ML20072H924

Deposition of LC Lanese on 820326 in New York,Ny.Pp 303- 468

ML20072H924
Person / Time
Site:	Crane
Issue date:	03/26/1982
From:	Lanese L GENERAL PUBLIC UTILITIES CORP.
To:
References
TASK-*, TASK-03, TASK-07, TASK-3, TASK-7, TASK-GB NUDOCS 8306290817
Download: ML20072H924 (169)

Text

{{#Wiki_filter:-__ _ - - -________- _. - hd1 303 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK _ -x GENERAL PUBLIC UTILITIES CORPORATION, a JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a Plaintiffs, 80 CIV. 1683 (R.O.) -against-THE BABCOCK & WILCOX COMPANY and. J. RAY McDERMOTT & CO., INC., Defendants. .x Continued deposition of GENERAL PUBLIC 4 UTILITIES NUCLEAR CORPORATION by LOUIS C. LANESE, taken by Defendants pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Friday, March 26, 1982 at 11:00 o' clock in the forenoon, before Joseph R. Danyo, a Shorthand Reporter and Notary Public within and for the State u of New York. n DOYLE REPORTING. INC k / CERTIFIED STENOTYPE REPORTER 369 LEXINGToN AVENUE WALTER SHAPIRO, C.S.R. NEW Yong. N.Y. 10017 CHARLES SHAPIRO. C.S.R. Tet.spwo N E 212 " 867 8220 8306290817 820326 PDR ADOCK 05000289 T_ PDR a

1 2 APP EA RANCE S: /~N (-) 3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS. Attorneys for Plaintiffs 4 425 Park Avenue New York, New York O j 5 By: STE'JEN J. GLASSMAN, ESQ. 6 -and-JOHN EICKEMEYER, ESQ., 7 of Counsel 8 9 DAVIS POLK & WARDWELL, ESQS. 10 Attorneys for Defendantu One Chase Manhattan Plaza 11 New York, New York 12 By: RODMAN W. BENEDICT, ESQ., 13 of Counsel l 14 15 Also Present: 16 NINA RUFFINI 17 JULIE JOHNSON 18 19 l 20 1 l 22 23 l 24 25 v e

395 1 2 LOUI S C. LANE S E,

resumed, f3 4V; 3

having been previously sworn by a Notary Public, l 4 was examined and testified further as follows: 5 E:< AMINATION (CONTINUED) 6 BY MR. BENEDICT: 7 Q You understand that your testimony today 8 continues to be under oath? 9 A Yes. 10 Q Yesterday, we were talking about the work 11 that you were doing during the spring and summer of 12 1978, and I believe you mentioned that you were involved 13 with an issue which somehow related or was an issue that 1 s.) 14 was resolved by instituting a cross-connection of high 15 pressure injection, is that correct? 16 A Yes, I was involved. 17 Q Did this project relate to a B&W analysis 18 with respect to a break in the reactor coolant system 19 at the discharge of the reactor coolant pumps? 20 A Yes, it did. 21 Q Did you receive written material from B&W 1 l 22 with respect to this? 23 A Personally? l r 24 l Q Yes. [^~ ) 25 A No. v

306 1 Lanoco 2 Q What did you understand the issue to be? /~N k) 3 A That as a result of a small break at the pump 4 suction, high pressure injection from one HPI leg would 9 5 or could be discharged directly out the break without I 6 going to the core and removing heat from the core. 7 Q You said " pump suction." Did you mean that? 8 A Pump discharge. 9 Q Did you understand that B&W had reported 10 this to the i 11 A I wanted to complete the description. 12 As a result of that situation, the operator 13 would be unable to determine that the flow was not / \\ (_j 14 reaching the core, and there was the potential for i 15 inadequate core cooling as

a. result of that sequence of 16 events.

17 Q About how much time during the spring and 18 summer of that year did you spend on this project in 1 19 hours, days, weeks? 20 A Three or four days. j i ggg Q I would like to show you a document that 21 \\ 22 previously has been marked as B&W 419. B&W 419 is a 23 letter from E. G. Ward of Babcock & Wilcox to Mr. 24 L. C. Lanese, and it is dated July 20, 1978, and it j 25 ('w) includes a multiple-page attachment. L-

1 Lanoco 307 2 Does this refresh your recollection that you 'G() 3 received from B&W some written material with respect to 4 this issue? 5 A No, I remember seeing the attached material. 6 I don't remember having received it directly. 7 Q You don't recall the covering letter,'but 8 you do recall the letter to the NRC,to Mr. Varga at 9 the NRC from S& W and the report attached to that? i 10 A Yes. 2! 11 Q If you notice in the covering letter from 12 ' B&W to you, it is mentioned in the second line of the 13 text a " June 19, 1978 analysis." 14 Do you recall whether you received that? 15 A I remember seeing an earlier analysis with i s s 16 the Zaloudek correlation included in it, yes. 17 Q You unA4'rstand that the analysis that you 18 have before you in B&W 419 which you recall receiving 19 excludes that, is that gorrect? 20 A Yes, it is. 21 MR. GLASSMAN: Could I just break for a i 4EP 22 moment. 1 y-q s (Discussion off the rec,ord between the 23 11 24 j w i t n e s s and his counsel.) '4 's 1 vN 25 BY MR. BENEDICT: 1 N.' ( ) fg x_/ s t '. 6 2 s. \\ y

1

L2neco, 308 s

2 Q Do you recall receiving any other written (_)\\ 3 material with respect to the pump discharge break issue 4 whether you received it from B&W or from any other 5 source? 6 A Yes, I saw other;rcorrespondence. 7 Q Did yov see any other analyses? 8 A I never,iev cnalyses: I saw results of 9 analyses. 10 Q Is what is' attached to B&W Exhibit 419 the 11 results of an analysis? Is that what you mean? 12 A Yes. 13 Q Did you keep a file on this subject? (3 y_) 14 A Yes, I.61d. 15 Q Do you know whether that file was searched 16 with respect to compliance with the document request 17 outstanding in this case? 18 A I'm not sure. 19 MR. BENEDICT: I will request that if that 20 file is still extant and if it hasn't been 21 searched that it be produced. 22 MR. GLASSMAN: I believe, as far as I am I 23 aware, we have searched for anything in this 24 regard, but we will double check to make sure i (~) 25 there hasn't been anything that hasn't been m,/

ct Lnnoco 309 e i produced that should be produced. /" 2 \\J 3 BY MR. BENEDICT: 4 Q Do you recall where you kept this file or G 5 the file on this subject? 6 A Yes, it was in the safety and licensing 7 central file. It would have been under accider.t analysis. 8 The major numerical heading was 2358, and I believe it 9 would have been under 2356.2 ECCS analysis. 10 MR. GLASSMAN: I believe we did produce 11 that material, but we will double check. 12 Q When did you first hear that there had been 13 an incident or occurrence O) 14 A Excuse me. Let me add, there may be another (_ 15 source. 16 Q Another source document or material that 17 you received? 18 A Yes, under TMI-1. 19 Q In other words, because, as I understand it, 20 this letter indicates that it applies specifically, the 21 letter being B&W 419, to 2,272 megawatt thermal plants. 22 Unit 1 has a lower thermal rating than that, is that i 23 correct? I 24 A That's right. 25 Q Was there other material with respect to the (~~} q,i e

I 1 Lonoco 310 1 2 lower-rated plants? r'~' s k-) 3 A No, Eventually, the 2772 megawatt analysis 4 was the reference analysis, and it was bounding for all 5 Plants. 6 Q By that you mean if the analysis was 7 acceptable to the NRC for the high termal output plants, 8 it would of necessity be acceptable for the lower thermal 9 output plants? 10 A That's right. 11 Q So, can you tell me about where files might 12 be kept? 13 A Under TMI-1, there may have been an ECCS O (_/ 14 file on it or in the raload files. This is probably 15 cycle 4. 16 Q cycle 4 of TMI-17 17 A of TMI-1, yes. 18 Q Refueling? 19 A Right. 20 Q Those files are P.ept where? 21 A They were in safety and licensing. They g 22 may have been microfilmed, i 23 Q To an entirely different subject, when did 21 you first hear about a transient or incident or off-i (~' 25 normal occurrence at Three Mile Island which occurred on L.)) e

1 Lonoco 311 2 March 28, 19797 (~') 3 A APProximately 9:30 a.m. on March 28, 1979. 4 Q From whom did you hear about it? 5 A From Mr. Nicholas Trikouros. 6 Q He was your boss then? 7 A No. 8 Q What relationship did you and he have 9 professionally at that time? 10 A We worked for Mr. Broughton. 11 Q You were on the same level? 12 A Yes. 13 Q What did you hear from Mr. Trikouros? OV 14 A He had called me at home from Richmond, 15 Virginia, where he was on a trip. He mentioned that 16 there was a report on the radio that there had been a 17 loss of feedwater event at TMI and that there were 18 high radiation readings on the dome monicors. 19 Q You were at home at 9:30? 20 A Yes. 21 Q When do you usually get to the office on a g 22 weekday? 23 A I'm normally in by 8:00. f Q Is there any reason why you were home that 24 ,o i 25 day? .,)

0 1 Lon000 312 2 A Yes, I was traveling to Lynchburg that day \\m/ 3 and the flight was in the afternoon. 4 Q For what purpose were you going to Lynchburg? 5 A I had a meeting on the next day to discuss 6 the asymmetric LOCA loads program and to discuss some 7 feedline break analyses that were to be used as part of '8 the TMI-2 feedwater redesign. 9 Q Did Mr. Trikouros indicate that he had any 10 source of information about the accident other than the 11 radio? 12 A No, he did not. 13 Q What you recall him telling you was that 14 there had been a loss of feedwater event and there was a' 15 high radiation reading from the dome monitor, is that 16 correct? 17 A Yes. 18 Q The dome monitor is a radiation monitor at 19 the top of the inside of the containment, is that 20 correct? I 21 A Yes. ggg 22 Q Did you go to Lynchburg that day? 23 A Yes, I did. 24 Q What was the next thing or bit of ,-m l () 25 information you heard about this incident?

313 11 1 Lonoco 2 A I had lunch at my parents' house that day 3 and driving over there, I heard a report on the radio. 4 Q Did it provide you with any information G 5 you hadn't already heard? 6 A No. 7 Q When you heard there had been a transient 8 at Three Mile Island Unit 2, did you call anyone at 9 your office to determine whether they would rather you 10 return to the office instead of going to Lynchburg? 11 A Yes, I did. 12 Q Who did you call? 13 A Mr. Broughton. (~% (_) 14 Q What did Mr. Broughton tell you? 15 A He said there didn't appear to be any reason 16 for me not to go to Lynchburg. 17 Q Did he provide you with any further 18 information? 19 A yo, 20 Q Did you ask? 21 A Yes. ggg 22 Q He said what in response to your question? 23 A That he didn't have anything to provide at 24 that time. This is approximately 11:00 o' clock. (~)'q 25 Q In the morning? i.. 1

314 2 1 Lanoso 2 A Yes. / T 3 Q Did he tell you whether GPU was assembling 4 a group of people to consider the events of that day? 5 A He mentioned that he was talking to Mr. 6 Arnold and Mr. Herbein, as I recall. 7 Q Did he mention Mr. Keaten? 8 A No, he didn't. 9 Q Other than your conversation with Mr. 10 Broughton, did you make any effort during the day of 11 March 28th to learn more information about the 12 accident? 13 A No, my only sources of information that day f l N-14 were the newspapers. 15 Q You went to Lynchburg that afternoon, I 16 take it? 17 A Yes. 18 Q And arrived at the Old Forest Road office 19 sometime in the morning of Thursday, the day after? 20 A Yes. 21 Q Did you discuss at that time the Three Mile gg) 22 Island accident with anyone? 23 A It was certainly a topic of conversation, 1 24 1 but the people who were in the meeting with me had very I l ,e. 25 few details. ( j %s I I 4

315 I 3 Lanoco 2 Q Who were those people? O 3 A The only person I remember specifically is 4 Bob Schumacher from safety and license. I believe Bob h 5 vossburg was there also. 6 Q Were there any other Met Ed or GPU employees 7 other than yourself? 8 A Dr. John Luoma was in the meeting with me. 9 Q Who is Mr. Luoma? 10 A He works for the Nuclear Fuel Analysis Group 11 at GPU. 12 Q Do you know when he arrived in Lynchburg? 13 A The previous night also. 14 Q Did you see anyone, whether or not in this 15 meeting, did you see anyone else in Lynchburg that day 16 who worked for Met Ed or GPU? 17 A No. O Q What did you learn on the 29th in addition 19 to the information you gained from your discussion with 20 Mr. Trikouros and what you heard through the news media 21 with respect to the accident? A At lunchtime, I remember one of the TMI-1 1 23 project people said that there may have been some 4 damage to the steam generator tubes and there would be 25 a potential outage to plug and replace some damaged

310 14 1 Lanoco 2 tubes. t \\_/ 3 Q Do you remember whom you were speaking with? 4 A I don't remember the guy's name, no. ) lll 5 Q A B&W employee? 6 A Yes. 7 Q on the 29th, did you make any effort to 8 learn more information about the incident? 9 A I don't recall what else I did to find out 10 about it, no. 11 Q Did you find out anything more about it? 12 A Only what I was able to read in the New York 13 Times. O) (s 14 Q Were you interested in it at the time? 15 A That vould be an understatement. Yes. 16 Q Did you make any effort, call anyone back at 17 your home office to ask them what information, friends, 18 what information they could provide you? 19 A I'm sure I must have. 20 Q But you don't recall any specific 21 conversation? 22 A I don't remember anything specific, no. 23 Q when, if ever, did you get your first job 24 request with respect to the accident at Three Mile f') 25 Island? v/

317 15 1 Lnn000 2 A The following morning, March 30th. /- ',\\# 3 Q Were you still in Lynchburg? 4 A No. ll 5 Q You had returned the night before? G A Yes. 7 Q You went to the office at your normal time, 8 8:00 o' clock? 9 A I was in by 8:00 o' clock, yes. 10 Q What were you asked to do and by whom? 11 A There was a phone call from the site by Mr. 12 Wilson, and he was asking us in general, and I got 13 involved, directly involved. The request was to n ( ) \\/ 14 determine if there was some way to create a 15 depressurization of the primary system in order to put 16 the plant on decay heat removal. The problem, as I 17 understood it at the time, was that as the RCS was 18 depressurized, pressurizer level was going up rather 19 than down. 20 Q When you said "Mr. Wilson," did you mean 21 Richard Wilson? O 22 A Yes. 23 Q When you heard when they depressurszed the I 24 l system that pressurizer level was going up instead of /^% t ] ) 25 down, what did you understand about that phenomenon, if ~,j l

310 6 1 Lenoco 2 anything, at the time you heard it? ()] \\~ 3 A In relation to what was going on, I couldn't 4 figure out why that was happening. G 5 Q Do you know how they were trying to 6 depressurize the system? 7 A No, I do not. 8 Q Did they tell you whether they were trying 9 to do it by coolin'g down the system or did they say they 10 were releasing fluid from the RCS through a valve? 11 A No, I don't remember now. 12 Q What information did he give you about the 13 details of the accident at that point? 7, \\_ 14 A There were none. I remember it being an 15 extremely bad telephone connection. 16 Q This is the morning of the 30th, as I 17 understand it, and at this point, is it correct that yourj 18 only sources of information with respect to the accident 19 had been conversation with Mr. Trikouros and anything 20 you could glean from the new media? l 21 A That's correct. g 22 Q Did Mr. Wilson provide you with a source j i 1 23 that you could use for information about the conditions I 1 l 24 l of the plant? () 25 A No. )

319 1 Lenoco 7 2 p Q Did he tell you anyone you should speak to C 3 in order to get necessary information? 4 A No. I have to add that I don't think he h 5 even knew who 'he was talking to on the other end. He 6 just making a general request to headquarters' was ~7 personnel to investigate the event. 8 Q But you spoke to him? 9 A I was one of the people who spoke to him, 10 y,,, 11 (Discussion off the record between the 12 witness and his counsel.) 13 3Y MR. BENEDICT: 'v/ i4 Q Who else was involved in the conversation - 15 with Mr. Wilson that morning of the 30th? 16 A Nick Trikouros, Jack Devine; for a small 17 portion of the conversation,Mr. Don Kroneberger. 16 Q What other assignments were handed out by 10 Mr. Wilson as you understood it in that phone 20 conversation? 21 A That was all. We terminated the connection. 22 Q Did you set to work on this project at that 23 time? o4 A Yes. l Q(m 25 Q What did you do in order to familiarize

8 1 Lenoco 320 2 yourself or provide yourself with the information 73 I i %.) 3 necessary to come up with an answer? 4 A I began looking through drawings, flow I 5 diagrams of the primary coolant system te verify a 6 path that I thought would be available, and proposed it 7 to Nick Trikouros, Jack Devine, and we also discussed 8 the general idea with Jim Harrison of Energy, 9 Incorporated. 10 Q Was Mr. Harrison present by happenstance? 11 A No, we called him on the phone. 12 Q You said that you were considering the flow 13 diagrams of the RCS in order to determine a path that G 14 was available. Available for what? 15 A For depressurization. 16 Q Was it your intention then to depressurize 17 by relasing fluid from the reactor coolant system? 18 A Yes. 19 Q Did you know what that fluid would be 20 composed of? 21 A No. l 22 Q Did you know at that time there had been l 23 substantial hydrogen generation? i i l [ 24 A I did not. 1 i ~ (_,s 25 Q What then came of your recommendation? l

9 1 Lenoco 321 2 A When we brought it to Mr. Keaten's t I 3 attention, he said that we could not subject the primary i 4 coolant system to a rapid depressurization because of 5 the condition of the fuel. 6 Q What did Mr. Keaten say or what did you understand 7 him to mean with respect to when he said "because of 8 the condition of the fuel"? 9 A We weren't able to go into it. That was 10 an unknown to me at that time. 11 Q Did you understand that there had been 12 rupturing of the zirconium alloy cladding of the fuel 13 pins at that time? /~s b 14 A No. 15 Q Were you aware of any fuel damage at that 16 point? 17 A No, I wasn't. 18 Q Were you aware of any further information 19 with respect to radiation readings other than what you 20 had been able to glean from the papers and from Mr. 21 Trikouros' conversation? 22 A No. 23 Q Whon during that day on the 30th did you 24 approach Mr. Keaten with this suggestion? ,- m ( ,) 25 A By midmorning. i

I Lenoco 322

0

() 2 Q What did you do after Mr. Keaten told you %-) 3 that your suggestion was unworkable at that time? 4 A By this time, numbers of other people had O 5 been assembled into one of the central conference rooms 6 and we began discussing alternatives. 7 Q Was there any presentation made at that 8 meeting of information that people at GPU or Met Ed had 9 with respect to the condition of the plant? 10 A No. 11 Q Did you have any idea at that point what 12 the cause of the accident had been? Excuse me, what 13 the mechanistic cause had been. You said you heard it (~'} 'v' 14 was a loss of feedwater. Had you heard anything else 15 with respect to the mechanistic cause of the accident? 16 A There had been an interruption of emergency 17 feedwater for some period of time, and the PORV had IO been opened for some period of time. 19 Q You knew both those facts by that morning? 20 A Yes. ll 21 Q Did you read those in the paper? 22 A Yes. 23 Q Do you recall knowing at that time anything l l about management of high pressure injection during the I 24 7_ ( / x' 25 course of the transient? e

1 1 Lonoco 323 2 A No. 7x k_ 3 Q Do you recall that you did not know anything 4 about it? I 5 A I specifically recall that based on the 6 newspaper articles, I was unable to tell what pumps were 7 being referred to as having been throttled and shut off. 8 Q When they referred to pumps, you didn't know 9 what pumps they meant, is that what you are saying? 10 A No. 11 Q What transpired during the course of this 12 meeting where you were discussing alternatives? I take 13 it you mean alternative suggestions for depressurization f. r x_/ 14 of the plant? 15 A That was at least one of the topics, yes. 16 Q What other topics do you recall being 17 discussed at that time? 18 A I don't remember now. 19 Q What topics did you involve yourself with? 20 A At the meeting? 21 Q Yes. 22 A None. I was basically listening, trying to 1 23 catch up with what was going on. j l (\\ l Did you understand at that meeting that you 24 l Q 25 had any specific assignment with respect to the events (_ )

!2 1 LSn000 324 2 at Three Mile Island over the last few days? ,_\\ ( 3 A I only knew that I was going to be there 4 for a long time performing whatever assignments were llh 5 necessary. 6 Q But you hadn't been given a specific task 7 as you understood it? 8 A Not by 10:00 a.m., no. 9 Q How long did this meeting last? 10 A We went through lunch. 11 Q How many people attended? 12 A Perhaps 15. 13 Q Do you remember who any of those people were?g ~% {\\- 14 A Mr. Keaten, Nick Trikouros, Jack Devine, 15 Don Kroneberger, Gary Capodanno. I don't remember the 16 others. 17 Q Was fuel damage discussed at this meeting? 18 A No. 19 Q Was possible fuel damage discussed? 20 A I only remember coming away from the meeting i 21 without any understanding that there had been any 22 damaged fuel. 23 Q Did anyone make a presentation with respect i 24 i to this meeting? Did anybody stand up and say "I want l es (G ) 25 I to tell you all the following," whatever it was?

O I 13 1 325 L0noco 2 A A presentation? ,s / s .\\ 3 Q Yes. Well, let's try again. 4 I believe you testified you don't recall any 5 discussion or any presentation with respect to the 6 conditions of the plant or the historical conditions 7 of it. 8 Do you remember any information with respect 9 to the plant being conveyed to the entire group by 10 whatever means? 11 .A There was certainly information, lots of 12 information, conveyed. I don't remember any of the 13 details. 14 Q You don't remember anything about_ fuel 15 damage? 16 A Not about fuel damage, no. 17 Q Do you remember anything about management of 18 high pressure injection? 19 A No. 20 Q Do you remember anything about the operation 21 of reactor coolant pumps? 22 A No. 23 Q Do you remember anything about failed open 24 I pilot operated relief valves or other relief valves? {) 25 A No.

326 4 1 Lnnoco V) f' 2 Q Do you remember discussion of a loss of 3 coolant with respect to what had transpired on March 4 28th? 9 5 A No. 6 Q You do remember discussion of loss of 7 main feed or absence of emergency feed for some time 8 period and an open PORV, is that what you said? 9 A That is what I read in the newspapers, yes. 10 Q But in that meeting, you didn't learn 11 anything more about either of those facts? 12 A No, that wasn't the purpose of the meeting. I 13 Q What did you understand the purpose of U("% 14 the meeting to be? 15 A To begin recovery of the plant. 16 A Q Was the thrust of this meeting, as you 17 understood it, to determine a means whereby the decay 18 removal system could be put into use at Unit 2? 19 A Yes. 20 Q What suggestions do you recall were put ggg 21 forth at that time? { 22 A None. l 23 Q Did you have any understanding at that time 24 .l of the radiological qualifications of the decay heat / i I,'" j 25 removal system?

327 1 !S 1 Lanoso ) i I 2 A No. j 3 Q Did you understand that at least portions 4 of the decay removal system required flow of reactor 5 coolant outside of the containment? 6 A Yes. 7 Q Did you know whether those portions of the 8 decay heat removal system which were outside the 9 containment were radiologically shielded? 10 A My understanding was that they were. 11 Q That they were? 12 A Yes. 13 Q What next transpired after this. meeting 7_ i N_)\\ 14 with respect to the incidents and events starting on 15 March 28th at Three Mile Island? 16 A By that time, we had established the 17 permanent communications with the on-site GPU people, 18 specifically Gary Broughton,and began receiving specific 19 requests for information, calculations and requests for 20 any comments or. possible plant operations that might 21 help in reducing hydrogen concentrations in the primary 9 22 system. I l Q You said "on-site GPU people," and 23 24 particularly Gary Broughton. /~S t ) 25 Do you know whether Mr. Broughton or other l

328-6 1 Lnnoco 2 GPU people were present in the control room? And for \\ \\ 3 this question, I mean GPU only as opposed to GPU and 4 Met Ed. llh 5 A These conversations were not being initiated 6 from the control room. 7 Q Do you know whether Mr. Broughton had access 8 to the control room at that time? 9 A No, I don't. 10 Q Was Mr. Broughton at the Visitor's Center? 11 A I don't know. 12 No, he was not. 13 Q Do you know where he was? p) \\ 14 A somewhere on the site. 15 Q on the Island? 16 A Yes. 17 Q Was any method used to record either 18 verbatim or b'y notetaking the contents of the 19 conversations that were had between GPU headquarters 20 and GPU representatives at the site? 21 A I don't remember. O 22 Q What form did this permanent communication i 23 that you spoke of take? 24 A It was a phone link from Mr. Keaten's office l I n 25 through a squawk box. l (,m_-) O

329

7 1

Lanese 2 Q To a telephone on-site somewhere? 3 A Yes. 4 Q Did you receive any graphic material by 5 facsimile transmission during that day? 6 A Somewhere during the day, we had a telecopier 7 setup next to Mr. Keaten's office, and information was 8 transmitted from there. 9 Q Did the graphic information go both ways? 10 Did you send material to them and did they send material 11 to you? 12 A By the end of that day, we had a flow of 13 information both ways, either graphically or by courier. 14 Q Do you recall whether any effort was made I 15 to, record any of the conversations that day over this 16 permanent link? 17 A By notes? 18 Q Either notes or audio-recording or any other 19 means. 20 A There were definitely no audio recordings. 21 People were taking notes. g I 22 Q Did you take notes? 23 A Not that day. 24 Q Do you 25 A I may have taken a few.

8 1 Lenoco 330 2 Q Do you know whether there was an effort made J '~~T 3 at any time following the establishment of this permanent '~ 4 communication link to assemble in one place people's k 5 notes with respect to what was discussed between GPU and 6 the Island? 7 A I don't believe notes were assembled in one 8 place. 9 Q Was any other effort made? 10 A All of our calculations, all of the plant 11 data that was recorded, was processed through a central 12 point. 13 Q Who or what was that central point? bl \\/ 14 A It was a table outside Mr. Keaten's office 15 in which all the calculations were filed and kept. 16 Q Do you know what became of that material? 17 A I think they are stored someplace. 18 Q Do you have any idea where? 19 A No. 20 Q Do you have any idea who would have been i 21 responsible for that material or is responsible for it 22 now? 23 A No. I 24 Q If you were going to look for that material l 4 r~s 25 today, whom would you speak with? jv) 1

333 19 1 Lenoco 2 A The first person who was managing the i 3 information was somebody from the headquarters building, 4 a guy named Brown. llh 5 g Do you remember anything else about him, 6 where he worked? 7 A I think he still works for GPU. 8 Q Do you remember what his first name is? 9 A No. 10 Q You don't remember what group he was from 11 or what department? 12 A He wasn't from engineering. 13 Q How is it that you know that he came to D. k-14 manage this material? Did you see him around? 15 A He had the responsibility for keeping track 16 of everything. Every time you completed a calculation 17 or an information request, you processed it through him. 18 Q What happened when you processed it? 19 A He kept the original. You got a copy for 20 your files, and he made sure it was transmitted to the 21 correct person on-site. 22 Q Did it receive a file number of some kind? 23 A I don't remember. 24 Q . hat next occurred on that March 30th? W N ( ) 25 You had the meeting which you say went through lunch. v

0 1 Lanoco 332 2 At the end of that meeting, did you receive 3 a specific assignment or specific assignments that you 4 undertook to complete? O 5 A Yes, by that time Gary was asking me for 6 information. 7 Q Do you recall what information it was he 8 was asking for? 9 A The task that I spent most of my time on 10 was in trying to determine a means of venting hydrogen 11 from the primary coolant system. 12 Q You mean most of your time that day or 13 most of your time in the early days? {s-14 A That day. 15 Q What, if any, conclusions did you reach 16 with respect to that? 17 A By the end of the day, we, in working with 18 Burns & Roe and also with -- principally with Burns & 19 Roe, determined that RCV-137 which was the pressurizer 20 vent valve was suitable for opening and for venting gg) 21 hydrogren to containment. 22 Q Do you recall when or how you came to know 23 that there was a significant quantity of hydrogen in 24 the reactor coolant system? (,,) 25 A No. Rs'

l 11 1 Lnnoco 333 2 Q what did you understand to have been the t ) \\/ 3 source of that hydrogen or the primary source? 4 MR. GLASSMAN: On March 30th? 1: h 5 MR. EENEDICT: Yes, what he understood at 6 that time. 7 A On March 30th, I don't know. 8 Q Did you know on March 30th that the 9 zirconium alloy cladding of the fuel pins would oxidize 10 and result in the generation of free hydrogen if it was 11 heated beyond a certain point? 12 A Yes. 13 Q Do you recall considering that as a possible (- w/ 14 or probable source of the hydrogen in the RCS? 15 A I didn't do much recollecting on that day. 16 Q Was it important to you in order to perform 17 your task to understand the source of the hydrogen? 18 A Not on the afternoon of March 30th, it 19 wasn't, no. 20 Q Did you have any understanding as to whether 21 hydrogen was continuing to be generated without the RCS? 22 A I believe that was one issue that I later 23 became involved with. i l 24 l Q On the day we are talking about, Friday the i fm i 9 -( ) 30th, do you recall any involvement? 0 ./

324 2 1 Lonoco 2 A There was -- that was a consideration, yes. (/ s-3 Q Did you come to any conclusions with respect 4 to that issue during that day? lll 5 A It didn't appear there would be significant 6 hydrogen generation. 7 Q In order to reach that conclusion, what 8 facts did you know? 9 A I wasn't doing the calculations at that 10 point, but based on the activity in the primary coolant 11 system and the production of hydrogen as a result of 12 radiolysis of water there didn't appear to be any 13 immediate problem. A(,_) 14 Q The radiolysis of water is a different source 15 of hydrogen from the one we are talking about with 16 respect to the cladding, is that correct? 17 A That's correct. 18 Q It is a result of the bombardment by 19 radioactive particles of water molecules which break 20 up, is that correct? 21 A That's right, gamma rays. 22 Q You said the RCV-137. l 1 23 l What valve is that? 24 l A It is a pressurizer vent valve. .(~3 25 l Q Did you understand that it was a valve that \\ i / e =

j 34. 1 LOnoco 335 s ~. ? s 2 war remotely' operated from the; control room? [ ,'\\ I 3 A that was one'of the facts I(had to establish \\-' 3 A 4 for Mr. Broughton. khk 5 Q Did you establish that? 6 A Yes. 7 Q Do you know the approximate area of this 8 vent valve? 9 A I don't now know. 10 Q Did you understand this was a valve that was 11 located at the top of the pressurizer or at least in the 12 hemispherical dome? \\ 13 A

Yes, p) t s

+ N 14 l Q Did you learn for the first time of the o s 15 existence of this RCV-137 on,that day? s 1 16 -A I knew that there was a valve that was used 17 duringt.chutdown to vent nitragen cover gas. I did not 18 know that it was RCV-137. I did not know that it was 19 remote-manually operated. 20 Q You did understand that there was a vent 21 valvo'.an the pressurizer other than the two code safety ! i s 22 valves an'd the pilot operated relief valve prior to the l I ( s 23 accident? 24 A Yes. i I 73 ( ) 25 Q You understood that it was used at least l

14 1 Lonoco 336 j 2 for venting the hydrogen overpressure gas during j ('^\\ \\ 3 shutdown conditions, is that correct? 4 A Nitrogen cover gas during shutdcun, yes. lh 5 Q What happened to your suggestion or 6 recommendation of use of the RCV-137 on March 30th? 7 A I didn't recommend the use of it. It was 8 an idea that was initiated through Gary. I supplied 9 information from Burns & Roe that demonstrated to our 10 satisfaction that the valve could be opened safely. It 11 was opened that night some amount, and by the next 12 mornAng hydrogen concentration was going up inside 13 containment. O)

(_/

14 Q Do you know where or how the RCV-137 vents? 15 A It vents into containment. 16 Q Directly, to your knowledge, or does it go 17 through the reactor coolant drain tank or some other 18 holding tank? 19 A I am not positive anymore. 20 Q Did you, prior to the Three Mile Island 21 accident, understand that the area circumscribed by the 22 opening of the RCV-137 was less than the area of the 23 PoRV opening? i 24 A I'm not sure. I (~m 25 () Q Did you have any understanding of the

337 5 1 L0noco 2 relative size of RCV-137 and the PORV on the day you were I\\/ 3 discussing this on March 30th? 4 A I knew that the 137 line, or at least I lh 5 recollect it, was approximately a one-inch line. 6 Q That is the line of the valve? 7 A Yes. 8 Q What else that you can recall transpired 9 with respect to specific work assignments for you on 10 the day of the 30th? 11 A I can't roca11 work assignments that were 12 specific to the 30th. 13 Q Did you have an opportunity on the 30th tjo tN._/ 14 learn more information about what had happened at the 15 plant? 16 A Very little that I recall. 17 Q When did you leave on the 30th, leave work? 18 A Somewhere between 9:00 and midnight. 19 Q Did you go to work the next day? 20 A Yes. 21 Q Am I correct in saying the next day was a 22 Saturday? 23 A Yes. 24 Q Did someone ask you to come in to the office '() 25 on a Saturday? I take it that is not a regular workday a i

f 6 1 Lonsco 338 2 for you. m 3 A No. 4 Q Were you esked to come in specifically? llh 5 A By Friday, we had been assigned specific 6 work rosters in 12-hour shifts. 7 Q By Friday, had GPU or your section of GPU 8 been put on a 24-hour shift? 9 A Yes, all of engineering had. 10 (Document marked B&W Exhibit 607 for 11 identification as of this date.) 12 Q You arrived at about what time on March 31st 13 at the office? OkY 14 A Fairly early. 15 Q Did you report to someone at that time to 16 get a work assignment or did you already have work that 17 you needed to do? 18 A I remember the first thing I did was check 19 on the plant status. I believe Mr. Keaten may have 20 still been there. If not, someone else had the day watch, 21 and they were providing assignments. 22 Q Did you not when you arrived, did you not 23 have already an assignment that was open? l 24 A I can't recall now what assignments f rN t ). 25 i initiated the evening of the 30th or began the morning _s i

339 7 1 L0noco \\ 2 of the 31st. f 3 Q Y u said one of the first things you did 4 when you arrived on Saturday, the 31st, was check on lh 5 the plant status. 6 How did you do that? 7 A Mr. Keaten's office had been set up as an 8 information center. It was a plant status board. There 9 was information written down on the blackboard, and 10 there was almost always someone on the line so you could 11 just ask for updated plant information. 12 Q Was there any historical information 13 provided at that time or was it strictly current? O\\' '/ 14 A No. By the 31st, we had received a printout 15 of the reactimeter data the first several hours of the 16 accident. 17 Q From whom did you receive that? 18 A I don't remember. 19 Q Do you recall whether you received it # rom 20 B&W? 21 A That is very possible. 22 Q But you don't know? 23 A No. 24 l Q Did you receive a copy for your own use of j i ,s{ ) 25 this? i } i j

18 1 Lnnoco 340 2 A It was sent to Mr. Howard, I believe, who f} (/ 3 gave it to me. 4 Q Do you know who, if anyone else, got a 5 copy of that reactimeter data? G A I believe that was the only copy. It was 7 kept within the Safety Analysis Group. 8 Q It was available to whomever wanted it? 9 A Yes. 10 Q Was there a key for the various columns of 11 the reactimeter data? 12 A No. The colttans were marked on the computer 13 printout when we received them. G). is_ 14 Q .Were they marked by hand or were they 15 typew.ritten? 16 A Marked in hand. 17 Q Do you know who marked them? 18 A Whoever it was that provided the reactimeter 19 data. 20 Q You don't recall who that was? i 21 A No. G E 22 (Discussion off the record between the 23 witness and his counsel.) l 24 f BY MR. BENEDICT: I l t f) 25 Q I would like to show you a document that v e

19 1 Lanoco 341 2 previously has been marked as B&W Exhibit 409 and refer fs(sj 3 you to pages W 21837 through W 21877, and ask you if the 4 reactimeter data that you recall receiving on the 31st 5 or prior to the 31st was in a format similar or the 6 same as the material attached thereto. 7 A No, it wasn't. 8 Q What, if you can describe it, are the 9 differences in the format or if there are any 10 similarities that you can point out to help me identify 11 the reactimeter data you are talking about? Obviously, 12 this reactimeter data is referring to a whole different 13 transient. That is not what I meant. I meant, is the s f% j) 14 format similar, not is this the actual document you 15 received? 16 A only in the sense there are columns of 17 numbers with plant data on them. IO Q But the reactimeter data you recall wasn't 19 generated in a format identical to that? 20 A No, it wasn't. 21 gg Q Do you know what became of that reactimeter l 22 data, the reactimeter data you got on or before March I 23 31st with respect to the March 28, 1979 event? l 1 24 A Yes. ./~N (_,) 25 Q What became of it?

f 0 1 Lcnoas rx 2 A It is in the computer file cabinet or in i i V 3 my office. 4 Q Do you still have the original of it? O 5 A I have the copy that I received on that day, 6 yes. 7 Q It was a Xerox copy? 8 A No, it was a carbon copy. 9 Q Was it on computer paper or was it on 10 regular-size business paper? 11 A It was on computer paper. 12 Q You can make a carbon copy of those computer 13 printouts? g_)g \\- 14 A Apparently. 15 g You still have that, though? 16 A Yes. 17 Q Do you recall whether that material was 18 provided to your lawyers in response to the document 19 production in this litigation? 20 A No, I do not. g 21 Q You don't know? 22 A I don't recall. 23 Q I show you a document that has been marked j 24 for identification as B&W 607, and ask you -- the cover (%. (,) 25 of this document, which appears to be handwritten pages

1 1 Lenoco 343 2 of a notebook, reads "LOFW W/O EFW" and then "Lanese." 3 Does "LOFW" stand for loss of feedwater? ~ 4 A Yes. lk 5 Q Does "W/O" stand for without? 6 A Yes. 7 Q And "EFW" I take it is emergency feedwater? 8 A Yes. 9 Q Can you identify this document for me? I 10 A Yes. i 11 Q Please do. 12 A This is a notebook that I began keeping 13 within a day or two after the accident. /3 \\ N/ 14 Q Did you keep this notebook chronologically? 15 Did you fill the pages up as you went along on a 16 day-to-day basis? 17 A Except for the first several pages, I did 18 keep it chronologically. 19 Q The first page that has horizontal lines on 20 it has a date at the top of 3/31,79. 21 A Yes. 22 Q Is that where you began keeping things 23 chronologically? 24 A .That was the first entry that I made in the /() 25 notebook as I was taking notes.

2 1 Lanoco 344 2 Q Then on page W 028069, there is an entry ,f S N) 3 for March 30, 1979. 4 Could you explain why there is a March 30th 5 entry and then a March 28th entry on the next page 6 following? Do you have any explanation for why these 7 don't seem to appear in sequential order? 8 A I started the notebook on the 31st and then, 9 subsequently, transcribed notes from the 30th and 28th into the notebook. from the 30th anyway 10 into 11 I am perplexed about the 3/28/79 entry. 12 That doesn't appear to be dated correctly. 13 Q could it be that the data under the 3/28/79 O 14 entry is a recollection of what you knew on that day 15 or information that you obtained? 16 A No, it is not. 17 Q Is the information that you say was under 18 the entry starting -- dated 3/30 which appears beginning 19 on page W 028069, you say that is a transcription of 20 notes that you had taken other than in this notebook on 21 that day? ggg 22 A I'm fairly sure that it is a transcription, l. 23 yes. 24 Q Do you recall whether the transcription was l /~ i (N a verbatim transcript of all the notes you had taken on - 25 k

345 3 1 L0noco 2 that day? ,r ) \\"# 3 A Yes. 4 Q It was? h 5 A Yes. 6 Q Do you recall any other notes other than this 7 notebook and the notes from which you transcribed the 8 material appearing under the date March 30, 19797 Do 9 you know of any other notes that you kept with respect 10 to the Three Mile Island accident? 11 A There are no other notes. 12 Q When, if you can recall, did you write the 13 title or heading on this front page of the notebook, (~) 14 " Loss of Feedwater without Emergency Feedwater"? 15 A The first weekend after the accident. 16 (continued on next page) 17 18 19 I 20 h 22 23 24 I (~'; 25

i 346' /1 i LanG00 2 Q During that weekend, had you come to (~N) D' 3 know that there had been an unrecognized loss of coolant 4 at the Three Mile Island facility on March 28th for G 5 some period of time? 6 A I don't know. 7 Q What is your best recollection as to when 8 you learned that there had been an unrecognized loss 9 of coolant from the reactor coolant system at Three Mile 10 Island on March 28, 19797 11 MR. GLASSMAN: Objection as to form. Lack 12 of foundation. 13 MR. BENEDICT: I will press my question. 73 14 (Record was read back.) 15 MR. BENEDICT: Is your objection based on 10 the fact that I haven't established that Mr. Lanese 17 knows that there was an unrecognized loss of 18 coolant on March 28, 19797 19 MR. GLASSMAN: It is based on the fact that 20 I am not sure what you are referring to. There ggg 21 are probably a lot of people who didn't recognize 22 it. I am not sure what you are referring to or 23 what the import of the question is. 24 MR. BENEDICT: That is patently ridiculous. ,a l I (, 25 I don't understand why you get involved in these

347 1 Lenoco 2 questions. If you are going to tell me that / ~.T Mr. Lanese d esn't know that there was at one 3 time an unrecognized, what your client calls 4 an unrecognized loss of coolant from the reactor 5 e lant system on March 28, 1979 at the Unit 2 6 on Three Mile Island, then that is beyond the 7 8 pale. I wasn't going to insult him by asking him 9 10 such a question. MR. G LAS SMAN : I don't know why you are gg 12 making a fuss. MR. BENEDICT: Because you are interfering. 13 O' Let's just get along with this. If you have an 34 15 bjection to form, fine, you can preserve it, but 16 giving a lot of speeches about it l MR. GLASSMAN: I wasn't giving a speech. 17 18 You were. MR. BENEDICT: You told me there was a lack gg f f undation. You asked for the question back. 20 The only problem I could see with it on the issue 21 f f undation is whether you were suggesting 22 I that Mr. Lanese has never learned that fact. 23 MR. GLASSMAN: I made a very brief objection 24 as to form. I permitted you to ask the question 25

1 Lanoce 348 to obtain answers. It was you who then speculated ./~N 2 ,] as to the nature of the form objection and who 3 decided to engage in colloquy. 4 lll MR. BENEDICT: I will tell you what. One 5 6 time your partner, Mr. Seltzer, told me that if j I couldn't state the specific reason for my 7 8 objection as to form, the objection was a nullity. I challenge yu to state your specific 9 10 reason for your objection as to form. MR. GLASSMAN: You received it. 11 12 MR. BENEDICT: What is it? 13 MR. GLASSMAN: The record stands, and whateve:- ,_s it is, it is. You may proceed. You are making 34 15 a travesty of this for reasons I can't understand. 16 MR. BENEDICT: I am not making a travesty. I am discussing this issue because there has been 17 18 a constant effort on your part to interfere with the examination of the witness. You are 19 20 constantly counseling with the witness. You are c nstantly taking him out of the room to talk 21 with him and I don't understand why. 22 Let's just get along with it. This is not 23 very controversial stuff. Let's get through it 24 ,m ) 25 and a t have to lay every foundation question. l 1

1 Lnnoco 349 2 If you are suggesting for a moment that s ( ) s_/ 3 I couldn't ask that question subject to 4 connection, your grasp of evidentiary law is 5 limited, to say the least. 6 MR. GLASSMAN: Thank you for your second 7 speech. The only new point that you have made 8 is that I have supposedly had too many conferences 9 with the witness at various points. 10 There have not been a lot of conferences 11 and I would note that in line with requests made 12 by your firm and we, too, by our firm, there have 13 been points where we have attempted to be O 14 cooperative in making sure that witnesses were 15 responsive. 16 MR. BENEDICT: I think both you and I know 17 why that issue came up and I don't think we have 18 to go into it on the record. 19 MR. GLASSMAN: Why don't you continue. 20 MR. BENEDICT: I agree. I am asking only 21 that we can spend the rest of the day doing this 22 relatively directly. 23 MR. GLASSMAN: I told you at least six 24 times that you should continue rather than engage /~ (,%) 25 in speeches.

350 1 Lnnoco 2 MR. BENEDICT: If you promise not to, I

/3

(~) Promise not to. 3 4 MR. GLASSMAN: Continue. 5 Q Could you look through this Exhibit B&W 607 6 and tell me whether or not it includes all the pages 7 of your notebook as best you can recall? 8 MR. GLASSMAN: I assume you are asking g the witness to examine every page or what is the 10 import? 11 MR. BENEDICT: I am asking him to do whatever 12 he has to do to establish, to the best of his 13 ability, that he recognizes it as being a complete I's/ 14 document. 15 A Without comparing page for page to the 16 original, this appears to be complete. 17 Q You have no reason to believe that it 18 isn't? 19 A Not at this point, no. 20 Q We had a pending question which is lurking 21 somewhere behind all of our colloquy, and if Mr. Danyo 22 can find it, I would like to get an answer to it. 23 (Record was read back.) 24 A I don't know. (^') 25 Q Do you recall whether you learned or heard \\a

1 Lanoa 351 2 that prior to the end of the weekend immediately ,a k~) 3 following the accident on March 28th? 4 A No, I'm sorry, I don't. h 5 Q Do you recall at any time that you began 6 to consider the events that occurred on March 28, 1979 7 to be in at least part a loss of coolant accident? 8 A No, I can't recall. 9 Q Are you aware today that there was for 10 some period of time at the Three Mile Island Unit 2 11 facility on March 28, 1979 an unrecognized loss of 12 coolant through an open pilot operated relief valve? 13 A Yes. 10 (,) 14 Q Were you aware of that before our discussion 15 commenced today? 16 A Yes. 17 Q Do you recall whether you knew that fact 18 before the end of the summer of 19797 19 A Yes. 20 Q But you can't be more precise with respect 21 to when you learned? G 22 A No. 23 Q on the front page, you will notice in the 24 upper right corner of the cover of the notebook there 25 is a handwritten file number which reads, " File: 2240.0." (^}> \\._ a

1 Lnnoco 352 2 Is that in your handwriting? i \\ A Yes. 3 4 Q What does that file number indicate? 5 A That is a safety and licensing file. 6 Q What is the subject matter encompass <ad by 7 that file? 8 A I believe it is the TMI-2 accident. 9 Q There are, I take it, then,other documents 10 in that file aside from this notebook? 11 A As I recall, yes. 12 Q Are these all.locuments that had you as 13 their source? (O _) 14 A No. 15 Q was this file a file kept generally within 16 your group? 17 A No. I should add that this notebook no 18 longer resides in the safety and licensing file. I had 19 put it there. Subsequent to that, I took it out of the l 20 file and had it in my possession. 1 21 Q What motivated you to remove it from the 22 safety and licensing file? 23 A originally, safety and licensing and safety 24 _ analysis and plant control were near each other, and l f~') 25 when we moved from the Mountain Lakes building, the two v

353 1 Lensas 2 groups were separated, and I started retrieving some (' ') ~ 3 of the files that I wanted to keep so that they would 4 be available for reference. 5 Q Do you recall what, if any, other materials 6 you removed from the file No. 2240.0 at the time you 7 left? 8 A No, I do not. 9 Q Do you recall that there were other 10 materials that you did remove? 11 A No, I don't recall. 12 Q Do you recall that this was the only 13 document that you removed from that file? () \\2 14 A I believe so. 15 Q Were you directed or requested at sometime 16 following the accident to submit to a central filing 17 system materials related to the Three Mile Island event 18 on March 28, 19797 19 A No. 20 Q Who, if you know, set up file No. 2240.07 21 A I believe I did. 9 22 Q Did the file contain material from other 23 people aside from yourself? I 24 A I don't remember. p) 25 Q Was it your intention when you set up the (v

1 Lanoco 354 2 file to include within it material prepared by people f.s 3 other than or whose source was people other than you? 4 A I expected the licensing people to use that O 5 file, yes. 6 Q All the people in licensing? 7 A If they saw fit, yes. 8 Q Did there ever come a time up until today 9 when you were directed or requested to accumulate all 10 of the material that you had with respect to the 11 accident on March 28, 1979 and send it to a central 12 filing location? 13 A No. O 14 Q Did you receive a document request memorandum' 15 in this litigation? 16 A Yes, I did. 17 Q Did you comply with it? 18 A Yes. 19 Q Do you recall whether you searched this file? 20 A By the time I had received the document ll) 21 request, that was a file in safety and licensing, so 22 I did not search 2240.0. 23 Q Are you aware whether anyone else searched i 24 it in compliance with the document request in this (A) 25 litigation?

1 Lonoco 355 A I recall seeing a sticker on the file. 2 'v Q I am n t sure I understand what you mean. 3 A A sticker that says "Do Not Remove," 4 something about it being related to the B&W litigation. 5 6 Q In other words, if original material is 7 returned to you that has been utilized for purposes of 8 this litigation, it has some sticker on it which would indicate to you that that is what happened to it? 9 10 A That's right. 11 Q When was the last time you looked at file 12 No. 2240.0 or any of the material contained in it? 13 A Not recently. O'd 14 Q When did you see that it had a B&W 15 litigation sticker on it? 16 A The last time I looked at it. 17 Q And you don't recall in terms of even 18 'what year that was? A No. gg 20 Q Why did you look at it, if you can recall? A I don't think I was looking for that file, 21 but from time to time I go through the 2200 files in 22 23 licensing because I need to find old information. 24 Q What do the 2200 files, as you refer to (~) 25 them, encompass? G'

11 1 Lanese 356 2 A Accident and safety analysis. 3 Q By " safety analysis," again, are you 4 referring to hypothetical accident scenarios analyzed O 5 for licensing purposes? 6 A Yes. 7 Q Was there any other central file to which 8 you submitted material related to the Three Mile Island 9 accident? 10 A safety analysis and plant control has a 11 central file. 12 Q Does that have a specific designation, that 13 file? 14 A Yes, it does. 15 Q Do you recall what it is? 16 A No. 17 Q Who would you ask in safety and licensing 18 analysis to determine which file that is? 19 A I would look on my file listing. 20 Q What is a file listing? You said you would ggg 21 look on your file listing. 22 A It is a listing by number and by 23 cross-referenced subject. 24 Q Is it organized by subject matter? 25 A No, it is not.

357 12 g Lanese 2 Q How is it organized? A I submit a file with one to four key phrases and a sequential number is assigned to that 4

1. 11**

5 6 Q Is the file listing that you referred to a file listing which pertains only to the 7 8 files which you have submitted or does it include every ne's files? 9 A It should include any other central filing 10 information on the accident. 13 12 Q Is the file listing limited to a listing f material related to the accident? 13 A mo. 1. 15 Q How long has this procedure of using key w ras and receiving a number assignment been in place? 16 A A few months. 17 18 Q What or how were files that had existed 19 prior to the institution of this practice, how were they incorporated into the system? 20 h A By assignment of key phrases and reference 21 numbers. 22 23 Q So there was an effort made to go back and catalogue the material that existed prior to the 24 institution of the present system we are discussing 25 - ---i i-

358 1 Lnnoco ~ (~~)) 2 under the present system? 3 A Yes. 4 Q Did you have any responsibility in seeing lll 5 to it that your materials were properly recatalogued 6 or properly catalogued? 7 A I assigned file names to my material. 8 Q Did you get your material back from central 9 files with instructions to categorize it in some manner 10 and then return it? 11 A No, the material was in my possession and 12 I added the key phrase and we then put it into the fs 13 safety analysis central file. 14 Q What about the material that already resided 15 in the safety analysis central file prior to the 16 institution of the filing system we are discussing? 17 A There was no safety analysis and plant 18 control group central file. 19 Q Did you retrieve any files from the 20 licensing central files for refiling in the safety I 21 analysis central files? 22 A Not after files were labeled for the 23 litigation. 24 Q In other words, if they were in the (- i_J 25 litigation, if they had been labeled for the litigation,

1 Lcnoca 359 l , ) 2 you left them where they were? %J 3 A Yes. 4 Q Was the system that you described instituted 5 in other sections of GPU? 6 A No. 7 Q Who instituted the system you described? 8 A Mr. Trikouros. 9 Q It applies only'to the people within your 10 group? 11 A It applies to safety analysis and plant 12

control, I believe to plant analysis, and Mr. Broughton 13 is utilizing the central file.

g~g Q,) 14 Q You said that there had not been a central 15 file for this group or this collection of people prior 16 to that. Is there a reason why that was true? 17 A It was never instituted before. 18 Q It is not as a result of this being a new 19 group or new assemblage, is that correct? 20 A No. That's right, 21 Q People prior to the institution of this ggg 22 system within safety -- what group was it? 23 A Safety analysis and plant control. 24 Q Within that group, people prior to the () 25 institution of the system we are discussing kept their

l 1 Lanoca 360 \\ own files and there was no central system? 2 ,s / \\ r i A That's right. 3 4 Q Were y u in that group at the time of the Three Mile Island accident? 5 A Yes, I was. 6 7 Q~ How did this file come to be in licensing's 8 central file? A As I said, at the time -- 9 10 Q This document, I am referring to B&W Exhibit 11 607. 12 A As I said before, at that time there was no 13 central file for safety analysis. I wanted to maintain !\\/ it in the central location, safety and licensing 14 15 licensing and safety analysis were in the same proximity. 16 I was familiar with the licensing file numbers, so I filed it in the licensing central file. 17 18 Q Did you make some effort to advise other of 19 your colleagues that you had established this central filing number f r material relative to the accident? 20 A No, my intention wasn't to have everyone 21 22 fr m our 9rouF put it in that file. 23 Q It was only by putting your material into a entral location other people could use it? That 24 es L ) 25 was your purpose? l

Lonoco 361 A Yes. 2 (a i () Q But you did not see to it that other people 3 put theirs in a central location? 4 A 5 6 Q Do you know whether any of the other people did set up a central location for their material with s g respect to the accident? A I d n't know what you mean by central 9 1 cation. 10 gg Q Do something similar to what you did, which was to send this to licencing central files. 12 A No. 13 A () Q You don't recall whether anyone did that? 14 A No. 13 16 Q Is it your recollection that no one did? A No one within the entire company? 17 18 Q I will withdraw the question. I take it that you removed this document, 19 B W 607, from file 2240.0 prior to the time that that 20 file was reviewed for purposes of the litigation? 21 Y A Yes. 22 23 Q Because this file didn't have a sticker n it, as you recall? 24 [ 25 A That's right.

6 362 1 Lanoco 2 Q Did you put this into a file after you O 3 removed it from the licensing central file? What became 4 of this document? Did you keep it again in your h 5 personal files or did you then refile it in this new 6 central system in safety analysis? 7 A It stayed in my desk for a year or two and 8 when we implemented the central system, I put it in 9 our central file. 10 Q What other material, if any, did you submit 11 to central files at that time which related to the 4 12 Three Mile Island accident? 13 A All of my hand calculations are in the 14 safety analysis and plant control central file. 15 Q Other than the filing system that you set 16 up personally in order to assure that material you 4 17 created was in a central location and the filing system 18 that has been set up in safety analysis in the last few 19 months, was there any system instituted whereby material 20 related to the Three Mile Island accident would be 21 centrally filed? 22 A I understand that there was. 23 Q what do you recall about that system? 24 A There are microfilm copies of calculations 9 . f~) 25 and documents that relate to the accident, and they are N/. '9 n

363 l. 1 Lenoco j 2 available in Parsippany. I don't recall where. 3 Q Have you ever heard of something called 4 the GPU System Libraries at TMI? 5 A No. 6 Q Prior to the accident at Three Mile Island, in the beginning of your creation of what has become 8 9&W Exhibit 607, did you keep a chronological notebook i 9 of work you were doing or information that you obtained 10 in the course of your job? 11 A At times I did. 12 Q What times do you recall having done it? 13 A I had,a chronological file most of the time 14 that I was the TMI-2 safety and licensing engineer. 15 I also maintained a separate chronological file with 16 regard to the emergency and main feedwater-modifications 17 to TMI-2 and a separate chronological -- I have been 18 saying file. I mean-notebook -- with regard to 19 asymmetric LOCA leads. 20 Q Was it a notebook like this notebook, a 21 steno notebook? 22 A Yes. 23 Q Did you maintainJany materialiafter, did 24 _ you maintain any chronological notebooks after this? 25 A-Yes. On occasions I still make entries into c

364 1 Lanose 2 the notebook.on asymmetric LOCA loads, and I have a 3 chronological notebook that I started as a result of 4 the chairmanship of the analysis subcommittee. 5 Q other than the notebook that has been 6 marked as B&W Exhibit 607, were any of the other 7 notebooks you mentioned or any other notebooks that 8 you kept provided to your lawyers for possible production 9 in this litigation? 10 A Yes. 11 Q Which, if any? Which, if not all of the 12 ones you mentioned, were provided to-your lawyer? 13 A of the ones that I mentioned, all except O 14 the analysis subcommittee notebook. 15 Q What is tne analysis subcommittee? 16 A The analysis subcommittee is a subcommittee 17 of the B&W owners group. It was chartered by the 18 executive committee in 1981. 19 9 I'm sorry.- Is this the asymmetric LOCA 20 loads analysis subcommittee? 21 .A No. 22 Q It'is different? 23 A Yes. 24 Q' 'When was it chartered? T,) 25 A In late April, early May, 1981.

1 Lanose 365 2 Q What is its charter or responsibility? O 3 A Its charter is to oversee and review all 4 generic analysis work that is performed for the B&W 5 owners. 6 Q You, I take it, are a member of that 7 committee? 8 A Yes, I am. 9 Q I would like to turn your attention in B&W 10 Exhibit 607 to a page numbered for this litigation as 11 W 028090 which has the date at the top of the page in 12 handwriting 4 or April 5, 1979. Before I ask you any 13 questions specifically on this page, is there any 14 handwriting in this document B&W 607 that is not your 15 own? 16 A Not that I can -- not that I have seen. 17 Q Looking at the second entry on page W 028090, 18 it reads, " safety valve leak J.P. Moore. Leaked 6 GPM at 19 2100 psig. Estimate 93 GPM leak now." 20 Is that an accurate reading? 21 A No. 22 Q Can you tell me what it says? 23 A It should be " estimate 9.3 GPM leak now." 24 Q What valve were you referring to when you h 25 made that entry?

l e 21 1 Lanone 366 2 A I presume that'was the code safety valves. J 1 s_/ 3 Q Were you referring to conditions existing 4 prior to the accident at Three Mile Island, conditions 5 at Unit 27 6 A First of all, I have to correct myself. 7 That 9.3 may also be .93. Without seeing the original, 8 I am not sure. 9 As to the question, was that a condition 10 that was existing at TMI-2 1 i t' 11 Q Is this entry an entry of actual conditions 12 existing at sometime at Unit 2 on Three Mile Island? 13 A My recollection is that at some point 14 ' there was a measured 6 GPM leak at 2100 pounds in the 15 system and by extrapolation,.the estimated leakage on 16 April 5 would have been, I presume,.93 GPM. j 17 Q It is your understanding that 1 18 A Lat.me say could have been.93 GPM. 1 19 Q Is it your understanding this entry relates 20 - to conditions existing on April 5, 19797 . 21 A Yes. W 22 MR. BENEDICT: In your bag of tricks,-do 23 you have the original of this notebook? 24 MR. GLASSMAN: Certainly we have it [ 25 _ available, but I do not happen to have this r. e -.e..,, e - s-y ,m- ,~..,,.-new,, ,ga

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~ __ e 1 Lenoco 367 4 ' original with me which doesn't seem to be 2 O 3 sufficiently readable, but we can, of course, j l 4 provide the.t to you. 5 MR. BENEDICT: I guess I might as well 6 make the record clear at this point. I was up i 7 quite late last night and I came to the conclusion 8 that I'couldn't finish today, and the reason was 9 not because necessarily I didn't just have.enough 10 time, it was because as a result of your delivering 11 to me documents on the eve of this deposition that 12 I didn't have a chance to review until the i 7 1 13 evenings during the deposition, I have discovered i. 14 documents that either were illegible when you 15 provided them to us or copied illegibly and I 16 couldn't use them, and I also discovered 17 engineering documents that I am not sure I amN 18 competent-fully to interpret. L 19 As you know, this is a difficulty that - 20 each side has had in terms of the' timing of 21 document production, but I suspect at least I 22 will not be able to finish today. There are i 23 portions of this notebook that I find very hard I l - 24 to read. That is to be expected when:you are \\ 25 - xeroxing off green paper. I understand that, f .+ i.. t "y3 -,w.e e- -+ w-we e--r y- --w-w-en=---a-sN--t -wa+-+--P--r---e--*t-

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s 1 Lnnsoo 368 2 but I may have to ask for access to the original. O \\' I will think long and hard before I ask 3 4 Mr. Lanese to come back. I hope I can finish the 5 things that are important today and decide I can 6 get stuff from somebody else down the road, but s 7 I am afraid I can no longer promise to tie things 8 up. I am going to have to leave it open at the 9 end of the day and read the things over the 10 weekend. 11 MR. GLASSMAN: We hope that you can finish 12 it up. We will be cooperative if it is necessary 13 to bring him back, but we sincerely hope that 14 you can finish it today. 15 If it would help speed things, we could, 16 of course, attempt'to arrange to deliver the 17 original of this notebook today, and we can make 18 a phone call right now and attempt to do that. 19 MR. BENEDICT: Unfortunately, the notebook 20 is really not the major offender. This was an 21 issue I was hoping to resolve since we don't s 22 know where and if there is a decimal point in this 23 number, but it is an issue that we can come back 24 to at some later date, but if you can get the f') 25 notebook down here this afternoon, we can try at-v

369 Lnnoso 2 least to clear up these issues, but there are O 3 some ones that are open with respect to some of 4 the other files I got on Monday before this 5 deposition. 6 MR. GLASSMAN: I will just note that we will 7 again try to be cooperative. While I recognize 8 the difficulty of going through documents to 9 ascertain whether each page is or is not readable 10 in the reproduced form, if in the future-it would 4 11 be possible to, as soon as you receive such 12 documents, identify any such problem, we could, o 13 of course, make the originals available before 14 the examination starts and in that way avert this 15 kind of a problem. 16 MR. BENEDICT: As I say, I agree that would 17 he the best of all possible worlds, but 18 unfortunately when I am confronted with a box of 19 documents on a Wednesday before the deposition 20 and another box of documents on a Monday the day 21 before the ocposition was supposed to commence, 22 I didnit have an opportunity to read them. There 4 23 is a disagreement. 24 I may be giving you the benefit of-the l ) 25 doubt when I said I got them-on Monday. I have \\/

0 1 L2noco 2 been told I may have gotten them on Tuesday 7-6 4 kJ 3 morning. 4 MR. GLASSMAN: They were sent Monday, but 5 regardless 6 MR. BENEDICT: The timing of the production 7 of the documents I am afraid made it impossible 8 for us to be as thorough in their review as we 9 might have been, and I am afraid I am going to 10 have to at least put Mr. Lanese over for another 11 day, but maybe we can decide we can cover the 12 same issues with somebody else. 13 MR. GLASSMAN: I will make only one more O (_j 14 point, and perhaps we can go on. 15 As you know, we have had this problem 16 frequently with B&W witnesses, but particular 17 documents produced here several days I believe 18 before the deposition began were not that 19 weighty. Nevertheless, we will try to be 20 cooperative. r 21 Q Referring to page W 028090, it is your %v 22 recollection then that this entry was with respect to l 23 conditions existing on or about April 5, 1979, is that 24 correct? l l t' 3 25 A No. ( I l

1 Lnnoco 2 Q What can you tell me about when these e nditions existed? 3 4 A They may never have existed. 5 Q Was this a calculation attempting at least 4 6 to determine the conditions that existed on or about 7 April 5, 19797 8 A As I recall, the intention was to calculate 9 that if there really were that 6 GPM leak that had 1 i 10 existed at sometime and that leak source was now 11 reinitiated, what would it be at the present plant 12 conditions, and that was the calculation that Jim 13 Moore made. 14 Q Who is Mr. Moore? l 15 A At that time, he was components engineering 16 manager, and he was at the site by this time. 17 Q Why do you have this entry in your notebook? 18 A It would have related to hydrogen generation 19 or a transport of hydrogen to containment from the 20 Pressurizer. 21 Q Because the valve you were discussing is 22 one of the valves on the top of the pressurizer? 23 A Yes, having a leak in the valve would have 24 been beneficial. 4 25 Q Because it would have been a pathway for the -gr + y 2+.-..i-._,- -m,

1 Lanoco 372 1 4 l 2 release of hydrogen in the system? 3 A That's right. 4 .Q What did you understand to be the condition 5 of the valve at issue here prior to the Three Mile 6 Island accident? 7. A I didn't have an understanding. 8 Q Have you since come to learn whether or not 9 that valve was leaking prior to the accident? 10 A No. j 11 Q You identified it or it is identified as a 12 safety valve here. I take it that means it was one of 13 the two code relief valves as you understood it? 14 A I don't recall. 15 Q At that time, did you know the distinction 16 between the pilot operated relief valve and the code 4 17 safety valves? 4 18 A Yes. 19 Q Would you have referred to -- at that time, 20 did you ever refer to the pilot operated relief valve 21 as a safety valve? 22 A No. I 23 Q could you turn to page, I will just read 24 the last three digits, to page '103. Since you seem to '[ ) 25 be'a better reader of your handwriting than I am, can v I .-r -v, -m..

373 1 Lonoco 2 you read the contents of that page? \\_/ 3 A I am not sure I agree with that presumption. 4 On 4/12/79, this page indicates I had a conversation, 5 it was a phone conversation -- 6 Q Let's just get the text in first. It says 7 " King House ITI." l 8 A Yes. The next line says, " Relief valve to 9 quench tank." Following the written line, it begins, 10 " Piping configuration of piping from valve to quench 11 tank - pipe sizes and lengths." Next line, "-sent him 12 drawing No. 2403,2644." 13 Q Is' King House a person? CE) 14 A Yec. i 15 Q Who is Mr. House? 16 A I don't recall. I presume he is a person. 17 Q Who or what is ITI? 1 18 A Intermountain Technology. i 1 19 Q Incorporated? 20 A I believe that is right. 21 Q Is that an organization that GPU uses for 22 consultation? 23 A No. 24' Q What was ITI's involvement with the Three (O ,/ 25 Mile Island accident?

1 Lanoco 374 2 A They were doing some analysis for someone b 3 with regard to the TMI-2 accident. 4 Q Could you tell me what -- do these notations 5 reflect a conversation you had with someone at ITI? 6 A Yes. 7 Q What was the substance of the conversation? 8 A I recall.that among other people, ITI was one 9 of the vendors or consultants or analysts that we were i 10 providing modeling information to in order that they 11 might investigate the accident. 12 Q Is the information this person is requesting 13 related to what is called here the quench tank, is that 14 the same as the reactor coolant drain tank? 15 A Yes. 16 Q Do you know what purpose ITI was going to 17 put this material to, the information you sent to them? 18 A It was related to modeling the relief valve 19 discharge to the quench tank. 20 Q What do you mean when you say "modeling" 21 something? 22 A Developing a computer model with which 23 to analyze the response of a system. 24 Q Did you ever see any results or any models [ ') 25 prepared by ITI with respect to the reactor coolant v

375 1-Lnnoco 2 drain tank? O 3 A Mo. 4 Q Do you recall having any other contact with 5 the people at ITI other than the conversation partially I 6 recorded here? 1 7 A I believe I provided them with other 8 information, yes. 9 Q Was it on the basis of him calling you up 10 and asking you for specific information? 11 A Yes. 12 Q Aside from providing him with specific 13 information at his request, did you have any other i (' 14 responsibilities with respect to modeling the piping 15 and valves of the reactor coolant drain tank? i 16 A Yes. 1 l 17 Q What other involvement did you have? 18 A I worked with Energy Incorporated in 19 developing a model of the drain tank. 20 Q-For what purpose was this model developed? i-21 A It was an attempt to determine the mass ~ tur 22 flow out of the PORV during the TMI-2 accident. 23 Q Was it used for such purpose? 24 A We attempted to use it for such purpose, h 25 yes. s_/

l i 1 Lanoco 2 Q Did you receive results that you considered r \\_/ 3 satisfactory? 4 A No. h 5 Q Was the project abandoned? 6 A Yes, it was. 7 Q Who other than you at GPU worked on this 8 project? 9 A Mr. Broughton provided supervision with 10 respect to the project, and Mr. Trikouros provided 11 comments from time to time. 12 Q Were you the principal GPU employee on the 13 project, as you understood it? O (,/ 14 A I was the principal contact with EI. 15 Q Did EI in fact create the model? 16 A Yec. 17 Q Did you review their work? 18 A Yes. 19 Q Did you conclude as a matter of engineering 20 judgment that it was not going to be effective at 21 analyzing -- it would not be effective at modeling W 22 the flow through the PORV7 23 A I didn't make that determination, no. 24 Q Do you recall who did? (~') 25 A Yes. u-

I 1. 377 g,3,, 2 p Q~ Who?. e O 3 A Mr. Broughton and Mr. Trikouros. 4 Q Was that the end of that project? h 5 3 y. 6 Q About when did that occur? 7 A Summer of '79. 0 Q Do you know of any.other projects undertaken t 9 by or for GPU to determine the mass flow rate through 1 the PORY during the accident at Three Mile Island? 11 g y,,, -Q Could you describe that project or those projects? 14 A There was a task that I undertook using 15 a pressurizer model to determine flow rate through the 16 PORV by duplicating the pressurizar pressure response. 4 17 2 When you say "model," do you mean a computer 18 model? A

Yes, 20 j

Q Were your efforts successful in creating 21 .an acceptable model or acceptable result?- h 22 A Only in a very limited sense. 23 Q Is it true that today, even today, no one 94 knows the mass' flow through the-PORV during the first-25 hours of the Three Mile Island ~ accident? ?

Lancos 378 1 A I don't know. 2 ) '~' Q Do you know? O A I don't know the mass flow rate, no. 4 Q Within what range in terms of a percentage {lg 5 r an err r range have you estimated the mass flow 6 through the PORV during the first few hours of the 7 accident? g A I never attempted to place an error band on g the estimate. 10 ii Q Is it your opinion that the estimates that 12 you have made, is it your engineering judgment that the estimates that you have made are accurate within 13 A I i \\~ plus or minus 5 percent? 14 MR. GLASSMAN: Are you asking Mr. Lanese 15 to comment or make a judgment about the accuracy 16 of some work he did? 17 18 MR. BENEDICT: Yes. I am asking when he 19 did it, what his state of mind was with r,espect to the result at the time he arrived at the result. 20 MR. GLASSMAN: I don't think there has been 21 O 22 any testimony that there was any result. MR. BENEDICT: My impression was that he 23 hadn't put an error band on it. 24 /'^s ( s, 25 MR. GLASSMAN: Perhaps you could ask the ~ e

380 1 Lenocs ('} 2 MR. GLASSMAN: You are not asking him to '<j 3 speculate? i 4 MR. BENEDICT: No. lh 5 A The problem is I don't have an estimate with 6 which to make that judgment. When we abandoned the 7 e s t im at e, the attempt to evaluate the flow out of the 8 PORV, there wasn't a latest estimate that I would stand 9 by. 10 Q In other words, when you abandoned the 11 project, it was abandoned at least in part because you 12 had been unsuccessful in arriving at an estimate that <w 13 was viewed as useful for purposes of further analysis? i \\ \\_) 14 A We abandoned it because there was no need 15 to duplicate the work that B&W was performing. 16 Q Is it your understanding that B&W has come 17 up with an accurate or useful figure for mass flow 18 through the PORV? 19 A I believe they have a number that they 20 consider correct. 21 Q Do you -- 22 A Not correct, but useful for study. 23 Q Have you or have other people at GPU used 24 that number for purposes of analysis? im i 'w / 25 A I haven't.

381 1 Lansco 2 Q So you don't have an opinion on its ) J 3 accuracy? 4 A No. h 5 (Whereupon, a luncheon recess was taken 6 at 1:00 p.m.) 7 8 9 10 11 12 3 oV 14 15 16 17 18 19 20 21 22 l 23 24 rm ] 25

382 1 2 AFTE RNOON OES S ION ^ 1:55 p.m. 3 4 LOUI S C. LANE SE, having been 5 6 Previously' sworn, resumed and testified further as follows: 7 g EXAMINATION (Continued) BY MR. BENEDICT: g 10 Q Did there come a time sometime after the J 11 accident at Three Mile Island on March 28, 1979 when you 12 became involved in efforts to calculate the net addition 13 of water to the reactor coolant system during the ( ( 14 transient? 15 A Yes. 16 Q Could you describe for me briefly the nature 17 of that project? j-18 A The purpose of the task was to, by using 19 information available from the computer printout, from 20 the reactimeter, and from understanding of systems 21 OPeratio,ns, to estimate the amount of water that was 22 added by way of high pressure injection and makeup 23 taken out by way of letdown, and determine the HPI 24 makeup injection scenario during the first two to three (D 25 hours of the accident.

Lanoce 383 2 i '^N 2 Q You were using the expression HPI makeup. 'a) Is it true that there is only one set of pumps and they 3 4 function both in the makeup mode and in the high k pressure injection mode? 5 6 A The pumps themselves can function as either 7 makeup pumps or high pressure injection pumps. The 8 valving associated with those two modes is different. 9 Q So -- 10 A As well as the piping. 11 Q It is a different mode of operation for the 12 same set of pumps? They are different modes of operatior, 13 for th*e same set of pumps, I take it, makeup and high 73 t t 14 pressure injection? 15 A Yes. 16 Q About when did you receive a request to do 17 this task? 18 A May 1979. 19 Q From whom did you receive it? 20 A Mr. Broughton. l 21 Q What did Mr. Broughton say to you with 22 respect to your project or task? Did he advise you of l 23 why he was seeking to have this information determined? 24 A Yes, it was part of an overall attempt to (3 .r / 25 analyze the TMI-2 accident. x

L0nco g 384 7' Q Was Mr. Broughton a part of a task force Q)' 2 r gr up of people put together for that purpose? 3 A I don't recall. 4 lll Q Did you ever consider yourself to be a 5 member fa 9r up or task force to examine the 6 circumstances surrounding the Three Mile Island 7 accident? g A 9 10 Q Y u say you were given this assignment sometime in May. Did Mr. Broughton or did anyone else 11 12 assign to this project any particular priority? fN 13 A It had a high priority. 14 Q Did you understand that you were to spend 15 the majority of your time on it until it was completed? 16 A I can't say that I remember. 17 Q Did it in fact occupy a substantial or even 18 a majority portion of your time during that period, the 19 period following your receiving the assignment? A I d n't believe it was a majority, but it 20 was a substantial period of time. 21 22 Q When did you stop work on the project or when was the project completed? 23 A I completed my work on the project on the 24 73 t 1 (_,/ 25 makeup addition sometime in early summer of 1979.

385 4 Lansco i i 2 Early to mid-summer. ( ]N N._ Q The summer solstice is on the 22nd of June. 3 4 Do you consider that the beginning of the summer or is { 1 lll that in the middle of the summer? 5 6 A That is the beginning of summer. 7 Q Would you.say that you concluded this work 8 sometime at the end of June or in July, or is it later than that? g 10 A I believe by July, by the end of July. 11 Q Were you working with anyone else on this 12 project? 13 A Only with Mr. Broughton. fS O 14 Q Was he functioning in a supervisory role 15 only? 16 A Yes. 17 Q Did you prepare a report with respect to 18 your findings or conclusions? - 19 A I prepared an appendix to a TDR. 20 Q Were you the draftsperson or the principal 21 draftsperson of the document that was appended to the 22 TDR7 23 A Yes. 24 Q I would like to show you a document that 25 has been previously marked as B&W Exhibit 341. Could

386 Lanoco 1 ) 2 y u look at the document I have put before you which /^x 'w ' has been previously marked as B&W 341, and teil me 3 4 whether you have ever seen that document before? A Yes, I have. 5 6 Q could you identify it for me, please? A It is a document entitled Accident 7 8 Transient Modeling Analysis, TDR No. TMI-102, Revision 9 No. O, dated May 18, 1979, 10 Q Under " originator Signature," your name is 11

typed, L.

C. Lanese. Is your name there, does your name 12 there indicate that you worked on this draft? (~T 13 A Yes. Q -] 14 Q Does B&W 341, which is dated May 18, 1979, 15 include any of the work or any of the information you 16 learned in the course of your work about makeup and 17 letdown? 18 A I am not sure. 19 Q can you identify for me any portion of this 20 document to which you had input, whether or not it 21 related to makeup and letdown? 22 A With respect to makeup and letdown, Figure 8 23 is the only possible input. 24 Q Other than with respect to-the makeup and 25 letdown?

Lanese t 2 A I also had input to Figure 9. Q Figure 9, what is the document number in 3 the lower left margin for Figure 9, if you can read it? 4 I A 9659. 5 6 I believe I was involved in generating 7 Figure 14. That is 9664, and pages 9667, 9668. 8 That is all, I believe. 9 Q I would.like to show you a document that 10 has been previously marked as B&W Exhibit 171, which is 11 a TDR No. 045, Revision 0, bearing the date August 1, 12 1979, and again it bears your name under the " Originator 13 Signature." O 14 Have you ever seen this document before? 15 A Yes, I have seen it before. 16 Q Do you recognize it as a TDR that was 17 prepared in the mid to late summer of 1979, related to 18 the accident at Three Mile Island on March 287 19 A Yes, I do. 20 Q .Does this TDR 045 contain any portion of 21 the work that you did during that summer with respect 22 to makeup and letdown during the course of the 23 accident? 24 A Yes, it does. 25 Q Could you tell me what section that is?

Lanoco 388 g A Appendix B. 2 V the microfilm number on Q Does Appendix b 3 the lower right is obliterated on my copy, but on the 4 llI lower left Appendix B begins on page N56489. 5 6 A That is correct. 7 Q Does that go through to the end of the 8 document, that appendix? 9 A Through N56512. 10 Q That is the end of the exhibit, B&W 171, 11 isn't it? 12 A Yes. 13 Q Do you recognize any other sections in ,s i,) 14 which you had input in what has been marked as B&W 15 Exhibit 1717 16 A Figure 14 and Figure 9. 17 Q Other than the text that appears in 18 Appendix B, were you wholly or partly responsible for 19 any,of the textual material in B&W 171? 20 A Page 13, the first and second paragraphs 21 might have been written by me. 22 Q Do you at least recognize that you provided 23 input into the information in those paragraphs? 24 A Yes, I did, s (_/ 25 Q Anything else?

389 Lanoes 1 A The textual material that refers to 2 [ 1 i \\ s' Figure 9. 3 4 Q Can you identify where that is in the lh document? 5 6 A Beginning on Page 9. There may be some I did not write the paragraphs. I may have reference 7 8 had some of the input on there. 9 Q On Page 9, does that carry over? 10 A Nothing on Page 10. 11 Q Did you want to change your last answer? 12 A Yes. Now I am not so sure about Page 9, 13 since it isn't the right figure reference. [_s\\ \\' 14 Q Do you recall having the principal 15 responsibilitiy for drafting or providing any input into 16 any section other than the Appendix B? 17 A The one reference that I made already, 18 there are perhaps two paragraphs which refer *to Figure 9. 19 Q And Figure 147 20 A I had some input into the textual material 21-relating to Figure 9. 22 Q Who was the principal draftsman, if there 23 was one, of this document, the textual material? 24 A 'Mr. Broughton. 7-( )! 25 Q This TDR 045, B&W 171, is dated August 1,

390 Lnnoco i 2 1979. Is this the latest version of this TDR or the ,s t i \\'~'/ l nly version of the TDR that you ever saw? 3 A It is not the only version. I don't know 4 lll if it is the last version. 5 6 Q Do you recall ever signing a version under 7 the originator's signature line? 8 A I don't recall. 9 Q Is it true that 045 is a direct outgrowth. 10 from the document we were discussing previously, which 11 has been marked B&W 341 and was headed as TDR TMI-1027 12 A Yes. 13 Q Could you turn to Appendix B in what has \\'J 14 been previously marked as B&W 171. Immediately above 15 the words Appendix B on the first page of that appendix 16 appears the word Draft. Is this the latest version or 17 the last version of the work product you produced with 18 respect to makeup and letdown? 19 A I believe so. 20 Q Do you recall doing any further work with 21 respect to this project after the preparation of 22 Appendix B? 23 A No. 24 Q Do you recall whether you sought out any (m) 25 further information up until today with respect to r

I 391 LGnoco 1 ) 2 makeup and letdown at Three Mile Island during the T v accident since you concluded drafting what is Appendix B 3 to 1717 4 A No, I did not. 5 again, I think there is 6 Q Is it in fact 7 an ambiguity because of the construction of my 8 question. Did you do any further review following the 9 conclusion of this draft of Appendix B7 10 A No. 11 MR. BENEDICT: Could you mark this as the 12 next in order. (~' 13 I would like to ask tne reporter to mark b) 14 the next document as B&W 608 and note for the 15 record that this is one of the documents that 16 I found some of the pages to be either very 17 difficult to read or impossible, and they do not 18 concern the portions'that I want to talk about 19 today but 'they are one of the documents that we 20 may have'to try to copy in a different manner. 21 MR. GLASSM N ' If you decide that ycu do g 22 want thac, let us know. 23 (Document containing information used in 24 preparation of Appendix B and Figure 14 of TDR (^'1

x. /

25 No. 045 ma'rked B&WsExhibit 608 for i 1 s., O ,e g

Lnnoco 392 1 (~'T 2 identification, as of this date.) %-) BY MR. BENEDICT: 3 4 Q B&W 608 is materials which were assembled F in a single file for production to us and were 5 6 identified by your counsel as having come from your 7 files. 8 Do you recognize this material? 9 A Yes, I do. 10 Q Could you describe it for me generally? 11 First, is it in fact a single file or was it in fact a 12 single file in your files? /~N. 13 A I believe it was. b 14 Q It was a single file? K' 15 A Yes. s 16 Q Could you describe for me generally the 17 contents of this file? i, ' 18 A Information that I used in preparation of 19 Appendix B to the TDR and in preparing Figure 14 of the 20 TDR. ~ \\ 21 Q That is TDR 045 which has been previously ggg 22 marked as B&W 1717 N 23 A Yes. 24 Q Putting aside for the moment discussions y> 25 with counsel or review at their direction in preparation x ,Q

Lonoco 393 f r this litigation, when was the last time you looked 2 v at this traterial? A When I put it in the central files several 4

• "9 5

Q Did you review it at that time for any 6 reason other than to be able to categorize it for filing 7 8 purposes? A No. I literally looked at it. g 10 Q When was the last time you looked at this material for some other purpose? gg A I don't know. 12 p 13 Q Do you recall whether you made any entries V or inclusions to this file since the end of 19797 g4 A No. 15 16 Q You believe you have not or you don't recall? 37 18 A I don't remember making any other entries, gg Q Could you turn toward the back of B&W 608, to a document that should be stapled together, starting i 20 with the document number W 026933 through 557 21 A Yes. 22 l 23 Q The first page of this document or that section of the file, the first page of this 24 ,/7 (,) accumulation of pages or document reads Appendix B, 25

l Lanoco 394 t 2 " Inventory change to RCS via makeup / letdown system," {^)/ Ns and written in hand in the upper right margin is 3 June '79. 4 llh Do you recognize this as a previous draft 5 6 of what became Appendix B in B&W 1717 A Yes. 7 8 Q It is dated June 1979. Can you identify 9 more precisely the date that you completed this draft? 10 A The first half of June 1979. 11 Q Was this the first draft of what became 12 Appendix B? f s. 13 A I don't remember. %N 14 Q How many drafts were there to Appendix B 15 before the one that appears in B&W 171? 16 A I don't remember. 17 Q Were there more than one? 18 A Yes. 19 Q Do you recall whether this is the first? 20 A No, I don't recall. 21 Q You can't identify it one way or the other 22 as the first? 23 A No. 24 Q Did you write the textual parts of this ,x k - 25 document?

~ Lunoos t (~) 2 A Yes. U Q Is all the handwriting appearing on the 3 textual portions of this document your handwriting? 4 k A Yes. 5 6 Q Did you submit this draft to anyone for review? 7 g A To Mr. Broughton. I don't know if e.nyone else saw it. 9 10 Q Did Mr. Broughton have any comments with 11 respect to this document? 12 A I don't remember. (~T 13 Q If you today were going to try to find (_ 14 other drafts of this document, where would you look? 15 A I can't think of anywhere else to look. 16 Q You, in considering that question today, 17 would have viewed this file as being the source you 18 would have gone to? 19 A It is all the information I have and that I kept. 20 21 Q Can you by reviewing this document identify 22 whether or not this draft was prepared prior to the interview that you had, that youand others had with 23 the operators on June 13, 1979, which you discussed 24 (_.) with me on Wednesday? 25

Lnnece 396 y A Yes, this was prepared prior to the interview (~~l 2 L) f the operators on June 13. 3 4 Q What specifically leads you to believe that h in the document? 5 6 A My references to batch feeding of the makeup 7 tank with borated water. 8 Q Referring back to Appendix B of B&W 171, f g looking at the first paragraph of Appendix B in 171, 10 there is a reference to " specific interviews regarding 11 operator actions with the makeup and letdown system 12 during the event." (~T 13 That passage does not appear in the (_) 14 paragraph, the first paragraph of the document in B&W 15 608. Are the interviews referred to here the ones we 16 have been discussing referred to in 171? 17 A Yes, the interview on June 13. I call that 18 a meeting rather than an interview. 19 Q To what were you referring in B&W 608 in 20 the first paragra.ph of the draft Appendix B or the 21 June '79 Appendix B, where you say, "Information 9 22 regarding the net mass input to the reactor coolant I I 23 system has been inferred from two sources: First; 1 24 operator interviews regarding their actions during g k) 25 the event."

Lnnoco 397 16 i What operator interviews were you referring <") 2 LJ to? 3 4 A Interviews conducted the day of the TMI-2 lll 5 accident by GPU personnel. 6 Q So these were interviews you read rather than -- they were not interviews where you were 7 g present? 9 A That's right. 10 Q I would like to refer you back to B&W 11 Exhibit 607 which is your notebook, the loss of feedwater 12 without emergency feedwater notebook, and turn your (~ 13 attention to page beginning at W 028129 through page 33. O 14 I would like to ask you whether the text following the er t: 15 6/13/79 represent your notes concerning the interviews 16 which you referred to in Appendix B of 1717 17 MR. GLASSMAN: Objection. Unless I 18 misunderstood the question, the witness had 19 testified that the interviews that he referred to 20 were at an earlier time and that Appendix B refers 21 to a meeting,at least as Mr. Lanese characterized 22 it, on June 13, somewhat distinct in his mind from l 23 an interview. l 24 MR. BENEDICT: I think the question was l /~'s (._) 25 unclear because of its placement.

8 1 Lanoso 2 Q What I mean, referring back to 171 and 3 Appendix B thereto and the first paragraph, you are 4 discussing sources of information, and you refer to lll 5 " specific interviews regarding operator actions with the 6 makeup and letdown systems during the event." 7 Were those specific interviews the same 8 interviews as are indicated to have occurred here in g your notebook marked as B&W 607? t 10 A Yes. That is what I recommend calling 11 meetings with the operators for simplicity. 12 Q There is a list at the top or toward the 13 top of the page where the 6/13 entry first appears. It O 14 says, as I read it, "TMI-site ACRS preparation," and 15 then it gives a list of people's names, Keaten, 16 Broughton, Gary Miller, LCL--and I take it that refers 17 to you? r l 18 A Yes. 19 Q Craig Faust, Ed Frederick, Bill Zewe, 20 Fred Scheimann -- can you read the next name? 21 A John Brummer. 22 Q And J.-Putnam. 23 Is that a complete list of the people 24 present at this meeting? 0V 25 A No.

Lanece 1 399 /^ 2 Q Who else do you recall being present? l k' A I recall that part-time, Dick Dubiel, then 3 of Met Ed, and Tom Van Witbeck of EI were also present 4 f r a portion of the meeting. 5 6 Q Were all the people whom you listed in your 7 notebook present for the entire meeting? 8 A I don't know if Mr. Brummer was there for 9 the entire meeting. Everyone else was. 10 Q You were present for the entire meeting? 11 A Yes. 12 Q Was the meeting called specifically to (~' 13 discuss the issue of makeup and letdown? 14 A No. 15 Q Do you recall for what purposes the meeting 16 was called? 17 A Yes. 18 Q What were those purposes? 19 A There was an ACRS meeting sometime in the 20 near future in which GPU and B&W were going to make 21 presentations regarding the TMI-2 accident. The 23 purpose of the meeting was to ascertain facts in 23 preparation for that ACRS meeting. 24 Q Were you to testify? ,m A' 25 A No.

Loneco 1 400 2 Q Was anyone else indicated here as present (~)'s \\_ to testify? 3 A I believe Mr. Keaten was. 4 5 Q Did you arrive at this meeting with the 6 intention of inquiring into makeup and letdown of the 7 Perators? 8 A Yes. 9 Q Did you have an opportunity to do that? 10 A Yes. 11 Q Do you recall how long you spent discussing 12 that subject with them? r^ 13 A Perhaps 45 minutes to an hour. '\\. 14 Q How long was the meeting, the entire 15 meeting? 16 A Four to five hours. 17 Q Do these five pages represent all of your 18 notes on this meeting? 19 A Yes. 20 Q Are you aware today of any other sources 21 of information with respect to what transpired during g 22 that meeting? I 23 A No. 24 Q This meeting was not recorded? 's k I b' 25 A No.

Lan000 1 401 g-2 Q It was not. %/ was any ne delegated the responsibility of 3 4 taking minutes? A No. 5 6 Q Do you recall discussing the meeting do you recall after the end of the 7 with anyone 8 meeting, discussing the contents of the meeting with 9 anyone? 10 A Yes. 11 Q With whom did you discuss it? 12 A Mr. Broughton. ,S 13 Q Other than with Mr. Broughton, do you -] 14 recall discussing it with anyone? 15 A No. 16 Q What was the subject or subjects, as best 17 you can recall, you discussed with Mr. Broughton? 18 A The makeup and letdown scenario. 19 Q Did Mr. Broughton have any notes on that 20 or any other subject that you saw or that he used while 21 you discussed this with him? 9 22 A I don't remember. 23 Q I am going to leave off these notes again, 24 with the understanding that it is very hard to read them (_) 25 and maybe we can get a clear one later.

m Lanons 402 1 Could I refer you back to B&W 171 and ask (^N 2 %.) y u to turn to the page marked in the lower left margin 3 as N 56497. 4 A Yes. 5 6 Q Looking at Table B-1, the continuation of 7 it, at the page I referred to there is an entry about 8 a fifth of the way down which reads, "1:41:XX~MU-P-1C 9 started? Operator interviews." 10 What is MU-P-1C? 11 A That is the 1C makeup pump. High pressure 12 injection pump. 13 Q In the right margin, you indicate (S () 14 immediately to the right of this entry, operator 15 interviews. Does that mean that the source of this 16 information or the source of this entry was operator 17 interviews? 18 A Yes. 19 Q In other words, the source of the 20 information in that entry was interviews with the 21 Operators? G 22 A Yes. 23 Q Are you referring to the operator meeting, 24 as you called it, on June 13, or are you referring to p(,,) 25 the interview transcripts that you read or some other

2 1 Lenoso 403 gN 2 source of operator interviews? h A I believe it was from the transcripts. 3 4 Q Did you discuss this question of the h 5 initiation of flow via makeup pump 1C during the 6 June 13th discussion? 7 A I don't remember. 8 Q Could you review your notes in B&W Exhibit 9 607 and see whether anything would refresh your 10 recollection about that? 11 A I don't see any reference to that item in 12 my notes. 73 13 Q Does that refresh your recollection as to k_ 14 whether or not it was discussed that day? 15 A I have no recollection of discussing it that 16 day, and it wasn't in my notes. 17 Q From whatever source you obtained this 18 information from the operators, do you recall whether 19 that source or sources indicated what volume of flow was 20 initiated when makeup pump 1C supposedly was started at 21 one hour and 41 minutos? 22 A No, there is no indication of the flow rate. 23 Q Did you utilize this information in drawing 24 any of the drafts or tables attached to Appendix B of ,r' \\ (,! 25 B&W 1717

2 1 Lansoo 403 2 source of operator interviews? A I believe it was from the transcripts. 3 4 Q Did you discuss this question of the lll initiation of flow via makeup pump 1C during the 5 6 June 13th discussion? 7 A I don't remember. 8 Q Could you review your notes in B&W Exhibit 9 607 and see whether anything would refresh your 10 recollection about that? 11 A I don't see any reference to that item in 12 my notes. 13 Q Does that refresh your recollection as to \\'- g4 whether or not it was discussed that day? 15 A I have no recollection of discussing it that 16 day, and it wasn't in my notes. 17 Q From whatever source you obtained this 18 information from the operators, do you recall whether 19 that source or sources indicated what volume of flow was 20 initiated when makeup pump 1C supposedly was started at 21 one hour and 41 minutes? 4 22 A No, there is no indication of the flow rate. l 23 Q Did you utilize this information in drawing 24 any of the drafts or tables attached to Appendix B of c., (/) 25 B&W 1717 x_

!3 1 LanGos 404 MR. GLASSMAN: Which information? (~) 2 V MR. BENEDICT: Information relating to the 3 initiation of makeup pump 1C. 4 MR. GLASSMAN: If there was some information. 5 I notice counsel earlier read into the record 6 there is a question mark that appears immediately 7 8 after the words MU-P-1C started. I don't know g what significance it has. 10 MR. BENEDICT: Let's hold off on the one 11 question I have. 12 BY MR. BENEDICT: (~ 13 Q It is true that you read or saw or heard, C]' 14 either in the course of an interview that you 15 participated in or in the course of reviewing transcripts 16 of operator interviews, that at least someone or someones 17 said at about one hour and 41 minutes into the transient, 18 makeup pump 1C was started. 19 A Yes. 20 Q And your recollection is that whoever it is 21 who you understood to have spoken that, whether you gg 22 heard it or read it, was an operator who was present at 23 one hour and 41 minutes into the transient, present in 24 the control room? l K/ 25 A I only recall that I took that information l

405 24 Lanoco 1 /h 2 fr m an operator interview. ~ \\-) Q Do you recall whether you had any 3 inf rmation with respect to the mode of operation of 4 makeup pump 1C when it supposedly was started on 5 March 28 at one hour and 41 minutes? 6 MR. GLASSMAN: Are you talking about 7 8 information Mr. Lanese obtained independently r information from the source in which he 9 10 obtained this indication that it may have been 11 started? 12 MR. BENEDICT: Again, if you want to expand r~ 13 the question. N_)S 14 Q Was there any other source of information 15 with respect to the initiation of makeup pump 1C at one 16 hour and 41 minutes other than the operator interviews 17 that you have noted here in Table B-17 18 A Not that I am aware of. 19 Q Did you have any information from whatever 20 source at the time you were preparing B-1 with respect 21 to the mode of operation of makeup pump 1C? And by 22 mode I mean whether it was in the high pressure 23 injection mode and utilizing that piping or whether it 24 was in the makeup mode? ('h 4-) 25 A Makeup pump 1C was aligned as a high

l Lnnoes 406 1 (N. 2 pressure injection pump. ) ix.s Q Is it true that 1C is a dedicated high 3 4 pressure injection pump? llh A It can be. 5 6 Q Was it to your knowledge on the day of the 7 accident? 8 A To my knowledge, it was on the day of the 9 accident. 10 Q Makeup pump 1A is also a high pressure 11 injection pump as well as a makeup pump, is that 12 correct? e-13 A Yes. l )3 \\, 14 Q Is it correct when there is an ESFAS 15 actuation, whether manually or automatically, that 16 makeup pump 1B is secured and makeup pumps 1A and 1C 17 operate in their high pressure injection mode? 18 A That is normally true. 19 Q What is the nominal flow rate for 20 makeup pumps 1A and 1C in the~high pressure injection 21 mode at 1600 pounds, if you know? 22 A I don't recall offhand. 23 Q Is it on the order of 1,000 gallons a 24 minute, to your knowledge? (_) 25 A No, I believe it is less than that. l

407 1 Lanoco /^ 2 Q Is it less than 800 gallons a minute, to V) 3 y ur knowledge? 4 A I don't think so. 5 Q Did the sources of information you relied on 6 in drafting Tabla B-1 to Appendix B of B&W 171 provide 7 any information with respect to the volume of flow or 8 the mode of operation of makeup pump 1A at or about an 9 hour and 41 minutes into the transient? 10 A Yes. 11 Q What indications did you have with respect 12 to flow through makeup pump 1A at or about that time? 7s 13 A There were two possibilities. One is that i )i N. 14 it was drawing water from the makeup tank and 15 approximately balancing letdown flow. And the other was 16 that it was drawing water from the borated water 17 storage tank, and it is not possible to determine the 18 flow rate at that time. 19 Q Is it true that even until today you do not 20 know what source makeup pump 1A was drawing from at that 21 time, at an hour and 41 minutes into the accident? gg 22 A There are two possibilities. 23 Q The first possibility you mentioned was that i 24 it was aligned with the makeup tank and that makeup I /~% ,_) 25 injection would have approximately equalled letdown

408 L noco 1 7-2 flow, is that correct? ( A Yes. 3 4 Q So during this period under that first 5 hypothesis or possibility, as you called it, there would 6 be no or no significant net input of water into the reactor coolant system? 7 8 A That's right. 9 Q Now, the other possibility that you suggested. 10 or stated was that the makeup pump 1A was aligned with 11 the borated water storage tank, and am I correct that 12 under that hypothesis you cannot determine the volume 13 of flow through makeup pump 1A for that time period? s 14 MR. GLASSMAN: You are asking for what Mr. 15 Lanese did in the. course of his work? 16 MR. BENEDICT: Not up until today what he 17 understands to be the case with respect to that 18 volume. 19 MR. GLASSMAN: You are not asking him to 20 speculate? l 21 MR. BENEDICT: No. 22 MR. GLASSMAN: You are asking him to l 23 testify as to what he did? 24 MR. BENEDICT: Right, and what he knows 25 from what he did.

409 Lanone 1 ~ A That is correct. [ ') 2 \\J Q And is it correct that you do not know today 3 4 which way the pump was aligned, to which tank the pump was aligned? 5 6 A That is correct. 7 Q Is it correct that makeup pump 1A was running 8 throughout the first three hours of the event? A It appears that that is true. 9 10 Q The mere fact of it operating does not, 11 however, in and of itself tell you what it was actually 12 putting into the system, is that correct? rN . 13 A That's right, for any period of time -- y e s, ( 14 that is correct. 15 Q It is possible to vary the flow of an 16 operating high pressure injection pump by reducing the 17 opening of a valve between the pump and the reactor 18 coolant system, is that correct? 19 A Yes. 20 Q Isn't it true there was some period of time 21 during the first few hours of the Three Mile Island ggg 22 accident when information normally recorded by the 23 computer was lost? 24 A It is unavailable, yes. ') \\ _/ 25 Q It is unavailable today and it has never

410 i I Lnnses ('T 2 been available, is that correct? \\, 3 A That is correct. 4 Q And that period included the time that we 5 have been discussing about an hour and 41 minutes into 6 the accident, is that correct? 7 A Yes. 8 Q At the time of the accident, was the 9 initiation of the high pressure inject 1on pump ^ 10 information that would be recorded on this information 11 source that we have been discussing? 12 A Yes, the plant alarm summary would have 13 (x indicated the 1C makeup pump had been started. 14 Q But since the plant alarm summary 15 information today and always has been unavailable, there 16 is no documentary evidence, contemporaneous documentary 17 evidence, with respect to whether or not this pump was 18 initiated, is that correct? 19 A Yes. 20 Q Do you recall whether the operators, the 21 material that you reviewed with respect to operator 22 interviews and the meeting that you had with the 23 i operators, do you recall whether any operator said 24 anything about changing the flow volume of makup pump ,m i (_,/ 25 1A at or about one hour and 40 minutes into the

i Lnnoco 411 I

7..

2 transient? ) ~ A No. 3 4 Q Isn't it correct that in terms of the lll verall sequence of events on the. day of the accident, 5 6 that one hour and 40 minutes was the approximate time 7 that the last two reactor coolant pumps were terminated? 8 A Yes. 9 Q' Why is there a question mark after the entry 10 we have been discussing on Table B-17 11 A Because there was no independent 12 verification of the operator recollection that a 1C 13 pump had been started. /'T' 14 Q Did you have any reason to disbelieve the 15 Operators with respect to this issue, or do you today 16 have any reason to disbelieve them? 17 A I don't think that was the issue in putting 18 a question mark there. 19 Q Did you h, ave at least two independent 20 scurces of information, one of which was documentary 21 for every other entry in this appenttix B? 22 A That wasn't my point. 23 Q What was your point? 24 A I didn't have any hard information that ,-(,) 25 indicated that the pump had been started.

1 Lanese 432 2 Q It wasn't that you questioned the 3 credibility of the operators, it was a lack of other 4 information? I A Yes. 5 6 Q Did you have any information which allowed 7 you to exclude the possibility that the operators in 8 fact initiated makeup pump 1C at that time? 9 A No. 10 Q Do you today have any such information? 11 A No. 12 Q I would like to ask you to turn and keep 13 two pages before you, because I want to read some O 14 text from the June draft and from Appendix B. 15 Turning in B&W 608 to a page marked W 026935 16 and then also turning in Appendix B in 171 to a page 17 marked in the lower left margin N 56491. 18 (Discussion off the record between the 19 witness and his counsel.) 20 Q Do you have those pages before you? 21 A Yes. 22 Q In the June draft, a draft you said was 23 the earlier of the two we have for Appendix B, you have 24 written at the page I referred to, "With this 25 information in hand, it is possible to postulate

413 L0noco 1 various sequences of events for RCS water addition. 2 (\\_)' These sequences have been limited to three scenarios 3 4 which represent the upper and lower bounds of water lll addition (scenario 1 and 3) as well as a most likely 5 6 amount of water addition (scenario 2)." Whereas turning to Appendix B in B&W 171 7 g and the page I referred to, you have written in the middle f the upper paragraph, "With this information 9 10 in hand, it is possible to postulate various sequences it of events for RCS water addition. An upper and lower 12 bound on water addition (scenarios 1 and 2) can be 13 postulated." f-14 The scenario mentioned in the June draft 15 relating to "the most likely amount of water addition" 16 has been eliminated from Appendix B. Why was that done? 17 A As a result of having borated water storage 18 tank level at three and a half hours, it was possible 19 to know the total injection into the reactor coolant 20 system over the first three and a half hours. Since 21 the total of water -- the unknown quantity of water that 22 could have been injected from the 1A and 1C pumps during 23 that period was small, the upper and lower bounding 24 scenario were really relatively close together, and g (_,) 25 the uncertainties in the most likely scenario weren't

I 3 Lnnoco 414 i worth addressing any more. 2 i ~ Q When y u refer to the upper and lower 3 boundaries, are you referring to what has been called 4 lll scenarios 1 and 2 in Appendix B to B&W 1717 5 A Yes. 6 Q Did you want to supplement that answer? 7 8 A That is it. 9 Q Turning three pages farther into Appendix B 10 of 171 and looking at the page numbered 6494, the statement appears in the middle of the final paragraph 11 12 on that page,"The position of MU-V 16A,B is not 13 known." (' 14 What are those valves? '~ 15 A Those are the high pressure injection 16 valves. 17 Q What is the significance of not knowing 18 the position of those valves? 19 A For any instant in time, it is not possible to know the actual HPI flow rate. 20 21 Q Since you prepared Appendix B of B&W 171, 22 have you come to know what the position of those valves 23 was during the course of the accident? 34 A No. ry (_,) 25 Q Do you have any additional information

415 1 Lnnoso [') 2 with respect to that? (.) A No. 3 4 Q Is the question of position of the MUV 16A 5 and B valves the same question as whether or not the 6 makeup pumps are drawing from the makeup tank or the 7 borated water storage tank? 8 .MR. GLASSMAN: I object to the form. I am 9 not sure I understand the question. 10 A would you read it back? 11 (Record read.) 12 A It leads to the same uncertainty. We know 13 that there was only a limited amount of water injected %.) 14 in the first three hours and 30 minutes. At any given 15 time we don't know exactly the flow rate but we know 16 the integrated flow rate over those three and a half 17 hours was only X number of gallons. 18 Q Have you ever been called -- you, Mr. 19 Lanese -- have you ever been called upon to make an 20 estimate as to the upward limit of makeup pump 1C 21 operation if it had been initiated at approximately one gg 22 hour and 40 minutes into the transient and if it had 23 been initiated at its full rated flow capacity? 24 A That was a thought process that was , ~. s./ 25 required in developing this TDR.

4J 6 1 Lnnoco 2 Q And what was your judgment, if you reached b,r~ "*? 3 A Again, since we knew the total injected 4 lll 5 volume over the first three and a half hours, at full 6 HPI flow, the 1C pump would have run no more than 7 twenty minutes. 8 Q Did you at the same time you were making 9 that calculation or making that estimate, reaching 10 that conclusion, did you reach a similar conclusion 11 with respect to the scenario where the 1C pump is 12 initiated at its full rated flow at one hour forty 13 minutes, and at the same time the 1A pump is permitted -s (_)1 e 14 to pump its full capacity into the reactor' coolant systet? 15 A At one hour and forty-one minutes? 16 Q Assuming those facts were to occur at 17 one hour and forty minutes, did you ever consider that 18 possibility? 19 A No. 20 Q Could you turn to Figure B-6 in Appendix B 21 of B&W 171, which you will find at N 56510. Did you 22 prepare this figure? 23 A Yes, I did. 24 Q What does it purport to reflect generally? (_) 25 I don't mean you to specify every bit of information

Lnnoco 417 1 on it. Would you describe generally'what this figure 2 -~ ( \\ \\'^') intends t Portray? 3 A It reflects the reactor coolant system mass 4 5 inventory as a function of time and the way inventory 6 was being affected by the makeup and letdown and relief 7 valve flow, given the uncertainties in those 8 calculations. (Continued on following page) 9 10 11 12 13 m 14 15 16 17 18 19 20 21 gy 22 23 24 k_./ 25

i l /1 1 Lanoce 418 s 2 Q' Do I understand th'e. top half of the table 7U 3 starting at 0 in the vertical axis and proceeding up 4 to 200,000 to represent inventory additions in pounds h 5 as a function of time? s 6 A Yes. \\ ~ 7 Q Is the' upper line above the shaded-in area 8 in the upper half of'this chart the-maximum upper limit 1 9 flow that could ha've occurred during that period based s 10 on your calculations? 11 A The one labeled Scenario 27 12 Q Yes. \\ s t 13 A Yes, it is. ,) ~ 14 Q And the minimum flow then is the lower 15 bounding line labeled Scenario, I assume numeral l ' h a s' 16 been cut off my copy. Is it on'yours? 17 A It is cut off mine. 18 Q Is that in fact the Scenario ~1 line? 19 A Yes. ~ 20 Q The area, I take it, shaded ik between these ag of uncertaintyN5-21 two lines is the area g s s 22 A Yes. m. 23 lQ Does this figure go 6nly out to 100 minutes? i 24 ,. - ~, ( ) 25 A Yes. '~ s, A-1 A \\ s h O

w 419 1-Lanoso ^ 2 Q You earlier referred to calculations out 3 past three hours. Are they incorporated in this 4 appendix? h 5 A In the appendix? 6 Q Is the information related to calculations s 7 beyond 100 minutes? Figures B6 and B7 seem to relate 8 only to 100 minutes. 9 A I don't believe there are any figures that \\ 10 show results beyond 100 minutes. 11 Q Turning to B7 which is the next page in 12 order, could you explain to me what generally this 13 table or this figure seeks to portray? o 14 A The upper and lower bounds for reactor h 15 coolant system water volume over-the first 100 minutes. 16 Q In order to prepare this table, how did you .s 17 calculate the volume of water? At what temperature 18 and' pressure? 19 .Let me ask the direct question first. Did 20 you make your calculations based on the ~ recorded 21 temperature and pressure parameter for the plant during s.1, h ";' 4 22 the transient for the minutes 0 to 1007 s-ga .J D 23, A Yes, I believe so. Yes. v. -{y' m i, 24 Q-In this chart, in light of the fact-that l} r. - (jN 25, the inventory.is measured 1in' cubic feet, how did you t 9,, ~ .,n '. tvdi . o +. - -. ,..-nn,..

1 Lnnaco 420 73 2 account for water in its vapor phase or steam? L] A This represents a so-called collapsed water 3 4 volume. llh 5 Q In other words, you assume that whatever 6 volume of steam existed was converted into water? 7 A I ignored the steam. 8 Q You ignored the steam content? 9 A Yes. 10 Q Am I reading this table or figure correctly 11 if I said at 100 minutes, the maximum quantity of water 12 you calculated was possible to be present in the reactor 13 coolant system was approximately 9,000 cubic feet whereas O 14 the minimum quantity for 100 minutes, the same time, 15 you calculated could be possibly approximately 4,000 16 cubic feet? 17 A That's correct. 18 Q So between Scenario 1 and Scenario 2, there 19 was 5,000 cubic feet of water? 20 A Yes. 21 Q The total system. inventory if water solid, 22 does that include the pressurizer? 23 A That includes the pressurizer to 220 inches 24 indicated level. O_ ',) 25 Q The total water inventory assuming that level y

421 ~ 1 Lnnsee !3 2 in the pressurizer is 10,500 cubic feet, is that e 1 \\'~/ c rrect? 3 A Excuse me. Let me correct myself. 10,500 4 ll is the water inventory excluding the pressurizer. 5 6 11,300 would be including the pressurizer to 220 inches. 7 Q So in any event, including the pressurizer 8 to that level, the total inventory or the maximum 9 inventory, I should say, or the volume of the reactor 10 coolant system is 11,-300 cubic feet, is that correct? 11 A Yes. 12 Q Turning to Figure B8 of Appendix B to B&W 13

171, could you briefly describe what this table purports 14 to show?

15 A It shows the known or possible times in 16 which the makeup pumps and letdown were operating or 17 not operating. It shows the borated water storage 18 tank level at known times, makeup tank level and 19 inventory contribution, and the total inventory 20 addition as a function of time. 21 Q Do I understand you to be saying that the 22 figures in the bottom line are numbers that you are 23 reasonably confident are accurate within the time frame? 24 These are not scenarios, I take it? fm () 25 A That's right. '~ \\ L

l 1 Lnnoes 422 2 Q So, in other words, from 4 minutes and 7-i 6 3 38 seconds into the accident on March 28th until three 4 hours and 20 minutes and 50 seconds, you know that 5 there'was a total -- there was a gross addition of 6 8,143 gallons, is that correct? 7 A Yes. 8 Q Is it true that you do not, however, know 9 the exact quantity of fluid lost during that same 10 period? 11 A That's right. 12 Q Lost from the reactor coolant system either 13 through makeup or through the PORV or by some other e \\~ 14 method? 15 A No, the sources of inventory loss would be 16 letdown and PORV. 17 Q Is it.a net loss or net gain through the 18 reactor coolant pump seals? 19 A It is a gain. 20 Q There is in the line immediately to the 21 right of MU-P1C, again there is a dash line ctarting 22 at one hour and 41 minutes and ending at two hours 23 and 45 minutes under which is a question mark. 24 Is that question mark there for the same ,p ) 25 reason the earlier one we discussed was where it was?

1 Lans00 423 2 A Yes, the alarm printer was unavailable. (3\\ v 3 Data was unavailable at that time. 4 Q The data from the alarm printer was llh 5 unavailable at times prior to one hour and 41 minutes, 6 is that correct? 7 A That is what I remember, yes. 8 Q But it came back on line or became 9 available again starting at two hours and 45 minutes? 10 A Yes. 11 0 Approximately. So that is the reason why 12 the two-hour-and-45-minute limit, the right-hand limit, 13 is included? 14 A Yes. 15 Q And the reason why you have the time period 16 started at one hour and 41 minutes is because it is that 17 time that your information from the operators indicated 18 that someone at least said that they had started it? 19 A Yes. 20 Q Turning back to B&W 608 and the June draft 21 of Appendix B, looking at the page numbered 5 at the 22 top and reading from the second paragraph, "A basic 23 premise of this report is that the operators' motive 24 for varying makeup and letdown was to control pressurizer .r3j 25 level."

424 i 1 Lanose 2 What basis did you have for using that as 3 a basic premise for this report? 4 A It was a starting point. lll 5 Q Had someone told you that that was indeed 6 the motive of the operators in their control of makeup 7 and letdown? 8 A No. 9 Q Was it necessary for you to make that 10 assumption in order to perform your responsibilities 11 in drafting this report? 12 A Some assumptions were necessary as a starting 13 point. I chose to make this one. As a starting point. 14 Q Are you telling me that in June 1979 you 15 had no basis for using a premise that operators' motive 16 for varying makeup and letdown was to control 17 pressurizer level? 18 A No, I didn't say there was no premise. 19 Q No basis for this premise? 20 A I didn't mean to imply that there was no 21 basis. N 22 Q What do you recall was your basis? 23 A By that time, there was a general 24 understanding that the operator had throttled HPI based ( 25 on pressurizer level indication, and I therefore started

l 1 Lanese 2 with that presumption as a possible motive for 3 subsequent HPI control. 4 Q Do you recall any specific sources for 5 the general understanding you referred to? 6 A No. 7 Q Do you recall whether you found any 8 information supporting that general understanding in 9 your review of transcripts of operator interviews? 10 A No. 11 Q Did you change at any time your view as 12 to this general understanding? Today, do you believe 13 the general understanding is accurate? O 14 A I believe that in general pressurizer level 15 was a prime consideration in controlling HPI flow. 16 Q I believe I asked this earlier, but just to 17 try to close the loop, what, if any, work have you done 18 with respect to these issues, the issues we have 19 discussed relating to inventory change in the RCS during 20 the March 28th accident since the time of your completion 21 of what became Appendix B in B&W 1727 22 A Nothing. 23 Q Are you aware of anyone else at GPU or Met 24 Ed who has done any work with respect to this? 25 A No.

426 I 1 LEnocs 2 Q Are you aware of anyone anywhere who has i '~ 3 done any work with respect to this? 4 A Yes. ll) 5 Q Who? 6 A I also remember that I had other involvement 7 with this work with B&W subsequent to completion of this 8 report. -9 Q What do you mean when you say "this work"? 10 Do you mean the issue of inventory? 11 A The makeup addition. 12 Q What did you do with people at B&W with 13 respect to this? [# 14 A Discussed which scenario to use in their 15 evaluation of the TMI-2 accident. 16 Q Was it a choice between one of the two 17 scenarios in Appendix B to 1717 18 A We ended up choosing one of the scenarios, 19 yes. 20 Q Which scenario did you choose? 21 A Minimum injection scenario. O 22 Q Did you choose that because that assumed 23 the worst case with respect to core uncovery? 24 A 'I t ic really because it didn't make that <r ( ) 25 much difference. v i e

427 1 L noca <g -2 Q But ending up having to choose one or the I qj 3 other or some third alternative, did the fact that 4 reliance on the minimum possible net inclusion of water 5 would lead to the worst possible consequences in terms 6 of core uncovery play a role in your decision? 7 MR. GLASSMAN: Objection. Lack of 8 foundation. 9 (Record was read back.) 10 A You have to specify when in asking that 11 question. 12 Q When what? , 13 A For any particular point in time, I can I3i U 14 minimize or maximize the HPI injection to three and a 15 half hours. 16 Q Over the time since you only had a number,as 17 you testified earlier, that you did not know at any 18 given moment what the input was, but you had gross 19 figures for a time period of three and a half hours, 20 considering those three and a half hours as the when in 21 your question, can you answer my prior question? 22 MR. GLASSHAN: Objection as to form. 23 MR. BENEDICT: Strike that question. 24 (Recess taken.) (h (_) 25 (continued on the following page.)

428 id 1 1 Lanase (~) 2 MR. GLASSMAN: I am pleased to note that I \\ / 3 now have available for your review the original of 4 the document which you have marked as B&W Exhibit 9 5 607. It is availabl'e for your inspection and, 6 obviously, for questioning Mr. Lanese. 7 For our mutual edification, I take note that 8 the page marked W 028090 bearing the date 4/5/79, 9 which we were previously reading and which there 10 was a question as to whether an item that appeared 11 to read "93 gpm" or ".93" or "9.3" appears, so far 12 as I can tell, to read something different, namely, (~N 13 quote, 3 GPM close quote, leak, although you can, \\- 14 of course, ask Mr. Lanese to interpret his own 15 . writing. 16 BY MR. BENEDICT: 17 Q Is that your reading of that? 18 A Yes. 19 Q It is a 3, not a .3 or a 3. or anything 20 else? l 21 A Absolutely. 22 Q To cut through the pending question or the 1 23 question that I withdrew immediately prior to the break, 24 if I recollect your testimony you said that you discussed 25 with B&W choosing a scenario for inventory addition to i I

1 Lenoco 428-A I' land 2 the RCS during the early hours of the Three Mile s "N, t 3 accident, and that you and the people at B&W decided to '/ 4 use, for the purposes of their analysis, the minimum lll 5 scenario. 6 When I asked you why did you choose that, 7 as I understand you, your answer was that there was very 8 little difference between the two in terms of the effect 9 it would have on their calculations or on their use of 10 those numbers, is that correct? 11 A Yes. 12 Q Did you have any other reasons aside from it 13 being not significant? O \\/ 14 A No, but by way of clarification, I should 15 mention that the analysis we are talking about is not a 16 core damage scenario. 17 Q What was the analysis with respect to that 18 B&W needed these figures? 19 A It was an analysis to evaluate the 20 possibility of using the major reactor coolant system 21 and secondary system components at TMI-2. N 22 Q Using them again? 23 A Yes. 24 Q Returning to my question, did you have any (' 25 other reason for picking the minimum over the maximum u b

429 I ! 1 Lensca-2 or some third possibility, aside from the fact that for {\\/- 3 the purposes to which these numbers were going to be 4 used, there was little difference between them? lll 5 A The minimum. scenario is in my mind somewhat 6 more likely.than the maximum scenario. 7~ (Discussion off xhe record between the 8 witness and his counsel.) 9 BY MR. BENEDICT: 10 Q You have the original of what has been r= 11 marked as B&W Exhibit 607 before you. I would like 12 you to turn to the portion of your notes relating to 13 the meeting you had and others had with operators on 14 June 13, 1979. That is at pages W 028129 through '33. 15 Could you review those five pages, which 16 you have identified as being the only notes that you 17 have with' respect to this meeting, and pick out for me i 18 all the entries that relate in any way to your work on 19 . inventory addition during'the early phases of the Three 20 Mile Island accident? 21 A Beginning on page W 028130, item 5. 4BP l 22 Q could'you read that? i 23 A " Makeup plus' letdown discussion with L 24 operators. MU-V127 opened ' as per emergency boration (~} 25 l. A/ . procedure from boric acid mix tank -- check boric acid l 1 i s ..,,..y ,y-, ,.m,-v,.r,- ,_--.---.c._ wy - -.,,,,,, _,, -... ,,y__-.-y y,, -.. - - --

1 Lenocs 429-A rs 2 mix tank level for amounts." ( l w/ 3 Q Was the indication of " check boric acid mix 4 tank level for amounts," was that a note to yourself? lll 5 A Yes. 6 Q Did you do that? 7 A Yes. 8 Q What is MU-V127? 9 A I don't recall now. 10 Q Did you check the boric acid mix tank levels 11 prior to your completion of Appendix B to B&W 1717 12 A I attempted to. 13 Q Did you seek any further information with e ) 14 respect to that level or those levels after you completed 15 Appendix B? 16 A No. 17 Q Were you unsuccessful in obtaining information 18 with respect to these levels? 19 A Yes, I was. 20 Q Is the next sentence under what you read 21 related to makeup and letdown? 22 A Yes. 23 Q Could you read it, please? 24 A "Saw letdown..." I left off the N on ,~ 25 letdown -- "... valve in'dication shut, but didn't check j n i

1 Lanoce 430 (T 2 flow." Q: 3 Q What does that passage mean to you? 4 A We asked if the operators isolated letdown 5 at the time of reactor trip. 6 Q They told you or you vere told? 7 A I was told by one of them that they recall 8 seeing the indication on the control panel that the 9 valve was shut. They didn't recall also having checked 10 letdown flow. 11 Q Did you white out a word on this? 12 A Yes, I did. 13 Q Is that something you did contemporaneously (~}/ w 14 with taking these notes? 15 A I did it a short time afterwards. 16 Q Was there any reason why you whited it out, 17 rather than crossing it out? 18 A It was a crossed-out word, and I just whited 19 it out afterwards. 20 Q Did you ever make a copy of these or any 21 other notes, any other portions of this Exhibit B&W 607 g 22 for anyone else's use? 23 A No. It is a nervous habit I have. 24 Q There are other passages or places throughout t\\ '/ 25 this exhibit where there appear to have been whited-out

431 1 Lanoca 2 words. 7-i'~'/ 3 Is it true that all those areas and places 4 that words were whited out were contemporaneous 1y or lll 5 very soon after you were drafting the material? 6 A Yes. 7 Q Is there any other in the pages that I 8 referred you to, is there any other reference to the 9 makeup and letdown issue? 10 A Yes, the next entry on the same page. 11 Q Which reads? 12 A "One minute, 25 sec. DH-VSA was opened. 13 1B plus 1A both running. Then opened up MU-V16A." \\ '/ 14 Q Does the entry "1:25 sec." mean 1 minute, 15 25 seconds after reactor trip on March 28, 19797 16 A Yes. 17 Q Where did you get this information? 18 A By examining makeup tank level, there was a 19 change in level that indicated some sort of operation 20 with the makeup system. 21 Q Does this note at the bottom of page 130 not 22 relate to your conversations with the operators? d I" 23 other words, this was not information you gained during 24 that meeting? /"N() 25 A There were two sources of information. In

432 1 Lnnees ('~N 2 having seen the change in level at a minute, 25 seconds, t ) 3 the question was what did you do at that time. The 4 answer was that they opened the DH-VSA which was a 5 normal procedure, and started the 1A and 1B pumps in 6 order to get additional flow in the system, and opened 7 MU-V16, since that was all normal post-trip activity. 8 Q The 1A and 1B pumps you referred to are 9 makeup pumps, is that correct? 10 A Yes. 11 (Discussion off the record between the 12 witness and his counsel.) 13 BY MR. BENEDICT: LJ 14 Q What is the next entry you see that relates 15 to this issue we have been discussing? 16 A The next entry is the top of the next page. 17 Q What does that say? 18 A " Tank increase-recire. of makeup pump 19 puts some water into MU tank at about 90 gpm per pump." 20 Q "Recirc." means recirculation? 21 A Yes. g 22 Q And "MU tank" refers to the makeup tank? 23 A Yes. 24 Q Did you learn this information during the A t I> 25 . course of your meeting? r

433 1 Lancee ,- ~s 2 A Yes. ( ) v 3 Q Was it in response to a specific question, 4 this information? h 5 A Yes. 6 Q Do you recall what your question was? 7 A No. 8 Q What does the next entry say, or at least 9 it is the next entry you read? Is that related to the 10 inventory issue? 11 A Yes. 12 Q Could you read that? 13 A "Recire. opened when not on ES. Have seen 's~~] 14 similar changes when come from.BWST." 15 Q "ES" stands for engineered safeguards? 16 A Yes. 17 Q Does engineered safeguards include actuation 18 of the high pressure injection system, as you used it 19 here? 20 A As used here, it was meant to mean HPI 21 initiation. 22 Q ESFAS actuation? 23 A Yes. 24 Q "BWST" is borated water storage tank? , ^g (,) 25 A Yes.

1 Lanoes 434 .r~N 2 Q What next do you see on the page related to 5 ) \\_/ 3 the issue we are talking about? 4 A "2 minutes and 1 second ES-isolates 5 recirculation." 6 Q "ES" is, again, the engineered safeguards? 7 A Yes. 8 Q At 2:01, high pressure injection was 9 initiated on ESFAS signal on March 28, 1979, is that 10 correct? 11 A Yes. 12 Q What is the significance for purposes of 13 your inventory study to know about recirculation of the. g- 'LJ 14 pump? 15 A In looking at figure B-2 of the Appendix B, 16 B&W document 171, both the previous entry and this entry 17 are related to the change in makeup tank level. The 18 opening of the DH-V5A meant that water was being drawn 19 from the borated water storage tank as opposed to the 20 makeup tank. The increase in makeup tank level from a 21 minute, 38 to 2:01 was due to HPI pump recirculation. ggg 22 At two minutes, pump recirculation valves were closed, 23 and makeup tank level flattened out. 24 Q Pump recirculation ~ 's_ 25 (Discussion off the record between the

0 1 Lanose 435 rw 2 witness and his counsel.) ( ) '\\.) 3 BY MR. BENEDICT: 4 Q Pump recirculation adds water to the makeup 5 tank? 6 A Yes. 7 Q The next entry reads: "2:01-4:38." 8 Does that refer to the period between 2 9 minutes and 1 second and 4 minutes and 38 seconds on 10 March 28th into the transient? 11 A Yes. 12 Q Could you read the text following that? 13 A "May have started some letdown to explain ,s + \\ 14 the 20 gpmsdid not have boric acid pumps on. Guess 15 is leakage from the BWST." 16 Q Again, are these entries made here as a 17 result of information you were hearing from the operators ? 18 A Yes. 19 Q With respect to any of the material we have 20 discussed up to this point or read up to this point, was 21 there any disagreement among the operators as to whether g 22 something had or had not happened? 23 A Not that I recall. 24 Q What is the "20 gpm" figure that is referred / 25 to here, if you recall? s_. 1

1 1 Lonses 436 ('N '2 A The 20 gpm figure relates to the slope of N/ 3 the makeup tank line between 2:01 and 4 minutes and 38 4 seconds. 5 Q Again, we are referring to figure B-2? 6 A Yes. 7 Q From 1717 8 A

Yes, I had originally considered that that 9

might have been due to addition from the boric acid 10 pumps. The operators said that was not the case. It 11 was possible that letdown had been reinitiated, but they 12 didn't believe that was the likely -- one or more of the ,3 13 operators did not believe that that was likely, and one .) %/ 14 of them suggested that it could have been leakage past 15 the pump recirculation valves back into the makeup tank. 16 (Discussion off the record between the 17 witness and his counsel.) 18 MR. GLASSMAN: I should just note that I had 19 a few very brief conferences with the witness 20 t which counsel has asked to be noted on the record, l 21 and their purpose has been to answer the witness' 22 question as to whether he is being sufficiently 23 responsive, appropriately responsive, to questions 24 regarding each line. p p 1 \\_' 25 MR. BENEDICT: Unless you want to waive your

2 1 LancOG 437 (^S 2 attorney-client privilege, don't include me on NI 3 part of your conferences and part of what you say 4 and not on the other parts unless you would like 5 me to ask Mr. Lanese all'that you have talked 6 about today. Let's not have these self-serving 7 statements. 8 MR. GLASSMAN: You should proceed. 9 MR. BENEDICT: I agree. 10 BY MR. BENEDICT: 11 Q Continuing down the page, there is an entry 12 at 4:38 which, again, am I correct in assuming, means 13 4 minutes and 38 seconds into the transient on March c) 'w] 14 28th? 15 A Yes. 16 Q Could you read the text that appears after 17 that entry? 18 A " Tripped C, H1A injecting through MU-V16A 19 and B, cut HPI flow in half to see effect on pressurizer 20 level (dip in pressurizer)." c. 21 Q Is it your recollection that when you 22 wrote " Tripped C," you meant makeup pump 1C? 23 a

yes, 24 Q

On the subject further in that sentence, (O_) 25 you say "1A." I take it that means makeup pump 1A?

438 2 1 Lnnoco 2 A Yes. I J 3 Q What is the significance in terms of volume '^' 4 of flow, if any, to the fact that 1A was injecting lll 5 through makeup valves 16A and B? 6 A It is the normal high pressure injection 7 path. 8 Q You then go on to say: " cut HPI flow in .9 l half to know effect on pressurizer level (dip in 10 pressurizer)." 11 What did you mean by that? 12 A That is"to see effect on pressurizer level." 13 Q I'm sorry? 14 A " cut HPI flow in half to see effect on 15 pressurizer level (dip in pressurizer)." 16 Q What do you recall you meant when you wrote 17 those words? 18 A One of the operators said that they tripped 19 the makeup pump 1C and cut the flow from makeup pump 20 1A in half to determine the effect that it would have 21 on pressurizer level, and that they noted a dip in the 22 pressurizer level at that time. 23 Q When you had this interview or meeting with 24 the operators, did you have traces or graphs to work ( ) 25 from? --_U

439 4 1 Lanoco gg 2 A I believe we were looking at the same b 3 figures that appeared in the June draft of Appendix B. 4 Q Could you look through that which appears G 5 in B&W 608 and tell me, if you can, which figures those 6 are? 7 A That is figure B-2, W 026932. it is the page 8 Q So it wasn't included 9 immediately preceding what we have been referring to or 10 I have been referring to as the June draft of Appendix 11 B in B&W Exhibit 608, is that correct? 12 A Had we agreed it ended on 26931? 13 Q That it started on 26933. O 14 Am I correct, you are referring to this 15 page? 16 A That is what I am referring to. I may be 17 wrong. 18 Q Is the same drawing included at some point 19 within the June draft of Appendix B? 20 A There was a similar figure that we were 21 looking at. I can't verify at this time which one it ggg 22 was. i 23 Q But it was similar in your recollection to 24 the figure in B&W 608 marked with the page number 25 W.0269327

5 1 LSnsce 2 A Yes. ,m i ) x.s 3 Q Had you provided copies of these to the 4 other people present? k 5 A I'm not sure. 6 Q Had you written out questions to ask the 7 operators? 8 A I think I did. 9 Q Do you have any notion of where those 10 questions would be found if they still exist? 11 A No. 12 Q The parenthetical in the entry we last 13 read, " (dip in pres surizer) ", what did you mean when 7s (\\" ') 14 you wrote that? 15 A As I recall, one of the operators noted a 16 d.ip in pressurizer level at that time. 17 Q Did any of the operators say anything with 18 respect to the cause or what they believe to have been 19 the cause of that dip at that time? 20 A No. 21 Q Did you ask them whether they thought it was 22 as a result of the reduction in HPI flow? 23 A I don't remember. 24 Q What does the entry starting with "DH VSA, ) 25 B" say?

6 1 Lenoco 441 2 A "DH-V5A, B open, recirc. valve closed until ,e-) r U 3 about 7-8 a.m." 4 Q Does that entry indicate that at or about 5 4 minutes and 38 seconds following the reactor trip, 6 those actions or stops were taken? 7 A That was someone's recollection, yes. 8 Q Is there a dispute as to whether or not 9 that occurred.or was there a dispute at the time you 10 were preparing Appendix B? 11 A I don't know what you mean by " dispute." 12 Q Was there disagreement as to whether or not 13 that occurred? Did some people think it had and some Oi / 14 people think it hadn't? 15 A I don't remember any other opinion being 16 offered, no. 17 Q What is the next entry on the page with 18 respect to inventory? 19 A " Started max. letdown right after 20 intermediate cooling water second pump was started, 21 110-130 gpm letdown best remembrance plus aeal return." g 22 Q What did you understand when you made this 23 entry you were setting forth trying to record? 24 A This was related to whether maximum letdown r^s () 25 was initiated, and if so, when. There was an alarm

442 7 i Lenose 2 summary that a second intermediate cooling water pump / \\ '~ 3 was started, which implied that operator or operators 4 were going to initiate maximum letdown, and the ll 5 recollection of one of the operators or more, perhaps, 6 was that they did immediately go to maximum letdown, 7 and the valve letdown flow that was recalled was between 8 110 and 130 gpm. 9 Q What is " maximum letdown" nominally for 10 Unit 2, do you know, at the pressures that existed in the 11 reactor coolant system in the first ten minutes or so 12 whenever this is supposed to have occurred? 13 A I don't remember the nominal value. fm 14 Q Do you know what it is rated? 15 A Not under that condition, no. 16 Q Was it your understanding at the time that 17 110 to 130 gpm was approximately the maximum letdown? 18 A Yes. 19 Q " Seal return," I take it, is return to the 20 makeup tank from the pump seals? 21 A Not directly from the pump seals, but 22 water that is returned from the seal injection line. 23 It is not reactor coolant water. 24 Q What is the next entry with respect to m ( ) 25 inventory in the reactor coolant system?

I 443 . 18 1 Lansco ^ 2 A "DH-V5A/B was open continuously. BWST at ' v 3 approximately 30 feet at 11:00 or 12:00 a.m. Possible 4 it could have been shut." 5 Q Did you understand the reference "11:00 or 6 12:00 a.m." to mean 11:00 a.m. to noon? 7 A Yes. 8 Q Turning to the next page, 132, there is a 9 time entry at the top, "6 minutes and 48 seconds." 10 Is it fair to say that the entries from 11 4:38 on the page preceding to the bottom of the page 12 preceding occurred after 4:38 and before 6:487 13 A No. (-~J. ~ 14 Q Do you recognize any that are out of-15 sequence? 16 A The reference to 11:00 or 12:00 a.m. 17 Q In other words, where it says: "DH-V5A/B 18 was open continuously," is it correct that that decay 19 heat valve was open at least as early as four minutes 20 and 38 seconds? ggg 21 A I think that entire reference was out of 22 sequence. "DH-VSA" continuously opened, BWST at 30-i 23 feet, referred to valve being open until 11:00 or 24 12:00 o' clock. /~ l gfs T ). 25 Q Do you'know when the decay heat valve SA and

o. ra I

8.

• ~p

)s L 2

u 444 1 L2noco (~} 2 B were initially opened? "'v/ 3 A Yes. 4 Q Were they open before the onset of the 5 transient at 4:00 a.m. on March 28th? 6 A No, they were opened after the event began. 7 Q Do you know about when after? 8 A Approximate'ly a minute and 25 seconds. 9 Q Nhat is the first entry on page 1327 10 A "six minutes and 48 seconds could have closed N s 11 DH-VSA." ,y i 12 Q Did you ever resolve whether or not this \\ s. 13 valve was, in fact closed'at,th a t time? ,ex w 14 A - No. 15 .Q What is the next c'ntry? IG A "Seven minutes',45 seconds HPI throttled, 17 two letdown coolers were on, continuously, alarm printer . t. 18 at 71.4 gpm at 4:07:35 a.m. .346, 4:08:05:1680 could be .\\ 19 171.4 gpm." 20 Q That is the end of the entry after seven 21 minute and 45 seconds? g 22 A Yes. 23 Q Turning back t,o'the page' preceding where 24 there is an entry on 4:38, it says " Tripped C," and if I; A) 25 I understand correctly, that means the operators m -m 4

445' t, q 0 1 Lanoco f~s .2 terminated makeup pump 1C at that time, is that right? / 3 A Yes. 4 Q Makeup pump 1C at that time was operating I 5 in a high pressure injection mode, is that right? 6 A Yes. s ,7 Q Do you know what the approximate flow of J 8 C was at that time? Maybe I can make it simpler. 9 Do you have any reason to believe that \\' 10 pump 1C was not operating at its expected volume at t. 11 that time? s s 12 A No. 13 Q Is it, in fact, the case that you understand ('T) 14 that it was operating at its expected volume? g i' 15 A That is what I was trying to verify. I 16 believe that is true. 17 Q It then goes on to say: " cut HPI flow in 18 half." 19 Does that mean that half of the HPI flow 20 from 1A was terminated or is that a repeat of the fact l 21 that one of the two operating HPI pumps was terminated, m i W 22 thus reducing capacity by one-half? I guess what I want 23 to know is was there one-half total HPI going into the 24 system after 4:38 or was there one-quarter going in. (7 ) 25 A At that time, injection was approximately

1 1 L0noco 446 2 180 GPM. 7s Y 3 Q At 4:38, prior to the throttling that you j i 4 were discussing at 7:45? k 5 A Prior to the throttling, it was approximately 6 700 gpm, and then throttled at 4:38 to approximately 7 180 gpm. 8 Q What table are you looking at? 9 A Table B-2. 10 g of Appendix B? 11 A Yes. 12 g of 171. 13 So referring to Table B-2, it is your f_~) ~ 14 understanding that up to the point of the termination 15 of the A makeup pump at four minutes and 38 seconds, 16 the inventory addition was 720 gallons per minute. In 17 .other words, that is the volume at which the pumps were 18 flowing? 19 A From approximately two minutes to four minutes 20 and 40 seconds, yes. 21 Q If I understand Table B-2 to Appendix B of 22 Bsw 171 correctly, actions were taken at four minutes 23 and 38 seconds which reduced the net RCS injection rate 24 from 700 gallons a minute to no gallons a minute, is l , ~. l (_,) 25 that correct?

447 2 y Lanoce 2 A No. g- - - ) 3 g could you explain what did I do wrong? Is 4 it correct that at four minutes and 38 seconds, the G 5 net RCS injection rate was 700 gallons? 6 A Yes. 7 g Is it correct that there were actions taken 8 between four minutes and 38 seconds and six minutes and 9 48 seconds that reduced the net RCS injection rate to 10 zero? 11 A Yes. 12 g can you tell me based on your notes or 13 other sources of information what, at the time you ~ 14 drafted B-2, you understood the operators had done to 15 result in that change in the net RCS injection rate? 16 A I believe at that point the operator was 17 taking maximum letdown and putting it into the makeup 18 tank and drawing the same amount of injection water from 19 the BWST and no more. 20 g By what means did he reduce the inventory 21 addition rate from 720 prior to four minutes and 38 g 22 seconds to 180 at six minutes and 48 seconds, reading 23 from the middle column on Table B-27 24 A Apparently it was by tripping the 1C makeup (~N (,) 25 pump and cutting the 1A makeup pump flow approximately

I 3 1 Lanoce 448 2 in half. 7s k_) 3 Q How did you understand at the time you were 4 preparing this material, did the operator effect a h 5 reduction in the flow through the 1C pump? 6 A By tripping the pump, the 1C pump. 7 Q How did he reduce the flow through the 1A 8 pump? 9 A Throttling the injection valves associated 10 with that train, MU-V16A and B. 11 Q Was there at the time you drafted this and 12 is there today any information available from which you 13 can directly determine the flow through the throttled 7_ r 'J 14 valves for the A pump? 15 A No. 16 Q At the time you prepared the material that 17 ended up as Appendix B to B&W 171, did you understand 18 that the flow from the A pump had been throttled prior 19 to seven minutes and 45 seconds? l 20 A Yes. 21 Q Does the entry in your notes at page W 028132 9 22 which indicates HPI was throttled at seven minutes and 23 45 seconds, does that indicate a further throttling of 24 HPI flow? (,) 25 A There may have been.

449 4 1 Lcncoo fx 2 Q Is the information contained in the entry Q 3 in your notes following the entry, the time seven 4 minutes and 45 seconds, is that information that you h 5 got from an operator or from more than one operator 6 during the course of your June 13th meeting? 7 A I don't remember. 8 Q Do you have any recollection of the source 9 of that information? 10 A No, that may have been a note to myself. 11 Q Is it your understanding today that between 12 the time of the reactor trip on March 28th and, let's 13 say, eight minutes, there were more than one -- the \\ i v 14 operators throttled makeup pump 1A more than once? 15 A It is a possibility, yes. 16 Q You couldn't confirm hat it happened more 17 than once? 18 A No, because of the uncertainty in the 19 position of DH-VSA. 20 Q That is not the valve that you used to 21 throttle the flow through the pump? G 22 A No. 23 Q Are you aware today and were you aware at 24 the time you drafted Appendix B that on at least one ~/3 () 25 occasion in the first eight minutes of the accident, the

S 1

Lcncoe 450 2 flow through pump A was throttled? f I v 3 A Yes. 4 Q Did you in the course of preparing Appendix lll 5 B to B&W 171 attempt to determine the extent of that 6 throttling? 7 A Yes. 8 Q Or the extent in the reduction of flow from 9 the A pump? 10 A In the first six minutes and 48 seconds? 11 Q Yes. 12 A Yes. Q In the first eight minutes? 13 14 A Yes. 15 Q Does Table B-2 from B&W Exhibit 171 exhibit 16 your best understanding at the time of the extent of the 17 throttling? 18 A No. 19 Q What is your best understanding or is there 20 another page or document that shows your best 21 understanding of the extent of that flow when makeup 22 pump 1A was throttled? 23 A Tables B-2 and B-4 present the alternative 24 possibilities for throttling. ,n] 25 Q These are scenario 1, which was the minimum (,

451

6 1

Lenose 2 addition, and scenario 2, which was the maximum addition? ,s 3 A Correct. 4 Q The first change between the two scenarios lll 5 with respect to net inventory addition from makeup and 6 letdown occurs in the period between six minutes and 48 7 seconds and seven minutes and 45 seconds, is that 8 correct? 9 A Yes. 10 Q Is the difference that is exhibited during 11 that period accounted for by your inability to 12 determine whether there was a second throttling of 13 makeup pump 1A7 '~ 14 A It is due to a combination of reasons. The 15 throttling was one point. The other point was the source 16 of water. 17 Q That is the decay heat valve number SA and 18 B issue? 19 A Yes. 20 Q Let's go on to the next entry here. I had 21 one question. 22 In the entry following the seven minutes 23 and 45 seconds notation, there were some point numbers. 24 Could you tell me what the point numbers are? (3 \\,/ 25 A I believe they are the plant's computer

l 7 1 Lanese 2 points or alarm printer points, one of the two, that D 3 indicate letdown flow. 4 Q In other words, in order to access 5 information with respect to letdown flow, you had to 6 know those numbers? 7 A I don't know. 8 Q Do you today recall what it was for, why 9 you entered'tl.ose numbers there? 10 A No. 11 Q Turning to the next entry, it starts with l 12 the entry "Nine minutes and 24 seconds ?" 13 What does that say? e 14 A "May have been stuck." 15 Q What were you referring to? 16 A The makeup tank level indication. 17 Q Does the question mark indicate that you 18 don't know for how long this condition may have existed? 19 A No. 20 Q Why is the question mark there? 21 A The question mark was whether it was 22 actually stuck or whether makeup tank level remained at 23 exactly a certain value for several minutes. 24 Q Was this remark a question that you had () 25 or was it an observation made by the operators or some umuu u muuuu u uum uu

453 8 g Lansse 2 other alternative? n i w,< 3 A It was a question I had. 4 Q Have you to this day satisfactorily resolved 5 that question? 6 A The possibility of the indication being 7 stuck for a short period of time is a reasonable 8 explanation. 9 Q For the conditions that you saw? 10 A Yes. 11 Q But you have never been able to establish 12 mechanistically that, in fact, it was stuck? 13 A No. fs ) 14 Q What is the next entry on the page? 15 A "Nine minutes and 36 seconds to ten minutes 16 and 24 seconds. Might have gone to RC bleed tank. 17 Were to.ld to go back to MU tank. Suggested looking at 18 NRC transcripts. Don't remember ever..." -- underlined --- 19 "... losing the 1A pump." 20 Q What is it that might have gone back to the 21 RC bleed tank? 22 A Letdown flow. l 23 Q What, if you know, NRC transcripts were 24 you referring to here? / \\ (,) 25 A operator interviews.

9 1 Lonoco 454 g-2 Q You don't recall specifically now? Q_3 ,) 3 A I don't recall, no. 4 Q Did you have with you the day of this meeting '5 with the operators the copies of the interviews which 6 you had reviewed up to that time? 7 A No. 8 Q Did anyone, to your knowledge, have them 9 present? l 10 A No. 11 Q " Don't remember ever losing the 1A pump." 12 To what does that refer? 13 A That refers to the alarm summary entries at 14 ten minutes and 24 seconds, ten minutes and 27 seconds, 15 and 11 minutes and 40 seconds, which indicate that the 16 pump was tripped, started and tripped, and started. 17 Q Can you tell me what page you are referring 18 to? 19 A Page N 56496, B&W 171. 20 Q That is Table B-17 21 A Table B-1. ggg 22 Q The operators or at least an operator took 23 issue with the entries that were on the alarm printer 24 or alarm summary, is that correct? 'p (,/ 25 A Not issue, no.

0 1 Laneco 455 2 Q Did they disagree with it? t i G' 3 A No. 4 Q Were they surprised as you perceived it 5 when this was related to them, that the alarm summary 6 or computer printout said that? 7 A No, I don't remember surprise. 8 Q Why the emphatic underscoring of the word 9 "ever"? 10 A They don't remember that the pump was lost 11 at any time during the accident. 12 Q Was that a unanimous opinion by those who 13 spoke on it? ~ 14 A I don't remember. 15 Q Do you recall disagreement among the 16 operators on that subject? 17 A No, there was no disagreement. 18 Q Do you know what, if any, material had been 19 provided to the operators up to the point of your 20 interview with respect to the Three Mile Island 21 accident? gg 22 A No, I do not. 23 Q Written material? 24 A I don't remember. ,s (,) 25 Q Were you aware that they had seen your first

456 i 81 1 Lenoco 2 draft of what became Appendix B? -) (O 3 'A I can't remember if they actually saw it 4 before the interview, no. h 5 Q Did you receive comments from any operating 6 personnel,either before or after the interview, on what 7 became Appendix B of B&W 171? 8 A No. 9 Q Did you ask for comments from anyone? 10 A I don't remember asking, no. 11 Q Did Mr. Broughton 12 A Excuse me. I did, at the time of the 13 interview on the 13th, ask them to provide any further /,Y s s 14 comments if they had any. 15 Q Comments with respect to 16 A Appendix B mass additional scenario. 17 Q To that issue, but you had not provided 18 them with the documents? 19 A I don't remember whether I provided it to l 20 them. I 21 Q You don't recall receiving any comments 22 after that interview? i 23 A I know I did not receive any other comments. 24 Q You don't recall speaking with any operators '\\ 3(._,) 25 with respect to this issue following the June 13th

1, 2 1 Lanoes 457 2 meeting, is that correct? '~' 3 A I know I did not speak to any of the 4 operators involved who were on shift at the time of the llh 5 accident. I believe I called for some system 6 information subsequent to that. 7 Q By " system information," do you mean 8 arrangement of hardware? 9 A Yes. 10 Q Did you at any time,in preparation of your 11 report that became Appendix B, review operating, 12 emergency, or other plant procedures for either TMI 13 facility? \\2 14 A I don't remember having reviewed procedures, 15 no. 16 Q There is an entry that reads: "16 minutes," 17 and that is scratched out, and below it there is an 18 entry starting at "26 minutes." 19 could you read that? 20 A "26 minutes to 40 minutes, probably change 21 in letdown to see how level behaved." 22 Q By " level," did you understand when you 23 wrote this, were you referring to pressurizer level? 24 A The reference was to pressurizer level. ) 25 Q Were you taking down a remark or comment v

458 3 1 Lnnsee 2 that you received from an operator at this point? 'LJ 3 A Yes. 4 Q Do you remember anything else that he or lll 5 they said at that time about changing letdown to see 6 how pressurizer level behaved? 7 A No. 8 Q Could you go on and read the remainder of 9 that passage? 10 A " Don't remember asking for batch additions, 11 but did cycle the MU-V12 every time the tank level came 12 up. Probably due to recirc. to the tank." 13 Q Who didn't remember asking for batch 14 additions? 15 A one or more of the operators. 16 Q What is a batch addition? 17 A That is addition of borated water to the 18 makeup tank from other sources aside from the reactor 19 coolant system. 20 Q After the period at the end of the entry, it 21 says: "Probably due to recirc. to the tank." 22 What was probably due to that? 23 A In the period of time we were talking about, 24 makeup tank level increased at a fairly constant rate [~'; 25 and,then, suddenly turned around at a fairly constant u./

459 4 1 Lansee 2 rate. My initial assumption, which was incorrect, was L,/ 3 that the operators were adding borated water from another 4 source. In fact, what they were doing was taking the G 5 level of the tank, controlling the level of the tank 6 withia its control band by opening and closing MU-V12. 7 Q What doe:' MU-V12 do when you open and close 8 it? 9 A When you open MU-V12, you provide suction to 10 the high pressure injection or makeup pump, and thus 11 you would draw water down. When the valve is closed -- 12 Q Draw water down from the makeup tank? 13 A Yes. With MU-V12 closed, tank level was ] 14 apparently increasing due to recirculation flow back 15 to the makeup tank, and so eventually the valve would 16 have to be reopened. 17 Q Where did the makeup pump or pumps take 10 their water supply when the MU-V12 was closed? 19 A The only source would be from the borated 20 water storage tank? 21 Q What is the next entry? 22 A "41 to 51 minutes - letdown orifice-type 23 flow. Only recollection of adding water to MU tank was 24 after RC pumps were off and they borated." , ~., (,) 25 (continued on next page) i

I f,6} 'l 1 Lnnoco 7-3 Q Does this entry indicate the the operators ( ) 3 who spoke on this subject had no recollection of adding 4 water from any outside source to the makeup tank until 5 after the tripping of the final two reactor coolant 6 pumps? 7 A That was specifically boration sources to 8 the makeup tank, yes. 9 Q Is the borated storage tank a source of 10 borated water? 11 A Not for the makeup tank, no. This is a 12 low volume source of water. 13 Q What is the next entry on the page? 14 A " Water from MU-V9 from waste transfer pump 15 never gets up to 50 GPM even with two pumps running." 16 Q Briefly, what were the operators trying to 17 relate to you when you wrote down this passage? 18 A They were trying to explain to me why the 19 increases in makeup tank level which were approximately indicated 100 GPM flow or so would not have been 20 100 l 21 due to batch additions. The waste transfer pumps 9 22 which would be the pumps which transfer that water into 23 the tanks only supplied about 50 GPM flow. 24 Q What is the entry on the top of page 13.27 _,.9 ! j 25 A That is the last entry with relation to this s

461 1 Lznaco 2 topic, and it says, "DH-V8A,B, alarm on 53.5 feet alarm I,) set point." 3 4 Q What did you mean to relate when you made llh 5 this entry? 6 A That has some relationship, I believe, to 7 the sodium hydroxide valves which would open at 53-1/2 8 feet level in the BWST. 9 Q Do you remember when in the sequence of 10 eventa following the reactor trip on March 28, 1979 this 11 issue arose or there was an actuation of these valves? 12 A In the time frame of three and a half hours, 13 I believe. f, '), 14 Q Did you discuss with the operators the period 15 between 51 minutes, which is the last time entry in your 16 notebook,and the period of three and a half hours when 17 the decay heat valve 8A and B issue arose? 18 A I don't remember any dis cussion, no. 19 .Q Do you recall any elements of your 20 discussions during this meeting with the operators 21 relating to your project to create what became 22 Appendix B of 171 which are not recorded here? 23 A No. 24 Q Do you recall with respect to any of the ( ) 25 entries in the pages of your notebook we just read any v

p 462 1 Lenoco <~s 2 disagreement among the operators with respect to the ( \\ %.) 3 facts or views set forth? 4 MR. GLASSMAN: You mean any voiced h 5 disagreement? 6 MR. BENEDICT: Yes. 7 A No. 8 MR. BENEDICT: Let's stop. I am not done 9 but I am done basically with this issue. It is 10 54 seconds before 5 o' clock. 11 MR. GLASSMAN: Counsel has indicated that 12 he is not yet finished with their cross-examination 13 of Mr. Lanese. We were originally scheduled to /~\\ U 14 start on Tuesday at the request of counsel for 15 B&W. We started on Wednesday. Because of 16 various scheduling problems, we have not had 17 complete days, counsel for B&W indicating for 18 reasons apparently beyond their control, we would 19 have to terminate a bit early yesterday and begin 20 late this morning. 21 It goes without saying that all parties agree 9 22 we would like to wrap this up as soon as we can, 23 and I note that the witness would also like to 24 complete this as quickly as possible. We are n (_) 25 prepared to complete the deposition of Mr. Lanese -s

1 Lonoca 463 2 at the earliest convenience. We are ready to go O( 3 3 Monday, we are ready to go Tuesday, we are ready 4 to go Wednesday next week. h 5 We are doing this as quickly as we possibly G can. I am advised we can tentatively schedule it 7 for next Wednesday, but that may be a problem. 8 MR. BENEDICT: Sometimes I really wish you 9 would stay off the record with your speeches, a 10 so let's go through the fagts. By letter dated 11 before Christmas of last year, we requested 12' Mr. Lanese's documents. We received some of 13 his files in the middle of last week. We received 7-14 the remainder of his files either Monday or 15 Tuesday of this week. Tuesday in the morning. 16 The deposition was scheduled to begin on Tuesday. 17 You called and told me you couldn't be 18 available in the afternoon. You agreed to try to 19 start a little early. I decided since I had just 20 gotten these documents, I couldn't start. Every 21 evening this week I have been reading these 22 documents. 23 One of the reasons why I had to end early 24 yesterday and begin late today was because I (~T (,) 25 hadn't had an opportunity to do my other work.

1 Lenoco 464 _s 2 I think it is evident to all hands that I ) s / 3 we want to get this over with. I think it is 4 ridiculous, however, for you to make speeches k 5 about things that include, at best, half the 6 facts. 7 so let's try to wind up Mr. Lanese on a 8 day sometime next week, and I would very much 9 like for it to be Wednesday myself. I expect 10 it would take a day. Perhaps a little less. 11 If you have any further documents, putting 12 aside the delivery today, I would appreciate 13 receiving them by Monday. [\\ 14 MR. GLASSMAN: I believe all the documents 15 relevant to the examination have been turned 16 over. 17 MR. BENEDICT: I might note another thing. 18 You told me on Friday that there might be a 19 page or two-- those are your words, Friday phone 20 call last week -- a page or two more documents. l 21 Nothing more. l 22 I asked you on Friday since I was going to l 23 be working over the weekend to get them to me by i 24 Friday. A half-full box of documents arrived [ [~N () 25 Tuesday morning.

g Lnnose 465 2 If you wanted me to put this all on the (_/ record, I am happy to, but there is no way on 3 4 God's green earth you will be able to make your lll 5 speeches about how you are doing all the 6 cooperation and I am doing all the delaying. 7 MR. GLASSMAN: Perhaps you misunderstood 8 the nature of my comments. All I was saying was 9 that we were prepared to continue with the 10 examination if you found it necessary to have 11 another day, and we were prepared to do it 12 expeditiously. 13 I am putting this on the record so we are ((,/ 14 clear that we are trying to push it along now as 15 quickly as we can. I note that your colleague, 16 Mr. Fiske, was intent on making similar points 17 in a deposition of Mr. Zechman which took place 18 today and all I am indicating is that we are 19 attempting to be as cooperative as we possibly 20 can. 21 (Continued on the following page.) 22 23 24 f'~N 25 h

1 Lenece 466 2 MR. BENEDICT: I am not going to quarrel gss (,) 3 with you on that one way or the other. The 4 record stands. lll 5 (Time noted : 5:00 p.m.) 6 7 8 Louis C. Lanese O Subscribed and sworn to before me 10 this day of 1982. 11 12 13 f ') a 14 (J 15 16 17 18 19 20 21 W 22 23 ~ 24 g_ 25 kh

l 7-1 467 I CERTIFICATE l 2 n l i 'Q STATE OF NEW YORK ) lj 3

ss.:

l COUNTY OF NEW YORK ) 4 j '9 I, JOSEPH R. DANYo , a Notary O Public of the State of New York, do hereby certify that the continued deposition of 7 LOUIS C. LANESE Was taken before 8 Friday, March 26, 1982 consisting me on 9 of pages through I further certify that the witness had been previously sworn and that the within transcript is a true record of said testimony; 13 O,V That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in the employ of any of the counsel. 18 IN WITNESS WHEREOF, I have hereunto set my hand this h 20 day of April 1982. Ig 21 pff,Gy 28 ps,e..ca.xe m,, n I i V 25 I i i l

8 468 /'N INDEX 'Q. WITNESS PAGE Louis C. Lanese 305 g EXHIB I T S B&W NUMBER FOR IDENT. 607 Notebook, first page bearing 338 date 3/1/79 at the top 608 Document containing infor-391 (_s} mation used in preparation of Appendix B and Figure 14 of TDR ntio. 045 1 I l l t \\~ 4

is u. f \\ UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ____________________________________________-x GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and 80 Civ. 1683 (RO) PENNSYLVANIA ELECTRIC COMPANY, AFFIDAVIT Plaintiffs, - against - THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., Defendants.

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X STATE OF NEW JERSEY

) O

sS.:

COUNTY OF MORRIS ) I have read the transcript of my deposition taken on March 24, 25, 26 and April 19, 1982 and together with the attached corrections, it is accurate to the best of my knowledge and belief. IM 6 Im Louis C. Lanese SignedgdayofOctober,1982. nd sworn to before me this.77. l AL, o. %,0 l Notary Public ~ e ifCE J. HOUSE O-TY Fe3U CF MEW JERSEY j maissica Expires !aarch 7.1985 i lj i i

Corrections-to L.C. Lanese Deposition September, 1982 Page Line Correction 39 10 "committe is" should read " committee is to" 52 19 "Clinton" should read "Clayton" 72 4 " basis" should read " bases" 88 12 "I assume," should read " assumed" 112 23 " include" should read " exclude" 122 18 "your" should read "a" 138 18 " agent" should read " manager" 310 7 "termal" should read " thermal" 315 4 "and license" should read " analysis" 340 2 "Howard" should read "Heward" 456 16 " additional" should read " addition" 472 14 " Asymmetrical" should read " Asymmetric" 476 12 "Martus" should read "Mardis" 511 15 "or" should read "our" 522 19 " Jay Correa" should read " Nick Trikouros" 527 20 "No" should read "Yes" 529 4 "and" should read "as" 531 22 " indicator" should read " indicated" 531 22 " fuel" should read "real" v u l

~, / Page Line Correction ~' '5'47 14 " differentiation" should read " differential" 562 20 "and" should read "in" i 586 17 " released ' should read " replaced" 588 20 "Denner" should read " Denver" 588 21 "1bn/sec" should read "1bm/sec" 589 9 "SAR" should read "ACRS" 1 O l l l l l D 1 %) ..}}