ML20072H942
| ML20072H942 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/25/1982 |
| From: | Lanese L GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-03, TASK-06, TASK-07, TASK-3, TASK-6, TASK-7, TASK-GB NUDOCS 8306290827 | |
| Download: ML20072H942 (174) | |
Text
___
129 (3,
U UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
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GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs,
-against-80 CIV. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
a I
Defendants.
x C J.
Continued deposition of General Public Utilities Nuclear Corporation, by LOUIS C.
LANESE, taken by defendants pursuant to adjournment, at the offices of Davis Polk &
Wardwell, Esqs., One Chase Manhattan Plaza, l
l New York, New York, on Thursday, March 25, 1982, at 10:15 o' clock in the forenoon, before Joseph R.
Danyo, a Notary Public within and for the State of New York.
DOYLE REPORTING. INC.
x )
CERTIFIED STENoTYPE REPORTERS 369 LexlNGTON AVENur WALTER SHAPIRO, C.S.R.
New Yong. N.Y.
10017 CHARLES SH APIRO. C.S.R.
TELEPNo Ns 212 - 867 8220 8306290827 820325 PDR ADOCK 05000289 T
pm
1 230 1
2 Appearance s:
g-N) 3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York By:
STEVEN J.
GLASSMAN, ESQ.
6
-and-JOHN EICKEMEYER, ESQ.,
7 of Counsel 8
DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for Defendants One Chase Manhattan Plaza 10 New York, New York 11 By:
RODMAN W.
BENEDICT, ESQ.,
of Counsel 12 13 Also Present:
("'\\
~'
14 NINA RUFFINI 15 JULIE JOHNSON 16 17 18 19 LOUI S C.
LANES E,
having been 20 pr.viousl'y duly sworn, resumed and testified 21 further as follows:
9 22 MR. BENEDICT:
Do you have those documents, 23 the originals of the two procedures that we 24 discussed yesterday, or at least the LOCA p)
(
25 procedure?
1 Lcnscs 333 2
MR. GLASSMAN:
We most certainly do.
As we
\\-)
advised you yesterday, we would attempt to be as 3
4 cooperative as possible in producing immediately 5
the original version of the documents you gg*
6 requested.
In particular, you had noted 7
yesterday that the document produced as and 8
marked as Nos. WO 29131 through '155, which had 9
been earlier produced, seemed to contain some 10 highlighting which in the copy produced earlier 11 to you was unreadable.
We have looked for that, 12 and we have that here for your inspection.
13 In addition, Mr. Lanese did testify that r~T k._
14 there was an additional procedure.
You had not 15 made clear yesterday whether you absolutely wanted 16 to see the original of that or not, but regardless, 17 we have the original of that as well, and that 18 is the document which had been produced and 19 marked as WO 29115 to WO 29130.
They are here 20 for your inspection, and Mr. Lanese is of course 21 here to cooperate and answer questions.
(Ik-22 MR. BENEDICT:
Thank you.
23 (Original of document bearing production 24 Nos. WO 29131 through WO 29155 was marked B&W
(~~')
25 Exhibit 605 for identification, as of this date.)
QJ l
1 Lenoco 332 2
(Origina'l of document bearing production
/~T Nos. WO 29115 through WO 29130 was marked B&W 3
4 Exhibit 606 for identification, as of this date.)
ggg
- 5 EXAMINATION (continued) 6 BY MR. BENEDICT:
7 Q
You understand that your testimony continues 8
to be under oath?
9 A
Yes, I do.
10 Q
I would like to show you two documents 11 which have been marked for identification as B&W Exhibits 12 605 and 606.
605 appears to be a copy of a Three Mile 13 Island Nuclear Station Unit 2 abnormal procedure No.
b 14 2203-2.3 steam supply system rupture, with a revision 15 date of 9/29/77; and B&W Exhibit 606 appears to be a 16 Three Mile Island Nuclear Station Unit 2 emergency 17 Procedure numbered 2202-1.3, with a revision date of 18 3/1/78.
19 Have you ever seen these documents before?
20 A
Yes, I have.
21 Q
could you identify them for me, please, or 9
22 each one?
23 A
605 is the steam line rupture procedure 24 for TMI-2, and 606 is the loss of coolant procedure
[}
25 for TMI-2.
r
1 Lancco 133
,m i
'i 2
Q When did you first see these procedures?
%,/
3 A
April 1978.
4 Q
Why did these procedures come to your ll) 5 attention?
6 MR. GLASSMAN:
Objection as to form.
Are 7
you asking whether Mr. Lanese knows the reason j
8 why someone showed it to him?
Are you asking 9
the purpose for which he looked at them?
I am 10 not sure what the question is.
11 MR. BENEDICT:
I am asking both those things.
1 12 Q
Why is it that those procedures came to your
(~]
13 attention in April '787
\\_/
14 A
They were sent to me as a follow-up to a 15 conversation that Jim Seelinger and I had in which he 16 requested me to review these procedures to determine 17 if FSAR analyses had been incorporated appropriately 18 to the procedures.
19 Q
Did you call Mr. Seelinger or did he call 20 you?
21 A
Neither.
9 22 Q
Was it a face-to-face conversation?
23 A
As I recall, it was.
24 Q
Did he initiate the conversation?
_.s
(
)
8 25 A
I don't remember.
1 Lenoco 134
(~)
2 Q
Did Mr. Seelinger give you an assignment
%.)
3 with respect to these procedures?
4 A
No.
5 Q
Did he ask that you review them?
lll 6
A Yes.
7 0
You said that, as I understood it, your 8
task was to review them to see if what you called 9
FSAR analyses were properly incorporated.
Is that a 10 fair characterization?
11 A
Yes, except it was more of a request than 12 a task.
f-13 Q
What is an FSAR analysis?
S.
N..,i 14 A
In the broadest sense, it is an analysis 15 that appears in the final safety analysis report.
16 Q
Is that the sense you are using the term?
]7 A
Yes.
18 Q
During the spring of 1978, was it unusual 19 for you to receive requests from Met Ed employees?
20 MR. GLASSMAM:
Objection.
I don't know 21 what you mean by unusual.
Would you like to 9
22 find out how often this occurred?
23 MR. BENEDICT:
I will press my question.
24 I think the word " unusual" is understandable.
\\
/
25 A
I did not receive requests from Met Ed
1 Lnnsco 335 2
employees very frequently.
l 3
Q Did you know Mr. seelinger prior to this f
4 contact?
lll 5
A Yes, I had met him before.
l 6
Q Had you met him professionally or in the 7
course of your job as opposed to just socially?
8 A
I had only met him professionally.
9 Q
Did you at that time have an understanding 10 as to what Mr. seelinger's position was?
11 A
I believe he was responsible for training 12 at that time.
13 Q
Training of operators?
O 14 A
Shift operators.
15 Q
Mr. Seelinger was an employee of Met Ed, 16 as you recall?
17 A
That's right.
18 Q
You said that you received these procedures 19 as a result of a conversation you had with Mr. Seelinger.
20 You did not, therefore, receive the procedures from him?
21 A
Not directly, no.
O 22 Q
Did he specify which procedures he 23 requested that you review?
24 A
We agreed which procedures I would look at.
25 Q
Did you agree you would look only at the
1 Lanese 136 i
\\#
2 two procedures that are now marked as B&W Exhibit 605 3
and 6067 4
A That's right, the steam break and lll 5
loss of coolant procedures.
6 Q
Did you agree you would only look at Unit 7
2 procedures?
8 A
Yes.
Those two Unit 2 procedures.
9 Q
From whom did you receive the procedures?
10 A
They were transmitted by Mark Bezilla 11 of the Met Ed staff.
12 Q
Who is Mr. Bezilla?
O-)
13 A
He served an administrative function at 14 Met Ed at that time.
15 Q
Did Mr. Seelinger tell you to get in touch 16 with Mr. Bezilla?
17 A
No, Mr. Seelinger requested Mr. Bezilla 18 to provide me with the procedures.
19 Q
You did not get in touch with Mr. Bezilla?
20 A
No.
21 Q
Did you discuss with Mr. Bezilla this 22 request of Mr. Seelinger's?
23 A
Not that I recall.
g}
24 Q
What more can you recall, if anything.
25 about your conversation with Mr. Seelinger beyond him
1 Lanese 137
((,)
2 requesting that you review these procedures to 3
ascertain whether FSAR analyses had been appropriately 4
incorporated?
lll 5
A He was interested in my opinion.
6 Q
Do you know why he picked you?
7 A
Because I had been involved in the steam 8
line break analysis and to some extent I had familiarity 9
with the LOCA analysis.
10 Q
By the steam line break analysis and the 11 LOCA analysis, are you referring to the analyses done 12 for inclusion in the FSAR for Unit 27
()
13 A
Yes.
14 Q
Did Mr. Seelinger tell you how to 15 communicate your comments, if any, to him?
16 A
No, we didn't discuss that.
17 Q
In order to carry out Mr. Seelinger's 18 request, was it necessary for you to read the whole 19 procedure of each of these procedures?
l 20 A
Yes, it was.
21 Q
Looking at the first page of B&W Exhibit 22 605, which is a memo from Mr. Bezilla, the memo 23 is dated April 7, 1978.
Does that comport with your 24 rS recollection of when you received these documents?
/
25 A
Yes, it does.
y.
_____._._______a
1 Lanese 138
";)
i,
)
2 Q
With whom else or with who else did you 3
work on this request at GPU?
4 A
I reviewed the procedures myself.
lll 5
Q Did you discuss your review or your 6
comments with anyone?
7 A
Yes, I did.
8 Q
With whom did you discuss them?
9 A
Mr. Broughton.
10 Q
Did you discuss them with anyone other than 11 Mr. Broughton?
12 A
No.
()*
13 Q
Mr. Broughton was your superior at that s_-
14 time; is that correct?
15 A
Yes.
16 Q
But he was not your immediate superior?
17 A
No, he was my immediate superior at that 18 time.
He was the safety and, licensing agent.
19 Q
Do you recall about how long you spent 20 on your review of these procedures?
21 A
A half hour to 45 minutes on each.
22 Q
Do you recall when relative to the April 23 7th date we discussed earlier that you did the review?
f3 24 A
Shortly thereafter.
)
25 Q
Would you look at B&W Exhibit 606, which is
1 LEnoco 139 2
the LOCA procedure, and'could you page through that
,ej
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)
m 3
document and tell me if you recognize your handwriting 4
anywhere on it?
lll 5
A On page 5 I made some notes.
/
6 Q
That is 5.07 7
A 5.0, yes.
8 Q
Is there anyone else's handwriting on that 9
page?
10 A
Yes, Mr. Broughton also made some comments.
11 Q
Could you read your comments?
12 A
At step 3.2.10, I had a comment, "could 13 be pumping water out the break.
Should verify the f-(
)
\\.s' 14 flow path is intact."
15 Q
Is that the only comment you made on the 16 page?
17 A
No.
Further below under step 3.2.11, 18 I made the comment, "only use mode 2 and mode 3."
19 Q
There are two other areas where there is 20 handwriting.
One has been scratched out.
Is that 21 your handwriting that has been scratched out?
O 22 A
No, it is not.
23 Q
Do you recognize the handwriting?
24 A
That is Mr. Broughton's handwriting.
k,,)
25 Q
The handwriting next or to the immediate
1 Lrnosa 140 2
left of the slash which seems to read to me, "O.K.
,, T 3
assuming LP is greater than 0 inches," is that a 4
fair characterization of the abbreviations?
~
lll 5
A Yes, it is.
6 Q
Is that Mr. Broughton's handwriting?
7 A
Yes, it is.
8 Q
Was that his response to your comment?
9 A
Yes, it was.
10 Q
Are there other places on these pages 11 where you see handwriting of yours?
12 A
At page 11.0, I have also made a comment.
13 Q
It reads?
)
{\\/
14 A
"Not required for this mode since have 15 two LPI's."
16 Q
Who wrote the note immediately below that?
17 A
Mr. Broughton.
18 Q
Is that an arrow pointing from his remark 19 to yours?
20 A
Yes, it is.
21 Q
Could you read Mr. Broughton's remark?
22 A
"But LPI's are not putting water into l
23 system."
l 24 Q
Is there,anywhere else on this document l
s I[
25 that you find handwriting?
i 4
1 L0noco 343
(^')
2 A
of mine?
\\._/
3 Q
Yes.
4 A
On page 12.0, at steps.).6.3.9 and 3.8.4, 5
I have written, "FSAR has order in beverse."
lll i
6 Q
Is the comment below your comment written s
~
7 in Mr. Broughton's handwriting?
\\
x s
[
8 A
Yes, it is.
x s
9 Q
could you read thdt for me, please?
10 A
"NPSH has not been' verified in this rode.
i s
11 Q
The numerals in ths lower part of'the
+
12 page where it is handwritten,"3.8.4.?;" is that your 13 handwriting?
~)
\\J 14 A
No, it is not.
t's-s s 15 Q
Is it Mr. uroughton's?
16 A
I don't know..
I
\\
17 Q
Is it correct that the original of B&W's 18 605 and 606 came out of your files?
- s-s 19 A
The original marked-up copy come out of' 20 my files, yes.
21 Q
Do you recall providing that copy to apyone
't s
22 other than -- or making it available to anyone other 23 than Mr. Broughton?
s 24 A
No, I do not.
(s i'
)
'/
25 Q
Is there any other place on this doedment, i-N,s
+
[
A
s 1
Lanese 142 jA
(_,)
.2 B&W 606, where you see your handwriting?
I A
On Page 14.0.
3 4
Q You made the markings?
i -
lll 5
A I made the markings under step 3.11.
\\
6 Q
Is there anywhere else you see anything?
\\
7 A
No.
8 MR. GLASSMAN:
May I go off the record and
+
1,
.+
~~.
9 speak with counsel, opposing counsel.
_y 1(
(Discussion off the record.)
il Q
Could you look at page 2.0.
I would like
^
12 to show you for a moment the original of 2.0, and I
/~'$
(_)
13 would'like you to see, or is it correct that the text s
14 which appears to be blacked out on the exhibit is in 15 fact marked over with a yellow highlighter?
'16 A'
Yes, it is.
g i-
~J s 17 Q
Could you read the text under the yellow
.
- 18 highlighter, please?
19 A
"If for any reason the operator cannot s
20 maintain makeup tank and pressurizer levels above
~
th'eir respective low level alarm setpoints, ' trip' 21 h
.g 3.22 the reactor, **mitiate' safety injection, manually I
y' s
23 ppen (push-buttons on panel 3), and then 'close' s
24 14U-V12. "
i C;
(_,/ !
'\\g 1
25 Q
Did you add the yellow highlighter to that 4
s s
page?
1 Lenoco 143
(~ N 2
A I believe so.
V 3
Q Do you recall at this point why you 4
highlighted that?
lll 5
A No, I do not.
6 Q
Do you recall whether you discussed this 7
highlighted section with Mr. Broughton?
8 A
No, I did not.
9 Q
You don't recall having any comment 10 with respect to the contents of this highlighted area?
11 A
No.
I believe I highlighted it recently.
12 Q
Turning to page 4.0, there is some 13
(-}
underscoring appearing on the page.
Did you make that LJ 14 underscoring?
15 A
I don't recall.
16 Q
You don't recall whether it is yours 17 or someone else's?
18 A
No, I do not.
19 Q
There are below 3.2.8.2, and also below 20 3.2.8.3, there are two entries, each of which reads 21 "O.K.,"
underscored.
Did you add those?
22 A
No, I didn't.
23 Q
Is that your handwriting?
24 A
No, it is not.
.s
( __)
- 25 Q
Do you recognize the handwriting?
a. :: ~
~~., :...;,w
- u, > : s. ; _ -:.,
a e u-v:., v, : :.;
- -+, 0.. ;r ', x, /,.
- %.
....re
. - % ;.~.t,- -
1 Lanese 144 2
A I believe it is Mr. Broughton's.
3 Q
Turning to page 5.0, again there are 4
passages which have been highlighted in yellow.
Could g
5 you read the passages which have been highligated?
6 A
"When MU-V" 7
Q Excuse me.
You are reading immediately 8
to the right of 3.2.10; is that correct?
9 A
That's correct.
"When MU-V16A/B/C/D 10 (Err flew valvesT are closed,. stop the high 11 pressure injection pumps and close DH-V7A and 7B 12 from the LPI pump discharge.
Injection flow path is 13 now as follows:
spill coolant to RB sump, RB sump 14 to LPI pumps, LPI pumps to RCS by DH-V4A/B."
15 Q
Reading down after 3.2.11, there is some 16 highlighting.
Could you read the sentence which 17 appears to be highlighted?
18 A
"Within about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, establish a long-19 term cooling circulation mode as described in 20 2104-1.3 and listed below."
21 Q
Did you highlight those passages?
22 A
I believe so.
23 Q
Turning to page 9.0, again at the top 24 of the page there appears to be some highlighting.
O 25 Could you read that?
1 Lnnoco 145 2
A
" Caution:
If normal power is lost while
[ w]
3 operating in the injection mode from the BWST, RB
)
4 isolation and cooling must be manually initiated, ggg" 5
when either the BUS 2-1E or 2-2E under-voltage alarm 6
is received to insure proper diesel generator load 7
sequencing."
8 Q
Did you put that highlighting on this page?
9 A
I don't recall.
10 Q
Then your answer with respect to this page 11 is different than the other ones where you thought 12 it was you that had done its is that correct?
13 A
That's correct.
[})
14 Q
Under 3.5, there is a subnumeral 3, and 15 there seems to be some handwriting near that which I 16 believe reads 1500 with a line and a circle around the 17 typewritten 1400.
Is that your writing?
18 A
No, it is not.
19 Q
Do you recognize the writing?
20 A
Yes, I do.
21 Q
Whose writing is it?
22 A
Mr. Broughton's.
23 Q
Would you turn for a moment to B&W 605.
24 I will hand you the original which I hadn't had a
,n
(
)
25 chance to review prior to this morning.
Am I correct v
1 Lnnoco 146 2
in my view that there is no marginal notation or
,I)
\\'
3 underscoring in that draft?
4 A
That's correct.
)*
5 Q
DJ you recall whether you had any comments 6
with respect to ;.his procedure?
This is B&W 605.
7 A
No, I didn't.
8 Q
My question was, do you recall that you 9
did not have any comments.
10 A
I did not have any comments.
11 Q
With respect to the marginal notations that a'e made on B&W 606, did you convey those comments to 12 r
13 anyone other than to Mr. Broughton?
b
\\'
14 A
I can't recall having discussed them with 15 anyone.
16 Q
Do you know whether Mr. Broughton discussed 17 your comments or his comments with anyone?
18 A
I don't believe he did.
19 Q
Mr. Seelinger, as I understand it, requested 20 that you review these B&W Exhibits 605 and 606 for the 21 Purposes that we described earlier.
Do you recall any l
l 22 communication or conversation to him with respect to 23 your views on this?
24 A
I cannot recall whether we discussed the l' )
25 Procedures or not.
Lj.
1 Lenace 147 2
Q Do you recall discussing anything with 3
Mr. Seelinger at about this time, the spring and 4
summer of 1978, with respect to steam line breaks or (g) 5 loss of coolant accidents?
6 A
No.
7 Q
Do you recall any discussions with him 8
about procedures?
9 A
No.
10 Q
Do you recall any conversations with Mr.
11 Seelinger with respect to these procedures at any time 12 prior to the Three Mile Island accident?
13 A
No, I do not.
14 Q
Do you recall any conversations with him 15 with respect to these procedures following the Three 16 Mile Island accident?
17 A
I did not talk to him following the accident.
18 Q
Was it your view in the spring and summer 19 of 1978 that you had adequately responded to Mr.
20 Seeli'nger's request?
21 A
I don't recall.
22 Q
Do you recall the view that you had not 23 responded to Mr. Seelinger's reeuest?
24 A
I remember that there was a period of time 25 in which I did not respond to his request, and I
1 Lenoco 148
(~N) 2 realized I hadn't responded to his request.
't )
3 Q
Did you take any actions to rectify that?
4 A
I don't remember.
lll 5
Q Do you remember any contact or 6
communications or attempted communications between 7
Mr. Seelinger and yourself during that period?
8 MR. GLASSMAN:
I think that has been asked 9
and answered.
10 MR. BENEDICT:
Strike the question.
l l
I 11 Q
Let's start with: do you remember any 12 attempted communications, receiving phone messages
(~)
13 indicating Mr. Seelinger had called you, being told V
14 by someone else that Mr. Seelinger was trying to get 15 a hold of you?
16 A
No, I did not receive any messages.
17 Q
During the spring of 1978, where did you 18 place, in terms of your work 7riorities, Mr. Seelinger's 19 request?
20 MR. GLASSMAN:
Objection.
Lack of 21 foundation as to whether the witness had 22 particular priorities at all.
There should be 23 a background question asked.
24 MR. BENEDICT:
I will take my chances on g~.
,J 25 the question.
x-
1 Lnnaco 149 2
A I don't recall what priority I placed on
(
)
3 it.
4 Q
Do you recall that you did not place it ggg 5
high on your list of things to do that spring?
6 A
No, that wouldn't be correct.
7 Q
Do you recall that you did place it high 8
on your list of things to do?
9 A
No.
10 Q
I would like you to turn in B&W 605, which 11 is the steam line break procedure, to page 5.0.
You 12 testified earlier that in order to respond to Mr.
13 Seelinger's requests, you read through the procedure, l')
I 14 the entire procedure.
Focusing your attention on 15 Section 3.7 16 MR. GLASSMAN:
That is not quite what 17 Mr. Lanese testified to.
He said -- you asked 18 him whether it was necessary to in order to 19 respond, and he said he thought it was.
There 20 may be a slight variation there.
21 MR. BENEDICT:
I will take that.
22 Q
Did you read through the entire procedure 23 which is now marked as B&W 6057 24 A
I believe I did, yes.
,m
\\
25 Q
Focusing your attention on Section 3.7
-(u-1
1 Lenoco 150
,/ T 2
on page 5.0, which reads, " Secure high pressure
%-)
3 injection when pressurizer level is greater than 4
100 inches by defeating the SFAS signals and placing lll 5
the makeup pump control switches to trip.
Notes" --
6 underscored -- "If pressurizer level drops below 20 7
inches, manually initiate HP injection."
8 Did you recognize when you read this 9
passage in the spring of 1978 that the'se instructions 10 indicated that high pressure injection was to be 11 controlled by reference to pressurizer level with no 12 mention of pressure in the reactor coolant system?
13 A
No, I didn't.
V 14 Q
Do you recall having any thoughts with 15 respect to the description of HPI management located 16 at Section 3.7 or, for that matter, in anyplace 17 throughout B&W 6057 18 MR. GLASSMAN:
Objection.
You are asking 19 a number of questions here, and I am not clean 20 whether it is directed now to the particular 21 section here and whether Mr. Lanese recalls O
22 any interpretation of it that he had at the 23 time, or whether you are now asking some broader 24 question.
I think we should be clearer.
rm
/
(_,I 25 MR.. BENEDICT:
I think my question was
1 Lnnoco 351 e-2 clear.
If you want to have the question and V
3 answer read back, and my next pending question, 4
we will do it, but I think I was clear.
5 MR. GLASSMAN:
It just seemed to be that (gg 6
you were first focusing on 3.7.
7 MR. BENEDICT: First I was, and I got an 8
answer, and I went on to my second question.
9 Could you read it back.
10 (Record read.)
11 A
Yes, I did have some thoughts.
12 Q
Do you recall what those thoughts were?
13 A
At the time, the FSAR analysis was as 14 a result of the FSAR analysis, we had questions about 15 preventing the system from becoming water solid during 16 a steam line break accident.
One of the reasons I 17 wanted to review this procedure was to determine if 18 the operator had guidance to throttle HPI during a 19 steam line break accident, and this verified that he 20 did.
21 Q
What is the significance in terms of the O
22 FSAR analysis to taking the reactor coolant system 23 water solid?
l 24 A
The concern for water solid system during
, - ~
(,)
25 a steam line break accident is in regard to material
1 Lansco 152 7m
()
2 integrity of the reactor vessel.
3 Q
Are you talking about thermal shock?
4 A
It wasn't characterized as thermal shock llh 5
at the time, but it is a materials-brittle fracture 6
concern.
7 Q
Was this concern a result of the possibility 8
when water solid of overpressurizing the system?
9 MR. GLASSMAN:
You are asking for the 10 witness's recollection?
11 MR. BENEDICT:
Understanding at the time.
12 A
The consideration was that with a water
()
13 solid system, the reactor coolant system pressure 14 would go to the maximum shut-off head of the high 15 pressure injection pumps which is within the design 16 capability of the reactor coolant system in terms of 17 Pressure.
It is the potential for a combination of 18 pressure and low temperature that was of interest.
19 Q
Isn't it correct that the cutoff high 20 pressure head for HPI is higher than the setpoints for 21 the code relief valves on the top of the pressurizer?
22 MR. GLASSMAN:
Are you asking for the 23 witness's recollection back then?
7s 24 MR. BENEDICT:
Yes.
\\,
)
25-A That is correct, and in fact my answer was l
1 Lenase 153
(,,)
2 slightly incorrect in that the concern was that the v
3 system pressure would go to the safety valve setpoint 4
rather than to the shut-off head of the HPI pumps.
lll 5
Q And when you say or use the expression 6
" water solid," I take it you mean that the entire 7
reactor coolant system, including the entire volume 8
of the pressurizer, is filled with subcooled water; 9
is that correct?
10 A
No.
11 Q
What is your definition of " water solid"?
12 A
That it is filled with water.
("}
13 Q
Do you assume the existence of any v
14 significant quantity of steam or gas?
15 A
No.
16 Q
Do you assume the existence of any steam 17 or gas other than nucleate boiling on'the' pins?
18 A
No, not necessarily nucleate boiling in 19 the pins either.
20 Q
Even then?
21 A
Right.
22 (Discussion off the record between the 23 witness and his counsel.)
l 24 Q
During your review of these procedures in
/_,i i
+j 25 the spring and summer of 1978, did it never strike you
1 1
Lanese 154
')
2 that a consideration of reactor coolant system pressure
(_
3 should be included in this procedure when management 4
of high pressure injection was discussed?
(ll 5
A Yes, it did, in the sense that the NDT 6
concern was a combination of pressure and temperature.
7 Q
NDT stands for?
8 A
Nil ductility transition.
9 Q
Did you understand at the time you were 10 reviewing this procedure that high pressure injection 11 should not be terminated at a time when there were 12 saturated conditions within the reactor coolant system
,,(j 13 outside of the pressurizer?
14 MR. GLASSMAN:
You are asking whether 15 this was an understanding he had at the time he 16 reviewed this procedure?
17 MR. BENEDICT:
Let's hear the question 18 back.
19 (Question read.)
20 A
I don't believe that was one of my l
l 21 considerations when I reviewed this procedure, no.
i I
22 Q
Did you understand that fact at the time l
l l
23 that you reviewed this procedure?
In other words,
(~3 24 was this information that you knew by April 7, 19787
)
J 25 MR. GLASSMAN:
The question is not whether
I 1
Lnneco 155 2
he focused on it that day, but whether that was 3
something he had learned from some source prior 4
to that date?
lll 5
MR. BENEDICT:
Right.
I believe I already 6
asked the first part.
7 MR. GLASSMAN:
I wanted to make sure the N m 8
witness was clear.
,9 A
At that time and I suppose now I still 10 don't believe it would be incorrect during a steam 11 line break accident to throttle HPI with voids in the 12 system.
13 Q
By " throttle," do you include terminat,e?
14 A
That could be a correct action.
15 Q
What if it were a small break loss of 16 coolant accident?
Did you know prior to or about the 17 time that you were reviewing these procedures in 1978 18 that it was an incorrect action to terminate high 19 pressure injection at a time when there was a loss of 20 coolant in progress and saturated conditions existing 21 in the reactor coolant system outside of the 22 pressurizer, assuming that the system had not reached 23 the low pressure point where the LPI system could 24 come on?
25 MR. GLASSMAN:
Objection to the form.
Can
1 LEnoce 156
/x
( )l 2
I have it read back?
3 (Record read.)
4
.A I never thought about the problem in ll) 5 those terms.
6 Q
I am not limiting myself to those terms.
7 I think that you recognize that your obligation as a 8
witness is not to play word games with me.
Your 9
obligation as a witness is to give me true and correct 10 answers.
I am focusing on your knowledge at a time 11 which is critical in this litigation, and I think I am 12 entitled to a responsive answer.
I understand that you
(~J')
13 say you did not think of it in those terms.
I would 14 like to press and ask you whether you considered 15 whether high pressure injection, a substantial 16 reduction or termination of high pressure injection at 17 a time when steam voids existed within the reactor 18 coolant system outside of the pressurizer was 19 appropriate action for the operator to take if a l
20 loss of coolant accident was in progress.
l 21 MR. GLASSMAN:
I would like to have that k
l 22 read back.
23 Also I would like to note my dismay at the l
24 comments of counsel.
It is a rather difficult 1y 7,
(
);
~
~'
25 posed question to answer.
I objected to form.
1 Lanssa 157 2
We are not asking the witness not to answer.
b 3
(Record read.)
4 MR. BENEDICT:
I will withdraw the question.
lll 5
I would like to restate the question.
6 Q
At or about the time that you were 7
reviewing these procedures which have been marked 8
B&W Exhibits 605 and 606 in 1978, did you understand 9
that operators should not terminate or substantially 10 reduce high pressure injection at a time when steam 11 voids existed and saturated conditions existed within 12 the reactor coolant system outside of the pressurizer 13 while a loss of coolant accident was in progress?
14 A
I had never thought about that situation.
15 Q
It is true that by the summer of 1978 16 you knew that pressurizer level was not always an 17 accurate indication of liquid water inventory in the 18 reactor coolant system, isn't it?
19 A
I had never thought of it in those terms, 20 no.
21 Q
!sn't it correct that by the summer of 9
22 1978 you had learned that an incident occurring at the 23 Three Mile Island accident on April 23, 1978 had 24 demonstrated that pressurizer level was not an accurate 25 indicator of reactor coolant system water inventory
1 Lenses 158
[~}
2 when there were saturated conditions in the reactor V
3 coolant system outside of the pressurizer?
4 MR. GLASSMAN:
Can I have it read back.
ggg 5
(Question read.)
6 MR. BENEDICT:
I will restate it.
7 Q
Are you aware that there was an overcooling 8
incident at Three Mile Island Unit 2 on or about 9
April 23, 19787 10 A
Yes, I was aware of it.
11 Q
Did you not participate in a committee to 12 review the facts surrounding that incident?
13 A
No, not all of the facts.
(']l 14 Q
I appreciate that.
I don't think that my 15 question asked if you reviewed all of the facts.
I 16 hope that is not how you interpret questions.
17 Did you participate in a committee that 18 reviewed facts surrounding that incident?
19 A
Yes.
20 Q
Isn't it true that one of the findings of 21 that committee which was published in a TDR numbered-0 22 001 was that the reactor coolant system pressurizer i
23 level was held at a level higher than would be expected 24 if the entire system had been subcooled as a result
,a i
i
\\/
25 of steam voids existing in the reactor coolant vessel
1 Lanoes 159
(~)
2 upper head?
y/
3 MR. GLASSMAN:
Can I have thut back?
4 (Question read.)
5 MR. GLASSMAN:
Objection.
If you are lll 6
asking for Mr. Lanese's recollection of the 7
finding or his understanding, that is fine.
8 Obviously we have been through this in numerous 9
depositions.
We can all pull out the report 10 to find out what it said.
11 MR. BENEDICT:
I am intere'sted more in 12 his understanding of the finding, if he understood
(~N,,
13 that to be the case.
\\.J 14 A
My recollection is that was a finding of 15 that task force report.
16 Q
When did you become aware of that finding?
17 A
Sometime in 1978, 18 Q
Do you recall whether it was about the 19 time that the TDR with respect to that incident was 20 published, TDR 0017 21 A
No, I do not.
i l
22 MR. GLASSMAN:
Note my objection to 23 referring to this as a finding.
We may have Mr.
24 Lanese's understanding of it, but as we covered t
25 in previous depositions,. including that of Mr.
1 Lnnecs 360
()
2 Broughton, there were questions of whether (J
3 that was a likely occurrence, whether it was 4
a finding.
We have been through that several g
5 times.
6 MR. BENEDICT:
The mere fact that you have 7
been through it with Mr. Broughton doesn't 8
establish anything for Mr. Lanese.
9 MR. GLASSMAN:
We haven't established that 10 as a finding here.
We dealt with Mr. Lanese 11 MR. BENEDICT:
The record is what it it.
12 Please stop making your speeches. 'This deposition
/~'N 13 is going to go on for more than three days at the U
14 rate we are going.
15 MR. GLASSMAN:
I haven't stopped you.
16 MR. BENEDICT:
No, but you just gab.
17 MR. GLASSMAN:
I think you would be better 18 off continuing.
19 Q
I would like to show you a copy of a 20 document previously marked as B&W Exhibit 186 for 21 identification.
Mr. Lanese, can you identify this 22 document?
23 A
It is a task force report on the TMI-2 24 transient of April 23, 1978.
O 1' ' ' '
25 g
Do you see your name on the distribution
1 Lansco 161 2
list on the first page of B&W 1867
()
3 A
Yes, I do.
4 Q
Do you recall whether you in fact received lll 5
a copy of this document on or about the date indicated 6
on the signature lines?
7 A
No, I don't believe I did receive a copy.
8 Q
Do you recall if you ever received a copy 9
of this report?
10 A
I believe I have a copy of it in my files.
11 I have had one for about the last year.
12 Q
You don't recall ever receiving a copy
[m) 13 prior to sometime last year?
%/
14 A
No.
That's right.
15 Q
You believe when you received it last year 16 was the first time you had ever received a copy?
17 A
That was the first time I had a copy of 18 my own.
19 Q
Was it the first time you had ever seen a
(
20 copy of it?
21 A
I had seen the pages in which I was involved l
22 before, and I may have seen some of the other text.
j 23 Q
Can you describe generally the areas in l
24 fs which you were involved?
(
)
25 A
Yes, I was involved in the sodium
1 L2naco 162 2
hydroxide injection considerations.
(
)
3 Q
Turning to a page that has been marked 4
for purposes of this litigation as 0529 in the lower (f) '
5 right margin, about four pages in, you are indicated 6
as an added participant.
Is that correct?
7 A
That's right.
8 Q
And your recollection of your participation 9
was that it related to the sodium hydroxide issue?
10 A
That's correct.
11 Q
Do you recall any other participation?
12 A
No, I do not.
13 Q
Prior to your involvement with the April (s
\\~-
14 23 transient, were you aware that steam voids could 15 exist in the reactor coolant system outside the 16 pressurizer resulting in a pressurizer level which 17 was not an accurate indication of the subcooled water 18 inventory of the reactor system?
19 A
No, I wasn't.
20 Q
Are you aware of that today?
i 21 A
Yes, I am.
22 Q
Do you recall when you first became aware 23 of that fact?
l 24 A
Sometime after the accident.
l (s
)
25 Q
You are referring to the March 28, 1979 LJ
1 Lanese 163 (m
2
(_
accident?
3 A
The TMI-2 accident, yes, 1979.
4 Q
Is it not true that the analyses done 5
during 1978 with respect to the April 23rd transient demonstrated that pressurizer level during that transient was affected by the presence of a steam 8
bubble in the reactor vessel upper head?
MR. GLASSMAN:
Objection.
The witness 10 has given you his understanding of it.
He 11 said he didn't see a copy of the report before 12 the accident, or at least didn't recall that.
I'D 13
(_,)
It is not appropriate for the witness to sit 14 here and try to tell you what a document or 15 work done back in 1978 --
16 MR. BENEDICT:
I will withdraw the question.
17 I will do it differently.
18 Q
Prior to the accident at Three Mile Island 19 on March 28, 1979, were you aware that during an 20 incident occurring at Unit 2 on Three Mile Island on 21 April 23, 1978 that pressurizer level was affected i
22 by the presence of steam in the reactor vessel upper 23 head?
4
(~'N, A
I was aware that that was considered to be
%.)
one explanation.
1 Lnnoco 164 2
Q Did you believe that explanation?
3 A
I thought it seemed to be a reasonable 4
explanation.
lll 5
Q Did you understand prior to the Three. Mile 6
Island accident that the effect that the steam bubble 7
in the reactor vessel upper head had on the pressurizer 8
level during the April 23 transient was to cause that 9
prassurizer level to be higher than it would have been 10 had the system been completely subcooled?
11 MR. GLASSMAN:
Can I have it reread.
12 (Question read.)
13 Q
You understand I am looking for your 14 understanding prior to the March 28, 1979 accident.
15 A
Yes, if by completely subcooled, you mean 16 that the upper vessel head was subcooled?
17 Q
Yes.
18 A
Yes.
19 Q
Having reviewed the procedures marked as 20' B&W 605 and 606, did you at any time prior to the 21 Three Mile Island accident on March 28, 1979 consider O
22 that any changes should be made to any procedures 23 as a result of what you learned about the effect of 24 steam in the reactor coolant system outside of the 25 pressurizer?
1 Lanoso 165 2
MR. GLASSMAN:
Objection to the form.
3 First, there is a predicate to your question 4
related to having reviewed the procedures.
5 Several possible questions are being asked here.
ggg*
6 One as to whether the subject matter was 7
considered in connection with the procedures.
8 A separate question as to whether it was 9
considered any time before the accident.
And 10 perhaps a third question as to whether those 11 were ever connected.
Therefore the question is 12 unclear.
In addition, the question talks about 13 steam outside of the pressurizer, and the (3
t a
(/
14 witness has testified as to something more 15 specific relating to voids in the upper head 16 region.
17 MR. BENEDICT:
Was all that an objection 18 as to form?
19 MR. GLASSMAN:
And a few other points.
20 MR. BENEDICT:
If it is only an objection 21 to the form, it is preserved, and I will press O
22 my question.
23 A
Not that I can recall.
24 Q
Do you recall ever hearing prior to Three l
(n) 25 Mile Island about anyone else having such thoughts?
'w!
1 Lanoco 166
,-3
(
2 A
Not that I can recall.
x_/
3 Q
Do you recall discussing the issue of the 4
effect that steam in the reactor vessel head had on lll 5
Pressurizer level during the April 23, 1978 transient 6
with anyone, where such discussions occurred prior to 7
March 28, 19797 8
A Yes.
9 Q
With whom did you discuss it, if you can 10 recall?
11 A
I believe I discussed it with Mr. Broughton.
12 Q
Do you recall when that discussion took f'T 13 place, approximately?
J 14 A
No.
15 Q
Was it prior to the Three Mile Island 16 accident?
17 A
Yes.
18 Q
Was it about the time you were working or 1
19 helping work on the document that ultimately became 20 B&W Exhibit 1867 21 A
I don't believe so.
22 Q
Do you recall whether it was before or 23 after the time you worked on that?
24 A
I believe it was after.
,s 4
y~,;
25 Q
Do you recall whether the subject of
1 i
1 Lanese 167 l
l ()
2 indicated pressurizer level came up in that discussion?
3 A
I believe it did.
4 Q
Can you recall the context in which it g
5 came up?
6 A
In the context of modeling the plant 7
response and the consideration as to whether the 8
pressurizer had voided or not.
9 Q
At any time in th'ese discussions with 10 Mr. Broughton, did the issue of operator reliance 11 on pressurizer level come up?
12 A
No.
(
13 Q
Do you recall discussing with him any 14 procedures with respect to the operation of the Unit 2 4
15 facility in the context of your discussions relating 16 to pressurizer level?
17 A
No.
18 Q
Or the Unit 1 facility, procedures for 19 thats did you ever discuss that, Unit 17 I, limited 20 my first question to Unit 2 procedures.
21 A
No.
O 22 Q
Did you review the equivalent procedures 23 for B&W 605 and 606, the procedures at Unit 1 which 24 were equivalent thereto?
O 25 A
No.
g
1 Lanoco 168 2
Q No one asked you to?
7 i
\\~/
A No.
I had never seen Unit 1 procedures 3
4 before the accident.
ggg*
5 Q
Do you recall whether you discussed the 6
issue of the effect steam voids in the reactor 7
vessel upper hea'd had on pressurizer level with ~
8 anyone else prior to the Three Mile Island accident, 9
other than Mr. Broughton?
10 A
I can't recall.
11 (Discussion off the record between the 12 witness and his counsel.)
13 Q
Did there ever come a time prior to the O
14 Three Mile Island accident where you connected or 15 considered together what you learned with respect to 16 the effect of steam voids in the reactor vessel upper 17 head on pressurizer level and the procedures of Unit 18 1 or Unit 27 19 A
No, because our fccus in safety analysis 20 and plant control was to determine if the pressurizer 21 had emptied completely or not, and in fact I wasn't O
22 even directly involved with those analyses.
23 Q
But your answer to my question is no, 24 that.you did not at any time consider those two subjects I
's 25 together?
%-)
l l
1 L0no00 169 sS s
s 2
A That's correct.
/N t
\\_/
3 Q
Prior to the Three Mile Island accident?
4 A
Right.
~
s (g) '
5 (Re ce s s taken.)
6 BY MR. BENEDICT:
s s
7 Q
Referring your attention,tu B&W Exhibit i
t 8
606, which is TMI-2 loss of reactor coolant / reactor
+
s 3
9 coolant system pressure, could,you turn'to page 2.0.
(
10 I asked you earlier about this highlighting, and you 11 read it into the record.
Is is" correct, is my 12 recollection correct that yob' testified you can't 13 recall why it is you highlighted that?
/~T
'\\ s/
14 A
That's correc6(
15 Q
I would like to show you a document i
16 previously marked as B&W Exhibit 272, and I would like
', t
~
17 to ask you to turn to page 2.0 in 272.
Itchas been 18 represented to us by GPU that the procedure marked
')
19 B&W 272 was the proce'd.
in effecd at Three Mile
,it 2'at ~ the tim of the 20 Island on this si n ;.; ; t, 21 accident on March 28, 1979.
22 were you aware prior to that date or have 23 you since become aware that no changc; were,made to the w
s *,
w 24 passage that you have highlighted?
- / ^)
25 A
I am now aware that no changes have been -
\\,
t I
i
\\v l
s.
\\ < sm
\\
- n
- ~3 s
[!
A s 1,
i Lanoco 170
- lj,,\\ c '
i 4,
r ps
[ \\ f')'
2.
- Unade, Ns b,
3 Q
Were you aware prior to my showing you 3
4 s
4 chis document?
1 5
A
, No, I wasn't.
[
6 Q
When did you highlight this?
MR. GLASSMAN:
We are talking about about 7
s
'8
'B&W 6067 r.
y l '} '
.M.
h Q
Yes, when did you highlight the passage on
(
10 page 2.0 on B&W 6067 11 A
I can't be sure.
12 Q
Was it before or after the Three Mile (D
13 Island accident?
v 14 A
It could have been either.
15 Q
You don't recall?
16 A
No.
17 Q
When did you last review this document, 18 excepting your review, if any, with counsel?
s 19 A
I had looked at it in the last six to
~.
20 eight months.
I came across it in my files.
v 21 Q
Why did you look at it?
What prompted
.O s
22 you to look at it?
D7 23 A
Interest.
\\
24,
Q It was not at the request of counsel?
c,
\\
't/
25 e'
A No.
y
- . b ~
~
s-
, g ;)
,3 y
4 A
3 g
g i
1 Lnnoco 171 2
Q Did you look at B&W 605 at the same time, Ak-)
the procedure on steam line break?
3 A
I came across it in my files, because 4
5 they were in the same place.
I don't recall whether gg) -
6 I looked at'it or not.
I know I saw it again.
7 Q
Did you set out to find the document that 8
has been marked as B&W 6067 9
A No.
10 Q
You came across it by happenstance?
11 A
That's correct.
12 Q
And you pulled it out and reviewed it 13 out of curiosity?
I_ (_)
14 A
I read it, yes.
15 Q
Do you know whether you made any markings 16 on it at that time?
17 A
I may have made some of the highlights 18 at that time, yes.
19 Q
Do you believe that any of the other 20 comments other than the highlighting were made at that 21 time or any time after the accident?
E 22 A
No.
I am fairly sure that all those-23 comments were made before the accident.
24 Q
.Do you believe that all the comments that L
/~'\\
25 you identified as being in Mr. Broughton's hand were
)
~_ /
1 Lenose 172 2
made before the accident?
3 A
Yes, I am sure.
4 Q
Do you believe that any of the highlighting ll) 5 in B&W 606 was made prior to the Three Mile Island 6
accident on March 28, 19797 7
A I don't know.
8 Q
Is it correct that you do not recall at 9
this point why you highlighted this section?
10 MR. GLASSMAN:
Asked and answered twice.
11 Q
The answer is you don't recall?
It is 12 just a foundation question.
Is that correct?
13 A
That's correct.
14 Q
Looking down the page to the handwritten 15 entry under 3.2.1, could you read that, in B&W 6067 16 A
It says, "MU-v12."
17 Q
That is after the designation 3.2.1.1.
18 A
That's correct.
19 Q
Is that your handwriting?
20 A
No, it is not.
21 Q
Do you know we,vse handwriting it is?
22 A
No, I do not.
23 Q
I would like you to refer to page 2.0 24 of the document previously marked as B&W Exhibit 272, 25 and I would like you to read what the text after
1 Lnnoco 173
/7 2
3.2.1'.1 says.
w) 3 MR. GLASSMAN:
We can all read this.
4 I think before we get into any questions of g
5 Mr. Lanese about B&W 272, we should at least 6
find out whether he has ever seen that document 7
before.
You haven't even asked him that 8
question.
9 MR. BENEDICT:
No, and I don't intend to.
10 I agree that we can all read it, but I think the 11 record is clearer if we can do this in a 12 question and answer form rather than me have a 13 p
lot of long questions.
This question is just
't.)
14 preliminary to the question I am going to ask 15 about his knowledge of any changes being made.
16 MR. GLASSMAN:
I object to his reading 17 something where you seem to even refuse to ask 18 him whether he saw it before.
19 MR. BENEDICT:
Are you going to direct him 20 not to answer?
If not, let him read it.
l 21 MR. GLASSMAN:
Why don't you read it?
O i
22 MR. BENEDICT:
No.
I will ask the 23 questions.
If you don't direct him not to answer, 24 just keep quiet.
f'/
l
)
L.
25 MR. GLASSMAN:
I direct him not to answer.
O
1 Lansco 174 2
MR. BENEDICT:
You direct him not to answer
("N 3
a question which asked him to read a document 4
that has been marked?
gg*
5 MR. GLASSMAN:
That's correct, because you 6
are refusing to ask him whether he has even 7
seen it before.
This is a game we are playing.
8 I don't know where you are going or why.
Ask 9
your questions.
He is not here to read the 10 encyclopedia to you either.
11 Q
I would like you to look at a document 12 that has been marked as B&W 272, and I refer you to 13 page 2.0 and the text following the designation 3.2.1.1, b)
\\/
14 and I would like you to read along with me as I read 15 where it says, "Close MU-V12 and MU-v18."
16 Were you aware there has been a change 17 made to the procedure which you reviewed in April of 18 1978 prior to the Three Mile Island accident in 1979 19 and that this change had been added?
20 A
3.2.1.17 21 Q
That's correct.
9 22 (Record read.)
23 MR. GLASSMAN:
Objection as to form.
24 MR. BENEDICT:
I will restate the question.
[^)
25 Q
Were you aware prior to the accident at
\\__/
r
r-1 Lenoso 175 2
Three Mile Island on March 28, 1979 that the procedure 3
which you reviewed in April of 1978 had been cht'ged 4
to include the passage which I just read from the (g) 5 document marked B&W Exhibit 2727 6
A No.
7 Q
can you tell me what MU-V12 and MU-V18 8
stands for?
9 MR. GLASSMAN:
Are you asking for current 10 understanding?
11 MR. BENEDICT:
Yes.
12 A
MU-V12 is the makeup tank suction valve, 13 and MU-V18 I believe is downstream of MU-v17 which is 14 the normal makeup valve.
15 Q
Did you know what MU-V12 was prior to the 16 Three Mile Island accident?
17 A
Yes, I did.
18 Q
Did you know what the valve was at the 19 time that you were reviewing this document marked 20 B&W 606?
21 A
Yes, I did.
O 22 Q
Do you recall any discussion with anyone 23 with respect to this valve?
24 A
Yes, I do.
O 25 Q
With whom do you recall discussing it?
i -
1 L2no00 176 2
A With the Nuclear Regulatory Commission.
J t
3 Q
At what time did you discuss this with the l
4 Nuclear Regulatory Commission?
5 A
Prior to licensing of Unit 2.
gg' 6
Q That would be prior to February 1978?
7 A
That's correct.
8 Q
Does any of this discussion we have had 9
refresh your recollection as to.who made the entry in 10 handwriting on page 2.0 of B&W 6067 11 A
No.
12 Q
At the time you wure discussing MU-V12 13 with the NRC prior to licensing of Unit 2, did you bl
\\/
14 also discuss MU-V187 15 A
No.
16 Q
Were you aware of what MU-v18 was prior 17 to the accident at Three Mile Island?
18 A
I don't remember.
19 Q
I would like to turn to page 3.0 in B&W 20 606.
I believe I asked you this question with 21 respect to both procedures before, but just so the 9
22 record is clear and to avoid an objection by Mr.
23 Glassman, it is true, is it not, that you believe, 24 in your words, that you reviewed the entirety of both
[
25 B&W 605 and 6067 C, )
1
}
1 Lensoo 177 j']
2 A
I believe I read both of those procedures,
\\_)
3 yes.
4 Q
At the time you first read B&W 606, I 5
take it the first time you read it would have been (gg 6
sometime in April 1978.
7 A
Yes.
8 Q
At the time you read it, did you understand 9
that Section 3.2.5, that is to say, the text after the 10 caution, required that continued operation of high 11 pressure injection be maintained if the pressure 12 in the reactor coolant system was below the high r-13 pressure injection actuation setpoint?
(3) 14 A
I can't recall.
15 Q
Do you recall having any thoughts with 16 respect to Section 3.2.5 at the time that you read it 17 A
No, I do not.
in April?
18 Q
19 Do you recall whether there was any portion 20 of B&W 606 which at the time you first read it you 21 didn't understand?
l 22 A
I am sure there were sections I didn't 23 understand.
24 Q
Do you recall if Section 3.2.5 is one of O)
(_
25 those sections?
l
1 Lenoco 178 i
2 A
No, I do not.
J (y
(_)
3 Q
Did you take any action or make any 4
effort to obtain information that would help you ggg.
5 understand those sections?
6 A
No, I didn't.
7 Q
Did you understand Mr. Seelinger's 8
request to include comments with respect to lack of 9
clarity or the misleading nature of any part of the 10 procedure?
i' A
No, that wasn't part of the request.
12 Q
This issue was -- his request was limited 13 to a review with respect to FSAR analysis; is that
,n
(
)
14 correct?
x/
15 A
That is the way I recall it, yes.
16 Q
Was there any FSAR analysis existing at 17 that time which did not require operation, the 18 continued operation, of high pressure injection when 19 the reactor coolant system pressure was below the 20 high pressure injection setpoint and was above the l
21 low pressure injection setpoint?
l 4EP 22 MR. GLASSMAN:
Can I have it read back.
23 (Question read.)
~
24 Q
Let me add, an analysis with respect to l
25 loss of coolant accidents.
gS V
1 Lanoso 379 2
A Are you asking for my present understanding?
\\'
3 g
I want to know -.first let's deal with 4
what your understanding at the time was with respect 5
to FSAR analyses then axisting.
6 A
At the time I don't believe I ever thought 7
about that question.
8 Q
Have you since come to a different 9
understanding with respect to that?
10 A
I now have an understanding of the need 11 for high pressure injection in that situation.
12 Q
Focusing specifically on the issue of the 13 requirements of the FFAR analyses in the Three Mile
[\\_
14 Island Unit 2 FSAR, do you now understand that there 15 is any LOCA-related analysis which does not require 16 the continued operation of high pressure injection 17 when pressure is below the 1640 pound setpoint for 18 the initiation of high pressure injection and above 19 the setpoint for low pressure injection?
20 MR. GLASSMAN:
Objection as to form.
It 21 sounds a little bit like some understanding as 22 to whether you didn't beat your wife or something.
l 23 MR. BENEDICT:
Let's hear it again.
24 (Question read.)
[
)
25 MR. BENEDICT:
I will live with it.
1 Lrnaco 180
[)
2 A
Yes, there are.
v 3
Q Can you give me examples or can you 4
describe each of them that you recall?
lll 5
A There could be a small break LOCA 6
situation in which the primary system is subcooled.
7 The system is refilled.
Pressure is below 1600 pounds.
8 HPI can be terminated, and normal makeup could be g
restored.
10 Q
Are there any examples that you know of 11 existing in the ThI-2 FSAR which permit the termination 12 of high pressure injection when the RCS pressure is
(
13 below the high pressure injection setpoint and above
(
14 the setpoint for the low pressure injection and where 15 saturated conditions exist within the RCS outside of 16 the pressurizer?
17 MR. GLASSMAN:
You are asking for Mr.
18 Lanese's current understanding of this question?
19 MR. BENEDICT:
If ha has no understanding, 20 I will be happy to ask, firstly, whether he had 21 any understanding of that in the spring and O
22 summer of 1978.
23 MR. GLASSMAN:
You can ask whatever you 24 wish, since we have been flipping back and forth.
)
25 MR. BENEDICT:
Let's start with that.
1 Lonage 181
/^\\
(,)
2 A
The FSAR analyses don't address saturation 3
conditions in the primary system in general, so there 4
aren't any examples in the FSAR --
lll 5
Q The examples --
6 A
Which could be relevant to the question.
7 Q
The example that you gave me earlier was 8
an example which included subcooled conditions in the 9
primary system.
You say that saturation is not 10 considered An the FSAR analyses.
Are subcooled 11 conditions considered?
12 A
I am not sure I said considered.
I I) 13 meant addressed.
No, they are not.
'% )
14 Q
Did there come a time prior to the Three 15 Mile Island accident when you considered the 16 appropriateness of the instructions to operators 17 included in Section 3.2.5 of B&W 606 in the light 18 of what you had learned with respect to the effect 19 on pressurizer level of steam in the reactor coolant 20 system'outside of the pressurizer?
21 A'
I never considered head voiding and O
22 incresses in pressurizer level outside of the context 23 of overcooling events, and I never thought of them 7-24 even within the context of overcooling events in
(
)
ws 25 terms of operator action.
1 I
1 Lanese 382
(_ /
2 Q
At the time that Mr. Seelinger asked you 3
to comment on B&W 605 and 606, was it your view that 4
it would be appropriate for you to remark on the lack lll 5
of clarity or what you considered to be an error that 6
was not in the procedures that was not related to the 7
issue of FSAR analyses?
8 MR. GLASSMAN:
Are you asking as to whether 9
this was something that.came to his mind?
10 MR. BENEDICT:
Yes, if it was his view.
11 He didn't have to think about it specifically.
12 I want to understand something much more; as A(_)
13 your partner says, the state of a man's mind is 14 just as much a fact as the state of his digestion.
15 I am trying to get into the state of Mr. Lanese's 16 mind.
17 MR. GLASSMAN:
I am not sure I understand 18 the question.
I object to it as to form.
He 19 can answer it if he can.
20 A
certainly had I found anything in the 21 procedure that I thought was an error, I would have og informed Mr. Seelinger.
As far as clarity, I was not i
l 23 I did not feel competent to understand how operators
(~'
24 use procedures and what represented clarity or lack N.)T 25 of clarity.
a 1
Lanese 183 2
Q Turning to page 4. 0 in B&W Exhibit 606, 3
looking at the text at Section 3.2.8, do you have any 4
recollection today of the reason for the underscoring lll 5
in that paragraph?
6 MR. GLASSMAN:
You are not asking him to 7
speculate, you are asking for his recollection?
8 MR. BENEDICT:
If my recollection of his
'9 prior testimony is correct, he indicated ho 10 didn't recall who had done this.
My question is 11 whether he had some knowledge of why it was put 12 on there, whether it was by him or Mr. Broughton 13 or someone else.
14 A
These steps would have been related to the 15 core flood line break accident, and step 3.2.8 would 16 have been related to core flood line break accident 17 in which the operator is assumed to place the plant 18 systems in a piggyback mode, low pressure injection 19 supplying suction to the high pressure injection pumps.
20 He would only need to do that if RCS pressure were 21 above the low pressure injection setpoint operational 22 value, and that is the reason for the 200 pound 23 reference in the procedure, I believe.
24 Q
Maybe my question was unclear.
I am not 25 interested in your view as to why the text above the
1 LEnoco 184 2
underscoring was included in the procedure, but rather
(~-)
\\_/
3 why that section was underscored in the context of the 4
review that you had been asked to perform in the spring lll 5
of
'78.
6 MR. GLASSMAN:
You are not looking for 7
Mr. Lanese's interpretation now of that language.
8 Rather, you are looking for any recollection he 9
has as to the underscoring at that time?
10 MR. BENEDICT:
That's right.
11 A
My answer was trying to address that.
12 Q
I don't disagree with that.
13 A
The core flood line break accident was an V
14 FSAR analysis in which we were interested, and the 15 reference to the 200 pound instructi6n being given 16 to the operator was a proviso as to whether he had 17 to go to the piggyback mode of operation or not.
18 The next section in the underscoring was 19 related to another FSAR analysis and concern.
There 20' were questions about whether cavitating venturis 21 were going to be required for the high pressure 22 injection lines.
The argument that they were not 23 necessary is that the operator could prevent the runout 24 of an HPI pump by balancing flows in the HPI lines
. f)J
'(,
25 during a postulated high pressure injection line break.
l l
1 Lnnoco 185 l
l 2
Q Runout of a pump means overspeed; is that 3
correct?
4 A
It means the pump would be in a situation lll 5
where steam could be created in the pump housing.
6 In the case of these pumps, that could cause the failure 7
of the pump.
8 Q
Do I understand you to be saying that l
9 with respect to the underscoring in sections 3.2.8 10 and 3.2.8.1 that they are underscored because they 11 relate tc FSAR analyses and that that was the subject 12 of your review?
(
13 A
That certainly appears to be the reason 14 they were underscored, yes.
15 Q
Do you have any reason to believe at this 16 point that they are underscored because you or someone 17 else who you worked with at this time reviewing this 18 thought that there was an error in any of the 19 underscored text?
20 A
No.
21 Q
Turning to the two "o.K." entries that 22 read.
"O.K."
on the lower part of the page, that is 23 not your handwriting: correct?
24 A
No.
I believe I said that was Gary's.
O 25 Q
Do you remember discussing those two
1 Lnnaco 186
(~'N, 2
passages with Mr. Broughton?
%)
3 A
No, I do not.
I don't remember if I did.
4 Q
Do you recall having any concern about the lll 5
accuracy of those two paragraphs?
6 A
No.
There may have been some discussion 7
about the seven-foot level in the BWST.
8 Q
But you don't recall that specifically?
9 A
No.
Actually, I do not.
10 Q
Turning to page 5.0, do you know today 11 whether or when you did the highlighting that appears 12 on this page in the two portions of this page?
gS 13 A
I can't be sure.
N]
14 Q
It could have been either when you reviewed 15 them within the last year or at the time you reviewed 16 them in April of '787 17 A
Yes.
It is more likely I highlighted 18 them in
'78.
19 Q
Do you recall any other reviews you made 20 of these documents other than in April of '78 or 21 around that time and then again within the last year?
22 A
No.
23 Q
Did you loan the documents or did you 24 have any reason to give them to another person for
,m
'/
25 their use?
~
1 Lcnces 187 2
A No.
I i
\\'
3 Q
You said that it was your handwriting, 4
as I recall, that reads "could be pumping water out lll' 5
the break, should verify the flow path is intact";
6 is that correct?
7 A
That's correct.
8 Q
Then Mr. Broughton has made a comment
~
g next to it.
What, at the time you and Mr. Broughton 10 were dealing with this, did you understand Mr.
11 Broughton's comment to mean?
12 A
We were -- my comment was related to the 13 possibility of this being a core flood line break rs
\\
)
N/
14 accident in which water from one low pressure injection 15 pump was not actually going to the core.
16 Q
That is because the low pressure injection 17 system utilizes some piping in common with the core 18 flood tanks?
19 A
That's correct.
The substance of Gary's 20 comment was that being in the portion of the procedure 21 in which pressurizer level had been recovered, since 22 Pressurizer level was on scale, there would be no i
23 concern about a core flood line break in that situation.
24 Q
LP is an abbreviation for level pressurizer?
)
25 A
Yes, it is.
1 L2noco 188
,s 2
Q Your concern with respect to this passage 3
related to the possibility of a core flood line break?
4 A
That is what I remember, yes.
lll 5
Q And the reason for your concern would be 6
that a certain quantity of the low pressure injection 7
water would be diverted and not make it to the core?
8 A
That's correct.
9 Q
Was it Mr. Broughton's position that if 10 pressurizer level was on scale, it was impossible 11 to have a core flood line break?
12 A
Based on the analyses, we knew that 13 pressurizer level would be off scale for a break of O\\
(
l 14 that size, yes.
15 Q
So if a core flood line broke, you knew 16 at that time that the pressurizer level would of 17 necessity or the pressurizer would empty or at 18 least go off scale low?
19 A
Yes, for the large core flood line break, 20 which is the one that I was concerned about here, it 21 would have been off scale low.
O 22 Q
Do you recall the reason for your 23 highlighting the second part of the passage next to 24 3.2.117
(%
(,)
25 A
Yes.
1 Lnnssa 189
()
2 Q
Can you tell me what that reason was?
3 A
Again there was a licensing issue related 4
to long-term circulation of reactor coolant water and
{ll 5
boron precipitation within the core.
There were 6
questions about how soon alternate cooling paths 7
should be implemented, and I believe at one time the 8
analyses demonstrated that a week was suitable.
The 9
staff insisted on a shorter period of time, and that 10 highlight verifies that we had incorporated a shorter 11 period of time for implementing the modes.
12 Q
At the time that you recognized that, did
(~}
13 you believe that it was improper or incorrect from
%)
14 an operating point of view to have the shorter time 15 that the NRC had requested?
16 A
At the time it seemed that our analyses 17 demonstrated that it was unnecessary.
On the other 18 hand, I knew we were required to implement it in this 19 relatively short period of time.
By relatively short, 20 I mean with respect to the onset of the phenomenon 21 of boron precipitation.
22 Q
would it surprise you if I told you that 23 portion of the procedure had not been changed prior 24 to the accident at Three Mile Island?
25 A
No, it wouldn't surprise me.
1 Lanese 190 N -)
2 Q
Would it surprise you that the passage 3
which you highlighted immediately above that one had 4
not been changed prior to Three Mile Island?
lll 5
A You are referring to 3.2.107 6
Q Yes.
7 MR. GLASSMAN:
I object to the line of 8
questioning, whether he would be surprised or 9
not surprised.
You can find out his knowledge.
10 MR. BENEDICT:
I will withdraw the question.
11 Q
Was it your opinion at the time you reviewed 12 this that changes should be made to the language that
!O
(_,/
13 you have highlighted immediately following 3.2.107 14 A
There was a question about what the staff 15 review of those modes meant.
16 Q
I am talking about 3.2.10, the highlighted 17 portion.
18 THE WITNESS:
Could you repeat that question.
19 (Record read.)
20 A
No.
Given Mr. Broughton's comments, I 21 didn't believe that the procedure needed to be revised.
22 Q
Turning then to the section you thought 23 I was talking about before, Section 3.2.11, you have I
t'~N 24 made a notation in the margin there next to che four C1 25 listed modes which reads, "No, only use mode 2 and
1 Lanoco 191
,9
(
)
2 mode 3."
\\_/
3 Can you recall at this time why you 4
recommended that that be changed?
llh 5
A Yes.
At the time my recollection was 6
that BAW 10103A, which was the approved LOCA topical, 7
had a staff safety evaluation letter included that 8
addressed the boron precipitation issue and made 9
statements about the unadvisability of using modes 10 1 and 4.
11 Q
Made statements about the inadvisability, 12 you say?
IT 13 A
Yes.
O 14 Q
Was it your understanding at the time that 15 the NRC required that for this practice only modes 2 16 and 3 be utilized?
17 A
There was a degree of uncertainty in my 18 mind as to what the safety evaluation letter required.
19 Q
It was your interpretation at the time 20 that it required that only modes 2 and 3 be used, 21 I take it.
l 22 A
No, there was a degree of uncertainty l
l 23 in my mind.
24 Q
One interpretation --
~
,3
)
'~'
25 A
Yes, that's right.
1 Lnnaes 192 2
Q
-- was that only modes 2 and 3 be used?
3 A
Yes.
4 Q
Could you look at page 14.0 of B&W 606.
h 5
Is the entry after 3.11 where the text following the l
6 words " mode 1" has been lined through and the text 7
following " mode 4" has been lined through, is this 8
the same issue that we were just discussing?
9 A
Yes, it is.
10 Q
So the same reasons would apply for why 11 you made those changes or made those entries.on this 12 draft?
13 A
Yes.
14 Q
Were you aware prior to the accident at 15 Three Mile Island that those sections had not been 16 changed?
17 A
No, I wasn't.
18 Q
Do you recall discussing this issue with 19 Mr. Broughton, the issue of the modes that you could 20 use in this situation?
21 A
No, I do not.
22 Q
Do you recall knowing Mr. Broughton's 23 position on this issue at the time?
24 A
No, I do not.
O 25 Q
could you turn, please, to page 9.0 of
1 Lonoss 193 i
2 Exhibit 606.
Noting the highlighted section at the
,_.s
/
\\
~
3 top of the paragraph which begins with the word 4
" caution," do you recall when you highlighted or llg' 5
if you highlighted it, and if so, when?
6 A
I can't recall if or when.
7 Q
Can you today recall being interested in 8
this section at the time of your review?
9 MR. GLASSMAN:
You are talking about the 10 time of the 1978 review?
11 MR. BENEDICT:
Yes.
12 A
Yes, I can recall a licensing issue 13 associated with that subject.
b) 14 Q
At the time you made this review or during 15 the spring of 1978, did you believe there was anything 16 inaccurate in the passage that has been highlighted?
17 A
No.
18 Q
Did you believe there was anything that 19 should be changed with respect to that passage?
20 A
Not that I can recall.
21 Q
Turning to page 11.0 in B&W Exhibit 606, 9
22 as you recall, can you explain to me the issue that 23 is indicated by the notes that you and Mr. Broughton 24 had made on this page?
(~%
)
_ 25 A
This is related to the same FSAR analysis 1
l_
1 LEnoca 194 j
r'
( )3 2
issue of core flood line break in piggyback mode.
3 Q
Is it your handwriting, the first entry, 4
which reads "not required for this mode since have lll 5
two LPI's"?
6 A
Yes.
7 Q
How does that relate to the issue of a core 8
flood line break?
9 MR. GLASSMAN:
You are asking for his 10 current 11 MR. BENEDICT:
No, I am asking how he 12 recalls that comporting with his concern about I
13 loss of LPI flow out of a broken core flood line.
\\J 14 A
At the time, the accident that was being 15 considered was a core flood lins break, and the worst 16 case single failure for that event was the failure of 17 a diesel generator affecting the low pressure injection 18 pump on the unbroken core flood line with two low 19 pressure inj ection pumps running.
What my comment 20 was related to there was there should be no need for 21 the piggyback mode since there was LPI flow going O
22 into the core.
23 The substance of Gary's comment was, s
24 I believe we i
1-
\\.)
25 Q
The substance of what you believe?
1 1
LEnaca 4 95 2
A Yes.
I believe we could not verify the 3
LPI flow into the core since we may not have been 4
able to identify the broken LPI line.
lll 5
Q Is it a fair characterization of the 6
discussion that you and Mr. Broughton had with 7
respect to this issue that you were of the opinion that 8
a change should be made to the procedure and that he 9
was of the opinion that a change need not be made?
10 A
My opinion was that the procedural step 11 was unnecessary, and his position was that the 12 procedural step was necessary.
13 Q
Did you come to accept Mr. Broughton's 14 view?
15 A
Yes, I did.
16 Q
In your testimony or in your answer to a 17 question a few questions back, you used the expression 18
" worst case single failure."
can you tell me what 19 that means, what you understood it to mean at that 20 time, and if you view has changed, what you understand 21 it to mean today?
22 A
First, my view of worst case single failure 23 hasn't changed.
What it means is for the particular 24 event considered, the postulation of a single failure 25 in a safety-related piece of equipment that minimizes t-
1.
Lanoso 196 2
the availability of mitigating equipment, thereby 3
resulting in the most severe accident consequences 4
to the plant.
l 5
Q In other words, you consider a number of
.l) 6 different single failures until you have established 7
what you view to be the one that leads to the most 8
severe consequences with respect to the condition 9
of the reactor?
10 A
of safety-related equipment, yes.
11 Q
I am sorry.
Single failure of safety-12 related equipment?
13 A-Right.
T 14 Q
Do you recognize the handwriting which is 15 directly opposite 3.8.1 at page 11.0 of B&W 606 which 16 reads "45"?
17 A
Yes, I do.
18 Q
Whose handwriting is that?
19 A
I believe it is mine.
. 20 Q
Do you have any recollection today of 21 why you made that entry?
22 A
Yes.
23 Q
could you describe it, please?
24 A
one of the licensing issues on TMI-2 s
25 was the_need for_ automatic transfer of the borated
1 L0noco 197 2
water storage tank on low level, and related to the
/~'T
(.,)
3 switchover and the draining of the BWST was the 4
question of how much time the operator.would have ggg.
5 during a core flood line break accident -- excuse me 6
not during a core flood line accident, but during any 7
loss of coolant accident, how much time he would have 8
to make the switchover.
In doing those calculations, 9
we determined that it could be as short as 45 minutes, 10 and that is where the 45 minute number came from in 11 that procedure.
12 Q
At any time prior to the Three Mile Island 13 accident, did you reconsider your opinion that 45
(_)
14 minutes was the shortest time?
15 A
I don't remember having reconsidered it, 16 no.
17 Q
I have asked you before about your general 18 recollection of the communication of your. comments 19 with respect to this.
Focusing now, has reviewing 20 this specific entry refreshed your recollection with 21 respect to making that particular recommendation Nnown W
22 to anyone?
l 23 A
I don't believe I considereds it im[ortant l
24 enough to make the comment.
/N 25 Q
Did you know that prior to the Three Mile
'^
\\
l x._/
b o
e r
\\
1 e
Lonoco 198 2
Island accident, no change had been made?
(
. (/
3 A
No.
\\
4 Q
Turning to page 32.0, I believe you 1
y lll-5 testified earlier that the expression or the marginal 6
notation "is there enough time?" was written not by 7
you; is that correct?
8 A
That's correct.
9 Q
Do you believe it was written by Mr.
10 Broughton?
11 A
It looks like Gary's handwriting, yes.
12 Q
Do you remember discussing the issue of 13 whether or not there was enough time to perform these
()'
14 actions with Mr. Broughton?
1 15 A
Mr. Broughton and I were involved in t ';
16 conversations with the NRC regarding the amount of time 17 involved.
18 Q
When were these conversations in progress?
19 A
Prior to licensing of TMI-2.
20 Q
If any, what was the resolution of those 21 discussions?
W 22 A
This again comes back to the core flood 23 line'. break accident and the resolution was that 24 regardless of the amount of time available to make eN 25 this particular valve alignment, the piggyback mode
(
u
1 Lenoco 199
[v')
2 could be implemented in a much shorter time and would 3
all w adequate core cooling.
4 Q
This is a different action than the lll i
P ggyback?
5 6
A Yes, it is.
7 Q
Did you have an opinion at the time you 8
reviewed this as to whether or not there was enough 9
time to perform those steps?
10 A
I believe I had the same question in my 11 mind.
12 Q
Did you ever resolve that question?
/~
13 A
The resolution was the piggyback mode of b) 14 Operation.
15 Q
Did the --
16 A
Yes, I did resolve it, and that resolution 17 was the piggyback mode of operation.
18 Q
Did you have the view at the time or were 19 you of the opinion at the time you reviewed this or 20 at any time prior to the Three Mile Island accident 21 that the procedures should be changed from what they 9
22 are in this draft, B&W 6067 23 A
No, this is not a procedural consideration.
34 Q
I am not sure I understand what you mean p
5-25 by procedural consideration.
1 Lanoco 200 2
A If there were an inadequacy that I t'~T k-)
3 perceived in the way the accident was being mitigated, 4
there should have been a hardware equipment change, lll*
5 not a procedural change.
6 Q
And you did not perceive an inadequacy?
7 A
No.
8 Q
There is a notation in the margin which 9
you testified is in your handwriting which reads, 10 "FSAR has order in reverse."
11 Did you at the time you wrote that mean 12 that in the FSAR the two steps described as 3.8.3.9 13 and 3.8.4 were in the reverse order from what they
/~N
(_)
14 appear here?
15 A
Yes.
16 Q
Did you consider at that time that the 17 reversal in this procedure was of consequence?
18 A
I can't recall.
It doesn't seem to be.
19 Q
Did you know prior to the Three Mile 20 Island accident that there had been no change made to 21 this part of the procedure?
E 22 A
No, I didn't.
23 Q
The notation at the bottom which I j
\\
24 believe you testified is in Mr. Broughton's handwriting,
{
(^]
25 you have the original there.
Could you read it to me?
w)
I
1 Lanoco 201 r^3 2
A "NPSE has not been verified in this mode."
b 3
Q Do you recall what Mr. Broughton was 4
referring to in that notation?
lll 5
A The NPSH available to the high pressure S
injection pump in the supposed -- that is not the 7
right word -- in what is called modified piggyback 8
mode.
9 Q
What is NPSH?
10 A
It stands for net positive suction head, 11 and it is an indication of the prevention of steam 12 formation within the housing of the pump with tl.e 13 purpose of preventing cavitation of the pump and (m
LJ 14 possible failure.
15 Q
Does the steam occur in an otherwise 16 subcooled system because the pump creates a localized 17 low Pressure area?
18 A
That's db rre c t.
19 Q
And the low pressure area is around the 20 veins of the pumps is that right?
21 A
I believe so.
22 Q
What is cavitation, as you used it?
4 23 A
The forming of steam voids within the 24 housing of the pump.
/' 'N.)
25 Q
What is the effect of cavitation?
1 L;noco 202 2
Let me stop and ask you just a p.
U 3
clarification question.
Your description of NPSH 4
and your answers with respect to my follow-up questions, ggg*
5 was that knowledge that you held at the time that 6
you were reviewing this?
7 A
Yes, it was.
8 Q
Continuing on, basing my questions on 9
what you knew at the time in 1978, why did you 10 understand that NPSH was to be avoided?
11 A
It could damage the pump or cause its 12 failure.
13 Q
By what means did you understand that 14 cavitation would result in pump damage or failure?
15 A
I am not sure.
16 Q
You don't know why it was that cavitation 17 causes damago?
18 A
No, I don't think I can accurately 19 describe the reason.
1 20 Q
Did you know at the time that cevitation 21 could cause vibration of the pump shaft?
22 A
No.
23 Q
Did you know that it could cause erosion j
24 on the pump veins?
im
(
)
25 A
Yes.
\\/
1 Lanese 203 2
Q You say that Mr. Broughton was concerned 3
or this note describes a comment he had with respect 4
to NPSH.
Can you give me any more detail on what lll 5
his concern was or what the basis for this comment 6
was?
7 A
No, I can't.
8 Q
Do you recall whether it was an issue 9
that you believed at the time needed to be resolved?
10 A
I remember some discussion with someone 11 in operations and coming to the conclusion that the 12 operators were well aware of the potential for 13 cavitation of the pumps and that they would prevent 14 Pump runout.
15 Q
Do you recall with whom you discussed this?
16 A
No, I do not.
17 Q
Do you recall that it was a matter of your 18 initiating a call to someone in operations?
19 A
No.
20 Q
By operations, do you mean a member of the 21 Met Ed TMI plant staff?
22 A
That is a possibility.
23 Q
You don't recall one way or the other?
24 A
No.
25 Q
Prior to the Three Mile Island accident,
1 Lnnoco 204 s
2 did you know that no change had been made to this I
\\
LJ 3
Portion of the procedure?
4 A
Based on the conversations that I lll 5
recollect, I wouldn't have expected any changes in the 6
procedure.
7 Q
You were satisfied prior to the Three Mile 8
Island accident that no change was necessary?
9 A
Yes.
10 Q
Based on what you had been told about the 11 knowledge of the operators with respect to NPSH7 12 A
That's correct.
13 Q
Having at rather great length reviewed
-s 14 the comments and marginalia in B&W 606, did any of 15 that refresh your recollection as to how or if any 16 of these comments or remarks were communicated from 17 GPU Service to Mr. Seelinger or to anyone else at 18 Met Ed?
19 A
I have a general recollection that after 20 talking to Gary, there were no serious concerns, 21 but I don't remember if I ended up transmitting the h
22 comments that had been generated to Jim Seelinger.
23 Q
By Gary, you are referring to Gary Broughton; 24 is that correct?
x l
25 A
Yes.
x_,
1 Lenoco 205 2
Q So it is your recollection that at some 3
time during the spring or summer of 1978 you and Mr.
4 Broughton agreed that you had no significant concerns (g) 5 as a result of this review?
6 A
None of our comments appeared to be 7
substantive, and what we were looking at was FSAR 8
analyses.
The question being, had they been properly 9
accounted for in the procedures. With the possible 10 exception of the boron precipitation mode, which I 11 may have also discussed, I am really not sure, I
\\
12 didn't see anything that would have required discussion.
13,
Q When you say you didn't see anything, are 14 you talking about the review we just made, or are you 15 talking about your recollection of your review at the 16 time?
17 A
My recollection at the time was thst I 18 realized procedures were being used differently than 19 what an engineer might have thought they were being 20 used for, and that everything was being accounted for.
21 Q
When I early on and very generally asked O
22 you who else you had dealings with -- and I may not 23 have used those terms -- we talked briefly on who you 24 could recall dealing with with respect to this, and 25 you did recall a conversation with Mr. Seelinger
1 Lenoco 206 2
which you recalled as being face-to-face, and you
/ T 1
, ~#
3 recall you dealt with Mr. Broughton.
Do you recall 4
whether you dealt with Mr. Broughton on more than one lll' 5
occasion with respect to this, with respect to the 6
review that you performed at Mr. Seelinger's request 7
of B&W Exhibit 605 and 6067 8
A I don't recall, no.
9 Q
Do you recall whether your conversation 10 or conversations with Mr. Broughton were in person 11 or over the telephone?
12 A
They were in person.
13 Q
You also, since our review, remembered 4
14 a conversation you had with someone in operations.
15 Do you recall whether that was a conversation that 16 was face-to-face?
17 A
It was possibly with someone in operations, 18 and I don't recall, no.
19 Q
You did, however, speak to someone who 20 gave you assurances with respect to operator 21 understanding of the phenomenon of net positive 22 suction head?
23 MR. GLASSMAN:
I am not sure what 24 phenomenon we are talking about.
We were talking g
i i
25 about the phenomenon of cavitation.
Net positive
'x.J
1 Lanose 207 2
suction head is just what it says.
It is not a 3
phenomenon.
4 MR. BENEDICT:
The fact of net positive g'
5 suction head then; is that acceptable to you?
6 MR. GLASSMAN:
You may use whatever word 7
you wish.
We are talking about an indicator 8
of perhaps cavitation.
l 9
MR. BENEDICT:
Can I hear the question 10 again.
11 (Record read.)
12 Q
I will amend the question to exclude the f
13 part about phenomenon of net positive suction head, and 0
14 just say net positive suction head.
15 A
What I talked to someone about and what 16 I was assured of is that the operator was familiar 17 with preventing pump runout and that that pump runout 18 would not occur as a result of the transition to a 19 piggyback mode of operaticn.
20 Q
I think the way we got started on all of 21 this was what you understood pump runout to be, and 22 pump runout occurs when you reach net positive 23 suction head at the inlet of the pumps is that right?
24 A
I believe so, yes.
25 Q
That is your understanding of what you o
1 LEnoco 208 2
meant by pump runout?
3 A
Again, I believe so.
4 Q
Do you recall whether the conversation g*
5 you had with this person about NPSH, do you recall 6
whether that was a face-to-face conversation?
7 A
I don't think so.
8 Q
Do you --
9 A
It could have been.
10 Q
You don't recall?
11 A
I don't recall.
12 Q
And you testified earlier you don't recall 13 whether you initiated it.
Do you recall whether
[(_/
14 during that period you had regular contact with 15 operations people as you described them before?
16 A
I did not have regular contact with 17 operations.
18 Q
Aside from yours and Mr. Seelinger's 19 discussion with respect to your review of this 20 material and a discussion or discussions with Mr.
21 Broughton with respect to yours and his comments, and O
22 the discussion with someone concerning operator 23 understanding of net positive suction head, can you 24 think of any other discussions you had with any other
()
25 person during the period in April or around there of N _../
1 Lanoco 208-A
(
2 1978 with respect to this review?
3 A
No.
4 (Whereupon, at 12:30 p.m.
a lunch recess h
5 was taken.)
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 l
22 l
23 l
24 (o
25
1 209 73
)
2 AFTERNOON SESSION 3
1:30 p.m.
4 L0UI S C.
LANE SE, resumed.
llk 5
EXAMINATION (continued) 6 BY MR. BENEDICT:
7 Q
In the period around March, April and May 8
of 1978, what percentage of your time was spent working 9
on matters which related to either of the units at 10 Three Mile Island?
11 MR. GLASSMAN:
I am not sure I understand 12 the question.
Is it directed to what percentage 13 was spent on Units 1 and 2 combined?
14 MR. BENEDICT:
Either or both.
15 MR. GLASSMAN:
You don't want him to 16 speculate.
17 MR. BENEDICT:
No, his best estimate of 18 how much time he spent on matters relating to 19 either or both of the units.
20 A
A large majority of my time.
21 Q
Are you aware today that there was a (Ik 22 transient which involved an open PORV at Three Mile 23 Island Unit 2 on March 29, 19787 A
t
)
24 A
Yes, I am.
s p
ss 25 Q
When did you first become aware of that?
1 Lanoce 210
[^')
2 A
I believe the day of the event.
LJ 3
Q On March 29th?
4 A
Yes.
5 Q
From whom did you hear it?
lll 6
A Gary Miller.
7 Q
Did Gary Miller call you?
8 A
No.
9 Q
Did you call.him?
10 A
No.
11 Q
Did you bump into him?
12 A
We were in a meeting.
l
(~}
13 Q
where was the meeting?
kJ 14 A
In Reading.
15 Q
Reading is where the engineering staff of 16 Metropolitan Edison is?
17 A
That's right.
18 Q
And Mr. Miller was in attendance at this 19 meeting?
20 A
Yes.
21 Q
And so were you?
22 A
Yes.
23 Q
Do you know how he found out about the 24 incident?
,o i
/
25 A
He was informed by the plant staff.
1 Lanoco 211
,m 2
Q Did Mr. Miller make a presentation ad hoc
( ))
q 3
or otherwise to an assembled group about the incident 4
or did you and he just happen to talk?
lll 5
A He related the few details that he had 6
available to me at the time.
7 Q
To more than one person?
8 A
Yes.
9 Q
Who was in this group?
10 A
Mr. Broughton and Mr. Trikouros, Mr.
11 Klingaman, I believe, Mr. Fritzen of the Met Ed 12 generation staff, Mr. Seelinger, Mr. Herbein for a 13 Portion of the discussion, and a number of other of
(~)
\\J 14 the Met Ed generation engineering staff.
15 Q
What was the subject of the meeting?
Do 16 you recall?
17 A
of the 18 Q
The meeting that you had at Reading that 19 day.
20 A
It was a licensing turnover meeting in which 21 we discussed the licensing issues in which we had S
22 spent most of our time, which had taken a fair amount 23 of time to evolve or which would result in subsequent 24 modifications to the plant.
( "'T
()
25 Q
When you say a licensing turnover meeting,
1 L0noco 212 rN 2
was this a meeting to discuss the turning over of
\\
l xs 3
licensing responsibilities for Unit 2 from GPU Service 4
to Metropolitan Edison?
ll) 5 A
I really should call it a debriefing, but 6
it was part of the process of making Met Ed fully 7
aware of the issues that we had dealt with during the 8
licensing of TMI-2.
9 Q
You mentioned a number of people who you 10 recall being present when Mr. Miller described what 11 facts he knew or had heard about the event on March 12 29, 1978.
One of the persons you named was Mr.
13 Klingaman.
Could you tell me who he is?
V 14 A
At the time, he had a responsibility for 15 Met Ed generation engineering services.
16 Q
Was he a Met Ed employee?
17 A
Yes, he was.
18 Q
Who was Mr. Herbein at that time?
19 A
At that time, I believe he was vice 20 President of generation engineering at Met Ed.
21 Q
Again Met Ed?
22 A
Yes.
i 23 Q
Other than Mr. Broughton and Mr. Trikouros, 24 who else from GPU Service was present when Mr. Miller n(_)
25 described this event?
1 Lcnese 213 (a,)
2 A
No one else.
3 Q
What do you recall Mr. Miller telling you 4
about the event on that day?
llk 5
A I believe it was that the PORV went open 6
as a result of a loss of power to an AC bus and there 7
was an HPI injection.
8 Q
Did he mention that there had been an 9
injection of sodium hydroxide?
10 A
I am not sure we knew that at the time.
11 Q
Is it in fact the case that that occurred 12 that day?
O i
NJ 13 A
I believe it did, yes.
14 Q
Did he describe any of the other 15 consequences of losing power to this vital bus?
16 A
I have to change the previous answer.
I 17 am not sure that it did on that day.
I am not sure 18 we had a hydroxide injection during that event.
19 Q
With respect to the other things you 20 recall him mentioning, you mentioned that he said that 21 the PORV had opened as a result of loss of power to 22 a vital bus and that there had been an HPI actuation.
23 A
- Yes, g-24 Q
Do you recall any other specifics he G)!
25 provided you?
1 Lsnoco 214
-~.
o A
No.
1 3
Q Do you recall whether he said anything 4
with respect to the cause for the HPI actuation?
ll) 5 A
I presume it was on low pressure.
6 Q
At the time you believed -- was that your 7
understanding at the time?
8 A
I am not sure.
9 Q
Was HPI in fact initiated that day as a 10 result of low pressure in the reactor coolant system?
11 MR. GLASSMAN:
You are asking --
12 MR. BENEDICT:
His knowledge up to today.
13 A
I believe so.
\\d 14 Q
Did he mention anything with respect to 15 loss of instrumentation?
16 A
I don't remember.
17 Q
Did he tell you what time of day this 18 incident occurred?
19 A
I don't remember.
20 Q
Do you recall about what time of day he 21 told you about it?
22 A
He told us about it in the afternoon.
23 Q
sometime before dinner?
24 A
Midafternoon.
,e "
\\_,g/
25 Q
Would it refresh your recollection if I
1 Lnnoco 215
(~N 2
told you that the event occurred sometime around L-)
3 two p.m.
in the afternoon that day?
4 A
It sounds plausible.
5 Q
You don't recall him mentioning anything (g) 6 about it having happene. only hours ago or anything of 7
that sort?
8 A
I know he mentioned it very shortly after 9
he received a call from the plant.
10 Q
Do you know who called him?
11 A
No.
12 Q
Did Mr. Miller leave the meeting at that 13 point?
p)
\\
14 A
No.
15 Q
Was the meeting ovor?
16 A
I believe it was close to being over.
17 Q
At the time Mr. Miller described these 18 events to the assembled group that you described, 19 did the attention of those people turn to this 20 transient for the remainder of the day or did the i
21 People return to the subject of the meeting, the O
22 original subject?
i i
23 A
There was quite a bit of interest in the t
24 event.
I remember Mr. Miller ascertaining as many
<~s 1
25 facts as he could to determine whether he needed to
1 Lnnoco 216 i
i 2
go back or not, and we stayed around for a while
\\~'
3 longer and discussed it.
4 Q
Do you know whether Mr. Miller called ll) 5 the plant or whether the plant called him to relate 6
this information to him?
7 A
I think the plant notified him.
8 Q
Do you know whether he talked directly to 9
people at the plant?
10 A
To the best of my knowledge, he did, yes.
11 Q
Following his initial description of the 12 event to you and the others, did anyone in that group 13 have any comment or ask any questions with respect to
/^T U
14 it?
15 A
I don't remember what comments or questions 16 were asked.
17 Q
Were there comments and questions?
18 A
As I recall, there were, yes.
19 Q
Do you recall anything that you said at 20 that time?
21 A
No.
Y 22 Q
Do you know whether Mr. Miller, following 23 his presentation, sought further information while i
24 still in Reading?
f) 25 A
There was a continuous attempt at collecting u/
\\
1 Lnnons 217
,(\\)
2 more data.
v' 3
Q What else, if you can recall, do you 4
remember hearing about the event following Mr. Miller's (lh 5
first revelation of it to you?
6 A
I don't remember hearing very much more 7
about it.
8 Q
Were you personally interested in it at that 9
point?
10 A
Yes, I was.
11 Q
What next occurred that provided you with 12 any additional information with respect to the
}
13 incident on March 29, 1978, after this meeting you 14 had with Mr. Miller?
15 A
I don't remember receiving any other 16 information.
17 Q
You don't remember receiving any information 18 with respect to the accident later in the evening or 19 the next day?
20 A
No.
21 Q
Were you still in Reading the next day, 22 March 30?
23 A
No.
24 Q
Did you return to work?
p_
(
l 25 A
Yes.
1 Lensos 218 O(~N 2
Q Did you obtain any further information 3
upon your return.to work?
4 A
Not that I recall.
lll 5
Q Following the incident on March 29, 1978 6
but before the accident at Three Mile Island on March 7
28, 1979, did you receive any requests to do work or 8
to study the March 29 incident?
9 A
I don't remember having received any, no.
10 Q
Did you participate in any studies of the 11 March 29 incident?
12 A
Not that I recall.
(~N 13 Q
So at no time between the incident on L.
14 March 29 and the accident a year later did you obtain 15 any further information that you can recall with 16 respect to this incident?
17 A
No.
I did have one other involvement 18 with the event, and that was related to the change of 19 power supply to the PORV.
20 Q
Maybe that will help me if I can ask, 21 generally, is it your recollection that the change of 9
22 power to the PORV was a change instituted at least 23 partially as a result of the occurrences on March 24 29, 1978?
['%d 25 A
Yes.
1 Lnnsoo 219
,m
(
)
2 Q
Are you aware of any other involvement Gi 3
in any other project or effort by GPU or Met Ed 4
which was in some respect related to information ggg 5
learned or events that occurred on the day --
6 information learned as a result of the events that 7
occurred on the day of March 297 8
MR. GLASSMAN:
Objection to the form.
9 You seem to be talking about some other 10 involvement as a result of an event.
I don't 11 know what you are talking about.
12 MR. BENEDICT:
Let's hear the question f~)'
13 back.
G 14 (Record read.)
15 MR. BENEDICT:
I will restate the question.
16 Q
Prior to the Three Mile Island accident, 17 were you aware that the change of power to the PORV 18 at Unit 2 which you worked on following the March 19 29 incident was at least partially a result of the 20 occurrence at the plant that day?
21 A
Yes, it was.
O 22 Q
I think my question was, were you aware 23 prior to the Three Mile Island accident that there 24 was a connection between the two things.
/si
'~
25 A
Yes, I was.
1 Lanese 220
(,)
2 Q
Were there any other projects or did you 3
do any other work which you understood to be related 4
in any way to the incident on March 29, J 978?
gg) 5 A
Not that I recall.
6 Q
Prior to the Three Mile Island accident 7
on March 28, 1979, were you aware that following the 8
March 29, 1978 incident an indicator light with respect 9
to the position of the PORV was installed in the 10 control room at Unit 27 l
11 A
No, I was not.
12 Q
Were you aware at any time prior to the 13 Three Mile Island accident on March 28, 1979 that there 14 was an indicator light with respect to PORV position 15 in the control room at Unit 27 16 A
No.
17 Q
Did you understand prior to the Three Mile 18 Island accident of March 28, 1979 that there was not 19 an indicator light with respect to the position of the 20 PORV7 21 A
No.
e 22 Q
Since the Three Mile Island accident, 23 have you come to understand that a position indicator
('
24 light with respect to the position of the PORV was Q.)y 25 installed at Unit 2 following the March 29, 1978
1 Lanose 224 2
incident?
O 3
A I just learned that fact.
(
4 Q
Today?
lll 5
A
- Today, 6
Q To exhaust your memory on this subject, 7
can you tell me today what it is that you know about, 8
if anything, about the indicator light at Unit 2,
an 9
indicator light related to the position of the PORV 10 at Unit 27 11 MR. GLASSMAN:
Are you excluding 12 information that he learned today in the 13 deposition?
(:)
14 MR. BENEDICT:
No, I want to make sure 15 that we have axhausted it.
16 Q
You can exclude anything you have just 17 learned for the first time through my questions.
18 A
Subsequent to the accident, I learned that 19 there was a PORV indication light and that it was a 20 demand-position light.
21 Q
What do you mean by demand position?
22 A
That it showed the position that the 23 operator demanded of the valve rather than the actual 24 Position of the valve.
25 Q
Did you know that the light indicated usuu 1
1 Lanese 222
\\m) 2 the presence or absence of power to the solenoid 3
which controlled the pilot valve on the PORV7 4
MR. GLASSMAN:
Know it when?
ll) 5 MR. BENEDICT:
At any time.
6 A
No.
7 Q
When did you first become aware that 8
there was an indicator light and it was a demand 9
indication?
10 A
Sometime after the accident.
11 Q
Was it within the spring and summer 12 following the accident?
3
,,)
13 A
It was within -- it was during the spring 14 following the accident, yes.
15 Q
By accident, you are referring to the 16 accident on March 28, 19797 17 A
Yes.
18 Q
From what source did you learn this 19 information?
20 A
I don't recall.
21 Q
Did you learn this information in the O
22 course of your performing some job-related function?
23 A
I don't believe so.
24 Q
You learned it because you were interested 25 in the accident and you were reading up on it?
1 Lanese 223
(_,)
2 A
I don't' recall where I heard it.
3 Q
so in sum, prior to the accident at 4
Three Mile Island on March 28, 1979, you recall having lll 5
no knowledge or you don't recall having any knowledge 6
about the presence or absence of any form of indication 7
on the Unit 2 control panels with respect to the 8
position of the PORV?
9 A
That's correct.
10 Q
Did you ever read any of the public 11 commission reports with respect to the Three Mile 12 Island accident on March 28, 19797 A
i,)
13 A
At most, excerpts from the Kemeny Commission.
14 Q
Would that include the staff reports or 15 are you speaking strictly of the one main volume of 16 the report?
Do you recall?
17 A
No, I do not.
19 Q
Do you recall reading anything from any 19 of the Rogovin or special inquiry group report?
20 A
I don't believe I have.
21 Q
Do you recall reading anything from any 9
22 Senate subcommittee or House subcommittee that 23 studied the accident?
(N 24 A
No, I haven't.
O 25 Q
Are you aware, from whatever source, of
1 LanOCO 224 e,=k 2
anyone else at GPU who prior: to the accident on O)
(v' 3
March 28, 1979 did any work that was related, as you 4
understood it, to the incident which occurred on g
5 March 29, 19787 6
MR. GLASSMANs Is he aware of that now?
f 7
MR. BENEDICT
'Ias.
8 A
There was a TDR that'was generated..iI 9
don't know who the people vere who signed the TT)R.
10 I believe Mr. Broughton signed it.
[
.s e
k 11 Q
Did you get a copy of that TDR7 i
12 A
no, I
j 13 Q
Did you see a-copy?
O
(,/
14 A
I don't renamber.
i 15 g
What is a TDE?
16 A
TDR stands for technical data report.
/
17 Q
Is it a GPU Service publication?
i 18 A
Yes, it is.
,I 19 Q
If there is-any particulariferm or purpose 20 for these TDR's, what is it?
21 A
The purpose is tomaintainajecor,d'of
/
g i ',,
22 work that has been performed in-house and to have a ',. '
q s
23 formal signature and sign-off anC to create a p e rm a ne r. t, 7..
',.q
', / '(
'j -
24 record of work.
,s
' 'j
- /^'s 25 (Discussion off the'redord betwee'n t e
'd k.
/
+1,Y
' \\ cy.3 s
rk s
q
.g-N y
'I r
1 L2noco 225 f g.[ ' t i
2' E
witness and his counsel.)
e o. 3
%.,/
/
4 3
Q Were the TDR's generated by GPU Service 4
readily availabls to anyone within the service company?
Jll 5
A They were available upon request.
\\
6 Q
Was there a practice of routing or 7
re. quiring a sign-off by any service company employees v
)
8 with respect to TDR's?
A 9
MR. GLASSMAN:
Are you talking now about 10 sign-off --
c 11 MR. BENEDICT:
Indicating that you 12 received it or read it.
Any procedure, formal 13 procedure, for routing or assuring that a TDR O
\\_)
14 came to the attention of cognizant people, s i 15 A
No.
'. i,
i 16 Q
Did you work on any TDR's prior to the Y
17 Three Mile Island accident on March 28, 19797
- \\
/
18 0.
A The April 23rd task force report was a
. t
~y' 19 TDR, and I had some involvement in that.
S..
3 5 ?F Q
Could I ask you if that is the document r
r 21 that we discussed earlier that is already marked as lh
'f/
,a 22 B&W 1867 23 A
Yes, it is.
24 Q
Have you worked on any other TDR's or Y ~%
~
I( _f 25 did you work on any other TDR's prior to the accident s
t_'..6,-
- 'J'o
.(
. i
+
-ll;
1 Lenoco 226 l
2 on March 28, 1979, that you can recall?
r^x
(
}
\\/
3 A
I had an involvement in one other TDR, 4
evaluating a transient in which there was a sodium ll) 5 hydroxide injection.
6 Q
Would that have been an event that 7
occurred or. November 7, 19787 8
A I believe so.
9 Q
An event that involved a loss of a main 10.
feedwater pump resulting in a runback and then a 11 reactor trip?
12 A
That's right.
13 Q
other than the work that you recall was p}
(_,
14 done with respect to a TDR concerning the March 29, 15 1978 incident, which you recall having been signed by 16 Mr. Broughton, do you recall anybody else who worked 17 on that project other than perhaps Mr. Broughton?
18 A
That project being the TDR --
19 Q
The TDR related to the March 29 transient.
20 A
I don't recall.
21 Q
Do you recall any other work that was done 9
22 during the year between March 29, 1978 and March 28, 23 1979 which related in any way, as you understcod it, 24 to the incident that occurred on March 297
()
25 A -
No, I do not.
L/
1 Lanese 227
)
2 Q
Do you remember seeing any documents or 3
other written or printed material that related to the 4
March 29 transient at any time prior to the accident ggg 5
on March 28, 19797 6
A I can't recall.
7 Q
So is it correct to say that prior to 8
March 28, 1979, the only information you recall 9
receiving with respect to the occurrences on March 10 29, 1978 was the information you received on the day 11 of the event from Mr. Miller in Reading?
12 A
That's correct.
[ ')
13 Q
I asked you earlier about whether you were v
14 aware of any work done within GPU which related to the 15 March 29, 1978 incident, in the year immediately 16 following it.
Would your answers be the same with 17 respect to work that you today are aware of occurring 18 within Met Ed?
19 A
Yes.
20 Q
So you are nct aware of any work being 21 done within Met Ed during that period?
22 A
No.
23 Q
And the syntax of that question was bad.
24 What I mean is even today you are not aware of any 7s
(
')
25 work that was done during that year immediately
1 Lanese 228
()
2 following; is that correct?
3 MR. GLASSMAN:
Relating to that event?
4 MR. BENEDICT:
Yes.
lll 5
A Not that I can recall.
6 Q
At the outset of the afternoon, you 7
testified that a large majority, if I recall your 8
expression, of your time during the March, April, May 9
period of 1979 was committed to work that related to 10 one or the other or both of the units on Three M'ile 11 Island.
12 Can you tell me specifically what work
('}
13 you were doing at that time that was occupying the N/
14 majority of your time?
Were there specific projects 15 that you can recall?
16 A
The chairmanship of asymmetric LOCA load 17 subcommittee.
The work on feedwater modifications to 18 TMI-2 as a result of the operating license conditions.
j 19 An issue related to small break LOCA that was affecting 20
'Jni t 1 and Unit 2, and in fact all the B&W plants.
21 Q
Was that issue'the issue that ultimately 22 was resolved by a cross-connect of the high pressure l
23 injection system?
24 A
That's correct.
7_.
(
25 Q
Go on.
1 Lnnoco 229
(~)
2 A
I think asymmetric LOCA loads and
's )
3 main feedwater modifications were occupying the bulk 4
of my time.
lll 5
Q You didn't mean to include emergency 6
feedwater, did you?
Was it main feedwater that you 7
were concerned with for Unit 2 at that time?
8 A
There were modifications being made to 9
both systems.
10 Q
Were these modifications related solely 11 to the issue of feedwater line breaks?
12 A
No, steam line breaks.
They did have some gg 13 impact on feed line break accidents as well.
t t
%J 14 Q
It was not related to LOCA response?
15 A
No.
16 Q
I would like to show you a document that 17 has been marked previously as B&W 409 for identification.
18 I would like you to tell me -- if you could review it, 19 please, and tell me whether you have ever seen this 20 document before or any part cf this document.
21 MR. GLASSMAN:
I assume your question is 22 outside of possible viewing with counsel?
23 MR. BENEDICT:
Yes, I am not talking about 24 in preparation for this deposition.
{}
25
-A I can recall seeing the information related
1 L0noco 230 2
to the engineering change mod.
3 Q
Could you tell me what the numbers that 4
are stamped at the bottom, what those pages are?
lll 5
A 21816, 21817, 21818.
There are some other 6
pages there that I may or may not have seen that 7
related to the ECM.
8 Q
ECM is engineering change modification?
9 A
Tes.
10 (Discussion off the record between the 11 witness and his counsel.)
12 Q
Maybe the best way to get this on the 13 record is to turn through the pages and ask you about
(
14 each separate item.
First turning to the first page 15 in from the cover, which is a memo to Gary Broughton 16 from V.
P. "odiaco, have you ever seen this before?
17 A
I don't recall.
18 Q
Turning to the next page which is marked 19 as 21816, do you racall ever seeing this reactor trip 20 report for Three Mile Island which is dated March 21 29, 19787 U
22 MR. GLASSMAN:
You are talking about the 23 one that also has the right-hand r.ide
. 24 MR. BENEDICT:
It says item 43 provided 25 5/4/79.
1 Lenoce 231
,N 2
A I am not sure.
(
i
's_)
3 Q
Y u don't recall ever seeing this?
4 A
No, I don't remember.
)
5 Q
Turning to the next page, which is called 6
superintendent's event report, dated 3/29/78, for Unit 7
2, have you ever seen this document before?
8 A
I believe so.
9 Q
Do you recall when you first saw this?
10 A
No, I do not.
11 Q
Do you recall whether you first saw it 12 before the Three Mile Island accident?
13 A
Yes, I think so.
f.
J 14 Q
You did first see it before the Three Mile 15 Island accident?
16 A
Yes.
17 Q
So this is a source of information with 18 respect to the accident that you didn't recall when 19 we went over it before?
20 A
That's right.
21 Q
Do you recall how it came into your 22 possession?
23 A
No, I do not.
24 Q
Did you actually have a copy of it or p3 25 did you see someone else's copy?
s
1 Lanese 232 2
A I don't remember.
3 Q
Did you read it when you saw it?
4 A
I am sure I did.
5 Q
It indicates in the middle of the 6
handwritten section under numeral 1,
"Also lost power 7
to electromatic relief B/S which opened relief."
Is 8
electromatic another way of saying the PORV7 9
A Yes, it is.
10 Q
Do you understand what, in engineering 11 parlance, the writer meant by B/S?
12 A
Yes.
13 Q
What does it mean?
14 A
Bistable.
15 Q
What is a bistable?
16 A
Bistable would be like a solenoid.
17 g
so __
18 A
A switch.
19 Q
The writer went on to write, "no indication 20 on console that electromatic opened."
Does that 21 refresh your recollection that prior to the accident 22 at Three Mile Island you knew there was not an 23 indicator in the control room of Unit 2 for the PORV 24 position?
25 A
No, it doesn't.
1 Lonose 233 m
(
)
2 Q
It goes on to say in the next to last
%j 3
sentence under numeral 1,
" injected some BWST and NaOH 4
tank to RCS."
NaOH is the chemical symbol for lll 5
sodium hydroxides is that right?
6 A
Yes.
7 Q
Does this refresh your recollection that 8
there was an injection of sodium hydroxide on March 9
29, 19787 10 A
No.
11 Q
Under the section headed numeral 2, it 12 says " Status at time of events:" has been written
["')
13 "532 degrees, four times ten to the minus ninth amps
%j 14 hot zero power physics tests in progress."
Could 15 you tell me today what your understanding is of hot 16 zero power pEyrict tests or what was being conducted 17 at that time at Unit 27 18 MR. GLASSMAN:
Objection to the form.
Are 19 you asking, one, as to his current understanding 20 of hot zero power Physics tests 21 MR. BENEDICT:
I will limit my question 22 as to what he understands today was going on 23 at Unit 2 on March 29, 1978 or thereabouts.
24 A
The reactor core had been loaded for the
_s
(
25 first time at TMI-2 and before having gone to full power
1 Lanese 234 I
[ ()
2 or any power, there were physics tests being conducted c
3 to measure parameters relating to the core physics.
r E
4 Q
Do.you know how the water in the reactor lll 5
coolant system was raised to 532 degrees?
6 A
By the heat from the reactor coolant pumps.
7 Q
So the reactor core was not generating 8
heat at this time; is that correct?
e 9
A No, it wasn't.
c 10 Q
Turning through the document that is i
11 headed Superintendent's Event Report which starts b
12 at document No. 21817, the document seems to include 13 at least through 21819, do you recall seeing this 14 three-page document?
Do you recall seeing all three 15 pages of this document?
16 A
Not specifically, no.
17 Q
Do you recall anything about the 18 circumstances or your seeing this document prior to 19 the accident on March 28, 19797 20 A
No.
21 Q
You don't recall having been asked to do E
22 anything with respect to this document, any work with
~
23 respect to this document?
K 24 A
I notice that there is a list of 25 reactimeter parameters back here in my handwriting.
=
1 Lcnoco 235
/~N 2
Q We will get to that.
If you need to refer
()
3 to it now, please do, but I am planning on moving 4
through the document.
lll 5
A At this point, other than the fact that 6
I have seen the sheet here, I have no recollection 7
of the work I did relating to this event.
8 Q
I am limiting my questions now to work 9
you did prior to the accident at Three Mile Island.
10 A
That's right.
11 Q
There is a piece of graph paper with a 12 trace on it on page 21820 which seems to show or 13 (g
purports to show RCS pressure as a function of time
(_)
14 on the transient of March 29, 1978.
Have you ever 15 seen this page before?
16 A
I don't remember it, no.
17 Q
Turning to 21821, which begins a three-page 18 document headed Sequence of Events Review, there is 19 some handwriting in the upper left-hand corner and down 20 at the bottom of the first page.
Have you ever seen 21 this document before?
22 A
I don't know.
23 Q
Do you recognize any of the handwriting on 24 the document?
l
/
\\
l
't
\\
- ._/
25 A
No.
1 Lnnoco 236 2-Q Do you recognize this type of document, t
~#
3 a sequence of events review?
4 A
I have seen similar printouts, yes.
(gg 5
Q Do you know where these printouts come from?
6 A
I believe it is the plant alarm computer.
7 Q
Is it your understanding that sequence of 8
events review printouts are generated at the site g
with respect to actual plant parameters and purport 10 to reflect actual plant parameters?
11 A
No, not plant parameters.
12 Q
Plant conditions?
13 A
Plant alarm conditions, yes.
/~h 4
'\\ -
14 Q
Some information about the state of the 15 plant, whatever?
I am not suggesting that it shows 16 all of the parameters or all of the conditions, but 17 it relates to actual plant events or circumstances?
18 A
No, it relates to equipment status.
19 MR. BENEDICT:
This was gone over in Mr.
20 Broughton's testimony, and we have gotten in the 21 record what is under these black marks; is that O
22 right?
23 MR. GLASSMAN:
You are talking about 24 certai~n pages here which appear to be blacked rm
(
)
25 out on the copy you have in front of you.
- Yes,
\\
1 Lanese 237 (A) wJ 2
we went over that with Mr. Broughton in his 3
d* position, and we made available to you at 4
your request the original copies of those ll) 5 documents in which I believe the black lines on 6
these pages were in fact yellow highlighting on 7
the original, and I believe in addition Mr.
8 Broughton did read that into the record.
For 9
your information, and I have to double-check 10 with what I have with me, I have a feeling it 4
11 is conceivable that this having come up once, 12 it may come up again.
I do believe I have the f) 13 originals of these with me, so if it becomes v
14 necessary to refer to the originals with the 15 highlighting, we can do so.
16 MR. BENEDICT:
If you can find them, I 17 would only like them just for the purpose if 18 seeing them in the original form would refresh 19 Mr. Lanese's recollection as to whether he has 20 ever seen the document before.
21 MR. GLASSMAN:
Bear with me while I O
22 review my briefcase.
I do indeed have that with 23 me, and they are available once again for your 7w 24 inspection.
Should I put them in front of the k) 25 witness?
1 Lnnoco 238 2
MR. BENEDICT:
Do you have the entire
'N 'I 3
Exhibit 409 with you, what became and was marked 4
as B&W 4097 It might be easier for the witness lll 5
to identify the material if he had the originals.
6 MR. GLASSMAN:
Yes, I do.
7 (Recess taken.)
8 MR. GLASSMAN:
I do have the originals of 9
the entire exhibit here and am making it 10 available again and placing it before the 11 witne s s at your request.
12 MR. BENEDICT:
Thank you.
1-3 BY MR. BENEDICT:
s/
14 Q
Could you turn through the first pages of 15 the original of Exhibit 409 and tell me whether seeing 16 the original changes your response as to whether you 17 had ever seen this material before or whether you 18 recognize or remember more about the pages we talked 19 about so far.
20 A
Not through the point that we left off the 21 last time, which was the sequence of events review.
)
22 Q
Looking at the original of 21821, is the 23 handwriting that appears on that copy before you 24 handwriting on the original of that document?
[v~)
25 A
No.
8
1 Lanese 239 q
l e
2 Q
In other words, it is a Xerox copy of a V
3 document that had writing on it?
4 A
Yes.
lll 5
Q The highlighting in yellow, turning 6
through the pages of this portion of the exhibit which 7
is through 21823, does seeing the highlighted sections 8
refresh your recollection as to whether you have ever 9
seen this particular sequence of events review before?
10 A
No.
11 Q
Turning to the documents, the first of 12 which is numbered 21824 f)
13 A
I may have seen this after the accident.
\\_-
14 Q
I am limiting my questions at this point to 15 before the accident.
16 A
I have no recollection of seeing this 17 before the accident.
18 MR. GLASSMAN:
Just so the record is clear, 19 the witness's remark seems to have related to 20 page 21822, and I just thought I would make that 21 clear, because the question seemed to be moving 22 already onto the next page.
23 MR. BENEDICTS I agree.
24 Q
At least a page of the sequence of events I,\\
25 review you recognize as having seen sometime after the
1 Lanese 240
(_)
2 accident?
3 A
Yes, that's right.
4 Q
But you don't recall seeing it before the jll 5
accident?
6 A
No.
7 Q
Looking at the documents that are marked 8
21824 through 21833, could you look through those 9
ten pages and tell me whether you remember seeing any 10 of those pages prior to the accident on March 28, 1979.
11 A
I don't know.
12 Q
Do you recall seeing any of them at any r~'
()s 13 time?
14 A
No, I can't recall.
15 Q
Moving to the page marked 21834, do you 16 recognize the handwriting on this document?
17 A
Yes, that is my handwriting.
18 Q
Do you remember preparing this document?
19 A
No, I do not.
20 Q
Do you remember ever seeing this document 21 before?
22 A
Yes.
23 Q
other than in preparation for this
(~N 24 deposition?
5
/
25 A
Yes.
l
1 Lnnoco 241 2
Q When do you'first remember seeing it?
p I
)
3 A
I am not sure.
4 Q
Do you remember the context in which you lll 5
saw it?
6 A
No.
7 Q
"urning to the next page, which seems to 8
be is the next page a continuation of the first page?
9 A
Yes, it is.
10 Q
Is this also in your handwriting?
11 A
Yes.
12 Q
Is it part of the same document as the 13 first page?
,\\'v)
(
14 A
Yes.
15 Q
Turning to the next page, which is 21836, 16 do you know whether this is part of the same document 17 or was it prepared by you at the same time?
18 A
Yes.
19 Q
I am correct in saying this is your 20 handwriting?
21 A
Yes, it is.
W 22 Q
Turning to a computer printout which is 23 numbered starting at 21837, could you look through --
24 (Discussion off the record between the em
/
p 25 witness and his counsel.)
1 Lnnoco 242 2
MR. GLASSMAN:
There was a lack of clarity
\\
\\~
3 in a prior question which the witness has indicated 4
to me resulted in his responding to the question lll 5
as he interpreted it, and yet I have to say that 6
he and I, as we discussed it, were unclear 7
as to the intent'of the question.
It is, as 8
you know, our intent to be as responsive as 9
possibles therefore, I want to point out the 10 issue.
11 There was a question as to, I believe, 12 relating to page 21834 and '5 as to whether Mr.
13 Lanese recollected the context in which he saw O
k/
14 it, and the question appeared to be directed 15 to his seeing it at some time subsequent to 16 his preparation of the document.
That was the 17 context in which it was answered.
The witness 18 apparently does have a recollection as to why 19 the document was prepared, if that should be of 20 interest, not that we care to volunteer 21 information, but we wanted to make sure the 22 witness was responsive.
23 Q
My recollection was that I asked you, did you reme'ber preparing it, and you said "no."
24 m
(])
25 So I ask a vou whether or not you remembered ever
1 Lanoco 243
(^T 2
seeing it, and you said "yes," and I assume if you
()
3 can't remember preparing it but you can remember seeing 4
it, then yes, you are right, I meant interpreting that lll 5
question seeing it sometime after you prepared it.
6 Do you now recall preparing it?
7 A
I recall why I prepared it.
8 Q
I will get into that.
9 A
I don't recall when I prepared it.
I 10 don't recall actually writing these numbers down.
11 Q
You don't recall doing the preparation?
12 A
No.
13 (x
Q You do recall having seen the document?
%]
14 A
Yes.
15 Q
And you acknowledge it is your handwriting?
16 A
Yes.
17 Q
And it was a document -- do you recall that 18 you created the document after the Three Mile Island 19 accident?
20 A
No, it was before.
21 Q
You craated this document before the Three 22 Mile Island accident?
23 A
I thought so, yes.
24 Q
I can only ask you for your recollection.
(_, '
25 I don't mean to change your mind.
1 Lnnoco 244 2
MR. GLASSMAN:
Which aspect of the
(
)
3 document are we now talking about?
4 MR. BENEDICT:
The first two pages, which l
5 I think was the only issue.
6 Q
I do note on page 3 of the three pages 7
that are stapled together in the original, there is a 8
date in the upper right that says 5/9/79.
Do you 9
recall preparing the second -- excuse me do you 10 recall preparing the page which is numbered 21836 11 at some time after you prepared the two pages 12 immediately preceding?
13 A
I am not'sure.
(
I
'/
14 Q
Is your best recollection today that the 15 first two pages at least were prepared sometime prior 16 to the Three Mile Island accident?
17 A
I am confused enough now after having seen 18 the date, I don't know.
19 Q
Moving on to what appears before you as an 20 original computer printout or a series of pages which 21 appear to be a computer printout, starting with the 22 document No. 21837 going through 21877, do you recall I
23 ever seeing those documents prior to the accident at 24 Three Mile Island?
,,()
25 A
No, I don't.
1 Lnnoco 245
(~3 2
Q You don't recall having seen it prior to
(_/-
3 the Three Mile Island accident on March 28, 19797 4
A No.
llh 5
Q I would like to go back and review these 6
documents with an eye toward whether you ever saw 7
them, that is to say, since we already discussed 8
whether you saw them before the accident, the question 9
would be:
did you see them at any time after the 10 accident other than in preparation for this deposition, 11 so why don't we go back to the first page of this 12 exhibit.
Starting with 21814, turning to the memo,
~x 13 I take it the memo is from Mr. Zodiaco to Mr. Broughton.
}
~_/
14 Do you recall ever having seen this document?
15 A
I am not sure.
16 Q
Do you recall ever having seen the 17 reactor trip report dated March 29, 1978, which 18 contains the document No. 218167 19 A
I don't remember.
20 Q
You don't remember whether you have ever 21 seen it?
22 A
No.
23 Q
Before or after the accident?
24 A
No.
7-~
5._ \\l 25 Q
I believe you testified that you believe
1 Ltnoco 246 (h
/~
)
2 you had seen at least the three pages of the 3
superintendent's event report, the textual material.
4 Those are documents Nos. 21817 through 21819.
Is it lll 5
correct your recollection is you saw those before the 6
accident?
7 A
I remembered seeing '817.
I assumed I 8
had seen the other two.
9 Q
But you do recall at least seeing '817 10 prior to the accident?
11 A
Yes.
12 Q
You, as I recall, did not recall ever
()
13 having seen the graph at 21820 prior to the accident.
14 Have you ever seen it other than in preparation for 15 this deposition?
16 A
I don't recall ever having seen it before.
17 Q
The same question with respect to the 18 sequence of events review.
Have you ever seen this 19 document?
20 A
Again, I can't recall.
21 Q
You said before that you had some 22 recollection at least of having seen one of the pages.
23 A
Yes.
24 Q
Do you recall the approximate time that fs
)
25 you first saw that?
6 1
Lanoco 247 j_
2 A
The page that I was referring to was
\\
)
3 page 21822, and I believe it was within several months 4
after the accident.
lll 5
Q Do you recall how that came to your 6
attention?
7 A
I believe Mr. Broughton suggested looking 8
at tailpipe thermocouple temperatures.
We were 9
considering whether thermocouple temperature could be 10 used to correlate electromatic relief valve flow, and 11 I took a brief look at that temperature.
12 Q
Other than the accident on March 28, 1979 13 and the event we have been discussing on March 28, (h
\\l 14 1978, have either of the units at Three Mile Island 15 experienced a failed open or stuck open PORV7 16 MR. GLASSMAN:
Objection.
Lack of 17 foundation.
The testimony, such as it is 18 here today, the questions of the examiner have 19 talked about an open PORV on March 29, 1978, 20 and there has been no testimony here that it 21
'was stuck or that it failed.
22 MR. BENEDICT:
I will restate the question.
23 Q
Are you aware of any incident other than 24 the two that I described in my previous question 78 )
25 that occurred at either of the units at Three Mile
1 Lenose 248
/~N 2
Island where the PORV remained open after reactor 3
\\_/
3 coolant pressure had decreased below the closure 4
setpoint for the PORV7 llh 5
MR. GLTSSMAN:
Objection.
No foundation 6
as to closure setpoint for a PORV.
7 MR. BENEDICT:
I will press my question.
8 I am sure I can connect it.
I guarantee it.
9 I don't have to connect it with this witness.
10 MR. GLASSMAN:
I would like to consult 11 with counsel.
12 (Discussion off the record.)
<-~
13 MR. GLASSMAN:
The objection stands, but v
14 the witness may answer.
15 (Record read.)
16 MR. GLASSMAN:
Objection for lack of 17 foundation.
There not only has been no testimony 18 with respect to PORV setpoints, but there has 19 been no tegtimony with regard to any possible 20 such setpoints being involved in the two 21 incidents with which counsel is concerned.
22 The witness may answer.
23 A
With respect to Unit 1,
I am not aware of 24 the PORV ever being open below setpoint.
rN i
i 1
'_/
25 With respect to Unit 2, I am not aware of l
J
1 Lanese 249 2
any other event in which the PORV was open below 3
setpoint, with the possible exception of the November 4
7 event, and that being because I can't recall the 5
closure setpoint of the PORV.
6 Q
Are you aware --
7 A
Although I do know that the PORV closed 0
in that event.
9 Q
Without express operator action?
10 A
Without express operator action.
11 Q
Are you aware of any other instances 12 besides the instances on March 29, 1978 and March 28, 13 1979 on Unit 2,
any instances with respect to either 14 of the two TMI units, where the PORV stayed open when 15 the reactor coolant pressure had decreased to the 16 ESFAS actuation signal?
17 A
No, that being 1600 pounds.
MR, GLASSMAN:
Same objection.
19 Q
You said something about Mr. Broughton 20 saying something to you about correlating tailpipe 21 temperatures to PORV flow.
Could you elaborate on what 22 he told you that summer and spring following the Three 23 Mile Island accident?
24 A
No.
I don't remember anything more than 25 that.
I believe he pointed me towards this particular
1 Lnnoco 250 2
document as a place where we could look at tailpipe
/ ')
V 3
thermocouple temperatures during the PORV actuation.
4 I only remember that we very quickly abandoned the lll 5
attempt to correlate thermocouple temperature and 6
PORV operation and flow.
7 Q
Why did you abandon that effort?
8 A
There wasn't enough data available.
9 There were too manyunknowns associated with the 10 problem.
11 Q
Did you at any time -- do you recaJ1 any 12 other occasion you had to look at any part of the 13 sequence of events review which is document Nos.
s_/
14 21821 through 21823 other than the occasion you just 15 mentioned?
16 A
No.
17 Q
Turning your attention now to the group 18 of documents bearing the document Nos. 21824 through 19 21833, could you review these documents and tell me 20 whether you recall ever having seen any of them at 21 any time with the exception of in preparation for 22 this deposition?
23 A
No, I can't recall if I had ever seen them 24 before.
(O
_)
25 Q
Are these the documents you were referring
1 Lonoco 251 2
to earlier in your testimony as the engineering change
,s 3
modification documents?
j 4
A There are some ECM documents associated llh 5
with this, yes.
6 Q
If I recollect your earlier --
7 MR. GLASSMAN:
I am not sure the witness 8
quite understood the question.
9 MR. BENEDICT:
I will try this:
10 Q
In your earlier testimony when I first 11 handed you the document and asked you to look through 12 it, you said that you may have seen or that you 13 believed you had seen, or some such qualified response, Ov 14 the material relating to the ECM, and I wanted to know 15 whether this is the material you were referring to.
16 A
The page that I believe I had probably seen 17 before was 21826.
18 Q
In closer review, do you now believe that 19 you can be more categorical in your answer either way?
20 A
No.
21 Q
You still think you may have seen it, but 22 you don't know for sure?
23 A
No, I don't know for sure.
24 Q
Do you have any recollection with respect p(,)
25 to this document as to the timing of your exposure to
1 Lunese 252
(_)
2 it if such occurred?
3 A
No, I generally didn't see ECM's, 4
Q so you don't believe you saw this at or I
5 about the time it is dated; is that whe.t you are 6
saying?
7 A
That's right, 8
Q Moving on to the document about which you 9
had some questions, starting with the two pages that 10 are 21834 and 21835, what is your recollection about 11 the circumstances surrounding your creation of this 12 document?
f~
(,)j 13 A
These are related to the reactimeter and 14 the channels on the reactimeter and which data would 15 he recorded.
I had determined where reacticeter data 16 could be found on a delog of the reactimater.
17 Q
Delog of the reactimeter' is the same as 18 sayit.. that you request the computer to print out data 19 gathered by the reactimeter?
20 A
It is a little more complicat.ed than.that.
1
~
21 Delog requires a translation of the information on the 22 tape and then a printout.
From my standpoint, I saw 23 a printout.
"l Q
24 Q
Is GPU or 'any company of GPU capa.ble of
(~)N,
(
L 25 doing that in-house?
,2 I
& /.
1 Lcnoco 253
.,, y 4
)
2 A
At the time, not that I an aware of.
q) 3 Q
The delogging had to be done by an outside 4
i vendor?
lll 5
A It had to be done by B&W.
6 Q
Why did you create this?
I understand 7
that is the subject matter covered by the document.
8 Why was the document created?
9 A
When you do have a delog, there are not 10 specific titles on top.
For example, there isn't a 11 title over the column that gives reactor power or hot 12 or cold leg temperature.
You have to know what each
')
13 column representa.
-(V 14 Q
Why did anybody want this information?
15 A
I believe Mr. Broughton was interested in 16 seeing it.
17 Q
Did he tell you why he needed this 18 information?
19 A
No, I don't remember now.
~
(. )
Q Did he ack you to do this?
t.
21 A
To provide the list, yes.
k l..
^ 22 J }.
r Q
Did you understand that it was going to be y
/'
23_
used in order to understand a delog printout of the
~#
24 reactineter data related to the incident on March 29,
( _q y'7, i
s'.., f.
1, 25
- 19737, o
n
.j l
4 s/
(t
)? >
l 1
Lanese 254 7(_)
2 A
At this point, I don't recall.
3 Q
You have no recollection of what data 4
he was going to apply this material to?
lll 5
A I would have had to have known at the time.
6 I don't reca11 now.
7 Q
Did you have any involvement after the 8
Three Mile Island accident with any review of data 9
pertaining to the March 29, 1978 incident, excluding 10 for the moment the issue of tailpipe thermocouple 11 temperatures which you mentioned earlier with respect 12 to the sequence of events review?
(~h.
i,)
13 A
No, unless this work was done after the 14 TMI-2 accident.
15 Q
My underste.nding of your prior testimony 16 was that you couldn't recall that by this work, 17 you indicated the three pages that are numbered 21834 18 through 21836.
My understanding of your prior 19 testimony was that you couldn't relate even that to a 20 review of data from the March 29, 1978 incident.
21 MR. GLASSMAN:
Is that a statement or a G
22 question?
23 Q
Is my understanding of what you said
(~' )
24 correct or are you changing what you said?
/
25 A
That is true.
I cannot relate this to the
1 Lnnocs 255
/~'
2 March 29 data collection.
If it was related to the N-)y 3
March 29, J978 event, I don't know whether it was done 4
before or after the TMI-2 accident, lll 5
Q At any time from the time you first heard 6
about this event from Mr. Miller in Reading on March 7
29, 1978, right up until today, have you ever been 8
involved in any review of data from that incident, 9
excepting for the moment the discharge line or tailpipe 10 temperatures we discussed earlier?
11 A
No.
12 Q
You can't recall any?
13 A
That's right, I can't recall any.
(-)
G' 14 Q
Can you in fact recall that you have not 15 been involved in such a review?
16 A
To the best of my recollection, I have not 17 been involved.
18 Q
I believe we were discussing the fArst 19 two pages of'what in the original is a three-page 20 document.
Turning to the page marked 23836, what, 21 if anything, can you tell me about the creation of 22 this document?
First it is true that you created it; 23 is that right?
24 A
Yes, I did.
(' 's,
's /
25 Q
Can you remember approximately when you
1 Lnnoco 256
('~'j 2
created it?
\\
,e 3
A It is dated May 9, 1979.
4 Q
Other than that, do you have any independent lll 5
rscollection of its creation?
6 A
No.
7 Q
Do you have any understanding of why it 8
was created?
9 A
I believe it was for the same reason as 10 the previous pages, to identify the channels on which 11 reactimeter data would be available for some event.
12 Q
Is this a continuation of the information 13 included on the two pages immediately preceding?
3 J
14 A
I don't recall.
15 Q
There is --
16 A
I can't tell from comparing the information.
17 Q
At the top, it says memo from Bill Nielsen, 18 Roger Falls.
Does that mean anything to you?
19 A
No.
20 Q
The memo was in fact at least prepared 21 by you, is that correct, or tl.is page?
22 A
The page was, yes.
23 Q
There is a word or two words, an acronym 24 and a word underscored about a fifth of the way down
,a
?
I
\\_/
25 the page.
It says " MUX," in block caps, " sheet."
1 Lenoco 257
,m
)
2 Do you know what a MUX sheet is?
3 A
MUX s a computer term.
With respect to 4
the reactimeter, there are MUX patterns and MU2 h
5 channels, and a MU2 pattern would identify what 6
information is located where on the tape.
7 Q
Turning to the computer printouts which 8
are the last 41 pages of the exhibit, can you identify 9
these pages?
Have you ever seen them before, up until 10 today, other than in preparation for this deposition?
11 A
I don't recall having seen them, no.
12 Q
Could you turn to what has been marked f) for the purposes of this litigation as page 21839..
13 v
14 g
y,3, 15 Q
On 21839, about midway down the page, it 16 says, "Please forward this to Louis Lanese."
Does 17 that refresh your recollection that you have aver 18 seen this before?
19 A
No, it doesn't.
20 Q
Can you identify this document type?
21 Can you identify -- is this a document of a type that 22 you have seen before, beyond being simply a printout 23 of a computer?
24 A
It is a MUX pattern printout of some
(.,_sl 25 information that was created by a code called SAS
1 Lanese 258
/m k_
2 statistical analysis system.
3 Q
Is this an output of reactimeter data?
4 A
It probably is.
lll 5
Q Do you know?
Can you tell from reviewing 6
the document?
7 A
No, I can't verify that.
8 Q
Turning to page 23842 9
A I can change that statement.
This 10 appears to be data in the form of reactimeter data.
11 Q
Can you determine from looking at the 12 document the incident or time period to which the data
)
13 relates?
14 A
Yes, I can.
15 Q
what time period or incident is that?
16 A
The date marked is 29 March
'78, the time 17 appears to be 83404.
I am sorry.
3404.
18 Q
3404 on the 24-hour clock is 2:04 in the 19 afternoon; is that right?
20 A
Yes.
21 MR. GLASSMAN:
I will allow you to ask a l
22 few more questions.
l 23 MR. BENEDICT:
I will get to where I am (N.
24 going.
\\._)
25 MR. GLASSMAN:
The witness has said he
1 1
Lcncon 259
(~
2 does not recall having seen this before.
D]
3 MR. BENEDICT:
I am not trying to get him 4
to testify as an expert on this.
lll 5
Q I am getting to this because I wanted to 6
know whether this refreshes your recollection with 7
respect to ever having seen this material before.
8 7.
No, it doesn't.
9 Q
Turning to page 21842, there is a date 10 at the upper right of that page which reads 1340, or 11 1 : 4 0 p.m., Friday, May 18, 1979.
Does that help 12 refresh your recollection as to ever having seen this
(~)T 13 material before?
't 14 A
No.
15 Q
Turning back to the page marked 21839 16 where your name appears, have you ever heard -- about 17 a third of the way down, there is an organization, 18 the name of which is the SAS Institute, and it gives 19 an address in North Carolina.
Have you ever heard of
, 20 this organization?
21 A
No.
22 Q
Do you recall at any time being asked by 23 Mr. Broughton or anyone else at GPU or at Met Ed to 24 obtain information related to reactimeter data or
("';
g
\\'
25 actual reactimeter data with respect to the March 29, i
1 Lanoco 260
/
)
2 1978 incident?
'Q 3
A As I said, the reason I prepared that 4
list, to prepare reactimeter data, was to allow it lll 5
to be identified.
I don't recall that I had been 6
asked to do it for the March 29, 1978 event.
7 Q
The documents th at you are referring to, 8
I take it, are the handwritten documen,*s in.your hand?
9 A
Yes.
10 Q
You were asked to prepare those by Mr.
11 Broughton, as I recall.
12 A
Yes.
/~'T 13 Q
What practice, if any, are you aware of b
14 at GPU for storing in a computer reactimeter data?
15 A
Now or before the accident?
16 Q
Let's start with up to today.
17 A
At present, there is a system implemented 18 for storing plant reactimeter data on the GPU system.
19 Q
Is the data only the data from the 20 reactimeter, or is it enhanced?
21 A
I believe that the data collected from 22 other sources can also be stored.
I am not sure 23 whether that is active presently, but it will be active.
24 Q
By other sources, you mean t
)
25 A
There is a plant data computer that is not
1 Lanese 261 t
\\/
2 the reactimeter.
3 Q
You mean other sources within the GPU 4
system?
llh 5
A Yes.
6 Q
Do you Nnow whether those other sources 7
or the sources other than the reactimeter data are 8
currently being included in this program for inclusion 9
on the computer?
10 A
I believe they are.
11 Q
Did this system exist prior to the 12 accident at Three Mile Island?
f'h
'x_)
13 A
- No, it didn ' t.
14 Q
Do you know when this system came into 15 existence?
16 A
It was implemented after the accident.
17 Q
Were you involved in its implementation?
18 A
No, I wasn't.
19 Excuse me.
Peripherally I was.
20 -
Q What was your involvement?
21 A
When the system was conceived, Gary asked 22 me for comments and recommendations on plant parameters i
23 that should be stored, especially with.espect to
(^h 24 being able to do mass balances on the reactor coolant
\\_/
25 system.
1 Lanese 262 gS
(_)
2 Q
To your knowledge, was Mr. Broughton 3
involved in the implementation of this program?
4 A
Yes, he was.
lll 5
g who else do you recall being involved in 6
the implementation of this program?
7 A
Mr. Keate n.
That is all I can recall.
8 Q
Do you have access to this information 9
today, you personally?
10 MR. GLASSMAN:
What information?
11 MR. BENEDICT:
The information that has 12 been put on the computer, reactimeter data and O)
(
13 other historical plant data.
14 A
Yes.
15 Q
Have you used this data base in the course 16 of your employment?
17 A
We are attempting to use that data base.
18 The delogging and implementation of the system is 19 still not complete, so that while we have reviewed 20 startup test data, for example, from Unit 1,
the 21 translating equations appear not to be completely 22 correct and the data isn't useful yet.
23 Q
I am correct in saying that what is being
("N 24 included on the computer includes at least certain
~_,I 25 historical plant data taken from the reactimeter at the
1 Lenocs 263
()
2 plant?
%_)
3 A
Yes, we have to specify two different 4
situations.
There is the ability in the future to llh 5
recall data from the plant, and that is operational 6
as far an I know.
Then there is the separate ability 7
to recall archive data from previous events in which 8
the reactimeter was functional and for which we now 9
have tapes, and that is not fully functional with 10 respect to Unit 1,
and I am not sure about the 11 capability to recall that data on Unit 2.
12 Q
There are two parts to the program.
The b(~~'s 13 first part is to have the ability to delog and 14 utilize reactimeter data obtained currently; is that 15 correct?
16 A
Reactimeter and other plant computer data.
17 Q
Is the ability going to include the ability 18 to access on a real time basis these information 19 sources?
20 A
Yes, I believe so.
21 Q
In other words, the intention at least, 22 whether or not it is functional, is for this system to 23 permit access to real time data concerning GPU plants 24 from a remote location?
n
\\
l A'
25 A
Including from a remote location, yes.
l
1 Lonoco 264 7 -S 2
Q The second part of this system, as I N._]
3 understood what you were saying, was to put on line 4
historical reactimeter data from past events; is that lll 5
correct?
6 A
Yes.
7 Q
Do you know how the selection process is 8
made with respect to which past events are included?
9 A
Anything that is available.
10 Q
The decision has been made to include 11 every tape, every event for which a reactimeter tape 12 exists?
13 A
Yes.
g-U 14 Q
Not how do you sign on to the computer, 15 but generally how is this information accessed, or 16 to be accessed?
17 A
By knowing the time, date, and reactimeter 18 parameters that are required, you can run a program 19 from a Parsippany office that creates a data file, 20 and that data file can then be printed or plotted as 21 required.
22 Q
By plotted, do you mean represented 23 graphically?
24 A
Yes.
l' )
(_j 25 Q
Have you received training or instruction
l 1
Lcnaco 265 l
i (V')
2 in the operation of this system?
l 3
A No, I haven't.
4 Q
Are there h
5 A
Not personally.
6 Q
Are there people within GPU Nuclear 7
who have been specifically trained with respect to the 8
utilization of this system or program?
. 9 A
Raactimeter data retrieval?
10 Q
That is what I am talking about.
11 A
We have a computer analyst in our group 12 who is capable of retrieving the data.
~
13 Q
Is it the expectation that this system g )s, r
14 will be accessed by only specific people, or will the 15
,information be available to engineers within GPU 16 Nuclear generally?
17 A
There is no limitation on distribution 18 of that information within or without GPU.
19 g.
Now I guess I am speaking a little more 20 specifically on the issue of actually sitting down 21 at a terminal and requesting the information.
Is 22 the expectation that engineers will do '
themselves 23 or that they will direct that it be a
24 functionary?
(3 k,/
25 MR. GLASSMAN:
Whose expectation are we
1 Lenosa 266 r'N 2
MR. BENEDICT:
Eis understanding of 3
management's expectations for this program.
4 MR. GLASSMAN:
I will let Mr. Lanese lhP 5
answer, but I should note that I have let this 6
line of questioning go on for quite a while, 7
It is far afield from anything relevant to this 8
litigation, so far as I can tell, If B&W 9
requests information that might be available in 10 our files or retrievable, like we have in the 11 past, we will be most cooperative.
12 MR, BENEDICT:
Let's cut this short, First 13 of all, you know as well as I do that Rule 26 14 lets me go into anything where I think that it 15 may lead to the disccvery of admissible evidence, 16 MR, GLASSMAN:
- Wrong, It's allowed where 17 it may lead to admissible evidence, not that 18 you think it may lead to admissible evidence, 19 MR. BENEDICT:
If you think for a moment 20 that reactimeter data with respect to past 21 events at Three Mile Island is not relevant to 22 this litigation, you have not been paying t
23 attention.
I do not agree with you that your 24 firm or anybody on your side of the table has
/3
(_)
25 been a model of responsibility with respect to t
w
1 Lenoce 267 p
' _)
2 complying with document requests, and I am not
(
3 going to be cut off from an area that I think 4
sounds terribly fruitful simply because you lll 5
have decided that I should stop, so why don't 6
we just let me go on with this so we can try to 7
finish up tomorrow.
8 MR. GLASSMAN:
I will let you continue.
9 I was just trying to express my frustration at 10 keeping Mr. Lanese here over something that is 11 at best tangential and appears to be leading 12 nowhere and taking a long time doing it.
13 You may continue.
14 Q
Again, you described this system as being 15 in two parts.
The second which we discussed was the 16 issue of making accessible historical data.
Do you 17 know wir.ther this process has been completed with 18 respect to the currently available historical data?
19 A
All of the tapes that we could retrieve 20 from the B&W archives have been installed on the 21 system and are available for processing, the problem 22 right now being that there may have been some errors 23 in the program that is going to be corrected.
24 Q
Do those errors relate to the translation Q,i 25 of this information?
1 Lanese 268
[V 2
A Yes.
3 Q
Whom did you understand to be the 4
supervisor of this project?
lll 5
A I believe Jerry Wiser has the responsibility 6
over plant data.
7 Q
Could you tell me what area Mr. Wiser works 8
in?
9 A
I am not sure.
10 Q
Could you spell his name?
11 A
W-i-s-e-r.
12 Q
Beyond the request by Mr. Broughton to
(
13 provide information with respect to what parameters 14 to make available on this system, have you had any 15 involvement in this computer project, if I can call 16 it that?
17 A
First of all, the request was the opposite.
18 Gary asked me what parameters were available.
He 19 didn't request me to make them available.
20 Q
When did he ask you this?
Do you recall?
21 A
Sometime after the accident.
22 Q
I thought I understood you to say that he 23 also asked you which parameters should be included,
(~')
24 partien'arly in order to be able to do mass balances.
(/
25 A
I am sorry.
That's right.
This is not now
1 Lanese 269
/N
)
2 reactimeter data.
This would be plant computer.
3 Q
In other words, he asked you two questions:
4 firstly, what data was on reactimeters, reactimete'r h
5 taper is that correct?
6 A
Yes.
7 Q
And the second thing he asked was if 8
there was any other data which you thought should be 9
included by reviewing the plant computer records:
10 is that correct?
11 A
From my experience in having done the 12 mass balance calculations on occasion and from just i
./
13 my general perspective of the plant design, what 14 parameters might be included on the list.
15 Q
Do I understand that you understood at 16 the time he meant parameters in addition to those 17 available on the reactimeter?
18 A
Yes.
19 Q
Then did you provide him with that 20 information?
21 A
For the plant computer, yes, I provided 22 him with my recommendations for parameters.
23 Q
Do you recall approximately when you
(
)
24 responded to his request?
v 25 A
That was in the spring and summer of
'79.
1 Lanoco 270 2
(~T Q
Was any reactimeter or other historical I
L./
3 plant data accessible on GPU or Met Ed computers 4
prior to the accident at Three Mile Island on March 5
28, 19797 0
A No, it was all stored at the B&W facility.
7 Q
In order to utilize the material at B&W, 8
it was necessary to request that B&W delog it, the 9
reactimeter material?
A First B&W had to find it, and that did II not happen, as it turned out.
Those tapes that were 1
still left were delogged by B&W, and they have now
-)
been peovided to us.
s/
14 Q
I think we are talking at cross purposes.
I meant prior to the Three Mile Island accident, GPU 16 or Met Ed did not have in-house the capability of 17 delogging the tapes of the reactimeter?
18 A
No, I guess there was that capability.
19 The process was that it could be delogged and there 20 was a printout on site and then the data was stored 21 in the B&W archives.
The actual delogging was probably 22 done in Lynchburg, but the general procedure was that i
23 there was a printout made on site, as I recall, shortly 94
~
afterwards.
/~s i
I 95
~
'v j Q
Did GPU prior to the Three Mile Island
1 Lcnoco 274 m
l 2
accident have the capacity internally, either GPU (Q
3 or Met Ed or some other subsidiary,.to make sense 4
out of the reactimeter tapes?
lll 5
MR. GLASSMAN:
Objection as to form.
I
-F don't know what you mean by capability.
I l
7 don't know what you mean by sense.
8 MR. BENEDICT:
I will take a chance on 9
my question.
It is just a discovery deposition.
10 THE WITNESS:
Could I hear the question 11 again.
12 (Question read. )
(~)T 13 A
They were dependent on the delogging of 14 the tape at Lynchburg.
15 Q
Do you know when the first reactimeter 16 data was loaded into the GPU computer system in I
17 response to this project or in furtherance of it?
18 A
The first loading of data into our 19 computers was immediately after the accident.
As I
20 far as the long-term project, that has been 21 completed only recently, although B&W provided the 9
22 delogged tapes perhaps a year ago.
23 Q
I beg your pardon?
24 A
They provided the delogged tapes perhaps
,_s
[
)
25 a year ago.
1 Lanese 272 k/
2 Q
What data was loaded immediately after 3
the accident?
4 A
The data for the first, perhaps, four lll 5
hours after the accident, maybe a little longer than 6
that.
7 Q
The March 28, 1979 accident?
8 A
Yes.
9 Q
Was there any other data that you know of 10 loaded at that early date?
Let's include the spring 11 and summer of that year.
12 A
It was continuously recorded and kept
(~)\\
\\_
13 available.
14 Q
To your knowledge, during that first six 15 months after the accident, was data relating to any 16 other event or transient at Three Mile Island loaded?
17 A
I believe the information that I just saw 10 was data that was loaded.
The March '78 event appears 19 to have come off of our system.
20 Q
You recognize the pages, the last 41 21 pages, of B&W 409 as being pages in the format of the 22 system we have been discussing?
23 A
No, they are not in the format of the
(' 24 system we have been discussing. v 25 Q What leads you to believe they were taken 4
1 L0nona ~ 273 {a') 2 off your system then? 3 A The notation GPU, the man number, G1279, i 4 which is a GPU notation, and the fact that it was lll 5 printed on remote 6, which is the printer in 6 engineering. 7 Q That is for GPU Service? 8 A For GPU. 9 Q So your understanding is that the printout 10 at the end of B&W 409 is a printout of data that was 11 then available through the GPU computer system? 12 MR. GLASSMAN: Whentwas what available? /~N 13 MR. BENEDICT: The information contained (,) 14 in that computer. 15 (Record read.) 1C A The printout dated May 18, 1979 was 17 available in some form through the GPU computer system, 18 although not directly accessible. 19 Q Was this same data available through the 20 GPU computer system prior to the accident at Three 21 Mile Island on March 28, 19797 22 A No. 23 (Recess taken.) l 24 BY MR. BENEDICT: / tb \\m) 25 Q You mentioned earlier that it was your
1 Lonoco 274 em 2 understanding that Mr. Wiser now has a supervisory 'w.) 3 role with respect to this computer project. Has he 4 always been the supervisor for this project? lll 5 A This project being the loading of 6 reactimeter data onto our system? 7 Q Yes. 8 A His responsibility is in managing and 9 controlling the data and he has always had that 10 responsibility. He is not actually responsible for 11 processing the information and delogging it. 12 Q Whom do you understand to have been 13 responsible for the conception and institution of this 7-~ k_ 14 program of loading reactimeter data initially? 15 A It was an idea that was conceived of by 16 Gary Broughton and me. 17 Q About what time did that occur? 18 A Within the first few months after the 19 accident. 20 Q Was this project or this view in your mind 21 an outgrowth of the original activity you mentioned (Il 22 of putting TMI-2 information with respect to the March 23 28, 1979 transient on the computer? 24 A No, I think it predated that. f)) i 25 Q Did it predate the accident at Three Mile m
I 1 Lenoco 275 / 2 Island? 3 A Yes. 4 Q Had you and Mr. Broughton discussed this lll 5 possibility prior to the accident at Three Mile Island? 6 A I can't specifically recall any discussions. 7 Q I am not asking you to recall the specifics 8 of a discussion. My question is whether you recall 9 that this topic was discussed by you and Mr. Broughton 10 at any time prior to the accident at Three Mile Island. 11 A I have a general recollection that our 12 plans always were to collect reactimeter data in order '~N 1? to understand plant transients. 14 Q How far back does "always" go? 15 A Approximately since the inception of the 16 safety analysis and plant control group. 17 Q That was in May 1978? 18 A October of 1978. 19 Q Do you recall who first broached the idea 20 between you and Mr. Broughton? 21 A No. 22 Q Were you receptive to the idea? 23 A Yes. 24 Q When you first considered it? i 's._' 25 A Yes.
1 Lenoco 276 rs 2 Q Did you think it was a good idea? ) (G 3 A Yes. 4 Q Did you take the idea or do you know lll 5 whether Mr. Broughton discussed the idea with anyone 6 who was his superior? 7 A I don't recall. 8 Q You don't know whether the idea ever got 9 beyond you and Mr. Broughton prior to the Three Mile 10 Island accident? 11 A No, I do not. 12 Q Did you ever write a proposal or drop 13 something in the suggestion box with respect to this 14 idea? 15 A Not that I recall. 16 Q Following the Three Mile Island accident, 17 how was this subject then presented to management? 18 Strike that. 19 I take it you do not recall any approach 20 to management with respect to this project prior to 21 the Three Mile Island accident, is that correct, 22 whether by you, Mr. Broughton, or by somebody else? 23 A I think there was Tne prior discussion l 24 with management. (- - (,/ 25 Q What-can you tell me about that discussion? l L i
1 Lanese 277 ,f - / 2 With whom was it? 3 A As I recall, after the April 23, 3978 4 event, a recommendation that I had made informally lll 5 as part of the TDR was that we have the ability to 6 recall plant data. 7 Q Did that recommendation, as you understood 8 it, include the creation of both halves or both aspects 9 of the computer program instituted following the Three 10 Mile Island accident as we discussed it? 11 A No, it didn't. 12 Q Which, if either, of the halves did it b) (_/ 13 include? 14 A The way it was implemented following the 15 event, which was really all I remember, was that we 16 made sure that the reactimeter was going to remain 17 available and would be a source of archive information. 18 Q Was that the full scope of your 19 recommendation, or did that satisfy the full scope 20 of your recommendation? 21 A It satisfied me, yes. 22 Q Prior to the Three Mile Island accident, 23 and putting aside the subject of the continued () 24 availability of the reactimeter, do you recall any %) 25 discussions between you and Mr. Broughton concerning 1
t 1 Lanese 278 ,(,,) 2 the implementation of a computer project such as the 3 one we have been discussing was implemented after the 4 accident? ll) 5 A No. 6 Q So the only recollection you have of any 7 suggestion or discussion that you and Mr. Broughton 8 had prior to the accident related to the assurance of 9 the continued availability of the reactimeter? 10 A I am sorry. That discussion was not with 11 Mr. Broughton. My recommendation was to Mr. Keaten. 12 Q I think I am confused. Didn't I understand s (_) 13 you to say that when I was discussing the inception 14 of the idea which then became ultimately the program 15 we have been discussing, which was instituted after 16 the accident, that you and Mr. Broughton had discussed 17 such a program prior to the accident? 18 A Yes. I misunderstood your original question. 19 That's correct. 20 Q What is it that is correct? 21 A The concept of collecting archive data O 22 from the reactimeter, to restate what I proposed to 23 Mr. Keaten as task force manager, was that there be '3 24 plant data collected for fut'tre use, and I believe in ,e ._) 25 combination, that recommendation and an independent
1 Lenoco 279 ex 2 recommendation that Mr. Broughton had made, the 'w j'\\ 3 reactimeter was left installed, which I found a 4 satisfactory resolution to my recommendation. lll 5 Q Prior to the accident at Three Mile Island, 6 .I did you discuss with Mr. Broughton a program whereby I 7 this historical data would be accessible through the 8 GPU computer, this data being historical reactimeter 9 data? 10 A I don't know that it took that form. 11 Q Not focusing on the form,but rather 12 the substance of the program, did you and Mr. Broughton 13 consider going beyond merely assuring that the 7-Y-) 14 reactimeter would be available and did you and he 15 discuss the possibility of making the information from 16 the reactimeter accessible through the GPU computer 17 system? 18 A I am not sure at this point. ' 1S Q Going back to your first recollection of 20 the inception of the program which we have been 21 discussing relating to the storing and accessing of 22 reactimoter data on the GPU computer, did that 23 conception occur after the Three Mile Island accident, 24 whether or not you discussed that idea with anyone? /^s (,) 25 MR. GLASSMAN: I will allow the witness to
r 280 i L0noco' 1 2 answer. I should note while I d.o acknowle dge. : ( ) ~ 3 that the line of 'pestioning which you have been <e 4 Pursuing in the last nuber of questions is 5 something which you are entiticI to pursue, I g 6 think we have been over the precise questions 'r can, rie t on wi e.h it. 7 a few times, but u 8 MR. BEN 50ICT: I think'you will -- I agree ~~ 9 with you that we have boen over'these' questions 10 in various forms. I believe the record will 11 reflect confusi.on if'not contradictory anrwe;s, 12 and that is why I'am trying to get as clear An 13 idea of what. :i. s going on as p'or:siblc o /% { ) ( L 14 ME. GLASSMAN: I will permic'you to contiinue-1 / i 15 'MR. BENEDICT: Lot ?.s' heve the questior. hsck, 16 and _ retype it here., / 17 (The reportcc ree.dcthe question as f;11ows: /. 18 "Goin7'back tc'<joLr first rbcollsedion of the ' inception of the program which we bave 19 been l g / l J,, 20 discus, sing; relating to the storing and accessing ./ / 7j 21 cf rWactimeter data on,.the GPU' computer, did that I " ['. , / y 22 conception occur after'the Three> Mile Island l _ l 23 ' accident, whether429 not you discuened that idea" l I ^ 24 with anyone?") /,,7 (' M ( l 25 MR. BENEDICT: I will strikeithat question
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o 4 0 4 d. 2 l, 1 Lnnoco 281 ll'3 / 2 and r. tart again. V 3 Q Did you consider prior to the Three Mile 4 Island accident the creation of a program for the i lh g, storing and accessing of historical reactimeter data? G A -I don't believe we ever discussed the / 7 program for doing that. 8 Q Right. I am not focusing on discussions 9 now. I am talking about your consideration of such an > [ ~ 10 idea, whether or not you discussed it. ~ t 11 A I believe th'ere was a consideration for ~ 12 collecting the information on reactimeter tapes. m; (L.J - 13 Q We discussed that. Do you recall having 14 considered at any time prior to the accident going 15 beyond that and creating a file accessible through the 16 computer of that material prior to the Three Mile & 17 Island accident? 18 'A I do have to change my previous answer. ,/v ' 19 I don't believe that we actually discussed storing ') P J 20 it on our rystem, storing reactimeter data on our ^ s' / 2L system. 5 k 1 22 0 Q I don't believe your answer said that. I g -l ~ am focusing -- we did discuss the concerns or the "j l ~ 23 4 1 l r"N - 24 recommendation that you made to Mr. Keat en that 'j \\ 25 reactimeter data be preserved and that the reactimeter I 1
1 Lnnoco 282 ) 1 2 be left in operation. Is that an accurate statement -[ \\- ~' 3 or summary of what you recommended to Mr. Kea ten ? 4 A There is a slight difference. Reactimeter k 5 data automatically is preserved at the B&W archives. 6 The only recommendation was that the reactimeter not 7 he disconnected. 8 Q Goir.g further than that, was there any time 9 prior to the Three Mi'le Island accident where you 10 considered the creation of a data base containing 11 reactimeter data which would be accessible through the 12 GPU computer? Did you sver consider that prior to the 13 accident? \\~ 14 A I don't remember now. 15 Q Do you know has Mr. Broughton ever 16 said anything to you that would make you believe that 17 he considered such a program prior to the accident? 18 A No, I don't recall him saying anything. 19 Q Considering the progran as it exists today, 20 what plants does it contain data from? 21 MR. GLASSMAN: You are talking about the 22 GPU program? 23 MR. BENEDICT: Yes. 24 A We have data for TMI-1 and TMI-2. J /~'s) t 25 Q Do you know whether there is any plan or a i
w 1 Lunsco 283 ('N intention to add information from ncn-GPU plants to GI 3 this system? 4 A We would have the capability of adding lll 5 that data. 6 Q Do you know whether there is any intention 7 at this point among management to obtain and add to 8 the data base that information, information from any 9 other plant other than Units 1 and 27 10 A No, I don't know. 11 Q Is there a manual or written guideline for 12 the use of the program related to this data base, rw 13 data base relating to historical plant information? NY 14 A I don't believe there is. 15 g whom would you speak with at GPU if you 16 wanted to access ths information contained in the data 17 base? 18 A Somnone from GPU information services. 19 Q Is that a part of GPU Nuclear? 20 A It is part of GPU Service. 21 Q Is there anyone in particular whom you 22 would rely on? 23 A I would start with Mr. Al L illy, L -i-1-1-y. 24 Q In what form can the data be recovered ('N, (_ 25 that is contained in this data base we have been
v 1 Lanese 284 , -~s ( ) N' 2 discussing? 3 A Either as a hard copy printout of the data 4 or in graphical form. lll 5 Q Is the graphical form on a cathode ray 6 tube? 7 A Yes, with the capability to make hard copy. 8 Q Is there any other source, bar graphs, 9 anything like that? 10 A No. 11 Q Why did you think it a good idea at the 12 time you recommended to Mr. Keaten the preservation ) (/ 13 or the retention of the reactimeter? Why did you think 14 that was a good idea to keep the reactimeter available? 15 MR. GLASSMAN: You are not asking him to 16 speculate; you are asking for his recollection 17 of his reasons? 18 MR. BENEDICT: Yes. 19 Q As I understood, that recommendation was 20 sometime in the summer or fall of 1978. Is that your 21 recollection? dBi 22 A Prior to that. If the April cooldown 23 report was issued i'.s August, then I made that i 24 recommendation prior to August. 25 Q When you made that recommendation in the
1 Lanoco 285 ( 2 summer or late spring of 1978, what were your reasons t 3 for thinking that the reactimeter should be preserved? 4 A It seemed like the most reasonable form ll 5 to preservo information to-be able to utilize it in 6 the future. 7 Q Did you think at that time it would be 8 useful for GPU to have real time access to the data 9 in the reactimeter or the data recorded by the 10 reactimeter? 11 A No. 12 Q Do you think it is useful today? Do you () 13 believe it is useful f".,: GPU to have that data 14 accessible in real time?- 15 A Yes, I do. 16 Q If there was a specific thing, what 17 changed your mind with respect to that? 18 A Living through the Three Mile Island 19 accident. 20 Q Did you -- 21 A In the headquarters building. 22 Q Is data accessible from the reactimeter -- 23 prior to the Three Mile Island accident, was data L 24 recorded by the reactimeter available in real time 25 in the. control room? i v.
1 Lnnoco 286 (^. (g, 2 A No. 3 Q Is it available today in -the control room? 4 A Not from the reactimeter. lll 5 Q Is it available anywhere on Three Mile 6 Island? 7 A Is data available? 8 Q The data from the reactimeter in real time. 9 A No, it is available from the plant computer 10 in real time. 11 'Q Is it the same data as the reactimeter 12 records? f~) 13 A There is an overlap in data. %J 14 Q Is that information which is accessible 15 today at Three Mile Island different from the data 16 which is accessible at GPU today? I am talking of 17 real time access. 18 A Can you restate the question? 19 Q Is tha data available in real time from 20 the plant computer, as you say, on Three Mile Island 21 -different from the data, the types of data, accessible 22 in real time at GPU headquarters? 23 MR. GLASSMAN: Today? 24 MR. BENEDICT: Today. p-V 25 A Yes.
1 LEnOSO 287 ['} 2 Q Could you describe the differences? \\J A There are additional parameters which allow 3 4 an analyst to better understand plant performance llh 5 so that he can benchmark. There is also other 6 information that would give additional information 7 about equipment performance directly without having 8 to ask an operator in the control room to provide the 9 information. 10 Q When did you learn that the reactimeter 11 would be left at Unit 2 on Three Mile Island? 12 A I don't recall. f^J) 13 Q It was prior to the T,hree Mile Island? \\, 14 A It was in response to my recommendacion 15 that there be plant data recorded. 16 Q Do you recall whether you learned about 17 it prior to the partial loss of main feedwater 18 incident occurring on November 7, 1978 at Unit 27 19 A No, I don't know. 20 Q You do, however, recall that it was before 21 the Three Mile Island accident? 22 A Yes. 23 Q Is the reactimeter available in Unit 1 24 as well? 25 A Yes.
1 Lanese 288 ,a i ) \\# 2 Q Is it a different reactimeter? 3 A I don't understand the question. 1 4 Q Is the reactimeter aa object? Is it a lll 5 thing or is it just a program in the plant's computer? 6 A It is a thing. 7 Q Are there two things on Three Mile Island 8 or is there one thing? 9 A There are two separate reactimeters, yes. 10 Q I would like to show you a document that 11 previously has been marked as B&W 408 and which is a 12 document of four pages with the document !!os. 21810 i s/ 13 through 21813. 14 (Discussion off the record between the 15 witness and his counsel.) 16 Q Can you identify this document? 17 A Yes, I can. 18 Q Could you tell me what it is? 19 A Mr. Broughton subsequent to the accident 20 created a file for training purposes of so-called 21 footprint data. 22 Q When you say subsequent to the accident, 23 you mean subsequent to the March 28, 1979 accident? f) 24 A Yes. The only accident we have had at ._/ s 25 TMI-2.
1 Lanese 289 (D 2 Q You say he created a file after the 3 accident containing footprint data? 4 A Yes. llh 5 Q What is footprint data? 6 A It was thermodynamic data from various 7 plant events that he used in training the TMI operators 8 in the use of PT plots. 9 Q What is a PT plot? 10 A PT plot is a means of graphically 11 determining the thermodynamic state of the primary 12 coolant system and also of the secondary system. (3 kl 13 Q Did you participate in the creation of any 14 of these footprint data files? 15 A I believe I provided computer printout 16 or computer information on pressure and temperature 17 for some of the events. 18 Q Have you ever seen these four pages before? 19 I don't remember if I have. 20 Q Were there footprint data files created 21 with respect to incidents other than the March 29, 22 1978 incident? 23 A There were footprints created for actual (h .j J 24 plant data as well as for computer analyses of x.J 25 postulated events.
1 Lanese 290 O (_j 2 Q Do you know whether with respect to actual 3 plant events there were footprint data files created 4 for any event other than the March 29, 1978 event? lll 5 A I believe they were created for all of the 6 events for which we had data. 7 Q Did you participate or assist in the 8 creation of any other footprint data files other than 9 the one that has previously been marked as B&W 4087 10 A I think I previously said that I may have 11 provided this data. As I think about it, I only 12 provided data for footprint files related to analyses 7-~) (_ 13 and not to actual events. 14 Q Can you describe for me how Mr. Broughton 15 would tse these in training of plant operators or 16 how he did use them? 17 A My understanding of what he did was to 18 provide the operator with this information on a real 19 time basis and ask them to plot the data, and using 20 the plot of thu data to determine the event that was 21 occurring. 22 Q In other words -- let's start at the 23 beginning. Had you ever heard of a footprint data /~^ 24 file prior to the Three Mile Island accident? Cf 25 A No. O
1 L0noco 291 [) 2 Q Do you know whether such things existed \\_/ 3 at GPU or Met Ed prior to the Three Mile Island 4 accident? lll 5 A No, they did not exist. 6 Q Do you know whose idea the creation of 7 footprint files for purposes of operator training was? 8 A Mr. Broughton's, I believe. 9 Q Did Mr. Broughton discuss with you this 10 idea? 11 A I remember him describing the concept of 12 a PT plot and mentioning that he was going to create ('] ~13 this type of data. This was subsequent to the accident. %/ 14 Q Did Mr. Broughton present this data to the 15 operators himself? 16 A Yes. 17 Q He was a lecturer for training? 18 A Yes. 19 Q Do you know whether Mr. Broughton did that 20 prior to the Three Mile Island accident? 21 A He did it after the Three Mile Island 22 accident. 23 Q Do you know whether Mr. Broughton ever 24 acted as a lecturer, whether or not with respect to ,Q 25 footprint data, did he ever act as a lecturer for
1 LcnGes 292 ,~ m -( ) 2 training purposes prior to the Three Mile Island 3 accident? 4 A No, he didn't. llh 5 Q Do I understand your description of how 6 Mr. Broughton used these to be that the operator would 7 be presented with the facts that appear on the first 8 page of the footprint data sheet which is 21811, 9 and the operator would be expected to plot this data 10 on a chart which showed pressure and temperature 11 as a function of time, and from this data determine 12 the event that it represented? rx ( l 13 A With the exception that the chart doesn't x_/ 14 show pressure and temperature as a function of time 15 explicitly, that's correct. It plots pressure versus 16 temperature, and each point is at a particular point in 17 time. In order to represent pressure and temperatur'e 18 in time, you would need a three-dimensional plot. 19 Q So one of the axes -- I take it the 20 horizontal axis is both temperature and time? 21 A No. can you look at 21812 and 22 Q Maybe you can 23 describe for me how this was done? f-24 A If you will notice, there is a point that t i J 25 has a half next to it. That would be the pressure and
1 Lanese 293 (~) (_) 2 temperature at one-half minute. Similarly, there would 3 be another dot, there is a 1 next to it. That is 4 pressure and temperature at one minute. That is how lll 5 you would represent a graph with three parameters 6 in two dimensions. 7 Q And the operators were expected -- were the 8 operators provided with a table or a graph similar 9 to the one on page 218127 10 A That is my understanding, yes. 11 Q So they would use this graph as a 12 diagnostic tool? /'h () 13 A correct. 14 Q By plotting onto it the footprint data 15 that was being described or being set forth by the 16 instructor? 17 A Yes. 18 Q And you provided data for footprint data 19 sheets with respect to FSAR analyses? 20 A No, with respect to restart analyses. 21 Q Would these be hypothetical transients? 22 A Yes. 23 Q or were these hypothetical transients? /3 24 A Yes. .] 25 Q Was one of the hypothetical transients a
1 Lnnoco 294 ,~() 2 loss of coolant accident through a break in the steam 3 space at the top of the pressurizer? 4 A No. lll 5 Q Do you know whether there is a footprint 6 data sheet created for such an incident? 7 A It is the one I have in front of me, isn't 8 it? 9 Q This is described -- yes. I am not 10 disputing that. I guess my question would be then, 11 this footprint data sheet is directed specifically that abtually occurred at Three Mile ' 12 at an event } 13 Island; is that correct? 14 A Yes. 15 Q And although it says that the data has 16 been adjusted for the exercise, it represents an 17 effort to set forth the trend that in fact occurred 18 at TMI-2 on March 29, 1978, for these 19 parameters? 20 A I don't know how Gary adjusted the data. 21 Q But is it your understanding that it is 1 22 at least accurate as to the trend of this data with 23 respect to the data, the event as it occurred on 24 March 29, 19787 'g-] \\ 25 A I don't know. I
1 Lnnoco 295 (~sv) Q Do you know whether there was a footprint 2 3 data sheet created for an accident similar to the 4 March 28, 1979 event? lll 5 A I believe there was. 6 Q Do you know whether there were footprint 7 data sheets created for the three other incidents 8 during 1978 in which high pressure injection was 9 actuated at Unit 2 of the Three Mile Island facility? 10 A It was my understanding that there were 11 sheets created. 12 Q Did you participate in the creation or the provision of information 5or any of those sheets? r3 13 b 14 A No. 15 Q Have you ever seen all the footprint data 16 sheets or a collection of them? 17 A I don't remember. 18 Q Do you know whether the footprint data 19 sheets that were created for Mr. Broughton's lectures 20 are collected in one place? 21 A Yes, they are. 22 Q Do you know where that is? 23 A The last time I saw the file, it was in 24 his office. p_ ) 25 Q can you approximate how many footprint
1 LSnaco 296 2 data sheets were created for use by Mr. Broughton _7_ ( I '~' 3 in training? 4 A No, I can't. lll 5 Q Did you ever attend one of Mr. Broughton's 6 lectures in which he used the footprint data sheets? 7 A No. 8 Q Did he discuss with you how he was going 9 to use them? 10 A Briefly, he did, yes. 11 Q Do you know what, if any, information was 12 conveyed to the operators at TMI-2 prior to the 13 accident on March 28, 1979 about the incident on A 14 March 29, 19787 15 A No, I do not. 16 Q Did you ever participate in any forum or 17 lecture whereby information with respect to that event 18 was transmitted to the operators prior to the accident? 19 A No, I didn't. 20 Q Do you know whether any such fora or 21 - 1ectures were held? 9 22 A No, I do not. 23 Q Have you ever seen any material that was 24 prepared prior to the Three Mile Island accident on fx t ) 25 March 28, 1979 which described the occurrence or vs O
1 Lanoco 297 2 aspects of the occurrence on March 29, 1978, other than f^) I%j 3 the documents and material we have discussed this 4 afternoon? g 5 A I believe I have seen the TDR. 6 Q That was the TDR that you mentioned that 7 Mr. Broaghton was involved with? 8 A Yes. 9 Q So other than that which we did talk about 10 earlier, can you think of any material? 11 A No. 12 Q Do you know today what, if any, information 13 the operators have been provided since the Three Mile 14 Island accident on March 28, 1979 about expected 15 discharge line temperatures as a result of flow 16 through an open PORV? 17 A No, I do not. 18 Q Do you know about any information provided 19 to the operators since the accident on March 28, 1979 20 which relates to the event on March 29, 1978, other 21 than the footprint data sheet we just d i.s cu s s e d? 22 A No, I do not. 23 Q Do you know what, if any, information has 24 been provided to the operators since the accident in ( ) 25 1979 with respect to the information provided by the 1
1 Lensco 298 /~] 2 PORV indicator light at Three Mile Island Unit 27 \\J \\ 3 A At which unit? 4 Q The operators, any licensed individual ggg 5 at Three Mile.I land or prospective licensed individual. 6 A They have been told that the indication 7 light is a demand indication and not an actual 8 indication. 9 Q My question was with respect to Unit 2. 10 Do you know if Unit 1 has a Poav indicator light? 11 A I believe it does. 12 Q Do you know what information is in fact (~ 13 presented by that light? \\v] 14 A It is the demand position. 15 Q Does it indicate the presence or absence 16 of electric power to the solenoid as does the Unit 2 17 light? 18 A I don't know. 19 Q How is it that you know that the operators, 20 at least some operators at Three Mile Island have been 21 told abcut the demand indication of the PORV light? O 22 A The indication light is labeled on the 23 control panel. 24 Q Are we talking now about Unit 2 or Unit 17 N> 25 A Unit 1.
1 Lanoco 299 f~} 2 Q Other than that, do you have any reason v 3 to believe that information has been conveyed to the 4 LPerators? 5 A Just a general recollection that they have 6 been told. 7 Q You didn't tell them? 8 A No. 9 Q In a lecture or something? 10 A No. 11 (Adjourned at 4:30 p.m.) 12 13 V 14 Louis C. Lanese 15 s Subscribed and sworn to before me ~ 16 this day of 1982. { 17 18 19 20 l 21 22 23 24 / 5, ) .5 ~....
1 CERTIFICATE 300 f' 2 STATE OF NEW YORK )
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- ss.:
CO M OF M YORK ) 3 4 I, JOSEPH R. DANYO , a Stenotype 5 Reporter and Notary Public within and for the 6 State of New York, duly commissioned and qualified 7 and authorized to adminster oaths and to take and g certify depositions, do hereby certify: 9 That the continued deposition of 10 LOUIS C. LANESE was taken 11 before me pursuant to adjournment, at the 12 offices of Davis Polk & Wardwell, Esgs., One p 13 Chase Manhattan Plaza, New York, New York, on 14 Thursday, March 25, 1982, at 10:15 o' clock in 15 the forenoon; 16 17 That I was attended upon the taking of said 18 deposition by counsel as listed on page 130 19 That said witness was previously duly 20 sworn to tell the truth, the whole truth, ar i 21 nothing but the truth, and that he was thereupon g 22 examined by counsel present; that I took down 23 the testimony of said witness in machine shorthand 24 and caused the same to be transcribed by a person kj 25 under my supervision. 1
c 1 301 2 I further certify that I am not of counsel O 3 or attorney for any of the parties in said 4 deposition and caption named, nor in any way G 5 interested in the event of the cause named in C_S 6 said caption; and the same applies to the person 7 who transcribed my stenotype notes. 8 IN WITNESS WHEREOF, I have hereunto set 9 my hand and official seal this day of Ard/ //, /Efd to / 11 M 18 g so,tps s. eamyo. - c ;) 14 15 16 17 18 19 20 21 ( 22 23 24 r^^: = (_ ! 25
l 302 INDE X WITNESS PAGE Louis C. Lanese, resumed. 130 E XHI B I T S B&W FOR IDENTIFICATION 605 Original of document bearing production Nos. WO 29131 through WO 29155 131 ( 696 Original of document bearing production Nos. WO 29115 I through WO 29130 132 a G O ,w-}}