ML20072H939
| ML20072H939 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/28/1981 |
| From: | Mehler B METROPOLITAN EDISON CO. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-04, TASK-05, TASK-06, TASK-1, TASK-10, TASK-2, TASK-3, TASK-4, TASK-5, TASK-6, TASK-GB NUDOCS 8306290825 | |
| Download: ML20072H939 (172) | |
Text
{{#Wiki_filter:_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ UNITED STATES DISTRICT COURT Ob r SOUTHERN DISTRICT OF NEW YORK ___-------------------------------------x GENERAL PUBLIC UTILITIES CORPORATION, s i [' . JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and a PENNSYLVANIA ELECTRIC COMPANY, l Plaintiffs, a
- 80 Civil 1683
-against- : (R.O.)
THE BABCOCK & WILCOX COMPANY and : J. RAY McDERMOTT & CO., INC., : Defendants. : e : ________________________________________x Deposition of Plaintiff, METROPOLITAN O EDISON COMPANY, by BRIAN A. MEHLER, taken by Defendants pursuant to agreement, at the of-i fices of Davis Polk & Wardwell, Esqs., One
; Chase Manhattan Plaza, New York, New York, on
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Tuesday, July 28, 1981, at 10:35'a.m., before Joseph R. Danyo, a Shorthand Reporter and Notary Public of the State of New York. I
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I I. DOYLE REPORTING. INC. CERTIFIED STENOTYPE REPORTERS 369 LExlNGTON AVENUE WALTER SH APIRO, C.S.R. NEw Yonx. N.Y. toot 7 CHARLES SHAPIRO, C.S.R. TELEPHONE 212 - 867 8220 I 8306290825 810728 PDR T ADOCK 05000289 - pop - - '
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2 1 O 2 APPe a ranc e s : , 3 4 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS., Attorneys for Plaintiffs, C 5 425 Park Avenue, New York, New York 6 BY: STEVEN J. GLASSMAN, ESQ. 7 and ANDREW MacDONALD, ESQ., 8 of Counsel
.9 10 KILLIAN & GEPHART, ESQS., e Attorneys for Witness, 11 Box 886, 216-218 Pine Street, 12 Harrisburg, Pennsylvania 17108
(:) 13 BY: SMITH B. GEPHART, ESQ., of Counsel 14 .
-and-15 LeBOEUF LAMB LEIBY & MacRAE, ESQS.,,
16 1333 New Hampshire Avenue, N .W . , Washington, D.C. 20036 17 BY: MICHAEL F. McBRIDE, ESQ., 18 of Counsel 19 20 DAVIS POLK & WARDWELL, ESQ., Attorneys for Defendants, 21 One Chase Manhattan Plaza, {' New York, New York 22 BY: RODMAN W. BENEDICT, ESQ. 23 and ROBERT F. WISE, ESQ., 25
1 1 3 1 0 2 ALSO PRESENT: 3 ' ROBERT P. CANNON 4 5 6 7 00o 8 4 9 10 IT IS HEREBY STIPULATED AND, AGREED by and 11 among the attorneys for the respective parties 12 hereto that the sealing, filing and cer'tifica-0 13 tion of the within deposition be,' and the same
~14 hereby are, waived; and that the transcript may 15 he signed before Notary Public with the same 16 force and effect as if signed before the Court. , 17 IT IS FURTHER STIPULATED AND AGREED that s_
18 all objections, except as to the form of the 19 questions, shall be reserved.to the' time of 20 the trial. 21 22 23 00o t 24- {) 25 e
. . , - - , - , , - - . , - , ~
4 1 [}
having been 2 B RI AN A . MEH L ER ,
3 first duly sworn by a Notary Public of the State 4 of New York (Joseph R. Danyo), was examined and 5 testified as follows: 6 EXAMINATION BY 7 MR. BENEDICT: 8 Q Would you state your name? 9 A Brian A. Mehler. . 10 Q Are you represented by counsel here 11 today? 12 A Yes, I am. O 13 Q Who is representing you? 14 A Steve Glassman and Michael McBride and Bert 15 Gephart. 16 Q When did you retain Mr. McBride and Mr. 't 17 Gephart? . 18 A I don't know how long ago it was. I think it 19 has been a year and a half. 20 Q Did you retain them to represent you with 21 respect to the accident and your involvement therein? { 22 MR. GLASSMAN: Objection. I direct the 23 witness not to answer. The two gentlemen we i I
"y-identified we told you are Mr. Mehler's
() 24 i 25 personal attorneys, and he would like to.have i -
5 1 Mehler 2 them here. I don't think we will have him 3 testify as to the matters in which they are representing him. We are representing the 4 5 company and representing Mr. Mehler in this 6 deposition, and I stated this before. 7 He does have his personal attorneys 8 here. I don't think we should be going any 9 further into the areas in which they are 10 retained. 11 BY MR. BENEDICT: 12 Q Who is paying Mr. Gephart's and Mr. 13 McBride's bills? 14 A At this time -- 15 MR. GLASSMAN: I object and direct the 16 witness not to answer. 17 Q Have you spoken with anyone-at Med Ed 18 about retaining private counsel? 19 MR. GLASSMAN: I object and direct the 20 witness not to answer. 21 MR. BENEDICT: The question includes 22 non-lawyers. I don't see how that question 23 can be possibly privileged. MR. GLASSMAN: I think we are goingJinto
/)_
24
- 25 an a'nswer where we are clearly seeking L: .
6 Mehler 1 2 conversations relating to either preparation 3 for litigation or privileged conversations 4 4 regarding counsel, and I direct him not to C 5 answer. 6 BY MR. BENEDICT: not 7 Q Have you spoken with anyone who is 8 an attorney at Met Ed or any GPU subsidiary about 9 retaining private counsel? 10 A Not that I recall. 11 MR. BENEDICT: I would like to mark as 12 Defendants' next in order which is 235i a resume
/~% .
N..] 13 of Brian A. Mehler. 14 (Resume of Brian A. Mehler marked B &W 15 Exhibit 235 for identification, as of this 16 date.)
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17 BY MR. BENEDICT: ; Have you ever seen this document before? 18 Q 19 A Yes. 20 Q Did you prepare this document?- 21 A Yes, I have. 22 Q With respect to your education it in 1959, is indicates you are a high school graduate
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23 (% . 24 that right? () 25 A 'That's correct.
i l Mehler 7 1 l C') G /. 2 Q Did you have prior to coming to work 3 for the GPU companies, any experience in the nuclear 4 field? 5 A No, I didn't. 6 Q Did you receive all of your training 7 in the nuclear field since you have arrived at
- 8 Metropolitan Edison?
,9 A Yes, I have. .
10 Q Have you received all of it in relation 11 to your employment at Metropolitan Edison? 12 A I don't understand that, b
\~ Have you of your own voliti'on taken any 13 Q 14 courses in nuclear theory that were not paid for by 15 Met Ed?
16 A No, I didn't. 17 Q It lists here on page 1 of Defendants' 18 235 " Job Related Training." It list the 48-week 19 course at the Reactor Operating Training Course, . 20 October 23, 1969 through September 18, 1970.
<~' 21 Was that your introductory course in the k
22 nuclear field? 23 A Yes, it was. m You then . listed a turbine course,
'(s/ l~ 24 Q 25 Was that given by General Electric?
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l 8 1 Mehler ex 2 A Yes. 3 Q And that related only to the turbine facility? 4 generator portion of the TMI l l 5 A Unit 1. 6 Q You then have a reactor familiarization for one 7 program listed at Penn State University 8 week.
.9 Would you tell me briefly what was reviewed 10 at that course in that week? e 11 A Very basically, that course up there reviewed 12 starting up the trigger reactor, how to operate it, the 13 first time, and also we had some courses on health 14 physics and radiation detectors, and we also built a 15 critical pile one time.
16 That is basically all I remember about it. 17 Q Did any of the Penn State training involve 18 pressurized water reactor theory? 19 A Not that I recall. 20 Q -Did any of it involve a discussion of the 21 B&W nuclear steam supply system? { 22 A No t that I recall. 23 Q Were you in the first group of operators p-- trained for TMI-17 X_,/- 24 MR. GLASSMAN: 'If you know. 25 ).
' 3 9 $
Mehler 1 i 0 2 A Yes. To the best of my knowledge, I was in the 3 first group. ] 4 Q Were you in the first group of operators 5 trained for TMI-27 - A I was not with the original group of Unit 2. ] 6 5 - Q You were licensed on Unit 2 prior to Unit 7 A 8 2's fuel being loaded, were you not? _ A To the best of my recollection, yes. 9 2 Q Prior to criticality? - 10 e A To the best of my recollection, yes. 11 T 12 Q Were you licensed on Unit 1 prior to fuel i O 13 being loaded? 2 14 A I don't recall. , ; Do you recall whether you were licensed 15 Q . d 16 prior to criticality on Unit 17
~l A That I don't recall, e ithe r .
17 - 0 Z 18 Q You mentioned at Penn State you operated , 19 or did certain evolutions on the trigger reactor { 20 there. a was that in compliance with licensing } 21 22 requirements with the NRC that you have start-up 5 23 experience on a reactor? l 24 A I believe that was. 25 Q Did you receive simulator training? It = e 7
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10 Mehler 1 says here 80 hours at B&W from August 20, 1973 through 2 3 August 31st, 1973. e 4 Do you remember whether you received 5 that training prior to your receiving any license? t 6 A I am not sure, but I believe that training 7 was before getting the Unit 1 license. !t 8 Q It says the effective date on your 9 operator license was August 8,,1974, 10 Is there a difference between the t 11 effective date and the date you received the license? 12 A No, that would be the date I received the O' 13 license. The test would have been sometime before 14 that. , 15 Q You listed receiving training then, job 16 related training, from TMI staff, from Ge'neral 17 Electric, from Penn State and B&W and Westinghouse. 18 You received turbine training from Westinghouse, and 19 that was again for the Unit 2 facility? _, 20 A That's correct. Q Was the Westinghouse training comparable (A. 21 22 to the training you received by. General Electric? f They were so far apart. I 23 A I. don't recall. Q The Westinghouse was focused on the turbine-(O; 24 25 generator part of Unit 27
l 11 1 Mehler l'h U. That's correct. 2 A 3 Q And it didn't deal with pressurized water 4 reactor theory? C 5 A No, it didn't. 6 Q What other organizations provided you 7 with some training prior to the receipt of your first 8 license on August 8, 1974 other than GE, Penn State, 9 B &W and Westinghouse, if any? 10 A The only other one I can recall would be I think
.It was an organization 11 it was called General Physics. ,s 12 that came in and gave us a simulator and written test. \_) 13 It was a real test and an oral walk-aro'und in 14 preparation for the Unit 1 license.
15 Q Did this include any classroom time, or 16 was this simply the exam? 17 A It was simply the exam. 18 Q You were told by someone at TMI that that 19 was in preparation for the NRC or at that-time AEC
.20 exam? ,
21 A That's correct. 22 Q There are some attachments to.B&W 235 which 23 indicate job related training program which seems to (s ( )-, 24 include -- 25 MR. GLASSMAN: Which page are you referring l l
)
_ j
Mehler 12 ( 1 2 to? f I MR. BENEDICT: Starting at the fourth l 3 l 4 page, headed " Licenses IIeld Past and Present,"
" Job Related Training Program" f
L ( 5 and then it says 6 immediately below that. 7 Q Is this something you prepared? 8 A No, this is something that came out of my file 9 from the Training Department. 10 Q .The Training Department prepared this
'11 and provided a copy to you?
12 A Yes, they.sent me a copy. O- 13 Q Did they send you a copy because you 14 requested it in order to put together this resume, or , 15 did you have it in your file? 16 A I don't recall if it was for this particular 17
' incident or if it was previous to that I. requested 18 this.
l 19 Q The first entry is " Reactor Operator 20 Training course," and it says, " Total Duration - 48 21 weeks."
.22 I take it that is the same course that 23 was mentioned on the front?
A That's correct. ( 24 25 Q- .Then the fifth entry down " General. e
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Mehler 13 1 T'T U Electric Turbine Course," again is the same as was 2 3 mentioned on the front? 4 A That's correct. (> 5 Q In between there are courses listed here 6 on basic health physics, intermediate health physics 7 and does that say pest training? 8 A I think it is post. 9 Q That makes more sense. 10 What differentiated these courses from 11 the 48-week course and why didn't you include them 12 on the front of your resume? (,
- 13 A I don't recall the difference between the 48 14 weeks except other than it would be more in-depth 15 training, and I didn't include it in the front, 16 because on the front I highlighted the major courses 17 that I thought were pertinent.
18 Q After your PWR simulator training that 19 ended in the end of August 1973 at B&W, when was the 20 next time you received any training by B&W? 21 A I don't know the exact next time I received 22 any training by B&W other than every year we go 23 down at least one time on each unit for a one-week A course, 24 (v) 25 Q uhat was that course comprised of? f i
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l 14 1 Mehler 2 A That course is comprised of 24 hour simulator 3 training, and you go over the different casualties on the simulator. Also 20 hours of classroom training. 4 g You said that you go down once a year, at ( 5 6 least, for each unit. Isn't it true that they had made a change 7 8 prior to the Three Mile Island accident in March 1979 9 to go down once every two years? 10 A I don't know that for a fact. e 11 Q You never heard anybody say there had 12 been a decision made to have simulator training at (~% d 13 B&W only once every two years for operators? 14 A I was not aware that that was a decision made 15 or not.
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16 Q The training listed in your job related 17 training, everything except the Westinghouse training, 18 which doesn't have a date, concludes in 1973 prior
'19 to receiving your first license. .,
20 What specific training do you recall was 21 administered to you by. Met Ed in preparation for 22 the receipt of your senior reactor operator license 4 23 on Unit 27 24 -A we work a six-shift rotation, and one week out
'25 of that six-shift rotat' ion is spent in training, and
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Mehler 15 1 l'"i U 2 the training would be on both Unit 1 and Unit 2. 3 Also prior to sitting for-the test, on 4 Unit 2, the NRC test, I received two weeks of that, so it would be very easy to figure out. I believe ( 5 6 I went to Unit 2 in 1976, so if you divide 6 into 52 7 and determine how many weeks and the number of years 8 up to that, you can determine how many weeks of 9 training I had on Unit 2 plus the two weeks. 10 Q You had an additional two weeks aside 11 from your shift training? 12 A Yes. CT Aside from your shift train ~ing you had an k/ 13 Q 14 additional two weeks. 15 Was that immediately prior to taking the 16 exam? 17 A Yes. 18 Q Who was that training given by? 19 A The Met Ed staff. . 20 Q Did you' receive any training from an 21 outside vendor? By that I mean Penn State of B&W or 22 General Physics? 23 A I think it was General Physics. I think that 24 is the name. Yes, I received training down atLB&W, (x/ ; 25 too, prior to that..
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Mehler 16 l 1
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Was this training other than the training 2 Q 1 3 you spoke of where each operator would go for a 4 week each year plus 20 hours? I am not sure if it was the year before I ( 5 A 6 received my license or the year after, but I spent 7 like three weeks down at B&W that particular year, one , 8 week on Unit 1 and one week at Unit 2, and then 9 a combination. . 10 Q You say you don't remember if it was 11 before you shifted over to Unit 2. 12 was it before you received your senior 13 reactor operator license? 14 A I don't remember that. It was'one solid week 15 for Unit 1, and one week for Unit 2. 4 16 Q This was separate from your a'nnual 17 training you were speaking of, separate or in addition 18 to the week of training you would get annually just MJ for being an operator? , b 20 l A with B&W? 21 Q Yes. L. 22 A No. 23 Q It was the same? () 24 A Right. You received an operator's license on Unit 25 Q 9 c
, , - , . - - .- +-,e 1 Mehler 17 2 1, and you listed here as receiving it on August 8, 3 1974, and it was then renewed. You then received a 4 senior reactor operator's license on Unit 2. You
( 5 went directly to a senior operator's license on Unit 2. 6 You didn't start with a control room operator's I 7 license? 8 A No, I didn't. 9 Q How did you then come to be licensed f l 10 on Unit.1 and Unit 2 as a senior reacto,r operator? l 11 A After we had taken the test from NRC, Unit 2, l ! 12 senior, both written and oral, my license was amended. {S
\- 1. They amended i
13 I still had a CRO license on Unit 14 my Unit 2 license to cover both units at that time. 15 Q "They" being the NRC7 ) 16 A Yes. 17 Q That was at the request of you or Met Ed? w 18 A Met Ed. 19 Q Prior to receiving your senior . reactor 20 operator license on both Unit 1 and Unit 2, the 21 amended date which you list as November 22, 1977, 22 did you receive a course or any' training specifically 23 focused on the differences between Unit 1 and Unit 27 24 A I don't recall.
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25 Q Do you recall in the course of your , .l:) O: - _ - _ - _ _ _ - . _ _ _ _ _ _ _ _
1 Mehler 18 i 2 training, whether it was at TMI or off site, ; L 3 receiving any training specifically oriented towards 4 the differences between Unit 1 and Unit 27 A I don't recall receiving any that was classified
- f. 5 6 as differences.
7 Q When you spoke earlier of having spent 8 three weeks around -- you couldn't recall whether it 9 was before or after you received your Unit 2 license, 10 spending three weeks at B&W, you said one week was 11 specifically on Unit 2. 12 How in the B&W training did they' differentiate between training on Unit'1 and Unit 27
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13 14 A The only way I can. recall they talked about the 15 differences was the' simulator instead of having 16 a T. Avg. of 579 which would be Unit 1, they use a 17 T. Avg. of 581 which would be Unit 2. 18 Q Do you recall what procedures'were used 19 in the course of your simulator training at that 20 time? 21 A Whenever you are down and you-use a procedure 22 from your plant that you are down there for, whether 23 Unit 1 or Unit 2, if they are appropriate,.if they O don't pertain to that particular_ simulator, we use (j '24 25 the B&W procedures.
1 Mehler 19 2 Q Is it your recollection that at the time 3 y u received this training, this three weeks, one 4 of which was specifically on Unit 2, that the Unit 2 ( 5 procedures were sufficiently complete so that they 6 could be used on the simulator? 7 A I don't recall. 8 Q Do you recall when you went down for your 9 80-hour course that you have noted as being in 10 August 1973 what procedures were used on the 11 simulator? 12 A I don't recall. 13 Q Do you recall 'ever using solely the B&W 14 Old Forest Road 1 procedures for the simulator 15 training? 16 A I don't ever recall using them solely. 17 Q So the earliest recollection you have . 18 of operating the simulator you had at least some 19 Unit 1 procedures or TMI procedures? .
'20 A I don't recall whether there were'so'me there
.. 21 or.not.
.k. fDo you recall when the last. time was that 22 Q 23 you had to use~any old Forest Road procedures for J' 24 .the simulator?
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- 25 . A Normally'whenever'wefare down in Unit 1, we 4
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1 Mehler 20
/~'T. . . O use the Old Forest Road procedure on bringing the 2
turbine on the line, for the simple reason Unit 1 has 3 4 a GE, and the simulator is a Westinghouse. In terms of operating the primary system, ( 5 Q 4 6 are the Old Forest Road procedures used at all, or 7 have you, since you received your senior reactor 8 operator's license, have you used Old Forest Road 9 procedures for controlling the primary side of the 10 simulator? 11 A I don't recall using them, and I don't recall 12 not using them. 13 Q When you were tested for yo'ur control 14 room operator's license,.what is the test composed 15 of, the written test? 16 A The written test, you are talking a' bout the 17 first license, the CRO license? 18 Q Yes. 19 A The first license was Sections A through G, 20 which starts -- it has to do with reactor theory, 21 health physics, emergency procedures, plant 22 characteristics. I don't recall.all.the sections. 23 Q What method is used to grade the sections?
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/ i Are they separately graded?
. 24 V
25 A Each*section is separately graded.
l-E 1 Mehler 21 __ 2 Q You receive a grade from zero to 100 on I 3 each section?
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b 4 A Yes. 5 ( 5 Q What grades are required in order to I_ 6 receive your license or to pass that section of the k 7 license application? 8 A Back then? E y . 9 Q Yes.
$ 10 A Back then I think you needed an overall average L
F 3 11 of 70. O A 12 Was-there any obligation that you pass Q 13 each section with a certain score? % 14 A I don't recall there was.
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[ 15 Q What then was your senior reactor operator E * ?# 16 license? How was the senior operator license exam r
, 17 different from what you just described?-
's 18 MR. GLASSMAN: You are talking of the 2 w e 19 senior operator license back in '777-w- b 20 MR. BENEDICT: The one he took.
- . 21 A Other than taking the RO sections, I km 5 2$ , , believe at the time it was five more sections you had 23 to take which was in more depth, the questions and i
24 answers. K - 25 Q Did the additional five sections involve e __._______._____.____.________._-__m__ _ _ . - _ - _ - - - - _ -
i 4 1 - Mehler 22 0 2 a greater degree of theory analysis than the first 3 seven sections? ! 4 A one of the sections did, yes. l 5 Q That was what sort of theory? 6 A It would go in more depth into the theory. The 7 six factor fo rmula , how it was derived. And the 8 questions had to be in more depth. The answers had 9 to be in more depth to show more depth of knowledge. 10 Q Was this thermal hydraulic. theory? 11 A There was no section that was classified at that 12 time as thermal hydraulics. ( - 13 Q What is the formula you were referring to? 14 A The six f acto r formula? 15 Q_ Yes. What does it relate to, or, rather, 16 .what the. formula is in fact? 17 A It relates to the nuclear reaction when K 18 equals 1. 19 Q -It is a nuclear physics question.as 20 opposed to a thermal dynamic ~or thermal hydraulic
- 21. question?
.c 22- A Yes.
23 Q- What-was the grading required, the () 24 ' passing grade, when you took the1 senior reactor
$$ license?
1 Mehler 23 2 A I still think at that time you needed an average 3 of 70. 4 Q When you took your first 48-week course, 3 q ( 5 was there homework assigned? 6 A Not that I recall. 7 Q During those 48 weeks, did you spend an 8 eight-hour day in a classroom or in classrooms? 9 ' A Yes, I did. 10 Q This 48 weeks did not involve any on-the-job 11 training at that time? 12 A Not that I recall. 13 0 Was one of the requirements for you to be 14 admitted to this program the experience that you had 15 had on the fossil plant, Crawford Station?
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16 A
-- g-I couldn't answer that because I don't know if
, 17 that was a requirement. IO Q Do you recall ever receiving any 19 unsatisfactory test results in the courseof your 20 applying for licenses? 21 A To the NRC? 22 Q Yes. 23 A No. 24 Q You don't recall ever having to take a 25 section ovsr?
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B 1 Mehler 24 O' 2 A Not because I had less than 70. 3 Q Did you ever have to take a section 4 over? A Not that I recall. ( 5 G Q When you were preparing for the senior 7 reactor operator's exam, did you then receive homework 8 from the TMI training staff? 9 A Not that I recall. 10 Q Did you do self-study in pr.,eparation for 11 the exam? 12 A Yes. 13 Q Were you permitted to do this while you 14 were on duty? . 15 A You usually didn't have time to do it while you 16 were on duty. 17 Q Was this, therefore, work you had to do 18 outside of your work hours? 19 A Normally, yes. ' 20 Q Were you paid for that time you spent? 21 A No. 22 Q Did you have to account for it to anyone? 23 A No. 24 Q The preparation sections, if I recall, 25 you testified the training you received in I
m-F m Lt 1 Mehler 25 i
- O~ 2 preparation for the senior reactor operator license e- 3 was composed of your shift training and then a two-4 week course immediately before?
E (. 5 A Yes, sometime before the test. w- 6 Q And that was administered by the Met Ed E 7 staff? 8 A Yes. = 9 Q And you cannot at this point place in E 10 time'the B&W three-wcek period hich you spent?
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m { 11 A No. r E 12 Q As to whether it was before or after that 13 exam? e "^ 14 A Yes, and also in that two-week course prior F i 15 to taking the test, I cannot say for certain that it E j 16 was only Met Ed staff. There could have been people 9 _ 17 coming in from B&W, because periodically on certain 18 systems we would request them to come up. j 19 Q When you said a moment ago that sometimes 20 B&W people would come up to give some training -- F 21 A We would request it. 7 (. 22 Q Who is "we"? c e 23 A Met Ed. r 24 Q Did you personally have any involvement [ 25 in requesting B&W employees for training? E
1 Mehler 26 A No. 2 3 Q How did you as a student know that you were 4 receiving training from a B&W employee as opposed ( 5 to GPU or Met Ed employees? 6 A I would know the individuals. 7 Q Do you recall who from B&W you received 8 training from during the period up to, let's take it 9 in sections, up until you received your control room 10 operator's license in 1974? Do you remember the 11 individual? 12 A I don't recall. I can give you some indiv iduals ' 13 names at different times I probably received instruction 14 from. . 15 Q O.K., if you can remember specifically 16 when'you received it, name the people you recall 17 receiving training from, either at B&W or people who , 18 came up to the site to train. 19 A I don't recall the first name, but there'was b 20 a gentleman named Redman. I received training from 21 .Ted Book, B-o-o-k. I received training from Walter 22 Perks,lP- -r-k-s. I received training from Bill 23 Street. I received training, and I don't know the
T - 24 gentleman's name, but he was in charge of the (O i. , ~ ,
.n 25 emergency coreccooling and safety analysis group.
e 3'
Mehler ' 2'7 A 1 s C \- ' V 2 There were numerous other individuals, too, that I received training from. We have also -- I know 3 . 4 particularly on Unit 1 we requested training on the ( 5 seal package on the Westinghouse pumps, r.nd we 6 received it from B&W, and then we asked for the 7 Westinghouse reps to come in. , 8 Q The person whom you recall being the head 9 of the ECCS and Safety Analysis Section, did you f 10 receive training f::om that persen at B.3W? i 11 ; A I received training from him already in Unit 1 1 - 12 auditorium at Met Ed, TMI Unit 1.
^
O 13 Q Do you remetaber when? Was'that p rior? . s 14 A That was prior to rec.e f ving e* inn my Unit 1's 15 list. 16 Q Before August 19747 , 3 n
- 17 A To the best of my~ recollection. .It could have '
y 3 s 18 -been after there, but it was on Unit 1 before, Unit 2. \ . 19 Q Are you a member of a union? - ,, ,- w < 20 A Not at this time. n
. p m.
- g. % ,h, 21 Q Have you been since you worked at Met Ed?, ' \' , ['
22 A Yes, I have. '
'N . N s
' .. g s What union? s 23 Q s
A International Brotherhood of Electrical Workers, [v } 24 (
?
. Local.563. 1 l25 ,
6 k
- s, t
.q _ -- ._
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Mehler 28 1 2 Q If your membership card is not expired, 4-m. 3 why do you say you are no longer a member?
- a v y 4 A It is an honorary withdrawal. I can reinforce
, i b 5 it any time I want. 6 Q Why did you withdraw from the union? 7 A Because I took a foreman's job in Unit 2. 8 ' Q Is that considered a management position? 9 A Yes, it is. .
,, .10' '
Q For purposes of bargaining? 11 A I am no longer in the bargaining unit, yes.
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12 Q . Werc yet at any time an officer or a G- , h 13 N x local representative of the union? J'~ 14 )A y };o ) ' , 15 Q A shop steward? 16 A yo. s -
-17 s Q Do you have any knowledge of involvement 18 that the union h' ail with respect to training decisions,
)
19 when%and how training would be conducted?
. 20 A No, I was never in any meetings that were 21 conducted between them and management.
_s 22 Q Do you know now whether the union did'in s' 23 fact have a role in arranging training at Met Ed?
%': $ ,x -s y pm.j 'L' ~
I don't know for a fact.
+, 24 A
'n.bq.J
.-g' 9 6 Q- .] 25 -Q. You have never been involved in discussions 3.'- .
N.,
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")._ . - _. , . . . . -
I l Mehler 29
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N_). with your union brothers about decisions that the 2 3 union made with respect to training? 4 A I cannot state anything for a fact, so I would ( 5 rather not state anything. 6 Q Do you know if the union continues to be 7 involved at this time in making training decisions 8 or suggestions to Met Ed about training? 9 A They are always open for suggestion. 10 Q In the course of your first 48-week 11 training session, what written material were you i 12 ' provided by your instructors? i
-' 13 MR. GLASSMAN: If you recall.
14 A I don't know what the books were called. I 15 don't recall the name of the material, but I accumulated over that period of time some' thing like 16 17 eight volumes of books, roughly'five inches thick. 18 Q Five inches thick each? 19 A Yes. That was on different systems,_and a lot 20 of it.came from B&W. The majority of it in fact. 21 Q Were these looseleaf notebooks? l 22 A Yes. 23 Q Three-ring binders? ; 7 .Yes.
;- 24 A -(
v 25 Q were you provided the material in bits
E 1 Mehler 30 2 and parts which you then added to your notebook, 3 r were you provided with the whole notebook? I 4 A I don't believe we were provided essentially E the complete package in the beginning. We had so ( 5 6 many to begin with, and we added to it as we went. 7 Q Do you remember how the books were divided? I 8 By what subject matters? 9 A You had the steam generators. You had the o a 10 reactor internals and the primary system. You had E - e 11 the CRDM's, the in-core detectors, the reactor 12 coolant pumps, and numerous other things in the 13 primary plant that I just don't recall at this time. [ F I 14 Q How much of this eight-volume material s 15 was focused on the primary plant and the secondary 16 plant up to the outlet, let's say, of the steam 17 generator, the secondary side outlet? h 18 A I can't venture a guess on that. E-19 Q How much was focused on the plant othe'r [ 20 than.the tertiary water systems and the turbine 21 generator? 22 A I had a specific book on the turbine which was - 23 one notebook which was not -- it was just a normal 24 notebook. 25 g Do you still have this material? r e
^
31 Mehler 1 I don't know. It may be stuck away somewhere. 2 A Q Do you have an office space that is yours? 3 4 A We have a room, a shift supervisor 's room, 5 that is shared right now with five other individuals. 1 6 Q Do you have filing space in that room? 7 A one set of filing cabinets. 8 Q Do you know whether the volumes that you first 48-week training course 9 received during your 10 would be in those filing cabinets? t 11 A No, they are not in there.
- 12 Q Where else might they be?
13 A Up in my attic. 14 MR. BENEDICT: I think we would like to have somebody -- obviously Mr. Mehler is not l 15 16 in his attic right now and can't l o'ok , but I I can't 17 would appreciate that being followed up. - necessary to conclude 18 say now whether they are 19 the deposition, but why don't we try to find out if they still exist. 20 We will review any request MR. GLASSMAN: 21
-{ that you make, and if I could be in his-attic 22 23 right now, I could help you look but
- s. - 24 BY MR. BENEDICT:
Q You say you received at the outset of the 25
32 Mehler 1
\
A ). 2 training course a certain volume of material and then 3 received handouts throughout. How did that work? Would you receive the 4 C 5 handouts the beginning of a lecture? 6 A Normally, yes. Q Did you take notes? 7 8 A Yes. Q Did you take them on the handouts? 9 20 A I would take them on a yellow tablet of paper. 11 Q Did you keep your notes in a system? , 12 A Yes. q 13 Q Do you still have your notes? 14 A I don't know. 15 Q Would they be in your attic with the books? 16 A Probably. Q Other than these eight volumes which you 17 18 received and put together over the course of your 48 19 weeks, what other materials do you recall receiving 20 in the course of the training you received up to your 21 first license? 22 A We had system descriptions which we got as 23 preliminaries and then final system descriptions , 1 O 24 on different systems throughout the plant, and we (_/ 25 used to go over them.
33 Mehler 1 O Q Who did you receive these from? 2 I don't know where they came from. I believe 3 A 4 they came from Gilbert Associates. 5 Q This was for Unit 17 A Yes. I am talking about the 48-week course. 6 Q Actually, we may be talking at cross 7 8 purposes here. I said other than the eight volumes, i
- ,9 what did you receive, and you put these system 10 descriptions as outside of those eight volumes? (
11 A They may be some of them in the eight volumes. 12 Quite a few of them I threw away because they were 13 no longer of any use. 14 Q What form would these system descriptions 15 take? i 16 A Basically it would give a purpose for the 9 system, a summation. Then it would go.through it 17 . 18 component by' component and give you the design of 19 the components and the capacities. _ 20 Q .Would you have or did you receive a system description for the core flood tank system? 21 f J 22 Is'that the sort of system that would.be isolated? MR. GL AS S MAN : Is the question directed 23 () 24
.to whether Mr. Mehler recalls receiving a 25 particular description?
i
,r - 1 - , - , , a, ,-4 - -~ ,.r y---...,-,-.,-,,,-r,-., -,,,-rw- ,,-g-.,,,.n,,-m--,,m ,, ,r-er- -,,-ww--e r,~w,,e .,.
34 Mehler 1
-(
\_J. Do you recall receiving a system 2 Q 3
description for the core flood system? 4 A No, I don't recall. 5 Q Do you recall receiving a system injection? 6 description for the ECCS high pressure 7 A I don't recall. 8 Q Is it your recollection that these system the core 9 descriptions dealt with topics as narrow as 10 flood system? t A In the components of it, yes. 11 j 12 Q They didn't deal with the primary system? O 13 There wouldn't be one system description for the 14 reactor coolant system? 15 A Not that I recall. 16 Q They were more narrowly focused? 17 A Yes. 18 Q Do you recall a system description on 19 the reactor coolant pump seals? , 20 A Not that I recall. 21 Q These were received in the course of your 22 48-week training course, is that right? I 23 A Yes. Q Did you receive lectures on these? l (_) 24 25 A Yes. l.
35 Mehler 1 2 Q From? 3 A Plant staff. I 4 Q Not from Gilbert Associates? ( 5 A No, I never recall receiving any from them. 6 Q Jumping ahead for a moment, do you recall ever receiving anything of this sort with 7 8 respect to Unit 2, system descriptions? 9 A Not that I recall. 1 10 Q I believe you testified earlier that you ( 11 believe that you were in the first group of licensed 12 operators for Unit 2. O v 13 A I don't believe I was in the first group. The i i first group of operators for Unit 2 were the CRO's, 14 - 15 and they were sent to Lynchburg to B&W to be 16 trained, and I don't recall if it was for an eight-week I was not with that group. 17 or 14-week duration. . 18 Q You did not receive th at training? 19 A No, I didn't. _ , 20 MR. GLASSMAN: I believe the earlier 21 testimony will be consistent with that. 22 Q The original control room operators
~
23 group for Unit 2;which you just mentioned, do you O recall who was in that group? (_) 24 25 A I' don't recall all of them. I recall some of
, . . , , - , , . , - , ~ , e .- .- -. ~ . - -
Mehler 36 1
~
(~1 v. i 2 them. g who do you recall? 3 I 4 A Lynn Wright, Fred Scheimann, Denny Olson. Joe Congdon. Marty Cooper, C. - 5 believe Mark Coleman. 6 .I believe. 7 Q Do you recall whether Craig Faust -- 8 A I don't recall if Craig Faust was in that group 9 or not. I know Walter Perhe was one of the foremen. 10 Later on he became simulator trainee at B&W. 11 Q Do you recall if Mr. Zewe was part of f 12 that group?
'~# 13 A No, he wasn't. I know there were'other CRO's 14 but I don't recall their names at this time. '
l 15 Q Prior to the receipt of your first 16 operator's license, what on-the-job training were you 17 required to perform or receive? . 18 A The type of on-the-job trainning we got is and trace the systems. We 19 ' physically we would go out 20 would also be taken out by the foreman on~the plant 21 and be given a walk-through on the different systems. 22 Also we would participate in the test program, and 23 in the test program you assisted the STE in lining 7
/N
( ,) 24 up the systems, running the tests on the systems, 25 doing hydros on the systems, doing flushes on the 4
Mehler 37 1 O (_/ 2 system, so you had a pretty well in-depth knowledge 3 of what the system could do and where the components 4 were. C 5 Q And did you have to account for the time Did you have to 6 you spent on on-the-job training? 7 keep a log? 8 A I don't believe there was a log kept. 9 Q Do you know whether in order for you 10 to comply with AEC regulations you were required to 11 participate in a certain number of hours of on-the-job 12 training?
\
13 A I don't know if there was a requirement or 14 not. 15 Q You don't recall at this point accounting 16 for your time spent? 17 A Your time wouldn't have been accounted for in - 18 a particular system. It would have been-accounted 19 for a specific code and that code would relate to the 20 job. 21 Q Are these numbers that you know and that -- ( 22 do you prepare your own time sheets and allocate your 23 own time? 24 MR. GLASSMAN: What time frame?
'(,
l MR. BENEDICT: Prior to his first license. 25
t Mehler 38 1 u) [' I prepared my own time sheets. The duties I 2 2 A 3 Performed during that period of time were dictated
< 4 by the foreman that I worked for at that time.
( 5 Q And you don't know of any requirement 6 that your time be assigned to a category which related 4 1 7 to on-the-job training as the category? 8 A Not that I recall. MR. GLASSMAN: I think that has been 9 10 asked and answered, t 11 Q You are now a shift supervisor, is that a 12 correct? 13 A Yes. i 14 Q And you are currently working at the site, ) 15 Three Mile Island? I 16 A Yes, Unit 1. 17 Q What are your responsibilities today 1 18 as a shift supervisor on Unit 1 which is' currently -- 19 is it in cold shutdown?
~
20 A Unit 1 is in cold shutdown as of the date of the accident. You want to know what my responsibilities i ( 21 ' 22 are right now? 23 Q Yes. fy A Or what they used to be? l () 24 25 - Q Let's talk about just today, what are your G E
Mehler 39 1 ' C )- . 2 responsibilities as a shift supervisor on Unit 17 1 3 A I am responsible for all evolutions that 4 take place during the time I.am on shift. C' 5 Q Do you oversee any people who are 6 receiving on-the-job training today? 7 A Yes. 8 Q Do you today account for the time that 5 9 they spend in on-the -job training? 10 A Right now, we h' ave people that arb, Auxiliary 11 C's, and they will move up to Auxiliary B and 12 then they move to Auxiliary A. 13 We have C's in training and B*s in 14 training right now, and we also have CRO's in 15 training. They have a written program where they 16 must study a particular system during a certain 17 ~ duration of time. I will question them on the system 18 or the foreman will question them on the system and 19 possibly give them a walk-around on the sys' tem. 20 They.must pass that. At the end, the 21 C's at the end of a year, they.will have to take an ( 22 oral walk-around. They will have to take a written 23 test and pass that. Upon passing that, they will O
- sl 24 become an Auxiliary B. .
E 25 Q These are tests-that are administered
Mehler 40 1 2 within Met Ed? 3 A That's correct. ' 4 Q They are not NRC tests? A That's correct. Then he will be a B, and he will 5 6 have the same type of program. He will be allowed on 7 the primary side. At the completion of a year he will 8 take a written and oral and he must pass that and he 9 becomes an A. Then he has to spend -- I forget the 10 exact number of time -- I bellene it ir a year he h'as - 11 to be an A. Then he is allowed to bid en the CRO job 12 if there is an opening. If there was an opening and .i , 13 he was a senior man and has the qualifications, he will i go ir.to the Cao program. In that program, he vill 14 15 receive classroom training and on-the-job training. 16 The on-the-job training will be up in the control 17 room and out in the plant, and it will be a series of ,
~
18 - certain systems he has to get walk-around and questions 19 and answers and then he will have to be administered 20 a test prior to taking the NRC test, both written 21 and oral. Upon passing that, he will go up for the ( 22 NRC test. 23 Q Focusing on the control room operator J 24 trainee, who prepares the required list or the list 25 of require'd systems for on-the-job training?
+ e ,%e *-y , , - -
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l 1 Mehler 41 O('h. 2 A Th .s t comes out of the Training Department. 3 9
- Is it your job responsibility to administer 4 that list to see to it i
5 A The company issues that. 6 MR. GLASSMAN: You are talking to today? 7 MR. BENEDICT: Yes. 8 Q Is it necessary for you to sign off on 9 a document that says he has performed these evolutions 10 or reviewed these syscems or whatever it would be? 11 A He can be signed off by a licensed CRO, by a 12 foreman, or he can be signed off by me. O 13 Q-t When you were s CRO trainee, did you have 14 tc go through a similar round of on- the-job training? 15 A I was with the original group, and I don't think 16 we had the documentation at that time. 17 Q You don't recall? . 18 A Other than the 48 weeks. During the 48 weeks, 19 the way that was designed was at the end of the 20 week'on Friday you would be administered a written 21 test, one in your theory portion of it or health 22 physics-and one in systems, and you had to pass that 23 test. If you failed that test, you'could make up i Oi one test the following week, and you had to pass it (,) 24 25 - the following week. If you dropped it two weeks in
e 1 Mehler 42
/~N .
U . 2 a row in the same subject, you were phased out of 3 that program. 4 Q You do not at this point keeping -- you 5 don't recall anyone having to sign off on performance 6 that you undertook.in the course of your on-the-job 7 training when you were preparing for your CRO license? 8 A I don't think there was any particular sign-off 9 on systems as a whole, but when we had walk-around . 10 which would be open to any system in th'e plant, 11 anything in the plant, they did give us sign-offs on I 12 that. i O 13 Q When is the earliest you can recall that t s I 14 there was the documentation that we were discussing 15 that you have to take care of now? J 16 A The earliest I can recall was right after 17 .the original CRO's went up for Unit 1 test. After-I 18 that, they started a training program called the 19 CAT 4 program. From that period onf there was always 20 sign-offs. 21 Q Did you say the original group of CRO's ( 22 went up for their tests? 23 A Yes, it would have been in '74. Sometime after
'N 24 '74, whether.it was two months or three months after 25 that, I don't know, but the people that went into-the
., - -n., n + - . , ,- -.- , -w, w , ,.,-c,-e,-.m,, ,-e .- - - . - - ,
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1 Mehler 43 A
\ J.
2 CAT 4 program had sign-offs and testing periodically. 3 one thing I have to also say is there is formal 4 classroom training all the way through starting at 5 the Auxiliary C operator and up through the A and 6 CRO. There is formal classroom training given by 7 Met Ed. 8 Q That is in addition to our discussion 9 earlier of what now is the system for noving f rom W 10 an Auxiliary operator C to a Control Room Operator? 11 A Yes, there always was previously, too. 12 l Q to you have any involvement in the (~)}
\_
13 classroom portion of the training that the potential l 14 operators receive today? Are you an instructor? 15 A no, I am not. q 16 Q Do you participate in discussions with 17 the Training Department as to what should,be covered? 18 JL I can have input to it when I am dissatisfied t 19 with something. 20 Q Let's take since the accident. Do you 21 recall any instance where you vere dissatisfied with ( 22 something and you raised this issue with Training? 23 A I don't recall any specific incidents. f, T,i Do you recall that you have done it, but -
\~) 24 Q l 1
25 you can't recall the specifics? l l
1 Mehler 44
\ %J.
2 A I believe I have done it. 3 Q Do you recall whether there was any 4 time, let's say, in the year of critical operation 5 for Three Mile Island 2 from March 28 to March 28, 6 March 28, 1978 to March 28, 1979, do you recall any 7 time during that period when you went and spoke to 8 the training people about things that you were !- 9 dissatisfied with? 10 A 1:o . - 11 Q Would these communications normally have 12 been oral communications? 13 A Normally, yes. 14 Q Do you recall ever writing memos? Have 15 you ever written a memo to Training complaining of 16 some aspect of the training? 17 A Not that I recall. w 18 Q Do you or do you and your fellow shift 19 supervisors have a secretary? , 1 20 - A - Not as such, no. 21 Q Do you have any clerical person assigned ( 22 to you? 23 A Not as individuals. We do not. n
- 24 'Q As a group?
25 A If I needed something typed, I can have it
- 9
-..,,.c, . , . , _ - . . , . -..,r . -, _ . -, , , , . . , , , .w, , .,c.
1 Mehler 45 w -
)
2 typed in the front office. 3 (Recess.) i
'4 BY MR. BENEDICT:
5 Q Have you ever heard of a horse book? 6- A Yes. I 7 Q What is a horse book? 8 A Basically it was a book made up by some of the 9 people that are licensed, and it really has tne 10 pertinent type information to it. '. l 11 Q Pertinent to the exam? ( 12 A Questions that could possibly be asked on the 13 exam. 14 Q Did you prepare a horse book? 15 A I never prepared one. I have one. 16 Q Who prepared yours? 17 A I don't know who prepared it.
- 18 Q When did you receive it?
19 A I don't recall exact 1r when. 20 Q Was it prior to your first AEC exam? 21 A No, it wasn't. ( (
)
22 -Q Was it prior to your SRO exam? 23 A I am not sure if it was or wasn't. n
- \~/ 24 .Q Tell me a little more about the contents 25 of the horse book. Is it a looseleaf notebook?
. - _ _ ___ _ _ _ _____ _ ___ _____ }
1 Mehler 46
~( .
s ). 2 A Yes, it is a three-ring binder. Q About how many pages does yours have? 3 I 4 MR. GLAS S MAN : If you recall. 5 A Roughly what you have. laying in front of you. 6 Q Two and a half or three inches? 7 A Yes. 8 Q What would be on those two and a half or 9 three inches? 10 MR. GL AS S MAN : You are aski'ng him to 11 l speculate. i
' MR. BENEDICT: No.
12 I , s 13 Q What is on the two and a half or three 14 inches of paper? 15 A I don't recall all the information in there. 16 Q Is it written in a question-and-answer 17 form? . 18 A No, it is not. 19 Q What purpose are these horse books 20 written for? A Study guide.
.( 21 22 Q You do not recall whether you received 23 yours prior to taking your SRO exam in 19777 O MR. GLASSMAN: Asked and answered.
(.) 24 25 A No. II .
. . . . i.. 1
1 Mehler 47 !
!,,_ )
U. 2 Q Have you taken any exams since your 3 SRO exam in 19777 4 A Yes, I just finished taking a written exam 5 administered by the NRC. I.think it was in April. 6 Q What was the subject covered by this 7 exam? 8 A It was a complete RO and SRO written test on 9 Unit t. 10 Q Were you required to take t'his exam? 11 A I don't know of any official requirement that l 12 the NRC said I had to take it. I believe, and I only 13 believe th at the company trent on_ record stating 14 that pricr to starting up Unit 1 they will have all 15 their operators retested by the NRC. 16 C This was not a normal procedure, to your 17 knowledge, in order to retain your licenses? 18 A Every two years you have to renew your license. 19 At any time the NRC has the authority to come in and 20 retest you at any time. (, 21 Q At the time of renewal of either of your 1 22 licenses, and you have renewed your operator's 23 - license on Unit 1 in 1976, did you have to take an y} 5 24 exam at that time? 1 25 A Not administered by the NRC, but it was
... --,,.c4 ---,,-*,-v -c ~,
1 Mehler 48 [d 2 administered by the company, and the NRC reviewed 3 it. 4 Q Did you use your horse book to prepare C. 5 for the exam you took in April, as you recall? 6 A I don't recall if I used it or not. 7 Q Do you recall that you received it in 8 order to prepare for that exam? 9 A I don't recall that, either. 10 Q Do you still have your horse book? 11 A I believe it is in my bcokcase. 12 MR. BENEDICT: I think that is part of
), %d 13 l the ettic. That is part of the same raquest 14 I made for documents in the attic. I can't 15 say at this point that I wouldn't be able to 16 finish Mr. Mehler's deposition without it, 17 but I would like to request it. ,
18 Q Do you recall any portion of your horse
~
19 book which takes the form of exam type questions 20 and model-answers? 21 A I don't recall anything in the horse book ( 22 that takes that particul'ar form.
'l 23 MR. GLASSMAN: I think we have been over
) this territory. It has been asked and
' \. / 24 25 answered a few moments ago.
~
1 Mehler 49 (~h tf 2 You can continue. 3 Q You said earlier it was your understanding 4 that the horse books had been prepared by licensed 5 individuals and that you did not recall who prepared 6 yours. 7 Do you recall any material in your horse 8 book, the source of which was something other than --
'9 in other words, that wasn't written by a licensed 10 person e.t TMI?
11 A I couldn't tell you that. 12 fe In other words, do you recall whether your ,' 13 horse book contains handouts received from the 14 Training Department, for example? 15 A Not that I know of. 16 Q Portions of published material? j 17 A I don't quite understand what you are saying. 18 Q Chapter from a textbook, for example? 19 A You'mean completely verbatim? 20 Q Yes, a photocopy. ( 21 A Ilot that I know of. 22 Q Do you know whether any of the contents 23 of your horse book had its source at B&W? n v 24 A Not that I recall. 25 Q You testified earlier about something
- . , --- ~ . - - . _ - - - - . -. . - .
1 Mehler 50 (s_ l , you called shift training or the training where you 2 3 trained for a week over a -- every certain period. 4 You said every six weeks. C 5 A We were on six-week shift rotation. One week 6 out of the six weeks was devoted to training. 7 Q Isn't it true that they shifted to a five-8 week rotation? 9 MR. GLAS S MAN : Who is they? 10 t MR. SENEDICT: Met Ed, for' training its 11 operatora. i .
~
~
12 A Not to my knowledge. 13 Q You don't know of any change from the 14 six-week arrangement you spoke of? 15 .A There may have been a period of time where they 16 went to five weeks, but I don't recall when it could 17 have happened. 18 Q You are not familiar with it ever being 19 anything other than six weeks? 20 A Right, ever since I have been licensed on
-( 21 Unit 1.
22 Q During the training week of your shift 23 training, do you spend your working day in a classroom? O' 24 MR. GLASSMAN Are you talking about
.25 at the present time?
l ! 1 Mehler 51 l ('T V. . I 2 MR. BENEDICT: In the year immediately 3 prior to the Three Mile Island accident. l l 4 MR. GLASSMAN: You are talking of Mr. 5 Mehler's -- 6 MR. BENEDICT: What did Mr. Mehler do 7 on his shift week from March of ' 78 to March 8 of '79. ( 9 A I recall the majority of the time was spent in I 10 the classroom, ", 11 Q During your shift week training, did you 12 receive training on the shift? Or was it alwa fs O 13 l daring the daylight hours? 14 A Always during the daylight hours. 15 g_ So whether or not during that six-week 16 period you were working a shift other than daylight, 17 your training week would be the daylight shift? 18 A It was always normally scheduled from 7:00 to 19 3:00 daylight. 20 Q From whom did you receive training during these weeks in the year immediately preceding Three ( 21 22 Mile Island, the accident? ) 23 A I don't recall exactly from whom I received O) ( 24 the training during that year. The majority of it 25 was from the Met Ed staff. h- m-._ _ - _ _ _ - - _ _ . _ _ _ _ _ . _ _ _ _ _ -
g .. . F k F F 1 Mehler 52 h 2 Q Did you receive any training from any s f 3 outside organization that you recall? 4 A Not that I recall. e ( 5 MR. GLASSMAN: We are talking about in the 6 period one year prior to the accident? {
~ '
7 MR. BENEDICT: Yes. - I Did you r 8 Q How were thess weeks arranged? I i 9 receive a syllabus at the beginning of the week or 2 10 a course list or subject matter list that would Le covered during the week? 11 12 A on a Thursday, usually your training program ( 13 for the following week is distributed, i 14 Q Daring this period, we are talking of the ~ 15 year immediately prior to the Three Mile Island L r 16 accident, what typically would this subject matter = 17 list contain? What sort of subject matters were 18 covered during that period? 19 , A It could pertain through the year's time to 20 anything from health physics to reactor theory to a ( 21 individual system training. 22 Q Attached to B&W 235 is what appears - 23 be a computer -- several sheets of computer printouts, 24 starting as the seventh page. It says at the top , 25 " Generation Division-TMI Station Resume." E
1 Mehler 53
- 9. 2 Are these lists of subjects covered 3
during the weeks, the shift training weeks? 4 A I couldn't say for any certainty that this 5 is a complete list of the subjects covered. 6 Q Are these subjects that were covered 7 during the shift week? For example, turning to the 8 second page, the longer page, it irdicates that 9 you received training on miscellanecus requalificatien 10 l lecture topics, and if you read across,. it says 11 " Hours," one, and then " Complete Date," Octcher i 12 2nd, 1978. 13 l coes that entry it.dicate that you received 14 one hour's training on that subject on that date? 15 A That is what the entry stipulates, yes. 16 Q Are these entries lists whether or not 17 complete of the subjects that were covered during 18 your shift week training? 19 A I would not know if this is a complete list 20 of the subjects covered or not. Whether or not it is complete, are these { 21 Q 22 lists -- is this list a list of subjects that were 23 covered during those training periods as opposed to 24 some other training period other than your shift 25 training week?
j_ eJ'
- f i f '
/
-1
^
hehler 54 kf . , 2 MR. GLASSMAN: If you know. 3 A I don't~know. 4 Q Did you attach this list to the resume C. 6 when you prepared it? 6- A I believe so, yes. , 7 Q Do you recall whereEyou obtained this 8 list? ' 9 A I believe I got~ it from the Training Department. 10 Q Do you recall whether you requested it 11 in order to prepare th f.s resume or whether you had o 12 it prior tnereto? V 13 A I don't recall if it was for this resume or 14 if I had it prior to that for snother resume. 15 Q Do you have any other records pertaining 16 to the training you received other than the material 17 attached or contained in Exhibit 235? , 18 A No, no t that I recall. I don't believe I have 19 any other. 20 Q when you were -- let's back up for_a j 21' minutn. 22: Do you recal'1 preparing this resume which 23 is dated July 20, 19797 O ( ,) . 24 A Yes, I recall' preparing this. 25 g Did you prepare it at someone's re que s t?
~ . . . . . .- , ,__
l 1 1 Mehler 55 4 \ ,/ 2 A Yes. 3 Q At whose request? 4 A I think it was for one of my depositions for C 5 the President's Committee. 6 Q Do you recall what individual asked you 7 to prepare it? 8 A No, I do not. 9 Q Are the pages, the first three pages of 10 the document which are typewritten, were ther 11 prepared on or about July 20, 1979, the date of this? gS 12 A I would say yes. b Did you draft them? 13 Q 14 A This here? - 15 Q Yes, the first three pages.
- s 16 A Yes. -w
~
17 Q When you attached the sheets after 18 the first three pages, did you review them prior to 19 attaching them? 20 A I reviewed them, yes. 21 Q Did you understand then what the contents ( 22 of these documents were, what the documents showed? 23 A It basically shows during this period of time , 7, that I had that type of training. , 24 25 Q Did you discuss with anyone in training s 4
4 n
.:\
f
- 1
- Mehler 56
^
i N 2 what this. document showed? 4 3 A ~ No, I didn't. _ 4 Q You don't recall whether you had this C -- 5 document prior to assembling this resume in your 6 s possession? l 1* 7 A I don't recall if I did or didn't. ,
- l 1
8, Q The latest date that I can find on the U 9 three pages concerning computers is on the top of
\
1 ' i l 10 the third page of the computer printout, and it says i 11 " simulator Training 38," pre sumably hours , and then 12 it says February 5, 1979. s . _ s' ' 13' ~ Do you recall receiving any training
, 1 d
14 between Febr'uary 1979 and March 28, 19797 , 15 A I do n t recall receiving any simulator training 16 between that period of time. 17 Q'- Do you recall receiving any training
~
i 18 whether on the simulator or not? 19- A I recall receiving quite a bit of training on . 20 the simulator, y
' 21 Q I understand that. You limited your
{ is 22 answer to my_ question to simulator training. I am i 23 simply'asking do you remember receiving any training b
%./ 24 ~ whether through' Met- Ed, whether by Met Ed or by a-
.25 vendor, between the time February 5, 1979 noted here.
O
- h. ,,.
?. ' .;fI 4
.VII
_ _w .. , , .. - . . . ., . -,
I Mehler 57 1
%) .
2 and March 28, 19792 A I d n't recall. 3 Q What is the requalification requirements 4 C. that you have to go through at Met Ed? What 5 requalification requirements do you have? I 6 MR. GLASSMAN: Are you talking about in 7 8 the present time? MR. BENEDICT: Today. 9
. 10 A Are you referring that to maintaining my ' 11 license?
12 Q I have heard people speak of 13 requalification training. I guesswhadI am getting 14 at is what your understanding of requalification 15 training is today? 16 A Requalificationwouldbepartofthe training 17 you receive during the six-week cycle, that one week ,
^
when you were in training. It could also' pertain 18 19 to the yearly: test either administered by"the company f or by the NRC. It could also pertain to certain i 20 21 sections on the NRC test or the company administered 22 test which you receive less than an 80 in that 23 section requires during that year's duration that1you A requalify~on that section and retest on that section (s) ~ 24 l and-get a grade greater than 80. It can be used very J
;25
., - - ,, . , , , . + . a ,,-n , . . . , , . - . . , , , . ,
1 Mehler 58 1 ()) (_ loosely. 2 Q During the period, let's say, from the 3 time you received your senior reactor operator's license 4 in october 1977 through to the day of the accident ( 5 6 at Three Mile Island, what methods did you have for 7 learning about plant experience, whether at a Met Ed nuclear facility or at other facilities? 8 A I don't know of any formal methods that are laid 9 out for us to learn that. We can learn it through, 10 t 11 the publishing house documents that come to the island. ' 12 We could also learn them from our experience when we O 13 go down to the simulator. Sometimes they will relate to us this happened in another plant. 14 Those are the only methods I-can recall 15 16 at this time. Q Do you remember a specific instance prior 17 to the Three Mile Island, any time prior to the accident 18 at Three Mile Island where you were instructed or told 19 ab ut events at a plant other than at the Three Mile 20 Island facility by a Met Ed training person?
- 21
- k. A I know we have been told about other facilities 22 ccurrences or incidents at other facilities.
1 I and 23 ix don't-recall the specific time or the facility at this
-( ) 24 time. .
25
Mehler 59 1 0 2 Q You do recall, though, that Met Ed training 3 PeoP le instructed you or told you about events during 4 your training at plants other than the Three Mile Island C. 5. Plant? i 6 A Yes. 7 Q What method was there for finding out about 's 8 occurrences at the two TMI units from, let's say, the 9 period receiving your senior reactor operator's license 10 to the accident? 11 MR. GLASSMAN: Formal methods? 12 MR. BENEDICT: Right. 3 13 Q What methods did you have tA learn about 14 instances occurring at either of the TMI units in which 15 you were not personally involved? A Any significant incident occurring at either 16 17 unit you would fill out a Superintendent's report, and 18 if it was significant enough, the report would be 19 distributed among the licensed personnel, and also if 20 it was'really significant enough, we would probably cover it-in training during the six-week cycle. ( 21 Distributed to all licensed personnel, that 22 Q
. ?J would. include control room operators and senior reactor 7-T) s 24- Operators?
p
,3 A Yes. l
Mehler 60 1 (~) ~
\_)
2- Q The auxiliary operators are not licensed 3 PeoPle? 4 A Right. g who else do you.know these Superintendent's 5 6 reports would be distributed to? MR. GLASSMAN: His speculation? 7 8 Q Do you know? 9 A I don't know anyone else for certain. 10 Q Did you ever file a Superintendent's report 11 in the period preceding the Three Mile Island accident? 12 A Yes. 13 Q Were any of your Superintendent's reports 14 circulated among the licensed individuals? f 15 A Not that I recall. 16 Q Do you recall what subjects you submitted 17 Superintendent's reports on? , 18 A Normally, it would be on a reactor ' trip. 19 Q can you recall a specific instance? 20 A No, I can't recall a specific instance. Q Is the Superintendent's report a form? l ( 21 22 A Yes. 'l 23 Q Which calls for certain information? C)
\ s' A Yes.
24
- 25 Q.
- Do-you recall what areas of information it
l l 61
. Mehler 1
p V requires you to provide? 2 A Normally, the condition of the plant prior to the 3 incident and, if known, the cause of the incident, and 4 5 the corrective action taken. Q Prior to Three Mile Island, do you recall 6 ever receiving a Superintendent's report discussing the 7 incident involving an open PORV on March 29, 1978? 8 MR. GLASSMAN: Objection. Lack of
'9 f undation. I don't know that we established 10 gg that there is or is not such an incident.
Q Have you ever heard that there wa,s an
-w + 12 d incident on March 29, 1978 involving an' open PORV on g
g TMI Unit 27 MR. GLASSMAN: Are you asking today, not 15 whether he heard it prior to the ac'cident? 16 MR. BENEDICT: Now, I am laying the 17 foundation for you. If you want to sit here for gg f ur-days, we will do that kind of stuff. 19 MR. GLASSMAN: Just ask proper questions. 20 (Record was read back.)
~
[ g Are y u today aware that there was an Q 22 in ident at Unit '2. on March 29, 1978 involving an open 23 l [ PORV? (- 24 l A I d n't recall the particular date, no. 25 e 4 r- . - - - ~ y_,,
l l l 62
. Mehler ! 1 7_
2 Q Do you recall an incident in which there was 3 a failure of a PORV at Three Mile Island Unit 2 as a result of a power failure which caused the PORV to open 4 , 5 on loss of power? - 6 A I am aware of that. 7 Q Do you recall ever receiving a 8 Superintendent's report prior to the aedident on Three 9 Mile Island on March 28, 1979, which concerned this 10 incident involving the PORV? e 11 A I don't recall. 12 Q Do you recall an incident occurring on 13 April 23, 1978 at Unit 2 resulting from failed main 14 steam relief valves? , 15 A I don't recall learning about it through a report. 16 Q Do you now recall that such an incident-17 occurred? . 18 A I do know that such an incident occurred but I
~
19 don't know if it occurred on that date. Q You don't recall receiving a Superintendent's l 20 report with respect to it prior to the accident at Three I 21 22 Mile Island? 23- A I' don't' recall if I did or didn't. , a
/'Nf t Are Superintendent's reports prepared for \ ~ 24 Q 25 incidents occurring prior to fuel being loaded at the i
w, y w g - , w- .m
Mehler 63 1 O 2 reactor? Were superintendent's reports filed for 3 Unit 1 or Unit 2 prior to their having fuel loaded? 4 A I don't know. C= 5 Q You don't know whether they are limited in 6 scope with respect to when they are filed? 7 A No, I do not. 8 Q Do you remember receiving a superintendent's 9 report prior to the accident at Three Mile Island which 10 concerned an incident during hot functional testing on 11 Unit 2 occurring in september 1977 in which there was 12 difficulty in removing saturated steam from the hot 13 legs? ? 14 A No, I don't recall receiving a report on that. 15 Q Have you ever heard of that incident, the
~
16 . incident I just described? 17 A: Yes, I have-heard of the incident.' . 18 Q But you do not recall _ receiving a 19 . superintendent's. report with respect.thereto prior to 20 the Three Mile. Island accident? 21 A- I don't recall how I became aware of it. 22 Q Do you recall receiving a superintendent's
~
23: report with respect to antevent which-occurred in' 24 October--1977 involving a trip of,the condensate'polisherL occurred? 25 ,on Unit:27t' Do.you recall if such an event P .
Mehler 64 1 2 Do you know now? MR. GLASSMAN: Are you asking if he 3 4 received at any time or whether he received such 5 a document prior to the Three Mile Island 6 accident? 7 Q Are you today aware whether such an incident 8 occurred? Do you recognize the incident I described? 9 It occurred in October 1977 on Unit 2 involving a trip 10 of condensate polishers, loss of feedwater? 11 A I am aware of the loss of the polishers, but I am
' 12 not aware of it. occurring in October 1977. -
. s 13 Q What incidents prior to Three Mile Island, 14 how many instances of condensate polisher' failure or trip 15 are you aware of occurring prior to Three Mile Island, 16 are you aware of today which occurred prior to Three 17 Mile Island? . 18 A Prior to March 28, 19797 19 Q Yes. 20 A Two. 21 Q Do you recall the approximate dates of ( 22 either or both of them? 23 A I don't recall the dates. D You don't recall that one occurred in (..) 24 Q October? It doesn't refresh your recollection if I were 25
+ - - -
-y ,e n -
1 , Mehler 65
- 0. 2 to tell you it occurred in October 1977 or May 1978?
3 A No. 4 Q Do'you recall ever receiving a ( 5 Superintendent's report concerning condensate polisher 6 problems on Unit 2 prior to Three Mile Island? 7 A' No, I don't recall that.
'8 Q Other than Superintendent's reports, what 9 formal methods are you aware of that existed prior to 10 the accident at Three Mile Island, what formal t methods 11 were there to communicate occurrences, communicate to 12 the licensed people the occurrences at the two Three Os 13 Mile Island units?
14 A I think we kept the LER book in the_ control room. 15 Q What is contained or was prior to Three 16 - Mile Island contained in the LER book? 17 A It would be a licensee event report.- I couldn't 18 tell you exactly what was contained in them.- 19 Q These are the entire licensee event reports 20 for incidents at the TMI units? l 21 A Y e s .- 22 Q Would an. incident at the' Unit 1 facility,
!M. the LER for that incident, be contained in'the Unit 2
[ 24 - control room? MR. GLASSMAN: You aren asking for this 25
~
l _ _ _ v
1 Mehler 66
. r~5 .
(M 2 witness' knowledge, and not his speculation? i 3 I noticed the question started with a "Would." 4 A I don't know. 5 Q Going back to the distant past, your 6 simulator training in August of 1973 at ,B&W, you list 7 here on your resume, B&W 235, that it was 80 hours. 8 Do you recall what the division was between 9 classroom time and simulator time? 10 A We were down for two weeks, and tp the best'that 11 I recall, it would have been 20 hours each week spent 12 in the simulator and 20 hours spent in the classroom. 13 Q so it was 40 hours? 14 A Yes. , 15 Q We discussed earlier as well the procedures 16 you recall using for your various periods'of simulator 17 training. Do you now recall.whether or not you used, 18 for this session, whether you used Unit 1' procedures 19 or the so-called old Forest Road procedures? 20- A I don't recall which procedures we used that two 21 weeks. 22= Q Do you recall whether.there were any TMI-1 23 Procedures available? b~ V 24 A I don't recall. 25 Q During this two weeks in 1973, were you
l 1 Mehler 67
~
(~]\ N-provided with any written material by B&W? 2 3 A I don't recall for certain. 4 Q Where would you look today to find material ( 5 that you received then? Do you have files that you 6 believe might contain it? 7 MR. GLASSMAN: That question is directed to 8 material received from B&W7 9 MR. BENEDICT: Yes, during that period. 10 A I wouldn't know where to look. , 11 Q Turning again to the next to the last page 12 of this exhibit which is part of this compute'r list, (~N ' 4 - N_ 13 it indicates at the top " Simulator Training," and what 14 appears to say 38 hours, and it lists as a date 15 February 5, 1979. 16 Do you recall that session of' simulator 17 training? 18 A No, I do not. 19 Q Do you recall how many sessions of simulator 20 training you had between the period in August 1973 and' 21 the training listed here.in February of.1979? 22 A No, I do not recall. It was numerous times. 23 Q Do you recall whether it was more than once (~3) 1 24 a year? x, ./ 25 A In certain years, yes. I know one year I was
1 Mehler 68
~'\
(O 2 down three times. 3 Q Because you were licensed on both units,, I 4 did you go for a week each year for each unit? ( 5 A Yes, I did. 6 Q Encompassing all of your simulator training 7 at B&W up to the day of the Three Mile Island accident, 8 do you recall ever seeing a failed open PORV7
,9 A I don't recall seeing that particular incident.
10 Q Do you recall seeing any incident which 11 involved a break in the steam space at the top of the 12 pressurizer? O- 13 A I don't recall ever seeing any. 14 Q Stuck open code safety leaking? 15 A I don't recall, 16 Q Do you recall ever seeing any event that 17 resulted in increased pressurizer level? . 18 A I don't recall. 19 Q Do you recall-seeing an incident involving 20 a stuck open spray valve?:
- 21- -A I don't recall the different incidents.
22 -Q 'During any of the period again including.
'23 the time from your first exposure to simulator lthrough ' v(OJ-
- ~
-24 the day of the Three Mile Island accident, did you ever 25 request of the.B&W people that you be shown-any
d } - 1 Mehler 69 l O 2 particular evolution or transient on a simulator? t 3 A I have made requests to see certain incidents 4 or failures. I don't recall which particular ones I C 5 requested. - 6 Q Do you recall you did make requests prior i 7 to-the Three Mile Island accident? 8 A Yes, sometimes we would ask to see a particular 9 -failure over again. 10 Q Do you recall ever asking to see a failure 11 that you had never seen before on the simulator? 12 A No, I don't recall that. 13 Q Do you recall ever seeing during that period 14 a multiple casualty on the simulator? ! 15 MR. GLASSMAN: The period prior to the 4
~
16 accident? 1 17 ;MR . BENEDICT: Yes. , 18 A I don't recall, no.
~ ! 19 Q Do you recall whether before or since the 20 Three Mile Island accident you have ever seen a multiple 21 casualty on the simulator at B&W7 22 A I.know that we have seen multiple _ casualties.
23- I don't recall if_they were before_or after, and I don't-(,,) ' 24 recall which multiple casualties we have seen. 25 .Q ' Have you ever discussed with anyone at_ Met Ed g' n-
,, . - - - - - - - , - - - . . ,-w. .y,.- , -%,. , - - - + + , - - , -
1 Mehler 70 D V 2 the consideration by Met Ed of obtaining its own 3 simulator? 4 A I don't recall any formal request or any formal ( 5 documentation on Met Ed getting their own simulator. I 6 know it is widely felt among the operators that we 7 should have our own simulator. I don't know if the 8 company was making plans for getting us one or not. 9 Q Was that feeling widely felt prior to the 10 Three Mile Island accident? h 11 A I can only speak for myself. I can't speak for 12 other people. It is my belief that, yes, it'was felt 13 that we wanted our own simulator. 14 Q Prior to Three Mile Island, you personally 15 felt that Met Ed should obtain its own simulator, in 4 16 your personal view? 17 A I would have liked to see them ha've,their own 18 simulator. 19 Q Did you have conversations prior to Three l 1 20 Mile Island with other licensed people at B&W about t 21 the advisability of Met Ed obtaining its own simulator? ( l 22 A No, I never talked to anyone from B&W on that, j 23 Q I misspoke. I apologize. f} Did you ever speak with anyone,'any licensed (_) 24 25 individual at Met Ed prior to.the Three Mile Island r e
Mehler 71 1 O, . 2 accident about the advisability of Met Ed obtaining 3 a simulator? 4 A I don't recall. Q You testified that it is widely felt among 5 6 the operators that it would be helpful for Met Ed to have a simulator. Is that an impression that you have 7-8 gathered only since the accident? 9 A You are asking for my opinion? 10 'Q I am asking for when you came to the view 11 that it was widely felt. 12 A That was even prior to the accident. g (J ' \ 13 Q That you felt it was widely felt? 14 A Yes. , 15 Q Have you discussed with any superior at any 16 time during the period prior to the Three Mile Island 17 accident, anyone who'was superior to you'in the Met Ed 18 hierarchy, be it the advisability or the v'alue of Met Ed 19 having its own simulator? 20 A I don't recall. Q You don't recall discussing it with the 21 22 Unit Superintendent? 23 A I don't recall any conversations along those /~T (j 24 lines. 25 Q Do you recall ever preparing a memo
1 Mehler 72 2 recommending that? 3 A I don't recall. 4 Q Do you recall any conversations with people 5 other than your superiors who are employees of Met Ed 6 about the value or wisdom of having a simulator prior 7 to the Three Mile Island accident? 8 A I could not say for certain that I recall any 9 conversations among anyone on getting a simulator. 10 Q Do you recall that you had such conver'sations 4 11 prior to Three Mile Island but can't recall the j~3 12 individuals? 13 A I believe such conversations took place. With 14 whom, I don't recall, and when, I don't recall. 15 Q can you recall whether or not they also 16 occurred since the accident? Can you recall that such 17 conversations did occur prior to the Three Mile Island 18 accident? 19 A. It is my belief that they occurred p'rior to the 20 accident even so far back as 1974. 21 Q Do you have any understanding as to why 22 Met Ed does not have its own simulator? 23 A No,-I could not answer that. I don't know. r" (T,,)- 24 Q During any of the simulator training you 25 had prior to the Three Mile Island accident, did you
1 Mehler 73 O('% 2 ever ask -- withdrawn. 3 How was a plant transient presented to you 4' as a trainee on the simulator prior to the Three Mile 5 Island accident? 6 A Normally, the transient was presented to us. We 7 would be in the control room during normal conditions, 8 operations, whether the plant was at 100 percent or 9 some other power level. The instructor would put the 10 transient into the computer, and we would not know when 11 it was coming, and we would respond accordingly. 12 Q They didn't tell you prior to it'that 13 "We are now going to have a loss of fe[dwatertransient," 14 or something like that? 15 A Not normally. We would respond to it , and then 16 you could ask for it to be rerun again so we could watch everything. , 18 Q What happened if in the course of your 19 response to the transient an error was mad'e7 Did they 20 stop the program at that point as soon as an operator 21 made an erroneous action? 22 A Not that I recall.
- 23 -Q They would allow the operators to continue
.(_(") 24 attempting to manage the transient?
A To the best of my recollection,.yes. v , - - , , ,. , - - , - - - , - , e~- - - - . , y
1 Mehler 74 l s l d~ 2 Q What is your recollection of the longest l 3 time a transient was allowed to evolve during the 4 period -- on a simulator -- during the period prior to 1 ( 5 the Three Mile Island accident? 6 A The longest one I recall, and I am not sure of 7 the actual duration, but it was -- it could have 8 exceeded one hour. 9 Q The instance that you recall exceeding an 10 hour ' exceeded an hour because it took that long for the 11 operators to respond in a way that the training people 12 at B&W found appropriate? (-- 13 A The operators, to the best that I" recall, were 14 responding properly, and it would have taken them that 15 long to determine which steam generator had the tube 16 leak which was quite small at the time. 17 Q You said earlier that you might then ask 18 after you had seen a casualty, you might a'sk to see it 19 again. When you said that, do you remember. instances 20 in which you requested.that the transient be rerun so
, 21 that the op'erators could observe what happens if they 22 take no action?
23 A A lot of times that would be why the request was made, f~') v 24 25 12 -Were the B&W training people responsive
1 Mehler 75 O 2 to those requests? 3 A Normally, yes. 4 Q Do you recall ever seeing a transient during ( 5 the period prior to Three Mile Island on the simulator 6 which reached saturation conditions in the primary 7 system outside of the pressurizer? 8 A Not that I recall. 9 Q Did you ever witness a large break loss of 10 coolant accident on the simulator? e 11 A Not th'at I recall. 12 Q Do you recall wi.tnessing any small break 0 V 13 loss of coolant accidents? 14 A Not that I recall. 15 (Whereupon, a luncheon recess was taken
* ~
16 at 12:40 p.m.) 17 18 19 . 20 21 22 23
, (') 24 v
25
bt i 76
/
2 AFTERNOON SESSION 3 (2:10 p.m.) 4 B RI AN A. MEHLE R, resumed. (, 5 EXAMINATION (Continued) - 6 BY MR. BENEDICT; J 7 Q I-show you a document that has been 8 previously marked as B&W Exhibit 174, 175, and 176. 9 It is three volumes. 10 , Do you recognize that? 5 11 A I know that this book exists.. 12 Q Did you have any responsibility for O (_) 13 making entires in that book? 14 A No. , l 15 Q Were you assigned to TMI Unit 2 during the 16 periods covered by the book or during the startup 17 period for Unit 27 18 A I was there during -- I don't know if I was there 19 during the whole startup period, but I was'there during l 20 part of the startup period. l 21 Q Can you tell me what date it was you 22 arrived at Unit 27 23 A Somewhere in the area of August 23rd,'1976. () 24 Q This book appears to be-a logbook. 25 Are you familiar with who is responsible.
, -n. , . - - , , n- - . , - - -
l l 2 I Mehler 77 2 for making the entries in this book? 3 A To the best of my knowledge, it was the STE on 4 duty at the time. - ( 5 Q "STE" means? - 6 A Shift Test Engineer. 7 Q Are they licensed individuals? 8 A No, they are not. 9 Q Do you kno'w whether the entries in 10 this logbook were made on the days indicated by the 11 date at the top of the entries? 12 A I don't know.
13 You didn't have any responsibility toward Q
14 assuring that these books were completed during this 15 period, startup period? 16 A I had no responsibilities at all for this book.
~
17 Q Have you ever reviewed any por,tions of 18 this book?
~'
19 A I have looked at the book already. 20 Q Prior to today have you looked at it? 21 A Yes. 22 Q Did you look at it since the Three Mile 23 Island accident? t'h ( ) 24 MR. GLASSMAN: You are looking for an 25 answer outside of counsel?
, ,. . _.,_ . _ . _ . . .. . . - . _ . _ . , _ -I.
3 I Mehler 78 / D]- 2 Q Have you seen this book outside of the 3 context of it being shown to you by your counsel? I 4 A Yes. ( 5 Q Had you seen it prior to the accident of 6 March 28th? 7 A Yes. i 8 What brought you to see it at that time? Q j 9 Do you recall? 10 A I don't recall the specific time when it was, , 11 but periodically, I would go in to talk to the STE 12 and the book would be there, and he would go back through (T ~\/ ..- 13 the book to refresh what may have happened previously. 14 Q During the startup period -- what do you 15 understand to be the startup period for Three Mile
-16 ' Island Unit 27 17 MR. GLASSMAN: You are looking,for dates?
18 MR. BENEDICT: The question is whether 19 he understands whether he and I are s'p'e a k i n g l 20 in the same terms when we use the expression 21 "startup period." It was a period ending at 22 criticality. 23 Q Is that correct, or is it ending at- [) 24 commercial operation or neither? 25 .A I - do n t know exactly what would be defined as'
l 4 Mehler 79
.s -
.{J 2 "
the startup period." 3 g The second volume which is marked 4 as B&W 175, each of the pages has a small five-numeral ( 5 page number, and could you turn to page 06071.
~
This 6 page is headed with the date September 8, 1977, is that 7 correct? 0 ) A Yes. l 9 Looking at the lower third, I will read l Q i 10 from the text, it says, " Pressurizer lov,el unexpectedly i 11 increased when venting the pressurizer and decreased
- 12 p re s s ure from 500 psig to 460 psig. Pressurizer level 4
, 0 13 increased approximately 150 inches during this evolution.
14 Pressurizer temperature was approximately 340 degrees i. i 15 Fahrenheit. Apparently the reference legs have flashed 16 and there was no steam in the pressurizer to fill the 17 reference legs." . IO Turning over to the next page about 19 the middle it says, " Pressurizer level indk[:ation 20 as shown in. control room is believed to be correct." ; 21 Then two sentences down, "Whenever 22 ~ Rc-V137 was opened to vent pressurizer, level would 23 indicate an increase." 24 , What.is the RC-V137' valve on the Unit 2 25 ' plant?
. I i
p .,w4 4 . - , .w9 is y w or wre m y a a,- -s g,--='+g-p wv9y *= - ~'-*--r 4-+ ' r1 T-t #'""
5 1 Mehler 80 (\ ~ Q.) - 2 MR. GLASSMAN: Are you asking for his 3 present knowledge? 4 MR. BENEDICT: Yes. l 5 A I don't know without looking at the prints right 6 now. 7 Q Looking at the sections I have read, are 8 you familiar with this incident? 9 A No. . 10 'Q Would it assist you if I told you this
'11 occurred during hot functional testing?
12 A No, it wouldn't. 13 Q You, to the best ofyourknhwiedge, have l 14 never heard of this incident before? 15 MR. GLASSMAN: Outside of any conversations 6 16 with counsel? 17 MR. BENEDICT: Yes. ,. 18 A I don't recall this.
~
19 Q Turning to the next page. 06073,'another 20 entry on the 9th of September says, "RC-V137 and 21 applied nitrogen to the pressurizer. The ' pressurizer 22 level came down proving that there was a steam bubble 23 in each of the hot legs." () 24 Does this assist-you in recalling whether 25 you ever heard of this event before?
I 5 Mehler O 2 A No. 3 Q Moving to 06173, beginning with an entry 4 beginning October 19, 1977, it reads in the top third C 5 of the page , "CO-P-1C was tripped due to condensate 6 polisher inlet and outlet valves" -- 7 MR. GLASSMAN: The entry 10/19/77 on page 8 06173 is in the lower half of the page. 9 MR. BENEDICT: I am sorry, turn back a 10 page. The portion I am reading flom is about the 11 sixth or seventh line down from the top 12 starting with the designation "CO-P-1C was O 13 tripped due to condensate polisher inlet 14 and outlet valves closing inadvertantly. Open 15 CO-v12 and restarted CO-P-1.C. Valves 16 apparently went closed when Unit II DW system 17 was used as sluice water creating a high pressure 18 condition that caused DW to leak back into 19 service air system on polisher skid. Air lines 20 were blown down and polishers returned to normal 21 operating st'atus. Co-v12 closed." 22 Q Do you recognize this incident as one 23 you have heard of before? 24 A No. 25 Q 'You mentioned earlier in your testimony
4
'7 1 Mehler 82 2 that you were aware of two instances prior to the accident 3 on March 28th in which the're were problems with the i 4 condensate polishers.
5 You do not recognize this as being one of 6 those instances? 7 A I would not know if this was one of those 8 ' instances or not because I don't remember the dates of 9 which they occurred.
- .10 - Q .Does this incident describetan incident
- i 11 similar to the ones you had in mind, to one of the 12 ones?-
7y_ 13 MR. GLASSMAN: Objection. don't know $ 14 ';what you mean by "similar."
- 15 -Q Do you understand the question?
16 A Could you repeat it? I
'17. / Q. Was the incident or were eitNe.r of the l
18 incidents that you recalled.concerning the condensate- l 19 ' polishers instances'in which water was force'd into the
-n .
20 ' service air system causing the condenstate polisher . 21 problem?; f 22 ' A- One of the instances I do recall 11s where-we had' l 1 o l
+
Jt3 water in the system. l
/~
( j} 24 Q , 'And'you are aware of dhat happening only once? #
- lc n 4 3 25 a
O ' 7 *
* 'E
~' , . _ . . . _ ,
l i I 3 1 Mehler 83 2 A Only once prior to March 28th, 1979. 3 Q What do you recall about the other incident 4 involving the condensate polishers that occurred 5 prior to the March 28th accident? 6 A The other incident that I recall was loss of 7 the polisher unit when someone inadvertently opened a 8 powe r switch. 9 Q When you say " opened," that caused power 10 to be' removed? 6 11 A Yes. 12 Q Do you know what CO-P-1C is? f -
\- A That is a condensats pump.
13 14 Q Do you know what CO-V12 is? 15 A Without verifying it, I would say that is the 16 bypass valve around the polishers. 17 Q When do you first recall hearing about .the 18 condensate polisher, the instance of condensate 19 polisher misoperation which you described as' involving 20 water in the instrument lines? 21 A I don't-recall when I first heard about it. 22 Q Do you recall whether~you heard about 23 . it prior to the ~ accident on _ March 28th? s.J
) 24 A Yes,1 I would have heard it prior to March 28th, l
25 but what period of time prior to March 28th, I don't
\
l
3 I 1 Mehler 3 84 ('y - N_] 2' recall. l 3 Q Do you recall how you came about hearing 4 it? 5 A No, I do not.
- 6 Q Do you recall whether it was by word of 7 mouth or in writing?
8 A I don't recall that either. 9 Q Do you recall whether you took any action 10 in response to learning about this incident? 11 A I don't recall if I took any action on this
- 12 specific incident or not.
\] 13 Q In light o f the fact that you don't 14 recall that incident, I am talking about the 15 incident you recall involving water in the instrument 16 lines.
17 Do you recall taking any action with 18 respect to that incident?
19 A I don't recall if I took action on thiIs-one here. 20 Q Did you take some action with respect to 21 something you heard about condensate polisher operation
? 22 prior to the Three Mile Island accident?
s 23 A I wrote a report on one incident, and I am not h,- 24 x,,/ sure which one it was, on, I'believe it was, during the 25 regeneration of_the polisher unit. I do not recall -- I e
--e r- -
I 10 1 Mehler 85 2 believe we did get water in the air system at that 3 time. 4 Q Do you recall whether that incident was ( 5 one that occurred before or after criticality on Unit 27 6 A I don't recall that. 7 Q You do, however, recall that it was an 8 incident that occurred prior to the accident at 9 Three Mile Island on March 28th? 10 A Yes, it was prior to the accident. , 11 Q was the report you ' wrote prepared prior to 12 the accident? O Q 13 A Yes. 14 Q Did someone request that you prepare that 15 report? 16 A Yes. 17 Q. Who? ) 18 A Jim Floyd. 19 Q Do you believe you knew about the incident 20 prior.to Mr. Floyd asking you to write the report on it? 21 MR. GLASSMAN: Objection. The question 22 calls for the witness' -- 23 Q Is it your recollection that you knew l l l
) 24 about the incident prior to Mr. Floyd approaching you 25 and asking you to write this report?
S
,- e v- e w~ - - , , , , --s -
l 11 1 . Mohler 86 I \.s . 2 A I don't recall if I did or didn't. 3 Q So you don't know at this point whether 4 it was Mr. Floyd who in fact told you about this? ( 5 A I don't know. . 6 Q What was the s'tbject matter of the report 7 you prepared? 8 A I had to -- if I had the report, I could 9 answer, but basically how we go.t water into the air 10 lines'. t 11 Q Was this report -- did you draft this 12 report out in long hand? (~h - ~, k./ 13 A Yes. 14 Q Was it then typed? 15 A I don't know if it was or wasn't. 16 Q Did you make more than the_or ginal copy of 17 it? 18 A I ran a copy off for myself. 19 Q And you retained a copy?
- - 20 A I did retain it. I don't know if I still have it.
21 Q You then provided Mr. Floyd -- 22 A He got the original. 23 MR. BENEDICT: I have not found that
/)
(./
.24 report in the files that I have looked through.
25 I have looked through all.the files that
12 Mahler 87
/~h-N~)
2 were designated as being from Mr. Mehler. 3 That is something I think is sufficiently 4 discrete so I think it would be helpful if 4 ( 5 we could get it be fo re' the end of the week if it 6 still exists. 7 MR. GLASSMAN: I don't know whether it has 8 been found before or not or produced. 9 MR. BENEDICT: I appreciate that. 10 If you can tell me it has been prdduced, then 11 the onus is on me to provide it. 12 MR. GLASSMAN: We will take your request b (- 13 under advisement. 14 Q Did this report include a description 15 of the event? 16 A I am not sure exactly what it included any more. 17 Do you recall whether it ine'luded a Q 18 conclusion about how water got into the lines? 19 A
- I believe it did.
20 Q .Do you recall what that conclusion was? 21 A No, I do not. 22 Q Do you recall whether it included any 23-recommendations with respect'to the condensate polisher 24
'v system?
25 A I dont recall.
l 13 - Mehler 88 2 Q Do you recall your title at the time you 3 wrote this report? 4 A I don't recall if I was Foreman or Supervisor at 5 { that time.
~
6 Q I take it you do recall, however, that the 1 7 incident upon which you wrote the report did not occur A 8 on your shif t? O A I don't even recall that. 10 4 Q Was Mr. Floyd's request that, you prepare 11 a report on this incident an unusual request? 12 MR. ' GLASSMAN: Objection. I don't know
~
13 [ what you mean by the word " unusual." 14 Q Had Mr. Floyd ever asked you to write a 15
. report before?
16 A Not that I recall. 17 ' Q Had anyone who was a Superviso.r or in a 18 senior position in the Met Ed hierarchy ever asked you 19 to prepare a report on a plant incident be[ ore?- 20 , -3 .Not that I recall. 21 Q Has anyone since asked you to prepare a l J-22 report up to today? i 23
'o Would you define what type of report?
- 24
.(sg ). Q You were asked by one of your superiors 25 to prepare a report relating to a-plant Ti ncident in e ye r .- * ,e . , , , _ . - -
~14 1 Mehler 89 . ,r~\ - -
U 2 which you discuss issues raised by the occurrence of 3 that incident. 4 A I had prepared reports , Superintendent event ( 5 reports. I have made out accident reports when 6 people got injured, so periodically I made out a lot 7 of reports. 8 Q Are you required to prepare a report every 9 time there is a reactor trip? . 10 MR. GLASSMAN: Whether he is personally 11 required to make a report? 12 MR. BENEDICT: We will start with that. (~)h -
\- 13 A I don't know.
14 Q Is there a requirement that someone prepare 15 a report with respect to every reactor trip? 8 16 MR. GLASSMAN: If you know. 17 A I don't know that either. ,, 18 Q I believe this is in volume 3 which is 19 Defendants' Exhibit 176. If you could turn'to page 20 06520. 21 In an entry beginning at the top of that 22 page which seems to be dated May 12, 1978, in the-23 third line down from the top, the sentence begins,
.'n.j'
/) 24 "Due to operator error, water ~ enter service and
-25' instrument air systems =via-condensate polisher s
i l 1
. Mehler 90 O)
(_ 2 fluffing air line. Polisher outlet valves went 3 shut on loss of air and trip condensate and condensate i 4 booster pumps." I 5 Does this de s c ri-be an incident that you
.(e 6 remember or recollect?
7 A No, it doesn't. 8 Q Does this describe an incident -- the 9 incident which you described there, two condensate 10 polisher incidents you had heard about prior 11 to the Three Mile Island accident, and one of them 12 involved flipping a switch inadvertently and another (J u 13 involved air in the instrument lines? Withdrawn. 14 Having looked at this and having looked 15 at the prior incident that I showed you in this 16
- logbook referring to water in instrument a'ir lines, 17 neither this nor that prior incident, these pages, 18 refresh your recollection as to which of either of these 19 incidents is the one you recall, is that correct?
20 A The one I recall I could not say if it was 21 either one of these or another one.
- < 22 Q Is this description inconsistent with 23 your recollection of_the incident concerning water 24 in the instrument air lines?
I%.) 25 MR. GLASSMAN: Objection. I direct the
1 . Mehler 91
~
1 .s 2 witness not to answer. He told you what his 3 recollection is as to a particular incident. 4 He told you he doesn't have a recollection as 5 to these particular incidents. I don't think 6 there is any purpose to be served by asking him 7- whether a recollection of something else is 8 or is not consistent with something that he 9 doesn't remember. We can all read these pages. 10 .MR. BENEDICT: I wish you would speak with 11 your partner, Mr. seltzer, about this. We can 12 certainly resolve a lot of issues if you and he i v 13 will stop taking inconsistent views. 14 Q Turning to page 06639 in this logbook which 15 is marked as Defendants' Exhibit 176, starting in the-16 middle o f the page in an entry which appears,to be 17 dated November 3rd, 1978, it reads, "An I&C MEC 18 technician" -- mechanical, is that what that means?
- 19. A That is an abbreviation for Met Ed Co.
20 Q "An.I&C Met Ed Co. technician was working. 21 in back of condensate polisher panel and in an attempt { 22 to turn on a light switch accidentally turned off a 23 power supply breaker to control power which caused A (v J- 24 all polisher _ valves to close, tripping both condensate 25 booster pumps, both feed pumps, and the turbine. 4
Mehler 92 1 O 2 Reactor tripped on high pressure." Does that describe the incident you had 3 4 recalled as involving the inadvertent switching C 5 off of a power supply? 6 A I don't remember this log entry. 7 Q Does it refresh your recollection that 8 that event occurred on or about November 3rd?
.9 A I am aware of an event where power was secured accidentally, to the polisher panel. That is all I 10 11 recall. - 12 Q And this doesn't refresh your recollection
'd 13 that it occurred in November of 19787 14 A No, it doesn't. . 15 Q The passages we have read through from the 16 logbook indicate three separate events co$cerning 17 condensate polishers. . 18 Does this refresh your recolle'ction that l l 19 there were more than two events than the ones you 20 recalled previously? 21 A No. { Q Did you with respect to any events 22 23 concerning the condensate polishers that you heard O) ' (, 24 _about prior to the accident on March 28th take any 25 action.other.than the report we discussed earlier
. .. -. .~.
l 1 Mehler 93 0 I to Mr. Floyd? 3 MR. GLASSMAN: That you recall.
'4 A Not that I recall.
1 Do you remember whether there was any ' 5 Q 6 response from Mr. Floyd to the report you prepared? 7 A No. I don't remember if there was any or not. 8 I don't recall that. 9 Q Do you recall suggesting any changes 10 be made to the Unit 2 condensate polisher system prior to the Three Mile Island accident on March 28th?
~
11 12 MR. GLASSMAN: We are talking about 1 ' 13 suggestion to anyone in particular?- 14 MR. BENEDICT:. I am talking about a 9 !- 15 suggestion to anyone. t. 16 Q I will exclude your spouse,-but other than 5. 17 that, prior to the Three Mile Island accid,ent --
- 18 A Verbally or --
19 Q . Written or. verbally. ' 20 A I don't recall any specific incidents where I made any recommendations or suggestions. 4 ( ~21
;22 Q Not focusing'now on the specificity or the .
23 details of that request,'do you remember making any
. ]) \~ 24- request'or a number of requests prior'to the M Three Mile Island incident about changes that might be A
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Mehler 94 1 (3
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2 made in the Unit 2 condensate polisher system? A I d n't remember ever making them. 3 4 Q Do you know today that you did make such 5 things, such recommendations? 6 A I don't know. 7 Q Did you ever recommend that the 8 condensate polisher system on Unit 2 be brought into 9 line with the system, that is to say, made similar 10 to the system on Unit 1 by the addition of an automatic 11 bypass? MR. GLASSMAN: The question is did Mr. Mehler g- 12 N~s 13 ever recommend this? - MR. BENEDICT Yes. 14 , 15 A I don't recall if I ever recommended that. Q You don't recall whether prior to the 16 Three Mile Island incident you ever recommended 17 18 that such a change be made? 19 A That's correct. i ! - 20 Q Are you aware of any suggestions being i I made by anyone else concerning any changes that ( 21 should be made on the condensate polisher system at 22 23 Unit 2 prior to the Three Mile Island accident tr's L(-) 24 whether the suggestion was made prior to the accident,
.25 whenever you may have found out that the suggestion was
. ~ . _ _ _ _ _ _ __ -. -, _ .,_,
95 4 1 Mehler 1 A ~ k,_/ 2 made? 3 A How do you define " aware"? 4 Q Let me try to state the question again. Just to make it clear. 5 6 Today, are you aware that a recommendation 7 or some recommendations were made to change the 8 design or some aspect of the design of the condensate 9 polisher at Unit 2 prior to the Three Mile Island g 10 accident? . 4 MR. GLASSMAN: You are asking whether 11 12 the witness has any knowledge at all about that? MR. BENEDICT: That is righb. 13 14 A I have no knowledge that anyone submitted any 15 official recommendations on having that change e 16 implemented on Unit 2. 17 Q Eliminating for the moment official 18 recommendations, were any changes ever requested by 19 licensed personnel at Met Ed prior to the Three Mile 20 Island accident? -Do you have any knowledge of any (, 21 such requests? 22 A I have no knowledge that anyone officially did 23 that. A -- let's (I 24 Q Again, I am trying to differentiate 25 take out " officially."
, - + . , ,, .-4, ,,
l Mehler 96 1
'Q What do you know unofficially? I would 2
3 rather f rom your answer you know something. 4 What unofficially was done with respect 5 to changes suggested for the condensate polisher 6 on Unit 27 i d MR. GLASSMAN: That you know of. 7 8 A I know many people said they recommended that 9 they do it but I don't know for,a fact that they did it. By "do it," you mean make a ecommendation 10 'Q 11 for a change?
- 12 A Yes.
l 13 Q You said that people talked'about.it. 14 My question then was they talk'ed about the 15 recommendations and you said yes.
.16 What recommendations did they talk about 17 making? -
18 A Basically, that we make the bypass valve on the 19 polishers on Unit 2 an automatic function on the Delta 20 P. Q Whom do you recall discussing such possible ( 21 22 suggestion? 23 A I don't recall who it was. . D You don't recall any individual? k- 24 Q 25 A No, I do not. 1
Mehler 97 1 O - k_). 2 Q Do you recall the people as being operators 3 or shift supervisors or shift foremen? A I don't recall who they were. 4 Q They were Met Ed employees? 5 6 A I believe so. 7 Q You, however, are not aware that anyone 8 followed up on these recommendations? A I am not aware if they did. 9 10 Q And you don ' t recall ever making any 11 recommendation? 12 A Not officially. (Continued on next page.) 13 14 . 15 t 16 17 . 18 19 20 21 ([ 22 I 23
'- 24
. 25 a
e 98 Mehler ik 1 O V, 2 Q Do you recall ever saying to anyone in the Met Ed hierarchy 3 a position superior to you in conduct 4 that you thought it might be a good idea to 5 these changes in word or substance? A I don't recall ever doing that. 7 Q You don't ever recall talking about it 8 with Jim Floyd. A I don't recall ever doing that. Q
'Could you tell me what the d.if fe re nce s 11 are with respect to the bypass valves between unit 1 and unit 27 ,
s_/ 13 MR. GLASSMAN: If you know. ! 14 A To my best recollection, the unit 2 bypass 15 value is a gate valve. The unit 1 bypass value is 16 a butterfly. The unit 2 bypass valve is motor driven, the 17 and it requires operator action to open or close ; 18 value. Unit 1 is air driven, and it automatically 19 opens on high Delta P. 20 Q By " Delta P," pressure can differ on
- 21. either side of the valve?
22 A No. Across the polisher units, which would Also, be reflected in either side of the valve also. (S N- 24 you can control manually the unit 1 valve. 25 Q But you cannot control manually the unit 2
.e -w -
, . - , . . , , --~ - - . - ,
99 i Mehler l 2 1 I
.-'f'\. -
(_). , 2 valve? A Yes, you do. 3 Q You can control it manually but it has 4 I misunderstood. I got 5 an automatic function? So unit 2 valve requires 6 unit 1 and unit 2 confused. the unit 1 valve 7 manual action to activate it whereas 8 will automatically activate upon differential in 9 pressure across the polisher? , A Unit 1 has Powdex vessels. Those are th e 10 11 basic differences. I could be incorrect on whether 12 unit 2's is a gate value. q Q But it is a manually operated valve? 13 14 'A It requires operator action to hit the extension 15 control to open or close that valve. Q On unit 1, what incident will' result in 16 the automatic opening of the bypass valve?
- 17 I
I object. You'are asking 18 MR. GLASSMAN: 19 for speculation in a hypothetical question. 20 If you would like to ask his understanding of
.how it works or if he recalls a particular (m' 21 22 .
incident, pleasesgo ahead. MR. BENEDICT: I am not asking him a 23 hypothetical question. Iam asking someone who 24 25 is. clearly qualified to answer these questions.
Mehler (- 1
\._.)-
The man has senior reactor operator licenses 2 3 on both units on Three Mile Island. ' MR. GLASSMAN: I just object to the form ' 4 and the way you are going about this. I think l 5 ! 6 you can get the information as to how it operates. We have had testimony on it from various other 7 people, but I think the form of the question the 8 9 way it appears in the record should reflect 10 the witness's understanding of how it operates 11 or particular incidents, not some question as for when it will operate or would operate 12 (} 13 or might operate. MR. BENEDICT: Can I have the pending 14 t 15 question read back? 16 (Question read) MR. BENEDICT: By " incident,".I do not 17 mean transient. I mean what physical 18 phenomenon results in the opening of the valve. 19 MR. GLASSMAN: Mr. Mehler's understanding 20 of that? (_ 21 MR. BENEDICT: Yes. 22 23 A When the valve opens, you are bypassing the 24 Powdex units. 25 Q
' ' 'The effect of it is, as I understand,
--..w* s, -y.- y v -re- - + + - wew, wew y v, y c-r--
101 Mehler 1 O
'\~J allow the secondary side water after 2
therefore, is to flow 3 it has been condensed into the condensors to through 4 past the condensate polishers without going 5 them, and from there, having passed through the 6 valve, to proceed to the booster pumps and from to return to the steam generator; is that 7 there 8 correct? Objection. I do not 9 MR. GLASSMAN: to 10 know that there has been any testimony as 11 condensate polishers in the TMI-1 system as opposed to the TMI-2 system. There has been 12 (~N d some discussion of the Powdex system in the 13 14 TMI unit 1. , 15 Q The unit which I referred to as the 16 condensate polisher and which you referred to as a 17 Powdex unit, is the purpose of that unit to remove 18 impurities from the secondary side water before.it 19 returns to the steam generators? MR. GLASSMAN: You are speaking of the 20 21 Powdex system? MR. BENEDICT: Yes. 22 23 A Yes. A
\' " 'l 24 Q Is that the same purpose that is served by the condensate polishers in unit 27 25
- i
- , --,--- - -- - -- , , . ~ . . . - - -
l F I f Mehler 102 5 1 2 A Yes. Q Do you recall whether, when you heard 3 4 about the incident involving the water being forced 5 into the instrument air lines of the condensate 6 polishers on unit 2, you recognized that had that j 7 event happened on unit 1, the automatic bypass valve 8 would have functioned? g A No. , l 10 Q Do you recall associating that incident 11 involving water in the air lines with the difference in bypass valves -between unit 1 and unit 27 {JT 12 13 A No, I don't recall associating it with l 14 anything. - 1 15 Q When you said earlier that you had 16 considered the appropriateness of changes to unit 2, did you include changes that would have' added an 17 18 - automatic. bypass talve to unit 27 19 MR. GLASSMAN: I do not know that there 20 is any testimony as to what Mr. Mehler (, 21 considered or did not consider. There has 22 been some testimony as to what he suggested. 23 I believe he said he did not recall who he
\ 24 suggested something to.
25 (continued on next page)
03 1 Mehle r V. 2 Q When you suggested something prior to the 3 Three Mile Island accident, do you recall one of those 4 suggestions being that an automatic bypass valve be 5 added to Unit 27 6 A I don't recal" making that suggestion. 7 Q Do you recall- conside ring that prior to 8 the Three Mile Island accident? 9 A I believe I would have preferred to have an 10 automatic bypass. ", 11 Q Had you considered that or thought about
/ 12 it prior to the Three Mile Island accident on March 13 28th?
14 A Yes. . 1-15 Q But you didn't suggest it or you can't 16 recall suggesting it to anyone? 17 A I don't recall suggesting it. . 18 Q You can't say you didn't suggest it, but 19 you just can' t recall suggesting it one way or the 20 other? (, 21 A That's right. 22 Q Again on Volume 3, which I believe is-the 23 one you have in front of you, turning back to 06453, i A/ 24 it says in the bottom six lines of that page in an
. 25 entry which appears to be dated the 29th of March, l
-w - - ---%.,- - ,m---- - ,,-,s . - - . -%. v y e
Mehler 104 1 L - r%) 2 39787 3 MR. GLASSMAN: The entry appears on the 4 prior page. 5 MR. BENEDICT: Yes. 6 Q "At 1440" -- which I assume -- "At 1440 7 it appears at this time that during ES testing, the 8 fuse on 2-1V inverter blew and gave a reactor trip 9 and a full ES actuation. The electromatic relief 10 valve lifted and pressurized the RC dra n tank to 11 approximately 100 PSIG. The inverter was put on alternate source, and the high-pressure, injection I stopped, DH-VSA/5B/8A/8B were closed. DH-VSA was then 14 opened to recover makeup tank level and then 15 Dn-V5A was again closed. The pressurizer level was 16 increased to approximately 200 inches.RCS pressure 17 decreased to approximately 1200 PSIG before recovery 18 started." 19 Do you recall this incident? 20 A No. ( 21 MR. GLASSMAN: Councel is taking the 22 liberty of translating certain abbreviations 23 into longhand. 24 MR. BENEDICT: As does .your partne r,
. 25 g, .- Seltzer. I 1
o
Me hle r 105 _ t V , 2 Q You are not today -- you cannot identify 3 this today as an event with which you are familiar, 4 the March 29, 1978 PORY lift at Unit 27 5 A I don't recall this event. 6 Q Are you today aware that such an event 7 occurred? 8 A Yes. 9 Q When do you first recall becoming aware t 10 that such an event occurred? , 11 A I don't recall when. 12 Q Do you recall whether the first time you [~h s )- m 13 heard about it was prior to the Three Mile Island 14 accident on March 28, 19797 15 A Yes. 16 Q It was? . 17 A I was aware of the failure of the inverter. 18 Q Do you recall how you came to know about 19 this event? 20 A No, I don't recall how. Do you recall what you learned about the (. 21 Q 22 event prior to the accident at Three Mile Island on >
../
I 23 March 287 (- O) 24 A All I recall about the event is that they were
-25 doing ES testing, and part of the test required you l
E * . j
Mehler 106
.g Somehow 2 open up the breaker to the alternate supply.
3 something caused them to lose the normal power supply 4 which I didn't know at the time, and they lost quite 5 a bit of instrumentation, and they got an ES. 6 Q ES is engineering safety? 7 A Engineering safeguard. O Q When you got ES, does that mean they
'9 initiated the engineering safeguard including the HPI?
t 10 a y,,, , 11 And you understood prior to the Three Mile Q 12 Island accident they had a high-pressure injection 13 initiation? 14 A Yes, and they terminated within a couple of 15 minutes by closing the alternate breaker. s 16 Q What was the effect of closing the 17 alternate breaker? 10 A They got power back to the inverter, which gave
. I 19 you your i*ndication back again.
20 Q Did you understand at the th.me that the ( 21 return of power caused the electromatic valve which is also called the~PORV, is that right? 22 23 A Yes. 24 Q Did that cause the PCRV to close? 25 A I-was not aware of it at that time. t
l l 1 Mehler 107 i 1 v. 2 Q Were you aware prior to the Three Mile 3 Island accident that incident involved an open PORV7 4 A I don't recall if I was aware of that incident 5 affecting the PORV. 6 g Do you recall when the first time was you 7 did hear that the March 29th incident involved an 8 open PORV? MR. GLASSMAN: Objection. I am not sure
'9 10 the witness testified he recalled %his at any 11 ' time. Perhaps I am not clear on the record.
(. 12 13 Q Is our discussion he re this afternoon the first time that you ever heard that thc_ March 29, 1978 14 incident involved an open PORV? 15 A I became aware of it, I guess, this past week ' 16 with counsel. ' 17 g so, to your recollection, prior to your 18 discussions with counsel in preparation for this 19' . deposition, you were not aware that the March 29th 20 incident involved an open PORV? I don' t recall being aware of it prior to this (, 21 A 22 week. 23 Q I may have asked this question, but it is (l
'- a foundation for the next one Do you recall how you 24 25 came to hear any information about the March 29th
1 Mehler 108 2 incident prior to the accident a year later on March 3 28th? 4 A You are talking about this incident? 5 Q Yes. 6 MR. GLASSMAN: The period prior to the 7 accident.
- 8 A I don't recall how I actually became aware of it.
9 Q Do you recall whether you read something s 10 about it? k-11 A I don't recall whether I read anything or it 12 was verbally told to me. I don't recall. 13 Q Were you assigned to Three Mile Island as 14 a shift foreman or shift supervisor on March 29, 19787 15 A In that period of time I was in training to 16 become a shift supervisor. I was still a shift j 17 foreman in Unit 2. . 18 Q Were you working on a day-to-day basis 19 as a shift foreman? 20 A No. What were you doing during that March - ( 21 Q 22 April period in 19787 23 A I am not sure where I was. 24 Q Do you believe you were not on site at
.25 Three Mile Island?
5
Me hler 109 cO 2 A I believe I was on site, but I don't know at 3 that time what my function was. 4 Q Do you recall that as being a period 5 during which you were training to be a shift 6 supervisor? 7 A There was a period I believe that started in 8 October up until when I became a supervisor which 9 was April 1st of 1978 that I was in the training i 10 program, which could have had me in eithhr unit or 11 possibly during short periods of time in Reading. 12 Q During the period from October to April 13 did you perform normal services as a shift foreman? 14 A The re were periods of time where I did, yes. 15 MR. McBRIDE: October '77 to April '787 16 MR. BENEDICT: Yes. 17 _ Q So this training did not require you to' 18 become completely excluded from your tasks as a' shift 19 foreman? 20 A Periodically I filled in. (, 21 MR. HENEDICT: I have let it.sp), but I 22 think it is inappropriate to end Mr. Mehler's 23 testimony by tapping him on the back or 24 punching him in the arm. 25 Mr. Mehler has come here and obviously r
Me hle r 210 1 O t_J , 2 intends to testify fully, and I appreciate that. But I think it is inappropriate for 3 4 his lawyer to indicate that his time is up for 5 answering the question. 6 MR. GLASSMAN: I think the record will 7 reveal that he gave a full and complete answer 8 to the last question and to all the others 9 before that. 5 10 MR. BENEDICT: I am not going to quarrel 11 about the completeness of Mr. Mehler's answer. 12 I am going'to quarrel with you about the {~J)
~
13 appropriateness of his counsel prodding him, 14 advising him that it is time to dummy up. 15 - If it is done from now on, I am going 16 to mention it, and you are going t'o look dumb. 17 MR. GLASSMAN: Counsel can mention 18 anything he sees. I think counsel has not 19 observed that. I regret your comments on the 20 ' record, and I think we are'really digressing I~ 21 from the testimony, which has been full and 22 complete. 23 , MR.EBENEDICT: I agree it was a ( 24' digression, and I hope I won't have'to make
;u 25 another one. l 1
a .
g Mehle r las (~x t) . 2 BY MR. BENEDICT: 3 Q During thu peri d we were discussing, 4 October to April of 3977 through '78 what percentage 5 of time did you spend in training as opposed to; 6 performing your normal function as a shif t foreman? 7 A I don't know the percentage. 8 Q Do you recall it being in ths 50-percen t 9 range? - 10 A 'I don't recall. , 11 Q You couldn't estimate? 12 A It would only be a guess. [ 13 Q on April 1st, when you became a shift 14 supervisor, did you then resume full-time, duty at 1 1'
- 15 that time or did you then take up full-time ddty at ,
16 that time? t'
\
S 17 A Yes. ; ~- 18 MR. GLASSMAN: So the record is clear 19 and reflects all that is going on.here, let it be 20 known Mr. Mehler has consulted his resume, (, 21 B&W 235, to be accurate about his . dates > i 22 Q You have described what it,is you recall
+ , ,t 23 knowing about the March 29, 19 78. incident prior .,to the -
() l wd accident on March 1979, and you cannot an'lyod
,\.i.'
24 25 testified recall whether or not you. kne N t .,it
. o . s. -
1, A e\ y L ,
l I Mehler 112
.O 2
involved an open PORV. I asked you whether you 3 recalled how you learned, and you said you can't recall i , i 4 whether it was in conversation or you read something.
- ,. 1
' 5 i- Do you recall whethe r during any period O
V s , *from your' arrival, your assignment to Unit 2 through ( *
. \ 7
-4
( to the date of the accident on March 28, 1979, whether ) 8 ~ i you received any publications or documents in the 8 regular course of business which described transients g . 10
,.or events.at the units on Three Mile Island?
4 t
'11
. A I don't recall any.
* .s ,
g i I h5 ' ' ' ' [ (. Continued on Page 113.) ,
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-1 1 Mehler 113 0 2 Q Did you receive a newsletter, a bulletin, 3 or anything of that sort that contained information 4 concerning incidents at the facilities, any periodic 5 report?
6 A I don't recall getting any. 7 Q So on April 1st, you returned to 8 full-time work and took up the position as shift 9 supervisor on Unit-2, is that correct? 10 A Unit 1 and Unit 2. O 11 Q How is it determined where you work on a 12 given day or whether you work at Unit 1 or Unit 27 13 MR. GLASSMAN: You are asking for 14 Mr. Mehler's knowledge as to how this works? 15 MR. BENEDICT: Yes. Up to today. 4 16 Q- Are you given a schedule which shows you 17 are to be working at which unit and which. shift? 18 A Right to tcday, I am working as a shift
~*
19 . supervisor at Unit 1 and Unit 1 only. 20 Q Going back to prior to the removal of l 21 Unit 2 from power generation services on March 28th, ( 1 22 979, how then did you learn where you would be 23 assigned? (_,k 24 A I was assigned to the Island. I was a supervisor 25' over both units with the shift foremen working under
Mehler 114 I 0 2 me in both units, and they had SRO licenses. MR. McBRIDE: Did you mean that you j 3 4 were assigned to both units with the shif' foremen assigned to you in each unit? 5 MR. BENEDICT: I will clarify that. 6 l Q Does that mean that there was only one 7 8 shift supervisor on site at a given time functioning 9 as a shift supervisor?. , 10 A Yes, except during outages or major evolutions. 11 Q In other words, there were periods once 3 12 you became a shift supervisor where you were the shift
\_ supervisor for both units?
13 14 A That's correct. , 15 Q And you were the only shift supervisor 6 16 on site? 17 A That's correct. . 18 Q Did you always work the same shift during 19 the day? In other words, did you always work days, 20 did you always work the second shift? 21 A No, we rotated. (' 22 Q Turning in 176 to page -- MR. McBRIDE: We still didn't get the 23 clarification I was seeking. When you said that l
. \ ,/ 24 I 25 you were the shift. supervisor-and the. foremen k
I 1 Mehler 115 2 were assigned to you in both units, did you 3 mean you had a shift foreman in each unit? 4 THE WITNESS: Yes. 5 Q Turning to page 06485, it has a date of 6 4/23/78 after Mr. Dominquez' name. It is 06495. 7 It is dated in the middle of the page 4/23/78. Over 8 on the far right margin. 9 A Yes. , 10 Q It says about the bottom thi,rd of the 11 page, " Increased reactor power to 20 percent.
! 12 FW-25B got to 80 percent open. FW-V30B traveled open .
13 to ten percent,then FW-V14B opened, starting a plant 14 oscillation. Once the operations Department had 15 control of feedwater, reactor power indicated 30 4
~
16 percent. At this point, the reactor tripped on 17 NI-8 overpower spike (NI-7 was still tripped). With 18 feedwater demand in manual, it was driven back,at-19 which point FW-V25B appeared to stick open kt 20 approximately 20 percent causing rapid plant cooldown and depressurization causing a full SFAS ( 21 22 actuation. Upon_ actuation, flow through MU-V16A 23 & B did not come up to 500 gallons per minute. []/ (_ 24 Pressurizer level went to "O" indicated. Level was 25 eventually recovered and engineer safeguards bypassed
- 1. Mehler 116 I
(~) V 2 (which occurred approximately four seconds after 3 actuation.) 4 Does this describe an event which you C 5 recognize? . 6 MR. GLASSMAN: Counsel seemed to be 7 placing special emphasis in his speech on the 8 words " rapid plant cooldown." I don't know if 9 that was intended. 10 ,MR. BENEDICT: No, I did not. 11 Q Does this describe an event that you 12 have -- g3 ' k_ I don't recall this event. 13 A 14 Q Today are you aware of any event that 15 occurred in this spring of 1978 which involved a . 16 rapid plant cooldown as a result of steam' relief-17 valve sticking open? _ 18 A I am aware of the steam relief valve-sticking 19 open. When it occurred, I am not sure if it was 20 May 1.978 or 1979. 21 Q Did you learn about that incident prior 22 to the Three Mile Island accident on March 28, 19797 23 A Yes, it was during the startup program that it C happened but when, I don't know. ( )h 24 - MR. GLASSMAN: I think the question is 25: s , , - - e , r w ,..
Mehler 117 1 O
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2 do you recall when you learned of this? 3 THE WITNESS: I don't recall when. 4 Q Then the follow-up question is, do you 5 recall whether you heard about it prior to the 6 Three Mile Island incident? 7 A Yes. 8 Q You did. I assume therefore that the 9 transient that you recall did o.ccur prior to the 10 ! Three' Mile Island accident. , 11 A Yes, as I recall. 12 Q What do you recall about that transient
~.
13 involving -- 14 MR. GLASSMAN:, You want the witness' 15 present recollection or what he recalled at some 16 time prior to the Three Mile Island accident? 17 MR. BENEDICT: Let's start with what 18 do you recall you knew about this incident 19 prior to the Three Mile Island accident? 20 A That the safeties on the main steam system either one of them or some of them, stuck open and ( 21 22 caused a rapid cooldown of the system and the 23 -safeties failed to close until'they were in a lower 24 pressure. 25 That's all I recall. a
I Mehler 118 0 2 Q Were you asked to prepare a report on 3 this subject? 4 A No, I wasn't. 5 Q Were -- do you recall whether the incident 6 occurred during your shift? 7 A I don't recall if it occurred on my shift or 8 someone else's shift. 9 Q Do you recall learning prior to the Three E 10 Mile Island accident -- strike that. , 11 Do you recall hearing prior to the Three 12 Mile Island accident that there may have been
~^
(J 13 saturated conditions in the primary system outside 14 of the pressurizer during_this particular~ rapid 15 cooldown event? 16 A I don't recall hearing that. 17 Q To this day, have you ever heard that 18 there may have been steam,.outside of preparation 19 for this or conversations with counsel, since the 20 accident? 21 A No. { 22 Q You are not aware? 23 A I am not aware of hearing about it. n\, _f 24 Q You have never seen any reports or 25 documentation prepared analyzing the issue of whether
I Mehler 119 O 2 saturation occurred in the reactor coolant system 3 during this transient? 4 A Not that I recall. 5 Q Do you recall at any time up to today 6 reading any documentation concerning this incident? 7 A I don't recall any. 8 Q Do you recall -- did you learn or do you 9 recall hearing prior to the Thr,ee Mile Island accident 10 of any suggestion made with respect to dhanges in the 11 plant as a result of the incident, this overcooling
- 12 incident?
13 A None that I can recall. 14 Do you recall hearing anyone -- hearing Q , 15- that'anyone had suggested the installation of flow 16 -measuring or indicating' devices upstream from __ r 17 am sorry -- downstream-from the steam safety relief 18 valves? 19 MR. GLASSMAN: You are talkins of 20 Mr. Mehler's recollection prior to the accident? ( 21 22 MR. BENEDICT: Right.
^ 1D A I don't'-recall if,anyone recommended that any 24 indicatinn be' installed downstream'of the~ relief M valves. .Iodo recall that we put a microphone down
--a gr..is i -i -a m l-n i --
l: m- n ii- m: Mehler 120 1 0 2 in that particular room where the relief valves are It 3 1 cated with a speaker up in the contro. reom. would not indicate which one is open. It would 4 5 just indicate that something.in that room was open. 6 g Do you recall that that was a change 7 that was made prior to the Three Mile Island accident 8 on March 28th? 9 A Yes. a hp 10 g Do you recall wheder hat g 11 thct was made after you had heard about this over-12 cooling event? . 13 A I don' t recall whether it was made after or 14 before. , 15 g Do you recall pdor M W bm O 16 Island accident learning that that change'was made 17 in response to the April 23rd overcooling event or 18 the overcooling event that you heard of? - 19 A I don't recall if it was in response-to that 20 or not. 21 Q Do you know whether any other changes { 22 were made prior to the Three Mile Island accident 23 to assist in the recognition of flow through the 24 steam relief valves. 25 A Other than installing the microphone down e
I 9 O . in that room, I am not aware of any other things 2 3 that were installed. 4 Q Are you aware of any changes that have 5 been made since the Three Mile Island accident to 6 Unit 2 with respect to that? 7 A No, I am not aware of anything in Unit 2. 8 Q Are the indicators for flow through the 9 steam relief valves different on Unit 1 and Unit 27 10 A 'I don' t understand what you are saying. 11 Q Is there an indicator for either the 12 position of the main steam relief valves or flow O. . through the main steam relief valves oItheUnit 2 13 . 14 facility? , 15 Is there any instrumentation or indication 16 of their position either by measuring valve position 17 or measuring flow? . 18 A You are referring to the main steam relief 19 valves? 20 (continued on page 122.) ( 21 22 23 24
'25
- Mohler 122 1
2 Q I am referring to the valves that you 3 heard had failed to open and resulted in the overcooling. There is no position indication on the main 4 A (E 5 steam relief valves on Unit.2 prior to the accident 6 and since the accident that I am aware of other than 7 the installed mike in the room which would just tell 8 you that you had flow-out of something in that room. 9 Q Am I mistaken in saying the main steam 10 relief valves are the valves you were d4scussing as 11 being the valves that you had heard had failed and 12 resulted in this overcooling transient? 13 A The ones that I know that have failed were the 14 main steam relief valves. . 15 Q What,1f any, indicator existed on Three 16 Mile Island Unit 1 pertaining to flow o'r valve position 17 on the main steam relief valves? . 18 MR. GLASSMAN: What period of~ time? 19 MR. BENEDICT: Prior to the Three Mile 20 Island accident.
.A None prior to the-Three Mile Island
( 21 22 Unit 2 accident that I was aware of. 23 Q ~Are you aware that there was a microphone-A
/
added to the Unit 1 steam relief valve room as there i (_) 24-25 was for Unit 2? _ :i e _. ,c ----. , , ,
^ 123 1
Mehler 2 A Prior to the Unit 2 accident, no, I was not 3 aware of that. 4 Q I don' t mean to suggest that it is true. such a thing 5 I only asked whether you knew that 6 existed. And you recall receiving no written material 7 8 with respect to this overcooling event, the event 9 we.have been discussing prior to the Three Mile 10 Island accident, is that correct? ( 11 A Not that I am aware of. 12 Q Do you know who recommended the addition 13 of the microphone? 14 A No, I do not know. 15 Q When you said "we installed that," you 16 didn't mean you physically went down and installed it? 17 A No, Met Ed did. . 18 Q Did you receive any advice or training
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19 as to the meaning or the use that this system could 20 be put?- (, 21 A I don' t recall receiving any training on the 22 system. All.I recall is that it was-installed and center, 23 we had a speaker mounted up behind console ('~') 24 and if you had flow within - that building, somewhere, 25 it was picked up on-the mike. i e
Mehler 124 y 0 2 g Going back for the moment to the incident 3 we had discussed immediately prior to this one, the 4 March 29, 1978 incident and which you have testified 5 you can't recall hearing that that incident involved 6 an open PORV until your p reparation sessions for this 7 deposition. 8 Did there come a time that you noticed 9 that there had been added to the panel in the control 10 room'in Unit 2 an indicator light for th.e position 11 of the PORV? 12 A I was aware that there was an indicating light 13 added to the Unit 2 control room for the PORV indication, 14 but I am not -- I do not , recall when it was added or 15 what period of time, whether it was there from day one 16 or whether it was put in after they started to build 17 the plant. . 18 g So, you do not recall whether'that
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19 indication on Unit 2 was added after you came on as 20 a shift supervisor for Units 1 and 2 on April 1, 1978? I don't recall when it was added. ( 21 A 22 g I would like to show you what has been 23 marked as Defendants' Exhibit next in order, 236. 24 (Photograph of PORV Indicator Light 25 and controls, marked as B&W Exhibit No. 236
1 Mehler 125
.rx .
U 2 for identification, as of this date.) i 3 Q Do you recognize this as a photograph of 4 a portion of the THI Unit 2 control room panel? ( 5 A With any certainty, I.couldn't say yes or no. 6 Q Did your job, prior to the accident at j 7 Three Mile Island but as a shift supervisor,therefore 8 after April 1, 1978, require that you manipulate the 9 controls of either Unit 1 or Unit 27 10 A I did not manipulate the controls of eithe r 11 unit except in an emergency when it was required to 12 happen that way, and the operator was not there. O 13 Q Did you direct the manipulation of controls? 14 A It was part of my job to direct. 15 Q Did you ever function solely ^as a control 16 - room operator and not as a shift foreman or shift 17 supervisor on Unit 27 .,
'18 A No, I didn't.
19 -Q Did y'ou ever as a shift foreman on Unit-2 20 manipulate the controls? 21 A Not that I-recall. 22 Q You can't look at this photograph and 23 . recognize it as a portion of the panel concerning the
-Vf A) 24 control of the PORV?
25 A I haven't been in the. Unit 2 control room looking
- -- ye w- -r-r =m+ s-e
1 Mehler 126
.(-
V at the panel at least for the last year-and-a-half. 2 3 MR., GLASSMAN: The witness had been asked 4 and answered the question a few moments ago. ( 5 I hope it is not necessary to repeat that kind 6 of question. 7 MR. BENEDICT: I don't know why you g persist in adding things unnecessarily. 9 I don't think I am hardly badgering the witness. 10 I don't think it is testing the witness by 11 a sk'i ng the question twice to lay a foundation. 12 MR. GLASSMAN: The only reason I made
%~ 13 the comment was because the sequebce was 14 identical, and it was very close in time, and
. 15 because the witness felt he needed to explain 16 to you why he couldn't identify the particular 17 document before you, and I don't think we should , 18 have that kind of situation, but c o n'tinue . 19 BY MR. BENEDICT: 20 ,Q .You recognize today that there exists at 21 Unit 2 an indicator for PORV position open or closed, 22 is that correct? 23 A I know they have indication lights on it-which
/m indicate eithe r open or closed. .
(v) 24
- 25 Q You cannot,at.this point, recollect when
-, - - , . -- 4 ,r --~ < = , , -n , , ~ ..,e
1 Mehler 127 O 2 'you came to that awareness, is that correct?
- 3 Strike the question. Let me go back.
4 I believe you testified that you cannot ( 5 recall whether the indicator light for the PORV on 6 Unit 2 ex,isted from the design of the control room or 7 whether it was a later add-on, is that correct? 8 A That's correct. 9 Q Do you recall that,there was an indicator 10 light for the PORV when you arrived as the shift F l l 11 supervisor on April 1, 19787 12 A To the best of my ability that I can recall, yes, O. 13 I am aware that there was indication. 14 Q At that time? 15 A At that time. 16 Q What is your understanding of the information 17 provided by the indicator light? , 18 A Prior to March 28th or since March 2'8th? 19 Q Let's start with what your understanding 20 was prior to the accident on March 28th. 21 A Prior to March 28th, I just -- I thought it told 22 you valve position whether it was opened or closed. 23 Q Did you have an understanding that it was ( 24 a direct indication of valve position? 25 A I don't know. I never thought about it.
1 Mehler 128 [) 2 Q Did you receive any instruction or training 3 with respect to the significance of information conveyed 4 by the PORV light? ( 5 A By the lights themselves? 6 Q The position indicator on the control 7 panel. 8 A Not that I recall. 9 Q Do you know today the PORV indicator 10 light indicates only that there is power across the 11 PORV solenoid? 12 A I understand as of today the lights indicate m 13 only a demand signal, not the acutal position of the 14 valve. . 15 Q Am I correct that the demand signal comes 16
- by energizing or deenergizing a solenoid on the PORV 17 valve? ,
18 A To the best that I can recall, yes. 19 Q Is it'today your understanding 'that the 20 PORV' indicator light is lighted when there is power 21 across the solenoid or when the tolenoid is energized? 22 A I don't know which way it works. 23 Q You don't recall any training prior to (
) 24' the accident on March 28th concerning the significance 25 aof the PORV* indicator light?
- =
r_ Mehler 129 g
=
2 A Not that I recall. 3 Q You are not aware that the PORV indicator E 4 light on Unit 2 was added in response to the event 5 which we have discussed on March 29, 1978? " MR. GLASSMAN: I object. 6 k - 7 We have had this question asked at least a u 8 once, probably at least twice. g p 9 I direct him not to answer. Let's get on with it. L 10 , P 11 MR. BENEDICT: You direct him not to i 12 answer a question that he can answer yes or no? 13 MR. GLASSMAN: He answered it a few times. 14 Read back the record for the last few moments. We will find it again. He testified 15 16 he didn't recall. h F MR. BENEDICT: I can't believe that you 17 b 18 think the question of an indicator light on 19 the open or closed position on the PORV in the _ 20 Unit 2 control room and what the shift supervisor knew about that up to the date of the accident ( 21 E - 22 is not important and isn' t worth a few questions 23 probing his recollect.
=-
O 24 You direct him not to answer the last 25 question?
t-
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Mehler 130 1 Yes. This is a silly 2 MR. GLASSMAN: l colloquy. 3 4 As you are well aware, I have allowed 5 the witness to answe r .more than once in the We know his answer. I don't 6 last hour or so. know why we are bothering going over the same 7 8 material again. I let him answer before.
'9 Continue.
10 Q .Today, are you aware of any > procedure that 11 exists for Unit 2 which relates to the PORV indicator 12 light? 13 A I can' t recall any procedure right now that 14 relates to the indicator light. 15 Q Do you know whether Unit 1 has a PORV 16 position indicator light? 17 A Yes, it does. , 18 Q Did you know that it had a PORV indicating 19 light prior to the accident at Three Mile' Island? 20 A -Unit I? 21 Q Yes. 22 (continued on the following page.) 23 (~') N-< 24
- 25
.-- - - , , n, - ,-
1 I Mehler 131 f (:) . I 2 A If I recall correctly, it has been installed 3 since day one. It is a back-lighted light which just i l 4 indicates a light and it changes color from either, ( 5 I believe it is green, closed, red, opened. This is 6 not the same identical indication that you have here. 7 Q Do you know whether there is on Unit 1, . 8 Three Mile Island, an indicator light which indicates 9 whether or not there has been a demand made on the 10 PORV to open? t l 11 A That particular light is a demand signal. It 12 is not actual. O 13 Q During the period that you ere training 14 as a control room operator for Unit 1, what do you 15 recall being told about the PORV position indication 16 instrumentation on Unit 17 17 A I don't recall what I was told about it in my 18 training on Unit 1. 19 Q Do you recall whether you knew prior to 20 the accident on March 28, 1979 that the Unit 1 PORV 21 indicator light was a demand indicator? 22 A I don't recall whether I knew that or not. 23 Q In order that we can be sure we are ( 24 talking of the same subject, when you refer to the 25 Unit 1 indicator light, do you mean an indicator
,a J
, 1 Mehler 132 m (_) 2 which tells you whether or not there is energy to the 3 solenoid? 4 A It tells you that a signal has been transmitted 5 for the valve to open or close, and that signal will 6 tell you what color light you have. 7 Q Does it tell you when a signal has been 8 made, has been given to open when that signal was 9 automatically initiated? 10 The distinction I am tryingtto draw is', 11 does the indicator light that we are discussing on 12 Unit 1 show only that a switch has been turned to 73 ' . \m 13 actuate the PORV, or does it show you -- 14 A There is no switch on Unit 1 that you can actuate 15 the PORV. There is a switch on the back panel which
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16 allows you to change set point on the P'ORV for when 17' you cool down. . 18 Q Is there a switch on Unit 2 which allows 19 you to open or close the PORV? 20 - A I don't recall.
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21 (continued on the following page.) 22 23 l
. m;.
24 I U ._ _.
't 1 Mehler 133 I
2 Q Prior to your receiving your Control Room 3 operator's license or your operator's license in 1974, 4 what training did you receive on the use of procedures,
- k. 5 operating, emergency, and abnormal procedures?
6 A I really don't recall the specific training we 7 received on any specific procedure, we did receive 8 training on procedures, what was contained within a 9 procedure and basically how to use it. 10 Q Was it your understanding that by the time i 11 you took the NRC exam, you had reviewed, in your training, 12 all of the operating procedures for Unit 17 '
\ ,
13 A I don't know. 14 Q The same questions for emergency procedures 15 and abnormal procedures. 4 16 A Emergency procedures and abnormal procedures were 17 reviewed in more depth; and prior to taking the NRC test, 18 we were responsible to know all the symptoms and 19 immediate actions required of an operator on'those-20 proced,ures. 21 .Q And all of the emergency procedures and 22 abnormal procedures for Unit 17 m A Yes. ([ 24 Q Did you have to go-through the same' exercise-25 . in order to.take your senior reactor-license exam for
g Mehler 134 O 2 Dnit 27 A You were supposed to know all th'e immediate symptoms and all of the immediate a'ctions required. 4 0 # ^ 5 g A Yes. Q For abnormal and emergency procedures? 7 g A That's correct. g Q In the course of your training, how were 10 y u examined by y ur trainers on your understanding of the emergency and the abnormal procedures? 33 12 A If I recall correctly, during training, they may ask you to list the response to some emergency procedure 13 or some abnormal procedure, and also during a walk-around 74 15 they would give you, it would be a simulated type of 16 walk-around just like the NRC real thing would be, and g7 they would ask you on a reactor trip, what are your. 18 immediate actions, and you have to show thhm, simulate gg what you would do. - Q W uld the questions in the written and 20 these oral questions take the form of the plant-has C experienced a loss of main feedwater, what are the 22 g symptoms and what are the immediate actions? (). 24 MR. GLASSMAN: Are you asking for his speculation?
i Mehler 135 2 MR. BENEDICT: I am asking if the form of 3 the question -- I will be more general. 4 Q When you were quizzed on your knowledge of 5 abnormal and emergency proce.dures, were you given the 6 transient and asked to set forth the symptoms and 7 immediate actions? 8 A Sometimes, yes. 9 Q Were you ever given symptoms and asked from 10 that to identify the transient? - 11 A Yes. 12 Q Would, in these questions, you ever be given O 13 less than all of the symptoms listed in an emergency or 14 abnormal procedure and asked to identify the transient? 15 A I don't recall if they gave them all or some of 16 ' them or parts of them. 17 Q Do you recall any questions'in;the course 18 of these examinations in which they listed'the symptoms 19 of a given event'and in addition misleading' symptoms? 20 A Not that I recall. 21 Q In your r le as' shift. foreman or-shift 22 - supervisor, do you have any responsibility in examining 23 . or quizzing applicants for CRO positions in emergency or j) . abnormal procedures? -(_/ 24 25 A I don.'t follow your question. Are you referring
1 Mehler 136
.[U ~
2 to someone that is already in the training program for 3 CRO or someone who would be wanting to get in the 4 training program for CRO? 5 Q Let's say a pers.on who is in the CRO training 6 program and is now going through the on-the-job training 7 program? 8 A Yes, that would be part of my job to ask him 9 questions on anything pertaining to that plant. 10 Q Including -- t 11 A Emergency procedures, regular operating procedures.
, 12 He is open to anything.
[h
%)
13 Q Has it been your practice in the past to 14 describe symptoms to a CRO candidate and ask him to 15 identify the event and the applicable procedure? 16 A I don't recall any incidents where it was 17 approached where I gave him symptoms and asked him.to 18 give me the event. Normally you say, "This is the event. 19 Show me the symptoms and what you are going'to do." g 20 .Q Is it a fair example, you would say you have 21 a loss-of main feedwater, what are the symptons? ( 22 A That would be a fair question. 23 Q You don't recall in your practice of
;(O)- 24 examining these people on their recollections or 25 knowledge of the procedure presenting them with symptoms
.^
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q -
1 Mehler 137 O ' and asking them to identify the event? 2 A I don't recall if it was ever done in that way. 3 4 Q Again, the period up to the time of your C. 5 receiving your Control Room . operator's license on Unit 6 1, what were you trained about the way emergency 7 procedures were to be used? 8 A Emergency procedures, the training up till and 9 since the time of the accident ,i s the emergency 10 procedure the operator is responsible to perform the 11 immediate manual actions. He is also responsible to 12 insure the automatic operations occur and in the O 13 capacity of a foreman or supervisor, you should pull 14 the procedure and verify that the actions have taken 15 place. 16 Q Arc all of the emergency procedures and 17 abnormal procedures for Unit 2 or were thely all kept 18 in the Control Room prior to the Three Mile Island
~'
19 accident? 20 A Yes. 21 Q Is this copy in the Control Room a controlled 22 copy? ) 23 A ies, they were= controlled copies. r 1
.f
()) 24 Q Therefore, they were assured to be up to 25 date? I - . l
1 Mehler 138 2 A Yes. 3 Q Were all of the procedures applicable to 4 Unit 2 kept in the Unit 2 Control Room including, I C. 5 mean, maintenance procedures, surveillance procedures, 6 operating procedures? 7 A Maintenance procedures, to the best of my i 8 knowledge, were not kept in the Control Room. To the
.9 best of my knowledge, all operating procedures, all 10 emergency procedures, all refueling-type, procedures, 11 all surveillance-type procedures that were done by the 12 operating staff were kept in the Control Room .
13 Q Response-to-alarm procedures? 14 A Yes, they were kept in the-Control Room also. 15 Q What was your understanding of.the use 16 response-to-alarm procedures were to be put prior to 17 the Three Mile Island accident? How did'y.ou use 18 response-to-alarm procedures?
- 19 A Response-to-alarm procedures, what you would have
.20 on the procedure itself-would be the alarm, the causes.
.' 21 I think also it listed autofunctions that~could occur 22 from it, and then manual actions that you should respond
- 23 to' terminate the alarm,. investigating probable causes 24 why you got the alarm.
, 25 There areicertain alarms where you could w - e
1 l l 'T$ s
.y 1
Mehler 139
- f%
.\ j .
l 2 have 15 different items to give that one alarm,'ao s , , 3 there is no way for you, without leaving the. control . l 4 Room, going out and researching it, ,to determine what ! 5 gave that particular alarm. t,
, \
6 Q Are all alarms in thetsense that that term < 's 7 is used in response-to-alarm procedures annuncist d i,n ; , 8 the Unit 2 Control Room on the annunciator panels with 9 the little windows with the words written o:t them? . s t 10 A' Are you saying all alarms in' Uni,t ,2 are annunciated t 11 in the Control Room? '
\ %
7- 12 Q I am asking whether that is the c&se. 13 A No, that is not the case. ' 14 Q Are there more alarms than there are 15 annunciators? 16 A I may not follow your question. . 17 0 That may be because I am not' aure I 18 .undcsWt., a. l . 19 There is a procedure called, or a group of 20 procedures called, response-to-alarm procedure. 21 A Yes. 22 Q What is the glarm in that title? What is l 23 the meaning of the technical meaning? What do you ! (, n). 24 . understand the word " alarm" to mean? 25 ~A Alarm means when the particular light annunciates 3 .
- , e ,e, -
r x s
't.
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l l' l l 1 Mehler 140 i' : . 8 2 and comen on. 3 Q , Are there alarms that would be covered in
.4 the response-to-alarm procedures which do not have 5 annunciator windows? -
- 6 A' Yes.
s 7 Wait, could I hear the question again?
, s 8 Q Let me give you an example.
9 A We have computer alarms which do not annunciate, l 10 and probably are not covered by a particular alarm 11 response. There is no piece of paper written up on it. 12 Q For example, it is possible to have an ( \. .
'~# 13 alarm such as a reactor coolant drain tank overpressure 14 alarm which is listed as an alarm and has'a 15 set point at which it will alarm but which does not 16 light up one of those little windows in the Control 17 Room? ,
18 MR. GLASSMAN: Objection insofar as it asks 19 for a hypothetical answer.
\
20 Q Is there an overpressure alarm for the 21 reactor coolant drain tank? 22 A I believe so. . 23 - Q Do you know whether that alarm is annunciated? o ,
/ ,
-iss ) . s- 24 A I believe it is on the back panel.
25 Q There are annunciators on the back panel?
1 Mehler 141 (~% - Q' 2 A Yes, there is. 3 MR.. GLASSMAN: TMI-2. 4 Q We were talking of Unit 2, right? C. 5 A I hope so. - 2 6 Q I just want to make sure. I was asking 7 about Unit 2. I want to make sure the answers were on 8 Unit 2. 4 9 was an operator required to memorize 10 response-to-alarm procedures? 11 A No.
. 12 Q Is there a-requirement that response-to-alarm 13 procedures be reviewed upon the receipt of an alarm?
14 MR.' GLASSMAN . Is that question directed to 15 Mr. Mehler's present knowledge?
~
16 MR. BENEDICT: Yes. 17 A There were certain alarms that would come in during 18 .the normal course of the shift. The operator will know 19 why-it came in. It may have been because .lbA secured a 20 pump. Under these conditions, he would not review the 21 alarm. { 22 Q Is it your understanding that 23 there is a requirement,where the s.ituation is:that the f;
- i. ,/ ~ 24 . operator has not initiated the causelof the alarm,that 25 he consult the alarm procedure when an alarm is received?
I 1- Mahler 141-A O 2 A Do I understand you to say if we received an alarm
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3 and we did not understand why it came in that we should 4 consult the alarm response sheet? 5 (continued on next page) 6 7 8 9 t 10 . 11 13 . 4 14 . 15 t 16 17 .... 18 19 20 21 ; { . 22 -' 23
.V 24 25 1
-----..)
L 1 Mehler 142 (~\ .
\ -
2 Q Let's take that question, s 3 A Is that what you are asking? 4 Q Yes. 5 A In those cases, the operator would consult the 6 alarm response sheet for guidance on what to do. 7 Q Is it your understanding that that is 8 required of him? 9 A I could not say where it is written down that it 10 is a black and white thing that it is d4, finitely 11 required.
- 12 Q You don't know of any procedure, technical
^
\. ) ~
13 specification, limits and precautions or anything like 14 that which requires it? , 15 A Not-that I can recall. 16 Q The question that you parsed out from my 17 maybe inelegant question was if an operator receives 18 an alarm and he doesn't know what caused it, is he 19 required to consult the alarm and you answered that
' 20 question.
21 Broadening the question to the operator-22 receives an alarm which is not known to him to be 23 in direct response or in response to an action he has (O / 24 affirmatively:taken,-for example, he trips a pump and 25 then gets a pump off alarm, is he then required to t e, --- ,, e n- e , ~ , - -
2 1 Mehler 143 i- . v 2 examine the alarm procedure? 3 MR. GLASSMAN: The breadth of this question, 4 is it intended to include situations where the 5 Operator knows the cause of the alarm but did not 6 himself initiate the cause? 7 MR. BENEDICT: Yes, I think the differential 8 I am drawing is between in a situation where the 9 operator did not initiate or did not take an 10 action which initiated the alarm, and he r e c'e i v e s 11 an alarm, is he required to consult the alarm p_ 12 procedure whether or not he believes he (_) 13 understands the source of the alarm. 14 A I don't know of any requirement that says he has 15 to consult the alarm response procedure. 16 Q Is there a requirement that any time it is 17 determined that an emergency procedure l's, applicable, 18 that the written version of that procedure be consulted?
'19 A I don't know of any requirement that'it has to 20 be_ consulted, but to my knowledge, they always are .
1 21 consulted, because no one has a perfect memory. 22 Q When it is determined by a licensed employee 23 in the control room that an emergency procedure applies, s ((^J - 24 is there a requirement that he consult with the other-
- 25 licensed people in.the control room about his l
l
1 Mehler 144 2 determination? 3 A I am not aware of any requirement that he has to 4 consult other people in the control room but it has 5 always been the practice that he will consult his 6 foreman or the supervisor in there and also talk to 7 his other control room operator. 8 Q Is it your understanding that under the 9 procedures applicable on the day of the accident at 10 Three Mile . Island that a control room o'perator may 11 institute the immediate actions required by an emergency
- g 12 procedure without speaking with anyone else?*
s-13 MR. GLASSMAN: Is this asking for 14 Mr. Mehler's current understanding? 15 MR. BENEDICT: Absolutely. 16 MR. GLASSMAN: Of procedures that were 17 applicable on the day of the accident? 18 MR. BENEDICT: That's right. 19 MR. GLASSMAN: I object and d[r'ect him not
.20 to. answer. If you want to ask for his 21 understanding on the. day of the accident, that
{
.22 is fine, and if you want to ask his understanding 23 regarding procedures today, that is fine, but f)
(_) 24 I think it is-inappropriate for.Mr. Mehler now 25 to give his opinions on what may or may not have
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1 Mehler 145 2' been done on the day of the accident with regard s 3 to procedures then in effect. 4 MR. BENEDICT: I am only asking him to tell 5 me in a discovery deposition, a person who is 6 required to memorize procedures and who has been 7 learning procedures for the last ten years, what 8 his understanding is of the requirements within 9 Met Ed for the institutign of emergency procedures. 10 If it will make you happy, t, will start 11 with the question of today at Three Mile Island. 12 Q What is your understanding? Is it your O. 13 understanding that a control room operator may institute 14 the immediate actions: called for by an emergency without 15 consulting with anyone else, period? 16 A It is my understanding that he can. 17- Q It is not required that he consult with 18 his shift foreman or shift supervisor? 19 A There is no requirement for him to co'sult n with
~ 20 a shift foreman or shift supervisor under' emergency 21- conditions. He can respond according to the emergency 22 procedures. It would be nice, though, if he did consult 23 with his foreman.
O(,/ 24 Q Was it your understanding that that was 25 true on the day of the accident?
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k 1 Mehler 246 lO 2 MR. GLASSMAN: I object, but I will let him l 3 answer. 4 A Yes, that was my understanding on the day of the C 5 accident. - 6 - Q I show you what will be marked as B&W 7 237 which is hesded "Three Mile Island Nuclear Station, 8 Station Administrative Procedure 1001, Revision 18," 9 dated February 21, 1979, and I ask you whether you have 10 seen this procedure before? t 11 MR. GLASSMAN: I want to make sure that 12 the reporter has marked it. 13 (Multipage document entitled "Three Mile 14 Island Nuclear Station, Station Administrative 15 Procedure 1001, Revision 18" dated February 21, 16 1979 marked D&W Exhibit No. 237 f'or identification, 17 as of this date.) , 18 A I am aware of 1001 document control procedure. 19 I am not sure if'I.have read Revision 18 of it. 20 Q. Have you been required in the course of your employment at Met Ed to review a revision of
'( 21 22 Administrative Procedure 1001 which is marked as Exhibit 23 2377 (O-,): 24 A Revision 18?
25 .g
- A revision.. Any revision.
1 Mehler 147 0 A I don't know of any requirement that said I had 2 3 to. read any revision of Administrative Procedure 1001. 4 Q Focusing rather than whether you were 5 required to read it, but my.new question is whether you 6 have read any revision of 1 -- 7 A I have read 1001. 8 Q Do you recall when it was that you would 9 have had to do that? E 10 A No, I, don't recall. , 11 Q Do you recall whether it was before you 12 received any licenses? 13 A I don't recall that either. . 14 Q Is AP 1001, B&W Exhibit 237, a document 15 that you consult from time to time in the course of 16 your responsibilities? 17 A Periodically, it is consulted when making TCN's 18 and PCR's . 19 MR. GLASSMAN: I don't know whether the last 20 answer reflected Administrative Procedure 1001 or I believe it just relates to 1001. ( 21 Revision 18. 22 Q Do you know whether you have ever referred 23 to Revision 18 of this procedure? 24 A No, I' don't know. 25 Q Turning to what is marked as page 21.5 of
1 1 Mehler 148 Q V 2 B&W 237, there is a heading there which starts with 3 numeral 2 and says, " Emergency and Abnormal Procedures," l 4 and in subpart (a), " Emergency and abnormal procedures 1 l 1 5 shall be available in the control room and operators 6 should be familiar with the entire procedure." 7 I believe you testified earlier that the 8 emergency and abnormal procedures are available in the 9 control room. . I 10 A That's correct. , 11 Q They were available on March 28, 1979, to 12 your knowledge? 13 A To my knowledge, they were. 14 Q It says in sub (b), "The operator should be 15 able to carry out the immediate actions without referring 16 to the procedure." 17 We discussed that earlier. That part of 18 your training you were required to memorize, is 19 that right? 20 A That's correct. And sub (e), it says, "In the event an ( 21 Q l 22 emergency in the control room occurs, one man (or both
]
l 23 control room operators depending on the emergency) should O) (_ 24 carry out the manual actions while another person l 25 (generally shift foreman or other control room operator)
l' Mehler 149 h NJ 2 gets the procedure and reads the manual action aloud 3 to check the man on the console. The man with the 4 . procedure then reads the follow-up action aloud and 5 verifies that the console man has properly executed 6 the follow-up actions." 7 Prior to Three Mile Island, did you ever 8 have occasion to do that as a shift foreman or other 9 control room operator,to get the procedure and assist 10 someone in the administration? L 11 A I don't recall any incidents. 12 Q Do you recall ever having to do it on Unit 1 13 up until today? 14 A Yes. , 15 Q Did you do it prior to the Three Mile Island 16 or did this event occur prior to the Three Mile Island 17 accident? ... 18 A To the best of my knowledge, yes. 19 Q Do you recall which emergency p'rocedure it 20 was that was used? ; 21 A Yes. { 22 Q which was it? ; 23 A If I remenber correctly, it was 1202-8 which is b(j 24 control ~ rod drive malfunction. The number may not be 25 correct. m_.
I Mehler 350 ,- g km 2 Q But it was that name? 1 3 A Yes. We consulted that procedure. 4 Q It is an emergency procedure? C. 5 A Definitely, it is. 6 Q Turning to the next page.which is indicated 7 as 21.6, sub 4, " Response to Alarm Procedures," it 8 says, "In certain cases the alarms are due to instrument 9 malfunctions (nuisance alarms) as determined by their 10 repeated oc.currence while appropriate p'rameter a 11 indications suggest no valid reason for the alarm. This 12 alarm may be bypassed by alarm card removal b'ut must be 13 documented by at least a sticker indicating disposition 14 of the alarm." , 15 What is an alarm card? 16 A An alarm card -- I am trying to think of the 17 correct word -- solid state card. It is punched out, 18 and it slips in the slot, and that would be part of 19 the electrical network that would give you that alarm. 20 on pulling that card, you would no longer get that 21 alarm. 22 Q It is part of the electronics of the alarm 23 system? /9 kl 24' A Yes. 25 Q The effect of pulling or removing the
1 Mehler 151 O x>. . 2 alarm card is that alarm won't alarm regardless of the 3 indications? 4 A That's correct. 5 Q Were there any nuisance alarms at TMI 6 Unit 2 on the day -- were there any -- let's back up. 7 It uses the term here, "In certain cases 8 alarms are due to instrument malfunctions (nuisance 9 alarms) . " Using nuisance alarms as they use it here
. 10 to relate to alarms as a result of instfument malfunction 11 are you aware of any such alarms existing on the day of )
12 the Three Mile Island accident? 13 A Not that I was aware of. 14 Q Is it not true that at both Unit 1 and Unit 15 2 it is fairly prevalent to have nuisance alarms? 16 MR. GLASSMAN: Objection. I don't know 17 -what you mean by " fairly prevalent.", 18 Q Prior to the Three Mile Island accident, were 19 there not nuisance alarms at both Unit 1 and Unit 2? 20 MR. GLASSMAN: Whether that had ever 21 occurred? 22 Q By " nuisance alarms" in this case, I do not 23 mean an alarm which' occurs on a given day. I mean were
-O
(_) 24 there not a number of alarms whose alarm cards had L ( 25 been pulled in response to what was perceived as a V ( .
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1 Mehler 151-A O 2 nuisance alarm at both Unit 1 and Unit 27
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3 MR. GLASSMAN: At what time frame? 4 (Continued on the following page.)
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6 7 8-9 10 e .. 11 O 13 14 . 15 16 17 .. 18 19 20 l
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Mehler 152 b/1 1
-(~) \j 2 Q Prior to the Three Mile Island accident?
3 MR. GL AS S MAN : At any time prior to the 4 Three Mile Island accident? C 5 Q Was it not from the period of critical 6 operation through to the Three Mile Island accident 7 common for both Unit 1 and Unit 2 to have at least 8 one alarm card pulled? 9 MR. GLAS S MAN : Objection. I don't know E 10 what.you mean by " common." 11 Q Was it not the fact that there was no 12 day from criticality on Unit 1 until the accident (-s U 13 at Three Mile Island Unit 2 when the re wasn ' t at t 14 least one alarm card pulled at each of the two units? 15 MR. GL AS S MAN : If you know. 16 A I don't know. 17 Q As a control room operator and then as a 18 shift foreman and a shift supervisor, what were your 19 responsibilities with respect to alarms that had 20 the alarm card pulled? 21 MR. GLASSMAN: What time frame? ( 22 Q- Prior to the Three Mile Island accident. 23 A First you had to find out whether it was Os a nuisance alarm due to some type of instrument (__/ 24 25 failure and the operation of what would hamper the J
1
-1 Mehler 153
( ). 2 operation of the control room operator. At that point 3 you would pull the alarm card. There would be an l l 4 out-of-service sticker put on that alarm plus 5 documented in the out-of-service book, and the reason 6 why a work request was submitted to have the alarm 7 fixed, the cause of the alarm. 8 Q During the year prior to the Three Mile
'9 Island accident on March 28, 1979, you at least from 10 April' lst, 1978 until the accident on M' arch 28, 11 1979, you acted as a shift supervisor for the Unit 1 12 and Unit 27
-C)s - = 13 A Yes. 14 Q During that period on any given shift, 15 what was the average number of alarms that were in 16 the condition of having had their alarm card removed 17 and not yet returned to service? - 18 MR. GLASSMAN: Are you asking for this 19 witness' recollection of an average on a 20 particular shif t or the average over the entire 21 year? ( 22 Q I.mean at any given moment. 23 MR. GLASSMAN: You want to know if the n>. t 24 witness has a recollection of the average -- 25 Q I want to know as one of .
a 1 Mehler 154 1 As.
- 2. the six shift supervisors on this facility 3 from the time-that you served as such, what 4 it was, what to your recollection was the 5 average number of alarms that were in a condition 6 of having had their alarm card removed and, 7 therefore, be out of service.
8 MR. GLASSMAN: I object. First ask the
'9 witness whether he ever made a calculation 10 as to an average or ever had an average in 11 his mind at all.
12 MR. BENEDICT: If he says he hasn't, 13 if he gives me an average, I may ask him about 14 the background for it. 15 MR. GLASSMAN: I object to the form but 16 you can answer the question. 17 A If I understand it correctly, you are asking
.18-
. me on any given day how many alarm cards were pulled 19 on either unit.
20' Q We will start with Unit 2. i I (. 21 A .It would only be a guess. . but I would say on . 4 I 22- an average of anywhere - from three -to five. 23 Q , Was the. number larger or smaller 'in your . 4
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=\' 24 ~ estimation for UnitL1-or.the same?
A'
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, 25 I would say on any.given day, Unit 1 would have
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1 Mehler 155 2 anywhere from three to five. 3 Q I may have stopped you before you 4 finally finished answering the question when I asked 5 you what were the responsibilities with respect to 6 situations where the alarm card had been pulled, you 7 indicated that there was certain documentation 8 necessary. 9 Were you not also required then to monitor 10 the parameters that related to that ala'rm to determine 11 the continued appropriate levels?
. 12 MR. GLASSMAN Appropriate levels'of what?
13 Q of whatever the parameter was that would 14 have caused the alarm. . 15 A Whenever you pulled an alarm card, you would , 16 determine prior to that that the cause of the alarm 17 was a malfunction of some sort of transmitter or 18 something giving the alarm. You can't monitor that 19 particular transmitter any more because its output 20 was erroneous. You would. monitor the other -- if there was other instrumentation that would let you ( 21 22 monitor that particular parameter, you would use them. 23 Q what is your understanding then or.what 24 was your understanding when you reviewed this document 25 of the last sentence in segment 4, sub B, which'
1 Mehler 156 O- . 2 reads, " Operating parameters associated with the alarm 3 shall be survelled with increased frequency or other 4 action taken until the alarm is again placed back in 5 service." 6 MR. GLAS S MAN : I object to your asking 7 the witness what his understanding now is of 8 this document unless it is first established 9 that he saw this particular revision or knew 10 about these particular procedures $ 11 MR. BENEDICT: I didn't ask him what his 12 understanding was now. I asked him when he 13 reviewed the document what his understanding 14 was. . 15 MR. GLASSMAN: I don't think ,there has 16 been any testimony as to his earlier review of 17 this document. I think he testified -- 18 MR. BENEDICT: You direct him not to 19 answer? 20 MR. GLASSMAN: I am just objecting. If the witness can answer it, fine. { 21 22 MR. BENEDICT: If you will just let me 23 take my discovery and assert your objection to (-~ , b . 24 form, we can-proceed. 25 Q Did you have an understanding of the
l l 1 Mehler 157 i (~ w 2 meaning of that sentence? 3 A You are referring to -- 4 Q The sentence that starts operating (1 5 parameters associated with this alarm. 6 MR. GLASSMAN: The question is directed 7 to your understanding when you reviewed this 8 document sometime prior to today. 9 A It is my understanding, yes, that we would monitor 10 at an increased frequency. i 11 Q Turning to the page marked 68.0 and 12 looking at 4.3 headed " Shift Supervisor and Shift O 13 Foreman," it reads, " Insure all Operations Department 14 personnel in his operating section are up to date on 15 revision / amendments in the Revision Review Book." 16 What is the Revision Review Book? 17 A ~The Revision Review Book was a book kept -- ,
, 1 18 which unit are we referring to?
19 Q Unit 2. 20 A Both units kept them. Revision Review Book is revisions that are put in the Revision Review ( 21 22 . Book as deemed necessary to be reviewed by the 23 operating personnel, but not all of' them were put II (3 l k_/ 24 in. There were only the ones that the supervisor of l 25 operations? deemed necessary we'should be' familiar i k
I Mehler 158 .f t 2 with. 3 Q You say " revisions." You mean revisions 4 of procedures? 5 A Yes. In other words , we may not have every 6 revision put in the Revision Review Book. 7 Q Who on the day of the accident on 8 Three Mile Island was the supervisor of operations? 9 Is there only one supervisor of operations? 10 A There was a supervisor of operati'ons on Unit 1. 11 There was a supervisor of operations on Unit 2 on the (~g 12 day of the accident. V 13 Q Who was it for Unit 2 on the day of the 14 accident? , 15 A He.was in Lynchburg, Virginia. 16 Q Jim Floyd? 17 A Yes. - 18 Q Is the title supervisor of operations. 19 one'that has only one holder for. Unit 27 There are 20 six shift supervisors? A That's correct. ( 21-22- -Q It is therefore a title 23 where more than_one person occupies that position O
^w_ 24 depending upon the' shift. RIs that true of'the 25 supervisor of operations?
k
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1 Mehler 159 O .N) . 2 A There is only one person who holds the title 3 on Unit 2 as supervisor of operations. There was one 4 person on Unit 1 that holds the title of supervisor 5 of operations at the time of the accident. 6 Q Who are Operations Department personnel -- 7 who were the people -- let's take it today by title. 8 Today, who are the people who are 9 Operations Department personnel in your operating 10 section? Does that include all AO's an$d CRO's? 11 A The AO's are not required to review the Revision rx 12 Review Book. Just licensed personnel. 13 Q So the Operations Department personnel 14 in your operating section today would be you, your 15 shift foreman, and the control room operators on your 6 16 shift? 17 A Right. - 18 Q During the period-after you became a shift 19 supervisor on April 1st, 1978 through the day of the 20 accident, the next year on March 28th, what actions did you take to insure that your personnel ( 21 ,
, 22 .w ere up to date on the amendments in the. Revision 23 Review Book? 'f%
I ,) ' 24 A There was a requirement while they were on shift l l I
1 Mehler 160 2 new revision that they reviewed it. It says that 3 they are just familiar that there is a revision. 4 They are not held verbatim of what the revision was. 5 Q You did not give them quizzes on it? 6 A No. 7 Q Oral or written? 8 -A No. 9 Q The only requirement you understood was L 10 to require you to insure that people we're signing'the 11 sign-off sheets? 12 A Yes, and they were familiar that there was a O. 13 revision, because the revision would only show the 14 particular page it was revised. So just by looking at 15 one page you could not get the full context.
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16 Q But there was no -- you did not understand 4 17 this to require you to make an effort to test their 18 understanding of what the revision was? 19 A I did not read any. requirement like that into 20 this.
.21 (Continued on following page.)
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a(:). 2 Q Turning to page 21.2, the section headed 1 3.8. 3, procedural deviation limitations , it reads, 3 4
" Deviations from written procedures may not be made
( 5 except in emergencies. In emergency operations 6 personnel are authorized to depart from approved 7 procedures where necessary to prevent injury to 8 ' personnel including the public or damage to the
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9 facility." 10 Was it your understanding p'rior to 11 the Three Mile Island accident that you as a licensed 12 operator were entitled to deviate from emerge *ncy {-)} y t 13 procedures in emergency situations? 14 A It was always my understanding that I could
- 15 deviate from procedures to protect personnel, major .
16 pieces of equipment and the general public at any 17 _ time. .
- L18 Q Did-you say you could deviate from any 19 . procedure?.
20 A At any time I could deviate from the procedure 21 to protect personnel, major pieces of the equipment (l 22 or the public in general. 23 - Q .And that' includes emergency procedures?- ()
\j A That would-include emergency procedures.
, JM 25 Q Would that include technica1' specifications?
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1 Mehler 162 2' A I cannot -- I could only answer that question 3 for myself. 4 Q What was your view prior to the accident 5 at Three Mile Island? 6 MR. GLASSMAN: You want the witness's 7 view or opinion or his understanding? 8 MR. BENEDICT: He said he could only l 9 answer it for himself, so let's find out what i 10 that is. . 11 MR. GLASSMAN: I do not want the witness
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3 12 to speculate. 13 MR. BENEDICT: I am asking what your 14 recollection is of your understanding about f
- 15 whether or not you were permitted to deviate 16 from technical specifications in order to i
17 protect personnel, the public, or major pieces
-18 of equipment.
19 A I don't recall any official stance on 'eviating d l ; I l 20 from the technical specifications that was giving ( 21 guidance whether we could or couldn't. 22 Q You indicated earlier though you had a 23 view prior to the accident on that subject. What was k/ 24 that view? j i 25 MR. GLASSMAN: .I am not sure that was the
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l 1 l 1 1 Mehler 363 (J h 2 witness's testimony. I think he just testified 3 his understanding was with regard to emergency 4 procedures, but I do not know that there was C 5 any testimony with regard to technical 6 specifications. 7' MR. BENEDICT: He answered my question 8 that he could only give me his personal view. 9 You may not have heard that, but he said it, t 10 Did you have, prior to the Three-Mile Q 11 Island accident, a personal view as to the propriety 12 of violating technical specifications in order to 13 preserve or protect the public, personnel, or major 14 pieces of equipment? - 15 MR. GLASSMAN: I object to the question 16 as to Mr. Mehler's personal view. If he had 17 an understanding of what he could or could not 18 do, that is fine, but it is inappropriate to 19 ask him his personal view or belief of any sort. 20 MR. BENEDICT: I stand on the question and-(- 21 press'it. 22 MR. GLASSMAN: _I object, but he can answer. 23 A I would think each-incident would determine O
- - 24 what priority I.would put'on. violating technical-25 specification.
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1
. 4 1 Mehler 164 Q Does that mean that you were not of the 2-3 Pi nion that you could, under those circumstances, violate or exceed technical specifications?
4 (: 5 A I am of the opinion that you are not supposed 6 to violate technical specifications, knowingly violate 7 them. 8 Q It was your understanding even if yow as a 9 licensed operator,were of the opinion that a violation
- i .
10 would allow.you to protect personnel, th.e public or 11 major pieces of equipment? 12 MR. GLASSMAN: -This question ask's for
.%,f')T 13 an answer to a hypothetical question. I 14 object to it, but you can answer it.
15 (continued on next page) 16 17' 18
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l t I Mehler 165 2 Q I ask for your view at the time, and I 3 don't want you to speculate. 4 A I have to know which incident, what 5 technical specification I was violating and what would 6 be the outcome of violating it, and, very truthfully, 7 if the outcome was not serious, to save a person's 8 life, I would do it. 9 (Recess taken.) . 10 BY MR.* BENEDICT: , 11 Q Back on page 21.2 at the section marked 12 3.8.1,"3.8.1 Discussion," " Procedure Usage," it'says, 13 "Some procedures should be memorized; some merely 14 followed without signing off completion of steps." 15 What procedures was it your understanding 16 prior to the accident at Three Mile Island you were 17 expected to memorize? . 18 A The emergency and abnormal type procedures. 19 Q When you say " emergency type"and " abnormal 20 type," were you including anything other than p ro cedure s that were entitled'" Emergency Procedure" ( 21 22 o r -- J , ns 23 A No, I wasn't.- Just emergency and abnormal were 4 24 the only ones and,only the symptoms and t e immediate ,- 25 manual: actions. . x
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! I Mehler 166 l O
2 Q Turning to page 28.0, it says at the 3 top, "The following is a recommended format 4 for emergency and abnormal procedures." 5 As I understand the response to my last 6 question correctly, you understood that you were 7 required to memorize everything which
)) 8' would appear in the format under the word " Symptoms" 9 here and everything that would appear under the 10 "Immediate Action"?
11 A That's correct. r'4 12 Q Does that include the automatic (. ' i 13 immediate action? x i '\ , 14 A Yes. . i 15 Q You were expected to memorize that? 16 A You were expected to know that and verified they M
., u. s 17 occurred.
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18 2 Q The follow up action you were not required s '# . 19 to memorizt27 ' sy 20 A No. 3, Just to button up, that was true for ( . 11 s Q q " 22 both emergency and abnormal' procedures?
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23 A 'Yes.
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4
> 24- Q. speaking earlier of technical specifications *33 ) i, ' 25 and the sque' s tion of your understanding of when and.if m:]' ~
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l 1 l 1 Mehler 167 l V 2 they could be violated, what understanding did you have 3 prior to the Three Mile Island accident as to when 4 limits and precautions could be violated? Under what 5 circumstances? 6 A I don't recall any circumstances that you 7 would violate limits and precautions. 8 Q It was not your understanding with 9 respect to limits and precautions there was -- strike 10 that. - 11 Referring back to what we talked about 12 earlier on page 21.2 where it says, " Deviations from 13 written procedures may not be made except for 14 emergencies. In emergencies, operations personnel 15 are authorized to depart from approved procedures 16 where necessary to prevent inj ury to personnel, including 17 public, or damage to the facility." 18 Prior to the Three Mile Island accident, 19 you did not understand this departure from approved 20 procedures to include limits and precautions? (_ 21 A I never gave it any thought prior to the accident. 22 Q Do you have or what was your understanding 23 prior to the Three Mile Island accident as to when p_ ' ( .I 4 \~' ' 24 you were required to comply with the limitations 25 imposed by the. technical specifications?
Mehler 268 1 2 A At all times. 3 Q Is it not true that the technical 4 ~ specifications indicate certain modes of operation for C. 5 the plant? - 6 A. That's correct.- 7 Q And those modes are numbered 1 through 5,
,) 8 is that correct?
9 A If I recall correctly, on, Unit 2, it is modes 1 through 5. e 10 , 11 Q Could you tell me what those modes are? 12 A At the time? OJ Yes. 13 Q 14 A 'No. , 15 Q Is it your understanding that if you' are 16 outside of modes 1 through 5, the technical 17 specifications do not apply? , 18 A Tt is my understanding as'each techn'ical
.- 19 . specification written for standard tech spec's' which 20 Unit 2 operated under prior to March 28th, 1979, that 4
to go from mode 5 to mode 4 you had to meet'the ( 21 22- requirements of technical specifications of mode 4 , 23 before you could'go into it. Upon going.into mode 4, 24 .to go to mode.3, you had to meet 3's requirements. 25 Also, you could come down in the modes without meeting t
. _ . _ _.__.mm__ _ _ _ _ . _ . _ _ _ _ . _ . . . _ . = . _ _ _
- ,: 1 Mehler ,
169 2 the requirements in emergency type conditions. 3 Q You could step down from 1 to 2 to 3 and
*4 on without meeting the tech specification?
C. 5 A In emergency conditions. 6 But you could never knowingly go up, 7 increase your mode, and when I say " increase," it is
) 8 going backwarde, 5, 4, 3, 2, 1.
9 Q Do you recall whether mode 1 for Unit 2 10 is power operation? - 11 A I believe it is. I would not want to say
/ 12 definitely it is any more because I have not looked 13 at the tech spec.
14 Q When you were speaking of moving from a 15 mode farther down the scale, in other words, from 16 5 to 4 or from 4 to 3, you indicated that you were 17 required to abide by the technical specifi' cations,'is 18 that my understanding? 19 A You had to meet the requirement of the 20 technical specifications for mode 3 before you could (, 21 leave mode 4 to get into 3. 22 Q In the movement from mode 5 up to mode 1, 23 is.it your understanding that is essentially power
\
(O' 24 escalation on the reactor with mode 5 being the most 25 stable or lowest output level of the reactor and i -- . . . . . . . .
l Mehler 170 1 V 2 mode 1 being the power level of the reactor? 3 A If my memory serves me correct, 4 mode 5 would be cold shutdown and mode 1 would be 5 Power operation, so, yes, that would be escalating 6 up in power. Q With respect to escalating downward, 7 0 8 deescalating, you said, as I understood it, you can g go from mode 1 to mode 2 without meeting the technical 10 specification requirements of mode 2 prior to the 11 departure in emergency situations, is that correct? 12 A Yes. D Q Prior to the Three Mile Island accident, 13 , 14 did you understand that accident conditions were 15 not within the defined modes of the technical 4 16 specifications? 17 A Would you define " accident conditions" to me? 18 Q Is it your understanding that the plant is 19 capable of being in a state other than one of the five
.20 modes listed in the Three Mile Island Unit 2 tech specs?
MR.-GLASSMAN: You are asking for his ( 21 understanding today? 22 MR. BENEDICT: We will start with that. 23 O \- A Today, Unit 2 has, to my knowledge, as I recall,
- (_j' 24 25 its own special. tech-specs written up. I think 4
7 1 Mahler 1.71
.()'
2 they refer to it as mode 6 which is special 3 conditions based on the conditions of the plant. 4 Q Was it your understanding prior to the 5 accident at Three Mile Island that the plant -- let 6 me back up. 7 Was it your understanding prior to the 8 accident at Three Mile Island that the five modes i) 9 listed in the tech specs for Unit 2 encompassed the 10 universe of conditions the reactor could ever be in? ! g 11 A To my knowledge, it encompassed the 12 conditions the reactor could ever be in, as long as l I 13 we had fuel in the core. , 14 (Time noted: 5:13 p.m.) 15 ' BRIAN A. MEHLER 16 17 subscribed and sworn to
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18 before me this day 19 - of , 1981. 20 21 (; 22 23 24 D)
-- (V 25
^
8 1 172 CEEIIEIEA1E
! 3 STATE OF NEW YORK )
- ss.:
- 4 COUNTY OF NEW YORK )
,/-
i 5 f -( I 6 JOSEPH R. DANYO
, I, , a
! 7 Notary Public within and for the State of New York, l 8 do hereby certify that the foregoing deposition 9 of BRIAN A. MEHLER was taken before
. ,! 10 me o July 28, 1981 ;
l 11 That the said witness,was duly sworn 12 before the commencement of his testimony and - 13 that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with.any of the parties herein nor l 17 interested directly or indirectly in the matter in
, 18 controversy, nor am I in the employ of any of the 19 i counsel. - .
. 20 IN WITNESS WHEREOF, I have hereunto set p 21 my hand this b day of 'b U 1983,
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