ML20072H914
| ML20072H914 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/19/1982 |
| From: | Lanese L GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-06, TASK-07, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290812 | |
| Download: ML20072H914 (129) | |
Text
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1 46c hd i
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UNITED STATES DISTRICT COURT hj ' SOUTHERN DISTRICT OF NEW YORK v.
_ _ _ _ _ _ _ _x ;
l f
4 3 GENERAL PUBLIC UTILITIES CORPORATION, a a
f C .
JERSEY CENTRAL POWER & LIGHT COMPANY, j
METROPOLITAN EDISON COMPANY and i PENNSYLVANIA ELECTRIC COMPANY, ,
Plaintiffs, 80 CIV. 1683 l
- (R.O.) l
_against- .
\ N \
l THE BABCOCK & WILCOX COMPANY and' J. RAY McDERMOTT & CO., INC., : ,
[ i -
s 4 '
Defendants. : ,
-- ________ ____ _ _)_ _ _ _ __x
)'
Continued deposition of GENERAL PUBLIC m -
U .
UTILITIES NUCLEAR CORPORATION by LOUIS C.
LANESE taken by Defe,ndants pursuant to adjournment, .at the offices of Davis Polk
& Wardwell, Esqs.', One Chase Manhattan Piaza, New York,.New York, an Monday, April 19, 1982 at 9:45 o' clock in she forenoon, before Catherine Cook, a Shorthand Reporter and Notary Public,within and for the State of New York.
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j' WALTER SH APIRO. C.S.R. ,
- New YomK. N.Y. 10017 CHARLES SHAPIRO. C.S.R. ., ; l s EPNoNE 212 - 867 8220 a
- - - - - - - - - s. - . . . . ._ _ . . .
470 1
O, s:
(-) 2 Appearance KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
3 Attorneys for Plaintiffs 4
425 Park Avenue New York, New' York By: STEVEN J. GLASSMAN, ESQ.
, -and-6 JOHN EICKEMEYER, ESQ.,
7 of Counsel 1 8 s
9 DAVIS POLK & WARDWELL, ESQS.
10 Attorneys for Defendants One Chase Manhattan Plaza 11 New York, New York RODMAN W. BENEDICT, ESQ.,
- 12 By:
s Of Counsel I
- g. ,,
15 Also Presents
/ '
(s 16 WINA RUFFINI s
17
)
18 7 s
! , ,1 1h 20 .
s j21 ggg 22 23 1
24 l
("N l LJ 25 l 1
- Q 4
471 1
/ \
( having C. LANE S E, 2 L0UIS 3
been previously sworn by a Notary Public, resumed )
4 and testified further as follows:
O 5 EXAMINATION (CONTINUED) 6 BY MR. BENEDICT:
7 Q 'Mr . Lanese, you understand your testimony 8 continues to be under oath?
9 A Yes.
10 Q Do you know that GPU or Met Ed is a member 11 of a group called the B&W Owner's Grpup?
- 12 A Yes, I do.
%/
13 Q I guess GPU is also a member of B&W Owner's 14 Group, is that correct?
15 A I don't know.
Have you had any involvement in Met Ed's or 16 Q 17 GPU's role with respect to the B&W Owner's Group?
10 A Yes, I have.
19 Q Do you attend meetings or have you attended, I
20 in the past, meetings?
l g 21 A Yes.
22 Q What function did you serve at the meetings 23 that you recall attending?
('h 24 A That would depend on the time frame.
(_-)
25 Q Looking at the' period prior to the accident
472 Lonoco 1
time that you rx l Island and starting with the
\'
~' 2 at Three Mile in 1977, j became lead nuclear licensing engineer sometime 3
to Owner's!
what roles can you recall playing with respect 4
e 5 Group meetings?
You are talking about some MR. GLASSMAN:
6 .
7 generalized role?
MR. BENEDICT: What he can recall from that 8
lead licensing period from the time that he became 9
'79.
10 engineer until the accident in March of in February 11 A Prior to the licensing of TMI-2 12 of '78, I was a representative from GPU Service i tee.
i 13 Corporation to the B&W Owner's Group Executive Comm t
\/
the Asymmetrical LOCA Loads 14 I was also the chairman of 15 Subcommittee.
What was the Executive Committee you 16 Q or GPU7 You were the GPUSC representative 17 mentioned?
A GPU.
There was a third function prior to 18 and that was as a 19 the accident and after February, a member of the 20 representative from GPU, but not as 21 Executive Committee.
ll) Is it correct to say that after the license 22 Q
'78 for Unit 2, you changed 23 was issued in February of
! roles with respect to the Executive Committee?
D 24
[O
)
A Yes.
25 l
f
\
473 Lanese 1
n N._,E Q
You stepped down?
2 A Yes.
3 licensing Q
Was that directly related to the 4
O 5 of the plant?
A Yes.
6 0
Why did you change jobs when TMI-2 received 7
8 its license?
A The Executive Committee representative then g
came from Met Ed Company.
There is also a fourth 10 loads?
function. I already mentioned asymmetric LOCA 11 Yes. The Executive Committee prior to 12 Q
(~ N
(. licensing the LOCA loads you were chairman of the LOCA 13 14 Loads Subcommittee, and then post-TMI-2 license in February of '78, you served what function other than 15 16 chairman of the LOCA Loads Subcommittee?
17 A As an attendee at some of the executive 18 group committee meetings.
When did you become a member of the 19 Q 20 Executive Committee?
A At its inception.
21 l
Q Do you recall when that was? .
22 A No, I don't.
23 i
/3 / Q Was it prior to the summer of 19777 N/ 24 A No, I don't know.
25
474 Laneco 1
\
(~J
<- Q Was it prior to your being lead nuclear 2
3 licensing engineer at GPUSC?
- 4 A I don't know.
Q What function did you serve as a member of 5
6 the Executive Committee?
A The purpose of the Executive Commitee was 7
8 to look at engineering and licensing issues that were 9
generic to the B&W plants and, as a committee, to decide to approach the 10 on how to expend resources and how That was my capacity 11 solution of these generic problems.
12 on the Executive Committee.
O t }. Q Prior to your leaving the Executive Committe
\ 13 in February of '78, was every B&W plant holding at least 14 15 a construction permit on the committee?
16 A No.
Q What plants do you recall were represented 17 accurately?
18 or what utilities were represented, more Duke Power, Sacramento Municipal Utility l
19 A i
l Arkansas, Toledo Edison, Florida Power 20 District, .
l 21 Corporation, Consumers Power, and GPU, Met Ed.
ggg Q
Do you recall today whether there are any 22 plants other 23 other utilities which owned operating B&W O 24 than the ones you have named?
! t /
v I object.
25 MR. GLASSMAN:
i 475 Lcnoco 1
there
('N 2 Are you now talking about whether
(_)
were any people on the Executive Committee?
3 MR. BENEDICT: Yes.
4 MR. GLASSMAN: At that time? l 5
MR. BENEDICT:
Let me say what I am getting 6
7 at.
8 BY MR. BENEDICT:
9 g My count is, you have named every utility Am I correct 10 that today has an operating B&W reactor.
11 in saying that?
12 A Yes, that's correct.
13 g Including, and you also named, Consumers 14 which has two B&W units, but neither one of them are on licensed for operation.
15 line at this point or are MR. GLASSMAN: Objection.
16 17 I don't,know whether this witness is 18 competent to answer regarding the status of other !
19 B&W plants.
l 20 0 Is that your recollection or your 21 understanding?
ggg 22 A No.
23 Q It is not terribly important.
Who were the representatives during the 24 (D
( ' ' ' '
/
25 period, let's say, from the inception of the organizatior si
476 Lenoce 1
m
('s /I 2 until you left in February of '78 for each of the 3
utilities you named, if you can recall?
A For Duke Power, Bob Gill, probably, at the 4
5 latter part; and I can't recall the name of the Duke 6 rep.
7 Q Mr. Gill worked for Duke Power?
8 A Yes, but he would have been just for a short 9 time during that period.
10 Q Toward the end?
11 A Right.
12 For Arkansas Power, Dave Martus and Dan Williams and Larry and Gary Young.
(('N
,) 13 Q
Are they brothers?
14 A Yes, twin brothers.
15 For Sacramento, D-a-1 F.-a-a-s-c-h and 16 17 Bob Dieterich.
18 For Toledo, Gene Novak and Fred Miller.
For Florida Power Corporation, I can't 19 20 remember for Florida Power.
Who was there from GPU, Met Ed other than 21 Q l g )
22 you, during that time period?
- l
\
l 23 A Prior to the accident?
Right. Actually, up to the point where you 24 Q r"~} '78.
%_J 25 left.the committee in February of
. I Lanece 477 1
2 A There were other GPU attendees, but I was 3 the representative.
4 Q Who regularly attended with you, if anyone?
h* 5 A There weren't any other regular attendees 6 that I recall.
7 g was there an attendee for Unit 1 from Met 8 Ed?
9 A I don't remember.
10 g Who do you recall replaced you when you 11 left in February of '78 from GPU, Met Ed?
12 A Jeff Fritzen.
13 Q Is it your recollection that you attended 0 14 every Owner's Gro.up meeting from the time the Executive l
15 Committee was created until the time you were replaced l
i 16 on the Executive Committee in February of '787 17 A I don't recall.
18 Q What other purpose, if any, did you serve 19 in your attendance at meetings during the two years 20 immediately prior to the Three Mile Island accident, 21 other than serving on the Executive Committee and serving W on the LOCA Loads that we talked about two weeks ago?
22 t
23 A That was all.
24 g What did you understand the purpose
() 25 generally to be of the owner's Group organization during ,
" ~~" _ . . . . _ _ . . _ _ , _ _ _ . _ _ _ , _ , _ .
Lanoco 478 1
2 the time that you served on the Executive Committee?
(T b A We were attempting to find generic solutions 3
4 to engineering and licensing problems for B&W plants in order to provide cost sharing and a uniform approach lll ' 5 6 with respect to the commission.
Q Was there a B&W representative on the 7
8 Executive Committee?
9 A I don't remember.
10 Q Were certain portions of the Executive 11 Committee meetings intentionally closed to B&W 12 representatives?
13 A Yes, our evaluation of proposals were g-D 14 closed to B&W.
15 Q Was that just for evaluation of B&W 16 proposals or any vendor?
A Evaluation of anyone's proposal.
17 18 Q Do you recall whether there was regularly 19 in attendance a B&W representative?
20 A Yes, there always was.
21 Q You can't recall who that was at this time 9 22 or who they were, if there was more than one?
23 A No, attendance varied.
How were these meetings conducted? Were 24 Q 25 they centered around formal presentations, the Executive
)
i
1 Lnnoco 479 1
2 Committee meetings?
A Portions of the meeting were formal 3
4 presentations, yes.
What form did the remainder of the meetings lll 5 Q 6 take?
A Discussion of agenda items.
7 8 Q Were these dicussions general discussions j l
9 or did people break off into smaller groups?
10 A These were general discussions.
11 Q Were you provided with an agenda prior to 12 the commencement of these meetings?
A sometimes.
) 13 14 Q Otherwise, you would get one at the meeting?
15 A Yes.
16 Q Did you keep a file or any records with 17 respect to your membership on the Executive Committee, 18 separating it for a moment from you LOCA Loads work?
19 A Yes.
Q What sort'of files did you keep?
20 21 A A file of the meeting minutes, formal 22 meeting minutes. .
23 Q Did you take notes at the meetings?
24 A On occasion.
25 Q Did you preserve those notes?
l
}
480 j l
Lnnocs
() 2 A I don't know.
Do you know whether the files that contain 3 Q 4 your material with respect to your Executive Committee work were produced in this litigation?
lll 5 6 A No, I don't.
7 Q Do you recall whether they were given to 8 the lawyers?
9 A No.
10 Q Where are they today, to your knowledge?
In the safety and licensing -- in the 11 A 12 licensing files.
13 Q Where would you go specifically if you were
(
14' trying to find them today?
In our Cherry Hill building on the second 15 A 16 floor in the Licensing Department.
17 Q Is there any other heading or qualification 18 you can put to it to narrow the scope,other than to 19 just say " licensing files"?
20 A No, no, I can't. .
21 Q How long were these meetings typically, 22 if there was a typical?
23 A Usually one to two days. !
24 Q Were they the entire. day?
(~)'
r l
25 A Yes.
1 l
481 1
Lnnoco
('~h k/ 2 Q During that time did you limit your involvement to the Executive Committee meetings or did 3
4 you attend other parts of the Owner's Group meetings?
Maybe I should back up. When the Executive 5
6 Committee met, was it in conjunction with a more general 7 meeting of the Owner's Group?
8 A In general, the structure during that time the 9 frame was that the subcommittee members attended In many cases, they were 10 Executive Committee meeting.
11 one in the same person.
12 Q so during these one or two day meetings, O(__,/ 13 how much of your time would be spent in the Executive 14 Committee and how much of your time was spent dealing 15 with other matters? I don't mean to make that 16 hypothetical.
17 In your recollection, how long was the 18 Executive Committee meeting? How long were they, relative 19 to the remainder of the activities?
20 A Part of the function of the Executive 21 Committee was to review the function of the subcommittees 22 Aside from that period of time, perhaps 20 or 30 percent 23 of the Executive Committee's time was involved in I
/~N 24 Executive Committee activities. i
( ;
L.J 25 Q In addition to the formal meetings and
)
l 1
l
I 482 l Lanese 1
/^s time that d 2 discussion of agenda items, did you during the 3
you served as a member of the Executive Committee have an opportunity to meet informally with representatives
- 4 5
of other utilities during the course of those meetings?
6 A Yes.
7 Q Did you talk shop, talk about work?
8 A Yes.
9 Q Do you know personally the representatives 10 from the other utilities on the Executive Committee 11 other than in the context of their membership, any of 12 the other members?
13 A In general, I do, yes.
have Q
Other than on the ' Executive Committee, 14 15 you worked with Mr. Gill?
16 A Now or then.
17 Q Prior to the Three Mile Island accident?
18 A I don't believe so.
19 Q Were Mr.Raasch or Mr. Dieterich people 20 that you had worked with other than in their membership 21 on the committee, Executive Committe?
22 A only on the subcommittee.
23 Q Which subcommittee?
24 A In that period of time, there was only one, O)
( -
25 Asymmetrical LOCA Loads.
483 Lenoco 1
r~s 2 Q Either one of them were members?
A Yes.
3 Q
How about Mr. Williams and Messrs. Young?
4 Again, only on the subcommittee.
Ih 5 A
6 Q What about Mr. Novak and Mr. Miller?
A Same thing. I don't believe Mr. Miller 7
8 was on the Asymmetrical LOCA Loads Committee.
from the Q
Did you know Mr. Miller other than 9
10 Executive Committee?
A No.
11 12 Q What contact with Mr. Miller other than the r"s committee did you have? Any contact, whether you knew
(_) 13 14 him personally or not prior to the Three Mile accident.
15 Did you have any professional contact with them other 16 than on the Executive Committee?
A No.
17 18 Q Have you ever been to Toledo, Davis-Besse?
19 A No.
Q What was Mr. Miller's position at Toledo 20 .
21 Edison as far as you knew?
22 A I don't know.
Q When was the last time you talked with Mr.
23 24 Miller that you can recall?
r'~T
] A Last Thursday.
25
484 Lcnoco 1
Q What did you talk about?
2 f'T
%-) We were in attendance in an Analysis A
3 Subcommittee meeting. We discussed the Analysis 4
I was being 5 subcommittee, and I also mentioned that llh ~ i 6 deposed on Monday and had been deposed previously.
that?
Q What did Mr. Miller say about 7
A Se mentioned that B&W lawyers had talked 8
9 to him.
GPU lawyers 10 Q Did he mention whether or not 11 had talked to him?
A No, he didn't.
12 Q
Did you discuss with him anything you had 13 r^3
'\J 14 talked about at your deposition?
15 A I don't b'elieve so.
Q Did vou.give a view as to whether it was 16 17 a pleasant or unpleasant experience?
18 A I don't think I did.
of Q What else do you recall about the fact 19 that 20 your discussion with Mr. Miller other than the fact i
21 you told him that you had been deposed and were going 22 to be deposed again today?
A Nothing else.
23 that you Q
Did you discuss with him the fact 24 O had a phone conversation with him during the summer of
'\ _-) 25
Lanese 485 I 1
V(O 19817 2
3 A No.
4 Q Did you, in fact, have a phone conversation 5
with him during the summer of 1981 in which you discussed llh in 6 matters relating to an incident at Davis-Besse 7 September of 19777 8 A I don't remember the date.
9 Q You don't remember the date of the phone 10 conversation that you had with Mr. Miller?
11 A Right.
12 Q Was it a conversation since the Three Mile
-w 13 Island accident?
14 A Yes.
15 Q What was the subject of that conversation?
16 A The transient at Toledo Edison in 1977.
17 Q September 24th transient?
18 A I don't remember the date.
19 Q Do you recall whether it was an upset on 20 the secondary side when the plant was operating around 21 9 percent power and led to a challenge to the PORV which 22 ultimately remained open below its set point?
23 A No, I don't remember that.
When was the first time you heard about an
(~% 24 Q
( )
25 incident occurring at Davis *Besse in September, the I
Lcnoco 486 1
2 incident you discussed with Mr. Miller sometime in '77 (j~'T
\
3 at Davis-Besse?
'77.
4 A I believe it was November What was the context of your hear 4.ng about lll ' 5 Q 6 it?
7 A It was after one of the Execut'ive Committee 8 meetings.
9 Q After one of the Executive Committee 10 meetings, did you talk to Mr. Miller about it? .
11 A Yes.
12 Q Who else was in attendance at this 13 conversation, if you can recall?
r-ks 14 A Mr. Smyth was there for a portion of the 15 conversation.
16 Q Courtney Smyth?
17 A Yes.
18 Q What is his position at Met Ed?
19 A He doesn't work for Met Ed.
20 Q Did he at the time? .
21 A Yes.
22 Q What was his position then?
23 A Unit 2 licensing engineer for Met Ed.
Q Did that make him at the time your opposite 24 t'%
t )
25 number at Metropolitan Edison?
(_/
Lanese 487 1
O C/ APProximately.
2 A
Q Was he the person whom you worked with most 3
4 closely on licensing issues relating to Unit 27 h 5 A Yes.
Slear, David Slear of General 6 Q was Mr.
7 Public Utilities involved in the conversation?
A No, he wasn't.
8 9 Q Who did Mr. Slear work for or what did he do 10 during that period of time, November of '777 A He worked in the Mechanical Component 11 12 Section of GPUSC.
Q Did this conversation take place following 13 14 a meeting of the Executive Committee during an Owner's 15 Group meeting?
16 A I don't. remember.
17 Q Did this conversation occur while you were 18 in attendance at an Owner's Group meeting?
19 A No, it didn't.
f Q
Where did it occur, do you recall?
20 A Outside of the motel we were staying at.
21 l 22 We were waiting --
Q You were staying at that motel -- that 23
,~
24 motel was somewhere in Florida, I take it?
(v\ i 25 A Yes.
l a - _
488 1
L2ncoo 1
You were down there because there was an (O
_) 2 Q 3 Owner's Group meeting?
4 A Yes.
5 MR. BENEDICT: I would like to mark as k
that is headed, 6 B&W 611 a copy of a document November 17, 1977, Place: Florida Power 7 " Dates Corp., Topics B&W Owner's Group Reactor Vessel 8
9 Support Subcommittee."
November 10 (Copy of a document headed " Dates 17, 1977, Places Florida Power Corp., Topic:
11 12 B&W Owner's Group Reactor Vessel Support for
() 13 14 Subcommittee"was marked B&W Exhibit 611 identification as of this date.)
15 BY MR. BENEDICT:
16 Mr. Lanese, have you ever seen what has Q
6117 17 been marked for identification as B&W 18 A I don't remember it now.
19 Q Are you a member of something called the
! 20 Reactor Vessel Supports subcommittee?
21 A That's the Asymmetrical LOCA Loads i
22 subcommittee.
23 Q To the best you can tell, is this document 24 a summary of minutes relating to a meeting that occurred fy
\'~' ) 25 in November of 19777
489 Lanoco 1
.~
2 MR. GLASSMAN: Objection.
( )T The witness just said he doesn't recall 3
4 seeing this document before.
MR. BENEDICT: That doesn't mean that I lll 5 6
can't ask him if it comports with his recollection 7
of what occurred at that meeting.
MR. GLASSMAN: I disagree. You can ask 8
9 what he recollects. If you start comparing a 10 document that he doesn't recall to some meeting 11 he might have been to, it is inappropriate.
12 MR. BENEDICT: I will press this question.
I think it won't go much farther than that.
() 13 14 Read the question back.
15 (Question read)
MR. BENEDICT:
I will withdraw the question.
16 17 BY MR. BENEDICT:
18 Q Does this document refresh your recollection in 19 that the meeting at which you had or which you were 20 attendance when you spoke with Mr. Miller about the .
21 Davis-Besse incident occurred on November 17, 19777
'77, yes.
22 A I remember it was in November of any other 23 Q Do you recall whether there were 24 Bsw owner's Group meetings which included discussions of p
N" .', 25 similar LOCA loads during November of '777 l
l
490 L0noco 1
2 A No, there weren't.
We l Q
Turn to the second page of B&W 611. 1 3
The ;
4 talked about Mr. Slear and Mr. Smyth before. l attendees list in this document includes your name.
llh' 5 any other 6
Do you recall whether there were or GPUSC employees in attendance at the 7 Met Ed, GPU 8 Nover.ber meeting? Do you recall?
9 A No, there weren't.
10 Q Does reviewing a list of attendees refresh 11 your recollection as to any other people who were present when you and Mr. Miller discussed the incident at 12 13 Davis-Besse?
No, there weren't. I should clarify that 14 A 15 during the conversation, we talked about several things.
I know he 16 I don't recall when.courtney was present.
17 wasn't for the whole conversation.
18 Q You recall Mr. Smyth was there for part of 19 the time; you don't recall whether he was there for the is that right?
20 part that Davis-Besse was discussed, i 21 A He was there at the end of the conversation.
22 Q was it at the end of the conversation that i
! 23 you and Mr. Miller talked about the incident in the fall 24 of '77 at Davis-Besse?
m I don't remember.
(-)
i 25 A H
e
491 Lanoco 1
O Q What prompted, if anything, the discussion
(,) 2 3
between you and Mr. Miller at that time?
MR. GLASSMAN:
Are you asking for a reading 4
l 5 of Mr. Miller's mind?
MR. BENEDICT: If Mr. Lanese knows.
6 A
I don't know what prompted the conversation.
7 do you recall, 8 Q Did you approach Mr. Miller, 9 to chat with him? Did he approach you?
10 A The circumstances of the conversation were 11 that Fred was waiting to go out to dinner with some of the other people, and I was standing outside and we began 12 to talk.
[)/
u.
13 What do you recall was the substance of that 14 Q 15 conversation?
16 A I don't recall.
17 g Do you recall any subjects that were 18 covered other than you say you recall that an incident 19 at Davis-Besse was mentioned?
20 A That's all that I remember.
21 Q You do recall that there were other 22 subjects aside from that discussed? .
23 A Yes, there were.
24 Q How long did this conversation take?
7-N] 25 A 10 to 15 minutes.
i 492 Lanoco 1
Q what do you recall Mr. Miller said with 2
3 respect to the incident that occurred at Davis-Besse?
.4 A I don't recall.
You say that was the first time you had lll - 5 Q at Davis-Besse.
- 6 ever heard that there was an incident
'7 Do you recall at that time that you learned 8 at Davis-Besse the PORV had failed open and stayed open its 9 despite the fact that RCS pressure had gone below 10 closing set point?
A I don't recall, no.
11 Miller told you 12 Q Do you recall whether Mr.
13 that there had been an actuation of high pressure
[~h injection during that incident at Davis-Besse?
\~/ 14 15 A I don't know.
16 Q You just don't recall whether he said that i
17 or not?
i 18 A No.
19 Q Do you recall that Mr. Miller told you injection 20 that the operators had terminated high pressure .
4 21 while the PORV remained open at Davis-Besse?
Y 22 A No.
23 Q You don't recall?
> e em 24 A No.
25 Q Do you recall any of the substance of the
- ()
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493 Lcnoco 1
i i conversation?
(_) 2 No, I don't. I'm sorry. I do remember A
3 4
asking Fred to summarize the conversations for Courtney.
The conversation with respect to that?
5 Q l-6 A The transient.
Q What, if anything, do you recall about Mr.
7 Miller's summary? What do you recall from the 8
9 conversation which allows you to place in your mind Miller was discussing?
10 which incident at Davis-Besse Mr.
A only the time frame.
11 12 Q It was September of 1977, as you recall?
I remember we had a conversation in
() 13 A November of '77.
14 15 Q other than that, you can't place the 16 incident?
17 A No.
18 Q Do you recall whether the incident involved 19 an overcooling situation?
20 A No.
21 Q Do you recall whether the situation involved O 22 an upset on the secondary side? )
23 A No.
24 Q Were you interested in what Mr. Miller had g-)
V 25 to say?
l n I
494 Lenoco 1
2 A Yes.
O 3 Q Did you pursue the issue? Did you seek 4 out further information on the transient?
A I don't recall.
lll - 5 Did you request of anybody that you be sent 6 Q 7 the LER on the incident at Davis-Besse?
8 A I don't know.
9 Q Did you know that there had been an LER 10 filed?
11 A I don't recall.
seen the LER, 12 Q Have you ever, until today, 13 for an incident at Davis-Besse,or its supplement?
~ 14 A Not that I can recall.
15 Q Have you ever seen any documentary 16 information with respect to this incident sometime prior 17 to November 1977 at Davis-Besse?
18 A No.
19 Q Do you recall any actions you took with 20 respect to your intereit in the event that occurred at 21 Davis-Besse?
4EP 22 A No, I don't. .
23 Q Did you talk to Mr. Miller at any time prior 24 to the accident, again, about this incident?
25 A I don't know.
(v) ll
495 Lenoco 1
2 Q Do you recall talking to anybody else who V('s worked for Toledo Edison prior to the accident about 3
4 this incident?
A No, I didn't.
lll ' 5 You know you didn't do that, but you don't 6 Q Miller again about it?
7 know whether you talked to Mr.
A That's right.
8 Q
When was the next time you saw Mr. Miller 9
10 following this conversation, if you can recall?
11 A I can't recall.
M Q Did Mr. Miller regularly attend the 13 Executive Committee meeting?
b 14 A At that time, I don't recall how often he 15 attended.
16 Q What was the frequency of the Executive 17 Committee meetings?
18 A Semiannually.
19 Q Do you recall whether you attended any 20 Executive Committee meetings following the November .
21 one that we have been discussing?
O 22 A I believe I did, yes.
in 23 Q But you left the Executive Committee 24 February of '78.
(3 25 Did you continue to attend them even after
'(,/
496 )
Lonoco 1
l A N- 2 you left?
3 A
On occasion, I still attended, yes.
3 l l
Q Did Mr. Miller tell you at the time that 4
you had this conversation in November of '77 that the llk 5 6 pressurizer level had risen at Davis-Besse during a t.
7 time when pressure in the reactor coolant system was s
8 decreasing?
9 A I can't recall.
10 Q Bas there ever, until today, come a time 11 when you learned that fact with respect to the accident 12 at Davis-Besse or incident at Davis-Besse?
A I have heard that before, yes.
O) 13 14 Q What, prior to the Three Mile Island 15 accident, other than your conversation with Mr. Miller, to learning about 16 if anything, did you do with respect 17 this incident?
18 I asked you that question before, but then 19 I went on to specify, did you seek out the LER, did you 20 talk to anyone at Toledo Edison. Is there anything else 21 that you can think of that you did?
MR. GLASSMAN: Objection to form.
22 23 You may answer.
24 A I don't recall doing anything else.
I
(~} in Ns/
25 Q After the Three Mile Island accident a e
- . . - . . - _ - = . _ _ . _ _ _ . - - . . _ _ _
I Lanoco 497 1
/^X I
'd t
2 March of 1979, did you do anything to learn more about 3
the incident at Davis-Bessi in the f a 11', o f '777
+
No, 4, .
4 A ,
- t Have you since the accident, gttether you h 5 Q 6 sought it; or. not , learned more about the incident?
r, 7 A Tes. <
How did you come to learn more about it?
i 8 Q %
MR. GLASSMAN:
Excluding conhedsations with 9 ,
- N ,
10 counsel? ,
s I
11 MR. BENEDICT: If that is his only [
\= s.
c.onversation, I want to know. I don't want to K 12 ,
know the substance.
I V 13 '
\
14 (Question read) N I
15 A I don't recall.
i it 16 Q Do you recall whether you learned about s to the accident c 17 reading published reports with respect 18 at Three Mile Island? .
19 . I don't.think so.
A ,7 JA seen any -
20 Q 1s Do y'ou, recall whether you have 4 1
4 21 documentary' material with respect to the incident that
~ *,
22 occurred in the fall of '77 at Davis-Besse?
l 23 A Yes, I have.
24 Q what do you recall seeing? l
(]
\ _./ '
25 A Mr. Dunn's memo. ' ,,
~
't
. \ Ik i k
- . e, 3 s
,. c
l
'~ ,
i Lanese 498
('N
-V 2 Q That memo is a memo written in February 3 of '78 by Bert Dunn of Babcock & Wilcox.
N. ,
L 4 A I don't remember the date of the memo.
5' Q Do you recall whether you have seen more Is 6 than one memo by Mr. Dunn with respect to the Davis-Besse 7 incident?
s % 3
" ' 8 A I believe there was a follow-up memo I
\
L g.
0% saw also.
10 Q How did you come to see these memos?
) 11< A I believe counsel showed them to me.
' 12 Q The first time you ever saw them was after 13 the Three Mile Island accident?
s
' ' 14 3 yes,
' s V'
, 15 ' Q Following the Three Mile Island accident, is ,
N' .
10 - you testified earlier you recall having a conversation l 'l 17 with Mr. Miller in which the subject of your November IO '77 conversation with him came up.
0
- 19 Did you call Mr. Miller?
'4 CD THE WITNESS: Would you read that again?
s s
- , s J21I (Question read)
{ ~ i+
- ' \22 A I don't recall.
~
'U 23 Q Was it a telephone conversation that you
,7
's , 1 h had with Mr. Miller?
~
. 25 A Yes, $t was.
~
l
-<s
_*L .
m_-___-.a___ ._.__.-._m_..-__--
l l
Lanese 499 g
0 2 g What did you say to him with respect to
'777 3 your conversation in November of 4 A I asked him if he remembered what we talked h 5 about.
g What did Mr. Miller tell you?
6 7 A He said that he told me about it.
g Q About what?
9 A About the incident.
10 g What did he tell you that he had told you?
11 A I don't think he specified.
12 g Did he tell you that he had told you about O 13 operator action with respect to high pressure injection?
14 A I don't know, especially since he was joking 15 about it.
to 16 g What prompted your question with respect 17 this conversation?
18 A I had been asked if I knew anything about 19 the Davis-Besse event by counsel prior to the TMI-2 20 accident.
21 g The syntax of that answer is a little off.
22 You were asked whether prior to the Three 23 Mile Island accident you knew anything about the 24 Davis-Besse accident, but you were asked by counsel after 25 the accident, I take it?
i
500 Lencao 1
()
(~n 2 A That's right.
What did you do in response to this 3 Q 4 question? Did you do anything other than call Mr.
5 Miller?
A I looked through the notes to find the 6
7 time frame of the meeting.
l 8 Q Did you recall that you had this meeting?
A I remember standing outside of the Gulf 9
10 coast Motel talking to Fred that night.
11 Q Did you remember, following the Three Mile 12 Island accident, that you had had a conversation with Fred Miller and that the subject of an incident at
() 13 Davis-Besse in the fall of '77 had come up?
14 I
15 A I didn't even remember the time frame.
16 remember we talked about some incident.
17 Q Do you remember anything specific about 18 that conversation?
19 A No.
Q You called er you and Mr. Miller had a 20 21 Ph one conversation, and I take it you raised the subject
'77, is that right?
22 of this conversation in November of 23 MR. GLASSMAN: What time frame are we 24 talking about?
~'
25 g When you spoke to Mr. Miller after the
1 Lanone 501 i
2 accident?
-O. A The July '81.
3 4 g Is that your recollection of when the g* 5 conversation was?
6 A No, that is what you told me.
7 Q I thought I said the summer of '81.
g .
A You did say " summer of '81.
g g There is a question lurking in there 10 someplace.
11 Did you raise the subject between you and 12 Mr. Miller as to this conversation in November?
13 A Yes, I did.
14 g What was Mr. Miller's response other than 15 to say that he remembers telling you about the incident?
16 A I remember him jokingly telling me, saying 17 "Sure, I told you all about it."
18 Q Did you discuss with him any of the 19 specifics of what he told you?
20 A I'm not sure.
21 g You don't recall whether you did or not?
e 22 A No.
23 Q Did your conversation with Mr. Miller 24 refresh your recollection at all.with respect to the 25 conversation that you had with him?
I
Lanese 502 1
(.
V 2 A No, in fact, I was more confused because 3 I am not sure how much he was pulling my leg.
4 Q Did you speak with Mr. Smyth about this at llk 5 any time since tne Three Mile Island accident?
6 A Yes.
7 Q What did you and Mr. Smyth talk about?
8 A I asked Courtney if he remembered any 9 substance of the conversation.
10 Q When was this conversation?
11 A I'm not sure.
12 Q Sometime after he talked with Mr. Miller?
13 A I don't remember.
14 Q Was it around the same time?
15 A Yes.
16 Q What did Mr. Smyth tell you about his 17 recollection?
That he remembers thinking, "Oh, my gosh, 18 A 19 that would have to be a mess to clean up."
20 Q What was the "that" in his answer?
21 A Water in the containment.
22 Q Water as a result of the open PORV7 23 A Apparently.
(~N,
\_) 24 Q What else, if anything, did Mr. Smyth tell 25 you about that?
I
503 Lencos 1
He remembered that that 2
A That was all.
3 was all that he remembered.
Q He did, indeed, remember, however, some
. 4 discussion with respect to this incident?
llh 5 A Yes.
6 Q Was it he who refreshed your recollection l 7
8 that you had asked Mr. Miller to summarize his accounr? l l
A No.
9 the Q
Did you remember that independent of 10 11 conversation with Mr. Smyth?
1 A Yes.
12 b Q In November of '77 when you were having x/ 13 14 this conversation with Mr. Miller, did you call Courtney 15 Smyth over specifically to allow him to hear what Mr.
show up?
16 Miller was saying or did Mr. Smyth just A He just showed up.
17 Q
other than conversations you had with 18 19 counsel, what, if anything, have you done since the Three to trying to reconstruc 20 Mile Island accident with respect 21 what happened while standing outside the motel in 22 November of '777 .
A As I said, I looked at the meeting notes to 23 try to find the time frame and see if there was any 24
')
[\_/-
25 discussion in it.
.- . . - , ..n. ,,
504 Lanese 1
- p U 2 Q Was there any indication in your notes?
A No.
3 to see whether you 4 Q Did you review your files made any notations with respect to this?
llh 5 6 A Yes.
Q What did you find?
7 8 A No notation.
9 Q Did you ask Mr. Smyth if he jotted anything 10 down about it?
11 A I believe I did.
12 Q What did he respond?
I,s V 13 A He didn't have anything.
14 Q Did you talk with Mr. Slear about this 15 subject at any time, either before or after the 16 accident?
17 A No.
18 Q Mr. Slear wasn't present during the 19 conversation with Mr. Miller?
20 A I'm sure he wasn't present. .
21 Q What else did Mr. Miller say during that 22 phone conversation that related to this issue other than 23 him saying that he had told you all about the accident?
<x MR. GLASSMAN: That.is not the exact
( ,)
24 25 language.
505 1 Lcnoco l
I'll bet you a nickel I 2 MR. BENEDICT:
(gss) .
3 am pretty close. I don't mean to characterize 4 Mr. Lanese's testimony.
G. 5 BY MR. BENEDICT:
Miller say with respect 6 Q What else did Mr.
told you about 7 to this issue other than telling you he 0 the incident?
9 A That's all I remember.
10 What did Mr.
Miller say about having Q
11 talked with the B&W lawyers as you put it?
12 A Just that he had talked to them.
Are we 13 Can you give me the time frame?
14 referring to --
15 Q I am referring to the phone conversation sought to reconstruct 16 you had with him and when you first 17 what happened in November of '77.
talking 18 A There was nothing else said about to B&W lawyers.
20 Q He mentioned that he had?
II A I think he did in that conversation.
ggg 22 Q Did he tell you that he told them about least part ;
23 this conversation that he had with you and at 24 of it with Courtney Smyth?
,es 25 A I don't remember, e
i Lanoco 506 1
('
'~
2 Q What, if any, conversations have you had 3
with Mr. Miller since that first phone call following
. 4 the accident in which the subject of either the November conversation you had with him in Florida or the lll 5 6
incident at Davis Besse in the fall of '77 has come up?
7 A In general, we have just made offhand 8 remarks. We never have had a serious discussion about 9 it. We always joked about it.
I What have you joked about? l 10 Q 11 A I kid him about how I always listen to 12 what he has to say.
/~'N) Is that true, do you always listen to what
\
N' 13 Q
! 14 Mr. Miller has to say when he is talking about nuclear 15 power, at least?
f 16 A I don't.
17 Q What does Mr. Miller, you say, joke about 18 it? What does Mr. Miller joke about?
19 A He kids me about having told me about the 20 event.
21 Q None of what he says has refreshed your 22 recollection as to the substance of what he did tell .
23 you?
24 A As I said, he has always been joking about (es) x_/
25 it, as I put it, pulling my leg.
i
- b. .
507 Lenoca 1
V' Q Have you always known he was pulling your 2
3 leg?
A No.
, 4 Q
Have you ever asked if he is serious when k 5 6
he told you about the accident?
A This Thursday, I did ask him.
7 Q
What did he tell you?
8 A He says he doesn't recall what was said 9
10 during the conversation.
11 Q He does recall the subject of the 12 Davis-Besse incident came up?
S A He didn't even say that, no.
' 13 14 Q You say you joked about it with Mr. Miller and Mr. Miller joked about it with you. I do know about 15 16 this phone conversation you had with him soon after you talked to your lawyers and they had raised this issue of 17 18 what you knew about it, which, I guess, set you off.
19 What other conversations,-if you can 20 enumerate them, with Mr. Miller have you had? .
MR. GLASSMAN: Objection to setting Mr.
21 22 Lenese off.
23 A I can't remember any specifics.
24 Q Why since that first phone conversation
(~')
Q/
25 after the accident have you had any interaction with
508 Lanoco 1
7s 2 Mr. Miller?
(} He is a member of the Analysis Subcommittee.
A 3
Q Asymmetrical LOCA Loads?
4 No, another subcommittee.
lk 5 A MR. BENEDICT: Let's take a break.
6 7 (Recess) 8 BY MR. BENEDICT:
Q Aside from Mr. Smyth, who was present at 9
least for part of Mr. Miller's and your conversation 10 in November of '77, prior to the Three Mile Island 11 12 accident,did you ever bring any of the contents of that 13 discussion to the attention of anyone at Met Ed or GPU?
/~'\
b A Not that I recall.
14 15 Q You said earlier that the first time you 16 recall hearing about the incident that Mr. Miller was is that 17 discussing was when Mr. Miller raised it, 18 right?
19 A When we discussed it, yes.
Q You at this time can't recall any detail 20 21 or any fact related'to that specific incident, I take g
22 it, from that conversation?
23 A No, I remember not understanding it and it.
24 wanting Courtney to hear about gs Do you remember whether Mr. Miller mentione
~# 25 Q H
e
509 Lansoo 1
(,)
l' 2
that the reactor was critical at the time it happened?
l i
A No, I don't.
3 4 Q Today, are you aware that an incident happened sometime in the early fall of 1977 at llh 5 secondary 6
Davis-Besse in which there was an upset on the excursion in the primary 7
side which led to a pressure the PORV 8 system causing the PORV to open and that though 9
ultimately failed open and remained open even 10 that the pressure in the RCS dropped below its closure 11 set point?
12 A I don't know of all those details.
in fact, such Is it your understanding that,
() 13 14 Q
an incident occurred -- I am not asking you to remember I know you weren't 15 specifically that it happened.
16 there.
such a thing 17 Is it your understanding that or read it or have 18 happened, whether you have heard it f
19 been told it? I 20 A What I meant to say before, that I was 21 unaware of all those details.
Q Even today?
22 .
23 A Yes.
24 Q Have you ever heard the expression
( ^')
25 " precursor"?.
Lanese 510 1
[) A Yes.
2 Q
What is your understanding of the meaning 3
. 4 of a precursor?
I 5 A Something that goes before.
6 Q Have you ever heard it used in the context 7 of Three Mile Island?
8 A Yes.
9 Q In what context was it used then?
MR. GLASSMAN: You are talking about 10 11 outside conversations with counsel?
MR. BENEDICT: Absolutely.
12 13 A sometime well after the accident, I came 14 to understand that the Davis-Besse event was a precursor 15 of the TMI-2 accident in some respects.
16 Q By that, do you mean that there were some 17 similarities with respect to the accidents?
18 A Yes.
19 Q After you heard sometime after the Three 20 Mile Island occident that this incident at Davis-Besse .
21 had been a precursor, did you then set out to find any l
22 information about it?
l 23 A No.
I have to correct that statement. Sometime 24
(~)/
\m 25 last summer, I did contact Mr. Miller at Toledo and asked'
511 Lancos 1
2 them if there was a reactimeter available from the 3 transient of '77.
. 4 Q What did Mr. Miller tell you? l lh 5 A He asked me to contact Mr. Sushil Jain.
6 Q What was the answer to that?
That he could provide some printout from 7 A 8 the event.
9 Q Did you obtain that from him?
10 A Yes.
Q What did you do with it?
11 A Gave it to Mr. Broughton.
12 rh Why did you want to get that?
- 13 Q A I believe it was related to bench marking 14 15 or RETRAN code.
16 Q Did Mr. Broughton ask you to get that?
17 A Yes.
that 18 Q Do you know whatever happened to 19 material?
20 A I know we haven't used it for bench marking .
21 Q Do you know if it still exists at GPU?
22 A I don't know.
23 Q where would you look for it or who would know?
24 you ask about it if you wanted to
- ( }
25 A I would ask Mr. Broughton.
512 1
Lnnoso Did you review the material when you got 7-)s 2 Q 3 it?
A I looked at portions of it, yes.
4 Q
was it in the form understandable to you llk 5 6 generally?
7 A One of the problems, it was incomplete.
8 Q Incomplete information?
9 A Yes.
10 Q Did you go back to anyone at Toledo Edison 11 and ask for further information?
12 A I believe I did call and that was all that 7.
13 was available.
14 Q Did you call Mr. Miller about that?
15 A I think it was Mr. Jain.
16 Q Can you recall any other efforts you made 17 to find out information about the incident in the fall 18 - of '77 at Davis-Besse?
A That's all. I can remember the specific 19 of wanting the' data and that was to find out 20 context after a reactor trip, and I 21 feedwater temperatures I 9 22 believe that data was not available. _
Do you recall whether anyone else had 23 Q I
24 expressed any interest with respect to other information f^3-N.] 25 pertaining to Davis-Besse?
I
i Lanese 513 l'
s s
2 A No, the specific interest was in finding 3 feedwater temperature as a function of time after a
- 4 turbine trip.
Other than that, Mr. Broughton did express lll 5 Q 6 to you at least any interest in information relating to 7 Davis-Besse?
8 A No, that wasn't the intention of getting 9 the data. There was no other intention of getting the 10 data.
When did you become lead nuclear licensing 11 Q 12 engineer? According to B&W 603, it says it was in 1977,
[\
\/ 13 but when, if you can recall, during 1977 did you do 14 that?
15 A sometime in the first three to six months 16 of the year.
17 Q Did you receive that promotion at the same 18 time that you became lead engineer for licensing for 19 Unit 2 at Three Mile Island?
20 A No.
l ,
21 Q When did you become lead engineer for 22 licensing of Unit 27 23 A In October of '75.
24 Q What prior to the accident, what did you
)
25 understand the expression " hot functional testing" to
514 l g L0noco 2 mean, if it had a meaning to you?
/')
V I don't know that it did.
A 3
4 Q Did you understand that prior to loading 5
the core that the plant at Unit 2 would undergo testing llk ~
6 which included heating up the water in the reactor 7 coolant system by operation of the reactor coolant 8 pumps?
9 A Yes.
Do you know about when that started?
10 Q A No, I don't remember.
11 12 Q Do you recall whether it was ongoing in 13 September of 19777 p
O 14 A No, I don't.
15 Q Have you at any time before or since the 16 accident become aware of an event that occurred at 17 Three Mile Island Unit 2 in September of 1977 during hot 18 functional testing, in which it was believed, at least the time, that bubbles 19 by certain people on duty at 20 were formed in the hot legs of the reactor during a i 21 depressurization through the pressurizer?
9 22 (Question read) 23 A I don't know.
24 Q I would like to show you a document that has previously been marked as B&W 175 for identification.
(-
O)s 25 e
0 Lanese 515 1
r'"s V 2 and it has been identified as the test logbook for the 3 start-up of Unit 2 covering a certain period which 4 includes September of '77.
I would like you to turn to a document llh 5 6 number which is stamped on "For Production Purposes 7 06068." Before discussing specifically the page I just 8 mentioned, have you ever to this day seen any portion of 9 B&W Exhibit 1757 10 A No.
11 Q Focusing your attention on page 06068 12 which begins with an entry dated the 7th of September, g-V 13 1977 and then proceeds onto page '071, several entries 14 later, to an entry which is dated the next day, 15 September 8, 1977, I refer you to most of the way down 16 the page (indicating).
17 It reads -- these are entries by start-up 18 engineers, as I-have come to understand from prior 19 depositions - " Pressurizer level unexpectedly increased from 20 when venting the pressurizer and decreased pressure 21 500 psig to 460 psig. Pressurizer level increased 22 approximately 150 inches during this evolution."
23 Do you see that, Mr. Lanesa?
(3 24 A Yes, I do.
(_) --
25 g I would like to turn to the next page l
Q
516 1
Lnnoso I should note that I object r~N 2 MR. GLASSMAN:
j j You are carrying on 3
to this line of questioning.
the habit of which we have objected to before of 4
said he delving into documents which the witness lh 5 Davis, Polk 6 had not seen the document before.
7 has refused to let people even ask one more 8 question regarding such a document.
MR. BENEDICT:
I am not asking a question 9
10 regarding this document; I am asking a question regarding his memory.
If you let me finish, which 11 12 I agree is long, you will see where I am going.
(N 13 BY MR. BENEDICT:
which you 14 Q I refer you to material on 0071, 15 said you have never seen before.
I would like to focus 16 your attention on the next page, which starts at about 17 half the way down the page.
in 18 " Pressurizer level indication as shown Started DH-P-1B 19 control room is believed to be correct.
and commenced plant cooldown.
Plant temperature at start 20 .
Whenever RC-V137 21 160*F. Plant cooled down to 100*F.
22 was opened to vent pressurizer, level would indicate i
23 an increase "
24 Turning to the next.page, righr in the
(~Tj another entry dated
' 25 middle of the page, page No. 06073, l
517 Lanoco 1
dated September 9, 1977 reads: " Closed RC-V137 and 2
[V ')
applied nitrogen to the pressurizer.
The pressurizer 3
4 level came down proving that there was a steam bubble in each of the hot legs."
llh 5 Does any of the material that I have read 6
to you, Mr. Lanese, refresh your recollection that you 7
occurring in September 8 have come to know of an incident 9
of 1977 wherein at lease some people thought a bubble 10 had formed in the hot legs of the reactor coolant 11 system?
12 A I have never been aware of any of this 13 information.
'(N Does looking at any of these pages or 14 Q 15 reading any of this material refresh your recollection 16 as to whether or not you have ever seen start-up test 17 logs before?
18 A I have never seen them before.
Prior to the accident at Three Mile Island 19 Q 20 on March 28, 1979, did you ever receive any information ,
j I in the course of your licensing responsibilities which f 21 Ed who were in charge of 22 you thought the people at Met l
23 training operators should be aware of?
i 24 A No.
j % From a time when you became the licensing
(J k- 25 Q H
~ -- , , . . ,
518 1
Lnnoco 2
engineer in charge of TMI-2, which I think you testified
'79, 3
was in 1975 sometime,until the accident in March of 4
did you know who was the head of Training at Metropolitan Edison for operators?
lll
- 5 6 A I would like to correct my previous response. I think there were lots of situations where 7
the operators 8 we provided information in the FSAR that 9 should be trained on.
10 Q By incorporation of the information in the 11 FSAR, your understanding was that that document was is that right?
12 being used by the Training Department, operators were being made aware of the 13 A f-( 14 information in the FSAR.
15 Q Was there ever anything prior to the Three 16 Mile Island accident, was there ever a situation where 17 you knew of information that was in the FSAR and that 18 you thought an operator should be made aware of.that you 19 made a special effort to communicate to people in 20 Training at Met Ed?
21 A No.
O 22 Q Do you know whether General Public 23 Utilities separate from Metropolitan Edison had any 24 responsibility in terms of day-to-day responsibility
(')
'x / -
m 25 with respect to training of the operators?
I don't mean l'
s
ca ,
Lenoco
" "I 519 1
/~N.
legal responsibility. Was there someone at GPU in
(_) 2 3
Parsippany who you knew was involved in training 4 Metropolitan Edison operators? .
A I am not aware of anyone who ever trained lll 5 6 operators at GPU.
Was it your understanding prior to the 7 Q 8 accident at Three Mile Island that operator training 9
with respect to its location within the GPU organization 10 was in Metropolitan Edison?
11 A Prior to the accident, I always thought of operator training as being at B&W.
12 Did you know that Metropolitan Edison had
() 13 Q a training department?
14 15 A I knew they had people who had 16 responsibility for training.
17 Q Did there ever come a time prior to the 18 Three Mile Island accident where you learned any 19 information that you thought that the people at B&W who 20 did training should know about? ,
21 A No.
Other than your recognition prior to the 22 Q 23 Three Mile Island-accident that information within the
- 24 FSAR was available to Training, d,id you provide any
\. j 25 information to Training, to people in Training, whether i
M
520 Lenoco 1
I in GPU, B&W, or Metropolitan Edison?
(~ l 2 A No, I did not.
3 the Q Did you know who was in charge of 4
or who was involved with training in Training Department lll 5 Did you know who that was prior 6 Metropolitan Edison?
7 to the Three Mile Island accident, during the time you 8
were lead licensing engineer on TMI-27 A I knew Mr. Floyd and Mr. Seelinger were 9
10 involved in training at various times during that 11 interval.
12 Q Mr. Lanese, did you ever consider prior to 13 the Three Mile Island accident that any of the the 14 information that Mr. Miller conveyed to you about 15 incident at Davis-Besse should be passed on to people 16 responsible for training?
17 A I never understood the information that 18 Mr. Miller gave me prior to the accident.
19 Q I would like you to refer to a document that It is 20 has previously been marked as B&W Exhibit 419.
21 a document we talked about the last time you were here.
that 22 My recollection of your testimony is 23 you recall receiving all of the material with the exception of the covering letter. Is that an accurate 24 rx
(_) 25 recounting of your testimony?
n i 521 I 1
Lanoco l
2 A Yes.
Q,o 3 Q Did you pass any of that material on to 4 anybody involved with training?
No.
h 5 A 6 Q Did you discuss with anybody who you knew 7 to be involved with training?
8 A No.
Are you aware of whether or not the training 9 Q 10 people were ever provided the information contained in 11 B&W Exhibit 419 prior to the Three Mile Island accident?
12 A I am aware that the operators were informed
~'T 13 as to the requirements of their actions during a small (d break loss of coolant accident at the pump discharge.
14 15 Q That was referring to the operator's role 16 in cross-connecting injection?
17 A Yes.
18 Q When did you learn that had been communicatei 19 to the operators?
20 A Either talking to Mr. Smyth or Mr. Fritzen.
-- I may be 21 Q That's how you became aware 22 confusing you. .
~.
23 Did you become aware of this fact prior to l I
24 the accident at Three Mile Island?
(~%
'- 25 A Yes.
l 1
l l
522 Lenoso 1
,r \
Q You became aware of -- the method you
(_) 2 Fritzen 3
became aware of, it is by talking to either Mr.
4 or Mr. Smyth?
5 A That's what I recall.
llh Q
Prior to the Three Mile Island accident, 6
7 had you ever heard something called the Oyster Creek 8 Risk Assessment Project?
A Yes.
9 10 Q What is that or was that?
It's a probabilistic assessment of various 11 A 12 risks due to the operation of Oyster Creek.
13 Q Were you involved in this project?
( No, I wasn't.
14 A
Q When was this project undertaken, do you 15 16 know?
17 A In the '77, '78 time frame.
18 Q Who was involved with it?
Tom Crimmins, 19 A Mr. Jay Correa of GPU and Mr. j l who, I believe, was at Jersey Central, and Pickard, Lowe,l 20 .
21 E.. Garrick , who were and still are the consultants 22 involved.
You say "and still are." Aro they still?
25 Q 24 A Yes, I believe there is some work on the i
7-N,] project.
25
Lanooo 523 1
cm 2 Q Has there been any written material that
( )
3 you have seen generated by this project?
A It is my understanding -- yes, I have seen 4
5 published reports.
(
6 Q Why did these reports come to you, if you 7 know? Were you given any responsibility?
8 A They haven't come to me.
9 Q Have you had an opportunity to review them?
10 A No.
11 Q As you understand it today, what were the 12 gaals or objects of the project prior to the accident 13 at Three Mile Island?
14 A To define the overall probabilistic risk 15 from the plant and identify what, if any, plant 16 modifications should be undertaken to improve the plant 17 safety.
18 Q Do you know whetherthere is any connection 19 between the Oyster Creek Risk Assessment Project and the 20 WASH-1400 report? e i
I 21 A one was undertaken -- the oyster creek 22 assessment was undertaken subsequent to WASH-1400.
23 Q Does it use the same methods of analysis 24 that WASH-1400 used in your understanding?
r,
" ?5 A As far aa I know.
a
524 Lenoco 1
(.--
Q Do you have any knowledge of any specific is _) 2 3
subjects covered with respect to the components that 4
were covered, for example ~, in terms of risk analysis or probabilistic analysis?
ll 5 don't understand the question.
6 A I Q
I am sure I am not making myself clear.
7 You said that this report
-- one of the 8
goals of this report was to apply probabilistic risk 9
10 assessment to the oyster creek facilities, is that 11 accurate?
12 A Yes.
Do you know what components of the Oyster
() 13 Q Creek facility were studied under this probabilistic 14 15 risk assessment?
16 A No, not specifically.
17 Q What, if any, published material do you 18 know was created by this project prior to the accident 19 at Three Mile Island?
the 20 A the report was published prior to 21 accident, as far as I know, at least in draft form.
to 22' Q What do you understand the ongoing work be with respect to it? Is it a matter of completing 23 they 24 the report that has already been published or are g-(_S) 25 now onto a different project?
3 -
. ; < ~< ,
- s
..' 525 ,
Lanoco 1 '
, i 2 A I don't know.
, ( ) '
LJ 3
g oyster Creek is a boiling water reactor,
,\,
4 is that right? ,
s
~
'\
'Yes. [
h 5 A-
. ~ y 6
g' i This assessment project, relates'to the -
is that 7 oyster Creak facility as it currently exists, ,
\
- 8 right? t 4
9 A Yes. \-
g ,I would like to show you again a document' 10 __
11 that was marked earlier in your 6toosition, B&W 606 12 for identification.
13 I ask you to turn to the page in the 1 ,
s _,
14 document immediately following the file cover, which is 15 marked, for litigation purposes, as Wo26721 3The page- ,
16 I have indicated is a G P U. -Service handwritten' interoffice P
3 g Lanese, " Subject 17 memorandum dated May 1d, 1979,from > ,
L.
18 TMI-2 Rx..." -- I take ic that is reactor? _
_ 8 1.
19 A Ies. ' 1 20 Q
.ef..-.oc Accident Expected vs measurdd .
t s
21 Pres'surizer Level. .
9 22 " Attached are hand calculations which 1
23 estimaEe the expected pressurizer. level for the first 70
- \
24 minutes,of the TMI-2 LCCA." ,N this What did you mean when you prepared
)
b(/_.
25
~
r
~
t-
% 526 1
Lanoco s
f~s. material when you said " expected pressurizer level"?
(_) 2 A I believe that was the collapsed system 3
s ,. s 4 inventory level. Expected level would be the level in the pressurizer assuming that there were no steam voids lll 5
6 in the reactor coolant system, b" What assumptions did you make with respect 7 Q s 8 to the' temperature of the coolant in the system other
. m; z 4
9 than it was subcoolant?
% I use the
~_
10 A I didn't assume subcooling.
11 temperatures that were available from the accident data.
12 Q But you assumed there were no steam voids i 13 in the system?
14 A I assumed tha,t all of the steam voids --
15 assumed isn't the right word. I calculated the level 16 that would occur if.all the steam voids were removed were separated from the from the lower elevations 17 N
18 water.
19 Q Is it accurate to say that you were 20 calculating what the pressurizer level would have been 21 at certain times in the Three Mile Island accident if 22 there were no significant steamvoidswithinthereactorl 23 coolant system except for the top of the pressurizer?
24 A No.
g) tv Where, if anyplace, in the reacter coolant 25 Q
g Lanone system did you assume steam voids would exist for the 2
3 Purposes of these calculations?
4 A The Purpose of the calculation was different g* 5 than what you seem to be implying.
6 g Maybe I don't understand what you are 7 trying to tell me.
g Why don't we try again?
9 A As I recall, we were trying to determine the 10 amount of the steam that existed in the reactor coolant 11 system. One way of expressing the amount of steam voids 12 in the system was to provide a collapsed pressurizer 13 level. It wasn't an attempt to predict the pressurizer 14 level behavior.
15 g But is it true that the figures that you 16 were calculating for what you called the collapsed 17 pressurizer level assumed that there was liquid water 18 throughout the reactor coolant system rather than water 19 in the steam phase except for the pressurizer?
20 A No.
21 Q Where, in the. course of your calculations, l
9 22 did you assume the existence of water in the steam phase 23 anywhere within the reactor coolant system other than the 24 pressurizer?
25 A The calculation didn't require an assumption
I Lanoco 528 1
2 of steam being available. Tt was an inventory y,
3 calculation.
4 Q Did the calculations then indicate what the inventory h 5 the pressurizer level would have been if 6 of steam -- relatively of steam and water in the reactor 7 coolant system had been separated so that all the water 8 that was in the reactor coolant system and the steam, 9 to the extent it existed, was in the pressurizer?
10 A That still is not a correct statement.
11 Q I am having a hard time understanding.
12 Maybe if we move on to specific documents, we can get a 13 little farther.
O)
\.
14 Looking at the page -- the last three 15 digits are '724 -- it is a document that reads, at the 16 top, "GPU Service" and " Subject," and the subject area 17 is blank. In the middle of the page, there is a box "The predicted level increases ,
18 which contains the text:
19 based on HP Injection RCS expansion and losses from the 20 ERV are..." and then a table immediately below it.
21 What is the -- again, maybe approaching this 22 subject, and if you can help me by using.this document, I am 23 what did you mean by " predicted level" in this?
24 correct in saying this is your handwriting?
fm.
( !
25 A Yes, it is.
v l
Lanese 529 1
O 2 Q What do you mean by " predicted level"? (
3 A I meant the amount of water that existed in the reactor coolant system. Water and liquid versus 4
h 5 steam form.
6 Q A method of measuring that is to -- or a 7 method of recording that measurement is by the level in 8 the pressurizer, is that correct?
9 A Yes.
10 Q What you are measuring is the inventory of I
11 liquid water?
12 A Yes. What I am calculating.
O 13 Q Calculating the inventory of liquid water?
14 A Right.
15 Q In the far right margin of the table in the 16 box is the heading " Cum void volume."
17 Is that an accurate reading?
18 A Yes.
19 Q Cum means cumulative?
20 A ,
Yes.
21 Q The figures listed below that are the total 22 quantity of cubic volume in the reactor coolant system 23 that is not occupied by liquid water, is that right?
24 A Yes, it is cubic feet of steam.
25 Q Can you go back to the first page we talked
ll L0noco 530 1
2 about, which was marked '721? It indicates " Attached
s 3 are hand calculations..."
4 Could you go through Exhibit 608 and tell me what it was in your recollection that was attached lll 5 6 to page '7217 Maybe the original exhibit would indicate 7 it. I don't know. We don't have it.
8 A I can't be sure what was attached.
9 Q Turning to page '731, can you tell me 10 whether that page and its following pages were or weren't 11 attached?
12 A I don't recall.
13 Q Turning again to page '731, who prepared f3 14 this form which reads, at the top, " Primary Mass Balance" ?
15 A I did.
16 Q When did you prepare it?
17 A In the spring or, possibly, summer of 1979.
18 Q Was it after the Three Mile Island 19 accident?
20 A Yes.
21 Q Had you ever performed primary mass balance
'. 22 calculations prior to the Three Mile Island accident?
23 A No.
l 24 Q How did you learn how to perform primary
<8
( ,) 25 mass balance calculations?
6
1 Lenoco 531 1
It wasn't a matter of learning. It was a 2 A f"N 3
matter of sitting down and thinking about how to do it.
4 Q Did you create the concept of primary mass llh 5 balance?
6 7 No.
7 Q Did anyone teach you about it or did you 8 recreate it for your own purposes?
9 A Mr. Broughton and I discussed the 10 calculations that had to be performed. I don't remember 11 who decided on the format.
12 Q It was your determination, though, to do it 13 by means of a primary mass balance?
\~- 14 A What we were trying to accomplish was an estimate of voiding in the system. That's the only way 15 16 I'm aware of that we could accomplish it.
17 Q What, in general terme- if you can, can is?
18 you describe for me what a primary mass balance 19 A What this calculation did was take 20 estimates of the amount of water that went into the
(
21 system and amount that went out by way of ERV or PORV, i 22 looked at indicator pressurizer level, versus fuel d
23 pressurizer level, and subtracted the two and interprete 24 the steam volume.
25 Q In the upper right-hand corner, there is a
(,)
Lenoco 532 1
2 box or a list which is headed " Conditions."
[v]
3 Are the conditions which were listed there 4 including the time, temperature hot, temperature cold, average temperature, pressurizer level, were those the lll 5 6 conditions that actually existed during the accident of 7 March 28, 19797 8 A Those were the conditions that I read off 9 the reactimeter.
10 Q For March 28th?
11 A For March 28th.
12 Q How did you calculate the amount of mass or 13 inventory lost through the open PORV?
14 A That was an estimate.
15 g What data did you utilize in order to make 16 that estimate?
17 A Vendor -- manufacturer's data, steam flow 18 versus pressure, and liquid flow versus pressure.
19 Q You also knew the area of the PORV?
20 A i didn't need to know that if I had the 21 other data.
22 Q You didn't need to know how big the PORV 23 was?
24 A No, the vendor gave you the flow of the
/ 'i V 25 valve.
533
~1 Lanoco l
1 2 Q The vendor gave you information related f l(} ^ specifically to the PORV?
3
' 4 A Yes. '
Q You assumed for the purposes of this 5
6 calculation or, I take it, that the vendor's information in its full open position? ;
7 assumed that the valve was 8 A Yes.
9 Q Did you assume for purposes of this 10 calculation that the valve, the PORV, had opened fully 11 within the first second of the accident and had remained 12 in that position throughout the course of that accident?
' 13 A That-war the initial assumption, yes.
14 Q-Was that the assumption you utilized 15 throughout these primary mass balances?
16 A Yes.
17 Q Today, do-you have any reason to dispute or 18 doubt the validity of that assumption?
2 19 MR. GLASSMAN: Objection, no foundation as
~
I~ 20 to whether or not the witness ever 1ooked into 21 that_ question.
MR. BENEDICT: I mean only based on his 22 _
23 knowledge today. I don't mean to suggest that-he 24' did a specific search with respect to it.
25 A I have no'information to lead me ~ to believe
m 534 1
LanOca 2 the valve was or was not fully open.
Q The document that is labeled page '731, 3
4 headed " Primary Mass Balance," includes in the lower it 5
half a box which contains information,in this case 6 hasn't been filled out, but the most left-hand column 7 reads, at the top, " volume cubic feet," and then it 8 lists below it, " Pressurizer, Hot Legs, Cold Legs, Steam Generator, Rx Vessel: Upper head, Core" and 9
10 " Total."
11 The next column over in this table reads 12 " Steam cubic feet," and then has blanks opposite the 13 parts of the RCS that I just read.
O
~
14 When did you first become aware that steam 15 could exist inside the reactor coolant system other than 16 in the pressurizer, putting aside nucleate boiling 17 on the fuel pins?
18 A I became aware that steam could exist in the and that 19 upper head during certain cooldown transients, 20 was sometime before the TMI accident.
21 Q Was that a result of the work you did with 22 respect to the April 23, 1978 event at Unit 2, Three 23 Mile Island?
24 A I did not do that work.
. 25 Q Was it as a result of your reviewing work
0 Lanoso 535 1
2 that had been done or seeing a report prepared on that? 1
(~%
N .] A It was a result of conversations with people 3
4 who did the work or reviewed it.
Q So you became aware of that sometime in the k 5 6
summer of 1978, is that right?
7 A I don't remember when.
8 Q Prior to the Three Mile Island accident?
A Yes, it was.
9 10 Q Did you consider at the time that you 11 became aware of this issue of steam existing in the 12 upper head, whether or not the steam could oxist in 13 other parts of the reactor coolant system, outside of
,-)
\
14 the pressurizer?
THE WITNESS: Could you read it back?
15 16 (Question read) 17 MR. GLASSMAN: Back in that time frame?
MR. BENEDICT: Yes.
18 19 A I don't remember.
20 Q Did you consider at the time that you learned about steam in the upper head as a result of an 21 22 overcooling transient that steam could be generated 23 within the reactor coolant system as a result of a small 24 break loss of coolant accident?
/~
25 A I wasn't aware of that.
( T.,)
l Lanoco 536 1
2 Q Were you aware of it prior to the Three
(~)'g
(
3 Mile Island accident, that steam could exist in the a
4 reactor coolant system outside of the pressurizer as 5 result of a large break loss of coolant accident?
6 A Yes, I was.
7 Q In fact, a ?arge break loss of coolant 8 accident, assuming the most severe break, the vessel, 9 reactor vessel, blow dry completely to a steam condition 10 inside, is that correct before the core flood tanks 11 actuate?
12 A It substantially filled with steam, yes.
13 Q Substantially steam, if not entirely 100 g-L..] 14 percent quality steam?
15 A Yes.
16 Q You indicated that prior to the Three Mile 17 Island accident, you had recognize that steam could exist in the upper head of the reactor vessel. That is 18 19 one of the blocks listed in the second to the left 20 column on page '731 of'B&W 608.
21 Had you ever considered whether steam could 22 exist in any of the other areas listed, with the 23 exception of the pressurizer, the hot legs, cold legs, 24 steam generator, reactor vessel --
C\
25 MR. GLASSMAN: Prior to the accident?
')
I
Lanoco 537 I
2 Q Excluding nucleate boiling in the pins?
(~}
v 3
MR. GLASSMAN: I think it has been asked 4 and answered, but go ahead.
k 5 A Yes, I guess I have to modify the previous 6 answer.
7 Yes, there was a certain consideration 8 about steam voiding occurring in the reactor coolant certain large overcooling 9 system other than the head, 10 accidents.
11 That was the question?
12 g yo, 13 As a result of anything, did you consider
(~N,
%-) steam existing elsewhere?
14 15 A Certainly not as a result of location, 16 and certainly as a result of large overcooling events.
17 Q What did you know, prior to the accident,of 18 steam in the upper head or outside the pressurizer, of 19 large overcooling events?
20 A only as a result of the design basis of .
21 the steam line break accidents that had been analyzed by 22 B&W, that the steam could evolve in the reactor coolant I
23 system.
24 Q Outside of just the. upper head?
25 A For some short period of time, outside the
()
0 538 1
Lnnoco j
2 upper head. j
)
(~'/
\~ Where did you understand that steam would 3 Q 4 exist?
5 A In the hot legs and, for some conditions, 6 in the tubes of the steam generator.
Did the analyses prior to the accident or 7 Q 8 did the understanding that you had prior to the accident, 9
steam existing in the reactor coolant system as a result 10 of a severe overcooling, did you consider the issue of 11 natural circulation in the context of steam existing in 12 the reactor coolant system?
13 A No.
p you U 14 Q You testified that steam would exist 15 understood prior to the accident that as a result of a steam 16 large overcooling transient, you could generate 17 within the reactor coolant system outside of the head 18 and that this steam would exist in parts of the hot leg 19 and upper part of the hot leg and other parts of the 20 tubes in the steam generators.
21 Did you understand that the steam would t
22 come there when the reactor coolant pumps were shut of f ? '
23 A No.
24 Q Is it possible for steam to exist in those I
(~T locations -- did you understand prior to the accident
(_) 25 l
I
Lnnoco 539 1
2 that it was possible for steam to exist in those (S l 5) locations if the reactor coolant pumps were operating? ,
3 l 4 A Yes.
g Is it an accurate summary then of your k 5 testiniony with respect to steam existing in the reactor
^
6 7 coolant system outside of the pressurizer that prior to 8 the Three Mile Island accident you were aware that steam 9 could exist in the upper vessel head and that steam 10 could exist in other important parts of the reactor 11 re ssels , specifically the hot legs and the tubes in 12 the OTSG, at least as a result of overcooling transients, 13 and that you knew that steam could exist throughout the
\.J 14 reactor coolant system at least as a result of large 15 break LOCAS?
16 MR. GLASSMAN: I object to the words "at 17 least." That was not part of the prior testimony.
18 MR. BENEDICT: I will stand by the question 19 and I will remove the "at least" part.
20 A With the understanding that I did not 21 recognize that steam could. exist in the reactor coolant 22 system during a small break LOCA I understood it could
! 23 exist in a large overcooling and large break loss 24 overcooling accident.
O. 25 Q As you used the term "large overcooling"
(,)
I Lonoco 540 1
,f' 2 prior to the Three Mile Island, did you consider the
,,/'
)
3 incident that occurred on April 23, 1978 at Unit 2 to 4 be a large overcooling?
It was an overcooling. I wouldn't classify k 5 A 6 it as a large overcooling event that I referred to 7 previously.
8 Q So you recognize that there was a spectrum 9
of overcooling that could result in steam formation within the reactor coolant system. You recognized that 10 11 prior to the Three Mile Island accident, and that the 12 degree or volume of steam, quantity of steam within the
.- 13 reactor coolant system was related to the severity of v 14 the overcooling transient.
15 A I recognize there could be head voiding for 16 a small overcooling event and for the very large 17 overcooling events, as a result of the pressurizer being 18 voided, that steam could also result in the hot legs and 19 possibly in the top of the steam generator tubes.
20 Q Turning to '736 in B&W 608, did the 21 conditions existing in the upper portion, are those 22 conditions conditions +h.at you understood existed at 23 Three Mile Island two minutes and 15 seconds after the 24 onset of the accident on March 28, 19797 fh x j 25 A That was the data I pulled off of the l
541 1
Lenoco 2 reactimeter.
(]
o 3 Q could you tell me what the last figure is 4
or what the last entry represents in the " Conditions" 5 area? It seems to have a square root sign and the 6 letter "F."
A That's a V, subscript F, and that's the 7
8 specific volume of water at those conditions.
9 Q That would be flowing through the PORV?
10 A No.
11 Q I'm sorry. Maybe if you explained what 12 specific volume is, I will begin to understand.
It is the inverse of density. It is the --
13 A
-}
i a In other words, it 14 Q I think I understand.
t 1 15 is volume relative to its mass.
[
16 A Yes.
)
l 17 Q Reading from the top, where it says 10 " Pressurizer Level," and the level is "225.7 inches," is to 19 that what you read from the data you had with respect 20 the Three Mile Island accident?
21 A Yes.
22 Q That was the indicated level at the unit at 23 two minutes and 15 seconds into the accident, is that 24 right?
,-~.
! )
'> 25 A Yes.
542 Lenoso 1
on the right side, it Q
Then at the bottom, 2
l has " Equivalent pressurizer level" and indicates "193.3" 3
1 4 inches.
for Can you explain to me what accounted G. 5 6
the difference of 30 inches, 32 inches betweeen the it was indicated that day and what 7
pressurizer level as 8
you called the equivalent pressurizer level?
A The assumption in this calculation was that 9
10 that difference was due to steam formation in the 11 reactor coolant system without specifying whsre that 12 steam was being formed.
of the Q
Referring to the box in the middle 13
(~T --
(._) following the word 14 page, it indicates -- the entry 15 immediately to the right of " Pressurizer," which says At the 16 "682.1" cubic feet of steam in the pressurizer.
17 bottom for total cubic feet of steam, "737.1."
18 Where was the additional 50 cubic feet of 19 steam?
A Not in the pressurizer.
20 Q
I take it since you haven't indicated which 21 ggg the 22 of these areas listed, you simply don't know where 23 steam was?
A There was no attempt to locate the steam.
24
[~) 25 MR. BENEDICT: Let's take a break.
k
Lnnoce 543' 1
2 (Rece s s)
/3 b 3 BY MR. BENEDICT:
4 Q Can you, by reviewing the entries that you 5
made under the " Conditions" part of Page '736, tell me 6
yhether any part of the system was at saturated 7
conditions, by reviewing the T-hot, T-cold, T-average, 8 and the pressure?
A Not without a steam table, no.
9 10 Q Is it possible for steam to exist in the quantities we have discussed here, something in the area 11 12 of 50 cubic feet, in the reactor coolant system if the 13 system is not saturated, based on the numbers -- based O on the measurements of temperature-hot, temperature-cold, 14 15 and temperature-average.
16 MR. GLASSMAN: I object.
17 We are not getting expert testimony from 18 Mr. Lanese.
I disagree. I think Mr. Lanesq 19 MR. BENEDICT:
20 is qualified on this one as a 1 actual witness. .
MR. GLASSMAN: You are not asking him a 21 22 fact.
23 BY MR. BENEDICT:
24 Q Is it a fact that you.can have steam in p)
(a 25 the core and, in fact, did have steam in the core at
L0n000 544 1
Unit 2 on March 28, 1979, even though the temperature
(^ 2 V] 3 at T-hot and the temperature at T-average is below the 4 saturation temperature for the pressure within the O. 5 reactor or coolant system?
MR. GLASSMAN: The same objection.
6 7
If you want to ask what analysis he did 8 the question'is inappropriate.
I will press it. I don't 9 MR. BENEDICT:
10 think it is that' complex.
11 MR. GLASSMAN: My objection is not to, 12 really,the complexity of it. You are not on an 13 appropriate track of asking this witness an 7x
(
s/
)
14 appropriate question.
15 MR. BENEDICT: I will take a chance on 16 this one.
17 THE WITNESS: Could you repeat the question?
18 (Question read) 19 MR. GLASSMAN: Also an objection to form.
20 A At two minutes and 15 seconds?
21 Q Yes.
Maybe I can make it clearer. I will strike 22 23 the last question.
24 I understood from your earlier testimony n 25 before you asked for the break that there is 682.1 cubic
()
1 1 Lenoco 545 l
/; 2 feet of steam. calculated to be in the pressurizer at two V You 3 minutes and 15 seconds into the accident.
4 calculated there is 737.1 total in the reactor coolant system including the pressurizer. That means that 5
6 there are 50 or so cubic feet of steam somewhere between 7 the reactor coolant system other than the pressurizer.
8 You haven't indicated where, and you indicated that you 9 didn't make an effort at that point to find out.
10 My question is, neither the system, hot 11 temperature listed here for the system, nor the average 12 temperature listed for the system is at the saturation eg 13 temperature for the pressure you have listed, which is d 14 1600 pounds per square inch, and I am asking whether 15 there are hotter points -- whether you understood at 16 that time that there were hotter points within the 17 system or lower pressure points within the system where 18 steam could exist, other than where the hot temperature 19 is read or where the average reactor coolant system 20 pressure is read?
21 A There could be.
22 Q Didn't you understand at the time that you l 23 prepared the indication that there was 50 cubic feet of l 24 . steam in the system, that, in fact, there was someplace 1 i
,~
j
(,) 25 in the reactor coolant system that was saturated at two L
I LGnoco 546 1
i minutes and 15 seconds?
(~]
C/
2 3 A Yes.
4 Q Turning to page '739 in B&W 608, referring llh 5 simply to the differentiation between the pressurizer 6 level, which is listed in " Conditions" in the upper 7 right, and the " Equivalent pressurizer level" which is 8 listed in the lower right, am I correct in saying that this difference -- your answer with respect to the 9
10 time period of two minutes and 15 seconds after the 11 accident as to why this difference exists is the same 12 at this point?
13 A No.
g3 N 14 Q How can you explain for me the difference 15 between equivalent pressurizer level, listed here,of 16 27.8 inches and the indicated pressurizer level,actually 17 read on the date of the accident at 30 minutes into the 18 accident,of 374.4 inches?
19 A In the previous situation at two minutes 20 and 15 seconds, the most likely explanation was steam 21 voiding in the reactor coolant system, most likely in 22 the upper head. At this point, the pressurizer level 23 indication could be indicative of the PORV being open, 24 rather th'an the pressurizer level being forced up as a A
25 result of voiding in the head. l
() i i
l 1
1
0 Lenoce 547 1
2 Q Or do you mean voiding in the head or g N,
(,)
3 voiding elsewhere?
4 A Or voiding anywhere in the reactor coolant lk 5 system, yes.
6 Q Can you explain to me how the fact that the 7 PORV was open could induce a high indicated or induce 8 this indicated pressurizer level?
9 A This is my understanding now; I don't think 10 it was at the time that I prepared this sheet, but the 11 fact that the PORV is open causes a low pressure region in the pressurizer, which causes water to flow into the 12 13 pressurizer, and the level wouldn't be directly
/,'T Gl 14 indicative of the voiding, only of the differentiation 15 pressure at the top of the pressurizer versus the reactor 16 coolant system.
17 Q Is it your understanding today, then, that 18 there are two forces causing the pressurizer level --
19 there were two forces on the day of the accident 20 causing the pressurizer level to rise, one causing 21 expanding steam outside of the pressurizer and one being 22 the existence of a low pressure area at the top of the 23 pressurizer?
24 A The voiding in the system in the upper head l
r~N
(,) 25 or voiding of the system was only in force at the l
V Lnnoco 548 1
2 beginning. Different pressure was the predominant
/~'s b phenomena afterwards.
3 4 Q You again limited your answer to voiding Do you mean voiding throughout the 5 in the upper head.
(lll 6 reactor coolant system?
7 A It it was, indeed, voiding in areas other 8 than the upper head, yes.
9 g Turning to '742 -- maybe I should go back 10 to '739 for a little bit of follow-up.
11 You indicated that there was -- focusing 12 again on the second column in the box -- you have 13 indicated that there is 209.5 cubic feet of steam in G 14 the pressurizer, 580-1/2 cubic feet of steam in the 15 reactor vessel upper head, and a total of 1312.2 cubic feet throughout the reactor coolant system. That 16 17 indicates to me about 600 cubic feet that has not been 18 specifically accounted for as to location.
19 Did you understand that at 30 minutes into 20 the Three Mile Island accident, did you understand at l
l 21 the time you were preparing this, that the reactor 9 22 coolant pumps were operating? ,
23 A Yes.
24 Q What effect did you understand the reactor
, O coolant pumps had as to the' distribution of steam that 25 I
()
e
Lcnoco 549 1
('~'y 2 existed within the reactor coolant system during the
'J
~
3 time prior to their termination?
4 A Prior to preparing this sheet, I am not v-G* 5 sure how I felt of effect of pump operation on steam 6 distribution.
7 Q Do you have an understanding today as to 8 what its effect was?
9 A Yes.
10 Q What do you understand today its effect 11 was?
12 A It would have kept the steam distributed 13 homogeneously through the upper portions of the reactor 14 or coolant system.
15 Q Do you say " upper portions" because the 16 lower portions of the reactor coolant system were 17 subcooled as a result of passing through the steam 18 generators?
19 A The steam would have been condensed in 20 going through the steam generator. I don't know if the 21 system was subcooled.
22 Q It didn't contain the same proportion of 23 steam in any event, as a result of some condensation 24 of steam in the steam generators?
O 25 A Yes.
(,,i
I 550 I
Lonoco
'2 Q Do you today have an understanding as to
[G') there would be a volume of steam in its 3 whether or not 4 single phase residing in the upper head even during 9 5 reactor coolant pump operation at Three Mile Island?
THE WITNESS: Could you repeat that?
6 }
)
MR. BENEDICT: I think I started out wrong. ;
7 8 Let's strike it and I will try it'again.
9 Q Do you today have any understanding as to 10 whether or not during the Three Mile Island accident, 11 while the pumps continue to operate, there existed 12 within the reactor coolant system a steam bubble in the g-s 13 upper or upper, upper head of the reactor vessel?
14 A I have never considered the problem 15 directly, no.
16 Q So, today, you don't know whether the
' 17 operation of the reactor coolant pumps would actually result in there being a two-phase mixture even within 18 19 the reactor vessel upper head?
20 A I don't know if it would result in or not.
21 Q Turning to page '742 of --
22 A under those circumstances.
23 Q Under those circumstances.
24 Again, turning to page '742, all I want is the entry which appears to n)
(, 25 to ask you about this page
Y 551 Lnncoe 1
2 be in your handwriting in the upper right-hand corner
['m)) of the page, which reads: " Scenario" numeral "2."
3 What did you mean when you wrote that? ,
4 Scenario 2 assumed different high pressure G. 5 A
6 injection volumes.
to the Q
What were you assuming with respect 7
8 psges we have talked to before which didn't have a 9 scenario number indicated?
1 10 A I believe that would have been Scenario 11 or 3 from the Appendix B of the TDR.
12 Q That is something we talked about last 13 time?
-p V A Yes.
14 All of these did assume that the 15 of voiding in the 16 pressurizer level change was a result 17 system.
18 Q But as a result of the fact that you did 19 not know and, I take it, still do not know what the 20 actual flow was for high pressure injection during the 21 periods that you were studying, you had two alternative Jgg 22 scenarios to cover the possibilities, is that correct?
23 A That was one reason.
for doing Q
Were there any other reasons 24
/~N
(_) 25 alternative scenarios?
l Lonoco 552 1
A There was -- these particular scenarios 2
{v) only varied the HPI flow. The ERV flow was also an 3
uncertainty.
4 Q Did you ever do any scenarios with respect 5
the 6
to that, changing the ERV flow and seeing what 7
results would be?
8 A They showed up in one of the figures to g Appendix B that we discussed previously.
Q Looking at page '749 of B&W 608, it says 10 in the upper margin: " Scenario 1."
11 12 Is that again a reference to the scenarios 13 discussed in Appendix B or in the drafts that you 3
%) 14 prepared thereto?
A That's my recollection, yes.
15 16 Q Making a big jump and turning to page '794, 17 this is a GPU Service handwritten interoffice memorandum 18 dated May 21, 1979 from LCL to Reactor Accident Calc.
rate 19 File,
Subject:
" Calculate the pressurizer surge 20 from reactimeter data on pressurizer level."
What was the pressurizer surge rate?
21 9 A That would be the flow of water into and 22 23 out of the pressurizer as calculated from the change
! 24 in pressu'rizer level.
i p)
( m 25 Q What significance at this time did you
Lanoso 553 1
What purpose were you 2 understand this rate to be?
calculating this surge rate? For what purpose?
3 4 A I believe it was to use as a boundary I
5 condition in an isolated pressurizer model.
6 Q By a "model," do you mean a computer 7 model?
8 A Yes.
9 Q Turning the page to '796, it is a document, 10 typewritten at the top, which says " Data transmittal 11 log TMI-2 reactor accident info sent to EI/ Richmond, 12 Virginia."
13 Is this a list of material that you O 14 provided to Energy, Incorporated? !
15 A Yes.
16 Q For what purpose or purposes did you send 17 this material to them?
10 A We were attempting to analyze the response 19 of the reactor coolant drain tank in order to infer the l 20 flow throuuh the PORV during the early portions of the 21 accident.
22 Q Was that project completed?
23 A No.
24 Q Why not?
() 25 A We determined that thinre were too many 4
L
I 1 Lenoco 554 2 unknowns associated with the reactor coolant drain tank
[))
's.
and too difficult an analytical task.
3 4 Q Focusing on the entry opposite of Cal. X h 5 of expended versus measured pressurizer level (not sent 6 to EI)."
- 7 Do you recall today why that material was N
8 not sent to Energy, Incorporated or do you know whether 9 it was subsequently sent?
10 A I think the emphasis there was on the 11 calculations. I didn't send supporting calculations 12 because they didn't need them.
13 Q Could you turn to pages '912 through '921 7-U 14 in this exhibit.
15 Could you tell me what this material is, 16 '912 through '9217 s- r 17 A It appears to be some sort of daily log of 18 plant conditions during the TMI-2 accident.
19 Q Do you recall why it is that you had this 20 material in ycur ft?e?
21 A Yes.
22 Q why did you have it? .
23 A I was looking for letdown flows as recorded 24 in the plant.
r~8 order to help you i 25 This was information in
-(_) Q I
i l
1 Lonoos 555 l
()
k/
2 in preparing what became Appendix B7 m
l 3 A Yes.
4 Q Of B&W Exhibit 171?
h 5 A Yes.
6 Q Do you remember how you came to obtain this 7 document, that is to say what is between pages '112 and 8 '121 inclusive?
9 A I believe it came off of microfilm of this 10 information.
11 Q Do you recall when you got it?
12 A Summer of '79.
g- 13 Q tir . Lanese, have you ever heard of O 14 something called the feed and bleed mode of cooling?
15 A Yes.
16 Q What is that?
17 A It's a mode of cooling the reactor core in 18 which high pressure injection water is introduced into 19 the reactor coolant system and relieved through either 20 the PORV safety valves.
21 Q Is it correct --
22 A Pressurizer safety valves.
23 Q --
feed and bleed does not rely on the 24 steam generators as a heat sink?
g-E_j- 25 A It doesn't require the steam generators,
Lonoco 556 1
2 that's correct.
(J~~]
\
When did you first hear about this mode 3 Q 4
of cooling?
Before the THI-2 accident.
lh 5 ,
A 6 Q Do you recall how much before?
A A year or two before.
7 8 Q What was the context of your coming to 9
hear about his or learning about it?
10 A There was a -- I don't remember why, but 11 there was a desire on GPU's part to review the 12 calculations that had been done by B&W for TMI-1
- 13 regarding feed and bleed cooling.
G 14 Q Is feed and bleed cooling a mode of 15 operation which is discussed or referred to in the 16 TMI-1 FSAR?
17 A I believe it is.
18 Q Do you know whether it is included in the 19 TMI-2 FSAR?
A I don't believe it is, no.
20 21 Q Is it true that the core at Unit 1 can b'e 9 22 effectively cooled within the definition that the NRC 23 puts on that by relying entirely on safety-grade 24 components through the use of the feed and bleed mode?
/7, A No.
ij 25
I 1 Lenoco 557
(~ j 2 Q What components that are not safety grade
, _,1 3 have to be relied on?
4 A PORV -- excuse me. Either the PORV or the lh 5 Pressurizer relief valves.
C Q The code safety valves are in safety 7 grade, is that right?
8 MR. GLASSMAN: Are or were? .
9 MR. BENEDICT: Are.
10 A The question that apparently remains is
. 11 whether they are safety grade with respect to this mode 12 of operation.
13 Q Do you know whether the feed and bleed mode r^3 j
14 of cooling is contained or instructions with respect 15 thereto is contained in either Unit 1 or Unit 2 16 procedures or was contained prior to the Three Mile 17 Island accident?
18 A No, I don't know.
19 Q Do you know whether it is now contained in 20 the Unit 1 procedures following the Three Mile Island 21 accident?
22 A I don't believe that there are explicit 23 instructions for feed and bleed cooling, no.
24 Q Does the feed and bleed mode of cooling
, .m f
i_ 25 result in the reactor coolant system being taken water
Lenoso 558 1
I' 2 solid?
L A It can, yes.
3 4 Q That means that by water solid, am I 5
correct in saying that by water solid the entire system 6 including the top of the pressurizer is filled with 7 water in its liquid phase?
8 A It can result in that condition, yes.
9 Q That would depend, I guess, on whether 10 there was any other breach in the reactor coolant 11 system?
12 A That would be one consideration.
13 Q The high pressure injection pumps at Unit 14 1 and Unit 2 have a shut-off head which is above the 15 pressure set point?
16 A Yes.
I'7 Q Taking the plant water solid at Unit 1 or 18 Unit 2 would result in taking the pressurizer off 19 scale high, is that correct?
20 A Yes.
21 Q How did you understand the operators were 22 to recover from the feed and bleed mode of cooling prior 23 to the Three Mile Island accident?
24 A I didn't have an understanding as to how
(~)',
(. 25 they would recover from that mode.
I Loncoo 559 1
2 Q Did you have an understanding prior to the
(" 's NY accident at Three Mile Island generally how the 3
4 operators would recover from solid operating conditions?
lh 5 A I don't think so.
6 Q Were you aware prio'r to the Three Mile a technical specification 7 Island accident that there was 8 at Unit 2 which specified that the plant was not to be 9 taken over 385 inches on the pressurizer except for 10 hydrostatic testing?
11 A No, I wasn't.
12 Q Did you have any involvement in the 13 preparation or review of the technical specifications 14 for Unit 27 15 A I had some minimal involvement, yes.
16 Q What was that involvement?
17 A on occasions, I transmitted materials 18 prepared by B&W in support of tech specs, and I.believe 19 I reviewed sections of the tech specs.
20 Q Do you recall at this point any sections 21 that you reviewed?
22 A No. .
23 Q Did you keep a file with respect to your 24 work on tecnical specifications?
O
-( ,j 25 A I don't remember.
Lanoco 560 1
2 Q If you were to go back to GPU and try to
/~}
\_/
3 find your files, if any existed on this subject, where 4 would you go?
In the licensing files.
llh 5 A 6 Q Is there a file with respect to tech 7 specifications as far as you recall?
8 A Yes.
9 Q You said that you passed on some support 10 prepared by B&W in support of technical specifications.
11 Did you pass those on to NRC?
12 A No, to Met Ed.
13 Q Do you know what Met Ed did with them?
14 A Incorporated them into the draft tech 15 specs.
16 Q Why were you included in this loop?
17 A B&W normally transmitted the material to 18 GPU, all material in support of licensing to GPU. It 19 was prepared through that contract and it came to us.
20 Q Then you would pass it on as a matter of 21 course to people at Metropolitan Edison?
22 A Yes.
23 Q Did you feel it was part of your ;
24 responsibility to review the material substantively at rN I
(
s ,) 25 the time it came in, material related to tech specs?
Lcnoco 561 1
2 A It depended on eut material.
fr3
(_) Q What criteria did you use to determine 3
4 whether or not you should review material relating to
\
technical specifications for Unit 27 I 5 6 A My understanding of the material contained in the tech specs. If I thought I could review it and 7
8 make substantive comments, I would attempt to.
9 Q To whom did you transmit this material at 10 Metropolitan Edison?
A I believe Mr. Smyth.
11 12 MR. GLASSMAN: Can we take a break?
13 (Recess)
U 14 BY MR. LENEDICT:
15 Q I would like to show you a document that 16 has not been marked.
17 MR. BENEDICT: Mark it as B&W Exhibit 612.
18 Q I ask you if you could look this over and 19 tell me whether you have ever seen this before.
' 20 Identifying it generally, B&W 612 appears l
21 to be a letter from Metropolitan Edison Company, Mr.
22 Herbein, to Mr. Varga at the NRC dated December 20, 23 1977 and Mr. L. C. Lanese is listed as a recipient in 24 the blind carbon copy list on the back page.
r~x J. G. Herbein, Metropolita r,
( ,) 25 (Letter from Mr.
I Lnnoco 562 1
2 Edison to Mr. Steven A. Varga, U.S. Nuclear
(^x,
%} Regulatory Commission, dated December 20, 1977, 3
4 listing Mr. Lanese as a cc on the last page, was llh 5 marked B&W Exhibit 612 for identification as of 6 this date.)
7 BY MR. BENEDICT:
8 Q Do you ever recall seeing this letter or 9 any of its contents before?
10 A Yes.
11 Q Could you describe this briefly for me?
12 A Response to an NRC question regarding 13 long-term cooling, core coolability following a major 14 steam line break accident.
15 Q Did you have any role in' preparing the 16 material attached to Mr. Herbein's letter?
17 A Yes, I did. f 18 Q What was your role?
19 A I prepared portions of it and incorporated 20 information from B&W and other portions of it.
21 Q Whom did you work with at B&W on this-22 subject? .
23 A Mr. Pletke and Mr. Ronald Lovell.
Turning to the second page of the attachmen 24 Q
(~h and the next to the last paragraph on the page, the last
( ,) 25
U 563 Lcncoo 1
2 sentence in that paragraph reads, " Independent of l
(^'J)
%- natural circulation, HPI injection will provide further I
3 4 assurance of adequate core cooling."
'h
- 5 A No.
6 Q What does it refer to?
7 A This is a situation in which due to the 8 large overcooling the reactor coolant system has steam This is not 9 in it and HPI is flowing into the core.
10 feed and bleed.
The addition of HPI water, which is cooler 11 Q a cooling 12 than the reactor coolant water, would have 13 effect. That is what you are referring to?
(3 w/
14 A That's correct.
Q In the fourth paragraph from the bottom --
15 let's refer to the part above that.
In the first full 16 17 textual paragraph of the letter, it indicates that, 18 " Based on the above initial conditions and assuming 2 19 HPI pumps running at 520 gpm, the pressurizer would be 20 completely filled in approximately 15 minutes, assuming .
21 the operator did not throttle JPI flow prior to this 22 time."
23 Do you understand that to be saying that 24 unless the operators throttle high pressure injection, D,
25 the plant will be taking water solid?
.)
I Lcnoco 564 1
A Yes.
(^)
'\_)
2 3 Q It goes on to say that, " Assuming that 4 natural recirculation has been lost in the RCS it can lh 5 be reestablished in several different ways."
6 Natural circulation would be lost in a 7
situation we are discuscing here, as a result of voided 8 conditions within the reactor coolant system?
9 A As a result of shrinkage in the primary 10 coolant system.
Q That would result in there being steam 11 12 voids in the primary system?
'3 A Yes.
O 14 Q By " natural circulation" here, were you 15 referring to natural circulation caused by the convectior 16 of solid water through the steam generators?
17 A Yes, of liquid phase.
18 Q Right.
19 You are not referring to natural circulatio r 20 as a result of a boiler condenser situation?
21 A No.
22 Q Were you familiar at the time that you 23 prepared thic with boiler condenser natural circulation?
l 24 A I don't recall.
3 25 Q Can you describe for me what you understand s_j i
I I
l
I l l
565 1
Lonoco
,- 2 that to mean?
(} Today?
3 MR. GLASSMAN:
MR. BENEDICT: Today.
4 O. 5 A Boiler condenser cooling is a mechanism in travels up the hot 6 which steam is created in the core, steam generator.
7 leg and is condensed in the aware 8 Q Do you recall when you first became 9 of the process of boiler condenser or natural 10 ci.rculation in a B&W plant? Not the actual occurrence theoretically.
11 of it, but the existence of the phenomena, 12 A I don't think I considered it before the 13 accident.
14 Q Anyway, the letter states, " Assuming that 15 natural recirculation has been lost in the RCS it can First, it 16 be reestablished in several different ways.
17 can be reestablished assuming no operator action until 18 after the RCS is in a solid water condition.
19
" Water will be relieved through the 20 pressurizer code safety valves, prevencing 21 overpressurization of the primary system."
gg s 22 What did you understand to be meant by thi 23 passage I just read from these two paragraphs?
24 MR. GLASSMAN: At the time he first saw-it?.
.m
( \
25 Q Is this describing a situation where the i~J w
D 566 Lcncoo 1
s 2 HPI refills the reactor coolant system with water in its (b 3 liquid phase, where even the pressurizer is filled with 4 liquid water?
A Yes.
5 Q
Is that a method of reestablishing natural 6
7 circulation?
8 A It's a prerequisite -- filling the system 9 not necessarily water solid, is a prerequisite to 10 establish single-phase natural circulation.
Q In other words, in order for single phase 11 in 12 circulation, which is natural convection of water, 13 order for that to occur you have to fill up the reactor g
14 coolant system with liquid water?
A Not the entire system.
15 16 Q Excluding the pressurizer for the moment, 17 you have to fill it with water?
A For the most part.
18 19 Q In this letter to NRC that Met Ed was 20 writing, the letter indicates that natural circulation and it 21 can be reestablished in several different ways, lists first, assuming no operator action the system can 22 the 23 be filled up to the point where water comes out is that right?
24 pressurizer relief valve, l A Yes.
(,/ 25 l
1
B 567 Lanoco 1
2 Q That will affect actively reestablishing
/~3 V circulation because it assures that the system is 3 l filled solid with water, is that your understanding l 4
at the time?
Is that what was being driven at here?
5 6 A No.
7 Q Isn't it a fact that -- I am not hure I 8 understand your answer.
In order to have natural convection, you 9
10 told me you have to have the system filled up with 11 water. This letter is recommending certain ways in One of 12 which natural convection can be established.
13 the ways I read this is, system is filled solid 7-)
\~) 14 excluding the pressurizer excluding operator action.
15 Isn't it true, when you wrote this, at the 16 time it was sent, that you understood that that was a 17 method of reestablishing natural circulation?
18 MR. GLASSMAN: Objection as to form.
19 A As far as I remember, I wrote that section.
20 What I meant to say, that the core cooling could be l 21 established.
22 Q Were you referring to feed and bleed in 23 this situation, position, or were you referring to a 24 reestablishment of natural convection?
/~'T A I believe I was referring to feed and bleed
(_) 25
C 568 Lanoco 1
^ ' 2 Q As you say further in that paragraph that i
(G the third full paragraph - "The operator will then 3
4 control plant conditions by taking manual control of and emergency feedwater systems to maintain hot 9 5 the HPI 6
standby conditions or proceed to cold shutdown if 7 desired."
How did you understand the operator would 8
9 maintain hot standby conditions or proceed to cold 10 shutdown in the conditions you described about?
11 A Since this is a non-LOCA situation and the 12 core is cooled, there is no need to continue HPI flow.
13 He can throttle or terminate HPI supply with emergency
-)
(G core decay heat through the 14 feedwater and remove all the 15 steam generators and remove that energy through the 16 atmospheric dump valves.
17 Q So you assumed at the time that you wrote 18 this that the operator would know the cause of the HPI 19 actuation?
A Yes.
20 l
21 Q That he would know it was a result of an g
22 overcooling transient? -
f A Yes. I don't think I even made an explicit 23 l
assumption about that. I assumed he was in an 24 I was thinking about an 25 overcooling situation.
(_/
g 569 Lanoco i
l
~N 2 overcooling situation.
[O Q You understood him to be responding to the 3
4 conditions that he saw? f Responding to a large steam line break 9 5 A
6 accident.
Q The next paragraph reads, "On the other 7
8 hand, if the operator assumes flow control over the HPI 9 system, he can establish natural circulation without He would do 10 putting the RCS in a solid water condition.
11 this by correlatt'ng RC hot leg temperature and 12 pressurizer pressure."
13 What did you understand the correlation --
g-)
'J 14 what correlation would the operator draw? Or what did leg temperature and 15 you mean by he would draw from hot 16 pressurizer pressure?
A He would look at the hot leg temperature 17 and pressurizar pressure and determine if the system 18 19 was saturated or not.
the Q What did you understand would be 20
- I l
21 significance of him determ!ning that?
i g Once the system was no longer saturated, A l 23 he could be assured that he had collapsed steam voids.
/
24 Q In the primary system?
t 25 A specifically in the hot leg.
(,
Lcnoco 570 1
You were talking 2 Q Then what could he do?
(/N,
\_
3 about assumes flow control over the HPI.
4 A Actually, what we were responding to was an NRC concern. You would take the same actions llk 5 6 regardless. He would try to establish the steam 7
generator by controlling the emergency feedwater flow.
8 Q What would he do with respect to high 9 pressure injection after he determined the system was l
10 no longer saturated? l His understanding at the l 11 MR. GLASSMAN:
12 time?
MR. BENEDICT: What he was recommending 13 7-b 14 what the operator would do when he says "he 15 would do this."
16 A He could stop filling the reactor coolant 17 system.
18 Q In other words, he could reduce HPI flow?
19 A Reduce or stop, yes.
20 Q The next sentence reads, "Once the RCS is n
21 pressurized at least 100 psi above the hot leg saturatio 22 temperature, the operator is assured that a solid water 23 condition exists and natural circulation through the 24 core has been reestablished, because of the heat sink 7 ~3
() 25 provided by the isolated steam generator which is being j
Lanoco 571 1
-s 2 supplied with emergency feedwater."
\
(G 3 Pressurizing 100 psi above the hot leg --
- 4 isn't that mixing apples and oranges, psi and temperature? Were you referring to the saturation ll)
- 5 6 pressure at T-hot when you referred to the hot leg 7 eaturation temperature?
8 A Yes.
9 Q Is it a correct reading of this, as you 10 recall when you wrote it, once the RCS is pressurized 11 at least 100 psi above the saturation pressure for the 12 hot leg temperature?
13 A Yes.
t N/
) 14 Q Is that a common formulation, your 15 expression, saturation temperature, or is that a 16 mistake?
A No, that's the way it came from B&W. It 17 18 was clear to me.
19 Q You understood what was meant was that 20 once it is pressurized 100 psi above the saturation 21 pressure for the hot leg temperature?
O 22 A Yes. .
23 Q I would like to show you a document which 24 will be marked as B&W 613 and ask you if you can
! ( ) 25 identify this document.
uJ a '
m 572 Lcnoco 1
(Early draft of document entitled l 2
(^])
\_ " Attachment I, Long Term Cooling Following Steam t 3
613 for Line Break," was marked B&W Exhibit 4
5 identification as of this date.)
g 6 BY MR. BENEDICT:
Could you tell ma what it is?
7 Q 8 A It is an earlier draft of the attachment 9
to the December 20, '77 letter.
Q Did you prepare any portion of this 10 11 earlier draft?
A Yes.
12 Q
Can you identify which portions you 13
(
V 14 prepared?
A I believe I prepared everything with the 15 16 exception of the paragraphs relating to the HPI 17 throttling at 100 psi below the saturation temperature.
18 Q Which paragraphs are those, on page 2 of 19 B&W Exhibit 613?
A Yes, paragraph 3, beginning, " Water will 20 .
21 be relieved..." I believe is some combination of my 9 22 words and B&W's.
The next paragraph was essentially all 23 n
24 B&W's words, and the next paragraph was probably writte by me based on the B&W evaluation. That was the real 25
(_)
I Lonoco 573' 1
2 emphasis of this analysis.
g)
LJ MR. GLASSMAN: Could I hear it read back?
3 4 (Answer read)
~
5 Q Comparing page 2 of the attachment on Bsw ggg 6 612 with page 2 of the draft, which is B&W 613, and "On eur other 7 looking at the paragraph which begins, 8 hand..." the next to the last sentence in the draft 9
reads, "Once the RCS is pressurized at least 100 psi the operator above the hot leg saturation temperature, 10 11 is assured that all steam voids in the piping have been 12 collapsed and natural circulation through the core has 13 been reestablished."
b)
N_ 14 You changed -- this same sentence in 15 paragraph -- in that paragraph in Exhibit 612 reads, 16 "Once the RCS is pressurized at least 100 psi above 17 the hot leg saturation temperature, the operator is 18 assured that a solid water condition exists and natural 19 circulation through the core has been reestablished, 20 because of the heat sink provided by the isolated steam 21 generator which is being supplied with emergency 9 22 feedwater."
23 Did you make the change in the contents of 24 those two sentences? ,
A I don't know.
() 25 1
1 I
i Lanoco 574 1
2 Q You don't recall?
(~N
% ]) No.
3 A
4 Q Who else at GPU worked on this with you?
Mr. Broughton reviewed it.
ll 5 A 6 No one else at GPU that I can recall.
7 Q You don't recall one way or the other how 8 this change came to be?
9 A No.
10 Q Do you know whether there were any drafts 11 other than the one marked as 613 to the attachment of Mr 12 Herbein's letter in 6127 A I don't think there were. There were no 13 f3 14 subsequent drafts.
15 Q Do you recall this as being the first 16 draft that you put together, this being B&W 6137 .
17 A I am not sure.
18 Q What material did you get from B&W.to 19 assemble what became the attachment to 6127 There was a telecopy providing some of 20 A 21 this information and, as I. recall, there was one phone 22 call with Ron Lovell and Mr. Pletke. .
23 Q According to counsel, B&W 612 and 613 came 24 from your files.
to
(~\ 25 Do you have any other files which relate
(_)
575-Lonoco 1
2 this subject?
(~')
L_J A No.
3 Mr. Lanese, I would like to show you a 4 Q document which has previously been marked as B&W Exhibit (jh 5 6
404 for identification, and what appears on the second
" Annotated Sequence of Events."
7 page of the exhibit, 8
Can you review this form me and identify 9 it?
10 A I don't know the source of the document.
Q Have you ever seen this document?
11 A As I recall, I have, yes.
12 13 Q Is it true that this document contains s
CJ) 14 your handwriting on it in some places?
A Yes, it does.
15 Q
Can you turn thrcugh the pages and just 16 17 identify your handwriting where it exists?
18 A Page '0160, 0164, '0165, '0166, '0169.
19 That's all. ,
l 20 Q How about on '01767 .
A No, that's not my handwriting.
21 O 22 Q On the pages that you identified as was there anybody else's 23 containing handwriting by you, 24 handwriting on any of those pages or were those pages pages your all -- was the handwriting on all those (h)
(._
25
u l
576 Lanoco 1
~~
2 handwriting?
(G )/ some of the handwriting was Mr.
A 3
4 Broughton's.
Q When did you first see this document, if 5
h sequence of events, not 6 you can remember, or the 7
focusing on the first page, sequence of events with 8 your handwriting on it?
A Spring of 1979.
9 10 Q Sometime after the Three Mile Island 11 accident?
12 A Yes.
Q Soon thereafter, I take it?
13
(~Y N A At least a month afterwards.
14 Were you given some Q Why did you see this?
15 to it?
16 responsibility with respect the A
Mr. Broughton asked for my comments on 17 18 sequence of events, expecially with regard to makeup 19 and letdown.
20 Q Are the handwritten entries on this the comments you had or did you also 21 sum total of the 22 discuss this with Mr. Broughton?
any substantive 23 A I don't think there were 24 discussions.
r~x i i Q Did you have any involvement in the 25
\_ '
i.
Lanene 577 i
2 initial preparation of this document?
.O 3 A No.
4 g Other than your involvement in reviewing g* 5 this, in particular with respect to makeup and letdown, 6 did you have any other involvement subsequent to the 7
accident with respect to any of the sequence of events 8 prepared by GPU or Het Ed?
9 A I don't believe so.
10 Q Turning to page '0165, there is an entry 11 after 4 minutes and 38 seconds which roads, "In an 12 attempt to gain control of the rapidly increasing 13 pressurizer level the operator throttled the High 6 14 Pressure Injection Isolation Valves (MU-V16A and 15 MU-V16B)." There is a handwritten entry following that 16 which appears to be in your hand, which reads, "to 17 approximately 68 gpm."
18 Is that your handwriting?
19 A Yes.
20 g Did you mean by this entry that at the time you reviewed this, you estimated that the reduction in 21 22 flow of high pressure injection at 4 minutes and 38
=
23 seconds was to approximately 68 gallons per minute?
24 A At that time, that's what-I believed.
25 Q Have you sinc 4 that time revised that view?
r' s d ' .. _ _ _ _ _ _ _ _ _ _ _ . _ _ .__ . _ . _ _ ._ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _
V 578 L noco 1
I A My view is,I don't recall the specifics, but I)
<J 2
to the TDR.
3 my view is stated in Appendix B Other than that, you have no additional 4 Q information with respect to this?
) 5 No.
6 A flow that What is the minimum quantity of 7 Q 16, 8
an operator can obtain by throttling makeup valve injection pump is 9
assuming that a high pressure operating? Is there a minimum or is it infinitely 10 11 varied?
I am not familiar enough with those valves 12 A 13 to be able to say.
^) You aren't aware at this point that it is
%J Q 14 them down below some quantity 15 impossible to throttle 16 one way or the other?
No, I don't know the minimum flow capacity 17 A
18 of the valve.
At least at tha time.you made this entry, 19 Q to 68 gallons per 20 you believed that you could reduce it .
21 minute?
lh A Yes.
Actually, I hadn't thought about the 22 23 question.
for the 68 gallon' Q
What basis did you have 24 p
4 i 25 per minute number? !
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6
~
579 Lnnoco 1
A That was based on the makeup tank level 2
f~')
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3 response.
Q You didn't consider in the course of doing 4
I 5 the analysis that went into this number or the analysis 6
that went into the Appendix B to B&W Exhibit 171, the through these valves?
7 mechanistic aspect of flow 8 A I hadn't at this time. I am not sure I 9 didn't subsequently consider it.
10 Q If you had,it would have been prior to 11 your preparation of Appendix B7 12 A Yes.
I am showing you what has been marked as Q
'"g 13 404, which (G 14 B&W 607 -- one last question on B&W Exhibit was the " Annotated Sequence of Events."
15 Were you aware at the time you were 16 17 reviewing this that an LER with respect to the Three 18 Mile Island accident was in preparation at General the NRC7 19 Public Utilities for submission to A I don't know.
20 Did Mr. Broughton say anything to you abou t 21 Q s
there was going to be a sequence of event 22 the fact that to 23 included in any submission that was going to be made 24 the NRC?
I' I A No.
\s' M
Lanoco 580 1
Did you have any reason to believe that 2 Q
[V') exists in 404 3
the material you were reviewing and that 4
would ultimately be included in the filing with the NRC7 A No.
5 6 Q Now, turning to B&W 607 and looking at the 7 page that has been marked for this litigation WO28118 8
Mr. Glassman has been good enough to put the original of I am having a hard time 9 your notebook in front of you.
reading your handwriting -- could you read for me the 10 11 full paragraph below the entry concerning criteria which failure" or " Single 12 'begins with the words " Single 13 failures"?
U(~N A " Single failures - will consider check 14 valves and safety / relief valves; otherwise we'll use 15 if looked 16 standard single failure analysis. Reason:
17 at integral probability of failure for plant, these 18 components are judged to be significant contributors; also systems may be dirty and cause check valves to 19 20 stick open."
MR. GLASSMAN: So it is clear, we are 21 22 reading from a page which appears to be under the date of May 1, 1979. That date appearing 23 24 actually appears on the prior page of this l 7
i (~'T .' l kl 25 document. l I
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/N BENEDICT:
Right.
N' MR, 3
' 3 BY MR. BENEDICT: were What analysis do you recall you Q
4 or in this whole entry?
referring to in this passage 5
recall, would have been related This, as I 6
A condition. ,
and its post-accident 7
to an analysis of TMI-2 I
understand, fully what you 8 Q I am not sure "in its post-ac:ident condition."
9 mean:by do with thec >
f Do you moan'the analysis had,to i 10 fdlure cubsequent to the' accident?/ ):
3 A
11 likelihood of a and . a f ter'
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subsequent v,
to thojaccident '
A ps 12 -
talled for removing the
%- 13 additional systems had been ins '
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14 decay heat.
r>21s analysis being,' done?J r, Q For whom was ,
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' It was being done[for .s GPU. i>m1 16 .
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Yes, g
' A / .* s you are ;
21
I What are t!,ilt> exceptions to,tho .
22 ! Q cingle <
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check valves and safety and/or relief
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4 valves.
Q why did you raise those as something that (ll 5 6 may need consideration beyond the single failure 7 criteria?
r 8 A Normally, these components were considered
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passive and weren't necessarily included in the scope of 9
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Q In other words, you didn't even have to s 11 12 assume that one of them failed?
i A Not necessarily, no.
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Q Let me rephrase the question and get it 7 14
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N As I un.derstand this passage, it relates to 16 L k, -
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19 were you considering applying a more
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stringent M cy
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A More stringent.
21 a / ([ i b I In what respect would it be more stringent?
22 Q 3
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failure of those components be considered.
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In other words, the single failure 3
criterion, as it was applied prior to the Three Mile 4 i I 5 Island accident, is that correct? ;
A As it is still applied.
6 include the pilot Q
Did any of these valves 7
8 operated relief valve?
A It could have been included, yes.
9 10 Q Were you concerned here with analysis that is to say the May 1st 11 pertaining to the current --
12 condition of the plant?
13 A I think it was both the May 1 condition of (x
%..) the plant and the subsequent condition of the plant.
14 15 Q It was not the condition prior to the 16 Three Mile Island accident?
A Definitely not.
17 18 Q Turning to page '120, the last three 19 numbers, looking under a date "May 3, 1979," which starts with block printing, which I can read,." Drain 20 21 Tank," What does the remainder of that entry say?
A " Tom Witbeck, 5/3/79."
22 .
23 Q Keep going. What is contained on the 24 remainder of that page?
,rx A " Tank pressures have no temp data recorded;
'N J 25
584 Lnnoco 1
2 no level recorders cooling is manually initiated."
(\_)) Does that say " actuated" or " initiated"?
3 Q 4 A " Actuated."
"No indication (yet) of manual initiation.
5 Ilh 6 MU and letdown.
No log of valve position."
Q What does this entry in your logbook relate 7
8 to?
A Apparently a conversation with Tom Van 9
10 Witbeck of Energy, Incorporated and related to an 11 attempt to collect or find out what plant data was 12 available regarding the drain tank.
13 Q Were you trying to collect data from Mr.
,e~g O 14 Van Witbeck or was he trying to get data from you?
I was trying to find out what data was 15 A 16 available from him.
17 Q For what purpose did you want data related 18 to the reactor coolant drain tank?
19 A I would have to assume it was related to 20 the drain tank analysis. .
Generally, what were you doing? What was ,
21 Q l 22 the purpose of the drain tank analysis, as you call it?
23 A It is what I described before, an attempt ,
24 to determine the flows out of the PORV.
l
/
(~') Q That ultimately was abandoned
(> 25
0 Lenoco 585 i 1
1 2 A Yes. ;
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3 Q -- because insufficient information 4 existed?
5 A Among other reasons.
I)lh 6 Q what other reasons besides scarcity of 7 information?
8 A I wouldn't say it's a scarcity of 9
information, but there were certain valve positions that 10 we couldn't be assured of. The other main reason is 11 that there was no good analytical tool available to 12 analyze this situation.
13 Q was the drain tank study generally done (s)^' as part of your attempt to determine the inventory in 14 15 and the inventory out of the reactor coolant system 16 after the accident?.
17 A Yes.
18 Q By inventory, I mean water.
19 A Yes.
20 Q Turning to page '125, about the lower third 21 of the page, it reads, "TMI-1 originally had a Dresser 1, 2, 3 and CR-1." I can't 22 solid wedge like Oconee 23 read the remainder of that. It says 24 A "Oconee plus TMI-1, it stuck closed quite
/T 25 oftens fixes did not work."
( ,/
I Lenoco 586 1
2 Q What valve were you discussing here?
f~]
U 3 A I believe that is the PORV block valve.
4 Q What was the source of this information?
Mr. Lee Pletke and Mr. Harry Henig of B&W.
llI 5 A 6 Q Had you known prior to the accident at 7
Three Mile Island that there had been some problem with 8 respect to sticking of block valves at TMI-17 9 A No.
10 Q Had you known anything about the operation 11 of block valves at any B&W plant prior to the Three Mile 12 Island accident?
- 13 A No.
14 Q What, if any, information did you obtain 15 at that time with respect to TMI-2's block valve?
16 A t.a I recall,the TMI-2 block valve had been released before operation.with the more reliable valve.
17 18 Q You say "the more reliable valve.".
Can you describe it? The earlier valve, I 19 How can you 20 take it, is the solid wedge valve.
21 describe the valve that TMI-2 had installed?
22 A It was a different manufactured valve.
23 Q Different design?
24 A I don't know.
l
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25 Q Do you know whether the valve at THI-1 had
(_/
m- 3 587 Lonoce 1
at Three Mile 2
been replaced prior to the accident
[)
v 3 Island?
that it was.
4 A These notes indicate Q
That it had been replaced?
h 5 indicate that, I. guess.
6 A My notes didn't 7
My recollection is that I was told that during this 8 conversation.
Q Is it your knowledge today that TMI Unit 9
10 1 has one of the later valves on it?
11 A Based on what I recall from this 12 conversation, it does, yes.
'Q Have you ever done any other work or 13 accident with 14 obtained any other information since the other 15 respect to the operation of PORV block valves, 16 than what is indicated here?
A No.
17 Excuse me.
I was involved in one meeting 18 testing of 19 of the B&W Owner's Group in which EPRI 20 block valves was discussed. .
Q That was subsequent to the Three Mile 21 22 Island accident?
A Yes.
23 Q
Do you recall when that was?
24 b:
\/ 25 A No, I don't.
I i
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588 f Lnnoco 1 l Q
Did you have any responsibility with
/~ 2 L.).) respect to that report?
3 A No.
4 Who, if anyone, at GPU was responsible for
'h 5 Q 6 or involved with EPRI's review of block valves?
A Jim Correa.
7 8 Q Is he at GPUSC?
9 A GPU Nuclear.
10 Q Do you know if there is anyone from Met 11 Ed involved with that?
A No, I don't.
12 Q
Does the entry immediately above the 13 fg
() 14 passage we read earlier on page '125, does that relate
-- I honestly can't read 15 to the issue of block valves 16 it. It is included within a box.
17 A No.
Q What does it say?
18 19 A It is not related to the block valves.
" Dan Denner 6/5/79 realized that the water relief 20 i
21 number for the valve is too large and the 12.36 lbn/sec O
22 number I gave EI is for saturated water at 1000 psig."
l 23 Q Does this relate to calculation of flow l
' 24 through the PORV7
[ ) 25 A Yes. I
( ,/
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0 Lnnoco 589 1
2 Q What, if anything, did you do with respect l
(']
L.J to the information you obtained from people at B&W with 3
4 respect to the PORV block valve operation?
A I believe Mr. Keaten needed the l ll 5 6 information.
7 Q Do you not recall what Mr. Keaten wanted 8 the information for?
9 A Preparation for an SAR meeting.
Did he ask you to call for someone at B&W7 10 Q 11 A Yes.
12 Q Did you pass this information along?
13 A Yes.
Did you ever hear anything about it?
'~ 14 Q 15 A Not that I can remember.
16 Q He never asked you to get any other 17 information?
18 A I don't remember.
19 Q Turning to page '142, there is an entry 20 at the top of the page dated July 10, 1979 with the 21 name Jim Seelingar in the left margin.
22 What does the entry below that and above 23 the bold line across the page read?
24 A "Small break LOCA - use the B&W (D
t 25 presentation, plus address how we categorize accidents J
l Lnnoco 590 1
2 (briefly).
/~N "Make it clear to the operator."
3 Q
There is an arrow leading up to the word 4
." presentation."
lll 5 that 6
Can you explain or do you recall what 7 arrow signifies?
8 A It seems to indicate, make the presentation 9
clear to the operator.
10 Q Stopping there for the moment, what does 11 this passage relate to?
12 A I don't remember.
13 Q Do you recall whether it relates to a 14 conversation you had with Mr. Seelinger?
A It would appear to.
15 16 Q Do you recall any of the substance of this?
17 A No.
18 Q Do you recall what he means by the B&W 19 presentation or what is meant here by the B&W 20 presentation? .
A No, I don't.
21 22 Q Did you make a presentation or do you know 23 whether Mr. Seelinger made a presentation to Metropolita r.
24 Edison operators around the time of mid-July of 1979?
7s I did not. I don't know if Mr. Seelinger
() 25 A
U 591 1
Lanoco 2 did.
T (U Q Could you continue on and read the 3
4 remainder of the portion above the line?
" Extension 211, Carl Nixdorf - address LOCA
'jh 5 A Any additional analyses that we 6 procedure 1202-6.
7 might have to clarify."
8 Q Is that LOCA procedure a TMI-1 LOCA 9 procedure?
10 A Yes, it is.
11 Q Do you recall what the significance of this 12 entry is?
13 A No, I don't.
fx NJ) 14 Q Do you recall who Miss Nixdorf was?
15 A No.
16 Q Do you, recall whether you were ever to 17 required following the Three Mile Island accident 18 review any TMI-1 procedures and in and around the time 19 frame of July of 19797 A I have reviewed TMI-1 procedures since the 20 21 accident, but not in that time freme.
22 Q When is the earliest you can recall 23 reviewing any TMI-1 procedures?
A 1980. Winter or spring of 1980.
24
(^T. Q You mean early 19807 25
(_)
V 3 592 Lcncoo i
A Yes.
/"'N 2 b g so you have no recollection at this point 3
4 what is meant either by this entry relating to small break LOCA and the B&W presentation or to this TMI-1 (h 5 6 LOCA procedure?
A could I hear the question again?
7 Q
You have no recollection with respect to 8
9 these subjects, I take it?
A No, I don't.
10 Why don't we break for MR. BENEDICT:
11 I will look over my notes. I think I am 12 lunch?
done. I won' t have very much , certainly, when 13 g-)' I would like to come back, though.
La 14 we come back.
15 I want to make sure, since I know you are having 16 lunch, I don't feel bad about asking you to do that. I hope you can do your cross-examination 17 18 or, if not, I would like to schedule it,.so 19 maybe you can review your calendar over lunch.
1:15 p.m.)
20 (Luncheon recess:
22 l
23 24 1
~,] 25
P 593 1
- 2 AFTERNOON S ESS ION L' (Time noted: 3:00 p.m.)
3 MR. BENEDICT: I don't have any further 4
I do have some open I 5 questions at this time.
6 issues in my mind about some documents we talked 7
about, and if the material that Mr. Lanese and I 8
have talked about has, indeed, been produced, I 9
don't see that I am going to have any other 10 questions other than those items we have talked about in terms of documents. Whether or not I 11 asked you whether they had been produced, with 12 13 the exceptions of those, I am finished.
fD I guess I am not sure I LJ 14 MR. GLASSMAN:
15 understand as to what matter you are reserving.
16 MR. BENEDICT: We talked about a number of 17 documents, some of which we found, some of which.
18 you and I talked about producing before the end 19 of the deposition.
20 Today, we talked about some material.
Assuming, for 21 Maybe we have it; maybe we don't.
22 the moment, that we have received all of the 23 material with respect to Mr. Lanese that has 24 been requested prior to this deposition, then I t
i /"% 25 don't have any further questions.
- i )
v 6
Lnnoco 594 1
2 MR. GLASSMAN: I might note that we have not
('S 1
3 only produced the requested documents before Mr.
4 Lanese's depositions, but during the course of the examination you requested documents we have 5
MR. BENDEICT: I am not quibbling with any 6
7 of the facts that happened with respect to 8 documents. If all the documents pertaining to Mr.
9 Lanese have been produced pursuant to a notice 10 request that we have filed in September of 1980 11 and all the materials have been produced, I have 12 no reason to talk to Mr. Lanese.
13 If material comes up that hasn't been 14 produced, despite its prior request before trial, 15 that is another question. -I don't think this 16 statement has any legal significance. I am 17 simply advising you of what the state of affairs 18 1,,
19 MR. GLASSMAN: It is our understanding that 20 all responsive documents have been produced.
21 MR. BENEDICT: Can you do your cross now?
22 MR. GLASSMAN: I have no questionc of this 23 witness at the time.
24 MR. BENEDICT: That's it. Unless I ask i
n),
25 any more questions, you don't have any more
594A LSnoco 1
2 questions?
'l
[Q MR. GLASSMAN: That's correct.
3 3:02 p.m.)
4 (Time noted:
5 6 LOUIS C. LANESE 7
8 Subscribed and sworn to before me this day 9
10 of , 1982.
11 12 13 q
14 15 16 17 18 19 20 21 22 .
i 24
- ]
i L.; 25 )
4
/
I ! 595 CERTIFICATE (q ii STATE OF NEW YORK )
y
> 3 : ss.:
i COUNTY OF NEW YORK )
4 i h I, CATHERINE CoOx , a Notary h Public of the State of New York, do hereby certify that the continued deposition of LOUIS C. LANESE was taken before me on Monday, April 19, 1982 consisting of pages 469 through 595A ;
I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; !
That I am not connected by blood or LJ marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel.
18 j IN WITNESS WHEREOF, I have hereunto set my l 19 I hand this S gll1.1Tday of
! %M ,1982. l 20 h 21 -
e 22 1 a4 on a- 1xn '
CATHERINE COOK .
I 24 l
- 25 v
9m- p * * *
- q l
- I 3 Lonoco 594A 1
'N 2 questions?
U i
MR. GLASSMAN: That's correct.
3 (Time noted: 3:02 p.m.)
4 5
6 LOUIS C. LANESE 7
8 Subscribed and sworn to before me this day 9
10 of , 1982.
11 12
[
v 14 15 16 17 18 19 20 21 22 .
l 24 3 25 f)
\,_
. . _ , _ /
I 1 595 l CERTIFICATE n il STATE OF NEW YORK )
(Q 3 l : ss.:
! COUNTY OF NEW YORK ) '
4 -
h 5 I, CATHERINE Coox , a Notary h Public of the State of New York, do hereby certify thr.t the continued deposition of LOUIS C. LANESE Was taken before j 8 ,
me on Monday , April 19, 1982 consisting of pages 469 through 595A ;
I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; m That I am not connected by blood or marriage with any of the said parties nor 15 interested directly or indirectly in the matter 16 in controversy, nor am I in the employ of any 17 of the counsel.
18 i
IN WITNESS WHEREOF, I have hereunto set'my l 19 :
20 hand this M day of kNhk ,1982. l l
l h 22 a$nmaL, nm !
23 ' '
l CATHERINE COOK .
1 i
,c m 25 I t )
v
. . g q l *
=, - - ___
596 April 19, 1982 ,
INDEX
( \
PAGE WITNESS 471 Louis C. Lanese l
EXHIBITS FOR IDENT.
'n sW 611 Copy of a document headed "Date: November 17, 1977, Place: Florida Power Corp.,
- Topics B&W Owner's Group Reactor Vessel Support 488 Subcommittee."
l 612 Letter from Mr. J. G.
Herbein, Metropolitan Edison to Mr. Steven A. Varga, U.S.
Nuclear Regulatory Commission, dated December 20, 1977, listing Mr. Lanese as a cc on the last page. 561 l
i 613 Early draft of document entitled " Attachment I, Long i
Term Cooling Following Steam I
Line Break." 572 t t 9 9
t )
v a
-- -