ML20072H949
| ML20072H949 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/23/1982 |
| From: | Shetler J BABCOCK & WILCOX CO. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-06, TASK-2, TASK-6, TASK-GB NUDOCS 8306290830 | |
| Download: ML20072H949 (146) | |
Text
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
- -x GENERAL PUBLIC UTILITIES CORPORATION, a
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, s
-against-80 Civ. 1683 (R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT &
CO.,
INC.,
a Defendants.
- - - - - - - - - - - - - - - - -x b(N.
Deposition of The Babcock & Wilcox Company by JAMES R.
SHETLER, taken by Plaintiffs, pursant to agreement, at the offices of Kaye, Scholer, Fierman, Hays & Handler, Esqs.,
425 Park Avenue, -New York, New York, on Friday, April 23, 1982, at 9:40 o' clock in the forenoon, be fo re Nancy A.
Rudolph, a Shorthand Reporter and Notary Public within and for the State of New York.
(O g
DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 La x tNGTO N AVENUE WALTER SHAPlRO, C.S.R.
NEw YOnt. N.Y.
1oo17
)
CHARLES SH APIRC, C.S.R.
TE R.E PHO N E 212 - 867 8220 8306290030 820423
~
PDR ADOCK 05000289 T
]
I 2
2 Appe arance s:
3 4
KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs ggg 5
425 Park Avenue New York, New York 6
By:
ANDREW MacDONALD, ESQ.,
7 of Counsel 8
9 10 DAVIS POLK & WARDWELL, ESQS.
Attorneys for Defendants 11 One Chase Manhattan Plaza New York, New York 12 By:
ANN MCDONALD, ESQ.,
13
-and-KAREN E.
WAGNER, ESQ.,
14 of Counsel 15 16 Also Present:
17 DAVID TAYLOR 18 19 20 1
21 IT IS HEREBY STIPULATED AND AGREED by and 2o between the attorneys for the respective parties 23 hereto that the sealing, filing and certification 24 of the within deposition be, and the same hereby 25 are, waived; that the transcript may be signed l
1 1
3 4
-s
(_)
2 before any Notary Public with the same force 3
and e ffect as if signed before the Court.
4 IT IS FURTHER STIPULATED AND AGREED that ggg 5
all objections, except as to the form of the 6
question, are reserved to the time of trial.
7 8
9 JAME S R.
S H ETLE R, having 10 been first duly sworn by the Notary Public, 11 was examined and testified as follows:
12 MR. MacDONALD:
I would like to mark as
/
13 GPU Exhibit 503 a copy of your resume that 14 we were provided this morning by your attorneys.
15 (Resume o f J ame s R.
Shetler marked 16 GPU Exhibit No. 503 for identification as 17 of this date.)
18 EXAMINATION BY MR. MacDONALD:
19 Q
Mr. Shetler, is this a copy of your resume, 20 educational background and work experience?
21 A
Yes, it is.
O 22 Q
Your education,your resume states that you 23 received a BS in Chemical Engineer in 1971 from 24 Clarkson College.
25 That was your major, chemical engineering?
~
1 Shetler 4
()
2 A
Yes, sir.
3 Q
Did you take any courses in nuclear 4
e nginee ring?
ggg 5
A No.
6 Q
Did you take any courses related to l
7 nuclear engineering or atomic physics?
8 A
No, not that I recall.
9 Q
Upon your graduation from Clarkson, you 10 went to Babcock & Wilcox?
11 A
Yes, that's true.
12 Q
And from June 1973 till August 1975 I
13 you were in their engi'neering department?
14 A
Yes.
15 Q
What positions.did you hold during that b
16 period of time in the engineering department?
17 A
Various positions from engineer through 18 senior engineer.
19 Q
,What groups or sections within the 20 engineering department did you work for during that 21 period of time?
I 22 A
- Mainly the auxiliary systems engineering i
23 department or section, and also a section called plant 24 integration.
)
25 Q
When you first came to B&W in June of 1971, what section were you assigned to?
I-
1 Shetler 5
2 A
I don't specifically remember the name 3
of the section at that time.
4 Q
What was its function?
ggg 5
A The original function I was hired in for 6
was working with one of'the chemistry people on plant 7
chemistry.
8 Q
Who did you report to?
9 Ms. MCDONALD:
At that time?
10 MR. MacDONALD:
Yes.
11 A
The first job I directly reported to 12 Mr. Jack Hicks.
(
13 Q
And you functioned as an engineer in 14 the plant chemistry area?
15 MS. MCDONALD:
You mean was that his title?
16 MR. MacDONALD:
I asked him whether he 17 functioned as an engineer.
18 A
Yes, I functioned as an engineer.
19 Q
What duties did you perform during 20 that time period when you first came to B&W as an 21 engineer in the ar'ea of plant chemistry?
O 22 A
Review of chemistry limits for primary 23 plants and secondary plants, some various calculations 24 relating to plant chemistry.
25 g
..Were you working on any specific contracts?
y
-c,--
1 Shetler 6
A-(_)
2 1
By that I mean we re you working on any specific utility 3
customers that B&W was supplying equipment to?
4 MS. MCDONALD:
Mr. MacDonald, I will allow ggg 5
you to proceed somewhat further with this, but 6
pursuant to agreement, I believe you are 7
entitled to inquire into Mr. Shetler's duties, O
responsibilities and various positions; however, O
I do not believe that encompassed within that 10 is every detail of everything that he worked on 11 within those positions.
12 I will allow you to go further, but I want you to know that I will instruct him I4 not to answer if you go into too much detail.
i 15 MR.~ MacDONALD:
I think the agreement 16 talked about duties and responsibilities about 17 his employment as it progressed through B&W.
)
18 That's what I am asking here.
19 MS. MCDONALD:
Well, I am just telling you that I do not believe that the agreement 2
regarding duties and responsibilities includes I
22 l
every single thing a person worked on i
23 because that is all-encompassing.
t
(~N MR. MacDONALD:
Those are his duties and
')
\\
25 responsibilities.
I J
I Shetler 7
2 MS. MCDONALD:
Go ahead for a while.
3 I am just telling you I am going to stop 4
it if you go too far with this.
5 MR. MacDONALD:
ltead the question, please.
6 Q
The question is what particular utility 7
customers of B&W did you do work on during the time 8
that you were an engineer working in plant chemistry.
9 A
I don't specifically remember one way or 10 the other specific contracts that were worked on.
11 Q
How long were you working in the area 12 of this plant chemistry as an engineer?
13 A
Basically about a year, year and a half, 14 in that range.
15 Q
And what was the next job you held at 16 B&W7 17 A
I transferred into the auxiliary system 18 group.
19 Q
That auxiliary systems group was also a 20 group within the engineering department?
21 A
Yes, sir.
22 Q
Who headed the auxiliary systems group 23 when you were transferred in?
24 A.
Mr. Ken Schroder.
25 Q
What position did you hold at that time?
~_
1 Shetler 8
O t
2 A
Engineer.
(_)
3 Q
Were you in any section of that 4
particular group?
5 A
I am trying to remember organization a 6
little bit here.
7 We had an auxiliary system design section 8
of that group which I was in.
9 Q
What were your duties and responsibilities 10 during that time frame?
11 A
We were responsible for the design and 12 equipment specifica for the auxiliary systems.
13 Q
Did you work on any particular contracts 14 for any B&W utility customers?
15 A
Yes.
16 Q
Which ones?
17 A
I don't remember all of them, Florida 10 Power Corporation, TVA, Detroit Edison were some.
19 Q
Did you do any work on either the TMI-1 20 or 2 contracts during that time period?
' 21 A
I don't recall one way or the other 9
22 whether I did work on those or not.
23 Q
How long did you stay in the auxiliary 24 l systems group?
25 A
Until-some time in 1974.
1 Shetler 9
2 Q
And where did you go from there?
3 A
To plant integration.
4 Q
Who was your immediate superior in ggg 5
plant integration?
6 A
I don't recall his name right now.
7 Q
You were an engineer in that unit?
8 A
Yes.
9 Q
What were your job responsibilities?
10 A
To provide an integration function for 11 the auxiliary systems group and work with that 12 interfacing with analysis groups and with the
(
13 project management function.
14 Q
Did you work for either a gentleman by 15 the name of Mr. Swanson or-Mr. McBrice?
16 A
No, I did not work for them.
17 Q
When you say "an integration function for 18 the auxiliary systems group, project management and 19 safety analysis," what type of integration function 20 were you performing as an engineer?
21 MS. MCDONALD:
I object to the form.
O 22 I-believe it misstates what he testified to.
23 You may answer it.
24 A
The integration function between analysis 25 and project management and auxiliary systems was to
w i
1 Shetler 10 2
take the analysis requirements, put them into a 3
requirements document for the auxiliary designer, and a
4 then in turn review his design to verify that it met 5
the requirements.
1.
l 6
4 Q
In this period of time did you do any work
[
7 on the primary system?
1 0
A No, not directly on the system, no.
ir 9'
Q Did you do any work while you were in the 10 auxiliary systems group on the primary system?
11 A
No, not on the primary system.
12 Q
Did you do any work in the auxiliary systems 13 group or the plant integration group on writing or 14 reviewing procedures?
15 MS. MCDONALD:
You mean operating 10-procedures?
17 MR. MacDONALD:
Plant operating procedures.
l 18 3
,,, we did not review plant operating 19 procedures.
20 Q
Did you review or draft any B&W draft
-21 procedures on the primary system that was sent to O
22 utility customer's?
23^
A
" Operating procedures," can you be a little T
24 more specific?
'O.
25 Q
operating procedures, draft operating
_.,,...,c..
4 s.
y
~.
-4y y-
l 1
Shetler 11 l
2 procedures during the time that you were in the 3
auxiliary systems group?
4 A
No.
g 5
Q Did you work on drafting any type of 6
procedures during the time you were in the auxiliary 7
systems group or plant integration group?
O MS. MCDONALD:
May I have that back?
9 (Record read back.)
10 MS. MCDONALD:
I don't really understand 11 what you mean by " procedures."
12 MR. MacDONALD:
I am asking him if there 13 are any other types of procedures that he drafted 14 while he was in those groups.
15 MS. MCDONALD:
For use by utilities?
16 MR. MacDONALD:
Procedures that dealt with 17 the operation of nuclear plants that were 18 sent to utilities.
MS. MCDONALD:
0.K.
20 A
Yes, we -- not so much procedures that 21 would be used by the utility in operating the plant O
22 but general engineering guidelines on how we envisioned 23 the system should be operated.
24 Q
When you say " general engineering 25 guidelines" on how the system should be operated, j
4 1
Shetler 12 2
by actual control room operators?
3 A
Again, it wasn't detail step by step, 4
turn valve, open, push buttons.
It was a general lll 5
l philosophy of operation, but it would be by those 6
people who we re licensed to operate the plants.
7 Q
Did you prescribe steps in some of these 8
procedures providing for what operators were supposed 9
to do in certain situations?
10 A
Again, in general terms, not in detail.
11 Q
What did you call these types of 12 procedures?
()
13 A
System descriptions.
14 Q
Did you participate in reviewing or 15 drafting any operating specifications during the time 16 that you were in the auxiliary systems group or plant 17 integration group?
18 A
No, not that I recall.
19 Q
Did you participate in reviewing or drafting 20 any emergency operating specifications during that time?
21 A
Not that I recall one ' way or the other.
22 Q
Did you review any draft procedures during i
23 this period of time?
f-24 MS. MCDONALD:
I object.
I believe that's
' lN 25 been asked and answered.
1 Shetler 13 fN
)
2 MR. MacDONALD:
I am not quite sure that 3
it was.
4 MS. MCDONALD:
You may answer it.
ggg 5
A What kinds of draft procedures?
There are 6
all kinds of draft procedures.
7 Q
I am asking you if you reviewed any, and 8
then if I have an af firmative answer, then I will ask 9
another question.
10 MS. MCDONALD:
Again you mean draft 11 procedures for use of the utilities in operation 12 of the plant?
{
13 MR. MacDONALD:
I am talking about B&W 14 draft procedures.
I want to know whether or not 15 Mr. Shetler, during the time he was in auxiliary 16 systems or plant integration, reviewed any B&W 17 draft procedures. '
18 MS. MCDONALD:
If you are using some 19 sort of term of art, I think the witness should 20 be advised what you mean by that.
21 MR. MacDONALD:
Let's do it this way 9
22 if you have a problem with that.
23 Q
Mr. Shetler, what did you mean, or did you 24 attach any meaning to the phrase " draft procedures"?
' ~ '
25 Have you ever heard that during the time you were in
I shetler 14 2
auxiliary systems or plant integration?
3 A
The term sounds familiar.
I don't 4-necessarily associate it with a specific item.
g 5
Q Did you ever see procedures drafted 6
by B&W that carried the letters "DP"?
7 A
Yes.
O Q
Do you know what those letters stood for?
9 Didn ' t they stand for draft procedure?
10 A
Those were the draft procedures that I 11' believe the service department generated.
12 Q
My question is, did you ever,_ at any time 13 during the period you were an engineer in auxiliary 14 systems or plant integration, review or write any 15 portion of those draft procedures?
16 A
I remember having reviewed some of those 17 draft procedures.
Specific ones,I don't recall what IO ones, but, yes, I have reviewed some draf t procedures.
19 I do not remember ever generating any.
20 Q
so you remember reviewing some draft 21 proc-4re s but you don't remember whether you ever 9
22 wrote any yourself?
MS. MCDONALD:
I object.
I don't believe 24 that's what he said.
5 MR. MacDONALD:
He can correct me.
I am l
.~_
1 Shetler 15 2
just asking him a question.
3 THE WITNESS:
Could I have the question 4
again, please?
(lg 5
(Record read back.)
6 A
That's true.
I remember reviewing some; 7
again, not specifically what ones.
I do not recall 8
one way or the other having written any.
9 Q
The ones that you reviewed, what was the 10 purpose of your review?
11 A
Again, it was customer service or our I
l 12 service department generated the procedures, and they l
l
()
13 were asking for engineering review to assure that 14 procedure conformed with the design.
15 Q
Did you make comments on these draft 16 procedures and then send them back to nuclear service?
17 A
Yes.
18 Q
After you made comments and sent them 19 back to nuclear service, did you ever at any time 20 follow up to see whether those were incorporated into 21 the draft procedure?
O 22 A
No, that wasn't our function.
23 our function was to make comments and 24 provide them to the service department.
If they had
.25
- problems with the comments, their normal procedure was C
1 Shetler 16 2
to come back and discuss it with us.
3 Q
Did you ever see a copy of the draft 4
procedure after you made your comments that was sent h
5 to the utility?
6 MS. MCDONALD:
I object to the form.
7 A
Can you repeat the question again?
8 Q
Let me break it down for you.
9 Did you know af ter you sent your comments 10 on draft procedures back to nuclear service what course 11 those draft procedures then took?
In other words, 12 do you know whether those draft procedures were then 13 sent to the utilities?
MS. MCDONALD:
Ever?
Right away?
MR. MacDONALD:
Whenever.
I am asking him 16 generally first.
17 A
I was not involved in the detailed 18 procedures of how they processed the draft procedures 19 in the service department.
20 Q
You were not on a distribution or 21 routing for the draft procedure after you sent your 2~9 comments back to' nuclear service?
A Not that I recollect.
I don't really 24 remember one way or the other,.though.
25 Q
well,'do you recall ever receiving a draft
1 Shetler 17 2
procedure back from nuclear service after the time 3
you made your comments?
4 A
A completed procedure, is that what you lll 5
are trying to say?
6 Q
The same procedure that you made your 7
comments on.
8 A
I guess maybe I need a little clarification.
9 Are you saying after the comments had been 10 incorporated or just sent back or --
11 Q
My question is you had previously stated 12 that on some of those procedures you made comments
()
13 and sent them back to nuclear service.
14 I am asking you, at any point in time 15 after those comments were sent to nuclear service on 16 the draft procedure, whether you ever saw any of 17 those draft procedures again.
18 A
I really don't remember one way or the 19 other whether I did'.
20 Q
You have no recollection of ever receiving l
21 copies of those draft procedures, do you?
22 MS. MCDONALD:
I object.
It's been asked 23 and answe red.
I(-
24 You may answer.
! ~
i l
25 A
I think I answered the question.
I don't
1 Shetler 18
()
2 remember one way or the other whether I did.
3 Q
Did you have any other position within 4
the enginee ring department after your position in plant 5.
integration before you moved to nuclear service ggg 6
department?
7 A
No.
8 Q
And at approximately September 1975, you g
moved from plant integration in the engineering i
10 department to the nuclear service department of B&W?
11 A
That's correct.
12 Q
What group or section or unit within the
()
13 nuclear service department were you assigned to?
14 MS. MCDONALD:
You mean when he first 15 went into --
16 MR. MacDONALD:
Yes.
17 A
I don't remember the specific name of the 18 group at that time.
10 Q
What was its function?
20 A
Provide support services to customers 21 under contract.
O 22 Q
Who did you report to?
23 A
I believe the supervisor at that time was 24 Jerry Kennedy.
y 25 Q
-Up to,this period of time that you moved
~
1 Shetler 19 f ')
2 into the nuclear service department, had you ever s_j i
3 had any post-graduate courses?
4 A
I took some post-graduate courses in lll 5
business administration.
6 Q
Did you take any post-graduate courses 7
which dealt with nuclear engineering?
8 A
No.
9 Q
During the time that you were in the 10 nuclear services department, did you take any 11 post-graduate courses that dealt with nuclear engineering?
12 A
No, I did not.
' - ()
13 Q
When you were in the engineering department 14 of the auxiliary systems group and plant integration, 15 were you required to approve the procedure that you 16 sent back to nuclear service-to make sure that those 17 comments that you made were incorporated into that 10 proce dure ?
19 MS. MCDONALD:
Could I have that read back?
(
20 (Record read back.)
21 MS. MCDONALD:
objection; asked and answered..
l 22 You may answer.
23 A
Again, I do not recollect that we i
24 approved the procedure other than we made initial V(~g 25 comments on it..
That's all I recollect.'
1 Shetler 20 2
Q What was your function in the nuclear 3
service department at the time you first arrived there?
4 A
I was transferring down there to specifically lll 5
go to the Three Mile Island site to work in support of 6
GPU.
7 Q
This was in September 19757 8
A Yes.
9 Q
Did you go to the site in September 19757 10 A
I believe I arrived on the site around 11 October 1st or thereabouts in
'75.
12 Q
Who were you reporting to when you went
()
13 to the site?
14 A
Our administrative supervisor on site was 15 Lee Rogers but our technical supervision, guidance, 16 was through GPU.
17 Q
Who did you report to back in Lynchburg?
18 MS. MCDONALD:
I object to the form; no 19 foundation.
20 A
Again, administrative supervisor back in 21 Lynchburg would have been Jerry Kennedy.
22 Q
Is there anyone else back in Lynchburg who 23
- you reported to?
r~s 24 A
Not directly.
Obviously there is a chain U
25 of command, but as far as the direct supervisor back
1 shetler 23
\\
2 in Lynchburg, no.
3 The administrative supervisor, as I said, 4
was Jerry Kennedy.
lll 5
Q How long did you remain at the Three Mile 6
Island site?
7 A
Through August o
'76.
8 Q
Then where did you go?
9 A
I went back to the Lynchburg office.
10 Then the service department.
11 Q
What group or section, the same one you 12 had been working in?
C)'
(_
13 A
I believe the title of the group at that 14 time was operating plant services.
15 Q
Who was in charge of operating plant 16 se rvice s ?
17 A
Mr. Jim Phinney.
gh 18 Q
And you were still an engineer at chis 19 time?
20 A
I believe my title at that time was senior 21 engineer.
O 22 Q
You reported to Mr. Phinney?
23 A
Not directly to Mr. Phinney, no.
24 Q
To whom did you report directly?
25 A
I believe it was Mr. Baker at that time.
l d
1 Shetler 22 2
Q What were your duties in the position of 3
senior engineer in operating plant services?
4 A
At that time I was assigned with other g
5 people to an engineering research and development 6
administration study on refueling outages.
I Q
Did you work full time on that?
8 A
I worked full time on that through about 9
February, March of
'77.
10 Q
Then what was your job responsibility?
II A
I was requested by the GPU customer to return 12 to the TMI site for TMI-1 refueling.
13 Q
How long did you remain at the TMI site?
14 A
Throuah May, June of that year.
15 g
1977 7 16 g
y,,,
17 Q
Did you again report to Mr. Rogers at 10 that point in time as the site person for B&W?
I MS. MCDONALD:
I object to the form.
20 A
No.
21 Q
Did you report to any B&W personnel O
22 during this time' period?
A No, I was directly reporting to GPU 24 personnel.
25 Q
Did you report to any individuals at i
e r-
-w
1 Shotler 23 2
Lynchburg during that period of time?
3 A
Again, I had an administrative supervisor 4
in Lynchburg.
ll) 5 Q
Which was who?
6 A
Mr. Baker.
7 Q
After June 1977, what were your next job 8
responsibilities in the nuclear service department?
9 A
I went to work on an assignment with 10 Sacramento Municipal Utility District in Sacramento, I
11 California.
12 Q
What was your responsibility there?
13 A
I was their consultant, advisor in helping 14 them there execute their first refueling outage.
15 Q
Who did you report to at that site?
16 A
I reported to at that time -- he was 17 operations supervisor, Mr. Pierre Oubre.
18 Q
Who were you reporting to at B&W7 19 A
Again, I still had the same supervisor, 20 Mr. Baker.
21 Q
How long were you consultant to SMUD.on O
22 the refueling?
23 A
I was there until November of
'77.
i 24 Q
Where did you go from there?
25
.A Back to the-Lynchburg office.
s
. _ _. _ _.,. ~. _.
1 shetler 24
\\_)
2 Q
what were your responsibilities at i
3 Lynchburg?
4 A
Mainly R&R, a little rest and relaxation.
llh 5
Q when did.you give up the R&R and return 6
to full-time work?
1 7
A January '78 I returned to the TMI-1 Tite 8
again.
9 Q
Whst were your responsibilities when you 10 went back to the TMI site?
11 A
I was asked to come back by the customer 12 to be assistant for the outage coordinator.
13 Q
Unit 17 f
14 A
Yes.
I 15 Q
Eow long did you remain?
16 A
Until March of that year,
'78.
17.
Q Where did you go in March of 19787 18 s
A The Florida Power ' Corporation plant at 19 Crystal River.
20 Q
what were your responsibilities then?
21 A
I was the site manager for B&W involved 22 in the repair efforts, recovery efforts due to 23 j
an incident they had at Crystal River.
24_
Q How long did you remain at Crystal River?
25 A
August of
'79.
_._.m s.
I 1
't Shetler 25 s
s 2
\\
l Q
q Where did you go in August of '797
\\,
3 A'
I went back to the' Rancho Seco site at s
4 lSacrame'nto, California.
t
'S Q
what were your job responsibilities there?
l 6
A
.I was assigned as the B&W resident 7
engi.neer for Rancho Seco.
r 8
Q How long did you remain at Rancho Seco?
9 A
I remained at Rancho Seco as a B&W employee 10~;
until 1980, May.
i r
+
11 Q
Then you went to work for' SMUT?,
12 S(
A~
Yes, that is true.
13' Q
And through today you are employed by IM SMUD?
)
10 A
No.
g 16" Q
In August ~of 1981, you went' back to work 17 for B&W?
18 A-Yes, that is true.
.(
19 Q
'What were your job responsibilities bh'en l
20 y6u came back to B&W7
..'. b/
r, k
21
- A
'I was assigned as a'supervi,sor of a group 22 involved in steam generatoraleeving. I 23 Q
What were your responsibilities du'ringy "
i s. e 24
- the timd ' you were - vorking - for 'SM'JD?
~
l-
.- v f
- r
, ~,
L
- 25 A i. '
- First six months 'or Us'o I) was ins a shift-
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I Shetler 26 x
2 technical advisor training program, and then from 3
about January 1st of 1981 until the time I left, I was 4
the supervisor of the shift technical advisor group.
lll 5.
Q Mr. Shetler, in August 1975 when you went 6
to the TMI site, what were your job responsibilities?
7 A
I believe I went to the TMI site in October 8
of
'75.
My job responsibilities were to work for 9
GPU to take the Unit 1 procedures and modify them to 10 include the particular nomenclature valve numbering, 11 component numbering or references to locations that 12 might be different in that unit and update those I
\\m/
13 procedures for Unit 2.
14 Q
I assume when you say "for GPU," you were 15 still working and being paid by B&W at this time?
16 A
I was being paid by B&W at this time.
17 I had my technical direction from GPU.
18 Q
What other, or were there any other B&W 19 engineers on site along with yourself who were working 20 on TMI-2 procedures?
21 A
Yes, there were others.
22 Q
Who were they?
23 A
John Flint, Jordan Gmach, Stan Maingi and f')T 24 Bill corbin.
N_
25 Q
Were they all engineers in the nuclear
1 Shetler 27 2
~service department?
-3 A
Are they or were they?
4 Q
Were they at that time.
llh 5
A Yes, they were at that time.
6 Q
Did they all report to Mr. Baker?
7 Ms. MCDONALD:
If you know.
8 A
I really don't remember one way or the 9
other exactly how they reported.
10 Q
During this period of time that you were 11 at the TMI site, did you have periodic communications 12 with the personnel in Lynchburg?
I
)
13 A
Yes.
We dealt with people in Lynchburg 14 on various subjects.
15 Q
Did you do this both orally and in 16 writing?
17 A
Mostly orally, and I believe we did have 18 some written communications.
19 Q
Did you also receive written 20 communication and have oral communication from Lynchburg?
21 MS. MCDONALD:
Can I hear that again?
22 Q
Did you also receive written communications 23 from Lynchburg?
(~T 24 A
Yes, on a lot of different subjects,
\\-]_
25 administrative items included.
1 Shetler 28
- p
\\ l' 2
Q Included among what?
3 MS. MCDONALD:
I object to the form.
4 A
We were seeing a lot of the correspondence llh 5
that was going on between GPU and B&W, and it was 6
routinely routed through the office.
7 Q
That correspondence related to 8
technical matters as well as administrative matters, 9
did it not?
10 A
Yes.
11 Q
And communications you had either orally 12 or in writing with Lynchburg during that time related
()
13 to both administrative and technical matters, am I 14 correct?
15 A
Yes, it did.
16 Q
During that period of time, October '75 17 to August '76 when you reported back to Lynchburg 18 to Mr. Kennedy, was Mr. Kennedy an engineer?
19 Ms. MCDONALD:
Could I have that again?
20 (Record read back.1 21 MS. MCDONALD:
I object to the form.
9 l
22 A
I do not know what Mr. Kennedy's degree I
23 was in, whether he was an engineer or not.
He was a
(~j 24 manager in the service department at that time.
%j 25-Q What group within the service department?
a 1
Shetler' 29 O
2 A
Again, I think I said I wasn't sure of the i
i 3
title of the group at that time.
4 Q
.But its function was what?
h 5
A Again, the function, as I described it 6
be fo re, was support to operating plants.
7 Q
Who else aside from Mr. Kennedy in 8
Lynchburg, the period October '75 to August
'76, 9
did you have communications with?
10 MS. MCDONALD:
I object.
11 A
Various personnel.
I can't say that 12 I recall or remember the specific names of which 13 individual I talked to over the course of that time 14 frame back in Lynchburg.
15 Q
Who else did you communicate to on 16 any sort of periodic basis?
4 II A
The second foreman.
18 Q
Aside from the second foreman, who else?
19
.A I really didn't have any, quote, unquote, 20 routine communications going on.
21 Q
The procedures that you were reviewing 22 for Unit 2 ', did you review any emergency procedures?
23 3
Well, I was reviewing Unit 1 procedures 24 for markup for Unit 2 and I believe, yes, there were 25 some emergency procedures involved in that.
.m.
A
1 Shetler 30 2
Q I would like to show you a copy of GPU 3
Exhibit 352.
The first page of this exhibit contains 4
a letter from Mr.
L.
C.
Rogers to Mr.
J.
F.
Hilbish h
5 dated November 28, 1975, and my question is, down at 6
the bottom left of that particular document, do you l
7 see the initials "LCR/JRS/ BAY"?
O A
Yes, I see that.
9 Q
Is that "JRS" your initials?
10 A
I believe they are my initials, yes.
11 Q
Did you review the pressurizer system 12 failure emergency procedure 2202 1.5 in the course of 13 your stay during October '75 to August of '76?
14 A
As I recall, I remember reviewing the 15 equivalent of the Unit 1 procedure, marking it up for 16 the Unit 2 nomenclature, and having it typed back up 17 or up for submittal to GPU.
IO Q
In this letter Mr. Rogers states, the first 19 sentence, " Attached is the following draft' procedure 1
20 EP 2202.1.5 pressurizer system failure for your review."
21 Do you see that?
22 A
Yes, I do.
23 Q
Was it your understanding during the time p
24 that you were reviewing pressurizer system failure
.()
25 procedure that you were compiling a draft procedure for w
~
.m-
~
l i
l 1
Shetler 32
/
2 Unit 2 which was then to be sent by Mr. Rogers to GPU?
3 A
It's my understanding that I was apprising 4
the procedure based cut marking up the Unit 1 procedure llh 5
which would be an initial draft of a procedure that 6
GPU would then take, comment on, and use as they 7
desired.
8 It would not be in the same context as 9
draft procedures we discussed before.
10 Q
How would it differ?
11 A
Very simply in a draft procedure that 12 discussed before was an officially generated B&W we 13 document.
This is not.
14 Q
This is a document that you reviewed 15 and then submitted back to Met Ed as an initial draft 16 proce du re for Unit 2, however, is it not?
1 17 MS. MCDONALD:
I object to the form.
18 May I have the question back?
19 (Record read back.)
20 MS. MCDONALD:
I have the same objection.
21 You may answer.
22 A
Again, this is a document, as I have 23 stated before, based cn a review of the Unit 1 24 procedure.
It was marked up appropriately for the 25 Unit 2 arrangements and configuration and submitted to
1 Shetler 32 O.
2 GPU, but, again, I was working essentially as a GPU 3
engineer in doing this,not as a B&W official engineer 4
doing this.
llh 5
Q Whatever your perceptions may have been, 6
Mr. Shetler, at the time you were doing this, you were 7
a B&W paid employee, were you not?
8 A
I was administratively paid by B&W.
9 Q
Is there any difference between being 10 administratively paid and any other way during the 11 course of your employment for B&W7 t
12 A
I was paid by B&W.
)
13 Q
There was no difference during the time 14 you were paid by B&W at the TMI site and any 15 other course of employment while you were there, is 16 that right?
17 MS. MCDONALD:
I object.
18 Are you talking about how he got paid?
19 MR. MacDONALD:
He made the point of being 20 administratively paid by B&W.
I am trying 21
,to find out what he meant by that.
22 I understood that he was paid and employed 23 by B&W.
1 24
(~}-
A I was paid and employed by B&W under the v
25 technical supervision of GPU at that time.
1 Shetler 33 0
2 Q
I take it that during that period of time 3
that GPU was not responsible for hiring or firing 4
you, were they?
h 5
MS. MCDONALD:
I object to the form.
6 A
GPU was responsible for whether I stayed 7
there or not.
8 Q
I didn't ask you that.
I asked you whether 9
GPU was responsible for whether or not you were 10 hired or fired from your job at B&W at that time.
11 Were they?
12 MS. MCDONALD:
What do you mean by 13
" responsible"?
I object to the form on that 14 ground.
15 Q
Did you understand, Mr. Shetler, when you 16 were at the TMI site that GPU would be able to fire 17 you from your employ at B&W7 18 A
From my employ at B&W7 No, they cou.'d not 19 fire me from my employ at B&W.
20 Q
Did you understand when you were at the 21 site that GPU could in any way affect the salary 22 you were receiving from B&W7 23 MS. MCDONALD:
If you had an understanding A
24 about that.
' k,k.
25 A
Directly, no.
Indirectly, yes, in that when
1 Shetler 34 2
my administrative supervisors provided performance 3
appraisals, they usually asked the customer on how the 4
technical per*ormance was going.
Jll 5
Q But you understood that it was B&W who 6
was setting your salary and paying you, isn't that 7
right?
8 MS. MCDONALD:
I object to the form.
9 That's been asked and answered several times by 10 now.
11 A
I have answered it yes, I understand that 12 B&W was paying me.
t
()
13 Q
What other materials did you review 14 aside from the Unit 1 pressurizer system failure 15 procedure when you were conducting your review or 16 drafting the procedure which is EP 2202-1.57 17 MS. MCDONALD:
I object to the form.
18 A
I can't say that I specifically recall what 19 documents I would have reviewed for this particular 20 procedure.
21 Q
In general when you were reviewing 22 procedures, Unit 1 procedures in order to revise those 23 procedures and resubmit to GPU for Unit 2, what types t
gm 24 of material did you use?
-Q 25 A
GPU drawings.
There are records and
i 1
Shetler 35 1
l 2
files pertaining to alarm set points, et cetera.
3 Q
Did you use any of the technical 4
specifications?
llh 5
A In general I probably would have reviewed 6
the technical specifications.
I don't know specifically 7
whether I used them on this procedure or not.
8 Q
Did you use or review B&W limits and 9
precautions?
10 A
We would have used the B&W supply limits 11 and precautions as an input to generating procedures,
, 12 yes.
13 Q
Did you review the B&W set points document?
14 MS. MCDONALD:
I object to the form.
15 A
I would have used that as a source of 16 information.
17 Q
Did you use the FSAR for Unit 27 18 A
I don't specifically remember one way or 19 the other whether I did or not.
20 Q
Did you review any B&W topical reports?
21 A
I do not remember reviewing any B&W topical 22 repo rt s.
23 Q
Did you review any B&W safety analysis?
24 A
No, I did not review any B&W safety analysis.
l 25 It was not part of the function of the job.
l l
~.
1 Shetler 36 2
Q Did you review any B&W draft procedures 3
that had been prepared for Unit 17 4
MS. MCDONALD:
You mean prior revisions?
ggg 5
MR. MacDONALD:
Any prior revisions 6
other than the one he was working on of operating 7
procedures, of draft procedures.
8 A
No, I did not review any prior revisions, 9
other than use the latest revision of the document in 10 effect at Unit 1.
11 MR. MacDONALD:
I would like to mark as 12 GPU Exhibit 504 a three-page document, the O
13 j
first page of which is a copy of a file folder 14 labeled "EP 2202-3.5 NSS 5 Pressurizer System 15 Failure Stuck Open Spray Valve."
16 The next two pages, a copy of a memo 17 from J.
R.
Shetler to the file for EP 2202-1.5, a
18 handwritten memo.
19 (Three-page document, the first page of 20 which is a copy of a file folder labeled 21 "EP 2202-1.5 NSS 5 Pressurizer System O
22 Failure - Stuck Open Spray Valve," with attached 23 two-page memo, marked GPU Exhibit No. 504 for 24 identification as of this date.)
v 25 Q
Mr. Shetler, are the last two pages of this
l 1
Shotlor 37
).
2 document a copy of a document which you wrote to the 3
file in or about early January 19767 4
A Yes, it is.
ggg 5
Q During the course of your review of 6
procedures to be sent to Met Edison for Unit 2,
did 7
you understand that if you saw anything that needed 8
to be changed in the Unit 1 p roce dure, that you would 9
be responsible for making that change?
10 A
My understanding is if we saw anything that 11 we considered grossly wrong or of a safety concern or 12 anything like that, that we should make note of it 13 and change it, but that we were not to make changes 14 just for the sake of changes.
15 Q
I understand, and if I understand your 16 testimony correctly, you were reviewing the procedures 17 such that when you were ' sending them back to 18 Metropolitan Edison, you believed that they were 19 adequate for use in terms of protecting the Unit 2 20 reactor in the course of operation from damage?
21 MS. MCDONALD:
I object to the form.
22 You may answer it.
i:
23 THE WITNESS:
Will you read that back, i
l 24 please?
25 MR. MacDONALD:
Let me'try and break it j
1 Shetler 38
'(~)%
.2 down a little for you.
(
3 Q
Y u understood, and I take it from 4
your prior answer, that you were reviewing these 5
procedures and sending them back to Metropolitan 6
Edison for Metropolitan Edison's use of these 7
procedures on Unit 2, is that correct?
8 MS. MCDONALD:
I object.
9 A
I guess I am losing it.
I'm sorry.
10 Q
You understood, preliminarily you 11 understood that those procedures were to be used on 12 the Unit 2 plant, right?
()
13 MS. MCDONALD:
You mean this exact draft?
14 MR. MacDONALD:
I didn't say this draft 15 of the procedure.
I said the procedures that he 16 was involved in using that those procedures 17 were to be used on the Unit 2 plant.
18 MS. MCDONALD:
Right away.
l 19 MR. MacDONALD:
I didn't ask him right l
20 away.
21 A
My understanding is that the Unit 1 9
22 procedures we were reviewing and marking up would be 23 eventually used by GPU, maybe changed to some extent 24 or to whatever extent they wanted to, but the intent 7
(
'~
25 was'for use on Unit 2.
1
1 Shotlor 39
()_
2 Q
You understood that part of your review functi n was to make sure that those procedures as 3
4 you perceived them were safe for the operation of the 5
Unit 2 plant when you sent them back to Met Ed or GPU, 6
isn't that right?
i 7
A Yes, we had a responsibility to address 8
any concern we had about safety and where necessary 9
to point out or revise procedures as they should be.
10 Q
And you did that, did you not?
11 A
Yes.
12 Q
After you had sent the procedure to 13 Metropolitan Edison, did you continue to monitor changes
(
14 that might affect that procedure?
15 A
No, sir.
We were asked to do the initial 16 changes and pass it on.
17 Q
Did you maintain files for the procedures 18 that you worked on?
19 MS. MCDONALD:
Him personally?
20 MR. MacDONALD:
Yes.
+
l 21 A
Personal files; I recall at the time I had 22 some personal files, yes.
23 Q
Were there any other files where the 24 work that you were doing on particular procedures was 25 maintained?
i m
..e
1 Shetler 40 l
2 A
I believe there was also a file in the ffice f r the master copies that we generated.
3 4
Q At the B&W site office, is that what i
lll 5
you are referring to?
6 A
Yes, there was a file in there of 7
essentially correspondence that went out on this.
8 Q
Those files contained procedures that 9
you marked up in performing your job function?
10 A
The actually marked-up procedures?
I 11 really do not recall one way or the other whether they 12 did or didn't.
13 Q
Did they contain documents with your s
14 comments on them related to those procedures that you 15 were working on?
16 MS. MCDONALD:
Objection; asked and answered.
17 MR. MacDONALD:
I don't think that was 18 asked and answered.
19 MS. MCDONALD:
Well, the difference between 20
" marked-up" and " comments," if you mean a 21 difference, I think it should be clarified.
O 22 MR.'MacDONALD:
- Well, I' assume there can 23 be a difference between whether or not he marked
,f-24 up comments on a particular procedure and whether NJ 25 there were any other documents that reflected his
1 Shetler 41 2
comments on a particular procedure that he was 3
working on, such as a sheet of paper, a letter, 4
a memo, there can be a number of other things.
lll 5
A It may or may not have been depending on 6
what the subject or item was.
7 Q
When you left the TMI site 8
MS. MCDONALD:
Did you finish your answer?
9 A
I don't recall one way or the other what 10 may or may not have been in there.
11 Q
When you left the TMI site in August 12
'76, did those files remain at the office?
()
13 A
Which files are we talking about, the ones 14 that were maintained in the office or my personal 15 files?
16 Q
The ones that were maintained in the 17 office.
18 A
I don't recall.
I was not involved in 19 the maintenance of the files.
I don't know.
20 Q
Did you take your personal files with you 21 when you left the office?
O 22 A
Yes.
M Q
Were you asked at any point in time prior 24 to this deposition to look at those files and produce g
(.3 25 documen ts from those files relating -- or turn - documents f
6.,
1 Shetler 42 2
over f rom those files to your attorneys relating 3
to the work you performed at the site?
4 A
I was asked by counsel to review or see ggg 5
if there were any of my files that remained.
6 Q
Did you conduct that review?
7 A
Yes, I did.
8 Q
Did you turn over whateve r files there 9
we re that remained?
10 A
There were no files remaining.
11 Q
What had happened to those files?
12 A
I am sure in one of my many moves they
(
13 were appropriately discarded.
Periodically when I 14 would move, I would get rid of stuff I wasn't using, 15 and I had no need for those procedures or records as 16 far as I was concerned.
17 Q
Did you throw them away?
Were they sent 18 to central files?
19 A
I would have thrown the personal files l
20
- away, i
21 Q
Turning to GPU Exhibit 504 for a moment, 9
22 this particular document deals with a problem that 23 you thought should be corrected in the Unit 1 and Unit 2 24 l
procedures regarding stuck open spray valves?
~~
l
%./
l 25 MS. MCDONALD:
Is that a question?
l t
I Shotlor 43 2
MR. MacDONALD:
Yes.
3 A
Yes, this involves a problem that was 4
uncovered.
gg(
Q Did you uncover this problem?
6 A
I believeat found out about it through a 7
discussion I had through an individual in Lynchburg.
r 8
Q Who was that?
9 A
I don't specifically recall now who it 10 would have been.
-11 Q
someone within the nuclear service 12 depa rtmen t?
13 A
It could have been services; it could 14 have been engineering.
I am not sure who.
15 Q
Do you recall any other instances 16 based on conversations or communications you had with 17 Lynchburg where problems' like this were discovered 18 relating to either the Unit 1 or Unit 2 procedures 19 that you were working on?
20 A
I don't recall any other specific-instances.
21 Q
This problem was a technical problem, 9
22 was it not, relating to the substance of what was in 23 the procedure?
24 A
Yes, what the procedure said based on O
M-late r analysis.
It was a record that needed.to be
I shotlar 44 2
changed.
3 Q
And what you were doing was sending a 4
memo to the file reflecting that need for a change?
l llg 5
A Yes. What I was doing here was documenting 6
the fact that a change was needed.
7 Q
Did you also notify Met Ed regarding the 8
ch an ge ?
9 A
Right now I don't simply recall whether 10 we wrote a separate letter to Met Ed or notified them 11 in any way, shape or form.
12 Q
You made these comments, did you not, at
(
13 a time after you had performed your initial review of 14 the TMI-2 procedure for pressurizer system failure?
15 MS. MCDONALD:
Could I have it back, please?
16 (Record read back.)
17 A
Yes, this comment was generated after 18 we marked up the Unit 1 procedure and after I had 19 submitted it back to GPU for their use.
20
-Q It's a fact, is it not, that you were l
21 making these comments because you felt that these
.O 22 changes should be made in Unit 1 and Unit 2 procedures 23 in order to have those procedures adequately provide 24 for the safe operation of a nuclear plant?
OG 25 MS. MCDONALD:
I object to the form.
1 Shetler 45 2
THE WITNESS:
Can you repeat the question, 3
please?
4 Q
You understood, did you not, when you g
5 were making these changes that the reason you were 6
making the changes was because they were required in 7
order to have the procedure reflect what you 8
believed was necessary for the safe operation of the 9
plant according to that procedure?
10 A
I felt it needed to be made that the 11 present procedures were not correct to the 12 operator.
If they were not made, they would 13 take them to a low pressure condition where he would 14 trip.
That did not affect the safety of the 15 plant but it could be misleading to the operator 16 and needed to be treated.
17 Q
So you felt the actions and the procedures 18 had to be clarified so they would not milead the operator 19 in this action?
20 MS. MCDONALD:
I object to the form.
21 A
Well, in this particular instance they 9
22 we re giving the operator direction that was not correct.
23 Q
The initial procedure?
N A
That's correct.
. 25 Q
And you were changing or recommanding that
(
1
.Shetler 46
. ()
2 that change be made so that he would not be misled?
A S
that he would have 3
4 MS. MCDONALD:
Let him finish the (l(
5 question.
6 Q
So that he would not be misled?
7 MS. MCDONALD:
I object to the form, 8
and it's been asked twice, I believe.
9 A
He made the change so that he would have 10 the correct instructions.
11 Q
Well, I believe that you stated in part 12 to an answer a minute or so ago that if he didn't
(
13 have those correct instructions,Rhe might be misled, 14 isn't that right?
15 MS. MCDONALD:
What he said a few 16 moments ago will remain on the record.
17 MR. MacDONALD:
I am asking him.
He can i
18 say what he wants.
19 MS. MCDONALD:
What is the question?
20 Q
The question is, as I just stated, you i
21 were making these changes so that the procedure would O
-22 he correct and so that the operator would not be 23 misled by the wording of the original procedure which O~ -.
24 you had submitted to Met Ed, isn't that correct?
25 THE WITNESS:
Could I hear that question I
u
- - - -.. - ~...
l I
1 Shetler 47 2
back again, please?
3 (Record read back.)
4 MS. MCDONALD:
I object to the form.
lll 5
A Again, I am not so sure.
I am hung up 6
with the word " misled" as it is providing him with 7
inaccurate information as to what would happen.
8 Q
What did you believe or understand would 9
happen if the change was not made?
10 A
If he did not change and the valves stuck 11 open in reality, it could go to the point where you 12 had a low pressure trip.
(
13 Q
Which was not what the original procedure 14 provided for?
15 A
Which was not what the original procedure 16 implied.
17 Q
So the original procedure provided 18 instructions that would in effect mislead the operator 19 if he was to follow those, isn't that correct?
20 MS. MCDONALD:
Objection.
This has i
21 been asked many times now.
22 MR. MacDONALD:
I still haven't gotten 23 an answer to its that's why we are asking it.
l 24 MS. MCDONALD:
He can answer it.
v L
25 =
THE WITNESS:
Can you repeat the question
1 Shotlor 4s 2
so I make sure I answer it properly?
3 Q
It is a fact, is it not, Mr. Shetler, that 4
you were changing or proposing in your memo to the file the change to the procedure so that the operator llg 5
6 would not be misled by the original instructions that 7
had been transmitted to Met Ed by B&W7 g
MS. MCDONALD:
I have the same objection.
9 A
I need help with the word " misled."
All 10 I am looking at is I am changing it to provide the 11 correct immediate actions that would happen.
12 Q
You understood, didn't you, that in 13 looking at the prior procedure, the operator
,.O 14 encountered a situation that was not consistent with 15 that and that he would be misled by that initial 16 instruction, did you not, and that's why you were 17 proposing this change to the procedure?
18 MS. MCDONALD:
I object to the form.
19 A
Again, I was recommending the change in 20 order to provide the correct symptoms -- I'm sorry, l
21 not the correct symptoms, but the correct automatic 22 _
action that would happen based on more recent analysis.
23 The fact that the operator may or may not f
24 have been misled by-that, I don't know.
O d'-
25 Q
Well,.Mr. Shetler, didn't you understand
1 Shetlor 49
(
2 that if the operator followed your previous instruction 3
that you provided to Met Ed a few months before 4
January 1976, that he would be misled in that lll 5
situation because he would be seeing symptoms 2
6 occurring that were different from those instructions?
7 You understood that, didn't you, and that was indeed j
8 the reason why you made the change?
9 MS. MCDONALD:
Object; I would like that 10 back.
11 (Record read back.)
12 A
No.
1, they were not my instructions.
j 13 They we re the instructions that were in the Unit 1 14 precedure.
15 No.
2, they would not change the symptoms.
16 The symptoms as they are written would have stayed the 17 same.
The symptoms would stablize at 2100 pounds 18 but would continue to decrease in pressure.
19 Q
That's all fine, Mr. Shetler, but my' t -
20 question is, didn't you understand that the change 21 that was made,that you made, was for the purpose of l
22 alerting operators that the symptoms or actions or 23 words or instructions that were used in the initial 24 procedure were wrong and that if indeed they l
/~T f
('"/
Zi relied on them, they could be misled in a situation L
1 Shetler 50 0-2 whe re the spray valve stuck open?
3 MS. MCDONALD:
I object to the form.
4 A
Again, the correction wasn't put in to llh 5
clarify and make the immediate actions that followed 6
the symptoms correct, and if they were changed, then 7
it is conceivable that the operators could be misled.
8 (Re ce s s taken.)
9 BY MR. MacDONALD:
10 Q
Mr. Shetler, prior to the time you 11 conducted your review of the pressurizer syster 12 failure procedure for Unit 2, had you had any
(
13 training on the simulator at B&W?
14 A
I had a brief one-week, half-day 15 introductory course they offered to engineering 16 people more or less to outline system operation.
17 Q
When did you take part in that one-week 18 course?
19 A
I really don't know.
I don't specifically 20 remember the date. It was prior to going to TMI.
21 My first field assignment, that's all 22 I remember.
23 Q
Was it immediately prior -- and by that 24 I mean within a year prior -- to the time you went l
25 or was it some time before that?
\\
1 Shotlor 51
()
2 A
Again, I don't remember specific -dates as 3
to when that occurred.
4 Q
What type of instructicn did you lll 5
receive at that one-week half-day introductory course?
6 MS. MCDONALD:
Can I hear that again?
7 (Record read back.)
8 A
My recollection is that it was an 9
instructor would go through a certain evolution, 10 startup, or whatever, and show us how the plant might 11 respond to that, what instrument you might look at, 12 what controls you might have to push, and then give (G~h 13 us a chance to get our handa on the controls.a little 14 bit and see how it would react.
15 Q
Did you.have any clas'aroom instrugtion 16 that went along with the simulator training?
17-A I do not remember any classroom instruction 18 while I was at 19 Q
Did you receive any training in off normal 20 or abnormal operation of the plant?
21 A
Yes, we went through various type failures.
22 Q
Did you have transient training on the 23 I simulator on loss of coolant accidents?
24
'A Yes.
(~h
's 25 Q
Did you have transient training on the 7v----
I Shetler 52 2
simulator on failures of valves at the top of the 3
pressurizer?
4 A
I do not remember any specific training h
5 on that at tha't time.
6 Q
Did you have training on plant cooldowns?
7 A
Again, I don't specifically remember that 8
one way or the other.
It could have been.
9 Q
Part of the time you went to the TMI site, 10 what experience had you had with dealing with the 11 primary side of the B&W NSS?
12 A
Well, as part of the function of designing
()
13 the auxiliary systems, since they interface with the 14 primary plant, I had a general understanding of how 15 the primary plant operates and what modes of operation 16 you would want to use in these auxiliary systems to 17 support the plant.
18 Q
How did you come to that general 19 understanding?
20 A
Through on-the-job training with other 21 engineers with experience.
22 g
Did you review any specific materials 23 related to the primary system to learn about how that i
24
(~S system functioned?
l
--\\ )
25 A
Yes, we had some FSAR material on general s
- we
^
1 t
4
.5
,1 tihetlor 53 2
ope [ation and that was mainly the mate ria J.' I remember 3
reviewing.
i 4
Q Auxiliary syste.ms didn ' t include the h
5 makeup or HPI systems, did they?
6 A
It most' definitely did.
7 Q'
What type of review did you do of
.8 those systems prior to the time of going to TMI?
9 A
Again, I was involved in the detail design 4
10 conalderations for high pre ssure ' inj ection and makeup 11 and purification system.
12' O
For.the primary side of the plant?
13 A
As they interface with the primary side of 14 the plant.
15 MF. MCDONALD:
I object.
16 Q
When you_,say " auxiliary systems," do you 17,
mean that those were systems that interfaced with 18 systems'on th'e primary side of the p.-
being thah.'
19 the' auxiliary 'syLs tems are on the secend'ary side of the 20 plant?
\\
21 MS',; MCDONALD:
I object to the form.
22 There is no testimony the auxiliary systems 23 he has been referring to appear on the a[econdary, p
[
~
24
's idk.
Uq
<- j si i
c
25 Mk..MacDONA D:
I am just a'sking him.
iG i
- , N. '%
g t
\\
k' A
d
) V y
b p
g_
.e.-
---'-T
'~
1 Shotlor 54
)
2 He can correct me if that's not right.
~
3 A
The auxiliary systems we were involved 4
in were those associated with the primary plant.
lll 5
Q What particular systems?
6 A
Makeup and purification, high pressure 7
injection, decay heat removal, low pressure injection.
8 Q
Any others?
9 A
Chemical addition and boron recovery, 10 waste management, building spray, core fl o o'd.
11 I believe that covers it.
12 Q
Did your work on auxiliary systems
()
13 cause you to interface with components in the 14 pressurizer?
15 A
Repeat the question, please?
l 1
16 Q
Did your job responsibilities in dealing l
l 17 with auxiliary systems have you dealing with the l
18 pre s s urize r?
19 A
We had some peripheral hardware associated 20 with the pressurizer.
21 Q
What was that?
22 A
spray valves, code safety valves, PORV.
23 Q
Prior to the time that you went to the TMI 24 site, did you have an understanding that in a situation bO' 25 where the code safety valve stuck open during normal
l 1
Shetler 55 2
operation, operation of power, that that failure of 3
a code safety valve in the fully open position would 4
produce a decrease in reactor coolant system pressure lll 5
and the pressurizer level?
6 MS. MCDONALD:
Could I have that again?
3 7
(Record read back.1 8
MS. MCDONALD:
I object to the form.
9 A
Yes, that is my understanding of a failed 10 closed safety valve would be the response.
11 Q
Failed open?
12 A
Yes.
()
13 Q
You understand that the initial response 14 would be that level and pressure would decrease?
15 A
Yes.
16 Q
Did I understand that pressure could 17 decrease in that situation to the point where high 18 pressure injection was actuated?
19 MS. MCDONALD:
Prior to going to the TMI-2 20 site?
21 MR. MacDONALD:
Yes, what's his understnading.
22 THE WITNESS:
Would you read that back 23 one more time?
i 24 MR. MacDONALD: I will repeat it for you.
(
l 25 Q
Did you understand that in the case of a l
1 Shetler 56
(
2 fully stuck open PORV the pressure could decrease to 3
the point where HPI cctuated?
4 MS. MCDONALD:
Now we are on PORV7 ll 5
MR. MacDONALD:
I'm sorry, I meant code 6
safety.
7 MS. MCDONALD:
Can we have it back again?
8 Q
did you understand in a situation which 9
we are talking about, which is the fully stuck open 10 code safety valve that pressure could decrease to the 11 point where HPI would actuate?
12 A
If the valve were stuck open, that would
()
13 be my un'derstanding, that it could decrease to the 14 point where HPI could be actuated.
~
15 Q
Did you understand that after HPI actuation 16 that level and pressure would begin to recover?
17 MS. MCDONALD:
I object to the form.
18.
I am not sure the question is clear as to what
]9 state we are in now.
20 MR. MacDONALD:
It's clear we are talking 21 about a trip, normal operation, where the code 22 safety valves stick fully-open.
23 A
A trip at that time would not normally have 24 accompanied safety valve lift.
(-]
V 25 -
MS. MCDONALD:
Just for clarification, 1
1 Shetler 57 2
the reason I objected before was for the 3
reason you said there was a stuck open code 4
safety during normal operation.
That's the l
lll 5
cla rifica tion.
6 MR. MacDONALD:
I ac talking about normal 7
operation being at power.
8 Q
So we are at power, you understood that it 9
was conceivable that a code safety valve could stick 10 open, isn't that right?
11 A
If it were caused to lift for some reason, 12 yes, there is a possibility that it will stick open.
()
13 Q
And what we are talking about is fully 14 stuck open; you would expect initially level and 15 pressure to decrease?
16 A
Yes, that is correct.
17 Q
And that pressure could decrease to the 18 point where HPI was initiated?
19 A
That is correct.
20 Q
Which is approximately 1600 psig?
21 MS. MCDONALD:
I object to the form.
22 You mean on TMI-27 23 MR. MacDONALD:
Hip general understanding 24
~}
that that's what it was.
\\s' 25 MS. MCDONALD:
Prior to getting to the
- ~- ~
1 Shetler 58 (D
2 TMI-2 site, his understanding?
3 A
The actuation point for HPI differs from 4
plant to plant.
llh 5
Q You understand that at or around the 6
time you were working on the draft procedures that the 7
actuation point on TMI-1 and 2 was approximately 1600 8
pounds for HPI actuation?
9 A
At the time I was working for GPU on marking 10 up the procedures, yes, I knew that the actuation 11 pressure for ES signal was 1600 pounds. approximately.
12 Q
Did you understand that ss a result of HPI 13 actuating, that you could get an increase in 14 pressure and pressurizer lovel during the course 4
15 of a transient where the code safety valve stuck fully 16 open?
17 MS. MCDONALD:
I object to the form.
18 A
My understanding at the time, that 19 if I had HPI actuated and the code safety valve 20 stuck, yes, I would start recovering pressure and level.
21 Q
Did you have an understanding at the time 9
22 you were working on these procedures at the TMI site 23 that in that situation, you would expect to see
_ [~))
24 pressurizer level high while reactor coolant system 8
25 pressure was low?' And by " low" I mean between its l
1 Shotlor 59 i
I
(
2 actuation set point of 1600 psig?
MS. MCDONALD:
I object.
I think it's 3
4 unclear again when you are referring to now.
llh 5
MR. MacDONALD:
I think it's very clear.
6 MS. MCDONALD:
Let me have the question 7
back.
8 (Record read back. )
9 MS. MCDONALD:
I object to the form.
10 A
And what value, you said between 1600 11 psig?
12 Q
I said below 1600 psig.
()
13 MS. MCDONALD:
Do you understand the 14 question as it now stands?
15 MR. MacDONALD:
Let me repeat it.
16 Q
Did you understand that in a situation 17 where the code safety valve had stuck open and pressurizer 18 level had decreased to the automatic level of actuation 19 and HPI had come on that in that situation, pressurizer 20 level would be high or could be high while reactor 21 coolant system pressure was low?
And by " low" I mean 22 below the 1600 psig.
23 MS. MCDONALD:
You are assuming HPI is 3
24 still on at this point?
b 25 MR. MacDONALD:
That's right.
I 1
Shotler 60
(
2 A
I don't think I specifically knew one way r the other the details into the accident of how 3
4 pressure and level would continue to respond.
llh 5
Q S
y u didn't have an understanding of 6
whether or not in that type of situation, fully 7
stuck open code safety valve, whether you would 8
see pressurizer level high while reactor coolant system 9
level was low?
10 MS. MCDONALD:
I object to the form.
11 A
I don't know that I thought it out to that 12 extent.
f'T g3 Again, I wasn't involved in the details of O
14 the ECCS analysis that went on through that.
15 Q
Well, you were reviewing the pressurizer 16 system failure proce du re, were you not, for 17 substance to the extent that if you saw changes that 18 had to be made, you would recommend that they be 19 made; isn't that right?
20 A
Part of the review of the Unit 1 procedure 21 in marking them up for Unit 2 was if we saw any obvious O
22 problems or errors to make changes.
23 Q
And in order to conduct that review, did 24 you feel you had to have an understanding of how the
-s
\\m'/
25 system operated under the conditions for whibh you T
e
-m-
=
w
+,
-e
1 Shetler 61 0
2 were reviewing emergency procedure?
3 A
I acquired a general understanding of how 4
it operated,'not necessarily a detail of every lh 5
conceivable accident that ever happened.
6 Q
Well, you understood that you were to 7
have a general understanding of the transients that 8
were listed in the emergency procedure, did you not?
9 MS. MCDONALD:
I object to the form.
10 A
Yes, I have a general understanding of 11 the transients involved in the procedure, yes.
12 Q
Did you have an understanding in the 13 case of a stuck open code relief valve of whether 14 or not during that transient you would expect to see 15 pressurizer level rise while reactor coolant system 16 pressure fell at any point in time during a transient?
17 MS. MCDONALD:
I object to the form.
18 THE WITNESS: Could you repeat the question, 19 please?
I 20 Q
At any point in time during the stuck open 21 code safety valve transient, did you have an O
l 22 understanding that you.would see pressurizer level rise i
1 23 while reactor coolant system pressure fell?
i-24 A
I don't recall that I considered it one 25 way or the other.- Again, I wasn't too hung up with
1 Shetler 62 0
2 the level for this particular procedure, but where 3
the pressure was going.
4 Q
Let me direct your attention to page 6 llk 5
of GPU Exhibit 352, the " Inoperative Code Relief Valve,"
6 Section D,under D.2 B.2.c.
,Page 6, do you see the 1
7 words " Manually initiate HP injection if required 8
to maintain pressurizer level"?
1 9
A Right.
10 Q
Did you understand that to mean that i
11 if in this situation of a stuck open code relief valve, 12 high pressure injection had not been automatically 13 initiated, it should be manually initiated to maintain 14 pressurizer level?
15 MS. MCDONALD:
You said in a situation 16 where it had not already at any time automatically
'nitiated?
17 i
18 MR. MacDONALD:
That's right.
19 A
Yes, in that situation where I am up in 20 pressure and if there is still a concern with inventory, 21 then I should initiate HPI.
22 Q
And a concern of inventory would be 23 reflected by a low pressurizer level, that's what this 24 was referring to, right?
25 A
Pressurizer level in itself is not a sole
=. _...
1 Shetler 63
, ()
2 indication of inventory.
It has to be looked at 3
with other parameters such as pressure and temperature.
4 Q
And this-particular part of the procedure lll 5
is telling operators to manually initiate high pressure i
6 injection in order to maintain pressurizer level, isn't 7
that what it says?
8 MS. MCDONALD:
Is that what this document 9
says?
j 10 MR. MacDONALD:
What he understood it to 11 say in 2.c there, what we are talking about.
12 MS. MCDONALD:
Objection; asked and
()
13 answered.
14 A
This says manually initiate high pressure 15 injection if required.
16 Q
To maintain pressurizer level?
17 A
To maintain pressurizer livel, which means 18 inventory.
19 Q
Do you see the next section, D.3, 20
" Follow-up Action," un der 2, "For a fail to open code 21 relief valve, a.
Hold pressurizar, if possible, at O
22 or greater than 220 inches with HP injection"?
Do j
23 you see that?
24 A
Yes, I see that.
. O>..
u-25-Q What was your understanding in or around-l L
L E
. ~.
i I
1 Shetler 64
(-)N
(_
2 the time that you were reviewing these procedures of 3
how an operator was to hold pressurizer level at or 4
greate r than 220 inches with high pressure injection?
lll 5
A My understanding is that he would be 6
looking at overall RCS inventory which includes 7
pressurize r level, temperature and pressure, and in this 8
particular instance, we are leaning him towards 9
cooldown which has restrictions on pressure and 10 temperature, and in order to maintain his inventory, 11 if he needed to, if whatever his leak was was in excess 12 of his normal capability, he would actuate additional
()
13 high pressure injection pumpu as required to maintain 14 inventory.
15 (Record read back.)
16 Q
And I take it what you are referring to is 17 that the procedure was telling the operator to 18 look at pressurizer level and maintain it at or greater 19 than 220 inches, is that correct?
20 A
Well, in looking at a procedure, you just 21 can't look at one step.
You have to look at the O
22 overall contentshof the proceduro.
23 In this context of procedure we are talking 24 about heading for cooldown.
It's how someone applies gS
'b 25 temperature and pressure restrictions and all of that f
1 Shetler 65 2
has to be incorporated when the operator is reviewing 3
this status and where you are going.
4 Q
You understood that this portion of lll 5
the procedure, 2.a, told him to hold pressurizer level 6
at or greater than 220 inches, didn't you, wasn't 7
that your understanding?
8 MS. MCDONALD:
He has testified as to his 9
understanding several times.
Now you are trying 10 to take out one sentence of this procedure and 11 force him to say, talk about that alone, and he's 12 given you his understanding of what the
()
13 operators would expect to hear.
I think he's 14 given you his understanding several times now.
15 MR. MacDONALD:
I am no t asking you to 16 testify, Ms. Mcdonald.
I am asking a very simple 17 question geared towards this portion of the 1
18 follow-up and the section of the procedure for 19 en inoperative code relief valve.
I am asking 20 the witness, isn't it a fact that he had an 21 understanding that 2.a was telling the operator, 22 as it states her told pressurizer level at 23 or greater than
.hes; did you understand r-\\
24 that that's what ocedure was telling you.
N_]
25 If'he didn't understand that it was telling
.,m,
1 Shetler 66 2
him to hold pressurizer level at or greater than 3
220 inches, he can tell me that.
4 MS. MCDONALD:
I object to the form.
5 A
Again, my understanding of what the 6
procedure is telling the operator to do is maintain 7
this RCS inventory in preparation for going into 8
cooldown and how he does that is observes his pressure 9
and temperature because he is going into cooldown and 10 that has limits and precautions on pressure and I
11 temperature and observe pressurizer level and attempt 12 to maintain it above 220 inches.
13 Q
Do you see anything in the follow-up 14 action here that tells him to monitor in 2.a pressure 15 and temperature limits?
16 On the piece of paper here.
Do you see 17 that?
18 A
The overall direction of the procedure is 19 proceeding to cooldown.
Cooldown has pressure and 20 temperature limits and operators are aware of that.
21 Q
Have you ever sat in any training sessions G
22 with operators?
23 A
Prior to or after?
24 Q
At or around the time that you were 25 reviewing these procedures or prior to that time.
I 1
Shetler 67 2
A No.
3 Q
So you had no idea, did you, of how 4
operators were trained specifically to operate lh 5
nuclear power plants?
6 MS. MCDONALD:
I object to the form.
7 A
I had a general understanding of operator 8
training in that they were given courses about thermo 9
dynamics and heat transfer and were aware of pressure 10 temperature leaks.
11 Q
Have you ever talked to the training 12 department in B&W about what type of training B&W
(
13 was giving to operators that came down to its simulator?
14 A
I don't spe cifically remembe r anything 15 about that.
16 Q
Did you have any discussions with any 17 operating personnel at Three Mile Island that related 18 to what type of training those operators were receiving 1
19 either on Unit 1 or Unit 2 on how to operate the 20 nuclear reactor?
21 A
I don't specifically remember any discussions 22 about that one way or the other.
I 23 Q
Did you know that a fully stuck open 24 code safety valve would result in pressure an d 25 temperature being outside the cooldown limits?
i
L 1
Shetler 68 2
MS. MCDONALD:
When?
3 MR. MacDONALD:
When a code safety 4
valve is stuck open at any point in time h
5 during that transient.
6 Q
Did you understand in that situation 7
pressure and temperature would be outside the cooldown 8
limits?
9 MS. MCDONALD:
-I object to the form.
10 A
I don't recall one way or the other 11 if I remember that or knew that.
12 Q
Did you ever consider when you were b)'
q, 13 reviewing this portion of the pressurizer system 14 failure procedure dealing with stuck open code safety 15 valves to include in 2.a, follow-up actions, a 16 specific instruction to have operators look at pressure 17 temperature in order to assess system inventory?
18 MS. MCDONALD:
I object to the form.
I 19 Q
Did you ever consider that?
1 20 MS. MCDONALD:
You mean using those 21 specific words, did he consider that?
22 MR. MacDONALD: hor that. concept.
23 MS. MCDONALD:
I object to the form.
Q(~T 94 You may answer.
25 A-I did not consider it necessary since the
1 Shetler 69 O
2 format that it was in was being used on an operating 3
plant and been approved for use on an operating plant 4
with the latest revision in effect at that time, and lll 5
since, as I have stated before was my general 6
un de rs tanding, that operators were aware of pressure 7
temperature relationships and this specific procedure 8
was leading them towards a cooldown situation.
9 Q
so I take it your answer is you did not 10 consider it?
11 A
I did not consider it necessary.
12 MS. MCDONALD:
Using those specific words.
()
13 MR. MacDONALD:
No, the concept.
14 A
I guess I don't recall specifically one 15 way or the other whether I considered the concept.
16 Q
Did you understand that in the follow-up 17
- action, 2.a, it was possible that an operator could 18 throttle back high pressure injection to hold 19 pressurizer level at or greater than 220 inches?
l 20 A
My understanding was that he could do that, i
21 yes.
22 Q
Did you h ave an understanding that other 23 portions of other procedures dealing with emergency l
(
'N 24 procedures specified pressure and pressurizer level I
25 be fo re the operator could throttle back HPI?
1 Shotlor 70 l ()
2 MS. MCDONALD:
May I have that back, l
3 please?
4 (Record read back.)
llf 5
MS. MCDONALD:
I object to the form.
6 Understanding when he was reviewing 7
this procedure?
8 MR. MacDONALD:
Yes, in and around the 9
time.
It's the time we are dealing with now.
10 I am going to state that in every question.
11 A
I don't specifically recall it one way or l
12 the other whether I knew that other procedures included
()
13 a statement on pressure at the time I was writing 14 this.
15 Q
Did you attempt to find out at the time 16 that you were writing this?
17 MS. MCDONALD:
So it's clear, your 18-question related to pressurizer level and 19 pressure?
20 MR. MacDONALD:
Yes.
21 MS. MCDONALD:
Did you understand that?
O 22 THE WITNESS:
Yes.
I understand that 23 pressurizer level and pressure together.
24 Now, what was the other question?
7-
\\j 25 (Record read back.)
L.....
i 1
Shetler 71 2
Q Did you attempt to find out at the time 3
you were writing this whether or not any other 4
pro ce dure s contained sections relating to lll 5
pressurizer level and system pressure when they 6
talxed about HPI operation?
7 A
I don't remember specifically one way or 8
the other whether I tried to find out.
9 As I said before, I was using the 10 existing procedure from Unit 1 and its format and 11 verbiage were what GPU had approved previously.
12 I do not have any great hang-ups in the
()
13 way it was written and did not modify it.
14 Q
Well, you understood that you 15 weren't required to adopt the specific language 16 or substance that GPU had in the procedure that it 17 gave you from Unit 1,
did you?
18 MS. MCDONALD:
I object to the form.
19 A
My understanding was to only make those 20 changes we felt were necessary.
And those consistent 21 with Unit 2.
h 22 Q
Did you have an understanding at this 23 time that in a situation where a code safety valve 24 stuck open that you could have saturation occurring g
[
25 in the reactor coolant system?
I
.4
g Shetler 72 l
\\-)
2 A
You mean other than in the pressurizer?
Q That's correct.
3 MS. MCDONALD:
Are you talking about 4
h 5
when it stuck open or after HPI came on or what?
6 MR. MacDONALD:
I am talking about during 7
8 the course of the transient.
A My understanding was that as long as HPI g
10 actuated, I was not aware that you would get voiding gg in any other areas of the core, a significant amount 12 of voiding.
)
13 Q
When y u say "significant amount," you mean ther than flashing at certain portions of the 14 hot leg?
15 16 A
Yes.
37 MS. MCDONALD:
I object to the -form.
18 A
Well, there was always a small amount of 19 v id f rmation due to localized temperature condition, i
l 20 mainly in the core area.
l 21 Q
Did you have an understanding at this time that the injection of high pressure injection 22 23 would be able to keep up with the break size of a 24 stuck open code safety valve?
25 MS. MCDONALD:
I object to the form.
4
-.m--
~
l 1
Shetler 73
.N/
2 A
At what pressure, or do you care?
I do.
3 Q
At the point in time when high pressure 4
injection has initiated and you have a stuck open h
5 code safety valve, did you have an understanding 6
that that high pressure injection flow was capable of 7
keeping up with the loss of inventory through the 8
stuck open code safety valve?
9 MS. MCDONALD:
I object to the form.
10 A
I don't know that I ever one way or the 11 other knew at what pressure the flow would equalize 12 out.
13 Did you ~ ver have an understanding at or Q
e 14 around the time that you were reviewing those 15 procedures of how much volume would be released 16 through a stuck open code safety valve,how many 17 gallons a minure of inventory from the system would I8 be released?
19 MS. MCDONALD:
Stuck open for how long?
(
20 MR. MacDONALD:
Stuck open, in its stuck i
21 g
open position, how many gallons a minute.
22 A
Oh, flow rate, not volume.
23 g
y,,,
24
)
A well, you said volume.
25 MS. MCDONALD:
He is asking you whether
1 Shetler 74 j
l 2
you had an understanding at that time.
3 A
I had a knowledge, but I don't remember 4
specific numbers of what code safety valve would pass h
5 in the flow rate.
6 Q
Did you also have the same understanding 7
for what pilot operated relief valves would pass?
8 A
I have a general understanding that I knew 9
whe re to find specific numbers.
10 Q
Did you understand a situation where 11 a PORV had stuck open that that valve could be 12 subjected to two phase flow during a transient?
w 13 MS. MCDONALD:
I object to the form.
14 A
I believe I was aware of that at that time.
15 I am not sure exactly one way or the other, but I 16 believe so.
17 Q
Did you understand at that time whether 18 or not the valve itself, pilot operated relief valve, 19 was qualified to pass two phase liquid?
l l
20 MS. MCDONALD:
Objection.
21 Are you asking about something in the l
22 context of his procedure review effort, which is 23 the subject of this deposition?
( )
24 MR. MacDONALD:
That's right.
25 MS. MCDONALD:
All right.
I
1 Shetler 75 2
A I do not recall one way or the other that I did at that time.
I don't remember.
3 4
Q so while you were reviewing these llh 5
procedures, you don't recall that you were aware that 6
the pilot operated relief valve could not pass two phase 7
fl0W7 8
MS. MCDONALD:
Objection.
9 I believe this line of questioning is 10 irrelevant to this deposition.
I strenuously 11 object to pursuing this line of questioning.
12 We are here to talk about what
()
13.
Mr. Shetler may or may not have done with 14 regard to the procedures.
15 MR. MacDONALD:
We are here to talk about 16 his work relating to those procedures and in 17 the course of speaking about his work relationship 18 with those procedures, it's obvious we are 19 entitled to find out what his understanding a
d i
20 was about the systems that he was reviewing 21 procedures for, and that's exactly what we are 22 doing.
23 MS. MCDONALD:
May I have the question t
24 back?
O:
25 Q
Did you understand at or about the time
1 Shetler 76 O-.
2 you were reviewing these procedures, Mr. Shetler, 3
that the pilot operated relief valve had been 4
tested or qualified to pass two phase liquid?
lll 5
MS. MCDONALD:
I object.
6 I don't think this is at all relevant 7
to knowledge relevant to this deposition.
8 I agree, Mr. MacDonald, that you are 9
permitted to inquire into Mr. Shetler's knowledge 10 which might be relevant to his review of the 11 procedures.
12 However, I don't believe that should be 13 a vehicle for inquiring about his knowledge 14 about anything in the world.
15 MR. MacDONALD:
Well, I don't think the 16 pilot operated relief valve as it relates to 17 this case is anything in the world.
I think 18 it's very germane and what I am talking about 19 is his understanding about the functioning of 20 the valve when he was reviewing the procedures.
21 MS. MCDONALD:
Well, whether GPU had done 22 any hardware testing I am not sure is relevant.
23 MR. MacDONALD:
If I wanted to ask you, 24 Ms. Mcdonald, for your answers to my questions, 25 I would do that.
l
_-_______-____-____-_-----a
I Shetler 78 g
l
)
2 MR. MacDONALD:
An increase.
3 MS. MCDONALD:
Any increase, O.K.
4 A
Yes.
If the valve routinely opened gg 5
and closed, you would get an increase in temperature 6
in the downstream line.
7 Q
Did you understand that increase in 8
temperature would also be above 200 degrees?
9 MS. MCDONALD:
I object to the form.
10 A
I understood it would be greater above 11 its normal ambient background.
How much I don't 12 think I knew one way or the other.
(~))
13 Q
So for either a leaking PORV or a PORV
\\_
14 that is cycled open and closed, you didn't have any 15 understandina at the time of how high those discharge 16 line temperatures would go, is that correct?
17 A
Again, I don't remember one way or the 18 other whether I knew just how high the discharge 19 temperature would go.
20 Q
Did you have an understanding in a case 21 of a stuck open PORV that the discharge line 9
22 temperatures would increase?
23 MS. MCDONALD:
Again, any increase?
24 MR. MacDONALD:
Yes.
,s
[
)
25 A
Yes, I would have understood at that time 9
1 Shetler 79 O
2 that you would have an increase in downstream 3
temperature.
4 Q
Did you understand how high of an increase 5
you would get?
6 A
I knew they were probably no higher 7
than what the steam temperature was of the fluid in 8
the pressurizer.
Specifically how high it would 9
ge t --
10 MS. MCDONALD:
Did you finish your 11 answer?
12 A
Specifically how high it would get I didn't s
13 remember knowing one way or the other.
14 Q
Did you understand that at the time 15 when a PORV stuck open, that the discharge line 16 temperature you would expect to see would be 17 approximately the temperature in the pressurizer?
18 A
I am sorry, say it one more time?
19 Q
Did you understand at or around this l
20 time that the discharge line temperature you would 21 expect to se e when a PORV stuck open was approximately
(
22 the temperature in the pressurizer?
l i
23 MS. MCDONALD:
I object.
I believe he's
(#')
24 given you his understanding at that time.
V 25 MR. MacDONALDs. I am attempting to clarify
l 1
Shetler 80 0
2 it somewhat.
3 A
The actual temperature you would see is a 4
function of how the utility instrumented the line over lll 5
which I had no control.
6 I did know that you would see an 7
increase in temperature above normal and the highest 8
you could see would be whatever the pressurizer 9
fluid would be at that time.
10 Q
Did you have any understanding of how 11 long the elevated temperature from a PORV which was 12 cycling open and closed would take to decrease to 13 ambient temperature?
14 MS. MCDONALD:
Objection.
15 Again, I believe we are getting 16 a little far a field on his procedure right now 17 which is the subject of this deposition.
18 MR. MacDONALD:
It's his understanding 19 of a particular condition.
It was mentioned 20 specifically in many sections of-this procedure, 21 and I am attempting to gain an understanding O
22 of what this witness knew at the time he was 23 reviewing the procedure.
[~)h 24 MS. MCDONALD:
I' object to the
\\_
25 characterization of what the prode' dure says.
n'g
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_j
1 Shetler 81
(~ N, l
1
'/
2 I will allow this answer.
3 May I have the question read back?
4 Q
The question is, what was your llh 5
understanding of how long it would take for the 6
increase in temperature resulting from a cycling 7
of the PORV to decrease to ambient temperatures?
8 A
That really wasn't a function of what was 9
going on with these procedures.
10 How it would decrease was a function 11 of design, which was under GPU's control, not mine.
12 My only concern was that if it went above r')T
(_
13 normal, that was a symptom that you had to evaluate 14 to determine whether you had a leaking valve or not.
15 Q
My question was did you have an 16 understanding of how long it would take to decrease 17 from cycling of the PORV?
18 A
Again, how long it would take is a 19 function of the design over which I had no control.
l l
20 Q
But did you know that B&W provided l
21 the thermocouples for those three discharge lines?
22 MS. MCDONALD:
I object to the form.
23 There is no testimony today from this
[^')
24 witness --
%/
25 MR. MacDONALD:
I don't have to have j
s
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+
1 Shetler
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2 testimony frca the witness to ask him a l*
, leading question, and that's exactly what the 3 d t
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questfoa in.
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[,,i.he wants to answs'r "no," he may answer h.
f, 5
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6 "No."<. If he (want's toj' answar "Yes," he may; 4
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ansse r "Yes.")i
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.MS. McDONALDs, You meard the actual 1
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they we'zo placed or.
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11 Q
My question was, did you know that B&W
+l.
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c 12 providee the t h,e rmo co up le s that were.util'ized on/
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13 those t bree ~ dis #cha:rge lines.
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1 Shetler 83
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2 of thermocouples, whether you knew who supplied those 3
thermocouples.
4 A
I said it was a function of the design lll 5
. layout of the thermocouples as to where they are 6
attached.
7 Q
Did you have an understanding as to who 8
provided the thermocouples?
9 Ms. MCDONALD:
I object.
It's irrelevant.
10 You may answer.
11 A
If you go back a couple of questions, I 12 think I have answered that.
O)
(_
13 Q
Which was?
i 1
14 A
Which was I,
at that time, don't think 15 I knew one way or the other who provided the 16 thermocouples.
17 Q
Did you have an understanding at that time I
18 as to how long it would take for temperatures to 19 decrease after the PORV had cycled open and closed?
20 MS. MCDONALD:
Objection.
It has been f
21 asked and answered a couple of times.
22 MR. MacDONALD:
I haven't gotten an answer 23 to the question.
I have gotten a response that 24 was not responsive to the question, but I haven't
- 25 gotten an answer.
~
1 Shetler 84
'<IT
$_/
I am asking him now in a situation 3
where it's cycled, if he had an understanding 4
of how long it would take for the PORV, for the lh 5
discharge line temperatures to decrease to 6
ambient levels.
7 MS. MCDONALD:
I object, but you may 8
answer.
9 A
I had an understanding that it would 10 take time to decrease.
How long, again, is a 11 function of how the thermocouple design is attached 12 to the pipes.
)
13 Q
And you had no understanding as co how 14 long it would take, isn't that right?
15 MS. MCDONALD:
Objection.
16 A
It would take a certain amount of time.
17 How long, again, is.a function of the 18
. design.
l l
19 Q
-Well, regardless of whether it's a function 20 of design, it's a very simple question as to whether l
21 or not you knew how long it would take.
That's all.
22 MS. MCDONALD:
Quite apart from his 23 reviewing of any procedures which are the L
24 subject matter of this procedure, did he know --
- x, 25 MR. MacDONALD:
It's not " apart."
It's
1 Shetler 85 O'
2 in conjunction with his review of these 3
procedures at that time period, did he have 4
an understanding of how long it would take lh 5
for the discharge line temperature downstream 6
of the PORV to decrease to ambient level after 7
the PORV had cycled open and closed.
8 It's been asked now several times.
9 MS. MCDONALD:
It's been asked about 10 four times and I believe it's been answered 11 about four times, and I object on the ground 12 of relevance.
13 You may answer.
14 A
Again, how long it would take to decrease 15 in temperature is a function of the design.
That was 16 not my responsibility, nor was it a germane matter 17 to what I was doing to review these procedures.
18 Q
It's a very simple question, Mr. Shetler, 19 and I still haven't gotten an answer.
I 20 The question is whether or not you had i
21 an unde rstanding-of how long it would for those 22 discharge line temperatures to decrease to ambient 23 lev.ls after the PORV cycled open and closed.
l [J]
24 MS. MCDONALD:
I have the same objection.
L 25 A
The answer to the question is the same.
l
G 1
Shetler 86 2
The question of how long is a function 3
of the design.
I was not aware of what the design 4
was.
That was the customer's responsibility.
llh 5
Q I take it then that because you were not 6
aware of what the design was as to how the thermocouples 7
were installed on either Unit 1 or 2, then you did 8
not have an understanding of how long it would take 9
for the temperatures in the discharge line once the 10 PORV cycled open and closed, it decreased to ambient 11 levels?
12 MS. MCDONALD:
I have the same objection.
13 A
I did not have a specific knowledge of 14 the amount of time it would take for the temperatures 15 to decrease.
16 Q
Mr. Shetler, did you have an understanding 17 of whether or not the temperature downstream of the 18 pilot operated relief valve would reach the 19 temperature of the mass in the pressurizer when a 20 pilot operated relief valve was stuck open?
21 MS. MCDONALD:
Objection.
I believe 9
22 that exact' question has been asked before and 23 answered before.
('N -
24 MR. MacDONALD:
No.
I think the question Q:'
25 was put and.his answer was that he understood i
1 Shetler 87 O
2 that the highest it would get would be that.
t 3
My question is if he understood if he had i
4 an understanding as to what he would expect to 5
see when the PORV stuck open downstream.
6 MS. MCDONALD:
Again, I believe that 7
precise question has been answered already.
8 I will allow him to answer it again.
9 A
Again, my understanding was that the 10 temperature would be greater than ambient and no 11 greater than temperature in the pressurizer fluid at 12 that time.
13 Q
You had no specific understanding as to 14 what that temperature would be other than in 15 that range?
16 A
That is a correct statement.
I did not 17 have a specific understanding of what that 18 temperature would be because, again, that was a 19 function of design of the layout of the thermocouples.
20 Q
Did you have an understanding at or 21 around this time, Mr. Shetler, regardless of where 9
22 the instrumentation was placed to read the discharge 23 lina temperatures downstream of the PORV, as to what 4
24 the temperature would be in that discharge line 25 directly downstream of the PORV if that valve was stuck j
1 Shetler 88 2
fully open?
3 MS. MCDONALD:
I object to the form.
4 Q
Do you understand now I am talking llh 5
about regardless of what the design was 6
thermodynamica11y, regardless of where you put the 7
thermocouple, did you have an understanding at or 8
around this time, if you had a stuck open valve what 9
you would expect to see downstream of the valve as 10 a temperature?
f l
11 MS. MCDONALD:
Objection.
I believe this 12 is again irrelevant to the deposition, even
\\
13 more irrelevant than the last question.
i 14 I will let him answer, but I am not 15 going to let this go on too long.
16-Go ahead, you may answer it.
17 A
I don't recall one way or the other 18 that I went through any thermodynamic tables and 19 actually calculated a number for what temperature 20 would be downstream of that valve after I relieved 21 steam through it.
22 Q
So you can't recall having a specific 23 understanding of that temperature?
\\
_[]
24 MS. MCDONALD:
Objection.
Again, I w
25 believe that these questions are irrelevant
1 Shetler 89 O
2 to the subject matter of this deposition.
3 I will allow you to answer the question.
4 May we have the question read back?
5 MR. MacDONALD:
Just so we can clarify 6
this, it relates specifically to symptoms 7
that are enumerated in the stuck open PORV 8
portion, the emergency procedure that was sent 9
from B&W to Met Ed.
10 As such, it couldn't have more relevance, 11 and my question is:
12 Q
Whether er not you ever did a calculation n
U 13 at that time, did you have an understanding as a 14 matter of thermodynamics as to what temperatures you 15 would expect to see downstream of the PORV for the 16 situation where the PORV was stuck fully open?
17 MS. MCDONALD:
Now the question is what 18 you would see?
19 MR. MacDONALD:
What he would expect to
'20 see downstream of the PORV when that valve was 21 stuck fully open.
22 MS. MCDONALD:
In other words, that's 23 dif fe rent from your last question about what 24 the actual temperature might be.
You are 25 talking about what you might see.
1 Shetler 90 l -
2 MR. MacDONALD:
I am talking about what his 3
understanding was of what that temperature 4
. would be.
llh 5
He doesn't have to look at a thermocouple 6
to see it.
We are disregarding that and where I
7 the thermocouples were connected to that piping.
8 I want to know where, at or around the time i
9 he was reviewing these procedures, one of which 10 dealt with an inoperable pilot operated relief I
l 11-valve, and one of which had the symptoms dealing 12 with discharge line temperatures for a pilot 4
13 operated relief valve, what this witness' 14 understanding was at that time as to what the l
15 discharge line temperature would be downstream l
16 of the PORV when that valve was stuck open.
17 MS. MCDONALD:- I object strenuously to
. 18 your characterization of this procedure.
l 19 I don't believe there has been testimony that 20 this procedure has anything to do with what the 21 actual temperature might be.
l 22 I will allow-him to answer.
23 I believe it is irrelevant.
)
24 Do you understand that the question 25-
- rolates to what the actual temperature would be l
i n-.
w aw,
,n
---e-
.~.....,,-,.m...-.,
1 Shetler 91 1
~O V
2 and whether you had any understanding regarding i
3 that at the time you were reviewing this 4
procedure?
5 A
Could you maybe read the original 6
question?
7 Q
Let me restate it so the reporter doesn't 8'
have to thumb back through the transcript to find it.
f 9
The question is:
At the time you were 10 reviewing these procedures, did you have an 11 understanding, irrespective of any calculations, as O.
12 to what the temperature would be downstream of the 13 pilot operated relief valve when that valve was 14 fully stuck open?
15 MS. MCDONALD:
Objection.
16 A
Again, I do not recollect one way or 17 the other that I knew a specific value or that I did 18 any specific calculations in relation to value, 19 and my general understanding at the time was that it 20 would be between above the ambient temperature normally 21 there and less than the pressurizer temperature at that 22 time'or steam temperature at that time, and as far as 23' doing this procedure, the actual number was irrelevant 24 anyway.
25 g
y,11, I take it from the last part of your-
1 Shetler 92 10
\\~2 2
answer, Mr. Shetler, that at the time you were 3
reviewing this procedure, you didn't really care 4
whether or not the operator was.given any guidance llh 5
as to whether or not the temperatures downstream of 6
the pilot operated relief valve would indicate by 7
the number or the temperature that the valve was 8
either fully stuck open or leaking or had cycled?
9 MS. MCDONALD:
Objection to the form.
10 A
In answer to your question, yes, I did 11 care what the operator saw.
12 However, the value we were interested in 13 as far as temperature was a value that GPU established 14 of 200 degrees.
15 Q
When you reviewed this procedure, you did 16 not consider it important to inform the operator 17 that there were different temperatures above 200 18 degrees that he might see for a stuck open PORV or 19 leaking PORV or a PORV that had cycled open and 20 closed?
21 MS. MCDONALD:
Objection, an assumption 9-22 in your qu'estion.
It has not been testified to 23 at all.
~
24 MR. MacDONALD:
It's simply a leading
- {a]
25 question.
i
1 Shetler 93 b
2 MS. MCDONALD:
I don't want this witness 3
to be misled by your questions, Mr. MacDonald.
4 I would like the question read back.
lh (Record read back.)
5 6
MS. MCDONALD:
I don't believe there has 7-been any testimony regarding temperatures over 8
200 or specifically that they might be 9
dif fe rent for leaking, cycled or stuck.
10 I will allow the witness to answer, but 11 I think it's a very unclear and confusing 12 question.
13 A
Not to be a pain, but I would like 14 to hear it one more time, too.
15 (Record reread.)
16 A
As far as temperature-is concerned, there 17 is only one of many symptoms the operator is given to 18 evaluate a certain situation.
19 The fact of the values used in here were 20 consistent with previous GPU approved procedures, 21 which we were basing our document on, in the sense 9-i l
22 there was only one parameter and GPU was satisfied with 23 Unit 1 and also in confirming the set points for Unit
(~'
24 2 with the' alarm set point, I did not see a need to
' Q,)i t
25 change that.
i 4
i l
l
.l 1
Shetler 94 O
2 Q
So I take it from your testimony that you 3
did not consider it important for the operator to 4
know the different temperatures above ambient which h
5 he might expect to see for a PORV that had either 6
cycled open and closed, was leaking, or was fully 7
stuck open?
8 MS. MCDONALD:
Objection.
9 I think he just answered that question.
+
10 MR. MacDONALD:
I don't think he's answered 4
11 the question.
12 MS. MCDONALD:
You are trying to make 13 a distinction between whether it was important 14 for him-to tell somebody versus having reliance d
15 on GPU telling him the right thing.
16 MR. MacDONALD ' He's previously 17 testified that he believed that a function of 18 his job responsibility in this situation was i
19 to provide procedures that were safe. for the i
20 operation of the plant, and what I am asking is l
21 whether or not in that. context he felt that it 22 was important to inform the operators of the 23 temperatures that they would expect to see in I) 24 situations where the valve cycled open and j
25 closed, was leaking,.or was fully stuck open.
1 Shetler 95 2
MS. MCDONALD:
I have the same 3
objection.
4 A
Well, I think the thing we need to lll 5
address is the context of the procedure and the 6
fact that if he gets a temperature above ambient 7
and in addition, other symptoms are in place which lead 8
him to believe there is a leaking valve or a stuck open 9
valve or whatever, his course of action is to close 10 the block valve.
11 Q
The question is still, Mr. Shetler -- I 12 don't think it's been answered -- whether you believed 13 it was important to inform the operator that the 14 temperatures downstream of the PORV would be 15 dif fe rent for a stuck open PORV or a leaking PORV J-16 or for a PORV that's cycled open and closed.
It's 17 very simple.
18 MS. MCDONALD:
I have the same objection.
19 A
What was important for the operator to i
20 know is that he had an increased temperature and that 21 he had to take some. action based on his --
22 Q
So I take it from your answer that you 23 believed that it was not important to tell him
[~')
24 the differences in temperatures'that he might see U
25 between a PORV stuck open, one that was leaking, or
1 Shetler 96 2
one that had cycled as long as you gave him an alarm 3
point that was above the ambient level?
4 MS. MCDONALD:
I object to the form.
Ih 5
Go ahead.
6 A
I did not believe at the time that it was 7
important to change the write-up as it stood.
8 Q
Did you understand at the time that 9
you were reviewing these procedures that a leaking 10 PORV could lead to an increase in the reactor coolant 11 drain tank temperature and pressure?
12 A
I believe it so states that in the 13 procedure, and I am aware of that, yes.
14 Q
Did you understand at the time that you 15 were reviewing these procedures that a stuck open PORV 16 could lead to an increase in reactor coolant drain 17 tank temperature and pressure?
18 A
Again, that would increase temperature 19 and pressure in the drain tank, yes.
20 Q
Did you understand that a'PORV that 21 had cycled could also lead to an increase in 22 temperature and pressure in the drain tank?
23 A
Yes, you would have relieved steam
(
24 to the drain tank and that would have caused I
- 25 temperature and pressure increase.
l 1
Shetler 97 w'
2 Q
Did you understand at the time that you 3
were working on these procedures that there were 4
also other events that could lead to an increase llh 5
in temperature and pressure in the drain tank?
6 MS. MCDONALD:
Objection.
7 what other events?
8 Q
Let me be more specific.
9 That there were other areas from which 10 the drain tank collected inventory from the primary 11 reactor coolant system.
12 MS. MCDONALD:
Again, I believe this is
(
13 irrelevant.
4 14 If you want to ask it what he thought 15 about writing this procedure, you are perfectly 16 welcome to do so.
17 I will allow him to answer it, but I think 18 it's pretty far afield here.
i 19 Q
Simply, Mr. Shetler, did you understand 20 that there were other things that could lead to an 21 increase in reactor coolant drain tank temperature 22 and pressure aside from a stuck open PORV, a leading 23 PORV, or a PORV that had cycled open and closed?
24 MS. MCDONALD:
Objection.
25 Go ahead.
+w...
1-Shetler 98
)
2 A
Yes, I was aware that there were other 3
sources or water that it collects.
4 Q
What were some of those sources?
h 5
MS. MCDONALD:
Objection.
6 Based on your understanding at the time 7
that you were considering this procedure, 8
Mr. Shetler.
9 MR. MacDONALD:
That's obviously the 10 question, Ms. Mcdonald.
We have been dealing 11 with that subject matter and area for the 12 last two hours.
13 MS. MCDONALD:
Mr. MacDonald, throughout 14 the course of this deposition you have been 15 trying to get Mr. Shetler's general understanding 16 about everything in the world, and in the guise 17 of saying that it's relevant to these 18 procedure writing efforts.
19' Now, I have been quite lenient about that.
20 I believe the agreement which we have here is 21 very limited, that this deposition is about 22 Mr. Shetle'r's duties and responsibilities in l
23 reviewing these procedures, and I am not going 24 to allow continued inquiry into all kinds of j
25 different areas under the umbrella of your saying
('
l
1 Shetler 99 2
that all of his knowledge about everything is 3
related to these procedures.
4 MR. MacDONALD:
We are speaking, 5
Ms. Mcdonald, directly about areas that are 6
related to pressurizer system failure procedure, 7
specifically the one for Unit 2, specifically the 8
one that he reviewed, commented on, and what 9
we are dealing with is his general understanding 10 at or around the time that he conducted that 11 review.
12 I don't think you could have any more 13 relevant line of inquiry as to what his 14 understanding was when he was reviewing a 15 p roce du re that obviously has a great deal of 16 relevance to the case which we are all here 17 about.
18 MS. MCDONALD:
I don't dispute that this 19 prodedure has relevance.
20 What I am disputing is your question 21 about whether he considered every other 22 possible thing in the world other than what 23 might be relevant to this procedure.
{)
24 I don't think that's appropriate for this 25 deposition.
1 Shetler 100 OO 2
MR. MacDONALD:
My questions are geared 3
towards his understanding about certain topics 4
and subjects which are directly reflected in h
5 this procedure, and my questions are simply 6
related to his understanding about those 7
topics and subjects at the time he was 8
reviewing these procedures.
9 My question presently is, so that we 10 can move on:
11 Q
Did you have an understanding that a leaking 12 code safety valve could increase the pressure and D
'\\m-)
13 temperature in the reactor coolant drain tank?
14 A
Yes, I understood that.
15 Q
Did you understand that a stuck open 16 code safety valve could also increase that 17 temperature and pressure?
18 A
Yes.
19 Q
Did you understand that a cycling of this 20 CSv could increase temperature and pressure in the 21 reactor coolant drain tank?
22 A
Yes, I understood that.
23 Q
What was your understanding of what other
{~}
24 areas of the primary coolant system could lead to an 25 increase in pressure and temperature in the reactor
1 Shetler 101 0
2 y
coolant drain tank?
3 MS. MCDONALD:
Objection.
4 A
I was aware that there were other drains h
5 and lines that drain to the drain tank which may or 6
may not affect pressure and temperature in the drain 7
tank.
8 Q
At the time that you were reviewing 9
the pressurizer system failure procedure, did you 10 attempt to determine the increase above normal 11 that would arise from the dif fe rent types of events 12 that might contribute to an increase in temperature b)
\\_
13 and pressure in the drain tank?
14 MS. MCDONALD:
Objection.
15 A
No, I did not feel that was part of the 16 effort GPU had asked us to do.
To analyze every 17 situation to take the existing procedures, mark 18 them up accordingly for Unit 2, and where we saw major 19 discrepanci,es or differences concerned, to address them.
20 It was not the intent to go off and reanalyze every 21 other conceptual problem that could exist.
22 Q
So I take it from your testimony that 23 you did not consider what the various increases would
(
24 be in temperature and pressure in the drain tank 25 from any of those events,specifically a stuck open PORV,
1 Shetler 102 2
a leaking PORV, a cycling of the PORV, cycling of the 3
code safety valve, a leaking code safety valve, or 4
any other-source that could lead to temperature and h
5 pressure increases in the drain tank?
6 MS. MCDONALD:
Are you asking whether 7
he felt it was necessary for him to consider i
8 that?
9 MR. MacDONALD:
I asked him whether he I
10 ever did consider it.
11 MS. MCDONALD:
Objection.
12 MR. MacDONALD:
If you want to answer 13 the question, Ms. Mcdonald, you may.
I have 14 asked the witness.
15 MS. MCDONALD:
I think he's answered it.
16 A
To answer your question, yes, I understood 17 that they would cause increases in pressurizer 18 temperature; I'm sorry, drain tank temperature and 19 pressure.
20 But as far as doing a reanalysis of how 21 much each inciden't would do, that, again, was not 22 the function of what we were serving there on the 23 site.
'.['
24 Q
You didn't consider in the section that l
f-M dealt with inoperative pilot operated relief valve to
1 Shetler 103 (D
\\~/
2 place in the procedure the temperature and pressure 3
increase in the drain tank from a stuck open PORV7 4
A Again, the concern the operator has to llk 5
or the item the operator has to be concerned with 6
is that there is an increase in pressure and 7
temperature and that is one of several symptoms that 8
would lead him to believe he had a leaking or 9
inoperative pressurizer relief valve.
10 Q
You understood, did you not, that that 11 symptom could come from a number of other places or 12 circumstances?
13 MS. MCDONALD:
Objection.
I don't 14 believe that's the testimony.
15 MR. MacDONALD:
I believe that based on 16 what we have talked about for the last ten 17 minutes, that that is obvious.
18 MS. MCDONALD:
Well, you may believe it's 19 obvious.
20 I am talking about what has been testified 21 to.
22 MR. MacDONALD:
Well, you can object j.
23 whenever you want, Ms. Mcdonald, and obviously
/~
24 on every question you want to object,
\\s)'
u i'
25 I am asking the witness did he understand I
Shetler 104 O
2 that that symptom, an increase in the reactor 3
coolant drain tank temperature and pressure, 4
if he understood that it could result from a 4h 5
number of other situations.
6 Ms. MCDONALD:
I object.
7 A
The answer to the question, again, is 8
yes, I understood that a leaking or inoperative 9
pilot operated relief valve is not the only cause 10 to increase pressure and temperature in the drain 11 tank, but it is a possible symptom for a leaking 12 or inoperative PORV and has to be considered by 13 the operator in his overall evaluation.
14 Q
And you also, I take it, understood that 15 it was a symptom of many other circumstances?
16 A
I believe I just said that.
17 MS. MCDONALD:
We have-been going over 18 this, and your attempts to make him change 19 his answer by asking it a hundred times is 20 I think torribly inappropriate.
21 This witness has answered the question 22 already.
23 MR. MacDONALD:
The question has certainly
(_
24 not been asked a hundred times.
25 MS. MCDONALD:
Excuse me, I am exaggerating.
1 Shetler 105 O
2 But I think they have been asked several 3
times.
4 MR. MacDONALD:
I think they have not been 5
answered in the sense that the question 6
deserves the answer and I think the reason 7
why I have continued on a number of occasions 8
to ask the question is because the answer has 9
not been responsive.
10 MS. MCDONALD:
I believe the witness' 11 answers have been responsive.
I object to 12 your characterization of the witness' answers.
13 (Whereupon at 12:50 o' clock p.m.,
a -lun ch 14 recess was taken.)
15 16 17 18 19 20 (Il 22 23 b
24 x3 25
1 106
{'
2 AFTERNOON SESSION 3
(1 : 35 p.m. )
4 JAME S R.
SH ET LE R,
resumed.
lh 5
EXAMINATION (Continued) 6 BY MR. MacDONALD:
7 Q
Mr. Shetler, you are aware that this 4
8 afternoon your testimony continues to be under 9
oath, are you not?
10 A
Yes, I am aware of that.
11 Q
I believe you testified earlier in the i
12 day that in a situation where a code safety valve b) 13 stuck open, that you didn't have an understanding 14 in that situatio level would rise while pressure was 15 falling.
16 I am not going to ask you to comment on 17 that.
I am just trying to give you a background 18 for my next question which is in a situation where 19 the pilot operated relief valve has stuck open, did 20 you have an understanding at or around the time 21 that you were working on these procedures that you 22 would see pressurizer level rise while reactor 23 coolant system pressure fell?
C) 24 MS. MCDONALD:
I object to the
. v 25 characterization of the prior testimony.
O i
~n
1 Shetler 107 2
I don't remember what he said.
3 MR. MacDONALD:
That's not part of the 4
question.
lll 5
MS. MCDONALD:
Yes, I understand.
6 A
The question again was?
7 Q
in a situation when a pilot operated 8
relief valve stuck open, did you have an understanding 9
at or around the time that you were working on these 10 procedures that pressurizer level would rise while 11 reactor coolant system pressure fell?
12 A
Well, I don't believe I had that O
t 13 understanding.
14 My understanding was that that was 15 initial phase of the incident level and pressure 16 would drop at which time it stayed open, HPI would 17 come on, you would recover.
18 Q
Both pressure and level?
19 A
And level, yes.
20 Q
Prior to the time you were working on 21 these procedures or at the time you were reviewing 22 these procedures, had you ever heard of any transient 23 where a PORV stuck open and level and pressure.
24 trended in opposite directions, that is, level rose 25 while pressure fell?-
1 Shetler 108 OG 2
A I do not recall one way or the other hear 4ng 3
of any incident which level rose and pressure fell 4
with a PORV stuck open.-
llh 5
Q Do you recall at'any time up until the 6
TMI-2 accident, did you understand that there 7
had been any transient whtre level rose and pressure 8
fell where a PORV was stuck open?
9 MS. MCDONALD:
I am not sure I heard the L
10 time period.
11 Can I have the question again?
12 MR. MacDONALD: 'During the time, the
\\_/
13 period when he was workin', for B&W since 1971 g
14 through the time of the accident, was there 15 any point in time that he ever learn d of a s
16 situation where a trans'ient occurred-where level 17 rose and pressure fell.
- c' 18 HS. MCDONALD:
Obj ection and 'I am,hoing
'i s
\\
i 19 to instruct the witness not to (qswer.,) '
20 Hir. knowledge up to and in c N4d ing.'th e s
21 time he'was. working on the procedures, his G
s s
22 procedureniare relevant to thi3N?eposition.
N' o
g y
23 I do not believe that the, scope cf the 'agreemenE \\
s, s
q f) 24 includes arf y t ing that he might have known
\\
v
- E %
25 generally up tc,[tae time of the ace,l,dsnt.
3
\\1 s
(\\[
\\
g
\\
1 Shetler 109 l
)
2 I instruct him not to answer.
3 MR. MacDONALD:
I think it definitely 4
includes portions of his duties and i
h 5
responsibilities as they were at B&W.
6 I am asking him in the course of chose 7
duties and responsibilities did he ever hear 8
from anyone at Lynchburg or anyone else at 9
B&W at any time prior to the Three Mile Island 10 accident of a transient where, when a PORV was 11 stuck open, pressurizer level rose as reactor 12 coolant system pressure fell.
Q(_)
13 MS. MCDONALD:
As I said before, I do not 14 believe the agreement relating to -- the 15 agreement regarding this deposition relating 16 to questions about his duties and responsibilities 17 can serve as a vehicle for inquiry on any topic 18 you wish to question him on as set forth in the 19 agreement.
20 You may ask him, and you already have, 21 what his duties and responsibilities are, and 9
22 I do not believe that this question falls within 23 the agreement, and I instruct him not to answor.
l 24 Q
Mr. Shetler, did you feel that you had 25 any obligation at any point in tine when you were
7.
. ' { }.,!
x;
\\
-\\
ll
/
t 31,r i
1
- e' l.
/[., 4 r# *
(, :s }
t
? (..
'I She tle'r 110 f
i
?O'%
A]( 2
~
r
~
i l})
\\
wo, king f'or B&W tprinform Met nd if you learned of j
r y
a ',
ff e y J..
t 3' l. inforu tion that ves different or affected in any way Q_ ( f f 3,,-
ll,
f t,
' ij.
J 2:.
t 4
the' piecedure s that you had previously reviewed and l
1,.
5 submittod to Metropolitan Edison?
j
/
h-1,
/
'f
/
M S '. MCDONALD, Objection.
f
~
You'aie asking him whether, for instance,
.(
7 t t
't j
8 when he was'. working at SMUD, is he supposed to i
i 9,
call up Met Ed and say sr.;mething about the 10-procedures?
11' MR. MacDONALD:
I am asking him whether 12 or not,'at any point in time when he was working l
13 for B&W, that he believed he had an obligation 14 to inform Metropolitan Edison if he learned 15 of events or circumstances such that they would 16 change in any way the procedures which he had 17 submitted to Metropolitan Edison.
18 MS. MCDONALD:
I instruct the witness not
-19 to answer on the ground that I do not believe i
20 that is in the scope of the agreement as to what 21 g
inquiry is permitted in this deposition.
22 MR. MacDONALD:
I thiak as with the other l
23 questions and answers, it's obviously in the 24 scope of the agreement.
25 The agreement talks about not only-his job.
1
1 Shetler 111 2
responsibilities and duties when he was at B&W, 3
but also any work that he may have performed on 4
the procedures relating to TMI Units 1 or 2, 5
and the question is germane to the extent that 6
we are dealing with any updating of those 7
procedures that he felt he would have to do, 8
and the question is geared towards that and 9
whether or not Mr. Shetler ever learned of any 10 information at or during the time that he was 11 reviewing these procedures or after that 12 period of time up to the point of the Three rh 13 Mile Island accident that would have caused him 14 to want to go back and update these procedures 15 in any manner.
16 MS. MCDONALD:
If you wish to ask Mr.
17 Shetler whether he had'any involvement with the 18 TMI-2 precedures after he left the site in 19 August of
'76, you may do so.
20 I will not allow the answer to the question 21 as' asked.
gg 22 MR. MacDONALD: Well, I think that's exactly 23 what I am asking him, but we can start
(~'%
, ()
24 preliminarily by asking whether or not, after 25 he had left TMI in August, 1976, did he end his 97
1 Shetler 112 2
responsibilities with relationship to the 3
TMI Unit 2 procedures that he previously worked 4
on.
5 MS. MCDONALD:
Are you asking him did he 6
do any further work on the TMI-2 procedures after 7
he left?
That's the question I will allow him 8
to answer.
9 MR. MacDONALDr The question was, and I 10 think it's perfectly appropriate, did his 11 responsibilities terminate with relationship 12 to the TMI-2 procedures when he left the O
13 site in August 1976.
14 MS. MCDONALD:
To the extent that you are 15 putting some meaning that maybe the witness 16 doesn't understand under the word 17
" responsibilities," I object to the question.
18 I will allow him to answer the question 19 did he do any further work on the TMI-2 20 p ro ce dure s after he left the site.
21 MR. MacDONALD:
Well, if you are instructing 22 him not to answer my question, then make that 23 instruction.
- -)s
(
24 I think the question is appropriate as 25 asked.
I am not going to chsnge it.
1 Shetler 113 2
MS. MCDONALD:
I don't.
i MR. MacDONALD:
Have you got an 3
instruction?
4 MS. MCDONALD:
Yes, I instruct him not 5
6 to answer.
7 If you wish to ask him whether he did 8
any further work on the TMI-2 procedures, you 9
may do so.
10 BY MR. MacDONALD:
11 Q
And I take it, Mr. Shetler, you 12 won't answer the question as to whether or not you 13 had any responsibilities with regard to the TMI-2 14 procedures after you left the site in August of 1976?
15 A
I believe I will defer to counsel's 16 suggestion.
17 Q
Mr. Shetler, I would like to show you a 18 copy of what's been marked previously as GPU Exhibit 19 354.
20 Have you ever seen a copy of this 21 document before, Mr. She.tler?
22 MS. MCDONALD:
I will not allow the 23 witness to answer questionr, related to this 24 document.
This document is dated May 7, 1979.
l 25 It clearly is after Mr. Shetler's involvement l
I Shetler 114 O
2 in the TMI-2 procedures and it's outside the 3
scope of this deposition.
4 MR. MacDONALD:
I don't know if it's 5
clearly outside because you won't let him 6
answer that question.
7 MS. MCDONALD:
You didn't ask the 8
question I told you I would allow him to 9
answer which is whether he did any further 10 work on the TMI-2 procedures after he left the 11 site.
You didn't choose to ask that question.
12 MR. MacDONALD:
All I am asking him today O
13 is to look at this document.
It's a simple 14 request in a deposition as to whether he's ever 15 seen it before.
Then you can direct him to 16 answer or not to answer at any point.
17 If you don't want him to look at a 18 document that I am presenting to him at a 19 deposition to tell me whether or not he's ever 20 seen a document before, you may do that, and I am g.
sura you will.
- 21 '
22 MS. MCDONALD:
Well, no, I will not allow 23 him to answer any questions including whether 24 he's ever seen this document before as this l
l-25 document clearly on its face, and as you very
[
.. ~.. -,.
1 Shetler 115 2
well know, is dated May 72 1979 and is after 3
the TMI accident and is outside the subject 4
of this deposition.
lh 5
MR. MacDONALD:
Well, I don't think that's 6
true and I don't think that's appropriate, but 7
regardless of that fact 8
MS. MCDONALD:
I instruct him not to 4
9 answer.
10 Q
I will j ust put this question to you, 11 Mr. Shetler.
12 Did you ever consider prior to the s/
13 time or at the time that you were working on the 14 Procedures for TMI Unit 2 including an instruction 15 to operators that a symptom of a stuck open PORV 16 could be pressurizer level increasing or indicated 17 high such that it was an opposite trend from 18 reactor coolant system pressure indicating low?
19 MS. MCDONALD:
Let the record reflect 20 that in giving his answer the witness is not 21 reviewing any document.
I also object because 22 I believe the question has been asked and 23 answered.
i
(
24 You may answer.
25 Do you want the' question read?
S 1
Shetler 116 O
2 THE WITNESS:
Yes, it would be helpful.
3 Q
The question is basically, Mr. Shetler, 4
whether you ever considered inserting in the lh 5
pressurizer symptom failure procedure for a stuck open 6
PORV the symptom that pressurizer level could be 7
increasing while reactor coolant system pressure 8
decreased while the PORV was stuck open?
9 A
To the best of my recollection, I do not 10 remembe r considering that item.
11 To the best of my recollection, I think, 12 as I have answered before, I do not remember that 13 there was any item where pressurizer level would 14 be -- whatever the question was -- rising while 15 the reactor coolant. pressure was decreasing.
16 Q
Did you ever consider at the time you 17 were reviewing the pressurizer system failure 18 inserting as a symptom for a stuck open PORV that 19 primary coolant temperature could be approaching 20 saturation?
21 MS. MCDONALD:
Could I hear that again?
22 (Record read back.)
23 A
I don't recall one way or the other f
i 24 whether I considered that.
V
~
25 My understanding at the time, again, was
1 Shetler 117
(~)
i 2
if it was in this incident depressurized below the 3
set point, HPI would actuate and return system 4
inventory.
k 5
Q And you would not have saturation, is that 6
what you are saying?
7 MS. MCDONALD:
Is there a question?
8 Q
And in that instance you didn't consider 9
that you would have saturation, isn't that correct?
10 MS. MCDONALD:
At any time?
At any time 11 in this transient?
12 MR. MacDONALD:
He has just answered a rh 13 question that he didn't consider putting that 14 into the procedure because he understood that 15 pressure and level would be recovering.
16 My follow-up question is just that 17 MS. MCDONALD:
You said pressure and 18 in ven to ry, I think.
19 MR. MacDONALD:
What he said he said.
20 I am not going to argue about that.
It's not 21 part of my question.
9 22 My next question was just that in that 23 situation, he did not expect to see saturated I
i 24 conditions in a reactor coolant system.
v' 25 Q
Isn't that right?
)
1 Shetler 118 2
MS. MCDONALD:
I believe he's answered 3
that question.
4 A
At that time I did not recollect or kh 5
do not recollect at that time that I expected to 6
see saturated conditions other than in the 7
Pressurizer assuming that during this incident 8
HPI actuated and was retained.
9 MR. MacDONALD:
I would like to mark as 10 GPU Exhibit 505 a document whose first page 11 is a letter from L.
C.
Rogers to J.
F.
Hilbish 12 dated February 20, 1976 the rest of the 13 document being draft of emergency procedure 14 2202-1.3, " Loss of Reactor Coolant /RCS Pressure."
15 (Multipage document, first page of which 16 is a letter from L.
C.
Rogers to J.
F.
Hilbish 17 dated February 20, 1976 with attached draft 18 marked GPU Exhibit No. 505 for identification as 19 of this date.)
20 Q
On the first nage of GPU Exhibit 505, 21 Mr. Shetler, the left-hand side of the page, do you 22 see where it says "LCS/JRS/ BAY"?
v 23 A
Yes, I do.
f~h
(,)
24 Q
The initials "dEE" are your initials?
l 25 A
Yes, I believe they are my initials.
I Shetler 119 O J 2
Q Is this a copy of a procedure, a loss of 3
coolant, loss of reactor coolant system pressure 4
that you reviewed during the time you were at the h
5 TMI site in October to August 1976, October 1975 6
to August 19767 7
A Yes, to the best of my recollection this 8
appears to be a procedure I was involved with taking 9
the Unit 1 procedure and marking it up to include 10 the Unit 2 items.
11 Q
And you conducted your review of this 12 procedure in a manner similar to what we discussed 13 earlier this morning wth regard to the pressurizer s
14 system failure procedure?
15 MS. MCDONALD:
Objection.
That's kind 16 of vague.
17 I am not exactly sure what you are asking.
18 Q
In terms of the manner of the review and 19 the reasons of the review you conducted of this 20 procedure substantially identical to that you 21 conducted for the pressurizer system failure procedure?
22 I am not going to go into each one.
I am 23 just trying to shortcut it a little bit.
l l [}
24 A
I reviewed this as the same reasons to 25 incorporate Unit 2 to specific items, and if there was
1 Shetler 120 0
2 any obvious thing that I felt was wrong with it, 3
to make notes of the changes.
4 Q
Did you understand at the time you were h
5 reviewing this procedure that the symptoms you would 6
see in the initial stages of a loss of coolant 7
accident was a loss of reactor coolant system pressure 8
and pressurizer level among others but just those two 9
specifically?
10 MS. MCDONALD:
How about all loss of 11 coolant accidents?
12 MR. MacDONALD:
Yes, in general.
13 A
Two of the possible symptoms you might see 14 as a part of loss of coolant accident would be loss 15 of inventory and loss of pressure.
16 Q
You said " loss of inventory."
I asked 17 specifically loss of pressurizer level and pressure, 18 and I take it that's what you were responding to?
19 A
The question you asked was pressurizer 20 level and pressure decreasing are symptoms of a 21 loss of coolant' accident?
22 Q
That's corr 2ct.
23 A
My answer is that loss of RC pressure and 24 loss of and reduction or lowering of pressurizer level,
, 25 as long as it is an indicaticn taken with the others
- -~
1 Shetler 121 0
2 in the system inventory, is an indication of a loss f coolant accident.
3 4
MS. MCDONALD:
Could you read that answer llh 5
back.
6 (Record read back.)
7 Q
Just so we are clear, Mr. Shetler, g
you understood at the time you were reviewing this 9
procedure that an initial loss of reactor coolant 10 system pressure and pressurizer level was a symptom 11 of a losa of coolant accident?
12 A
I understood that those two were (O
_/
13 possible indications of accident.
14 Q
Did you understand that in a loss of 15 coolant accident within the capability of the HPI 16 system to keep up with the flow that when HPI was 17 actuated, that reactor coolant system pressure and 18 pressurizer level would recover, in other words, 19 would rise?
I 20 MS. MCDONALD:
Could we have that read I
21 back?
22 (Record read back. )
23 MS. MCDONALD:
You are talking about in l -
24 a situation where HPI has automatically 25 actuated?
f
~
m
i 1
Shetler 122 O
4 2
Q We are talking about a situation -- let J
3 me make it clear, Mr. shetler.
4 You understood that an automatic
[
h 5
initiation of HPI could happen in many different 0
circumstances?
2 7
A That's correct.
I O
Q One of those circumstances would be in 9
an overcoolant transient, did you understand that?
10 A
Yes, I understood that an overcooling 11 transient could result in possible actuation of HFI.
12 Q
And another instance was a situation where 13 you had a loss of coolant accident that you could I4 automatically initiate HPI?
15 A
Yes, another possible reason or cause IO for actuation of HPI obtaining the low pressure set 17 point was loss of coolant accident.
18 Q
And you understood in situations where,in 19 your experience in loss of coolant accidents, HrI l
20 had b,een initiated automatically that the decrease 1
21
-in reactor coolant system pressure, pressurizer 22 level would stabilize and begin to rise; that is your 23 understanding of how those two parameters worked?
4 A
Can you repeat the first part of the 25 question?
l
1 Shetler 123
\\ J)
(
2 Q
I will repeat it if you have a problem.
j 3
Did you understand that in a loss of 4
coolant accident where HPI had automatically initiated lll 5
that you would see pressurizer level and reactor coolant 6
system pressure begin to recover after the injection 7
of HPI?
8 MS. MCDONALD:
You mean if the injection 9
were allowed to continue, if HPI stayed on?
10 MR. MacDONALD:
After HPI was initiated.
11 We are assuming HPI is on now.
12 Q
As it is on, I am asking you if you expected (3
(_,)
13 to see an increase in reactor coolant system pressure 14 in the pressurizer level.
15 A
Are we still talking about in the 16 capability of the 17 Q
We are not talking about a double-ended 18 guillotine.
19 A
In a situation where HPI can make up or 20 handle that size break, yes, my understanding was 21 when HPI was actuated, you would start to see an 22 increase in presr>ure level after that.
23 Q
Did you understand in a situation where
/~N 24 you had a leak or rupture of significant size such as L.)
25 engineered safety-features are automatically initiated
1 Shetler 124
)
O 2
which appears on page 6 of this procedure, that the 3
symptoms you would expect to see, two of the symptoms 4
you would expect to see are rapid and continuing lll 5
decrease in reactor coolant system pressure and 6
pressurizer level in the initial stage of the accident?
7 MS. MCDONALD:
Namely before HPI comes on?
O MR. MacDONALD:
That's right.
9 A
Yes, my understanding was that during the 10 initial phases of an accident like that that prior 11 to actuation of HPI, you would expect to see decrease 12 in pz asure and level.
)
13 Q
And that after the automatic initiation, 14 you would expect to see level and pressure rise?
15 A
Again, that would be a function of whether 16 it was within the capability of the HPI system.
17 Q
I take it you didn't have the understanding 18 that in those situations you would expect to see 19 pressurizer level rise while reactor coolant system 20 pressure fell?
21 MS. MCDONALD:
Again, before or after HPI 22 actuation?
23 MR. MacDONALD:
After HPI.
(G'].
24 A
Again, after HPI actuation, when the
~
25 assumption is maintained, I would not expect to see
1 Shetler 125 2
decreasing pressure and increasing level.
3 Q
Mr. Shetler, did you, during the time 4
you were conducting this review, expect to see lll 5
saturation in the reactor coolant system after HPI had 6
been automatically initiated duri:2g a loss of coolant 7
accident?
8 MS. MCDONALD:
Assuming it was left on?
9 MR. MacDONALD:
At the time it was 10 actuated and was on.
We are dealing with a 11 time that it's on, O.K.?
That's the question.
12 l
MS. MCDONALD:
I think the question is
()
13 unclear.
I mean, if you are talking about the 14 exact moment it comes on versus some --
15 MR. MacDONALD:
I am talking about the 16 period it was on did he expect to see during 17 that period of time saturation in the reactor 18 coolant outside the pressurizer.
19 A
It would depend on what size break we 20 are talking about.
21 Q
If we do not assume a large double-ended O
22 guillotine break of some sort.
l 23 A
Again, if we are assuming that it was (x
24 within the capacity of the ~ HPI system, the makeup of i
25 the break, my recollection is that I believe you
1 Shetler 126 w uld n t see any major voiding.
i 2
l There may be some minor voiding here and there, but nothing major that I was aware of would stay 4
asove saturation.
o aside from a 1ar,e areak, had you ever seen or heard of a loss of coolant accident prior to 7
the time you were reviewing these procedures in 8
whi h saturati n in the reactor coolant system had 9
i ccurred?
10 MS. MCDONALD:
Other than a large break gg 12 you are defining as a double-ended guillotine?
MR. MacDONALD:
Other than a large break 13 1 ss f coolant accident.
14 A
I believe we are restricting ourselves 15 16 to breaks within the capacity of the HPI system?
37 Q
We are talking about other than a large 18 break situation.
19 In any situation other than a large break situation, did you have an understanding 20 i
prior to the time when you were reviewing these n.g 22 procedures or around that time ever hearing or seeing 23 a transient involving a loss'of coolant where you had saturation in the reactor coolant system?
24 MS. MCDONALD:
Well, again, what 25 l-
-n
,n
..e-+
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1 Shetler 127
(~V) 2 you mean by a large break may make a difference 3
in the question.
4 You are talking about a break that's k
5 not within the capability of HPI?
6 MR. MacDONALD:
I am talking firstly 7
about within the capability of the makeup system.
8 MS. MCDONALD:
Makeup system?
9 MR. MacDONALD:
HPI.
10 A
That makes a difference as to how I would 11 answer the question, obviously.
12 Have I heard of a transient that actually i
13 occurred, is that what you are saying?
14 Q
Have you heard or seen of any 15 situation, a transient, simulation or otherwise, 16 or one that may have been analyzed in a report 17 somewhere, where in that situation, a loss of coolant 18 situation, you would have saturation in the reactor 19 coolant system outside the pressurizer?
20 MS. MCDONALD:
Before or after HPI came on?
21 MR. MacDONALD:
At any point in time..
9
\\
22 A
I believe I recollect I would expect to 23 see saturation at the break point. 'But as long as 24 it was in the capacity of the HPI to make up for that
,(
25 break point, I would not expect to see in my
I Shetler 128 O'
2 recollection at that time any large amount of voiding i
3 throughout the system or anything like that.
4 Q
Mr. Shetler, where were you on March 28, h
5 19797 6
A Crystal River, Florida.
7 Q
At the Florida Power Crystal River plant?
8 A
Florida Power Crystal River Unit 3.
9 Q
Did you participate at all in any of the 10 activities related to the accident at Three Mile 11 Island on that day?
12 A
No, sir, I was not involved in that.
O(_)
13 Q
Were you at Crystal River during a transient 14 that occurred there in February 19807 15 MS. MCDONALD:
Objection.
I believe 16 that's outside the scope of this deposition 17 and I instruct him not to answer.
18 MR. MacDONALD:
Well, I think we will 19 save a lot of time and e f fort, Ms. Mcdonald, if 20 he just answers the question yes or no.
You 21 may be able to instruct him on the next one, O
to'whether or not we may find something 22 but as 23 out during the period of time that he was there
. [}
24 I think you will save a lot of time and effort V
25 if you let him answer the question now yes or no.
1 Shetler 129 2
MS. MCDONALD:
It's going to be your last 3
question on that topic?
4 MR. MacDONALD:
Well, depending on the lll 5
answer I get, O.K.?
6 MS. MCDONALD:
Read the question again.
7 (Record read back.)
8 MS. MCDONALD:
I will let him answer that 9
one question.
10 A
No.
11 Q
Let me clarify one point here.
12 You were at Crystal River during the
()
13 period August 1979 and May 1980?
14 A
No.
I was at --
15 MS. MCDONALD:
He can ask another question.
16 Q
Where were you?
17 A
As I testified before, I was at the 18 Rancho Seco site after August
'79, through August 19 of
'81.
20 Q
When were you at Crystal River?
l 21 A
March o f '78 through August of
'79.
22 MR. MacDONALD:
I have no further questions.
23 MS. MCDONALD:
can we take a short break.
24 (Recess taken.)
25 MS. MCDONALD:
I have some brief I-
l 1
Shetler 130 0
2 cross-examination.
3 BY MS. MCDONALD:
4 Q
Mr. Shetler, while you were on the TMI I
5 site in 1975 and
'76, was there any practice regarding 6
informing GPU and Met Ed about concerns such as those 7
raised in GPU Exhibit 5047 8
A Yes.
9 It's my belief that at that time we 10 would inform GPU either verbally or in writing that 11 there was a possible need to consider a change in 12 the procedure or whatever the instance might be.
13 Q
Do you have a belief as to whether the 14 con ce rns raised in Exhibit 504 were handled in that 15 manner?
16 A
It's my belief that they should have 17 been handled in that manner at that time, yes.
18 Q
Do you recall testifying earlier today 19 that you did not consider putting the concept of 20 pressure and temperature into the procedure for an 21 inoperative code safety valve?
Do you recall that 22 testimony?
23 A
Yes, I remember we talked about that.
-[ /
i 24 Q
Could you tell me why you did not s-1 25 consider that?
1 1
1 Shetler 131 2
My question is can you tell me why you 3
did not consider that?
4 A
I believe that the answer probably should llh 5
have been not that I didn't consider it, but I didn't 6
consider the need to make that an addition 7
since the words in the procedure are leading you 8
toward a cooldown situation in which pressure and 9
temperature are re ferenced there, and, again, my 10 understanding of operator training and knowledge 11 that pressure and temperature is an item they are 12 concerned about all the time.
O 13 Q
So I understand that, Mr. Shetler, was 14 it your understanding that the concept was already 15 in the procedure?
16 MR. MacDONALD:
I object to the form.
17 That's obviously a leading question.
18 Q
What was your understanding regarding 19 what that procedure told the operators about pressure 20 and temperature, if anything?
21 MR. MacDONALD:
I object to that based 1
22 on the last question being leading.
23 Q
You may answer.
}
24 A
Again, it was my understanding that 25 pressure and temperature was implicit in there due
1 Shetler 132 0
2 to the fact thet we are talking about going to a 3
cooldown situation.
4 Q
Co you recall testifying earlier about llh 5
the possibility that. operators could throttle HPI 6
in response to an open code safety?
Do you recall 7
that testimony?
8 A
Yes, I do.
9 Q
Under what circumstances did you 10 understand the operators would throttle HPI in 11 response to an open code safety?
12 A
Would want to, would want to throttle 13 HPI in an attempt to maintain system inventory which 14 would be a function of his analysis of pressure, 15 temperature and pressurizer level.
16 Q
Do you recall testifying about tailpipe 17 temperatures and drain tank parameters earlier today?
18 A
Yes, I do.
19 Q
Did you undertake any analysis or did you 20 review any analyses regarding what temperatures might 21 be on the discharge line, on the tailpipe?
22 A
No, I believe as I testified earlier, I 23 did not conduct any analysis of that.
l-( )
24 Q
Why not?
25 A
It's my belief that detailed analyses were I
l
- + -.
y m
-w-y- - -.
w
1 Shetler 133 A
2 not required for this procedure.
3 The way GPU had the original Unit 1 4
procedure written and the format was such that ll 5
if there was any temperature above normal, it led the 6
operator to this procedure and the conservative 7
application of this procedure was close the block 8
valve.
That was the most conservative thing he 9
could do in any situation like this, and, the re fore,
10 I was not concerned with actual temperatures.
11 Q
The procedure you are referring to is 12 GPU Exhibit 352, is that right?
13 A
Yes, that is correct.
14 Q
You also recall testifying about 15 drain tank parameters earlier today?
16 A
Yes.
I remember we talked about that.
17 Q
Did you undertake any analysis or review 18 any analysis of what the sources of the increases in III temperature and pressure in reactor coolant drain tanks 20 might be?
l 21 A
No, I did not conduct the analysis of that.
I 22 Q
Why not?
l 23 A
Again, I did not consider it-to be a
('
24 necessary item for this procedure.
25 The way that it w'
'ormatted that GPU
-.w
1 Shetler 134 O
2 had done in the Unit 1 procedure was if there was 3
an increase above normal pressure and temperature in 4
the drain tank that it led him to this procedure.
lll 5
Again, the most conservative outcome of 6
this procedure was applying to shut the block valve.
7 That was the most conservative situation to do, and I 8
had no problem with that if that's the way GPU had 9
operated the plant.
10 Q
Do you recall testifying about what you 11 might have expected regarding saturation in the 12 reactor coolant system in a situation where you had 13 a break sufficient to have automatic actuation of HPI?
4 14 A
Yes, I recollect we talked about that 15 subject.
16 Q
What was your understanding as to why 17 you would not expect to have large amounts of 18 saturation in the reactor coolant system under those 19 circumstances?
l 20 A
My understanding was that within the l
21 capacity of the HPI that we are adding water to O
(
22 equal to or faster than the break was relieving it i
23 and, therefore, we would be reincreasing the pressure i
l l'
24 in the system and the inventory would not be
-.(_s)
I 25 approaching saturation.
1 Shetler 135 O
2 Q
Does GPU Exhibit 505, which is a 3
procedure; address the operation of HPI under the 4
circumstances which it has automatically actuated?
llh 5
A Yes it does.
6 Q
What does it say to do?
7 MR. MacDONALD:
In what part of the 8
procedure?
9 MS. MCDONALD:
Under circumstances when 10 HPI has automatically actuated.
11 Q
What does the procedure say to you?
12 MR. MacDONALD:
Immediately, follow-up f}
13 actions?
14 MS. MCDONALD:
At any time.
15 MR. MacDONALD:
I am not clear on whether 16 you are asking for his understanding or just 17 to read the procedure.
18 MS. MCDONALD:
I am asking for his 19 understanding as a person that reviewed this 20 procedure in 1975 and 1976.
21 Q
What was your understanding as to what 22 this procedure told the operators to do?
23 A
My understanding is that it essentially
[V~h 24 told the operator to maintain HPI until or unless 25 LPI came on with sufficient capacity to make up to
1 Shetler 136 2
the RC system.
3 MS. MCDONALD:
I have no further questions.
4 (Record read back.)
lll 5
MR. MacDONALD: I have a couple of 6
questions-Mr. Shetler.
7 BY MR. MacDONALD:
8 Q
Mr. Shetler, did you understand at this 9
time that you were reviewing these procedures that in 10 certain instances when HPI automatically initiated the 11 loss of coolant accident within the capacity cf the 12 HPI system, that you could get to a situation where,
(
13 as a result of the HPI being injected into the 14 reactor coolant system, that the system approached 15 a solid state including the pressurizer and you 16 were required to throttle back high pressure injection 17 to prevent the system from going solid?
18 MS. MCDONALD:
Are you talking about 19 where the entire RCS system is approaching solid?
20 MR. MacDONALD:
The question is what 21 it is.
G 22 THE WITNESS:
Would you repeat the 23 question?
(G^]
24 (Record read back.)
25 A
My understanding was at that time that if l
v-
1 Shetler 137 10 U
2 you were going to approach a solid condition in the 3
reactor coolant system, that you would want to 4
throttle back on HPI to maintain inventory.
lll 5
Q You understood that in the technical 6
specifications for Unit 2 that there were 7
specifications directing that you not fill the 8
pressurizer except in a hydrostatic test situation 9
to more than 335 inches?
Did you understand that 10 at the time you were reviewing these procedures?
11 MS. MCDONALD:
I object to the form.
12 A
I understood at the time that you did Ok-)
13 not want to fill the RCS system solid and that within 14 the pressure temperature restriction that said you 15 had a solid system 385 inches was an indication, a 16 maximum indication you wanted to get to.
17 Q
And you understood that was the 18 maximum indication, 385 inches in the pressurizer 19 level that was the tech specs limit that you could not 20 exceed, didn't you?
21 MS. MCDONALD:
I object to the form.
22 A
Again, I understood that was the tech 23 specs limit for a solid reactor coolant system or a (n) 24 full reactor coolant system.
j m
25 Q
And you understood that based on 385
l 1
Shetler 138 inches in the pressurizer, you were not to exceed that level where you would take the system solid, i
3 i
isn't that right?
4 MS. MCDONALD:
I object to the form.
e It's been asked and answered.
6 THE WITNESS:
Would you read the question 7
again?
1 8
(Record read back.)
?
9 Q
Let me try and --
l 10 A'
I don't recall that the 385 inches 2
11 necessarily was the limit of the system going solid 12 in the tech specs.
I don't recall that being the specific terminology.
14 7
Q You understood that the tech spec 15 l
talked about pressurizer level at 385 inches.
It 16 l
didn't say anything about a solid reactor coolant j.
17 3
system, did it?
j-18 MS. MCDONALD:
Objection.
19 A
I don't recall one way or another at 20 this stage of the game, right now, what-I remember l
- h
. 21 about the tech specs having specifically said at l
22 L
that time.
l D
l : q...
Q I take it from your prior testimony 24 l.
that you had no understanding based on either talking 25 w
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1-Shetler 139 2
to Bsw personnel, training personnel, or Met Ed 3
training personnel or any other training personnel 4
or plant operators that would lead you to a lll 5
determination of how operators were being trained to 6
Operate nuclear plants, did you?
7 MS. MCDONALD:
Objection.
I believe 8
that mischaract9rizes his prior testimony.
9 MR. MacDONALD:
All right, he can state 10 that.
11 MS. MCDONALD:
I don't think it's fair 12 for you to lead him to think he said that when
()
13 I don't think he did.
14 MR. MacDONALD:
I am not leading him
-t 15 to think he said that.
16 THE WITNESS:
Would you mind repeating 17 the question?
18 (Record read back.)
19 A
I believe, I remember what I said is l
20 I don't recall having discus 9).on one.way or the other
-21 about that.
22 MS. MCDONALD:
His question-related to j
f 23 whether you had any understanding about'that, j'
24 I think, based on conversations.
25 Q.
The question is simply, Mr. Shetler, l
1-Shetler 140
~
2 did you have any understanding based on any 3
conversations with any training personnel or operating 4
personnel in how operators were being trained to lll 5
operate nuclear plants?
6 Ms. MCDONALD:
I think the question that 7
came up before was did you have any idea.
8 I think that was the exact question.
i 9
A Again, my recollection is I had general 10 concepts of how they were being trained.
11 I don't remember specific conversations 12 with individuals about how they were being trained.
)
'13 Q
From where did you obtain your 14 understanding regarding operator training?
15 A
I don't really recall one way or the 16 other where I obtained that understanding.
17 Q
Did you ever sit in on any _ classes 18 with operators who were trained to operate a nuclear 19 plant prior to the TMI-2 accident?
20 A
No, I don't recall one way or the 21 other that I have-done it.
l 22 Q
You' don't recall having sat in on M
classroom sessions of operators being trained to if N 24 operate a nuclear plant, do you?
\\
M.
A I' don't recall one way or the'other J
=,
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1 shetler 141 0
2 whether I did.
3 Q
Did y u sit in on any simulator training 4
at which operators were being trained on how to lll 5
operate a nuclear plant?
6 A
I do not remember ever sitting in 7
on any operator training courses with operators 8
being trained on the simulator.
9 Q
It's a fact, is it not, that in 10 the pressurizer system failure procedure that you 11 reviewed and in the loss of coolant accident 12 procedure that you reviewed, that there are no O.
13 specific statements to the effect that operators 14 should look at pressure, temperature, and level 15 together to determine system inventory?
16 MS. MCDONALD:
Objection.
17 This has been gone into quite a bit.
18 May I have the question back, please?
19 (Record read back.)
20 MS. MCDONALD:
You mean those exact-words 21 versus a general understanding?
O 22 Q
You don't see in those particular r
99 procedures, do you, Mr. Shetler, that in the I
24 instruction to the operator that he look at pressure, 25
. temperature,-and level to determine system inventory?
.. ~. ~. _ -,. -,, _.... _
b i
Shotler 142 2
Do you see those words used together in 3
determining system inventory?
4 A
I do not see the separate words.
P-n lll 5
However, the general concept is in there.
p_
6 MR. MacDONALD:
I don't have any more 7
questions.
8 MS. MCDONALD:
I have one more question.
9 BY MS. MCDONALD:
10 Q
Did you have an understanding at the 11 time you were reviewing these procedures, Mr. Shelter, 12 as to whether pressurizer level was an indication
()
13 of whether the reactor coolant system was solid?
14 A
Pressurizer level is one of the 15 indications that you would use in determining whether 16 the system was solid or not, but in itself it's 17 meaningless without knowing what the pressure and 18 temperature are in the system to assure yourself 19 you are subcooled saturated or whether you are void 20 in the system.
21 Q
Did your definition at the time you 22 reviewed these procedures of the word " solid" include 23 the concept of void in the reactor coolant 24 system?
'N_/
25.
A That there would be voids if I was solid
1 Shotlor 143
)
2 you mean?
3 Q
Was that your understanding?
4 A
No.
Jll 5
To be solid, you would have to have no 6
voiding in the system.
7 MS. MCDONALD:
Thank you.
8 I have no further questions.
9 BY MR. MacDONALD:
10 Q
Mr. Shetlez, did you understand during 11 normal operation there could be voids in the reactor i,
12 coolant system?
(
13 MS. MCDONALD:
I object on the ground 14 it's outside the bounds of recross and I think 15 it's been asked and answered.
16 MR. MacDONALD:
I don't think that is 17 correct.
18 May I have the question again?
19 MS. MCDONALD:
Is it today?
20 MR. MacDONALD:
No.
Was it at about 21 the time he was working on it.
O 22 MS. MCDONALD:
Could there at that 23 time, during normal circumstances, could there 24 be voids in the reactor coolant system?
\\
25 THE WITNESS:
One more time?
1 Shetlor 144
(
2 (Record read back. )
i 3
A It's my understanding that there is J
4 a small amount of potential voiding in the core and gg 5
I say very small due to localized temperature 6
effects in the core.
7 Q
That was sometimes referred to as 8
nucleate boiling?
9 A
I believe some people refer to it as 9
10 that, yes.
11 Q
Did you understand it as nucleate boiling?
12 A
I don't recollect one way or the other that 13 I considered it nucleate boiling or not.
14 MR. MacDONALD:
I have no further 15 questions.
16 (Time noted:
3:10 p.m.)
17 JAMES R.
SHETLER 18 i -
19 subscribed and sworn to 20 before me this day 21 of 1982.
S 22 M
f 24
- b 25 y
k 1
145 4
2 CERTIFICATE 3
STATE OF NEW YORK
)
4
)
SS.
p COUNTY OF NEW YORK
)
5 I,
NANCY A.
RUDoLPH a Notary 6
Public within and for the State of New York, do hereby 7
certify that the foregoing deposition of 8
' JAMES R.
SHETLER was taken before me 9
on April 23, 1982 10 That the said witness was duly sworn before 11 the commencement of his testimony and that the 12 within transcript is a true record of said testimony; That I am not connected by blood or marriage 14 with any of the parties herein nor interested directly 15 or indirectly in the matter in controversy, nor am I 16 in the employ of any of the counsel.
17 IN WITNESS WHEREOF, I have hereunto set 18 c1.
my hand this e day of
'/
1982.
19 20 7
gg l>,.
e i
s, j N AN C'4 A.
RUDOLPH 22 23 24 23
t.
146 N
).
I NDEX i
WITNESS PAGE 9
James R.
Shetle r 3
EXHIB ITS GPU FOR IDENT.
4 503 Resume of James R.
Shetler 3
504 Three-page document, the first 36 page of which is a copy of a file folder labeled "EP 2202-1.5 NSS 5 Pressurizer System Failure - Stuck Open Spray Valve,"
with attached two-page memo 505 Multipage document, first page 118 of which is a letter from L.
C.
Rogers to J.
F. Hilbish dated February 20, 1976 with attached draft i
e 9
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