . ru N 4 19 and you are saying take -- - -- 1 _, 20 MR. SELTZER: .No, I am not excluding , 21 ( .: heir experience onCB&W plants. s I am saying i
+
' 22 ,[if they saw a loss-o(f-coolant accident,.which:
t. 23 this witness says was highly infr9quent,-those 3 't' 24 people who
; ) ' happened to b~e .there v when that very
\ J ,,
J
. 25
- infrequent.,
c s.event occurred hadiexperienced' plant' -
.a '
' ' ' L
~j , , }_ ,
h
" _;- $ i i'
~!
- - ( ,
% y ' q\ :y . . .,_ , .l
* . s. . .,
, , , , , -..-,,. ,.; ,.. - . . * - - - - -A q* .'
. _ _ _ ~ _ . _ . . _ _ - _ - - -
(
- -~
f-
-p--
- -~
~~;~ve
* ~
t (. l , v 1 j Lind ;) 66UT
,- - /
( '2
- response t a LOCA -- _
3 Q -
.but if tre operaters had.naver had. -
1~ .t 4 ' .such an experience either in the Nary or at another y J > 5 r ; g xeactor operating in the field, isn't.ic correct g i 6 that you recognized before the accident the only 7 I place where those operators would have expericaced 'I 8 the response of a plant to a loss-of-coolant accident ", 9 was at the B&W simulator? 10 MR. FIGE: , Well, I object on the grounds 11 that I don't know what the question means but-12 if he can go' ahead and answer it, hc may. I;( } 13 A ?. have a little'~ trouble wish the word 14 " experience." Those types of transients are ' 15 discussed in training at utilities during classroom ,
~ ,
16 discussions, graphs and' charts in the FS R requir'ing 17 training that they have to experience. - 18
.( As.far as sitting and watching the .
i 19 dynamics of needles and recorders move, if they L 20 hadn't seen it in the plant.and they hadn't seen it 21 on the simulator, there . is ru) place else you could e 22 see it,.I will' agree with that. M Q Prior to the Three Mile Island accident, r . 24 did you consider the simulator a very important , 25 training' tool? 4 U,,. v + ,& v r p #---,-c _.,,.--ae , - - , - s- -, y , %
~< - -
J . F 4 1 Lind 67 [) 2 A I did, yes.
,V- ,
6 3 Q You still do, don't you? 4 A Ch, yes, absolutely. 5 Q How would you compare the effectiveness 6 of simulator training to other methods of ' 7 instruction on plant operation during transient I 8 conditions? 9 A In certain aspects of plant operation, 10 it is the most effective tool. e 11 Q In what way was it the most effective? 12 A Let me go back to basic learning theories.
"I 13 f-}s Most of your information comes from visual observation, 14 and direct observation of dynamics visually is an . 15 extremely effective way. You learn plant response, 16 plus actual hands-on practice facilitates response 17 in the event that something happens at the actual .
18 plant. I would think, myself personally,"that it is 19 much easier to handle a transient or to re' cognize a 20 transient if it has been seen before. 21 Q And seeing could be either seeing in 22 the plant actually happening or seeing on a simulator?
' 23 A Yes.
24 Q In terms of effectiveness,-how does
- ('N)
\_/
25 simulator training compare to reading about 3
( 1 Lind 68 2 ( transients? 3 A It is more effective than reading about 4 transients. 5 g .Q In terms of effectiveness, how does 6 simulator training compare to classroom 7 instruction on transients? O A There are certain aspects of classroom 9 instruction that are very important as far as 10 transients and there are certain aspects of transients 11 that are handled more adequately on the machine. 12 Classroom discussion I think lends itself to a more ( 13 in-depth controlled discussion of procedures, t,he 14 whys and wherefores of procedures, whereas on the 15 machine it is more effective as to an application 16 of the procedures, you know, lifting that procedure 17 off the paper and actually putting it in'to practice. 4 , 18
, Q Didn't you feel when you were' lead 19 instructor that it was very important to b'e able to 20 reinforce classroom instruction on-the simulator?
21 A Yes. 22 Q In fact, wasn't there a tendency to 23
- cover in the classroom only those things that could
(~'y 24 be -shown on the simulator? ~ V 25 A As far as operational portions of e
-- y
I 1 Lind 69
~
- 2. classroom discussion. We had a lot of discussions in
( 3 class which didn't directly relate to hands-on 4 controls of the system, but when we did talk about , 5 operational considerations in the classt om and the 6 material that we discussed in class pertained to the 7 ' evolutions that were going to be, there was normally I 8 correlation between what we talked about in class 9 and what we were going to do on the simulator. 10 ( Q If the simulator could not show a t 11 specific operational situation, you did not cover that 12 operational rituation in the classroom, did you? ( 13 A Normally not. 14 Q In terms of effectiveness, how did you 15 think simulator training compared with operators C
- 16 going into a control room and pretending 'that the 17 dials were moving as they would move during a 18
( transient? - 19 A Personally I think, again assuming, it 20 was more effective. 21 Q If the operators -- based on your actual 22 experience, I am not asking you to hypothesize 23 something -- if the operators went into a control room 24 to pretend that they were experiencing a casualty, V 25 would they be able to manipulate the controls as y e
I 1 Lind 70 j r3 2 though they were making the plant respond to a (U 3 casualty? 4 A Well, again, if you are walking through a ( 5 casualty on an actual plant, you are going to walk 6 through the control response, toor if you are the 7 power and you want to go in and have a discussion ( 8 on the LOCA, the operators are not going to 9 start the high pressure injection pump, so everything 10 becomes a walk -through the symptoms, the response { 11 and the plant response, and the operator operates.
~
12 It all becomes a walk-through. 13 Q In a walk-through, the operators don't 14 get the hands-on experience that they get in a 15 simulator? I . 16 A That's correct. ' 17 Q That is one of the reasons why simulator 18 ( training is more effective than a walk-through of a 19 control room of a plant that is critical, right? 20 A Yes. L 21 Q If an incorrect response had been taught 22 on the simulator, what, in your opinion, was the best 23 way to learn the correct response? -(. 24 MR. WISE: . Could I have that read back. O -25 (Question read.) y v <
l l ( 1 Lind 71
'~) 2 MR. WISE: I object to that.
(b- I don't know 3 what you are talking about. 4 A We aren't in the habit of teaching ( 5 incorrect responses. If an operator took an 6 incorrect action, we would -- there were a number 7 of devices to reinforce the fact that a wrong step ( 8 was taken or an incorrect decision was taken. On 9 some occasions, we would let the casualty continue so 10 ( that the operator could see results of the incorrect 11 action and under other conditions we could stop and 12 explain the problem. ( kJ f') 13 14 Q After the Three Mile Island accident, 15
~
the Babcock & Wilcox simulator was reprogrammed to 16 some extent; isn't that true? 17 A Yes. ~
- 18 Q ~
one of the things that was introduced . 19 into the program for the first time after'the Three 20 Mile Island accident was an ability to model
-21 saturation in the reactor coolant system outside 22 the pressurizer; isn't that correct?
23 A . The saturated response was much more
~N
-(y sophisticated; we improved the nature of the 24 25 response, saturated response-of the system.
y +v-- , -
-(
1 Lind 72 2 Q For the first time after the Three Mile C 3 Island accident pressurizer water level would rise 4 in response to saturation in the reactor coolant (. 5 systems isn't that correct? - 6 A Yes. 7 Q One of the specific transients that 4I 8 you were able to show after the Three Mile Island 9 accident was a break at the top of the pressurizer 10 ( resulting in saturation in the reactor coolant system t 11 and a rise in pressurizer water level; isn't that 12 a fact? (( } 13 MR. WISE: At what point do you mean 14 a rise in water level? 15 MR. SELTZER: After there is saturation 16 in the reactor coolant system.
- 17 A Yes. -
; 18 Q Operators from each of B&W's 177 fuel 19 assembly plants were trained in Lynchburg on that 20 transient after the Three Mile Island accident, 21 . weren't they?
22 A Yes. 23 Q You believe that showing them that r~N u) ( 24 transient on the simulator was a particularly ~ 25 effective way to teach them the system response to w ,+ m - e..e.. v. -e y--
( 3 Lind 2 that saturation; isn't that corrdct? 3 A Yes. 4 MR. SELTZER: I would like to mark 5 g another B&W exam given in January 1976. This 6 is GPU Exhibit 563. 7 (Copy of B&W exam given in January 1976 8 was marked as GPU Exhibit 563 for 9 identification, as of this date.) 10 .g (Discussion off the re c o r d .,) 11 BY MR. SELTZER: 12 Q During the-time that you were an ( 13 instructor and a lead instructor, was B'&W asking 14 exam questions similar to these? 15 g y,,, s , 16 Q When I asked you about the purpose of 17 giving exams earlier, you described their importance 10 for testing knowledge or auditing s t ude n t s' ' 19 understanding. " 20 were exams also given as a learning tool 21 themselves as a way of helping operators consolidate 22 what they had learned? 23 A
. well, I think any well-written exam does
'3 24 that.
(O 25 Q And did you believe that the B&W exams
(
- 1. Lind 74
("T 2 that were being administered in B&W's' training (- 3 department did that? 4 A Yes. 5 g was o,ne of the models that B&W used for g 6 its exams questions which tended to show up on NRC 7 exams? t 8 A Yes.
- 9 Q Why is that?
10 A It was generally a lot of the questions <( t 11 were good questions so that they were t'esting 12 knowledge. The other factor is that as much as ( 13 knowledge for a person passing the examination, he 1 14 has to have a certain degree of test-taking expertise 15 beyond knowledge, his ability to answer questions i 16 orally and his ability to understand what questions 17 are asking specifically so that he is not.off on a 18 .! . tangent attempting to answer questions that really 19' aren't being asked; and by essentially utilizing, in 20 cases, NRC format type questions in addition to the 21 knowledge-increasing aspects of the test, it would 22 also help to, what we called, boardmanship or the 23 ability to take tests. It is a very important 24 aspect. . Q' '25 Q Would you take a look at question C-4 on w ,.*e-9 - we
+.3 -v- -+yw,we- -
w -,-e -
I 1 Lind 75
-- 2 the third page of GPU Exhibit 563.
I 3 That question begins as follows: "The 4 plant is operating at 80 percent power. When you 5 receive the following alarms: ( reactor coolant 6 pressure low and pressurizer level low, what
*7 additional indications and alarms would you expect 't 8 for the following?" The the question goes on 9 to list the following three events: "a. A reactor 10 coolant leak. b. Steam line leak. c. Steam C
i 11 generator tube failure."
- 12 A reactor coolant leak as used in this 13 s .i context is a loss-of-coolant accidents.is that 14 right?
15 A Yes. 16 Q What was the purpose, as you understood 17 it, in a B&W exam asking what additional indications 18
. and alarms there would be for these transients?
-19 MR. WISE: If you had any understanding.
20 MR. SELTZER: That is what I said. 21 A Well, my understanding is that for these 22 three accidents, there will be some common conditions 23 which will actuate certain alarms and what you would 24 _ ,r% normally.be looking for here would be some indication . 25 on the student's part of his ability to use additional w -- w=*
I 1 Lind 76 ('~ 2 alarms and indications to differentiate between these
- I V}
3 three different accidents, which again implies some 4 understanding of a transient or the dynamic behavior 5_ of the system. ( 6 Q You referred to certain common conditions 7 for these three transients. The common conditions ( 8 would be low reactor coolant system pressure and low 9 pressurizer level? 10 A They would be two of them, yes. ( - 11 Q Was there anything in B&W t' raining before 12 the Three Mile Island accident that prepared an
; .13 operator for reactor coolant leak, as it is called 14 here, without both conditions being present, namely, 15 low reactor coolant pressure and low pressurizer 16 level? '
17 MR. WISE: What do you mean, was there 18 anything that prepared him? - 19 Q Was there anything in B&W's training? 20 MR. WISEi I object to the form of the 21 question. 22 You can answer it if you can. 23 A If you mean specifically any instructions
- 24. regarding the fact that actual pressure and actual ~
25 level might diverge rather than move in the same 9m
- v
( 1 Lind 77 2 direction, I don't recall specifically myself giving ( 3 any instructions or detailed instructions on that 4 fact. g 5 Q Question C-4 in the Bsw exam assumes, 6 doesn't it, that both pressure and level would be 7 low when there is a reactor coolant leak? 5 8 A The question states those two conditions 9 for this question. 10 ( Q when the operators came to Lynchburg E 11 for simulator training, they either brought with 12 them their own plant operating and emergency ', 13 procedures or you already had a copy of their 14 procedures on file; isn't that true? 15 A That's correct. If the operators brought 16
-procedures down, it was normally to bring'down 17 revisions to the procedures. In some cases, we were 18 in a direct pipeline to get those revisions directly 19 from the utility and other cases we would-contact the 20 training coordinator and have him bring -- have someone 21- in-the first group either bring the procedures down 22 or send them down prior to the commencement of the 23 :
training. 24 . . ; O. ' Q. Generally,-you would use the utility's ' 1t5 own procedures to train its operators at the
( l Lind 78 (- 2 simulator? -}% - 3 A Generally, yes. 4 Q Ir. addition to the utility's own 5 procedures, there was a set of so-called OFR 6 procedures that had been prepared for the simulators 7 isn't that true? I 8 A Yes. 9 . Q OFR stood for "Old Forest Road"? 10 A Yes. (
- 11 Q And the simulator procedures drafted by 12 B&W for use with the simulator were referred to as
( 13 OFR Unit 1 procedures? 14 A Yes. - 15 Q Were those used sometimes to train s 16 operators when you didn't use their own p'lant's 17 specific procedures? ^ 0 A Yes. - 19 Q' I would Aike to show you the OFR Unit 1 20 procedure for loss of reactor coolant / reactor coolant 21 system pressure, which has previously been marked 22 as part.of GPU Exhibit 58. It has also:been marked 23 as GPU Exhibit'396 as a separate exhibit. 24 (~ u) . 25 Let me show you this, which is clearer
- than the copy I just handed you. I don't mean to 9
, r
- 1 Lind 79
~
2 lead you in any way by the markings on that. If you 3 want to refer to that as a more legible copy, feel 4 free to. 5 Are you familiar with GPU Exhibit 396 ( 6 as being the B&W loss-of-coolant accident 7 procedure prepared for use with the simulator? ( 8 A Prior to TMI, yes. 9 Q Prior to the Three Mile Island accident? 10 A That's correct. ( " 11 Q Was it your understanding that the 12 procedures which were drafted by B&W for the simulator ( 13 came from the same basis of draft procedures that were 14 sent to the owners of B&W plants? 15 A I really had no understanding of that. 16 I never gave it much thought. ~ 17 Q What did you understand, if anything, was 18 the origin of the procedures that had been ~ prepared-19 by B&W for the simulator? - 20 A These procedures were in place when I 21 started working for B&W and 4 I, to be quite honest 22 with you, never gave much thought specifically to 23 their origin. q 24 Q . You worked with the OFR simulator V 25 procedures, right? 4
,_e ., . . _ r_ , , . , , . _ , , . ,. _
( 1 Lind 80
. 2 A Yes.
3 Q And you also worked with the procedures 4 that utilities were bringing? g 5 A Yes. 6 Q -Were these procedures ever updated before 7 the Three Mile Island accident? By "these" I mean 8 the procedures for simulator generally. 9 A Prior to my time as the lead instructor, ( 10 I don't specifically recall any changes being made. t 11 Q Well, you were lead instructor before 12 the accident. Were any changes made in the OFR '. 13 procedures?
- 14 A The time frame is hard for me to 15 remember but I think we did initiate some corrections 16 on some procedures, specifically some of'the operating 17 procedure s , prior to TMI.
18 Q Before the Three Mile Island accident, do 19 you recall making any revisions in procedures at the 20 suggestion of anyone in the engineering department at 4 21 B&W? 22 A No, I don't recall. 23 .Q In-addition to simulator training,_was 24 7s - _there classroom instruction on_how to deal with ~ 25 loss-of-coolant accidents?
.(
1 Lind 81 i Q 2 A Yes. 3 Q Who at B&W gave the classroom lectures 4 on loss-of-coolant accidents? 5 A During my time there, the instruction, 6 again pre-TMI, was given by the operators, the , 7 instructors. ( ' 8 Q' You didn't bring in personnel from the 9 engineering department to give the lecture on loss-i ( 10 of-coolant accidents? 5-11 A Not on the loss-of-coolant accidents, no. 12 Q So nobody -* rom Bert Dunn's ECCS analysis 15 (D/~T unit came down to give any lecture relating to how 14 to handle a loss-of-coolant accident before the Three 15 Mile Island accident?- ( , 16 A . Not that I can recall.
.17 Q When the operators went into the 18 simulator for simulator training on loss'of-coolant 19
. accidents, who gave the simulator instruction?
- 20 A The instructors.
21- Q Not anybody from engineering? 22' A No.
, Z3 Q The B&W loss-of-coolant accident' t-24 procedure which has been marked GPU 396, has three
)
i
' 25 categories of leak or ruptures is that true?
e
- w w , 3 - ,_ - <ry 6 y yis 3 -e y- ,_
-m. y +wy- ,-4. y- -
9
1 Lind 82 2 A Yes. t V 3 Q Those three categories describe 4 successively the larger leaks or ruptures, right? 5 A Basically, yes. ' ( 6 . Q The sections of the procedure that 7 correspond to those three different sized ruptures ( 8 are sections 4, 5 and 6. 9 Section 4 is the leak within the 10 ( capability of one makeup pump to overcome the lead? t 11 MR. WISE: That is not whad it says. 12 A It says "...to maintain RC system pressure 13 and pressurizer level. " 14 " Q In other words, one makeup pump is - 15 injecting sufficient water into the system to overcome 16 the loss of water through the break and restore 17 system pressure and pressurizer level? 18 A Yes. - 19 g Section 5 describes a leak within'the 20 capacity of the high pressure injection system to 21 overcome the loss of coolant and maintain pressure and 22 pressurizer level? 23 A Yes. 24 '
. f'}
Q And section 6 is,a large leak or rupture .
~'
25 which exceeds the capability of the high pressure
~
I 1 Lind 83 - i 2 injection system to overcome the loss of coolant, I 3 right? 4 A Yes. 5 Q Each of the break sizes has a description , (. 6 of symptoms; am I correct? 7 A Yes. I 8 Q Since this was an emergency procedure, 9 these were symptoms that the operators were expected 10 to memorize? ( e, . 11 A If they were utilizing our procedure,
- 12 yes. -
/; 13 Q If they were utilizing their own loss-(d 14 of-coolant accident procedure, they were expected 15 to memorize the symptoms of their procedure?
16 A That's correct. ' 17 Q The' symptoms were stated so.that the 18 s operator would compare plant conditions with the-
'19 memorized symptoms to see whether a particular 20 procedure applied,to the conditions that existed in 21 the plant?
22 A It is the function of the' symptoms 23 portion, yes.
- s. 24 Q, In 4.1, the first symptom begins with' 25 pressurizer level and-reactor level coolant system n
y g .--y g -w - y yw g-- >w'- - g.,y-- - y
( 1 Lind 84 2 pressure decreasing, right? 3 MR. WISE: It says decrease. 4 A Right. 5 Q In other words, the first symptom states 6 that there will be a decrease in both pressurizer 7 level and reactor coolant system pressure in ( 8 the event of a small leak or rupture as defined by 9 section 47 10 A Yes. ( ' 11 Q In section 5, which is the next larger 12 sized leak, the first symptom begins with a decrease ( ,/~} 13 in pressurizer level (_/ and reactor coolant pressure, 14 right? 15 A yes, ( . 16 Q And that would be a decrease both in 17 pressurizer level and pressure, right? 18 ( A , Yes. ' 19 Q In section 6, which is the largest leak l 20 or rupture, the first symptom is a rapid unexplained 21 decrease in reactor coolant system pressure and 22 pressurizer level, right? 23 A res, 24 7s i Q And that would be a simultaneous decrease . 25 in both system pressure and pressurizer level? l
( 1 Lind 84 2 pressure decreasing, right? 3 MR. WISE: It says decrease. 4 A Right. 5 Q In other words, the first symptom states 6 that there will be a decrease in both pressurizer 7 level and reactor coolant system pressure in ( 8 the event of a small leak or rupture as defined by 9 section 47 10 ' A les. ( >. 11 Q In section 5, which is the next larger 12 sized leak, the first symptom begins with a decrease C/x 13 U in pressurizer level and reactor coolant pressure, 14 right? 15 A Yes.
'l .
16 Q And that would be a decrease ~both in 17 pressurizer level and pressure, right? 18 ( A , Yes. ~ 19 Q In section 6, which is the largest leak 20 or rupture, the first symptom is a rapid unexplained 21 decrease in reactor coolant system pressure and 22 pressurizer level, right? 23 A Yes. gs 24 Q And that would be a simultaneous decrease . km 25 in both system pressure and pressurizer level? n ~ + -m-
I 1 Lind 85 2 A Yes. ( 3 Q would you look at the immediate actions 4 in section 4. 5 , These are actions which the operator was 6 expected to be able to execute from memory without 7 opening the procedure? ( 8 l A That's corr 5ct. l 9 Q Item 4) under the immediate actions, 10 section 4.2, says:
" Maintain makeup tank level s.
11 above the low level alarm point and maintain 12 pressurizer level in the normal operating range."
- 13 Do you see that?
14 A 'l e s . 15
~
Q That is an instruction to the operator 16 to manually initiate high pressure injection if 17 necessary to maintain pressurizer level in the 18 normal range? 19 A No. - 20 Q What would the operator do to maintain 21 pressurizer level in the normal operating range 22 under this B&W instruction? 23 MR. WISE: Mr. Seltzer,.you are reading 24 from a section that is labeled a leak within ~ 25 the capacity to maintain the system. I don't l
i I Lind 86 1 .
~T . 2 know whether you are trying to trap or trick f
{Y 3 the witness. 4 MR. SELTZER: I am not trying to trap 5 the witness. I am just trying to find out 6 information. - 7 MR. WISE: Well, you went through the ( 8 three categories and you demonstrated to us -- 9 M R'. SELTZER: I think it is improper. 10 If you have an objection, I think you should ( t 11 state it. I don't think you should be speaking 12 what your understanding of the procedure is on ( 13 the record. 14
.MR. WISE: I am not making --
15 MR. SELTZER: Do you have an objection? 16 l MR. WISE: I do have an objection. I 17 have an objection to the way you are conducting 18-t the examination. If you want to ask this 19 witness straightforward questions and get his 20 answers, that is fine, and I have not presented 21 objections, but you are asking questions after 22 referring him to a section of the procedure 23 i, without stating the name of the section that 24 you are in. ~ I think it is extremely
)
~/
25 misleading to someone trying to read this, and
, ,. - ,,n, -- . , . - - a e
' 1 Lind 87
(~) 2 unless you are purposely trying to mislead f V 3 someone, I don't know the reason for it. You 4 are in the section called " Leak or rupture 5 within capability of one makeup pump capacity 6 to maintain RC system pressure and pressurizer 7 level." You have asked him the question about ( 8 how he would maintain it by using HPI. 9 Q I don't know whether what Mr. Wise has said l 10 ( sheds any light on it and makes it easier for you to t 11 answer the question, but if you recall the question, 12 you can answer it. ( 13 A Thi s section does essentially define the 14 fact that the normal system under the normal 15 operating conditions will maintain level and directly s' , 16 below that statement then you manually in'itiate j 17 safety injection and move to another section of the 18 procedure. -
\
19 Q When you s ay " manually initiate safety 20 injection," you mean manually initiate HPI? . 21 A Yes, but that is not an instruction for 22 staying in this procedure. 23 g The note you were referring to is a note 24 under subparagraph 4) in 4.2, correct? _. 25 A Yes.
( 1 Lind 88 2 Q In order to maintain pressurizer level 3 in the normal operating range, the operator would 4 use all the information here, including the note that 5 appears right under that; isn't that true? ( 6 A Yes, but he would no longer be in 7 section 4. ( 8 Q I understand he would be moving on to 9 another section. 10 A That's correct. 1 11 Q In moving on, he would first manually 12 initiate high pressure injection, right? r 13 A Yes. 14 Q And the purpose for manually initiating 15 HPI is in order to attempt to maintiin pressurizer ( . 16 level in its normal ranger right? 17 A Yes. - 18 Q The key that tells him manually to 19 initiate high pressure injection is pressurizer water 20 level; isn't that right? 21 A Yes. 22 Q It has nothing to do with reactor coolant 23 system pressure in this B&W draft procedure, does it? 7_. 24 A Not in this specific instruction, no. - V 25 Q Will you turn to section 5, which is the
( l Lind 89 ( ( 2 intermediate size loss-of-coolant accident. , 3 " Symptoms" 5.1, sub 1) , as we indicated 4 earlier, starts first with pressurizer level and ( 5 reactor coolant pressure having a' decrease. It goes 6 on to say that that will happen "without an I associated reactor coolant average temperature change, ( 8 and continues decreasing as the pressurizer level 9 control valve opens fully." 10 The pressurizer level control valve would 11 open fully because pressurizer level has fallen; 12 isn't that correct? ( 13 , A That's correct. 14 Q It is that decrease in pressurizer level 15 which also caus.es the makeup tank J.evel to decrease; 16 isn't that right? 17 A Makeup tank is a source of water that 4 18 - i is flowing through the pressurizer level 6ontrol valve 19 back into the system, so as the valve open's to put 20 water back in the pressurizer without any makeup 21 being initiated by the operator, the makeup tank 22 level will decrease. 23 g In other words, it is the drop in 24 pressurizer level which produces the second sympton 25 in 5.1, sub 2; is that right? D w , -
+ - -
r e
( g Lind (~T 2 A That's correct. c d 3 Q For a break at the top of the pressurizer, 4 there wouldn't be the pressurizer level control 5 valve opening fully and makeup tank level decreasing 6 rapidly, would there? 7 A Initially, yes. ( 8 MR. WISE: Wait a minute, now. It is 9 unclear. What were you saying?
~
10 MR. SELTZER: He said " Initially, yes." { t 11 A Initially, the level will decrease and 12 the pressure will decrease independent of where the ( 13 leak is. 14 MR. WISE: I am not sure the way the 15 question is phrased what you are answering 16 yes to. Maybe we could have it read back.- 17 MR. SELTZER: I think he has clarified it 18 s with his subsequent response. If you want to 19 have it reread, go ahead. -- 20 MR. WISE: In other words, you are 21 disagreeing with Mr. Soltzer's statement? 22 THE WITNESS: I am saying that the level 23 and the pressure will decrease initially on 24 this leak independent of where the leak is 25 located, whether it is on the top of the .- l l
t (
- 1. Lind 91 2 pressurizer or -- -
3 MR. WISE: He was asking you specifically 4 about a pressurizer level control valve 4 5 mentioned in the procedure and asking you 6 whether it is a fact if there is a break at the top ; 7 of the system that the valve would not'open - I 8 fully as is contemplated in this particlilar 9 . 4 symptom, andIwasunclearastowhethefyou
- 10 are agreeing or disagreeing with Mr. Seltzer's i (
11 question. i 12 THE WITNESS: I am disagreeing with 13
'{} Mr. Seltzer's statement that the'1evel control 14 valve would not open. The level control valve i
15 would open. 16 BY MR. SELTZER: ' 17 g Would it open fully? - 18 A The position of that. valve lsc a function 19 7 of how far the level deviates. - 20 g so it opens more fully as the level decreases 21 .A The further the level departs from the 22l setpoint, the further the valve opens, and we are 23 not considering here very,'very large deviations in
, 24 order for the valve to open fully. In'other words, if 25 we were operating at 220 inches,1the level would not !
_ . . . _ . _ ~
( 4 1 Lind 92 e. ( 2 have to drop to 100 inches for that valve to open ( 3 fully. ' 4 Q If a break continuee at the top of the
^
5 pressurizer,_such as thrdugh a stuck open pilot 6 operated relief valve as had occurred at Davis-Besse 7 on September 23, 1977 for 21'sinutes , would the E x . 8 pressurizer level c o o *. r o l valve remain open fully? 9 MR. WISE: I am going to obj e :t' to that
\
19 question. ( I don't know if there is any q 11 foundation that this particular witness ,is i 12 familiar with all of the circumstances and (( 13 c'haracteristics of the, Davis-Besse transient 14 and your question prefaced itself by saying 15 that r s ycu were, positing the circumstances at 16 Davis-Besse. e I don't know if this witness 1 17 knows hll the circumstances. ~ 3 18 Q r \ To the extent that you are fa$iliar with 19 0 that pressurizer: break scenario and keying on the ~ 20 fact that you said initially the pressurizer level 21 control valve would open, Yhattis'your understanding 22
' about whether that s U valve'would remain open, what is 23 . your understanding currently about whether that
(^]
%)
24 valve remains open during a period when the pilot 25 ope rate d relief valve remains in a failed open
- (
1 Lind 93 I~h 2 position? U - ( 3 MR. WISE: Based on everything he has 4 learned since the TMI accident, now? 5 MR. SELTZER: Fine. 6 A If the pilot operated relief valve 7 remains open, the system will go into saturatior.. I 8 once the system reaches saturation and provided that 9 system temperature is not decreasing too rapidly in 10 ( the system, if the temperature stabilizes at some Il point, eventually the saturation conditions in the 12 reactor coolant will begin to push water back into the ( 13 pressurizer and once the level is above setpoint, 14 the level control valve will go shut. 15 '( Q If the high pressure injection of water 16 causes' pressurizer water level to rise, that could also 17 cause the pressurizer level control valv'e .to close, 18 ' couldn't it? 19 A Ye s '.
~
20 Q It would also stop the makeup tank level 21 decrease? 22 A 4 By this time, we are not pulling water 23 out of.the makeup tank anymore. The answer is ('] N_- 24 the response of the system this far into the transient 25 has no effect on the makeup tank directly because we
. , , , s . - ,
( 1 Lind 94 2 are no longer utilizing water out of the makeup ( 3l tank to inject water back into the system. 4 Q So after high pressure injection begins g 5 raising pressurizer water level above the actuation 1 6 point for pressurizer level control valve, there l 7 will not be continuing rapid decrease in makeup tank E 8 level? 9 A Well, once high pressure injection is 10 initiated, the normal makeup flow path is isolated. 11 Q That means that normal makeup flow is 12 stopped, right? . (( } 13 A That's correct. 14 Q So the makeup tank level is no longer 15 going to be decreasing? ( , 16 A That's correct. 17 Q Section 5 is the section of the B&W 18 simulator procedure that applies to breaki that are 19 within the capacity of the high pressure injection 20 system.
~
21 MR. WISE: Read the rest of it. 22 Q -- to maintain RC pressure and pressurizer l 23 level. 24 Under the "Immediate Action," does . 25 immediate action No. 5 tell the operators when to
. 1
( i Lind 95 2 ( throttle high pressure injection? ( 3 A It gives guidance for controlling high 4 pressure injection flow. 5 g And controlling includes reducing the 6 high pressure injection flow as app rop riat e'? 7 A Yes. ( 8 Q And shutting it off as and when 9 appropriate, right? 10 A Yes. I ( 11 Q Subsection 5) indicates that one condition 12 under which the operators would be instructed that it 13 was permissible to begin reducing high' pressure 14 injection flow was "If the reactor coolant system 15 and pressurizer level stop decreasing..." If , 16 Do you see that? 17 A Yes. 18 Q That means that they could behin 19 throttling high pressure injection to redu'ce ~ the 20 flow into the system when reactor coolant system 21 pressure and pressurizer level stopped going down, 22 right? 23 A Yes. (T 24 Q There is an instruction in the note
%/. '
25 below subparagraph 5) concerning limiting high v v. . _ , . , , , .,, -w--. e. y- - - .w--, w --
.- - - .- =- .
i ( 1 Lind 96 2 pressure injection flow to prevent pump runout. 3 What did you understand that was telling l 4 the operators? Is that something to protect the 5 pumps from damaging themselves? 6 A i Yes, pump runout can result in damage 7 to the pump motor, not the pump. I' 8 Q And this is an instruction to the 9 operators to reduce high pressure injection flow 10 ( under certain circumstances to protect the pump
. t 11 motor?
2 12 A Limit it to, specifically to no more than (( 13 500 gallons per minute, yes. ' 14 i Q In order to reduce the flow or throttle 15 l the high pressure injection, the operetors had to l(
- j 16
.take manual control of the high presacre injection 17 system, right? -'
18 A Of the valves at least.
~
19 Q Did that mean that they had to~ initiate 20 a maInual bypass'of the automatic safeguards system? l 21 4 A- At Old Forest Road, . individual components i go were bypassed. 23 At'different plants, either portions 24' of the systemicould be bypassed or an entire bypass 25 was required. y --, -- -p. -wr. p ,--y ren,g e p w m- -- - r
I 1 Lind 97 2 Again, I just don't remember exactly - I 3 what had to be done at TMI but at least the valves 4 had to be bypassed in order to regain control 5 ( for the operator to be able to change their position. 6 Q And the valves you are referring to are 7 the valves on the high pressure injection system? ( 8 A Yes. 9 Q At what point in the loss-of-coolant 10 C accident would the operators be trained to manually I 11 , bypass the automatic control of high pressure 12 injection? ( 13
. MR. WISE: Which loss-of-coolant 14 accident section are you talking about now?
15 MR. SELTZER: Let's stay with No. 5. 16 MR. WISE: That is the one wh'ere they 17 were able to maintain RC pressure and 18 pressurizer level, just so the record is clear. 19 A The point is defined in the prbcedure. 20 Q Where? 21 A In section 5. It is 5.2, step 5). 1 22 Maintenance of the " pressurizer level as close as i i 23 possible to l the normal operating range" is obviously l 24 7-] going to require limiting the_ flow, and right below . 25 that, the note which discusses runout also requires G w *
( 1 Lind 98 (~} 2 a bypass of part of the system to limit the flow so k_/ , ( 3 as not to exceed runout on the pump.. 4 Q Under section 5.2, sub 5), were the 5 operators instructed that when they saw reactor 6 coolant system pressure and pressurizer level stop 7 decreasing, they were to manually bypass the high-C 8 pressure injection system? 9 A No. 10 Q Would that have been a permissible thing 11 for them to do in order to get ready for the 12 g operator action required in that subsection? ( ) 13 A Just actually bypassing the components 14 without manipulating specifically would be permissible 15 once the pressurizer level had stopped decreasing. 16 Q 4 Under section 5.2, sub 5), it'says that 17 the operator is to " maintain pressur,1zer~ level as 18 close as possible to the normal operating' range by 19 varying the number of running makeup pumps." It is 20 the running makeup pumps that are supplying.the high 21 pressure injection, right? 22 A Yes. i 23 Q " Makeup pumps" was being used in this gs 24 L. procedure as you understood it, interchangeably wi.th . 25 high pressure injection pumps? A Yes, i
I 1 Lind 99 g- 2 Q " Maintain pressurizer level as close as (_]/ ( 3 possible to the normal operating range," that meant 4 whatever was the normal range for the particular 5 plants that the operators were from; is that correct? { 6 A If we were using this procedure, we were 7 using OFR s e t'p oin t s . ( 8 Q OFR means the simulator setpoints? 9 A Right. . 10 Q What was the simulated normal operating ( 11 range for pressurizer water level on the simulator? 12 A Under these conditions, 100 inches. 13 Q ( So once the system pressure and 14 pressurizer level stopped decreasing, the operators 15 would take manual control of high pressure injection C 16 to maintain pressurizer level as close as' possible 17 to 100 inches? 18 A ( Once the level -- now,.we said that 19 once the pressure and level stopped decreasing,-it 20 was permissible to bypass. As_far as actively taking 21 control of the components and beginning to manipulate, 22 the operators would not do that until the level had 23 been restored to the setpoint; so, in~other words, _ 24 the level may stop decreasing below 100 inches and at .. 25 -that point it would be permissible to go to an
-r g- ~g w
( 1 Lind 100 , 2 override but actual movement of the control components i 3 would actually not occur until a level had come 4 back and restored to a normal operating range, which f 5 would be 100 inches. 6 Q So they were not throttling HPI 7 under this procedure until they had a level of 100 C 8 inches of water in the pressurizer; is that right? 9 A That's correct. 10 Q when they got 100 inches of water in the 11 pressurizer, they would then be instructed under this i 12 procedure to throttle back on HPI; is that right? ( 13 A PPovided that the pressure was stable 14 or increasing in the system also. 15 Q That means it has either stopped (
- 16 decreasing or is rising? .
1 17 A That's correct. - 18 Did there'come a point in time"when you Q 19 l learned that there were loss-of-coolant accidents 20 for which reactor coolant system pressur'e would 21 recover above'the actuation point for high pressure 22 injection, yet the accident would still be_in progress? 23
, To state it another way, did there come a--
f- 24 point in-time when you learned there were loss-of- . , J-25 l coolant accidente that would eventuate in a
. , - - - - - > , <- , ,.- y v v. -y --
g- r -%,- y-
( 1 Lind 101 { ) 2 repressurization of the system? 3 MR. WISE: If you don't understand the 4 question, just tell him you don't understand ( 5 the question and he will have to ask you 6 another. 7 A I don't understand the question. ( 8 Q I am describing a situation where there 9 is a loss-of-cdolant accident in progress . The 10 accident is releasing coolant from the pressure 11 boundary and while that release of coolant is 12 continuing, the system repressurizes above the HPI I() 13 setpoint. ~~ 14 MR. WISE: And your positing that HPI 15 is on or off or har, it been throttled by the 16 . operators, and if so, how much? 17 MR. SELTZER: That is not in issue. 18 . Q I am asking, did you ever hear before or 19 after the-Three Mile Island accident, that there were 20 loss-of-coolant accidents that result in a 21 repressurization of the reactor coolant system? 22 MR. WISE: 1 Any kind, with or without j 23 HPI on? We have just spent the last half
/~S '24 hour discussing a procedure that talks about ^
b 25 in at least two sections maintaining RC
- r- g .v- e. -m -m - g -- - .,-. .r g g y- -.r4 --s-r -w--- -
l f ! 1 Lind 102 l 1 2
) pressure. You are not asking him did he ever {
3 hear about these two sections of the procedure? 4 These two sections of the procedure, as I ( 5 understood the testimony in the last half hour, 6 posit decreasing pressure and posit a 7 situation in which the capacities of f ' 8 one makeup pump, in the case of one section, 9 are enough to maintain pressure, so on its 10 c face, what we have been discussing for the last 11 half hour talks about a break where the system ' 12 is capable of repressurizing. You are not C() 13 asking him did he ever hear of that? 14 MR. SELTZER: That is a very useful 15 addition. s 16 Q Before the Three Mile Island accident, did 17 you have any understanding that there co'u.ld be a 18 repressurization of the system while the beactor 19 coolant system was boiling? " 20 A While we were still in the saturated 21 condition is what you are saying? 22 Q That is what I meant by boiling.
~
23 A I_ don'.t recall hearing anything 24 specifically a')out that. ~
]\_/ ,
25 g After the Three Mile Island accident, did
( 1 Lind 103 ( [D 2 you come to know that there were loss-of-coolant 3 accidents for which B&W predicted there would be 4 repressurization of the system even though the ( 5 system was still boiling or saturated? 6 A Yes.
~
7 Q Did you learn after the Three Mile Is1and
-(
8 accident that such a repressurization with boiling 9 still going on in the reactor coolant system could 10 g occur for ruptures that were within the capacity 11 of the high pressure injection system? 12 MR. WISE: Could I have that read () 13 back, please. 14 (Question read.) 15 MR. WISE: I will object because I don't 16 understand the question. If the witness 17 understands it, he can try and ans'wer it. , 18 I don't understknd it THE WITNESS: 19 either. There seems to be a contradiction in 20 terms there. 21 Q What is the contradiction? 22 A Continuing boiling on a leak that is 23 within the capacity of the high pressure injection ; (~
\,_-}' 24 system to replace mass. It is not going'to happen.
~l t
25 The system is going to become subcooled if you i
1 ( ' k i Lind 104
- . ( ).
4 2 replace mass f aster than you are losing it. 3 Q You said you learned after the Three Mile I i 4 Island accident that there were breaks which could. I 5 result in repressurization of the reactor coolant 6 system even though there was s'ill t boiling or i ( 7 saturation in the reactor coolant system; right? 8 A That's correct. 9 Q For those breaks, it would have been an 1 '( 10 incorrect instruction to train the operators to , 11 reduce high pressure injection flow merely because 12 pressure was no longer decreasing and pressurizer [ ) 13 level had been restored to its normal operating r*ange; j 14 isn't that correct? 15 A Yes. 16 Q After the Three Mile Island accident, 17 B&W modified its procedures for guiding the operators 18
, on how to handle high pressure injection durng i 19 loss-of-coolant accidents; didn't it?
20 A Yes. 21 Q And it changed what were the instructions 1 22 for when the' operators should throttle or reduce 23 1 high pressure injection flow; isn't that right? 24 A' Yes. 25 l Q specifically, the operators were given
. . . -.--.- .-._2.-. , _ . . . - - . .- . . . . . ., --
( l Lind 105 2 a subcooling rule? 3 A That was one of the criteria. 4 Q After the accident, the operators were I 5 told that if high pressure injection had automatically 6 actuated, they should not terminate high pressure ( 7 injection unless they had verified that the system 8 was not' boiling, had not saturated; isn't that right? 9 A
- That is one of the criteria, yes.
! 10 (At this time, 12:15 p.m.,ta luncheon 11 recess was taken.)
12 13 14 15 O 16 17 t 18 19 23 21 22 23 G3 24 25
, m w e 9 - , - - a -- .-- n- -, ~ g-
~
t' 1 106 2 AFTERNOON SESSION ( 3 1:50 p.m. 4 JOHN ALBE RT L IND, resumed. ( 6 EXAMINATION (continued) 6 EY MR. SELTZER: - 7 Q Before the TMI accident, what did you (
- 8 understand were the plant technical specifications 9 or tech specs?
{ 10 A Regarding what? e 11 Anything. Q 12 What are tech specs? () 13 A Tech specs are conditions essentially 14 developed by the vendor in concurrence with the NRC 15
,~ for conditions that must be required for operating r
- 16 th'e plant at different --
under different conditions in 17 terms of equipment availability, instrument and 18 control availability, plant conditions to guarantee 19 that the plant will in fact be operated safely and 20
. can be shut down and controlled in a safe' fashion if 21 necessary and will also responds the automatic 22 control system is.used for protection of the plant 23 and the core will function properly. So they are
, /" 24 ( )N really guidelines developed which are to be followed 25 to insure protection of the plant and the core. W
(. 1 Lind 107 l ( () 2 Q As compared to other instructions or 3 guidelines that the operators have for a nuclear 4 plant, how important are technical specifications? i ( 5 A Technical specifications are one of the 6 bases -- one of the bases for the development of 7 procedures at the plants, so they are important, ( 8 they are a foundation for the correct operation of 9 the plant. ' 10 Q What happens when a plant yiolates its 11 technical specifications? 12 A What generally is involved is a report has f() 13 to be filed with the Nuclear Regulatory Commission. 14 Depending on the severity of the vio1'ation, there 15 are different time restraints imposed as to how soon 16 a report must be filed. Violation of tech specs also' 17 requirec, once the actual, the specification is
~
18 violated, certain actions have to be taken within 19 specified time frames for_different types Iof problems 20 with the tech specs. So there are both, control e 21 actions taken immediately by the operators and also 22 ultimately administrative operations that are 23 performed to inform the NRC of noncompliance .of tech 24 specs or violation of tech specs. {~T
~-)
~~
25 Q The operator's action in controlling a G % m "
i f - 1 Lind 108 1
) 2 nuclear plant is governed by what is written in 3 technical specifications, limits and precautions 4 and operating procedures; is that right?
( 5 A That's true. 6 Q Before the Three Mile Island accident, 7 what was your understanding, if any, as to which of L 8 those three writings had the highest priority if 9 there were any conflict between the instructions in ( 10 the three writings? > t 11 A The final goal is operation of plant in 12 j a safe manner to protect the core, the systems, and ( 13 ultimately, the general public. Procedures direct 14 themsulves to a much wider range of considerations 15 than tech specs so that I guess in order of priority, 16 the tech specs, their sole purpose is protection, 17 whereas procedures are protection, effibient operation C 18 and other considerations. So if push came to shove, 19 the bottom line would be safe operation o[ the plant L 20 and protection of the core and the general public 21 and that really is a direct tie to the tech specs. 4 22 So I would say the prioritizing would be that i 23 the highest priority is the safe operation of the 24 plant and that would tie to direct compliance with - 25 the technical specifications. m r + A-
-( 1 Lind 109 ( ( 2 Q Were operators trained at B&W to be 3 familiar with the requirements of technical 4 specifications? ( 5 A Yes., 6 Q Did that include training the operators 7 to know in which modes the particular technical 1 8 specifications applied? . 9 A Yes.
; 10 Q As applied to technical specifications, 11 mode 1 covered critical operation of the reactor 12 at what power levels? $() 13 A Above five percent.
14 Q In other words, if the plant is at 100 15 percent of power or 90 percent or anything down to 16 five percent, it is covered by mode 17 17 A That's correct. 1 18 .Q Mode 2 is tha only other mode'that 19 " covers power operation; is that'right? 20 A Critical operation, yes. 21 Q What power level is covered by mode 2, 22 five percent or less?. 23 A Five percent or less and when you shut {~./~} 24 down, anytime you are less than one percent - 25 suberitical. That. mode really covers both the 9
( 1 Lind 110 (
) 2 shutdown.and the critical condition. With 3 constraints being greater chan .99-K effective to 4 five percent power is mode 2.
C , 5 Q When the operators came to B&W for 6 training and were being trained on the technical - 7 specifications, did they have their own plant ( 8 specifications with them? 9 A Yes. 10 Q g I would like to show you technical 11 specification for pressurizer operation for TMI-2. 12 MR. SELTZER: We will mark this as GPU 13 Exhibit 564. 14 (Three Mile Island Nuclear Station 15 s Unit 2 technical specifications Appendix A 18 to License No. DPR-73, was marked as GPU 17 564 for identification, as of thi~s [date.) 18 MR. WISE: Could we have a statement on 19 the record as to what this exhibit kurports 20 to be? It looks like a lot of stuff and 21 pages are missing. ' 1 22 i Q- Let me show you a book of TMI-2 23 tech specs, and I would like to call your attention 24 specifically to page 3/44-5. f'))
~
\_
25 First.of all, are you familiar with this e
( 1 Lind -11 1 2 ( format for technical specifications for B&W designed 3 nuclear steam supply systems? 4 A Yes. ( 5
, , Q Is the page that you have open in front 6
of you the page that describes in technical [ 7 specifications the limiting condition for operation 8 of the pressurizer? - 9 A Yes. 10 g Q Is this scmething that the operators 11' would have been trained on at B&W7
- 12 A Yes.
13 Q This technical specification is 14 applicable in modes 1, 2 and 3. What did mode 3 15 govern? i 1E A Mode 3 has greater K effective of less 17 than .99 and the other is a temperature limitation. ( 18 Q During the first several hours of the 19 Three Mile Island accident, immediately after the 20 control rods were scrammed, what mode was Three 21 Mile Island Unit 2 in? 22 A Mode 3. 23 Q Does this tech spech indicate that the [~N 24
%. ' pressurizer level must be kept between 45 inches and 25 385 inches?
,- ,y .---p p v. m m,
f . *:L 1 Lind 132 O 2 A Yes. 3 Q And that is a requirement while the 4 plant is in modes 1, 2 and 37 2 g 5 A Yes. 6 Q 385 inches below the top of the 7 pressurizer, right? i l( 8 A Yes. 9 Q If the water level is not permitted to ! 10 exceed 385 inches, this is a requirement that the I i ~ 11 pressurizer not be filled solid with water? l 4 12 A Yes. I( 13 Q Is that requirement in this technical
- 14 specification typical of other plants' technical 15 specifications?
'l 16 A It's typical for all plants operating with } 17 standard tech specs. l( 18 Q Three Mile Island Unit 2 was a standard 19 tech specs plant? - 20 A Yes. I. 21 Q So was Davis-Besse? 22 A Yes. I i 23 Q Do you know which other_177 B&W plants fg were STS or standard tech spec plants?
) 34 25 A I am not sure of the status now. Oconee ,
i != y ~ , - - - , -e , , ., e e
( 1 Lind 113 ((r) 2 was not, Rancho Seco was not. TMI-1 I believe 3 initially was not and made a transition but I am not 4 exactly sure when that transition was made. ( 5 Q Was Arkansas Nuclear one? , 6 A I believe so. It's been a while. I don't ! 7 rememb er specifically. ( 8 Q In any of the training at Lynchburg, were 9 the operators ever shown a transient in which it was g 10 the correct action while the plant was in modes 1, 2 11 ! or 3 to violate this tech spec? 12 A No. ( 13 Q Were operators ever shown a simulation 14 at B&W in which the correct action was to take the 15 pressurizer solid? In other words, fill it solidly 16 with water? 17 A Prior to TMI, no. t 18 Q If the pressurizer were goin[to a water 19 level that would exceed 385 inches, was the B&W ~ 20- training-prior to the Three Mile Island accident that 21 they should throttle high pressure injection, or 22 throttle makeup, whatever was adding water to the
, 23 system at the time?
/"
}u.))
24 A- I believe we established that this - 25 morning. 4
( l Lind 134 ( 2 Q The answer is yes? ( 3 A Yes. 4 Q It is your understanding that this ( 5 technical specification was applicable at Three Mile 6 Island Unit 2 on the day of the accident? 7 A Yes. - ( 8 Q This morning, and I don't want to repeat 9 the questions or even paraphrase your answers, you 10 testified to what you understood were the undesirable 11 consequences of going solid. 12 Were those things which were discussed
\
C[d 13 with the operators in training at E&W7 14 A Yes. 15 Q
; Before the Three Mile Island accident, 16 do you recall whether there was any instruction'at 17 B&W regarding how long it would take for the
, 18 pressurizer to go solid with water after the 19 pressurizer water level went off scale high?
' 20 A I don't recall any specific discussions 21 of that, no.
22 Q Just so the record is clear, about what 23 off scale high means, could you explain what you {~x 24 understood I meant when I used that expression? - v 25 A There is an indicated range on the i
( 1 Lind 135
}
2 pressurizer,. The top end of an indicating range is 3 not physically located at the top of the pressurizer 4 so off scale high means essentially off the top of g 5 the indicating range. It does not necessary mean 6 that the system is completely filled up. There is 7 basically a hemispherical volume above the upper end ( 8 of the indicating range. 9 Q In other words, just at the point where 10 the pressurizer is filled to the top of its indicated i e 11 range, it still has some additional space before the 12 pressurizer is filled completely with water? , C (~) 13 A That's correct. () e 14 Q Among the procedures that the operators 15 were trained on in Lynchburg, did you train them on s 16 the pressurizer operation procedure? ' 17 A We had this procedure there. Myself, I 18 don't specifically remember doing a lot of training 19 on this procedure but there are malfunctions that 20 we ran that are covered by this procedure. 21 MR. SELTZER: I would like to mark that 22 as GPU Exhibit 565. 23 Let me interrupt where we are now and
~
24 indicate that since we had problems with our - q,! 25 excerpt, Exhibit 564, which hadn't been
l [ l Lind 116 2 duplicated adequately by our staff before 3 the deposition, we showed the witness a 4 complete book of technical specifications { , 5 that included the specifically numbered page 6 3/4 4-5. 7 Just to preserve the sanctity and coherence <( 8 of the record, I would like to substitute as 9 GPU Exhibit 564 that one page.
- 10 Is that acceptable, Bob?
11 MR. WISE: Yes, although I will say that, 12 of course, you selected one page out of a very 13 thick document of technical specifications. C( 14 MR. SELTZER: That is why I put 15 on the record that we put in front of the 16 witness the full book of tech speed. 17 MR. WISE: We may have some-questions
; 18 on cross-examin ation that will require us to 19 use the full book of tech specs and since you 20 have chosen to show him one page out of that, 21 I would like to have that available-so that we 22 can examine him on other parts of the tech 23 specs rather than selecting out one page.
24 MR. SELTZER: 6 I seem to recall at
\-
25 Mr. Miller's' deposition that there was a lot of 3 -hk v t -- m *
-. _~ -.- - --
(. 1 Lind 117 2 use of excerpted exhibits to wh'ich GPU's C 3 patient counsel made no objection. . 4 (Excerpted page entitled " Reactor i g 5 Coo'lant System Pressurizer, Limiting Condition 6 for Operation," pa,ge 3/4 4-5, marked GPU 7 Exhibit No. 564 for identification, as of this E 8 date.) 9 Q I have passed a copy to you of pressurizer . i 10 ' operation procedure for Three Mile Island which we ( ,. , 11 are marking as GPU Exhibit 565. 12 (Document entitled "Three Mile Island {( 13 Nuclear Station, Unit #2 Operating Procedure i 2103-1.3, Pressurizer Operation" marked GPU
~
14
- 15 Exhibit No. 565 for identification, as of this s
16 date.) ' , L7- Q What is a system hydrostati.c test? 18 A That's a test to determine that in fact 7 19 the system when subject to high pressure -- it's a 20 leak check of the system after construction-initially 21 and then after maintenance, the pressure boundary -- 22 the integrity of the-pressure boundary is broken by 23 the removal of a manhole or the addition or deletion g_ 24 of a penetration. 25 It would button that component.or system
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. o .m ..-g,,.--.-, ,p, -
- , . . . - - ,, y~tw --v4-,--,-r . -
.(-
1 Lind 118 () 2 backup and then pressurize it and static pressure 4 3 condition to test the integrity of the system. 4 Q A system hydrostatic test is conducted 1 ( 5 before nuclear fuel is loaded into the reactor, 6 right? 7 A That's correct. ( 8 Q Would you take a look at Section 2.1.8, 9 - please. 4 , g 10 A Yes. 11 Q That section of the TMI-2 procedure 12 says that " Ths pressuzizer/ reactor coolant system (() 13 must not be filled wit.h coolant to solid conditions 1 14 (400 inches) at any time except as req'uired for system 15 hydrostatic tests." ( 16 Was that a typical instruction in the , 17 pressurizer operation procedures for B&W plants that ( 18 you were familiar with before the acciden't? 19 A I can't recall if that's a typical
" i 20 statement. !
21 Q- Without the specifics of the specific 22 number of inches, was it a typical requirement for 23 all B&W 177 plants before the accident that the 4
-(} 24 pressurizer and reactor coolant system not be filled 25 with water to solid conditions at any time except
.mw - - - - , 9-~- e--- s- r e n .yn-4 + - . , , -n-nm,- nn - e-, yp--,-. p.-e---p- ye- -p-me> +-,o=-
. (.
y Lind 119 2 during system hydrostatic tests? ( A 3 I can't be certain that that precaution 4 was included in all pressurizer operation procedures. Q Were you aware before the accident that 6 m re than one plant had that guideline? A I don't recall if I checked it specifically 7 ( to see how many plant procedures included that 8 g precaution. ' 10 Q Do you know whether any included it? I C g A This one obviously. " 12
. Q Are y u aware that the B&W limits-and
( 13 pre auti ns for pressurizer system operation precluded g4 filling the pressurizer to indicated solid water 15 nditions except as required for system hydrostatic. 16 g A I am sure I was at the time. i , 18 Q W uld y u turn to section 2.2.7. Is that
.gg essentially a restatement of the requirement that was L
in the page of the tech spec that you were testifyin'g from? A Y*** 22. g Q The operators.would be expected to know when.they were in charge of their plant that these b kJ 24 requirements on not going solid were contained both J 9
( 1 Lind 120 l
) 2 in the tech specs and in their pressurizer operation t
3 procedures and in the limites and precautions? 4 A I would expect the operators would be ( 5 familiar with thos,e. 6 Q To your knowledge, were the operators 7 ever shown a transient on the simulator at B&W { 8 where the correct action:was to violate either this 9 pressurizer operation procedure, GPU 565, or the
, 10 B&W limits and precautions with respect to maximum i.
11 water level in the pressurizer? 12 A To the best of my knowledge, no. l() 13 Q To the best of your knowledge, was there 14 any classroom instruction that told the operators i 15 before the Three Mile Island accident that there were 16 conditions under which they could go solid in th's 17 pressurizer? - 18 A No. ' 19 Q From your f amiliarity with thd technical 20 specifications, is it correct that there are some 21 pressure / temperature limits included in the tech 22 specs? 23 A Yes. 24 Q And there are also some pressure / temperature l 25 limits that'are contained in B&W's limits and 1
.% m- <w . - w ,, y =--,---.y-ee c g-e- r-= w+. --a
l
-i
.1 Lind 121 2 precautio,ns?
( 3 A Yes. 4 MR. SELTZER: Let me mark as GPU Exhibit 7 5 566, Section 2.0.from the technical 6 specifications. It is a section entitled 7 " Safety Limits and Limiting Safety System 8 Settings." (S ection 2.0 from the technical 9 10 specifications entitled " Safety Limits and i 11 Limiting Safety System Settings" marked 12 GPU Exhibit No. 566 for identification,
. 13 as of this date.1 4
14 Q Would you take a look at Section 2.1 4 15 headed " Safety Limits." 16 Does this section describe'the combination 17 of re' actor coolant core outlet pressure and outlet 18 temperature which should not be exceeded? - 4 19 A Yes. .. 20 Q And there is a figure 2.1-1 which 21 describes graphically where the safety limit is on 22 a temperature / pressure coordinate?
- 23 A Yes.
24 Q' These safety-limits as described by O. - 25 the curve in figure 2.1-1 are applicable to which
,,N ,, , -y mq -g-.- *- ' * * *
( l Lind 122 modes?
, [~'}
2 NJ - . L 3 A Based on this figure, that's modes 1 4 and 2. 7 5 Q In other words, it applies only while 6 the reactor goes critical? 7 A Yes. I 8 Q These limits would not have applied during 9 mode 3 which existed af ter the first eight seconds 10 of tha Three Mile Island Unit 2 accident, right? t 11 A That's correct. 12 Q What was your understanding before.the 13 Three Mile Island accident of the purpose of this [] x-14 portion of the technical specifications? 15 A The pressure / temperature limits outlived 16 in this figure are essentially for the margin before 17 we get excessive boiling in the core which can 18 ultimately result in fuel damage. - 19 Q Clad failures? - 20 A Possibly clad failure if allowed to 21 continue for a long enough period of time. 22 Q Were the operators trained that these 23 safety limits applied only to modes 1 and 2? ("N, 24 A This specific limit, yes.
\_)
25 Q B&W designed into its 177-plants a e
( t Lind 123 rs 2 gizmo called the reactor protection system, right? s 3 A That's correct. 4 Q Part of the design of the reactor 5 protection system was to insure that when the 6 reactor was operating at power, in other words, in 7 modes 1 or 2, the system stayed within the proper I 8 pressure / temperature bounds as defined by figure 9 2.1-1 of the safety limits? 10 A Yes. s 11 Q Am I also correct that the ~r'eactor 12 protection system would automatically trip the ( 13 reactor if the pressure / temperature position of the 14 reactor coolant system was outside the bounds of 15 the safety limits? 16 A Yes.
- 17 Q And the operators were taught that?
18 A Yes. - 19 Q 2.1.3 is also part of the safety limits
- 20 section of the tech specs, right?
21 A Yes. 22 Q That defines a maximum pressure for 23 the reactor coolant system? 24 A Yes. -
%J 25 Q Are there any modes other than the modes q,w -
- w. e-y.- -- --
we-,.a -4. =- - - - - - ,%-m----+q.,a ,, e-' = =
E l' Lind 124 7s 2 to which this is applicable? i 3 A No. Well, there is another mode but it 4 would be very difficult to pressurize the system 5 that high because the head of the reactor vessel ( , 6 would be off so even though there is an additional 7 mode, it wouldn't apply to it. { 8 MR. WISE: I haven't posed any objection 9 and you are free to go on but there is a limit 10 to this. It seems to me we are wasting a lot
! s 11 of time reading from these documents.
12 I can show him other parts of the limits
, 13 and precautions. If you are trying to establish 14 something here, perhaps we can get to the point 15 of this.
,' 16 MR. SELTZER: 0.K., we are moving along. 17 MR. WISE: Parts of the procedures that 18 aren't applicable and asking him questions about 19 those as if they were the only parts. of this 20 is kind of silly. We have all got the tech 21 specs and can read them. 22 MR. SELT2ER: But the lead instructor of 23 B&W's understanding of the procedures is 24 probably more probative than my understanding O 25 or maybe even your understanding. w---m..-- , , - - - g , _- -e
I 1 Lind 125 , g 2 MR. WISE: But you have b'een aski.ng him b* 3 about a section of the procedure that governs 4 critical operation in TMI. -They~weren't 5 oparating when they were critical. I don't . i 6 know why you have chosen that. 7 There are other parts of the tech sp'ecs ( 8 that do govern noncritical. Perhaps you can 9 show the witness those, i 10 Q The design pressure for the reactor { j I ( 11 coolant system was 2500 psig?
- A 12 That's correct.
13 , Q And the tech spec is setting.a limit of 14 10 percent greater pressure? ' 15 A 110 percent is safety limit, yes. 16 Q And that is all based on ASME code 17 requirements for vessel integrity, i s n ' .t that right? 18 A Yes. They set the 110 percent factor . 19 for the safety limit. They set the 125hercent 20 factor for hydrostatic test. They don't set a 21 number, they set a multiple of design. 22 Q High pressure was not a problem on the 23 day of the accident, was it? 24 MR. WISE: You are asking him based upon I 25 what he has learned. You know he wasn't there.
I 1 Lind 126
~
2 I think we can all stipulate th'at the problem I 3 at TMI during the accident was low pressure, 4 not high pressure. ,- 5 MR. SELTZER: I will accept that C 6 stipulation. 7 Q What is your understanding of the ( 8 maximum discharge pressure of the high pressure 9 injection pumps at TMI-27 10 A Their shut-off head approaches -- I can't 1 i 11 give you a speci.fic number but I would'think ball park 12 it's close to the safety limits there but I can't i 13 give you no exact figure. It's somewhere between .i \ l ,14 2500 pounds, slightly higher than that'. 4 15 Q If the high pressure injection pumps were 16 running and the pressurizer did become solid, was it
, 17 your understanding that the reactor coolant system t -
18 pressure would rise almost immediately to.the head 19 of the high pressure injection pumps? .. 20 A No. 21 Q Why not? 22 A Because of the relief capacity of the 23 safety valves.
. l 24 MR. SELTZER: I would like to mark as -I 25 GPU Exhibit 567, a section from the technical
1 3 l 1 Lind 127 2 specifications which is 3/4.4.9, " Pressure / ( 3 Temperature Limits for the Reactor Coolant
.4 System."
5 (Document entitled " Reactor Coolant 6 System, 3/4.4.9 Pressure / Temperature Limits, 7 Reactor Coolant System, Limiting Condition I 8 for operation" marked GPU Exhibit No. 567 for 9 identification, as of this date.) 10 Q This is another section of the technical ( 11' ' specifications that deals with temperature / pressure 12 relationships, right? 13
.( } A Yes. '
14 Q Based on your familiarity with the 15 technical specifications applicable to B&W 177 plants, 16 are there any other sections of the techn'ical 17 specifications that would prescribe pressure / temperature 18 limits? - 19 MR. WISE: I will permit the witness 20 to answer as best he can sitting here today 21 not having gone through the tech spec in years 22 for whatever value that has. I think it is
- 23 irrelevant given what his answer is, given he 24 is not employed by B&W but if the question is v-25 l
how good is his memory today of what a 2-inch l. t._. _
'(
1 Lind 128 4 2 thick volume has in it, I suppose we can get iC 3 that answer for whatever it is worth. I 4 MR. SELTZER: Will the court reporter }( 4 5 let the record reflect Mr. Lind has the complete
- . 6 tech specs in front of him and was looking 7 through the table of contents in the front l lE 8 to refresh his recollection on whether there i- '
l 9 were any other sections that deal with . 4 a' ' 10 pressure / temperature limits. ' ii '. - i 11 A Just based on a fast scan, there is a l l
- 12 P/T limit on the steam generators and there is also i i
'(
s 13 a sect &on that talks about pressure / temperature relationships in the tech spec called "DNB Parameters." l 14 t j 15 MR. WISE: Have you had enough time to i i 16 testify that you have reviewed this thoroughly 17 so that you would know whether there may be ; 1-18 others? - 1-19 THE WITNESS: Based on a f ast--scan, ! i 20 that's all that comes to mind. I would have , [ 21 to review each page. I just. don't recall. 1 22 Q The DNB part is the portion that we have i 23 just previously covered, is that right? l ' 24 A- No. -
, \~
i- 25 Q. What section is the DNB7' l
.. l
( 1 Lind 129 2 A Power distribution limits.
)
3 Q What modes are those applicable in? 4 A I would have to go to them. I believe ( 5 it's mode 1 and 2 but I would have to check. Mode 1. 6 Q So that is power operation above 7 5 percent? 5 8 A Correct. 9 Q* Looking at GPU 567, which was the part 10 beginning at page.3/4 4-24, what did you understand t 11 was the purpose of these limiting conditions? 12 A The basis for these? 13 Q Yes. , 14 A The basis for these is mechanical stress 15 to the reactor coolant system piping and components. 16 -Q In order to avoid'that danger' to vessel 17 components, this part of the technical. specifications 18 specifies a maximum allowable pressure? - 19 A It specifies allowable temperature / 20 pressure relation
- ships. This limit does not include 21 the safety limit we discussed earlier.
22 Q For any particular temperature, doesLit 23 indicate a maximum' allowable pressure? A Yes. 24 25 Q Let me show you what has previously been S
1 Lind 130 2 marked as GPU Exhibit 349 which are the limits and
>t 3 precautions which B&W prepared for Three Mile Island 4 Unit 2.
- ( 5 Are you familiar with limits and 6 precautions that B&W issued to 177 plants? Are these
- 7 guidelines for system operation that you worked 8 with when you were in training? Are these guidelines 9 for system operation that you worked with when you
., 10 were an instructor and a lead instructor at B&W7 i- t i
11 A We normally worked with the limits and . 12 precautions in a different format, the format that 5- 13 was done at the utility. But, yes, we' worked with 14 limits and precautions. , j 25 Q Are you familiar with the fact that 16 B&W's limits and precautions prescribed pressure / 17 temperature curves that were required for maintaining 18 operation consistent with the net positive suction j 19 head curve? - 20 A Yes.
- 21 Q And are you familiar with curves that 22 were required to be observed to maintain fuel pin 23 compression?
I 24 A Yes. , . 25 g What did you understand was the purpose w . -_, . , ..-.a , , - . - - . , , , - . , , , , , s - . . . . _ , .,,,...,.,en.,,..,-,..,,-mw--- n ,.,,e,,,,.n,, ,,.,.-,.-,-.,e-,,-,,..,, , , , ,
l l C 1 Lind 133 l l 1 2 of the clad compression curve? 3 A The purpose of the clad compression curve 4 was to keep the fuel pin in compression to minimize g 5 improper stress orientation of zire hydrides. 6 g In other words, it was to protect the 7 mechanical integrity of the cladding on the fuel ( 8 rods? 9 A That's correct. 4 10 Q The curve was created and described on ( 11 graphs in.such a way to attempt'to insure the design 12 lif,e of the fuel r'ods, isn't that correct? (( ) 13 MR. WISE: You know, you are asking him
- 14 an awful lot of questions that are really i
15 design questions. If you are trying to pin 16 this back to training that Mr. Lind gave t'o . 4 j 17 the operators at TMI and something relevant to 18 this case, I have no objection. l '. 19 We are really going on and on about design 1 . 20 , questions. Mr. Lind has not been shown to be i. 21 a designer or a person who writes these 22 procedures and you have justified on the theory i 23 that this is a test of the training lead l 24 instructor's knowledge and understanding and-it - Ov 25 seems to me asking him all these questions two L __ _
C 1 Lind 132
) 2 ,
years after he left B&W to see what his i 3 knowledge and understanding today of this 4 4 matter is, well, I think irrelevant.
- ( 5 MR. SELTZER
- Let me reassure you and 6 Mr. Lind simultaneously that this isn't a 7 test or a quiz of technical expertise.
8 The point is that all of these procedures 9 and technical specifications that we have been 10 going over are ones on which I am sure B&W
- n 11 gave training to operators as a matter of
.12 routine.
() 13 Q Isn't that right? . 14 MR. WISE: If you want to ask him those 15 questions, that is fine, but you are asking 16 -him a lot of questions about what is the 17 purpose of this and what is the purpose of that. 18 If you can ask him did he provide 19 training to operators on tech specs; I think 20 he answered that question about an hour or two 21 ago, but go ahead. I really don't see where 22 this is going. It seems to me we are wasting 23 everybody's time. We have all got copies of 24 these things. , 25 Q You understood, didn't you, that B&W
(~ 1 Lind 133
) 2 engineers had calculated the shape of the fuel 3 compression curve that was in the limits and 4 precautions, right?
~
( 5 A Yes. 6 You knew that that same fuel compression Q 1 7 curve was also contained in a number of procedures (
- 8 such as unit cooldown and pressurizer operations, 9 right?
- 10 A Yes. ,
11 You understood, didn't you Q that that 12 curve.was created by B&W engineers to allow for a
' ("N 13 (jf substance safety margin, icn't that right?
14 A Generally speaking, all these curves 15 have ability in safety margin. 16
'O And by that, is it correct that a plant 17 could exceed those curves, go to the wron,g side of 18 those curves without destroying with thad one 19 transient the integrity of the clad? "
20 MR. WISE: I object to that. 21 A I can't answer that question. 22 Q Didn't you understand that the design 23 life of the clad was such that it was intended to ) 24 ['))
%- he able to absorb some excursions that exceeded the ~,
j 25 clad compression curve? l j l 1
iC 1- Lind 134 2 MR. WISE: I object to that. We wouldn't 3 be here today if that were entirely true. At 4 TMI they went to the wrong side of the curve 5 and we all know what happened there. l 6 I as,sume you are not including that in 7 your question? 8 MR. SELTZER: Let's talk about Davis-Besse 9 where for two hours they exceeded the clad 10 compression curve. And B&W issued a report l: ,. 11 which was submitted to the NRC ul'timately by 12 the licensee which said that the clad had-
} 13 maintained its integrity notwithstanding the 14 fact that for two hours the temperature /
15 pressure relationship was on the wrong side 16 of the clad compression curve. ' 17 MR. WISE: And we know at TMI there was 18 a different result so what is the point of 19 the question? It's irrelevant. In some + 20 instances you can and some instances you can't. 21 You are wasting our time at this point. 22 MR. SELTZER: That is your opinion and 23 you are entitled to it. I think if you have a 24 lawyerly objection to make, you should state
~ n(. -
25 the objection, otherwise you are the one who is
t y Lind- 135 2 wasting time by not permitting the examination E +- to proceed. , 3 , , . 4 MR. WISE: Go ahead with the questions 1 4 5 but I object to this line of questioning. I-6 Q Didn't you understand at the time that i you were trainer and the lead instructor that not 7 i i every excursion across the clad compression curve g
"**"" * * "O "D*9# Y * **" - * "" *
- 9 10 plant could not safely resume power operations?
e
- gy A Yes. ~
12 . Q You did understand that? * () 13 A Based on the fact that the curve had been violated at certain plants during~ transients l 14 i 15 and the clad still had its integrity, i l 16 Q The NPSH curve was a curve that defined
- 17 the limits for continued operation of the reactor 18 e olant pumps, right? .
19 A That's correct. ., 5 20 Q Was it y ur understanding that if'the 21 pumps continued to be operated while the pressure / 22 temperature relationship was on the wrong side of 23 the NPSE curve, that there would be cavitation in ! the reactor coolant pumps? O 24
,, A Y.s.
e .-,_ep. ,- ., ,_ m,.% , , , . - , _ , r--,..r,., , ~ . . . . . . , , , ,, .#- ,,y- , - . , ..%, . _ , , , . e.,,, -,,- - , r
T 1 Lind 136 ]
) 2 Q That meant that there would be vapor o*
, 3 formed at the eye of the impeller which would then .i 4 implode on the impeller blades? In other words, ( 5 the vapor bubbles would form at the eye of the
.6 impeller and then collapse on the higher pressure 7 blades of the impeller?
C' 8 MR. WISE: Did what mean that? What is i 9 the "that" at the front?
, 10 MR. SELTZER: Cavitation.
11 A Cavitation is really the formation of 12 bubbles on the low pressure area on the leading edge i E( ) 13 or the trailing edge on the blade of a' pump and then 14 the subsequent travel of those bubbles to the leading 15 edge of the next blade and at a higher pressure area L l ,
- 16 and the collapse of that would have a corrosion 4
17 effect.
; 18 Plashing in the eye of the im'peller would 19 have a slightly different consideration. -
l 20 Q If the temperature / pressure. conditions i 21 in the reactor coolant system were on the wrong side 22 of the-NPSH curve, were the operators trained on 23 what steps to take to restore the system conditions
~
to the correct. side of the NPSH curve? 24 25- A I personally don't recall any training 1
-. _ , . _ _ - ~ .
(- 1 Lind 137 I 2 where I got the plant on the wrong side so that in A( J L 3 terms of a simulated training session, I.can't say 4 whether or not that was done. ( 5 , In terms of classroom discussion, 6 obviously there would be discussions about corrective 7 options for improper P/T actions. 8 Q What were the operators' trained to do 9 in order to regain the proper P/T or pressure / 10 temperature relationships? 11 A There are two ways to get to the right 12 side of the curve. You can either hold temperature 13 constant, increase pressure or you can hold the i 14 Pressure constant and decrease your temperature, 15 depending on the conditions that got you to the wrong
- 16 side of the curve which would-dictate how you go't 17 back. .
18 on some conditions it would b'e easier to 19 lower temperature. Under other conditions, it would 20 he easier to lower pressure so I can't give you a i 21 blanket statement as to how to go about correcting 22 that condition. t 23 Q If the operators were going to use the= {~} v 24 pressure-reducing strategy', they would remove heat 25 :by increasing the cooling being achieved at the
l C 1- Lind 138 l b l
/~
L)' t 2 once-through steam generators, right? 3 MR. WISE: I don't believe he testified 4 to a pressure-reducing strategy. ( 5 MR. SELTZER: I withdraw that. Let me 6 start again. I misspoke. . 7 -Q If the operators are going to reduce r 8 temperature in order to get back on the right side , 9 of the net positive suction head curve, am I correct
. 10 that the instruction was that they should use the
. t 11 once-through steam generators to increase the heat 4
12 removal? () 13 A If that was the mechanism for cooling 14 the core at the time, if generators were in use, yes. 15 Q was there any instruction given on any 16 other way to reduce temperature *in order'to brin'g 17 the plant to the correct side of the NPSE curve
, 18 focusing.just on response to the NPSH curve?
19 A Very far down in that.NPSE curve would 20 be first starting puups up, you might be-using the 21 decay removal system in whi.ch case it would require 22 manipulation of those controls vice manipulations with i
.. 23 the steam generators.
24 That would be a very limited applicat. ion 25 because.there is only a very small area where-you
(- 1 Lind 139 {
- ~'
2 would be on decay removal and operating reactor coolant 3 pumps. 4 Q For the rest of the curve the operators (. , 5 were instructed to rely on the steam generators for 6 heat removal? 7 A Yes. ( 8 . Q If the strategy that was used for bringing 9 the system conditions to the correct side of the
; 10 net positive suction head curve were pressure control, C
, t 11 were the operators trained to use the pressurizer 12 heaters for that? '
'.C 13 A Yes.
14 Q If the operators could not through use of 15 the steam generators or the pressurizer heaters lC 16 restore-system conditions to the correct side of 1 17 the net positive suction head curve, were the operators i r, - 18 taught to shut off the reactor coolant pumps? i 19 A I don't recall a lot of specific training 20 on that. I_know-some of the' guidance given in-some .
. 21 specific cases and,.for instance, at crystal River, 22 the guidance would-be to reduce the number of i
- 23. runnin'g pumps to a more -- to a better pump _
; ('T 24 combination.
Af 25 .There are certain pump combinations that
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?
1 Lind 140
'(
c
} 2 can withstand lower P/T relationships than others 3 so they would go to a better pump combination rather 4 than turn all the pumps off at once.
( 5 Q If the plant temperature and pressures 6 were on the wrong side of the clad and the compression 7 curve,was the instruction to the operators to take
~(
8 the same actions to bring it back within the curve 9 as you have just described for bringing it back within ( 10 the NPSM curve? 11 A Basically, yes. Except that there would 12 be no use of the decay heat removal system. ([D %) 13 Q In B&W's training before the Three Mile 14 Island accident, if the system conditions were s 15 outside either the NPSH curve or the fuel compression 16 curve, were the operators ever instructed that they 17 should use the high pressure injection system to
, 18 bring system conditions back within the curves? ~
19 A I could not say for sure one day or the other 20 on that. 21 Q You don't have any recollection as you 22 sit here today of that? 23 A~ No. recollection, no. (^ 24 Q That wasn't a simulator exercise, was 1 V) -l 25 - it?
( 1 Lind 143
) 2 MR. WISE: Was what a simulator exercise?
3 Q To use HPI to bring the plant within the 4' clad compression curve. ( 5 A If you were in that situation, you were 6 normally on HPI. If you bounce those curves against 7 actuation set points for safety systems, it's pretty
- C 8 hard to get there in most cases without having 9 already initiated an HPI system.
r 10 Q But you don't recall any specific 11 instructions to the operators about the relationship 12 of high pressure injection use to either the clad
( ) 13 curve or the NPSH curve?
14 A You mean in terms of initiating high 15 pressure injection if it wasn't in operation to get 16 above that curve? 17 Q That's right, or maintaining it in i 18 operation to get above that curve. ~ 19 A Maintaining is different. Initiate, I 20 don't recall anything. 21 Q Do you recall any specific instruction 22- that you gave to operators that they should maintain l i 23 high pressure injection in order to bring the plant
/
l 24; above the NPSH curve or above the fuel clad 25 compression curve?
~ _ - _
-- - .__ - ~ -
C 1 Lind 142
'f' 2 A Specifically, no.
cd -) - - 3 Q Do you know of any other instructor who 4 was specifically giving that as a lesson? r [ 5 A No. 6 Q You have previously testified that there 4 7 was no transient simulated before the Three Mile , 8 Island accident where it was correct for the operators 9 to permit the reactor coolant system to go solid. 10 The way the simulator was programmed s 11 before the Three Mile Island accident, could the 12 operators tell when the simulator was going solid? 13 A Yes. -' 14 Q Once the simulated reactor coolant system 15 was at solid conditions, the simulator lost its 16 ability to continue to model system resp 5nse
- 17 accurately, isn't that right?
18 A Yes. ~ 19 Q Given the way the simulator was programmed
.20 for transients before the Three Mile Island accident, 21 taking the plant solid was just about the worst the 22 operator could do, wasn't it?
23 A There are a lot of things,-there are (~ 24- things that he could have done that would have been
\~/
25 worse but that was regarded as an unsatisfactory
.(
1 Lind 143 {} C 2 place to move the plant to. 3 Q It was an absolutely incorrect operator 4 response, right? ( 5 A Yes. It was incorrect. 6 Q In light of the Three Mile Island 7 accident, what is your opinion now, if any, as to 8 the appropriateness of B&W's earlier training of ( ) 9 operators n'ot to go solid? 10 MR. WISE: I am going to object to that 11 for all the reasons which should be obvious. 12 MR. SELTZER: 0.K. I will take my ' I( ) 13 chances. l 14 A I feel that our training was consistent 15 because for all the accidents imposed, accident scenarios imposed on the simulator going' solid was 16 17 incorrect. . l
; 18 Q It just turned out to be incorrect for l 19 one scenario that hadn't been anticipated-in modeling 20 the simulator?
21 MR. WISE: I object. What is it that 22 you are talking about? The question is so vague 23 it is impossible to know what you are talking r^ 24' about. -
. k_)T 25 Q Since the Three Mile Island accident, the O
j ( 1 Lind 144 I3 2 simulator wt.s reprogrammed and operators were trained (\_) 3 on a particular transient in which it was appropriate 4 operator response to let the simulator pressurizer
? 5 go solid, isn't that right?
6 A That's correct, yes. 7 Q If an operator at the simulator console 8 took the pressurizer solid, made the mistake of 9 taking it solid, that ended the transient, didn't 3 10 it, on the simulator? 11 A Yes. 12 Q Are you familiar with situations where
- I) 13 when an operator was bitten by that drill and let
\m/
14 the plant go solid, other operators laughed, derided 15 the operator who had let the plant go solid? 16 A I would say there is, especially if there 17 is a situation where we had, say, fooled them with 18 the instrument malfunction we talked about earlier. 19 There would be some amount of internal. discussion 20 about that between the operators. 21 Uncontrolled mayhem and laughter in the 22 control room was not the normal response but there 23 would normally be some riding about it among.the (')
%J 24 operators.
-25 Q You mean good-natured ribbing of'somebody
1 Lind 145 (" 2 who had let the plant go solid? c~. 3 A Yes. . 4 Q Did you ever come to realize either i
- r 5 before or after the Three Mile Island accident that l'
6 the simulations which the operators had seen, always 7 showing true pre.ssurizer level rising and pressure r- . l' 8 rising and always being taught that they should 9 throttle HPI before the pressurizer went solid had
, 10 created a conditioning of the operators so that e
11 mentally they believed that they should never let 12 the plant go solid? 1
'( 13 A' I need you to repeat the front end of 14 that question.
15 (Record was read back.) I-
~
16 MR. WISE: I object to the qu'estion. 17 'A The thought never especially crossed my 18 mind prior to that. There is discussion about it 19 now. I can see how there is a possibility-that some 20 conditioning might occur as a result of that. 21 Q Prior to the-Three Mile Island accident, 22 was there any Bsw training of operators on the l 23 occurrence of saturation in the reactor coolant 24 . system outside the pressurizer? p(d.
- 25 A- Yes.
C 1~ Lind 146 O
) 2 Q Was that training that was associated 3 with large break loss of coolant accidents? Is that 4 the context in which the training occurred?
( 5 A The majority of that training would have 6 been in relationship to large break LOCA's. Also in 7 terms of the topic we discussed earlier,which was 8 reactor coolant pump operation, cavitation is 9 essentially a saturated response in the system as y 10 is excessive boiling in the core. 11 Q Nucleate boiling occurs on the edge of 12 fuel rods, right? 13 A Yes. 14 Q That is a highly lo'calized saturation, r 15 also, isn't it? 16 A Yes. 17 Q And cavitation is a highly lo,calized
. 18 saturation occurring at the eye of the re' actor coolant 19 pumps, right? ~
20 A Yes. 21 Q Nucleate boiling does not indicate th at 22 the reactor coolant system generally is saturated, 23 does it? 24 A No. 25 g cavitation in a reactor coolant pump r
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- j. 1 Lind 147 2 doesn't indicate that the reactor coolant pump is 3 generally at saturation, does it?
I 4 A cavitation indicates you are very close. l ( 5 Nucleate boiling dcas not indicate the system is
; .6 close to saturation but DNB, which is the prime 7 we are concerned with when we are talking about i
1 S
; 8 safety limits, you are getting close.
4 1 9 Q Other than discussing saturation in ' 4 10 connection with a large break loss of coolant accident t i 11 or the very localized saturation that occurs during- .; 12 pump cavitation, was there any other discussion
*(
13 before the Three Mile Island accident of saturation f' f 14 in the reactor coolant system outside the pressurizer? ' - s 15 A I can't say for certain that no one spoke 16 about it. It was not a specific ear-marked.four-hour 17 block of lecture. It's the kind of topic that would
} 18 come up in relationship to other subjects rather. l 19 than be a single topic discussed within one 4
20 schedule so it's very hard to say. *
^ S 21 Q In indicating that saturation is 22 something that was discussed in connection with 23 large break loss of coolant accidents, are you '\
, s
~
s . 24 referring to the very large breaks where the pressurizer. drains and there is.a massive or rapid. ~a ' 25 s w , s
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f l A 1 Lind 148 , i t () 2 depressurization down to the head of the low { 3 Pressure injection system and core flood tanks? 4 4 A Not necessarily that large but larger ,( 5. leaks, yes., 6 Q Leaks that drain the pressurizer? 7 A Leaks that drain the pressurizer, di' 4 8 Q Before the Three Mile Island accident,
- 9 did B&W give any instruction to the effect that l -
10 saturation was a symptom of a loss of coolant 11 accident?
^
3 12 A As far as including it in a list of
' () 13 symptoms, in terms of a symptomatic discussion, b 14 I can't say. The dynamics of'the accident, the 15 results of a large leak putting the system in 16 saturation I am sure would be discussed during 17 discussions of leaks.
_ 18 Q In terms of giving the operators
~
19 guidance on transient identification, can you recall - 4 20 any specific instruction that told operators that , 21 they should watch for the onset of saturation as an 7,. 22 indication of a loss of coolant. accident? 23 % A I can't recall anything specifically y' 24 along those lines,'no. -
' 25 Q As lead instructor, did you'ever tell
)4' ,
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( 1 Lind
- 149 2 the instructors working for you that they should 3 teach operators that saturation may be a symptom to 4 watch for in trying to identify a loss of coolant
'C 5 accident? 6 A I can't recall ever giving that . 7 instruction, no.
~
8 Q You said_that the only time you discussed 9 saturation in terms of a loss of coolant accident
,- 10 was a large break that drained the pressurizer.
11 Is it a fact that you never discussed 12 saturation as a part of a loss of coolant accident 13 while there was high pressurizer level or solid 14 pressurizer? 15 A That's true. 16 Q I take it the operat' ors were never shown 17 on the simulator a transient in which there was both 18 saturation in the reactor coolant system 'and normal l 19 or full pressurizer water level? - 20 A That's correct. 21 Q After the Three Mile Island accident, 22 B&W augmented its training on operator identification 23 of. loss of coolant accidents, didn't it? () 24 A We were able to expand the scope of the ~! 25 accidents available for the operator to identify. O
1 Lind J50 2 Q After the Three Mile Island accident, b(~N ' one of the points which was included in B&W's 3 training was the existence of saturated conditions in the reactor coolant system is a principal longer 6 term indication of a loss of coolant accident, isn't that correct? 7 8 MR. WISE: Of all loss of coolant g accidents?
. 10 MR. SELTZER: Of a loss of coolant e
accident. 12 THE WITNESS: Repeat that ques, tion, g please. g (Record was read back.) A For certain break ranges. Not for every 15 16 Q After the Three Mile Island accident, 17 18 - greater emphasis was placed on recognizing saturated gg conditions in the reactor coolant system,.isn't that right? A Well, I think a better way to phrase that is a lot more emphasis was placed due to imposed requirements on leaks and those type of accidents l~ we ran a lot more transients after TMI that would , 25 put us in a situation where we would discuss that l l-1
[ 1 Lind 151 C () 2 type of thing. 3 Q Did you help design that training? 4 A Most of that training was specific or C 5 simulator, yes, but those requirements for increased 6 participation in loss of coolant accidents and the 7 emphasis on compound casualties and unrealistic ( 8 multiple, multiple, multiple casualties for the 9 most part were impos e d externally on us and every one 10 of us. ( ,. 11 (Recess taken.) 12 BY MR. SELTZER:
) 13 Q What is a Mollier or Mollier chart?
~
14 A It's a diagram which essentially 15 graphically displays the properties of the steam 16 tables. 17 Q Does it show the point at which '; 18 saturation occurs in a fluid? 19 A Yes, there is a saturation liAe on the 20 diagram. 21 Q In-training at B&W on the handling of 22 a loss of coolant accident, were steam tables or 23 Mollier charts ever used as part of the instruction? 3 ) 24 A I can't recall Mollier diagrams being - 25 used but steam tables were used on occasion if we
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i l 1 Lind 152 ("s g 2 were in a saturated condition that wasn't at a point
\
3 that was easily identifiable. There were certain 4 temperature / pressure combinations that are familiar r 5 to operators as designated saturated conditiong, 6 others aren't, so a lot of times you refer to the 7 ste am tables to determine in fact you are at that ( 8 point or how close. 9 Q Do you have a specific recollection of 10 instructing operators to take out steam tables (. t ! 11 when they had a loss of coolant accident transient? 12 A It's much too long ago for me to remember 13 something like that. , J 14 Q Let me turn now to some questions II5 regarding the discharge pipes that are connected I 16 to valves at the top of the pressurizer. 17 Are you familiar with the concept
; 18 described as the throttling process? '
- 19. A Yes. -
20 Q What does it mean? 21 A It's a term that is generally applied 22 to the dynamics of certain fluid processes, behavior 23 of fluid through an orifice across a valve, and in I I
-24 some instances, it's also applied to centrifugal -
25 pump. characteristics. It's a rather widely used
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C 1 Lind 153 2 term. It's a term used in thermodynamics to . s N[ D 3 characterize certain types of behavior fluid when 4 they were worked upon certain mechanical devices, t 5 Q In a BWR reactor -- 6 A Wrong type. 7 Q In a B &W reactor, is there any place ( 8 within the closed primary loop, in other words, the 9 reactor coolant system without any valves to the
\.
10 outside open or without any breaks, is there any l 11 place where throttling occurs under normal operation? 12 A Without leaving the reactor coolant C( )
~
13 , system pressure boundary? 14 Q Right. 15 A Specifically, does that mean you are f. discounting the relief valves on the pressurizer? 16 17 Q Those are closed. . r 18 A Yes, throttling processes can'be 19 applied to some of the dynamics of the refetor coolant 20 pumps and also to the method used to pressure 21 reactor coolant system flow. 22 Q Before the Three Mile Island accident, 23 did B&W include as a specific part of its training {} 24 program teaching the operators about the throttling - 25 process? l 6 y . 7 w,- ; -w., - v n m--sw - > - - , - - - - , ,-py .--4 ~ ~ ~ ~ - , , - - ,w.-e --wv-e - - . , n e-e-
(I 1 Lind 154 I
-s '
) 2 A The theoretical bases for why a flow 3 detector works or how a reactor coolant pump works 4 were discussed at B&W.
( 5 Q Before the accident, operators were l 6 taught to expect that there would be elevated 4 7 temperature in the discharge pipe just beyond the ( 8 pressurizer if there were a failed open pilot 9 operated relief valve, weren't they?
, 10 .A Yes. . g 11 Q . Was there any training at B&W on what 12 specific tailpipe temperature the operators would
( 13 see if there was a failed open pilot operated relief 14 valve? 15 A The concepts that would need to be ( 16 developed to do those type of calculatio a would 17 more specifically belong in a thermodyn'amics course. 4 i ', 18 ' Q "Would more probably belong," is that 19 what you said? 20 A In a theory course, a fundamental or i 21 basic training course such as would be conducted at 22 a utility rather than at an operations-oriented
- , 23 training-course, I assume, and I can't specifically J) 24 remember us going through any detailed ways to arrive .
25 at a tailpipe temperature.
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i 1 Lind 155
'(c' 2 Q Did you from time to time review the 3 e ntents of the training programs which any of the 4 utilities were giving to their operators?
( 5 A No. 6 Q So you don't know one way or the other 7 . whether any utility's training program included the 8 training on the thermodynamic calculations that would g be necessary to determine tailpipe temperature 10 followingthrottlingthroughapressurgzerrelief 11 valve, do you? 12 A No, the rules and regulations regarding
'I
) 13 contents of training courses, I am familiar with 14 general" fact that a thermodynamics course is taught 15 as part of a basic training of an operator prior to
( 16 the simulator which is at the end of the entire
- 17 operator training period but a specific review of
, 18 any utilitf's very detailed analysis of their course 19 curriculum, we wouldn't do that. ~
20 Q- And you wouldn't know one way or the 21 other then whether any of.the utilities that own 22 B&W plants were teaching their operators about the 23 throttling process and how to calculate discharge
- (T 24 temperatures in the tailpipe, would you?
%.)
25 A No.
$ g* yw y e- yw-p- - - - .
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( 1~ Lind 156 4
} 2 Q The water in the pressurizer under normal
<k 3 operating conditions was about what? 4 MR. WIS E : The water was about what? [ 5 A The water temperature? 4 6 Q Yes. 7 A 650 degrees. ( 8 Q And the steam on top of the liquid water 9 was also 650, right? 10 A That's correct. .. 11 Q If the pilot operated relief valve opened 12 wide and started discharging coolant into the () 13 edis ch arge line, does it follow that the coolant in 14 the discharge line would be the same temperature
~
15 as the coolant that was in the pressurizer? ( 16 A No. 17 Q And the reason it wouldn't is,because of ( 18 the throttling process, right? 19 A That's one of the factors, ye i. 20 Q On the simulat'or, is it correct that 21 when a pressurizer safety valve or the pilot operated 1 22 relief valve opened, the operators would see a high 23 alarm indication on the simulator panel rather than Lfh s/ 24 .a specific discharge pipe temperature? - 25 A That's correct. e - - , , - +=w-- -----p , , - . * , - -eae- g -m+w ,w -- ~-w
l l [ l Lind 157 2 Q So their simulator training was not t l 3 conditioning them for what specific temperature 4 they would observe if there were a failed open pilot ( 5 operated relief valve? 6 A Well, the temperatures were available 7 and I can't say for sure whether or not as a matter ( 8 of course they were shown. Our general policy was 9 that if indications were available to an operator at 10 g a specific utility and we could provide that 11 information, we did so so that if an operator asked 12 what the tailpipe temperature was, that information E
) 13 was available to display to him.,
14 Q What you would be showing the operator s 15 is what his plant's set point was for discharge pipe 16 high temperature alarm, right? 17 A No, we would be showing him t,he actual ( 18 temperature of that fluid. 19 Q How would you find that out? ^ 20 A It's displayed on what we call a digi box 21 which is a device we could use to access parameters ; 1 22 in the computer and display them. Any parameter l 23 calculated in the computer was available on a visual 24 display on the digi box. (G) - 25 Q What exactly was the process by which l
1 Lind 158 2 B&W did obtain from the utilities tailpipe discharge 3 temperatures actually observable at the different 4 B&W plants? ( 5 A We wouldn't obtain that information. I 6 am talking about a display of a parameter that the 7 computer calculated based on the conditions existing ( - 8 in the simulator at a given time.
,9 It is not something which was
( 10 dynamic as being calculated as the transient was 11 taking place. 12 Q You are saying that Rosser had programmed 13 into the computer the ability to simulate the real 14 tailpipe temperature? , 15 A Capabilities in the computer. There are 16 a number of parameters that weren't displayed
~
17 directly on the meter. They had to be' calculated C 18 in order to make the-model behave consistently and ) 19 these were all accessible. 20 Q Do you recall any specific situation in 21 which operators were being trained on a failed open 22 PORV when you, as the instructor or the lead , i 23 instructor, called up the digital reading for tailpipe (O 24 temperature? - 25 A I don't remember specifically myJelf, no.
,- ,, --e, - . , , . - - . ,- , # , y --,,-.v. -- .v.y
C
-l' Lind 159
-s 2 Q And do you have any specific recollection f
3 of knowing that another instructor did that? 4 A No. ( 5 Q At Crystal River, which is a control room ( 6 that you are familiar with, did they have a continuous 7 readout of tailpipe temperature or did you have to ( 8 call it up on a computer printer? 9 A It's been a long time. I don't remember. 4 { 10 I believe it was a printout on the enunciator log 11 which the operator would not have to specifically 12 , call up, it'would be periodically printed as a value 13 ' if it was an alarm condition. 14 Q Does that mean it would be printed out 15 or. the alarm printer? 16 A Yes, again, I don't specifically remember 17 if there were other indications besides't, hat. It's
~
C 18 been a long time. 19 Q Was there an alarm printer in"the 20, simulator control room? 21 A Yes. 4 22 Q It is a fact, isn't it, that !you did not 20 believe before the accident nor believe since the
~(}- 24 accident that the. alarm printer.is useful as a -
25 ' diagnostic tool when a transient is in progress?
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( 1 Lind 160
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A Not as a diagnostic tool, no. t 3 Q It is a fact, isn't it, that you believe 4 the alarm printer is not useful as a diagnostic tool j ( 5 during a transient because it spews out so much data 6 that it's impractical to try and find useful data 7 on the alarm printer? ( 8 A It is my opinion, yes. 9 Q During the time that you were instructor 10 and lead instructor, is it correct that you were not ( t 11 teaching people to use the alarm printer as an aid 4 12 in diagnosing what was happening during a transient? C( ) 13 A That's correct. In fact there were a 1
- 14 number of times the alarm printer wasn't functioning 15 because of mechanical problems with the typer. We 16 didn't feel that was a problem in effect on the 17 simulator because, as I said, we didn't-feel it
( 18 was -- in that type of function a really 'useful 19 diagnostic tool. " 20 Q And by " diagnostic tool," do you'mean a 21 tool for understanding what is happening in the l 22 transient? 23 A At that time. 24 Q At that time, yes. - :- 25 A At that time, yes. 'It's very easy to use-that later to.backfit what had
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Lind 163 2 urred but as an ongoing, as the casualty is-
'I progressing, device for analysis, no, it's not a 3
practical device. 4 Q Later on when the casualty has been l g successfully brought to a Conclusion, is that the 7 time when the alarm printer is useful for developing i . 8 an after-the-fact sequence of events? g A Once the flow of data slo,ws down, which 10 may n t ne essarily mean that the transient has ( ( g been terminated, but there is always a' tremendous 12 inrush of data, all the alarms come on during the r- ' initial part of any transient and eventually a lot 13 g of that w'ill terminate as portions of the system 15 get stabilized and you eventually reach a point in C 16 any transient where the data is not being fed out 37 on the device anywhere near as quickly as it is initially. ( 18 . gg From that point on, you can bggin to use it to start to analyze. You wouldn't necessarily 0 g have to have terminated the-transient but you would. 22 n t use it in the first few moments of a transient because ;you are concerned with actions on the panel-and tha data is coming very quickly.-
- (~T . 24 ,
R.) l . 25 Q. Are you saying that when you have-got'the l-I w:
, g -
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g Lind 162 O 2 Pl ant stabiiized, that is the point at which the i-operators could find it useful to start using the l data and the alarm printer? 4 i
, MR. WISE: What do you mean by s-6 "s 1 zed"?
MR. SELTZER: At the point when the 7 ( g plant is under control. MR. WISE: He described in his answer 10 when he thought the item should become useful. ( , Are you asking him to change his' answer or what? 2 MR. SELTZER: I am asking him to -- 13 Q Are y u saying at the point at which g using the alarm printer would become useful is after 15 the systam parameters have stabilized? 16 MR. WISE: I don't know what.you mean
- by " stabilized" so I will object to the form.
gg You may answer it again if you think you 19
"** 9 *
- 7 *#*" ""'"*** -
A I will give you the same answer, once the initial large amount of data input slows down, you can begin to use it. i Q Would you begin to use it then to check- - on-the current plant-status or to go back into the '
~
I . l 25 - mass of data that was printed out to try and learn 1 p I L _
( 1 Lind 363 (N 2 something and what I am asking you is -- let me [ rephrase it. 3 4 Before the Three Mile Island accident, ( 5 were y u training operators to use the alarm printer 6 during the course of a transient in order to review 7 what had happened in the heat of the transient? 8 A We weren't teaching that at the simulator, 9 n , but I have directly observed that application
, 10 f the alarm printer at plants.
t 11 Q Was there a sequence-of-events printer 12 in the simulator control room? ' 13 A Again, most of the time prior to TMI 14 until the hardware updates, those things weren't 15 reliable enough mechanically. We had a lot of l 16 problems with some of the hardware compon'ont typers
- 17 so we didn't use it that often.
ig Q Why was it not useful to try and use 19 the alarm printer when it was rapidly printing out 20 data? - 21 MR. WISE: You just asked that and he 22 just answered it. 23 A It was just too much information coming 24 ut and the machine would tend to back up because - 25 in some instances, there was so many alarm points w e- si- p @ =
- e 4 --e-=1
f
-1 Lind 164
( 2 coming in simultaneously, the ma, chine could not 3 condition to operate at one time, it would have to 4 back up and retrieve that information later.
- .5 so it would not be large departures from 6 real time but there would be smaller departures until 7 the machine could catch up on the backlog of alarm 8 printers plus a lot of the alarms that were printed 9 were not directly applicable to an analysis of the
, 10 transient because all alarms are typed, not just t
11 alarms that are specifically related to the casualty,
- 12 so there is a sorting process that has to be done.
() 13 Q What do you mean there are' alarms that 14 are printed that are not related to the casualty? 15 A A lot of alarms that will just 16 reflect plant status, operation of systems which 17 would operate that way independent of whether it 18 was an accident, serious transient, _ a minor transient, 19 a normal shutdown. " 20 Q Because ~the printer is printing'out all 21 of these alarms that aren't related to the casualty 22 in addition to the alarms related to the casualty, 23 did it make it difficult to-find the alarms that were ~ 24 relevant to understanding the casualty? 25 MR. WISE: This is getting.awfully vague. l U -
i. 1 Lind 165 2 We are not talking about any specific transient, 3 any specific plant or any specific alarms. 4 We are just going on and on with these general
., 5 , questions and given that we are trying to go 6 on and move this up so we can get Mr. Lind 7 free and the rest of us free so we can finish 8 tomorrow, I must say I' object to the form of 9 the question as vague and indefinite.
10 If he can answer it, I will permit him t 11 to. 12 A It's difficult to sort out information
.( } 13 when there is a very large amount of it in front 14 of you, the typing is'small, it's closely spaced and 15 you have to look at it carefully to find things.
16 It's there, you have to look carefully. 17 Q Returning to tailpipe temperatures, do
. I 18 you know if the method of calculation of tailpipe 19 temperatures, which you said Rosser had put into the 20 computer program, is something that was defined 21 before the Three Mile Island accident in the 22' simulator specifications?
23 A I am not' totally familiar with the
=r^S .24 specifications but we calculated.the pressure, we N$
25 calculated the - dynamics' at the end of the tape in: 1 L.
l 1 1 Lind 166 I~T -2 order to have those two respond correctly in t _( /- 3 relationship to the other, the calculations of 4 what went on in the middle had to be performed so 5 that stuff had to be calculate'd in order to make 6 the model work correctly. You can't have blocks 7 in the middle. 8 Q Would it surprise you if you learned 9 that prior to the Three Mile Island accident, there 10 were operators at B&W facilities who were under i ( 11 the belief that tailpipe temperature downstream of 12 an open pilot operated relief valve would be in () 13 excess of 500 degrees? 14 MR. WISE: I will object to the form 15 but he can answer that. 16 A It would surprise me if they~said 17 anybody in Lynchburg ever told them that but as far 18 as.what they believe, surprise is probabl~y not the 19 best. word in the world, if they said they heard that 20 from someone in Lynchburg, I would be more than a 21 little surprised. 22 Q It is a fact, isn't it, that you believe 23 that the' concept of throttling or the concept of 24 the throttling process is a not obvious concept? (V~)_ 25 MR. WISE: What is meant by "not obvious"?
i 1 Lind 167 m 2 I object. 3 Q Not obvious to operators. 4 MR. WISE: I object. I don't see that
- 5 Mr. Lind can say what is obvious and not 1
6 obvious. 7 I also object that the question is so 8 general as to be irrelevant. Operators have 9 had a lot of training and may have come from 10 many different backgrounds and experiences and 11 you haven't specified which ones you are 12 talking about. * () 13 g Isn't it a fact, Mr. Lind, that it has 14 been your belief that the throttling process is a 15 sophisticated concept that would not be obvious to 16 operators? 17, A Calculations of specific tailpipe , 18 temperatures is more complicated than tha't straight 19 mathematical calculation. It involves soEe concepts 20 which are more sophisticated than just saying, "Well, 21 there is going to be a temperature decrease." There 22 are specific techniques for calculating what that 23 temperature decrease would be across the valve. lN 24 They involve a couple of steps so it is in a sense O - 25 a little more complex than other types of calculations
r s 1 Lind 368 (~'s 2 an operator has to form. k.) 3 Q Focusing on the throttling process and 4 the concepts that are involved such as enthalpy,
; 5 isn't it a fact that you have recognized that the 6 throttling process as a concept is a sophisticated 7 one that would not be obvious to control room 8 operators?
9 MR. WISE: I object again. 10 Q Isn't that something you have told me t 11 in the past? 12 A It's not' intuitively obvious what the
.() 13 temperature is going to be downstream of the valve 14 given what the steam space temperature is.
15 Q And" downstream of the valve" means outside 16 the pressurizer on the nonpressurizer side of the 17 PORV? - 18 A Yes. - ] 19 Q Prior-to the Three Mile Island 2 accident, 20 B&W's training of operators included a casualty that 21 was a weeping pilot' operated relief valve, right? 22 A Yes, that was a malfunction on the 23 simulator.
~S- What does the word " weeping" mean in that 24 ~Q
.) .
25 use? L. _.
I i 1 Lind 169 2 A
) Weeping in that application is a leak 3 rather than a failed wide open valve.
4 Q What were the symptoms, as you recall
; 5 them, of a weeping pilot operated religf valve?
6 A The symptoms would be the same as we 7 discussed earlier as far as symptoms for a small 1 . 8 leak and in addition ultimately additional indications 9 concerning tailpipe temporature and conditions in 10 the quench tank. t l 11 Q I don't understand what you mean, they 12 would be the same as the conditions we discussed 4 () 13 earlier for a small leak. ' 14 A A mass lost from the system manifested 15 as perhaps a small decrease in pressurizer level i ' ^ 16 until the level control valve caught it and then you 17 would see a decrease in the makeup tank level due f 18 to the additional mass having to be added to.the 19 system and an increase in the level in the quench 20 tank, the temperature in the quench tank and then 21 - ultimately an alarm cut the tailpipe when the _22 temperature on'the line got above the normal set l Z3 point. i
- 24 Q Were those conditions'any different from
- 25. -the conditions for a failed open PORV?
- =
- et a W -r -y 4 y 7 9 *a7
\
1 Lind 170 2 A Failed open PORV would differ from a i 3 weeping PORV in terms of the magnitude of the 4 symptoms.
, 5 Q Where would the operator detect that 6 greater magnitude?
7 A He would see a much m6re rapid change 8 in pressurizer level, a much more rapid change in 9 pressurizer pressure, a much more rapid change in 10 quench tank parameters, the tailpipe alarm would r: 11 come on much faster. 12 Q Before the accident, was there any (} , 13 training by B&W on how an operator could distinguish 14 an open pilot operated relief valve from an open 15 code safety valve? 16 A There may have been discussions but 17 I don't remember any specific training. conducted in 18 that area. . 19 Q Let.me show you what has previously 20 heen marked GPU Exhibit 354 which is a memo from 21 G. T. Fairburn to a list of people including J. A. 22 Lind. 23 Do you see your name on the v"T '24 distribution list?
) -
25 A Yes.
~
y Lind 171 Q Is GPU 354 a copy of a site instruction J::) s 3 sent out after the Three Mile Island accident of 4 which you received a copy? A es. 5 t . . 6 Q What was your understanding of the 7 purpose generally of sending out site instructions?
; g A It was a transmittal of information to utilities for which B&W was a vendor.
g It covered a 10 very wide range f subjects.
< e 73 ,
Q Would you look at the second page of 12 GPU 354. Do you see item 3 which lists the symptoms 7N 13 f a stu k open pilot operated relief valve? g4 A Yes. 15 Q Sympt m A is described as " Reactor 16 lant pressure below the reset pressure for the ' 4 77 pilot operated relief valve and decreasing (primary 18 symptom) with (a) Pressurizer level increasing or 19 , indicated high (opposite trend may be possible under 20 ertain conditions) (b) Primary coolant temperature 21 approaching saturation." 22 Prior to the-accident at Three Mile 23 Island, had B&W communicated to operators at its e- 24 plants the fact that pressurizar level increasing ,
'\ '
25 - c uld be a symptom of a stuck open pilot, operated O e - W-- - -me
l 1 Lind 172 ('] 2 relief valve?
,'%.J 3 MR. WISE: Without some idea of a 4 foundation for this witness to possibly answer 5 that question, you can certainly ask him 6 whether he personally had --
7 MR. SELTZER: Don't get so didactic. 8 MR. WISE: -- whether he personally had 9 been involved in doing that or not. 10 MR. SELTZER: All right. I.1 11 Q From your participation in training, 12 do you know whether anybody in the training 13 department was communicating to operators that (J'T 14 pressurizer level increasing or indicated high was 15 a symptom of a stuck open pilot operated relief 16 valve? ' 1 17 A No. . 18 Q No, they were not, to your knowledge? 19 A No, not to my-knowledge. -- 20 Q And you are not aware of any site 21 instruction going out before the accident that 22 informed utility operators that pressurizer level-
- Z3 increasing or indicated high was a symptom of.a s 24
/ 1 stuck open pilot operated relief valve, were you? -
Q j' 25 A I don't. remember one. y -mw y y *--^ w
I 1 Lind 173 l 1
'T 2 Q Before the Three Mile Island accident,
[%.J . 3 are you aware of anyone in the B&W training 4 department telling operators that primary coolant
, 5 temperature approaching saturation was a symptom of t
6 a stuck open pilot operated relief valve? 7 A Not specifically, no, I can't remember L 8 that. 9 Q And it is also a fact, isn't it, that 10 you don't recall any site ine*ruction being sent out 11 before the Three Mile Island accident that told the 12 utilities that had B&W plants that primary fluid ( 13 temperature approaching saturation was a symptom of
~
14 a stuck open relief valve? 15 A Not that I recall. 16 Q And you don't recall any other 4 17 communication to a utility telling them that either 18 pressurizer level increasit.g or high or' primary 19 system approaching saturation was a symptom of a 20 stuck open PORV, _do you? 21 A .Not that I can recall. 22 Q It is a fact, isn't it, that those two 23
. symptoms, Ca) and-(b) in GPU 354, are what distinguish
(~N- 24 a stuck open pilot operated relief valve from the (_) 25. symptoms that would be seen inia normal opening and i
1 Lind 174 2 closing of a pilot operated relief va'1ve? 3 MR. WISE: Are you saying those are the
.. 4 only symptoms that would distinguish it or 5 those are two symptoms that would distinguish 6 it in addition to others, just so the record 7 is clear?
8 Q These are the only two symptoms set out 9 in this list of symptoms supplied by BGW to 10 utilities on May 7, 1979 that distinguish a stuck t , 11 open pilot operated relief valve from a, normal 12 opening and closing of a pilot, operated relief valve, Dt- 13 isn't that right? 4
- ? c .
14 MR. WISE: Well, I d,on't see anything 1 -
'~
15 in this partic,ular -- if you are asking him 16 ,
! to read t'his!particular document add tell you i
17 what it saysi'we can all do that and I don't 18 see anything about that about opening and 19 - closing. ., 20 Q Here is the question. Do you see the 21 symptoms'under 3, Mr. Lind?
~
, 22 A Yes, I do.
23 , Q t There is capital A with two subparagraphs,
, "l >
24 little a an'd little b. There 0 25
~'
there is capital C. is capital B'and Among those symptoms that are ,'
1 Lind 175 a l q 2 set forth, isn't it correct that , it -l's only
,D
~
3 little a and little b that would distinguish a 4 stuck open pilot operated relief viilve from the
, 5 symptoms that would be observed dtsring a normal L
6 pilot operated relief valve openingyand closing?
. ;- s 7 A I would concede that b might be an
. , m ,
f 8 indication, a, not necessarily. 1 . 9 MR. WISE: Y oti are speaking of little b s. 10 and little a?
- t i 11 THE WITNESS: Little b an.d'little a. !
s 12 MR. WISE: That is'not the question that 13 he asked you, though. He asked you whether 14 it was tr,ue that only little a and little b 15 distinguished a normal ra6her than a stuck y 16 open PORV from a normal' opening and closing. 17 So the question is',41s there anything 5 . 18 else in here that you ses ,that would. '* '
?
19 distinguish -- that would also distinguish a , 20 stuck open condition from a normal condition? s 3: 21 That's the question he has asked you. 22 MR. SELTZER: I thought his last an s we r - x 23 responded to that. \' i 24 THE WITNESS: Your rephra ing ofIit -- - l (") 25 c-is also an indication of aN.p o s s ib le - N s.
~
N I
*t
-w K M ' .
,. _.,,..y.---+e--- -~ ~- ~ ' ' " ' ' *"Y"
i' y Lind 176 (. . 7- 2 sustained long duration opening of the valve, O ' f a failed open valve, large C. 3 Q On a normal opening of the pilot operated relief valve following a high pressure reactor 5 ,f V trip, there would be an increase in reactor coolant s drain tank level, right? , I.{. g t E***
\
Q There would be an increase in reactor Coolant drain tank pressure, right, from the steam ( u~ being discharged into the tank? . A Yes.
, (- '
13 Q There would be an increase in temperature
\/
g from the hot steam being discharged into the tank, y\ I '?' wouldn't there? A In rease in what temperature? ' 16 g Q RCDT temperature.
'l A es, up to a limit, it would continue 18 to, increase.
g Q Before the Three Mile Island accident, s (i- , s s 21 did the Lynchburg simulator have a PORV position
' indicator ight?
22-A No. s
-Q Did training instructors at B &W have , .f-] \~'
24 25 - a bank of simulated transients that they could choose g s .-- .9': "1 s 1
, .h'
lp 1 l Lind 177 i 1.
/~
- 2 from in selecting what transients to run on the i
>~ T 3 simulator for their classes?
i 4 A There was a listing of malfunctions in g 5 the book. 6 Q What was the basis for selection of those 7 transients? I 8 A I would like you to elaborate on that 9 question a little bit. 10 3, Q What was the basis for the selection t 11 of the transients that went into the bank or the 12 complete list of all transients that could be run ( 13 on the simulator, that were mvailable to be run on 14 the simulator? 15 A A very large number of those were put into 16 place when the machine was fabricated so'I can't T 17 really talk-about what the mechanism was that 18 determined how those transients were chosen. 19 Generally speaking, additions were made based on 20 actual. transients that occurred at power plants or
- 21 just transients that occurred in the minds of an 22 instructor during discussions or operations which'he 23 thought would be of some training value.
. (^g 24 Q During the time that-'you were^ lead A_/
.25' instructor , who was responsible for. adding new e g -
y n ,y.-wy, -..ve,,w.e .- .c w . - .-,-,,-e +- g w m e, ,r . y. , ,v.m v-%w.~-,--w
1 Lind 178 transients to the bank of potential transients that
- . uld be run on the simulator?
3 4 A All instructors were encouraged to think l 5 f any transients that they thought worthwhile.
- i 6 They were normally cleared through me and then 7 ultimately given to the computer people to augment 8 the actual casualty.
e g Q What do you mean to " augment the actual 10 casualty"?
?
11 A There are specific physical manipulations 12 required to~ enter a casualty and in a case where we 13 wanted to add a casualty, that could be entered by 14 pushing a button that required programming and. 15 hardware modifications. If it.was a program that 16 could be accessed through already.in-place equipmen6, 17 we w uld generally develop a set of instructions explaining to the instructors 18 essentially [a 19 step-by-step process for entering that~ malfunction. 20 Q The lead instructor had to approve any i 21 additions to the casualties to be run on the 22 simulator? Is that your practice? 23 A :Lf we were adding additional malfunctions g4- beyond the'ones-that were candid,-if someone came to .. 25 me and said, "I think it would 'be good if we do l-
,_ . . -, . . . ~ . . . _ . , , _ _ _ _ . . . _ . , . . . _. . , _ . - _ _ _ . _ . _ . , . . . , .
i
'l Lind 179 2 this," I would generally say, "That sounds fine, 3 let's go ahead and see if we can get that into the 4 system."
5 Q Had that been the practice to the extent C 6 you were aware of it when Walter Perks was lead 7 instructor and you were an instructor working under ( 8 him? A 9 When Walt was the lead instructor, 10 everything was put through Walter. i , 11 Q Including additions to the' bank of 12 transients?
. (~s 13 A Everything. _
14 Q Who was responsible for any programming
- 15 changes to the computer for the simulator?
9 16 A Responsible for physically making the 17 changes to the system? 18 Q Well, you said if you approved it and 19 it wasn't something that was already set up on the 20 computer you would have to go to the people who 21 handled programming the computer. 22 A That's correct. 23 -Q Now I am asking who was that? t 24 A That would be Ralph Rosser and Bill O wj 25 Farrell for the softwareLand Jack Brown, Bill Petrie, l y - -- --. , -,- - - -
1 Lind 180 (~% 2 there was another gentleman named George, whose last i 3 name escapes me, who was hardware. It would depend 4 on which of their talents were required to get it 5 in. C 6 Q Do you recall any situation when you 7 were instructor or lead instructor when someone C 8 outside the training section recommended a change 9 in what was being u?.otin on the simulator? 10 A We would periodically get comments from 11 students about --
^
12 Q From student,s? 13 A From students -- about a response in the 14 system which they thought-was not quite right based ' 15 on their having observed that transient on an actual 16 plant. ' 17 Q Did you ever get any recommendations 18 from the engineering department at B&W for showing 19 something on the simulator that you weren't.already 20 showing? Do you recall,any such suggestion? 21 A I can't specifically recall any, no. 22 Q Do you generally recall any such 23 suggestion before the Three Mile Island accident? 24 A No. I g\ x^ .) - 25 Q Were you aware before the Three Mile am m -
[ 1 Lind saa (~ 2 Island accident the simulator could not show the h}- 3 response of the reactor coolant system to saturated 4 conditions? 5 A I was aware of the fact that all aspects 7 6 of saturated response were not included in the model.
- 7 Q Were you aware that the simulator could C 8 not show the response of the system when the 4
9 pressurizer was solid? 10 A Yes. I n
~
11 Q Before the Three Mile Island accident, 12 did it concern you that the simulator could not sh ott
. 13 the response of the system to solid conditions?
14 A Not especially, no. 15 Q Prior to the Three Mile Island accident, s 16 did you believe that the simulator was programmed
'17 to enable B&W to provide adequate training on 18 transient conditions?
19 A Yes. - 20 Q I take it before the accident you never 21 suggested to Ralph Rosser or'any of the other people 22 responsible for programming that thay augment the 23 simulator programming to be able to show the 24 response of the system to solid conditions? 25 A No. g 9 ,pe-9 ~ .c s\- , ,,-e e
E 1 Lind 182 2 Q And I take it before the accident you 3 never recommended that the simulator programming be 4 improved so that more system response to saturation r 5 could be shown? t . 6 A No. 7 (Time noted: 5:15 p.m.) E 8 9 10 John Albert Lind i ( 11 Subscribed and sworn to before me ' 12 this day of 1982. ( '13 . 14 15 l 16 , 17 4 6 ,. 18 .
~ ,
- l 19 ..
20 I l 21 22 23 24 L.q. 25 1 , 1
, . _ _ -. ., ,. . . - . . . . . - - . . _ , . _ , . . . . . .,. - . _ _ , _ ,..,r
( 1 183 2 E E E 11 f.1 C, f,1 E 1 3 STATE OF NEW YORK ) '
- ss.:
4 COUNTY OF NEW YORK )
- r s f. 5 6
I, NANCY A. RUDoLPH , a 7 Notary Public within and for the State of New York, 8 do hereby certify that the foregoing deposition 9 of JOHN ALBERT LIND Was taken before , C 10 ' me on Tuesday, June 22, 1982 ; t 11 That the said witness was duly sworn 12 before the commencement of his testimony and
- c. 13 that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or
- 16 marriage with. any of the parties herein nor 17 interested directly e ' indirectly in the_ matter in 18 controversy, nor am I in the employ of any of th.e 19 counsel.
- 20 IN WITNESS WFJ.REOF, I have hereunto set
( -
<A-21 my hand this O
_' day of July 1982. 22 23 - ht / gNcYx.aooot,H v
. 25
( 184 INDE X , f WITNESS PAGE p John Albert Lind 4 I E XH IB I TS ( GPU - NUMBER FOR IDENT. 560 Resume of J. A. Lind, Jr. 5 E E 561 Three Mils Island Unit 2 Reactor
- Trip Procedure, Revision dated October 25, 1978 12 7 562 Document entitled " Babcock.&
Wilcox, Nuclear Training Center, Lynchburg, Virginia,. Plant Operations Exam" 47 563 Copy of Bsw exam given in
- January 1976 -
73 564 Excerpted page entitled " Reactor Coolant System Pressurizer, . Limiting Condition for' Operation," page 3/4 4-5 ' 117-565 Document entitled "Three Mile Island Nuclear ~ Station, Unit #2 Operating Procedure 21-3-1.3, Pressurizar Operation" 117 566 Section 2.0 from the technical specifications entitled " Safety Limits and Limiting Safety System 1 Settings" 121 G
- , , - e.-, , . - , , ,,,,.n.-, ,a ,, ,,_,y, , , , , . - - ,, -~ -e.-s,p -
- 7
( 185 EXH IB I TS i (Continued) l
. GPU i NUMBER FOR IDENT.
567 Document entitled " Reactor Coolant System, 3/4.4.9 Pressure / Temperature Limits, ( Reactor Coolant System, Limiting Condition for Operation" 127 5
) * * '*
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