ML20072H960
| ML20072H960 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/24/1982 |
| From: | Lanese L GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-02, TASK-03, TASK-04, TASK-07, TASK-1, TASK-2, TASK-3, TASK-4, TASK-7, TASK-GB NUDOCS 8306290836 | |
| Download: ML20072H960 (128) | |
Text
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pos UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
______________________x GENERAL PUBLIC UTILITIES CORPO RATION,
s JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY arid
}
PENNSYLVANIA ELECTRIC COMPANY, Plainti ffs,
a 80 CIV. 1683
- ag ai n s t-(R.O.)
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
De fe n da nts.
x Deposition of Gene ral Public Utilities v]
[
Nuclear Corporation, by LOUIS C.
LANESE, taken by Defendants, pursuant to Notice, at the o f fice s of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on We dne s d ay, March 24, 1982 at 10:15 o' clock in the forenoon, before Joseph R.
Danyo, Stenotype Reporter and a Notary Public within and for the State of New York.
DOYLE REPORTING, INC.
(N CERTIFIED STENOTYPE REPORTER $
k.
369 LaxlNGToM AVENUE WALTER SHAPIRO, C.S.R.
New Yong. N.Y.
10017 CHARLES SHAPIRO, C.S.R.
TELapwoNe 212 - 867 8220 8306290836 820324 PDR ADOCK 05000289 T
1 2
2 Appe a ran ce s :
O)
C 3
KAYE, SCHOLER, FIE RMA N, HAYS & H AN DLE R, ESQS.
4 Attorneys for Plaintiffs 425 Park Avenue 5
BY:
STEVEN J.
GLASSMAN, ESQ.,
of Counsel 7
8 DAVIS POLK & WARDWELL, ESQS.
9 Attorneys for De fendants One Chase Manhattan Plaza 10 New York, New Yo rk 11 BY:
RODMAN W.
BENEDICT, ESQ.,
of Counsel 12 13
-s Also Present:
I(.-)
14 NINA RUFFINI 15 JULIE JOHNSON 16 17 18 19 IT IS HERFBY STIPULATED AND AGREED by and 20 among the attorneys for the respective parties 21 he re to that the sealing, filing and ce rtification lll 22 o f the within deposition be, and the same hereby 23 are, waived; that the transcript may be signed 24 before any Notary Public with the same force i
25 and effect as if signed be fore the Court.
l
1 3
l 2
IT IS FURTHER STIPULATED AND AGREED th at
(')
3 all objections, except as to the form of the
(._ /
4 question, are reserved to the time of trial.
g 6
7 LOU I S C.
LA N E S E,
having been i
8 first duly sworn by the Notary Public (Joseph 9
R.
Danyol, was examined and tes tified as 10 follows:
11 EXAMINATION BY MR. BENEDICT:
12 Q
Could you state your name and address for 13 the re co rd?
('}
14 A
Louis C.
Lanese.
My address is 8-149
\\_/
15 Ashland Court, Stanhope, New Je rs ey.
16 Q
What is your business address?
17 A
100 In te rp ace Parkway, P ars ipp any, New 18 Jersey.
19 Q
By whom are you currently employed?
20 A
Gene ral Public Utilities Nuclear 21 Co rp o r ati on.
9EF 22 Q
Is that a cubsidiary of General Public 23 Util3 ties Corporation?
24 A
Yes, it is.
25 MR. BENEDICT:
I would like to have marked f~y 1
l
1 LEnace 4
2 as B&W Exhibit 603, a copy of a res ume of 79
+
\\
K/
3 Louis C.
Lanese, which is taken from his restart 4
testimony in the f all o f-19 80.
5 (Copy o f res ume of Louis C.
Lanese was 6
marked B&W Exhibit 603 for identification, as 7
of this date.)
8 Q
Can you identify this as a resume which you 9
prepared or' had prepared for you for submittal to the 10 Atomic S a fe ty and Lice nsing Bo ard during the TMI-1 11 restart hearings?
12 A
Yes, it is.
13 Q
Wo uld you review it and tell me if there is (3
'(,)
14 anything that is inaccurate on it or that needs to be 15 updated?
16 A
Under " Education," you can striko 17
" Completing thesis."
18 Q
Have you completed your thesis?
19 A
No, I haven't, 20 Q
You have ab an do ne d, at least for the time 21 being, your thesis?
22 A
That's corre ct.
23 Q
You have a master's in engineering, and I l
24 take it the thesis was in preparation for a doctoral l
l
(~}
25 de g re e ?
l La'
Lonnse 5
1 2
A No, that is not co rre ct-3 Q
'What was the thesis?
4 A
In preparation for an enginee ring degree.
5 An engineer's de g re e.
6 Q
Is that an academic de gre e or a professional 7
de g re e ?
8 A
Academic degree.
9 Q
That was at the Polyte chnic Institute of 10 New Yo rk ?
11 A
Yes.
12 Q
Are you s till' taking classes at Polytechnic?
13 A
No.
(
14 Q
When did you stop taking classes?
15 A
My last semester was the f all o f 1978.
16 Q
Is your current job assignment indicated 17 on this resume?
18 A
I do work for the Safety Analysis and 19 Plant Control Se ction o f GPU Nucle ar Corporation.
The 20 group has since changed names.
21 Q
What was the name of the group?
4EP 22 A
It was Safety Analysis' and Plant Control.
23 Q
For GPU Service?
24 A
For GPU Se rvice.
It was changed to i
25 Safety Analysis and Plant Control o f GPU Se rvice, and-1 7-t 1
e 1
9
.s
.sw--
7
1 LnnROG 6
2 it is now a section in GPU Nuclear Corporation.
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3 Q
The resume indicates that you were with 4
GPU Service Corporation from 19 79 to present.
What is 5
the time that you switched from the Service Corporation 6
to the Nucle ar Corporation?
7 A
That is not correct.
8 Q
What is it that isn't corre ct?
9 A
I have been with GPU Service Co rpo r atio n 10 since January 1974.
11 Q
I think that is indicated at the bottom of 12 the first page.
I was referring rather to the issue, 13 not how far back you were with the Se rvice Corporation, c
'(-)
(
14 but when did you change from the Service Co rpo ration to 15 the Nucle ar Corporation.
16 A
I can't recall.
17 Q
Was it principally a change in the name of 18 the organization for which you worked?
19 A
Yes, it was.
20 Q
Did you change job responsibilities at the 21 time you moved from the Service Co rpo ration to the 4lP 22 Nuclear Corporation?
23 A
No, I didn't.
24 Q
Does the Service Corporation s till e xis t at 25 GP U?
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I l
1 Lenono 7
2 A
Yes, it does.
3 Q
Is your current title Senior Control 4
and Safety Analysis' Engineer?
5 A
No, it isn' t.
6 Q
What is your current title?
7 A
My current title is Safe ty Analysis-Plant 8
Control Engineer Senior 2.
9 Q
Is that a demotion, a promotion or 10 essentially the same position?
11 A
I have since been promoted since this 12 resume was written.
13 Q
Who is your present s upe rvisor?
14 A
15 Q
Is Gary Bro ghton a supervisor of yours?
16 A
He is Mr. Trikouros' boss, and he is my 17 supervisor also.
18 Q
For how long have you worked at a GPU 19 company?
20 A
Since January 1974.
21 Q
When were you first one.o f Mr. Broughton's W
22 j unio rs ?
When was he firs t one of your supe rvisors?
23 A
I do n' t recall.
24 Q
Could you describe your responsibilities 25 with your current job' assignment?
1 Lenac e 8
2 A
My present responsibilities are as-lead
()
3 systems engineer for TMI-1.
That encompasses reviewing 4
systems engineering responsibilities f o r TMI-1 designs, 5
for implementing safety analyses in which major code 6
modi fications are not required, and reviewing ce rtain 7
plant emergency procedures for te chnical content and 8
accuracy.
9 Q
What do you mean -- what is your task with 10 re spe ct to s afety analyses?
I am not sure I understand 11 that.
12 A
There is a division of responsibility 13 within our group between TMI and Oyste r Creek systems,
14 and also between code applications and code w
15 modi fi cations and developments.
16 Q
And your role with respect to safety 17 analyses is to perform analyses which do not req ui re 18 code modification?
19 A
That's correct.
20 Q
Is a safe ty analysis a study done for 21 purposes of submission to the NRC7 lEP 22 A
No, it is not.
23 Q
What is the purpose o f the safety analysis?
24 A
In general, it is not.
We do s a fe ty 25 analyses for seve ral reasons at this point.
In support b>
x-
1 Lenoco 9
2 of system designs, for design ve rification, in order
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f 3
to be tte r ur derstand analyses that are being pe rforme d 4
for us, priricipally by B&W, and to evaluate procedures 5
and determine the ef ficacy o f the procedure.
6 Q
By --
7 MR. GLASSMAN:
The witness used the word now, but I note the questions have not been 9
clearly delineated between curre nt time or some 0
othe r - time ?
Are the questions directe d to the 11 present?
MR. BENEDICT:
Yes, the question is:
What 13 are his job re spormsibilities today.
m 14
)
Q You said that one of the issues surrounding 15 s a fe ty analyses had to do with de te rmining the 16 e f ficacy o f proce dures ?
Is that what you said, or the 17 propriety of procedures?
You mentioned procedures.
18 When you s aid proce dures, you we re talking ab out 19 p roce dure s for the operation of the plants is that 20 co rre et ?
21 A
I didn't use the word "proprie ty " or the W
22 othe r word.
23 Q
You did use "e f ficacy" but pe rh aps not 24 with respect to procedures?
25 A
We are most interested in the emergency _
e
- - -.. ~
1 Lenano 10
,2 procedures for which a system enginee r is responsible
()
3 for reviewing them, reviewing the content and at times 4
determining if we can improve the content of the 5
procedure.
6 Q
What emerge ncy procedures is System 7
En ginee ring responsible fo r?
8 A
I can't give a comprehensive list.
9 Q
It is not all of the eme rgency procedures 10 for Unit 17 11 A
No, it is not.
j 12 Q
Do you know whether it includes the 13 procedures for loss of reactor coolant?
. ()
14 A
If by that, you mean-loss-of-coolant 15 accident, yes.
16 Q
Does it include the eme rgency procedure 17 relating to loss of pressurize r control?
18 A
I don't recall.
19 Q
Pressurize r f ailure, pressurizer relief 4
20 valve failures?'
21 A
I don' t recall.
4lP 22 Q
The Systems Engineering Group is the group M
to which you are assigned, I'take it?
24 A
That's co rre ct.
25 Q
How long has Systems Enginee ring had
_..,e..
.. ~.
,..m_
r
1 Lenoco 11 2
responsibility for emergency procedures for Unit 17 f%
(_,)
3 A
since octobe r 1981.
4 Q
Is that the time that GPU Nuclear was 5
e s t ablishe d?
6 A
I believe so.
7 A
Was there any equivalent organization in-8 GPU Service to the Systems Engineering Group prior to 9
the creation of GPU Nuclear?
10 MR. GLASSMAN:
I am not sure what you mean 11 by " equivalent," but he can answer if he 12 unde rstands it.
13 A
I don't know -- are you asking that question
()
14 with respect to responsibility for emergency procedures ?
15 Q
Why don't we have that.
i 16 A
No, there was no equivalent organization.
17 Q
In terms of your involvement and your 18 employment at GPU, what othe r involveme nt have you had 19 with respect to review or draf ting of operating l
20 ab no rmal or emergency procedures?
21 A
In what time frame?
$5!
22 Q
From the time you arrived at GPU in 1974 23 for either of the units on Three Mile Island.
24 A
Sometime during 1980, I began'to see 25 p ro ce dure s from TMI-1 in preparation for restart of the s,
o m
l l
1 Lonaco 12 unit.
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i
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3 Q
When you say, began seeing p ro ce dures,
4 do you mean you were reviewing them in order to 5
familiarize yourself with them or were you reviewing 6
them for some othe r purpose?
7 A
Again, this was for some selected 8
emergency procedures, but I was reviewing them and 1
9 pro viding comments to the plant staff.
10 Q
Comments to the plant staff with respect 11 to th e clarity?
With respect to the accuracy?
What 12 form -- what we re the areas 'upon which you commented?
13 A
With respect to operator actions and which 14 actio ns might be revised or added or deleted from the 15 procedure.
16 Q
Ltd you work with anybo dy on this project?
17 A
It was n' t a project.
18 Q
This task.
Is that an acceptable noun?
4 19 A
It was an informal review, and the person 20 who asked me to perform th at review was Gary Broughton.
21 Q
Aside from the instance you just mentioned, lh 22 can you recall any other involvement at any time during 23 your employment at GPU with operating abno rmal eme rgency 24 procedures for eithe r of the TMI units?
1 25 A
The re was ne ve r any other time on Unit 1
1 Lan3co 13.
2 that I had provided comments to the plant staff or i
3 review proce dures.
On Unit 2 there were two procedures 4
that I looked at in 1978 fo r Mr. Se e lin ge r.
5 Q
Could you tell me what procedures those 6
we re ?
7 A
There was a LOCA procedure and a steam line i
8 bre ak procedure.
9 Q
Do you recall which LOCA procedure it was?
2 10 It was for Unit ??
11 A
It was for Unit 2.
No, I don't remember 12 either the title or the identification numbe r.
13 Q
Do you know. whethe r it was a LOCA procedure
(
14 which encompassed LOCA's which would qualify as small 15 break LOCA's?
l 16 A
It was a procedure that looked at LOCA's 17 th at we re small enough to be handled by the normal 1
1 18 makeup system and LOCA's that required actuation of l
19 high-p re s s ure and/or low-pressure inj ection.
20 Q
Is that the full spe ctrum of LOCA's, as 21 far as you know?
h 22 A
Yes, it is.
23 Q
what did Mr. seelinger ask you to do -- did 24 he give you these two specific procedures?
25 A
They were mailed to me.
(N x) i l
l e
1 Lonsso 14 2
Q What did he'ask you to do with them?
()
3 A
He asked me to review them to de te rmine if 4
we had properly incorporated any FSAR analyses that had j
5 Leen performed.
6 Q
When you say -- to whom are you referring l
7 when you say "we" in that answe r?
-8 A
We, meaning GPU and Met Ed.
9 Q
So you were not referring to you personally 10 or to your group pe rsonally; you we re referring to 11 whoever it was who drafted the procedure and got it 12 to the condition it was in when it arrived on your desk?
1 13 A
That's right.
At that time we had no i
(
14 responsibility and no involvement in drafting j
l 15 p ro ce du re s.
16 Q
Your section had none?
17 A
GPU Service Co rpo ratio n.
18 Q
GPU Se rvice Corporation in its entirety?
19 A
That's right.
20 Q
Had you worked with Mr. Seelinger be fore 1
21 this time?
lll 22 A
I had conversations with him previous to 23 this time, yes.
24 Q
Did any of those co nve rs ations relate to 25 operating or other procedures ?
1.
Lanoco 15 2
A No.
3 Q
what did you do with respect to these two 4
p ro ce dure s ?
5 A
I reviewed them, marked up some comments O
6 on them.
I remember that Gary Broughton reviewed them 7
and commented on them, and I don't remember the 4
8 resolution of the comments with Mr. Seelinger.
9 Q
Did you discuss with Mr. Broughton your.
10 comments?
11 A
Yes.
12 Q
Did he review the copies of the p ro ce du re s 13 that had your comments on them as you recall?
14 A
Yes.
15 Q
You do not recall what became of your 16 comments af ter you passed them along to Mr. Seelinger?
17 A
I do n' t remember if the re were comments 18 that I felt required passing along to Mr. Seelinger.
19 Q
So at this point you can't recall whether 20 you made any comments on the procedures which you then 21 passed to Mr. Seelinger or to someone else at Met Ed?
gy, 22 A
No.
I do not remembe r making any 23 substantial comments, how e ve r, or at that time believing 24 that the re were any substantial comments.
l i
25 Q
Just so the re cord is clear, are you saying l
l l
1 Lanone 16, 2
at_this stage you can't recall one way or the other
)
3 whether you had substantial comments, or do you in fact J
4 recall that you did not have s ub s tantial comments?
5 A
I remembe r that the comments weren't 6
substantial in the sense that they required documentatior, 7
and resolution.
8 Q
Do you know what time during 1978 this 9
o ccurre d?
10 A
April-May time frame of
'78.
11 Q
Did Mr. Seelinge r give you any indication
^
12 of his motivations for sending these two specific 13 procedures along to you?
~
14 A
Only that he was inte reste d in assuring 15 that the analyses that we had performed in the FSAR 16 were being reflecte d in the proce dures.
17 Q
I take it these were procedures currently 18 in force, the ones you were provided with?
19 A
Yes.
20 Q
They were the current draft o r revision, 21 wh ate ve r, of those two proce dures?
4lP 22 A
Yes, they were.
23 Q
Did you follow up on this issue to determine 24 whether any changes had been made to these procedures ?
25 MR. GLASSMAN:
What issue?
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'Lan30s 17 2
MR. BENEDICT:
The issue only of reviewing
)
3 these proce dures.
4 Q
Do you know whether any changes were made 1
5 to these procedures subsequent to your review?
l 6
MR. GLASSMAN:
Are you talking about 4
-7 changes made as a result o f Mr. Lanese's comments, 8
if any?
9 MR. BENEDICT:
More broadly.
I 10 Q
Do you know whether any changes were made,
11 following your review of these procedures,to them at 12 any time up to'the day o f the ac ci de nt in Three Mile 13 Island which was March 28, 19797 14 A
No.
15 Q
Do you recall whether or not you 16 corresponded with Mr. Seelinger?
Wrote him a letter-i 2l 17 with respect to your comments or your lack of comments?
7
)
18 A
I neve r documented any comments on the ' procedures.
I 19 Q
Do you still have the copies of.the
=
1 j
20 p ro ce dures that Mr. Seelinger sent you that you 21 comme nted on?
lll 22 A
Yes, I do..
I 23 Q
Are they in your files at Parsippany?
{
24 A
-Yes, they are.
c 25 MR. BENEDICT:
.I do not re' call seeing l
..-/
1 Lennaa ja 2
them.
I would appreciate them, if they have
,rx
(_j) 3 comments on them, being produce d.
4 MR. GLASSMAN:
May I speak with the witness 5
for a moment?
O 6
MR. BENEDICT:
Sure.
7 (Dis cussion of f the re co rd. )
8 MR. GLASSMAN:
We be lie ve I believe 9
after consulting with the witness that the 10 documents to which he is re fe rring have been 11 produced to you.
12 MR. BENEDICT:
I just talked to Nina 13 Ruffini.
She says we did get them.
We did get n
(v) 14 two boxes of documents or half boxes of documents 15 from you, one last week and one two days ago, 16 and I will admit I haven't had an opportunity to 17 look at e ve ry page, so we can come back to this.
18 MR. GLASSMAN:
I gather if your assistant 19 here has a re collection o f it, then you will be 20 able to review that, and if you think it is 21 suf ficiently interesting to pose any questions l
llk 22 to Mr. Lanese, we will be glad to have Mr. Lanese 23 answer any questions.
24 MR. BENEDICT:
That seems f air to me.
25 S
Q Othe r than this instance, the instance with m
1 Lanese 19 2
Mr. Seelinger in 1978 and the time in 1980 with the 3
Unit 1 procedures, can you recall any othe r involvement 4
you had with reviewing or drafting o r commenting upon 5
Three Mile Island procedures?
6 A
In the course of preparing a response to 7
an NRC question, I read the h e a t-up and cool-down 8
p ro cedure s for TMI-1.
9 Q
Do you recall the time that you did this ?
10 A
1977.
Possibly late 1976.
11 Q
Has there eve r come a time in the course 12 o f your employment that you made a gene ral review of 13 procedures, Three Mile Island procedures, in order to 14 f amiliarize yours elf with them?
15 A
TMI-2 procedures?
16 Q
Either Unit 1 or Unit 2.
17 A
The answer for Unit 2 is never.
The answer 18 for Unit 1 is th at we ' re in the p rocess o f -- we ' re 19 continuing to review emergency procedures at TMI-1, 20 those that are our responsibility and will be e xp e cte d 21 to indicate our concurrence with the exis ting p rocedures h
22 to GPU management p rio r to re s ta rt of the unit.
23 Q
When you say "our responsibility," who is 24 "our"?
" * " " " ^ " '
O
1
'Lenoco 20 2
the words that were used by the witness.
I think 2
()-
3 the witness talked about our concurrence, some-4 thing to that effect.
5 MR. BENEDICT:
I agree he did say that, 6
too, but at an earlier point, he said "those 7
procedures which are our responsibility."
8 A
Systems Enginee ring of GPU Nuclear.
9 Q
Who allocated to this Systems Engineering 10 Group the procedures which you are responsible for now?
11 A
I don' t know.
12 Q
You tes tified e arlier that this is not 13 you know that the p ro ce dure s for which you are
(
14 responsible do not rep re s e nt all o f the eme rgency i
15 p roce du res for Unit 1.
Do you know who else at GPU 16 or GPU Company is responsible for the othe rs, if anyone?
17 A
Someone else, othe r people are.
I don't 18 know who the y a re.
19 Q
H aving finished. for the time being 20 discussing procedures, what has been your involvement 21 while wo rking for GPU with technical specifications ?
lll 22 i
MR. GLASSMAN:
What time frame?
23 MR. BENEDICT:
Anytime from '74 to today.
24 A
While I was the s afe ty and licensing engineer l
25 for TMI-2, I had some involvement in Tech; Spec i
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l l
,~
Lenoco 21 y
2 de ve lopme nt, although the majority of the responsibility
.(m,)
3 rested with Metropolitan Edison.
i, 4
On occasion, since I have been in S afe ty 5
Analysis and Plant Control since 1978, I have re viewe d 6
te chnical spe cifications as a member of Safety Analysis 7
and Plant Control, or commented on them.
As a me mb e r 8
of the Generation Review Committee, I also reviewed 9
tech specs on Unit 1 and Unit 2 from time to time.
10 MR. GLASSMAN:
I would like to take a 11 one-minute recess.
12 (Discussion off the record between the 13 witness and his co un s e l. )
(~)
14 MR. BENEDICT:
I was talking to Ms. Ruffini V
15 about the documents that I first thought we 16 didn't have, and there is a problem with them.
17 The problem is that great portions of the docume nt 18 have been highlighted, and when they were Xe ro xe d,
19 they came out black, so we can't tell what was 20 highli gh te d.
I recall during Broughton's 21 deposition you did bring in original files in s
qgy 22 order that we could read into the record the 23 portions that were highlighted.
If you can do 24 that tomorrow, we can cover that then.
25 MR. GLASSMAN:
We're talking now about V
1 Lenoca 22 2
particular procedures?
,a
(_/
3 MR. BENEDICT:
It was the two procedures 4
that were referred to, the LOCA p rocedure and 5
the steam line break procedures.
We will give 6
you the document n umb e r.
7 MR. GLASSMAN:
That would be helpful.
8 If you give us the document numbe r, we will make 9
our best e f fort to have it he re as soon as 10 possible.
Certainly before the end of the 11 q uestioning o f Mr. Lanese.
12 MR. BENEDICT:
Could you read back the 13 last question and answer?
A'
(_j 14 (Record re ad. )
15 BY MR. BENEDICT:
16 A
Could you des cribe for me the job 17 responsibilities of the safety and licensing engineer for 18 TMI-2 during the time that you held that position?
19 MR. GLASSMAN:
By " responsibility," you 20
'a r e talking about them in the functional sense, 21 not in the legal sense?
llh 22 MR. BENEDICT:
Yes.
23 Q
What did you do on a day-to-day basis?
24 What was your job?
(s 25 A
My job function was to deal with the N) e
1 Lenaco 23 2
Nucle ar Regulatory Commission, become familiar with the gx
)
3 questions that they had regarding the TMI-2 plant,
\\. J 4
resolve those questions in order to receive a favorable 5
safety evaluation report from th e staff and ultimately 6
receive an operating license for the plant.
7 In doing that, I was require d to 8
coo rdinate responses that were p ro vi de d f ro m B &W, Burns 9
& Roe, the architect-engineer, from time to time othe'r 10 co ns ultin g firms, review the information, comment on 11 it, re s ol ve inte rnal questions abo ut the responses, 12 and present and provide those responses to the NRC 13 staff.
(~)
14 Q
Did you work with a specific section of the
'wJ 15 Met Ed organization in order to accomplish this function S
16 A
My normal working relationship was with the 17 Met Ed licensing group.
18 Q
Who was the head of that group at the time 19 you were in this position?
Do you recall?
20 A
No, I do not.
21 Q
Do you recall who it was that you worked 4EF 22 with most re gula rly ?
l 23 A
Yes, Courtney Smyth.
l 24 Q
How did te chnical specifications come up 25 or come to your attention in the course of pe rforming p_
i
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e
1 Lanaco 24 2-
'the tasks that you j ust des cribe d?
3 A
Most of the technical specifications were 4
provided by B&W, and then it was my function to 5
coordinate in-house comments and provide them to Met Ed.
O 6
Q Between your unit and the' licensing unit at 7
Metropolitan Edison, who had the ultimate responsibility 8
for dealing with the NRC?
9 MR. GLASSMAN:
Yo u a re saying if there was 10 one individual?
11 MR. BENEDICT:
Not individual, as between 12 thos e two groups, on the issues of the s afe ty 13 evaluation repo rt.
()
14 A
There was a split responsibility.
Anything-15 that would affe ct design and construction of the plant 16 was the responsibility of GPU Se rvice Co rpo ration.
17 Issues that affected operations were the responsibility 18 of the operating utility, namely, Met Ed.
19 Q
Un de r -- on whi ch si de of that dichotomy 20 did te chnical specifications f all or were they split?
21 A
Met Ed had the functional responsibilities f
ggP 22 f : p rovidin g the tech specs to NRC or proposing the 23 te ch spe cs to the NRC.
24 Q
If it can be done, between the two i
25 organizations, the two licensing organizations, one i
1 Lensco 25 2
being at Met Ed and the other being at GPU Se rvice, who
, 'N
(._,)
3 had ultimate responsibility for the licensing process 4'
overall for Unit 27 5
A That resided within GPU.
6 Q
Was it within the Licensing Department of 7
GPU Service or was the re anothe r group ultimately 8
responsible?
9 A
Ultimately the proj ect manager made 10 decisions about the licensing of the unit with NRC.
11 Q
For what GPU subsidiary did the proj ect 12 manager work?
13 A
GPU Service.
14 Q
Do you remember what his name was up until 15 the time that the operating licens e was issued on 16 Unit 27 17 A
- Yes, r
18 Q
What was his name?
19 A
Richard Heward.
l 20 Q
He is the person you were talking ab out as l
21 having the responsibility as you recall?
$EP 22 A
Yes.
23 Q
Looking at your resume which is B&W 603, 24 at the bottom where we ' re talking about the -- I 25 take it fir s tly, th a t the '74 to ' 77 pe riod j ob
{g
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~.
1:
Lan200 26' 2
description and the ' 77 to ' 78 period job description 3
indicate to me that you were promoted but did you stay 4
within the same area of responsibilities ; is that 5
corre ct?
You went f rom a s a fe ty and licensing enginee r 6
to a lead nuclear licensing engineer?
Is that the 7
same job with a promotion or was that a di f fe re n t j ob ?
8 A
It was an expansion of functionh1 9
responsibilities.
10 Q
But it was within the same unit or group?
11 A
Yes, it was.
12 Q
It says un de r '74 to ' 77 that your 13 re s ponsibili tie s include d te chnical resolution of TMI-2 14 licensing open items.
Among these open items I take 15 it were the issues that we have been discussing with 16 respect to te chnical specifications, is that right?
17 MR. GLASSMAN:
In general terms?
18 MR. BENEDICT:
In general, the issue of 19 how technical specifications would come to Mr.
20 Lanese's attention.
21 I will s trike the question and start again.
S 22 Q
What do you mean when you have written here,
i 23 "Re sponsibilities ' include d te chnical resolution o f TMI 24 licensing"?
25 A
It did not include te chnical spe ci fic ation s.
1 LanGae 27 2
Q What did this task include?
' O)
(_
3 A
It included coordination, review, comment, 4
negotiation with NRC staff on issues relating to plant 5
safety when they af fe cted design.
Essentially the 6
design of the plant since that was the GPU function.
7 Q
Principally by design, you me an the hard-8 ware components and their construction?
9 A
Yes.
10 Q
Would the computer and its software that
-11 was used for Unit 2, would that have fallen under the i
12 responsibility of GPU as design or would it have fallen 13 under the responsibility of Met Ed as operations?
(
14 A
I don't know.
15 Q
Were you involved with choice and the issue 16 of access and the program to the compute r used in the 17 control room at TMI at any time?
18 A
no.
Could you specify what you mean by 19 "you"?
20 Q
You personally?
'21 A
No, I wasn't.
lll 22 Q
Do you know of anybody within your licensing 23 unit o r g ro up that was involved with those issues?
24 A
No, no one was.
25 Q
Moving to the '77 to '78 time period, which
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p-
,p
,W
1 Lenoco 28 is the last full paragraph on your resume, it says 2
primarf resp nsibility ' for TMI-2 licensing activities.
)
3 4
How is that, if that job is di f fe ren t from the one we dis cus s 3 d for your earlier period, how is it di f fe re nt ?
5 O
6 A
There were no dif fe rent responsibilities 7
with respect to Unit 2.
Ag ai n,
f un ctio n a'l responsi-8 bilities.
My job function was dif fe rent in that I 9
be came involved in Forked River licensing in providing 10 guidance to the Forked River licensing engineer and 11 occasionally. commenting on Oyster Creek issues as well, i
12 and being involved in generic issues that af fe cted TMI-l i 13 TMI-2, and Forked River.
(~
14 Q
Forked Rive r has never been constructed; V) 15 is that correct?
16 A
It was abandoned with less than one percen t 17 construction complete, yes.
18 Q
In the proposal, who was to manufacture the 19 reactor coolant system or'the steam supply system?
20 A
The nuclear steam supply system was provided 21 by Combustion Engineering.
(g) 22 Q
When yo u s ay ge ne ri c s a fe ty is s ue s for the 23 units, the two units on TMI and the Forked Rive r plant, 24 I take it you me an issues relating to pressurized wate r 25 re actors ?
1 LcnOco 29 2
A Issues that were applicable either to all g
(l three p ressurized water reactors or issues that were 3
4 applicable to all four of the reactors including Oyster 5
Creek.
6 Q
Who was your superior during this time 7
period?
8 A
Fo r much of that p e rio d, the safety and 9
licensing manage r's job was unfilled, and my imme diate 10 superior was Mr. Jack Thorpe, who was the director of 11 environmental affairs.
12 Q
You obviously -- there is a great
~
s 13 in your tit 1e during 1978.
What occurred.to TN.
- ),
14 cause that change?
\\_
15 A
The previous s afe ty and licensing manager 16 was Tom crimmins, and before he transferred ove r to 17 Jersey Central Powe r & Light, he change d the functional 18 organization of the g ro up to make it, what he. felt was 19 more responsive to our nee ds.
"Our" meaning GPU 20 Safety and Licensing and the service corporations.
21 Q
Was the Safety and Lice nsing Group divided? '
22 A
We tried to delineate more clearly between f
i x
23 l
nuclear licensing activities and fossil' fuel licensing
.l 1
24 activities.
(~';
25 Q
How did your job change as a result of this
~,i 1
1 Lentoo 30 2
reorganization?
(%
(_)
3 A
I gave up responsibilities for procuring 4
non-nucle ar-relate d pe rmits.
There were no changes in 5
responsibilities with respect to TMI-2.
I began to 6
become somewhat more involved in TMI-1 on generic 7
issues, and the same was true fo r Fo rked Rive r.
I 8
be came more involved in Forked Rive r.
9 Q
Do you recall when the construction permit 10 was issued for Unit 2 at Th re e Mile Island?
s 11-A Yes.
s
'12 Q
When was that?
[
13 A
February 8,
1978.
(
14 Q
The construction pe rmit?
15 A
I'm'sorry.
I believe it was July 1973.
x 16 Q
I take it the Feb rua ry 8,
1978 date is the 17 i'
date which the operating li ce ns e for Unit 2 was is s ue d?
s-
~
18 A
That's co rre ct.
19 Q
Did your responsibility, or did GPU 20 Service's responsibility to TMI Unit 2 ch ange following 21 the issuance of the operating license?
IEE 22 A
I'didn't unde rstand the ques tion be cause I 23 realized that the construction pe rmit was not issued in 24 1973.
)
j g
s'
.s ss 25 Q
When was -- when do you recall the
%J s
s.
s T
I' a
s
1 Lenoco 31 2
construction permit being issued?
[V 3
A I don't reme mbe r.
4 Q
Not worrying at this point about the 5
construction permit and moving on to the issue of the
.O 6
date of the operating license, did your responsibility 7
in licensing or as you unde rstood it, did GPU Service's 8
responsibility with respect to TMI-2 change as a result 9
of TMI-2 receiving its operating license?
10 A
Yes, it di d.
11 Q
How did it change?
12 A
Af ter issuance o f the operating license,
13 functional work responsibility shifted to Met Ed
(
14 licensing, and GPU safety and licensing functioned on 15 an as-requested basis.
16 Q
so if I un de rs tand ---
17 A
And also to continue to have responsibility 18 for design and construction activities that were 19 committed to in order to receive the operating license.
20 Q
In other words, the re were some issues that 21 were still open at the time you re ceived or. the (gP 22 operating license was granted and the operating li ce ns e 23 was conditional upon their completion?
24~
A No, that is not quite co rre ct.
25 Q
Let's j us t say there were issues that were v
i Lanoco 32 2
open prior to the issuance of the license which was
\\' l 3
being handled by GPU and they continue to be handled i
4 after the issuance?
Is that more accurate ?
5 A
The issues were resolved within NRC staff.
6 What remained was the implementation of the resolution.
7 Q
wh'at was the e ffe ct of this change on your 8
work load?
Did you shift your attention in a 9
significant manner to another subject?
10 A
There was a gradual change in my work 11 ac ti vi tie s.
After the operating license was issued, I 12 was able to focus more on my chairmanship o f the 13 Assymetric LOCA Load Subcommittee which had an impact C';
(_)
14 on Unit 1 and Unit 2 and also to concentrate on the 15 hardware modifications for Unit 2.
16 Q
You mentioned the Assyme t ric LOCA Load 17 Technical Subcommittee, that committee membe rship is 18 liste d under " Professional affiliations" on your 19 resume on the second page o f Exhibit 60 3.
20 Are there any other professional af filiations 21 that you didn't list here that now would be app rop ri ate ?
h 22 A
Yes, there are.
23 Q
Could you list them for us?
24 A
Since May of last year, I have been the
(;
25-chai.rman o f the B&W owne rs Group Analysis S ub commit t e e.
J
1 Lcn32G 33 2
Q Is there anything else?
,.-.b 3
A No.
4 Q
You list no professional publications here.
5 Do you have any professional publications?
6 A
No, I do not.
7 Q
Can you tell me what hardware modifications 8
for Unit 2 you were working on during the period from 9
the issuance of the operating license through until the 10 accident 14 months later?
11 A
I can't recall all o f them.
12 Q
List the ones you recall.
13 A
There were mo di fi cations that were (m) 14 committed to on the main feed water system, 15 modifications with respect to plant temperature 16 monitoring in the auxiliary building and control 17 buildings.
That is ambient temperature conitoring.
18 Q
Main feed and plant temperature in 19 a uxilia ry and control building.
Any other?
20 A
The re were othe rs.
I can't recall them at 21 this time.
lll 22 Q
You have listed under your resume in the 23 second f ull paragraph on the bottom, " De ve loping l
24 analyses in support of the TMI-2 feed water system
,f y 25 mo di fi ca ti o n. "
Are you there referring to the i
!%./)
1 Lensse 34 2
mo di fications to main feed water system you just
(~%.
()
3 mentioned?
4 A
Yes, that's co rre ct.
5 Q
Could you tell me what those modifications O
6 or proposed modifications were or were to be?
7 A
The addition of safety grade main feed 8
water block valves in the feed wate r piping of TMI-2.
9 Q
'What was the -- what would be the purpose 10 of these valves if installed?
11 MR. GLASSMAN:
Are you asking --
12 MR. BENEDICT:
His understanding at the 13 time.
()
14 A
To mitigate the consequences of large steam 15 line b re aks.
16 Q
We re they in fact installed at U n i t.:2 7 17 A
No, they were not.
18 Q
Did they exist at Unit 1 or equivalent 19 valves exist at Unit 1 at that time?
20 A
No, they did not.
21 Q
Are they -- are valves equivalent in
$5P 22 function going to be installed in Unit 17 23 A
No, they are not.
24 Q
In the course of your review o f the main l
25 feed water system, did you have any opportunity to l
i Lcnoco 35 review the demineralizing system for feed wate r at 2
fm
. 27 Unit
)
3 v
A No.
4 Q
Y u had n resp nsibility with respect to 5
O 6
reviewing thnt?
A No.
7 g
Q Moving up to the top paragraph under 9
" Experience " which is '79 to the p res ent, with the 10 mo di fica tions we talked about e arlie r, you indicate 11 that your responsibilities in clude d "TMI-1 eme rge ncy 12 feed wate r design."
13 Could you tell me what that work entailed?
f^))
14 A
We have committed to make the emergency
'w 15 feed wate r system at TMI-1 fully safety grade.
In the 16 process of revising the system, we also made p7 mo di fi cations to it to improve the operational 18 characteristics of the unit when emergency feed water 19 is operational.
20 Q
Was any work in this area done prior to 21 the accident on March 23, 1979?
llP 22 MR. GLASSMAN:
Work by whom?
23 MR. BENEDICT:
Any work he is aware of on 24 the de si gn o f th e TMI-1 e me rge ncy fee dwater or 25 modifications to the design.
i i
G/
1 Lensco 36 2
A No.
3 Q
was there any wo rk, to your knowledge, with 4
re spe ct to the design of the emergency fee dwate r or 5
modifications to the design of the fee dwate r at Unit 1 6
prior to the accident at Th re e Mile Island?
7 A
Not that I am awa re of.
8 Q
When do you first recall being involved 9
in a review of the TMI-1 emergency fee dwate r system?
10 A
In the summer of 1979.
11 Q
Furthe r down in that same firs t paragraph 12 unde r "Expe rie nce," you say "Me mbe r o f th e TMI-1 and 13 TMI-2 S afety Review Committees (GRC). "
What is the (h
(_ !
14 GRC?
15 A
GRC stands for Gene ration Re view Committee.
16 Q
That is a committee within General Public 17 Utilities?
18 A
Presently it is a committee within General 19 Public Utilities, yes.
20 Q
When did you first become a membe r o f the 21 GRC?
h 22 A
Sometime in 1979.
23 Q
Do you remember whether it was be fore or 24 after the Three Mile Island accident?
r'^)
25 A
It was afte r the accident.
V i
1 Lcnocs 37 2
Q Did you replace someone?
Did you fill 3
someone else's spot at that time?
4 A
No.
Q Who asked you to be on the GRC?
6 A
No one asked me to be on the GRC.
Q Who directed that you be on the GRC?
8 A
I believe Mr. Wilson de te rmined the 9
membership of the committee.
10 Q
John Wilson, an atto rne y ?
II A
No.
Dick Wilson, vi ce president of 12 Technical Functions at GPU.
13 Q
Who, othe r than you, were the members of
,r N
(_)
.the GRC at the time you took your place?
15 A
We were all appointed at the s ame time.
16 I don't remember the full membe rship at that time.
17 Mr. William F. Schmauss is the chairman o f the GRC and was then.
Mr. Don Reppe rt, Ron Furia, also was in Tech 19 Functions in the Nucle ar Fuel Analysis Group.
The re 20 were one o r two membe rs 'who were not employees o f GPU.
21 I don't remember who they were.
lll 22 Q
Do you remember if one of them was a B&W 23 representative?
24 A
I am not sure.
25 fx Q
Was the Generation Review Committee a (v)
1 LcnGDQ 38 2
committee formed for the fi rs t time afte r the Three
(--
kJ 3
Mile Island accident?
4 A
No, it wasn't.
i 1
5 Q
Do you re call wh en, if you know, tne 6
committee was firs t formed?
7 A
No, I do not.
8 Q
What do you understand the charte r or 9
responsibilities of the Gene ration Re view Committee to 10 be?
11 MR. GLASSMAN:
At the time it wac formed?
12 MR. BENEDICT:
Let's ask a preliminary 13 question.
O\\
(_,/
14 Q
Are you still a member of the Generation 15 Review Committee?
16 A
Yes, I am.
17 Q
As you understood it, have the 18 responsibilities of the Gene ration Review Committee 19 cha nge d f, rom the time you first became a membe r until 20 today?
21 A
I am not sure, h
22 Q
What is your current ge ne ral unde rs tanding 23 as to the responsibility of the Generation Review 24 Committee?
r^N 25 A
We're responsible for, by technical
(
)
m
1 Leno8@
39 2
spe ci fi c atio n, we're tasked with reviewing the
(-
3 functioning of the Plant Operation Review Committee, 4
the PORC, of reviewing tech spec ch an ge s, of reviewing i
5 licensee e ve nt repo rts generated by the unit, either
)
O 6
Unit 1 or Unit 2, and reviewing determinations by the 7
PORC of the reportability of events.
We also review 8
NRC I & E bulletins and notices, both prior to their 9
being responded to and subsequent to their being 10 responded to; and the function of the committee is 11 report through the chairman to the vice president of 12 technical functions an d mak e recommendations as to the 13 adequacy of the functioning of the PORC, and of the
,e (s) 14 pl ant staff in responding to these issues.
15 Q
PORC stands for Plant Ope rating Re view _
16 Committee; is that corre ct?
17 A
Yes.
18 Q
Is the re a separate committee for Unit 1 19 and a separate committee fo r Unit 2?
20 A
Yes, there is.
21 Q
I take it, then, you or the GRC reviews l
22 work done by each of those committees?
23 A
Presently we do, yes.
24 Q
You said by technical specification, and
(^')
25 you set forth some of what you understand to be the Q)
1 Lenase 40 2
responsibilities o f the GRC.
Is it your unde rstanding
\\~l 3
that the GRC is mandated by the technical specifications 4
for Unit 17 5
A Yes, it is.
6 Q
Do you know the numbe r o f the technical 7
specification ?
8 A
No, I do not.
9 Q
You said that one of the responsibilities 10 of the GRC was to review licensee event reports from 11 either Unit 1 or Unit 2; is that right?
12 A
That's correct.
13 Q
Do you re view licensee e ve n t reports for
(_)
14 other B&W reactors not owned by a GPU company?
15 A
I have to clarify the first response.
The 16 "you" is indefinite.
The GRC chairman is responsible 17 ultimately for reviewing licensee event reports, so it 18 is possible th at I m'ay o r may not see li ce nse e event 19 reports.
20 In response to the second question, we do 21 not review licensee event reports f rom othe r units.
22 I do not always see them, and I am not s ure as~to whether 23 the chairman would or not.
24 Q
You don't know whethe r the committee f~J)
25 re views licensee event reports from any plant other t.
a
1 Lanceo 41 2
than Three Mile Island Units 1 and 2?
(,/
3 A
That's right.
I don't recall if that is 4
part of the functional responsibility of the GRC.
5 Q
Do you know whether the re is any 0
6 organization or group or person within GPU who is 7
responsible for reviewing all lice ns ee e ve n t reports?
8 We will start with some person who is responsible for 9
it today.
10 A
My understanding is, the present re s pons i-11 bility would be within the Plant Analysis Section of 12 Systems Enginee ring.
13 Q
That's part of GPU Nuclear?
/'
(_)s 14 A
Yes.
Their function -- part of their 15 function is to review licensee event reports.
16 Q
Do you know who heads that group?
17 A
Yes, Pat Walsh.
18 Q
I occasionally get confused as a result of 19 these long names of the groups.
Have you ever worked 20 for that group?
21 A
No, I haven't.
h 22 Q
What is the name of the group to which you 23 are now assigned?
24 A
Safety Analysis and Plant Control.
r~'
25 Q
What is the next segment of GPU Nuclear up N.]N
1 Lonase 42 2
from that?
s I
s/
3 A
The next level of management would be Mr.
m l
4 Broughton, who is the systems analysis director.
t l
5 Q
Is there a group called the Systems 6
Analysis Group or Unit or Se ction?
7 A
It is not a group.
It is Mr. Walsh 8
reports to Mr. Broughton.
9 Q
Does that mean that Mr. Walsh's group is a 10 group that is on the same level as your group in the 11 structure of GPU Nuclear?
12 A
He is at the same level of management as 13 M r.
Trikouros, yes.
73(,)
14 Q
And Mr. Trikouros is your boss?
15 A
Right, reporting to Mr. Broughton.
16 Q
Mr. Walsh's group, as you unde rs tand it, has 17 the responsibility today for re viewing all licensee 18 event reports, is that correct?
19 A
I believe that is co rre ct, yes.
20 Q
And you unde rs tand when I say "all," I am 21 not limiting it to LER's generated within the GPU lP 22 system, but I inclu de the other nuclear plants within 23 the Unite d States?
24 A
That is true.
gy 25 Q
Do you know whether that group receives the i
i
%.J
L3n300 43 1
2 actual LER or whether they receive summaries and pick
(\\(,)
3 and choose f rom the re ?
4 A
No, I do not.
5 Q
Do you know,.was this function being done 6
within GPU, this same function as you described for Mr.
7 Walsh's group, being done within GPU prior to the 8
accident at Three Mile Island on March 28, 19797 9
A There was no formal organization or s tructure 10 within GPU prior to the accident which re viewe d 11 licensee event rep ort s.
12 Q
When you say within GPU, do you mean to 13 include all GPU subsidia rie s or do you mean j ust to I )
14 in clude
(
15 A
Including all of the s ub s i di a rie s.
16 Q
Is there today a fo rmal licensed program 17 for doing that, for reviewing LER's ?
18 A
Embodied by Mr. Walsh's group, yes.
19 Q
So there was a change since the time of the 20 ac cide nt with respect to the formality, at least, of the 1
21 re view of LER's within GPU?
4EF 22 A
Yes, at least the formality.
l 23 MR. GLASSMAN:
Can we take a b re ak for a 24 second?
25 (Re ce s s t ak en. )
7._
,/
Lensca 44 i
2 Q
To the extent the re was a systematic review
(.)
3 of LER's at GPU prior to the accident on March 28, 4
whether or not it was formalize d, who was responsible 5
to your knowledge for that review?
6 A
The review of LER's would be determined by 7
the project management so LER's would be route d to 8
Enginee ring or Licensing or Fuel Analysis or Operations 9
depending upon the perception of the event involved.
10 Q
And the perception of the e ve n t involved 11 would be the perception of someone in Project Management?
12 A
Yes, I believe it was Project M a na ge me nt 13 that made dis t rib utio n.
/N. )
14 Q
Do you re call who, if you know, within Project 15 Management had that responsibility prior to the 16 accident?
17 A
No.
18 Q
Do you recall or do you know how that 19 responsibility was implemented within the proj ect 20 management o f fi ce ?
Do you recall what steps were taken 21 to as s ure that relevant LER's were reviewed or were EP 22 routed to people for review?
23 MR. GLASSMAN:
You are talking ab out the l
24 general practice?
('"N 25 MR. BENEDICT:
As he un de rs t an ds it p rio r s
Cl
1 LEn300 45 2
to the accident.
\\
3 A
I am not sure that LER's only went dire ctly 4
to Proj ect Management.
5 Q
Do you know who else they went directly to, 6
or what othe r units or groups?
7 A
I am not sure.
8 Q
Do you know whether Proj ect Management 9
. undertook a systematic review of LER's prior to the 10 Three Mile Island accident?
11 A
I do remember that there was an NRC 12 question regarding review of operating experience in 13 power plants and that we responde d de s cribing -- not
( )
14 a program -- but the manne r in which we reviewed LER's 15 and the reasons for our review being an adequate review 16 of operating experience.
17 Q
When was the NRC questioning GPU about this 18 s ub j e ct?
19 A
Late 1975 or e arly 1976.
20 Q
Did you have some responsibility with 21 respect to responding to this inq uiry ?
lll 22 A
No, I di dn ' t.
23 Q
Did someone within the licensing group have 24 responsibility with respect to it?
g-25 A
Yes, Mr. Crimmin s prepared the resp,onse.
\\
?
N,_/
1 Lonaco 46 2
Q Did you review the response at that time?
(,.
3 A
I re ad the response.
s 4
Q Did it compo rt with your understanding of 5
what was in fact the practice at GPU at that time as 6
you recall?
7 A
3At that time, I was unable to evaluate 8
the response.
9 Q
Did there come some time subsequent to the 10 but prior to the Three Mile Island accident that you 4
11 reviewed the procedure or practice within GPU for 12 reviewing plant operating experience?
13 A
No.
()
14 Q
Has there been any time since the accident 15 when you did that?
16 A
No.
17 Q
Other than licensee event reports, what 18 other sources do you know o f, sources o f information 19 about plant operating expe rience that are systematically 20 reviewed within GPU today?
21 MR. GLASSMAN:
I will allow him to answer 4EP 22 the -ques tion, but I note we used a lot of I
23
'dif fe rent word.s here :
formality, in fo rmality,
f 24 systematic review, nonsys temati c review.
I am 25 not sure what the question is directly trying to gg
,._m v
g' LanSSG 47 y-2 ascertain.
Perhaps you would want to follow up.
A I am n t sure of what Plant Analysis 3
4 reviews beside s LER's.
I do know that they review 5
note pad entries.
They receive in formation from INPO.
6 I have no other understanding of the documents that 7
they review.
-8 Q
By "they," are you r efe rring to Mr. W alsh ' s 9
group?
10 A
Yes.
- 11 Q
What is a note pad entry?
12 A
Note pad'is a compute riized data system 13 in which participating utilities provide information 14 to other utilities and to othe r participants such as 15 EPRI, the NSS vendors.
16 Q
This is a se rvice one subscribes to?
17 A
I don't know how it is a dminis te re d.
j 18 Q
What is INPO?
19 A
I don't know what the acronym s tands for.
20 Q
You said they review INPO material or 21 something1along those lines.
Wh at form does this W
22 material take, if you know?
23 A
I haveseen questions-from the organization-24 and surveys in which we have had t'o respond based on
" p-95 an INPO' review of licensee event reports or plant 4
1 Lansco 48 2
experience.
(,'-)
3 Q
Do you receive any periodicals or other 4
sour ce of in formation, you personally, othe r sources 5
of information with respect to plant operating 0
experience?
7 A
Only on occasion.
O Q
You do not regularly receive any sources 9
of information?
10 A
No, I do not.
11 Q
Do you know whether Met Ed has within its 12 organization a group today that reviews on a systematic 13 basis LE R's or other descriptions of plant operating n
_)
14 experience?
15 A
With respect to TMI operation, I don't 16 believe there is a Met Ed any mo re.
17 Q
With respect to TMI operation, you don't 18 be lie ve there is a Met Ed any more?
19 A
That's right.
20 Q
I take it you mean that operations fo r 21 TMI have been assigned to GPU Nuclear?
22 A
That's correct.
23 Q
Taking the time prior to the creation of 24 GPU Nuclear, do you know whethe r Met Ed had a group
('^')'
25 or a method for systematically reviewing plant Lj
1 Lansso 49 2
operating experience?
(
)
(_ /
3 A
Certainly PORC would be responsible the ri'ht word; PORC would have been 4
responsible is not g
5 tasked to review licensee event reports.
I do not know 6
the mechanism by which Met Ed Gene ration Engineering 7
or Operations staff other than PORC reviewed licenseee 8
event reports.
9 Q
When you say licensee e ve nt reports, are 10 you limiting your response to LER's generated with 11 respect to Units 1 and 2 on Three Mile Island?
12 A
No.
13 Q
All LER's, was your unde rstanding?
,.-(_j 14 A
At least all LER's related to pressurized 15 water reactors.
16 Q
Do you know by what means or by what method 17 the PORC or PORC's for the units at TMI accomplished 18 the task of re viewing these LE R' s ?
19 A
No, I do not.
20 Q
In the course of your work on the Generation 21 Review Committee, have you had an opportunity to llk 22 consider the methods used by the PORC's to review licensee 23 e ve nt reports or other plant ope ra ting expe rie nce ?
24 A
I.have had an opportunity to observe the A
25 methods.
- Rj!
1 Lanace 50 2
Q what did you obs erve abo ut the methods?
I I
\\-J 3
A That every LER that came in was re viewe d 4
by PORC.
5 Q
Is PORC composed of more than one person?
6 A
Yes, it is.
7 Q
would each o f them be reviewed by all of 8
the members?
9 MR. GLASSMAN:
You are talking ab o u t --
10 Q
what you obs erved.
11 MR. GLASSMAN:
You are not talking about 12 particular instances?
13 MR. BENEDICT:
No.
(~)h
\\m 14 Q
In your understanding, or what you ob s c rve d 15 as to their practice ?
16 MR. GLASSMAN:
Also I note it is unclear as 17 to what time frame these observations occurred in.
18 l
MR. BENEDICT:
My only limitation was during I
19 th e time he had serve d on the Ge ne ration Review 20 Committee.
21 A
I don't know how many people reviewe d any 22 particular LER.
In orde r for PORC to conclude anything 23 or to satisfy their function of having reviewed it, 24 the LER would have been put on a PORC agenda.
There i
/
25 would have been an opportunity fo r comment.
- Normally, i
1 Lanace 51 1
2 at least one person on PORC will review a piece of
/^N
(_,)
3 material in detail and be prepared to present 4
observations, results or comments to the remaining 5
PORC membe rs.
O 6
Q I am not s ure I unders tand how an LER in 7
your understanding gets onto a PORC agenda.
8 A
It is provided to th e PORC ch airma n.
9 Q
By?
10 A
I don't know who provides it.
11 Q
Go on with your answer.
I will follow up.
12 It is provide d to the chairman.
13 A
He dist rib ute s the mate rial and PORC
'(
)
(
14 memb e rs review the m ate rial.
At some future PORC 15 meeting, the LER will be on the agenda; discussion of e
16 the LER is always on the agenda, and PORC would have 17 to conclude that there were no comments or that there 18 were comments and then proceed to the next agenda item.
19 Q
Is it your unde rs tanding that all LER's 20 re ceived at least with respect to pressurized water 21 re ac to rs are included on the agenda, or is there a llP 22 culling process be fore their inclusion?
23 A
My understanding is that I guess I don't 24 know.
25 Q
I recognize that your involvement with the
~s
(
)
Nm/
1 Lenace 52 2
Generation Review Committee starts after the Three (n
is,,/
3 Mile Island accident.
But are you aware of whether the 4
practice you just described was followed by the PORC 5
committees prior to the Three Mile Island accident?
6 A
I can't say.
7 Q
You don't know one way or the othe r?
8 A
I don't know.
9 Q
I take it PORC Committee minutes are 2
10 maintained?
l 11 A
To the best o f my knowle dge, they are, yes.
12 Q
Are Ge neration Review Committee minutes 13 made?
(
(
)
14 A
My only expe rience has been since I have 15 been on GRC, and yes, they are main tained.
16 Q
Have you at any time during your employment 17 at GPU, have you been on any othe r committee s within 18 Gpu?
19 A
I was a GO RB alte rnate for Mr. Clinton 20 Montgomery for some period of time.
21 Q
GORB stands for?
lll 22 A
Gene ral Office Re view Board.
23 Q
During what pe riod were you an alternate 24 for the GORB7
(z 25 A
1978, possibly portions of 1979.
\\
,)
i e
6
1 Lansoe 53 2
Q Did being an alte rnate entail your gs
(_)
3 attending meetings on a regular basis ?
4 A
No.
5 Q
Did you review minutes on a regular basis?
O 6
A No.
7 Q
Did you ever have an opportunity to attend 8
a meeting as an alternate?
g A
I believe I attended one meeting.
10 Q
What is the function of the GORB during, 11 o r wh at was the function of the GORB during the period 12 you served as an alternate as you unde rstand it?
13 A
The GORB is another independent review group
(
')
14 to make evaluations ab o ut conduct of the plant
\\_/
15 and its safe operation.
16 Q
Was the membe rship of the GORB composed 17 en ti re ly of GPU or GPU Service employees?
18 A
No, it wasn't.
19 Q
Who constituted the membe rship o r, f rom 20 what s ub sidiarie s o f GPU did they come?
21 A
GORB included membe rs from GPU, Met Ed, lll 22 B&W, and at least one other outside consultant.
23 Q
Does the GORB still exist?
24 A
Yes, it does.
y 25 Q
Is there only one as opposed to the PORC's I
l v
1 Lnn900 54 2
whe re there is one for each unit?
\\s /
3 A
I don't know.
4 Q
1%at 5
A I may have to clarify my comment ab out 6
I'm sorry.
PORC's.
No, I don't know ab out the 7
constitution of the GO RB and whether it is the same 8
membe rship for TMI-1 and TMI-2.
9 Q
Was it your unde rstanding that the GORB 10 performed a review function ove r the work of the PORC?
11 A
It include d a review o f the PORC, yes.
12 Q
What does ATOG stand for?
13 A
Abnormal transient operating guidelines.
(,)
14 Q
What are the abnormal transient operating 15 guidelines?
16 A
They are a consolidation o f various 17 emergency proce dures into one post-trip procedure 18 that allows the operator to systematically treat plant 19 symptoms that are indicative of various off-normal 20 con di tion s.
21 Q
Have you been involved with the cre atio n lll 22 o r p reparation of the ATOG7 23 A
I have been involved in the ATOG program 24 in various degrees of activities since early 1980.
rx 25 Q
Can you describe what your activities have i
l wj o
1 Lansoe 55 2
been with respect to this program?
3 A
My first activity was to review the event 4
trees that were the basis for developing the 5
guidelines.
6 Q
Had you ever seen an event tree used for 7
developing procedures prior to your experience with 0
ATOG7 9
A No.
10 Q
ATOG, the guidelines created under the ATOG 11 program are not intended to replace eme rgency o roce dures ;
12 are they?
13 MR. GLASSMAN:
Intende d by whom?
14 MR. BENEDICT:
Intended by the people who 15 are paying for the program.
16 A
They are in some instances intended to 17 repl ace the existing procedures.
" Incorporate" may be 10 i
a better word.
19 Q
The guideline would incorpo rate the l
l 20 procedure?
21 A
In some cases in c o rpo ra t e.
In some cases, 22 change.
In some cases, eliminate existing procedures.
23 Q
What else did you do aside ~ from reviewing 24 the event t'rees that you recall?
25 A
Since the f all' o f las t year, I have been Lf
\\
1 Len3De 56 2
involve d with a committee within GPU to implement ATOG
[ ')
3 at TMI-1.
L/
4 Q
What has been your responsibilities for 5
that committee?
6 A
My responsibilities are to provide any 7
technical assistance required by the plant site people 8
in understanding the basis for the ATOG guidelines.
9 In cases wehre I don' t know answe rs, I am responsible 10 for dete rmining what th e answers are.
I have also 11 functioned with the plant people in ge ne rating comments 12 on the draft ATOG guidelines.
13 Q
Is it your unde rs tanding that the ATOG
(~3 14 approach to plant operation is new since the accident
(_)
15 at Three Mile Island?
16 MR. GLASSMAN:
I am not sure what the nature 17 of this question is, whether you are asking for 18 opinion.
I don't know what is new, what is old.
19 If you are going to ask him how it di f fe rs from 20 what was done before, we are getting into a 21 question that seems ob j e ctio n ab l e.
43r 22 MR. BENEDICT:
I will stand on the question.
23 I may want to purs ue it with mo re de tail, but I 24 think it is an answe r ab le question.
25 (Re co rd re a d. )
,3
./
1 Lenaco 57 2
A I don't know.
~
('~h
\\
(_)
3 Q
nad you ever in the course of reviewing any 4
procedures prior to the accident at Th re e Mi$e Island --
t, 5
we discussed seve ral instances e a rlie r -- 41 d y o u e ve r -
~
6 review a procedure which had an event tree atUached toi
,x 7
it?
O A
No.
9 Q
Are you aware of the use o f e ve nt t re,e s in 10 the drafting of either the Unit 1 or Unit 2 procedures 11 that existe d p rior to the accident at Th re e Mile Island?
12 A
I don't know if they were used.
13 Q
Prior to the accident at Three Mile Island, r~x 2
14 did you read WASH-1400?
N L j) 4 seensekeet'edsections 15 A
I have of WASH-1 00.
16 Q
Did you see any of those sections prior,
17 to the accident at Three Mile Island on March 28, 19 79?
i 18 A
Yes.
19 Q
Did those portions which you saw prior to i
\\
s q
20 the accident include fault or event trees?
s w.
21 A
I am not sure.
4pP 22 Q
Do you reca11' anytime prior to the accident a
23 at Th re e Mile Island when you utilized in the course'of 24 your work for any purpose either fault or event t re'e s ? -
j
~
25 A
Yes.
i
)
..]
w
- 4. g 9
s T
s
s 1
Len2co 58 m
A 2
Q Could you describe that?
x lV, -
)
3 A
Prior to licensing of Unit 2,
one of the 4
remaining issues was fire hazards analysis, and we did 5
' us e event trees in developing what are called safe ill 6
shutdown logic diagrams.
Those diagrams were actually N
7 developed and provide d by EDS Nuclear for GPU.
8 Q
To what use were these diagrams put?
9 A
They were used to identify equipment that 10 could or would be needed to shut down the plant in the 11 event of a fire, and identify areas in whi ch a fire in
,5' 12 a particular area might prevent tne achievement of a b
13 safe shutdown condition.
s 14 Q
Do I understand you to say that GPU or 15 people within GPU did not prepare these trees?
They 16
-were prepared by an outside s e rvi ce ?
17 A
That is corre ct.
18 Q
We re these event trees utilized in the 19 preparation of procedures with respect to fire hazards 20 or fire prevention?
21 A
I don't recall.
You may have asked two L
$gP 22 questions.
23 Q
My question was:
Do you know whether the 24
' event trees that you described were used in the 25 preparation of procedures with respect to responding to y
=
a Y
1 Lanace 59 2
a fire?
[m
(
,)
3 A
No.
4 Q
You don't know?
5 A
I don't know.
6 (Document on GP Service Co rpo ration 7
letterhead, subject:
Major outstanding TMI-2 8
NRC Licensing Issues, the document dated 9
Novembe r 19, 1975, was marked B&W Exhibit 604 10 for identification, as o f this date.)
11 MR. BENEDICT:
Firs t we only need a copy 12 of, or to see the original of, one of the 13 p ro ce du re s.
And the document numb e r for that
{~}
14 was Pages WO 29131 through
'55.
m.,
15 MR. GLASSMAN:
We will do our best to be 16 cooperative.
17 Q
I would like to show you B&W Exhibit 604 18 for identification.
It is on GP Service Co rpo ratio n 19 letterhead or memo head, and its subject is:
Major 20 outstanding TMI-2 NRC licensing iss ues.
The document 21 is dated Nove mbe r 19, 1975, and it is signed by L.
C.
43r 22 Lanese.
I would like to ask you if you recognize 23 this document.
24 A
Yes, I do.
l 25 Q
Could you des cribe it for me?
v.)
1 Lansco 60 2
A This was a summary of the licensing issues
,cy 3
requiring resolution with NRC s taf f, and we pe riodically 4
updated the list.
5 g
was it on a regular basis, monthly, weekly, O
6 quarterly?
7 A
I don't remembe r the frequency.
1 8
Q Did you keep a file o f these update memos ?
9 A
They were filed in the safety and licensing 10 central file and in my write r's file.
11 Q
Were you' responsible for preparing the 12 attachment to this cove ring memo, each page of which 13 is headed TMI-2 licensing issues?
(')N
'v_
14 A
I p rep are d mos t o f th e att a ch me n ts but not 15 all of them.
16 Q
Was that a regular responsibility during 17 some period of your time in the licensing group ?
18 MR. GLASSMAN:
Was what a regular respon-19 sibility?
20 MR. BENEDICT:
The responsibility o f 21 p rep aring attachments, whether all of them or l
lk 22 not, att a chmen ts describing or summarizing i
1 23 TMI-2 licensing issues.
24 A
It was an activity that I performed for
/^)
25 some period o f time.
'N_ /
1 Lenose 61 2
Q Can you tell me for how long a period of
()
-3 time you assembled such summaries and routed them as 4
appears to have been done with B&W 604?
'5 A
I don't remembe r when I stopped preparing 6
these memos.
I started sometime in the fall of 1975.
7 Q
Did you stop be fore you became or after you 8
became lead nuclear enginee r, lead nuclear licensing 9
engineer, which occured sometime in 1977, according 10 to your resume?
11 A
I am fairly certain that I did stop before 12 1177, yes.
13 Q
You mentioned that you kept a write r's 14 file.
Is that a file where all the mate rial that you L
15 p rep are or that you sign you file away ch ronolo gi cally ?
4 16 A
I don't -- I didn't keep it pe rsonally.
17 It was kept in the safety and licensing fi le s.
18 Q
When you left S afety and Licensing, did 19 you take with you your writer's file?
20 A
No, I believe it stayed behind.
21 Q
Do you know whe ther your write r's file was j
l l
tur 22 reviewed or examined in response to the document i
i
'M request that was served in this litigation by the 24 defendants?
i L
25 A
No, I do not.
o
1 Lenoss 62 2
Q can you identify this document as being one r'(_)s 3
that came from your writer's file, the actual specific 4
document?
5 A
Based on the cover page it app e ars it came 6
f rom the writer's file.
7 Q
That it does.
8 A
That it has come from the writer's file, yes, 9
Q Do you keep a write r's file currently?
10 A
No.
11 Q
You don't keep a co rre sp o n/.e nce file?
12 A
No.
13
.Q I would like to --
()
14 A
Perhaps you better explain what you mean by 15 co rrespo nden ce file.
16 Q
Do you keep a file in which you retain 17 co pie s of everything that you write or a certain portion 18 of what you write on a chronological rathe r than a 19 subject matter basis?
20 A
No, I do not.
21 Q
Do you currently keep files or are all lll 22 your files under the control of the central safety 23 analysis and plant control group?
24 A
We are in the p rocess of implementing our 25 central filing system.
Most o f my files are in the 73
{
)
v
1 Lenaco 63 2
central file. Some of them are not.
,8
(
)
3 Q
What files do you keep pe rsonally?
4 A
General files on mate rial that I am 5
c urre n tly involved with.
6 Q
Dire cting your attention i n B &W 604 to 7
a page marked for this litigation as WO 26469, it is 8
a page headed TMI-2 licensing issues.
Then it reads 9
Roman nume ral VI, a program, unde rs co re d, to insure 10 operating experience from other plants is f acto re d 11 into tes t program.
12 Do you re co gnize this page of Exhibit 604?
13 A
Yes, I do.
f~]
14 Q
Did you prepare this page?
G' 15 A
No, I didn't.
16 Q
Did you review this page be fore you routed 17 it to the people shown on the nemo cove ring it?
18 A
I read it before I route d it, yes.
19 Q
Do you know who prepared it?
20 A
Yes, I do.
21 Q
Who was that?
%gr 22 A
Tom Crimmins who was my supervisor at the 23 time.
I 24 Q
Did Mr. Crimmins discuss with you this open 25 licensing issue prior to the preparation of this?
/
3 l
1 Lon300 64 2
A I don' t reme mbe r.
/^N t
I
(_/
3 Q
Did he discuss it with you at any time prior 4
to its resolution?
5 A
Not that I can re call.
6 Q
At the time that you reviewed this and 7
route d it in 1975, what did you unders tand the NRC --
8 what had the NRC asked o f GPU which was considered an 9
open licensing issue or an outstanding licensing issue?
10 A
I don' t belie ve I had an unde rstanding of 11 the is s ue.
12 Q
You don't recall having any othe r unde r-13 standing other than what is contained in this ?
(~)%
(_
14 A
No.
It predated my time as licensing 15 engineer.
16 Q
The is s ue did?
17 A
Yes.
18 Q
Did you at any time have any responsibility 19 during your tour in the Licensing Department ove r this 20 issue relating to insuring that ope rating experience 21 from other plants is f actored into the test program?
h 22 A
No.
23 Q
At the time you reviewed this for inclusion 24 in your memo, did you unde rs tand the final line to mean,
(~'T 25 "Ame ndme n t 34 provided this response 10/ 31/ 75, "is it Y_]
1 Lanaco 65 2
co rre ct that your unde rstanding at that time was that (x
(_/
3 the resolution of this issue was contained in an 4
amen dmen t to the FSAR numbe red 34 which was sent to 5
the NRC on October 31st, 1975?
6 A
Yes, it was my unde rstanding.
7 Q
Do you recall whether the NRC accepted this 8
re solution ?
9 A
I believe they did.
10 Q
Did you recall whether following at any 11 time af ter Octobe r 31s t, 1975 this issue arose again 12 as an open item?
13 A
Not to my recollection.
p(,)
14 Q
Do you know of any other documentation with 15 respe ct to this issue othe r than this s ummary and the 16 amen dment to the FSAR No. 34 referred to herein?
17 A
No, I do not.
18 Q
Where would you look today if you wanted to 19 fin d files related to issues, licensing issues that 20 were open seve ral ye ars ago?
21 A
That would depend on the s ub j e ct.
lll 22 Q
This s ub j e ct, the s ub j e ct of factoring 23 in operating experience to the tes t program at TMI-2.
24 A
The s afe ty and licensing files and Tom
(~x 25 Crimmins ' file which may have been incorporated in the
(
)
~-
1 LEncoo 66 2
safety and licensing files on this topic.
p_
(
)
'~'
3 Q
Is it your unde rs tanding that Mr. Crimmins 4
handled this issue alone as opposed to receiving 5
assistance from another?
6 A
He dis cussed the issue with othe r people.
7 Q
Do you recall whether anyone worked with 8
him on the resolution of the issue?
9 A
No, I do net.
10 Q
The only thing you recall about the 11 timing o f the NRC's, the expression of the NRC's 12 concern abo ut factoring in operating expe rience is 13 that it predated your arrival in the Licensing
[
)
\\/
14 Dep artme n t ; is that correct?
15 A
It was an NRC question, not ne ce s s arily a 16 concern, but it did predate my assignment to TMI-2 17 licensing.
18 Q
When did that occur?
Do you know?
19 A
Octobe r 1975.
20 Q
Was this your debut in dealing with 21 outstanding NRC Unit 2 licensing conce rns or issues ?
lI 22 A
I don't think so.
I don't know.
This is 23 approximately six weeks a f te r I s tarted working on 24 Unit 2.
[)
25 Q
Could you turn through the pages attached v
9
1 LEn300 67 2
to your memorandum and tell me which, if any, of the
.s
(
)
3 licensing issues raise d here you were responsible, or 4
at least partly responsible,for at that time?
5 MR. GLASSMAN:
Responsible, you are 6
talking about 7
MR. BENEDICT:
He had a job assignemnt with 8
respect to it.
9 A
I worked on issue No.
I, Roman numeral I.
10 I worked on issue No. II. I worked on issue No. III.
I 11 worked on issue No. IV.
I am not clear about issue 12 No.
V.
I don't re call it.
Mr. Crimmins worked on 13 issue No. VI.
I worked on issue No. VII.
I worked
/~N I
I 14 on issue No. VIII.
15 Q
Is issue No. VII the same or a part of the 16 same issue which you mentioned in your resume concerning 17 de veloping analyses in support o f the TMI-2 fe e dw ate r 18 system modification?
19 A
It was the same issue that led to the 20 requi re ment for modifying the TMI-2 fee dwate r sys tem.
21 Q
B rie fly, how would you describe that issue, 22 if you can?
23 A
The NRC staff eventually required us to have 24 f ully safety grade seismically qualified mitigation
[
)
25 for a large steam lin e b re ak accident, the result of j
x e
1 L0ncoa 68 2
(D
\\s/
3 which was that we committed to installing feedwater 4
isolation valves.
l 5
Q And that is part of the same issue that is 6
expressed here in issue No. VII, steam line break 7
accident?
8 A
Yes.
9 Q
Up until the day of the Three Mile Island 10 accident on March 28, 1979, did you have any 11 involvement with contributing to or reviewing the 12 contents of training given to prosppctive control 13 room operators?
C
()h 14 A
No.
15 Q
Did you ever prior to the accident 16 review the contents of training of operators?
17 A
No.
18 Q
Have you since the accident provided 19 input into training of operators?
20 A
Yes, I have.
21 Q
What specific instances do you recall 22 of that.
23 A
In January 1979 -- excuse me; 1980. I 24 l
was involved with accelerated operator requalification
(~]
25
's_)
1 Lanoao 69 2
program and giving some le ct ure s on FSAR transients
(~%.
(_)
3 and accidents.
In the summer of 1981, I gave a lecture j
4 on the containment isolation modifications to the 5
op e rato rs and also a lecture on selected plant response h
6 to plant transients that had been performed in the
~
7 restart analysis.
Those analyses were specifically 8
ge are d to imp roving the ope rator's understanding of 9
plant response to situations in which emergency 10 fee dwate r initiate d, given our revise d e me rgency 11 fee dwater design.
Those are the only times I was 12 involve d in ope rator -training.
13 Q
If I recall what you said, you said in
,-[,)
14 each case, these were le ctu res that you gave s is that
\\~ '
15 right?
16 A
Yes.
17 Q
Did you have any involvement or input into 18 materials other than lectures?
Did you assist in 19 drafting lesson plans?
Did you help prepare someone 20 to give a lecture?
Did you prepare slides or overhead 21 p roj e ctio ns for training that you didn' t use in your lll 22 le cture s ?
That is the sort of thing I am looking for.
23 A
No, not that I can recall.
24 Q
In the lecture you said you gave in January
,7 w 25 of 1980, you s aid one of the s ubj ects o f the lecture was
(
)
w.-
I
-i
1 Luness 70 2
"FSAR transients and accidents."
\\
)
~
3 What are FS AR transients and accidents ?
4 A
Those are the design basis events that are 5
analyzed in the FSAR which are used to demonstrate.the 6
adequacy of the plant design.
7 Q
I am afraid I have yet another question on des'ign b asis accident, if they 8
this s ub j e ct.
What is a 9
can be des cribed gene rally?
10 MR. GLASSMAN:
You are looking for the 11 witness's current unde rs t anding ?
12 MR. BENEDICT:
We'll start with today.
13 A
They are events which establish the design
\\
k_)
14 requi reme nts for the plant. A design basis accident 15 would be one for which the plant is required to mee t 16 spe cifie d acceptance c ri te ri a.
17 Q
When you say " required,"do you mean 18 required by law?
19 A
By regulation.
20 Q
By the NRC?
21 A
That's right, h
22 Q
And you s ay it has to meet certain criteria.
23 Where are those crite ria fo un d?
24 A
The criteria would be specified in the 25 safety analysis report.
j
1 Lenoca 71 2
Q In the FSAR?
S
)
3 A
In the FSAR.
In some cases in regulations.
4 There may even be circumstances where they are not 5
spe cified in the FSAR, but the staff's judgment is 6
that some crite ria should be a design crite ria for an 7
event, and it will be enforced upon the licensee.
8 Coff-the-re cord dis cussion ens ued between 9
the witness and his counsel.)
10 Q
Do these crite ria that you described as 11 being found in regulations and in the FSAR and at times 12 spe cified by the NRC staff, do they take the form of 13 descriptions of specific accidents, or are they more Ch (m,)
14 general crite ria?
15 A
A specific acci de nt or transient would be 16 defined and then gene ral acceptance criteria would be 17 applied for that specific accident and transient.
18 Q
What is a general acceptance crite rion, or 19 what are they?
20 A
I would have to give an example or two.
21 Q.
I don' t mind working from examples so long ll 22 as I am trying to get at a gene ral view.
But please 23 start.
24 A
For a loss-of-coolant accident regulation
(~~]
25 Part 100 would require that you s tay within certain
\\m/
l
1 Lan90s 72 2
dose limit &.
That would also be true for other g
i i
\\
3 se ve re accidents.
By "s e ve re, " I mean limiting design 4
basis. Accidents rather th an transients.
For certain 5
transients, a design limit would be, or might be, the 6
departure from nucleate boiling ratio stay greater than 7
1.3, whe re as that is a crite rion that would not be met 8
for a loss-of-coolant ac ci de nt.
9 Q
Are you f amiliar with the core cooling 10 criteria of 10 CFR, 50 point 46, and Appendix K?
11 A
In general.
12 Q
Are they cri te ri a such as the ones you 13 have been discussing?
{T q_,)
14 A
Yes, they are.
15 Q
So-called gene ral acceptance c ri te ria?
16 Is that the expression you used?
17 A
They are acceptance crite ri a, yes.
18 Q
So an FSAR transient and accident, is it a 19 f air s umma ry to say by FSAR transients and accide nts,
20 you meant design bastraccidents as we have been 21 discussing?
h 22 A
That is the way I would de fine a design basis 23 a c ci de n t and the FSAR accidents and transients, yes.
24 Q
You said one of your lectures in the summer,
(~'}
25 I think, of 19 81 was related to selected plant response 4
E_
1 LEnsos 73 2
to plant transients, and you indicated that the 4
\\_)
3 transients principally were ones involving the 4
actuation of emergency fee dwa te r.
We re these lectures 5
related specifically to TMI-1?
6 A
Yes, they were.
7 Q
Did you unde rs t and the purpos e of the 8
lecture to be to relate to the operators the changes 9
in the system since the accident in March 1979?
10 MR. GLASSMAN:
Objection to the form.
11 (Re cord read. )
12 A
That was one purpose of the lecture.
13 Q
What did you unde rstand the other purposes f')
U
14 to be?
15 A
To illustrate to the operator the plant 16 response to emergency fe e dwate r, e sp e ci ally for 17 situations that he had not expe rienced in. a plant,
18 sin ce emergency feedwater h as very rarely been 19 initiate d at TMI-1.
20 Q
Did you understand that that lecture was 21 being given to all of the operators who were licensed h
22 for Unit 1?
23 A
No.
24 Q
Who did you unde rs tand were to have been
(
)
25 excluded?
1 Lanoco 74 2
A I don' t know that anyone was exclude d.
I 3
did not give the lecture to every shift o f ope rato rs.
4 Q
Did you have some unde rstanding as to how 5
the information, you conveyed in the lecture was to be 6
provided to those absent?
7 A
By videotape and by training pe rsonnel.
8 Q
With whom did you wo rk in preparation for 9
these le ctu re s, not j us t limited to the ones in the 10 summer, but all the lectures you mentioned?
11 A
During the lecture of 1980, January, I gave 12 a portion o f the lecture.
Ni ck Trikouro s gave a 13 '
portion.
Dr. John Luoma and Allan Easly, both of
.)
14 the Nuclear Fuels Group, gave other portions of the 15 lectures.
In the s umme r o f 1981 lectures, I dis cus se d 16 and received comments from Gary Broughton as to the 17 content of the lecture.
18 Q
Those are the only instances of participatior 19 in training that you can recall?
20 A
Yes.
I think I said July
'81.
It must have 21 been the summer of 1980, not the s umme r o f 1981.
fh 22 Q
Othe r than those two events or instances,
23 you can't re call eithe r be fore or afte r the acci de nt 24 participating in the training of operators ?'
O, 25 A
No.
s_
1 Lenaco 75 2
Q Did you eve r re ceive any training at t
)
3 Metropolitan Edison of a type that you unde rstood to be 4
like training re ceived by the operators?
5 MR. GLASSMAN:
Objection to the form.
6 A
I have to correct the previous answer.
It 7
was the summe r of 1981.
8 (Re co rd re ad. )
9 A
No, I never did.
10 Q
Did you eve r re ceive any training of that
)
11 sort from any GPU entity ~t 12 A
No.
13 Q
Did you e ve r receive any training pe rtaining
,3
'\\ /)
14 to the operation of a nuclear facility outside of GPU, 15 whether before your employment or during?
16 A
No.
i 17 Q
Did you eve r review for your own purposes 18 as opposed to reviewing for the purposes o f p roviding 19 input any training mate rial prepared by or for use by 20 Metropolitan Edison?
21 A
No.
lh 22 Q
Have you ever been to a nuclear, a commercial 23 nucle ar powe r plant simulator?
24 A
Yes.
(D 25 Q
Which simulator?
\\
1 Lenace 76 2
A The B&W simulator.
)
3 Q
Did you have an opportunity to observe its 4
function?
5 A
Was that question before or since the 6
accident?
7 Q
At any time.
8 A
Before the accident, I had seen the B&W 9
simulator once for approximately ten minutes.
Since 10 the accident, I have observed simulator function twi ce,
11 once in June of 1981 and once in February of this year.
12 Q
We re eithe r of thos e instances simulations 13 of the Three Mile Island accide nt o f March '797 n
N-)
14 A
No, they we re n' t.
15 Q
What did you observe on the simulator during 16 those two events?
17 A
I was the re with non-shif t personnel to 18 observe the use of the ATOG procedures on the simulator.
19 Q
How long were the sessions?
20 A
Approximately four hours.
21 Q
Each?
22 A
Each.
23 Q
Have yo u e ve r be e n i n th e control room o f 24 a nuclear power plant?
(^]
25 A
Yes.
i/
1 Lenaco 77 2
Q Which powe r plant?
I l
'/
3 A
Prior to comme rcial operation, I was inside 4
the control room of Unit 2 during construction.
I 5
believe I had been inside thecontrol room of Unit 1 6
for several minutes when I fi rs t came to GPU.
I had 7
been in the Unit 1 control room several times in the 8
last year fo r periods of five or ten minutes.
I was in 9
the TMI control room s eve ral weeks afte r the accident 10 for ten or 15 minutes.
11 Q
By TMI, you mean TMI-27 12 A
TMI-2 control room.
Prior to working at 13 GPU I spent app roximately another ten minutes in the f(_)
14 control room of St. Lucie while it was being 15 constructed.
16 Q
You said you were in the TMI-2 control room 17 prior to commercial ope ration.
Do you know whether 18 testing had begun on the RCS at Unit 2 at the time you 19 were in the control room?
20 A
Testing had not begun.
21 Q
They were not in hot functional testing?
22 A
They were not.
23 Q
Was the control room complete or essentially 24 complete or was it too unde r construction?
[\\
25 A
It was unde r cons truction.
'Ll
1 Langso 78 f~s 2
Q Aside from your visits to control rooms,
)
3 have you ever studied the control room panel of either 4
Unit 1 or Unit 2 at Three Mile Island?
Study 5
diagrams or photos o r mock-ups ?
6 A
I had never studied photos, mock-ups or 7
di ag rams of the control room prior to the accide nt.
8 I have reviewed the Unit 1 control room, control panel 9
re arrangeme nts on seve ral occasions.
10 Q
Focusing specifically on changes there being 11 made to the panel, subsequent to the accident.
12 A
Changes with respect to eme rgency f e e dwate r 13 and containment isolation.
(y
/
' '/
14 Q
Prio r to the Th re e Mile Island accident in 15 March 1979, what contact had you had with licensed 16 ope rato rs at Unit 1 or 27 17 A
I never met one.
I suppose that is not 18 quite true in that I had met Gary Mille r, Jim Seelinger 19 and Jim Floy d, and they are licensed operators.
20 Q
But in te rms o f anyone who served as a 21 control room ope rato r, shift foreman or shift k
22 supervisor, you don't recall meeting any?
23 A
No.
24 Q
Since the a cci de nt and for the moment
(
)
25 le aving out meetings th at you had with op e rato rs as a
1 Lansco 79 2
result of your various and sundry assignments to
-s
(
)
'~'
3 inve s tigate the occurrences at Th re e Mile Island on 4
March 28, 1979, what contacts have you h ad with 5
licensed operators for Units 1 and 27 6
A The two occasions in which I gave le ctures.
7 You are re fe rring to shi ft pe rsonnel?
People who 8
actually operate?
9 Q
Yes.
10 A
During the two simulator trips, Larry 11 Knoll, who is a shift supe rvisor in Unit 1,
was the re.
12 I have been at one or possibly two meetings at which 13 Bill Zewe was present.
That's all I can recall.
O; 14 Q
Focusing now on times when you were 15 executing your responsibilities or your job to look 16 into the Three Mile Island acciden t, what can you 17 recall abo ut the extent of your contacts with ope rators 18 at that time or during those times?
19 MR. GLASSMAN:
Objection.
I don't know it 20 h as been established that Mr. Lanese had any 21 responsibility or job to look into the Th re e Mile 22 Island accide nt.
He certainly did pe rform some 23 functions following the accident.
I don't know 24 what relationship they had to it.
It has not r m.
/
)
25 been es tabl.ishe d h ere.
Lack of foundation.
N
1 Lcn300 80 2
MR. BE NE DICT :
I p rob ab l'y co ul d a s k the 7-N.j 3
question subj ect to connection, but I will 4
withdraw that question and start with the 5
fo un datio n.
6 Q
Following the Th re e Mile Island accident 7
on March.28, 1979, did your job responsibility includs 8
interviewing ope rators with respect to ce rtain 9
occurren ces during and immediately afte r that accident?
10 MR. GLASSMAN:
Objection on the grounds of 11 lack of clarity.
I am not s ure whether the 12 question is directed to whether Mr. Lanese had 13 that as a general responsibility or whethe r he i
14 eve r talked to operato rs, et cetera.
Perhaps 15 the ques tion could be clarified so you can get 16 whateve r testimony Mr. Lanese has to o f fe r.
17 MR. BENEDICT:
I think the question is 18 clear.
I di dn' t use the word " general 19 re sp ons ibili ty. "
I s aid as part of his job a
20 re sp o ns ib ili ty.
I am not here at this moment 21 interested in whether or not he happened to meet 22 Bill Zewe in a bar one day' and talked to him 23 ab out it.
I want to know whether he understood 24 part of his job responsibility during the days, 7,
(
)
25 weeks and months following the Three Mile Island
1 Lename 81 gs 2
accident included discussions with operators w
3 where those discussions would relate to the 4
subject of the accide nt.
~
5 A
There was one occasion on which I talked 6
to the ope rato rs in connection with my evaluation cf 7
high-pressure injection and let-down flows during the 8
first seve ral hours of the TMI-2 a c ci de nt.
9 Q
Do you recall whe the r that co nve rs ation 10 took place on June 19, 19797 11 A
No, it didn't.
12 Q
Do you recall when it did take place?
13 A
I thought it was June 13.
\\'
14 Q
I am not going to quibble with you.
All 15 I want is what you recall.
With whom did you meet at 16 this time to dis cuss HPI operation?
17 A
The topic of the meeting was more general.
18 I attended the meeting for the spe cific purpose of 19 establishing some operator actions with regard to e
20 the HPI s cen a rio.
21 Q
Do you recall who was present?
22 A
Gary Mille r, Bill Zewe, Ed Frede rick, Craig 23 Faust, Mr. Scheimann, Mr. Broughton, Mr. Keaten.
24 Q
And yourself?
r~N
, (,)
25 A
And I was there.
I believe Tom _wan Witbe:k I
1 Lan3De 82
~r 's 2
of EI and Dick Dubiel of Me t Ed were also there for a k_ I 3
small portion of the meeting.
4 Q
How long was this meeting?
5 A
The entire meeting was probably four to 6
five hours.
7 Q
Do you know whether the meeting was 8
recorded or transcribed in any way?
9 A
It wasn't.
10 Q
It was not?
11 A
It was not.
12 Q
Did you take notes at the meeting?
'~'s 13 A
Yes, I did.
14 Q
Do you still have those notes?
15 A
Yes, I do.
16 Q
Are those notes included in a spiral 17 notebook?
18 A
Yes, they are.
19 Q
Do you know who else took -- did you notice 20 that anyone else took notes at the meeting?
21 A
No, I don't recall.
22 Q
Other than the one, this one inte rview th at 1
23 you attended sometime in June, do you recall any other 24 contacts you had in the course of your work at GPU 5
'n J' 25 with operators whe re that contact related to the l
1 Lcnoco 83 2
accident at Three Mile Island?
p._
i i
3 A
No.
4 Q
Do you recall testifying before the Atomic 5
safety and Licensing Board on the s ub j e ct o f the TMI-1 6
restart?
7 A
Yes, I do.
8 Q
Do you recall the dates on which you 9
te sti fie d?
10 A
November and e arly De cembe r 1980.
Possibly 11 later in De cembe r and early the next ycar.
No, I 12 believe it must have been all in the fall of 19 80.
13 Q
Do you remembe r what s ubj ect matte rs you b/
14 were interrogated with respect to?
15 A
I was a witness with regard to emergency 16 feedwate r system respons e and the adequacy of emergency 17 feedwater for certain design base transients and also 18 on containment isolation.
,19 Q
Other than your testimony before the ASLB, 20 have you given sworn testimony in any fo rm?
21 A'
No.
I 22 Q
Have you at any time bee n inte rviewe d by 23 rep re se ntative s of the NRC with respect to the 24 accident at Three Mile Island?
,y l
l 25 A
No.
J
1 Lanana 84
< ~s
(
)
2 Q
Have you been interviewed by rep re se ntative s qj 3
of any other body that studied the acci de nt ?
4 A
No.
5 CRecess t ake n. )
6 Q
Have you ever heard of a regulation called 7
10 CFR, Part 217 8
A Yes, I have.
9 Q
Could you describe for me what 10 CFR 10 Part 21 requi re s as you understand it today?
11 A
Part 21 requires the reporting o f de fe cts 12 in equipment, components, and se rvices associated with
(^]
13 safety-related functions in nucle ar powe r plants.
LJ 14 Q
When did you first become aw a re that there 15 was promulgated a rule called 10 CFR or a regulation 16 called 10 CFR, Part 217 17 A
At the time that draft or proposed 18 regulations were published in the Code o f Fe de ral 19 Regulations.
20 Q
Do you recall about when that was?
21 A
The fall of 1977.
G 22 Q
How did you be come aware o f those proposed 23 re gulatio ns ?
24 A
At that time, as lead nuclear licensing p_
l
)
\\J 25 engineer, one of my functions was to collect comments
~
8 s
85 1
Lenoco s
2 on regulations that af fected the operation of the ry
/
1 1-U 3
nucle ar powe r plants that we were ope rating.
4 Q
From whom were you to collect these 5
comments?
~
~
6 A
From Met Ed licensing, from enginee ring,
7 if that were applicable or reasonable, and from other
~
8 management personnel within GPU as applicab1e.
9 Q
so at this time in the fall of 1977, when
-s 10 the NRC would put forth the rule and requeet" comments,
(
11 or proposed rule or re gulation, and re que s t commentd, 12 it was your responsibility to, gathe r those comments.
's s
.s 13 and make some submission to the'NRC is that accurate?
(, )
i 14 A
If the rule af fe cte d.the operation design
'~
s 15 of our plants, that would be true.
16 Q
Do you recall whether there were comments 17 that you accumulated with respect to the p ripss e,d Rule 18 10 CFR, Part 21?
s 19 A
No, I do not.
~
20 Q
You don't recall?
21 A
I don't recall.
h 22 Q
Do you recall whethe r Gene ral Public 23 Utilities or any subsidiary made any comments to the 24 NRC with respect to Part 217
'-\\
4
()
25 A
No, I don't re call.
{
I
.g
'l sq l,h
(
1-,
t
.1 Lcnoco 86 l
II l
,y 2
Q Did you have any responsibility with respect
()
3 to draf ting internal procedures in orde r to comply with 4
the requi rements of the new Part 21?
5 A
I do n' t recall if it was a responsibility, 6
but I was involved in drafting the inte rnal procedures 7
on Part 21.
8 Q
When did that involvement begin?
9 A
In the f all o f 1977.
10 Q
Is it accurate to say that GPU draf te d 11 procedures for compliance with Part 21 prior to the 12 e f fe ctive date of Part 217 13 A
That is my recollection, yes.
-s 14 Q
How did you become involved in drafting i
15 these procedures?
16 MR. GLASSMAN:
Is the question who asked 17 or whethe r anyone asked Mr. Lanese?
18 MR. BENEDICT:
If someone asked him or N
s
,3 19 how he came ab out to do some work with respect N
N..y ;
20 to that.
s 21 A
I don't recall how I received the job I
22 as s i gnme n t.
23 N
g what do you recall about the job assignment?
24 A
That I took a draft procedure, worked on
)
25 it, circulated it for comments, inco rporated thos e s
4!
A
1 Lcnoco 87
['Y S
2 comments, and eventually had the procedure signed by
\\~
3 appropriate manageme nt.
4 Q
From whom did you re ceive the original 5
draft or the draft that you worked on?
6 A
I don't recall where the o rigin al draft 7
initiated.
8 Q
Do you recall who draf te d it?
9 A
No, I do not.
10 Q
Was it based on a prior procedure in 11 e f fe ct at GPU?
12 A
There was no prior procedure in e f fe ct at 13
'(~3 GPU that I can recall.
\\-)
14 Q
Have you ever heard of a regulation called 15 10 CFR 50.55-E?
16 A
Yes, I have.
II Q
Could you describe your unde rs t anding 18 brie fly of what is required by 50.55-E?
19 A
I am not sure I can, no.
20 Q
Do you know whethe r 5 0. 5 5-E continues to 21 he an active regulation with respect to the Three Mile 29 Island units?
23 MR. GLASSMAN:
Objection.
24 Q
Does 50.55-E still apply to GPU with respect
(_)
25 to the Three Mile Island units?
1 Lonaco 88 2
A I don' t know.
fs
(
)
N_/
l 3
Q Would it refresh your re colle ction if I 4
told you that 50.55-E required reporting with respect 5
to de fe cts discovered during the construction phase 6
of a nucle ar plant?
7 A
Yes, it would.
8 Q
Does that help you recall any more detail 9
than what I just gave you about 50.55-E7 10 A
Yes, 50.55-E required the reporting of 11 de fe cts that if left undiscove red could adve rs e ly 12 impact the safety analysis of the plant, I
- assume, 13 equipment pe rformance or ope ration,and could lead to
(,)\\
e x-
14 events outside the design base.
15 Q
Was th e re a proce dure in e f fe ct at GPU at 16 the time you arrived and began your employment there 17 with respect to compliance with 50.55-E?
18 A
I believe there was an enginee ring procedure 19 that was in e f fe ct, yes.
20 Q
Did you understand that procedure to apply 21 o r to m ak e requirements or impose requirements upon you 22 pe rs on ally ?
23 A
I don't recall.
24 Q
- Did you unde rs tand that 10 CFR Part 21 l
f~%
(a) 25 when it became e ffective would impos e upon you
1 Len233 89
(~)
2 pe rson ally some responsibility or obligation?
\\_)
3 A
obligation, yes.
4 Q
What did you understand your obligation to 5
be pursuant to Part 21 and GPU's procedures with 6
respect the re to ?
Let's say at the time period of 7
the implementation or the e f fective date of Part 21.
O A
To repo rt to management potential de fe cts 9
as defined in Part 21 relate d to s afety-related '
10 equipment.
11 Q
Was it the procedures which specified thos e 12 obligations which you worked on during the fall of 1977?
13 A
I don't recall the content of the p roce dure.
(
)
14 Q
Tod.ay you can't recall th at the procedures 15 you worked on in the f all o f 19 77 were in fact the 16 implementing procedures or the procedures by which 17 Gene ral Public Utilities was going to assure compli an ce 18 with Part 217 19 A
The procedures I worked on were the 20 imple me nting p roce dures for -- was the implementing 21 procedure for Part 21.
O 22 Q
To whom, if you recall, did you circulate 23 the draft that you worked on o f these implementing 24 procedures?
7-~
()
25 A
I can't recall.
1 LOnsce 90 l
1
,f"y 2
Q Did you rece'ive back, from whomever it Q./i 3
was you did circulate them to, comments?
Do you recall 4
receiving comments?
5 A
I believe so.
6 Q
You said that one of your obligations with 7
respect to these procedures was to see to it that it 8
was signed.
Did you say by whom it was to be signed?
9 A
No, I didn't.
10 Q
Who was to have the ultimate authority?
11 1
I don't reme mbe r.
12 Q
When you said " signed," you mean be 13 accepted as app rop riate as a GPU procedure?
g3'0 14 A
I meant incorpo rate comments through the 15 signature chain until everyone who had signed the 16 procedure was s atis fied with its content.
17 Q
By what method was this procedure conve rte d 18 from a draft into a procedure applicable within GPU?
I am not sure I unde rs tand 20 the question.
21 MR. BENEDICT:
I am trying to understand 22 the process whereby this procedure went from 23 being a draft to being e f fe ctive.
24 A
I don't recall.
7-(,,)
25 Q
There c mme a time sometime, I take it,
1 LEn90s 91
(")N 2
during the f all or winter of 19 77 th at this draft
\\_
3 became an active procedure or an applicable procedure 4
within GPU; is that right?
5 A
I don't recall when it be came appli c ab le.
6 Q
Is it your recollection thac the e f fe ctive 7
date of 10-CFR Part 21 was in January 19787 8
A I don't remember.
9 Q
When you we re drafting or when you were 10 working on.:this draft procedure, did you understand 11 that this procedure was to be utilized by all the GPU 12 companies?
13 A
I don't re me mb e r.
~)
%)
14 Q
Does GPU Service Corporation or did GPU 15 Service Corporation at this time h ave its own set of 16 procedures?
17 MR. GLASSMAN:
P ro ce dure s for anything?
18 MR. BENEDICT:
Fo r any thing, othe r than 19 clerical, other than style books fo r se cre taries.
20 Procedures that you thought were applicable to 21 you personally and within your j ob.
22 A
I don't know.
23 Q
Did you unde rstand at that time or at any 24 time prior to the accident at Three Mile Island that
(
)
k' 25 Ge ne ral Public Utilities had p rocedures, at least some i
1 Lanace 92
()
2 which were appli cable to you in the cou rs e of your job?
(.)
3 A
At th at time, I don't reme mbe r.
4 Q
You don' t recall or you did say you 5
re called there were p ro ce dure s for compliance with the G
6 requirements of Part 217 7
A That's right.
8 Q
And you recall also that there were 9
p ro ce du res for compli ance with 5 0. 5 5-E ; is that right?
10 A
That's right.
11 Q
Do you recall any othe r procedures?
12 A
I do not, no.
(~}
13 Q
I am not limiting myself, and this question V
14 is pe rhaps broader and maybe simple r than it o riginally 15 sounded.
I am not limiting myself to procedures which 16 may have be6n required for GPU to have pursuant to 17 some law or regulation.
I am refe rring much more 18 broadly to procedures related to your work.
You 19 referred to something earlier called an engineering 20 p ro ce du re.
What are engineering procedures?
21 A
The only one I recall was the one related 22 to 10-CFR 50.55-E.
I can't recall if there were 23 procedures rel a te d to the conduct of my work.
24 Q
Are there today procedures related to the
/~S e
k/
25 conduct of your work?
1 Lansoe 93
[~')
2 A
Yes, there are.
'd 3
Q Could you describe generally those 4
p roce dures ?
~
5 A
No.
g 6
Q Can you remembe r the general titles or 7
areas in which these procedures cove r?
O A
Those procedures cove r the conduct of 9
most are as of operation of the company.
10 Q
Are these procedures assembled in any one 11 place for review?
12 A
There is a GPU Nucle ar procedures book.
s 13 Q
GPU Nuclear is the s ubsidiary for which you
\\_)
14 currently work?
15 A
Yes.
16 Q
Do you know whether there is a book for 17 any other s ubsidiary of General Public Utilities?
18 A
No, I do not.
19 Q
Do you recall that the re was a book on 20 procedures for GPU Service at any time during your 21 employment by that comp any ?
22 A
I don't believe there was.
23 Q
Does GPU Se rvice continue to exist as far 24 as you know?
/~N
()
25 A
Yes.
1 LanOGG 94
/m 2
Q It does exist?
(O' 3
A Yes.
4 Q
Do you know today whether there is a 5
proce dure book for GPU Service?
6 A
No, I do not.
from the time you fi rs t 7
Q At the time 8
were asked to do some work on th e draft procedure for 9
compliance with Part 21, did you utilize any source 10 material with respect to your re view of the draft 11 other than the draft itself?
12 A
Not that I recall.
(')
13 Q
Do you recall whether*you looked at the
\\_/
14 procedure for 50.55-E?
15 A
No, I do not.
I do recall that some 16 point along th e line the re were briefings by NRC, 17 questions and answers on Part 21 and inte rpretation of 18 its applicability.
I am fairly sure that I had re viewe d 19 that mate ri al.
20 6
Would that be the mate rial that is contained 21 in NUREG 03027 9
22 A
I don't remembe r the de s i gn atio n.
23 Q
was it a publication by the NRC that you 24 re viewe d?
O
'/
25 A
Yes.
1 Lcnace 95 h
2 Q
Did you attend any se mina rs on the (d
3 p rospe ctive 10 CFR Part 21 given by the NRC?
4 A
No, I did not.
5 ggg Q
Did you understand that the material that 6
you reviewed, the question and answer material that 7
you reviewed from the NRC, had come partly from these 8
seminars?
9 A
Yes, that's co rre ct.
10 Q
Do you wtill have the mate rial that you 11 used to review?
12 A
No, I do not.
f ')
13 Q
Do you recall where you obtained it?
'v 14 A
It was issued by NRC to licensees.
15 Q
Making "you" the personal "yo u, " do you 16 re call whe re you, Mr. Lanese, got th e document?
17 A
No.
18 Q
Do you recall what you did with it when 19 you were done with it?
20 A
No.
21 Q
Did you make any ch ange s in the draft O
22 procedure you received as a result of your re view o f 23 any material including this material from the NRC?
24 A
I don't recall.
25 Q
Do you recall having any s ub s tantive
1 Lan20e 96
[~'T 2
changes at all on the draft?
C#
3 A
No, I do not.
I don't recall.
4 Q
Did you retain any of the material that 5
you used including the draft itself and any comments 6
you may have received?
7 A
I don't remember.
8 Q
Where would you look today if you wanted 9
to find that material?
10 A
In the licensing files.
11 Q
Can you be -- if you were t rying to help 12 somebody to find it, where would you look?
Under what 13 topic?
Is it a chronological subject?
Are they kept
(^3
(_j 14 chronologically?
Are they kept by s ubj ect matter?
15 Kept by individual?
16 A
It would have been -- I would look for a 17 file th at is en ti tle d 10-CFR 21 or comments on 18 regulations.
It would not have been a chronological 19 file.
20 Q
It would be a file dating from sometime in 21 the fall of '777 22 A
There wouldn' t have been a date associated 23 with the file.
24 Q
Not necessarily written on the file, but
(_)
25 that was when all this was happening; is that righ t?
i 1
Lanace 97
(~T 2
A That's right.
N) 3 Q
Do you recall ab out the latest date that 4
you had any involvement with this draft p ro ce dure ?
5 A
If impleme ntation was indeed in January 6
1978, I don' t believe I had any involvement much beyond 7
that.
8 Q
By what me ans, if any, did GPU bring the 9
requirements of 10 CFR Part 21 to the attention of its 10 e mploy e e s ?
11 MR. GLASSMAN:
You are not looking for 12 Mr. Lanese's personal role b~ut his knowledge if 13 any --
g-k) 14 MR. BENEDICT:
Sure.
If he did something, 15 that is certainly relevant, and also if he 16 remembe rs how -- that he was included in a 17 lecture or slide show or handout or wh ate ve r.
18 A
The regulation required posting of 19 requirements o f Part 21.
I know they were poste d.
20 I believe Mr. Ve rro chi transmitted the procedure to 21 at le ast manage rs at GPU.
lh 22 Q
Who is Mr. Verrochi?
23 A
At that time, Mr. William Ve rrochi was the 24 vice president of the Se rvice Corporation, I believe.
l
(./
25 Q
And it is --
1 Lan320 98
(,)
2 A
Unless it was Mr. Arnold by that time.
3 Q
Robert Arnold?
4 A
Yes.
5 Q
It is your re colle ction that at least the 6
manage rs at what level?
7 A
I am not sure.
8 Q
It was your re colle ction there was some 9
di s t rib utio n o f 'th e regulation itself or of the 10 p ro ce dure s or both or neither?
11 A
of the procedrue.
I don' t recall if the 12 regulation was included in distribution.
[
')
13 Q
Did you receive an unsolicited copy of the 14 p roce dure relating to 10 CFR Part 217 15 A
No, I don't remember.
16 Q
Do you reme'mbe r any othe r disseminations of 17 information co nce rning 10 CFR Part 21 othe r than the 18 postings you have mentioned and the distribution of 19 the procedure t o s ome o r all m,an age me nt level people?
20 A
I know there were postings at the plants 21 as well.
22 Q
Do you know whether there were training 23 sessions conducted on obligations or the requirements 24 of 10 CFR Part 21?
,_s i
8
\\
/
'^'
25 A
I can' t be sure.
1 Lanose 99 s
'L/')
2 Q
You don't recall eve r attending?
3 A
No, I don't believe I did.
4 Q
Do you know of anyone at GPU who atten de d 5
the NRC seminars from which the NRC mate rial came, or G
6 at least parts of it?
7 A
I don't know who if anyone attende d the
(
8 seminars.
l 9
Q Did you unde rstand there to be at the 10 time you were working on the draft procedure for 11 compliance with Part 21, whom did you understand to 12 be in charge of the preparation of that p ro ce dure ?
(/
s 13 A
I don' t understand what you mean by "in
\\_s e
14 charge of."
l l
l 15 Q
Was the re someone who had the ultimate 1
16 responsibility of seeing to it that this procedure l
l 17 was app rop riately drafted and put into e ffe ct, or did 18 you know who that person was?
(
9 j
19 A
I don't remember.
l l
f 20 Q
Who was'your immediate s upe rio r at this f
I 21 time?
22 A
I don't recall if the s afety and licensing 23 manager?s position was filled at the time.
In that 24 sense, I don' t know.
m, 25 Q
Did you have an acting supervisor at le as t
1 Lenaco 100 (v) 2 in that pe riod?
3 A
No.
4 Q
To whom did you report?
5 A
To Mr. Tho rp e.
6 Q
Do you 'have any reason to believe that you 7
did not get this work with re spe ct to this draft in the 8
normal chain of command, through the normal chain of 9
command?
10 MR. GLASSMAN:
I object.
I am not sure 11 what the no rm al chain of command is.
l l
12 MR. BENEDICT:
I will get to that.
(}
13 Q
What is the normal chain of command for you Nm>
14 to get work at this time in the fall of 1977?
How 15 did you get your work?
16 A
Ass uming that the s a fe ty and li ce nsing 17 manager's position was not fill e d.
18 Q
That is your re collection.
19 A
From Mr. Tho rp e.
20 Q
Any othe r source ?
21 A
I could receive work requests from the 22 project manager or work re qu es ts from any other 23 manage r within GPU to supply support.
24 Q
What pe rcentage o f your. work as you can best
)
'/
25 re call during the period of the fall of 1977 did you
1 Lansco 1C1
/ ]'i 2
get from sources other than Mr. Thorpe?
N.
3 A
Pe rhaps ten pe rcent.
4 Q
Do you have any reason to believe that 5
the work that you did with respe ct to 10 CFR Part 21 4
6 and its implementing procedures was work that you did 7
not receive from Mr. Tho rpe ?
l t
I 8
A No.
9 Q
When we began dis cussing 10 CFR Part 21, 10 you p rovide d me with a brief s ummary o f what 10 CFR l
11 Part 21 required.
Since your initial exposure to 12 Part 21 in the fall of 1977, has your understanding of r~s 13 its requirements changed between then and now?
14 A
I don' t believe so.
15 Q
You s aid that you recalled that there were 16 posting requirements which included posting at the 17 plants.
Does that refresh your recolle ction that the 18 procedure that you were working on was a procedure which 19 would apply to plant pe rs onnel as well as to 20 administrative personnel?
21 A
No, it doesn't.
22 Q
You can't recall one way or the other?
23 A
No.
24 (Re ce s s taken.)
7m NJ 25 Q
I would like to show you a ecpy of the
1 Lanose 102 l
)
2 tran s cript of the ASLB hearing on the Metropolitan
\\_/
3 Edison Company Three Mile Island Unit 1 restart, Docket 4
No. 50-289, the date is Novembe r 14, 1980.
And I would 5
like you to turn to Page 5699.
6 First, does the volume I handed you 7
repres ent a copy of testimony that you gave on 8
No ve mbe r 14, 1980, before an ASLB panel with respect to 9
TMI-1 restart?
10 A
Yes, it does.
11 MR. GLASSMAN:
One moment.
12 (Of f-the-re co rd dis cussion ensued between
(~')
13 the witness and his counsel.)
\\/
14 Q
I would like to read, and I would like you 15 to read along with me, the questions and answers 16 beginning et Line 3 of Page 5699.
The question reads:
17 "Weuld you agree that if there were an 18 accide nt with loss of main fee dwate r and total loss of 19 e me rge ncy fee dwate r that you would be unable to meet 20 the re quiremen ts of 50.46 without using feed and bleed?"
21 MR. GLASSMAN:
Objection.
The correct 22 transcript says bleed and fe e d.
23 Q
" Answer:
(Witness Lanese)
I don't think 24 50.46 is applicable as a crite rion be cause we ' re
,(
)
\\
)
l 25 talking ab o ut a multiple failure situation.
50.46 l
l
1 LEncso 103
/~'s 2
does not address that situation.
b 3
" Question:
Let's assume we have lost 4
main fee dwater and assume we have no eme rgency fe e dwa te r.
5 Can the reactor core be adequately cooled following an 6
ac cide nt such as a small bre ak LOCA without using 7
bleed and fe e d?
8
" Answer:
(Witness Lanese)
I think the 9
answer that we gave in response to 6-A still stands, 10 that you would require feed and bleed to cool the 11 re actor core again with the understanding that the 12 total loss of main and emergency feed water isn' t a 13
< ~$
design basis."
d 14 We re you asked those questions and did you 15 give those answers before the ASLB?
16 A
Yes, I di d.
17 Q
Have you had an opportunity to review your 18 testimony before the ASLB at any time since you gave it?
19 A
I believe I read it.
20 Q
Were you asked to prepare an e rrata sheet 21 or note errors in your testimony?
22 A
Yes, I was.
23 Q
Did you do that?
24 A
Yes, I did.
(~)
(_,/
25 Q
To whom did you give your errata sheet?
1 Lanaco 104 (3
2 A
I don' t remember how that was transmitted N]
3 to counsel.
4 Q
Earlie r in the afternoon, we discussed 5
the term, design basis.
That term appears on Line 19 6
of this testimony.
It s ays -
your answer says, in 7
part:
"With the unde rstanding that that total loss 8
of nain and emergency fee dw ate r isn ' t a design basis."
9 What did you mean by the expression, 10
" design basis" when you used it in that se n te nce or 11 that answer?
12 A
An e ve nt for which the requirements of 13 10-CFR -- not requirements -- but acceptance criteria 14 of 10-CF R 50.46 would have to be applied.
15 Q
Is a design basis e ve n t as you used it 16 he re an event which would qualify as the worst case 17 under the assumptions contained in Appendix K to 18 50.46?
19 MR. GLASSMAN:
Are you asking for an 20 opinion or inte rpretation?
21 MR. BENEDICT:
If that is his un de rs t an din g l
22 of the word " design basis" as he used it in his 23 testimony.
24 MR. GLASSMAN:
Objection to the form.
(3qj 25 Lack of foundation, that he refe rred to Appendix K
j 3
Lan2ao 105 i
.I'd 2
in the course of his testimony or that he was V
3 thinking of it at the time or anything of that 4
sort.
It is a compound question with a numbe r o f 5
g as s ump tio ns in there.
6 We are not here to find out some general 7
opinion that this witness now has of a re gul ation,
8 but if you rephrase the ques tion to seek infor-9 mati'on as to what the witness had in mind at 10 the time and what he gave conside ration to, I will l
11 permit him to answe r that.
12 MR. BENEDICT:
I press my question.
13 (Record read.)
g']
\\_/
14 MR. GLASSMAN:
Are you asking for his 15 current opinion or his re collection of what he 16 intended?
17 MR. BENEDICT:
What his unde rstanding is 18 of the word as he used it here.
19 MR. GLASSMAN:
Are you asking for his 20 current understanding of the word as it appears 21 there,or are you asking for his re colle ction o f 22 his unde rstanding as he was applying it i n the 23 testimony?
24 MR. BENEDICT:
Let's try to go with what f
1
/
25 I said, and if the witness can't divine how I 9.
1 Lanaco 106 l
l l
s '%
\\
(Y 2
want it answered, he can ask.
3 MR. GLASSMAN:
I don't think that is an 4
appropriate way to proceed.
The question is 5
so me what unclear, and I am entitled to know what 6
you are asking for so the witness has some 7
. guidance.
8 MR. BENEDICT:
I think it is fair to say 9
that the reason the question is posed the way it 10 is is because Mr. Lanese has not been forthcoming 11 in des cribing what he unde rs tan ds the word 12
" design basis" to mean.
~N 13 MR. GLASSMAN:
I find that absolutely (O
14 obje ctionable and outrageouc.
15 The witness has gi ve n testimony quite a 16 while back today on this.
There w ere no 17 objections voiced by counsel at the time as to 18 the nature of the witness's testimony.
It was 19 totally forthcoming.
You were free to proceed 20 with any furtha r questions if you thought there 21 was some other information that you wante d.
22 MR. BENEDICT:
That is exactly what I 23 am doing here.
I think that my question is 24 un de rs tandab le and acceptable.
I will run the i
(
l 25 risk of it being ob j e ction ab le as to form.
1 Lanese 107
()
2 As you know, you have only to note that 3
on the record, and it is preserved.
4 I would appreciate if we can get this 5
answer, and if I do n' t understand the answer or 6
if Mr. Lanese doesn' t unde rstand the question, 7
I am sure he and I can work that out.
8 I don't app rove or appre ciate e f forts 9
to m ake a question sound even more confusing 10 than it is.
11 MR. GLASSMAN:
We have our different views.
12 MR. BENEDICT:
I am sure if we can get an 13 answer to this question, we can move on from 14 there.
We can save a lot of time by not entering 15 into a bunch of colloquy.
16 MR. GLASSMAN:
He can attempt to answer 17 it, but the objection s t a n ds.
18 (Re co rd re ad. )
19 A
As I have used the te rminology he re, I 20 was dis cussing and commenting on whether the 21 postulated event was required to meet the accepcance 22 criteria of 10-CFR 50.46.
23 Q
Is that your response to my question?
24 A
As best as I can give it at this time, yes.
O 25 MR. BENEDICT:
.I object and move to strike
1 Lansaa 108
(~')
2 as nonresponsive.
But'we will go on rather V
3 than quibbling abo ut i t.
4 MR. GLASSMAN:
Let me add he re, lest 5
there be any confusion:
Besides the point I 6
was making, I am not directing the witness not 7
to answers and obviously I think you received 8
a responsive answer.
9 There are di f fe re nt in te rp re t atio ns of 10 what your question was, whether it was directed 11 to what the witness meant by " design basis" as 12 used in the testimony, or whether the re was 13 perhaps a different question implied by counsel
-sIs)
RJ 14 as to some othe r inte rpretation o f Appendix K 15 or something like that.
The witness has given 16 his testimony as to what he meant when he gave 17 his testimony, which may not be the same as what 18 counsel thinks he meant.
You are free to ask 19 further questions if you wish.
We were not 20 dire cting the witness not to answer.
21 BY MR.
BENEDICT:
h 22 Q
As I understand it, Appe ndix K contains 23 certain maximum limits with respect to core cooling; 24 is that cor re ct?
e i
(_/
25 A
It contains limits on allowable pe ak cladding f
1 1
Lanago 109
/~1 2
temperature.
3 Q
And local oxidation?
4 A
Yes.
5 Q
overall hydrogen generation?
6 A
Corre ct.
7 Q
Coolable geometry?
8 A
It doesn't sp e ci fy coolable geomet ry, but 9
it addresses it.
10 Q
Were you answering this question utilizing 11 50.46 merely as a list o f wh at the NRC co nside rs 12 ac ceptable co re-c oo ling crite ri a, or were you using
~s 13 it in the analytical sense as it is utilized for
'b 14 licensing?
15 MR. GLASSMAN:
Objection as to form.
16 The witness may answer.
17 A
I don't believe either one of those 18 characterizations explains the context o f th e answer 19 here.
20 Q
I guess what I am getting at is that 21 isn't it true that the limitations imposed for core 22 cooling in 50.46 are limitations on hypothetical 23 events which are calculated based on assumptions 24 containe d in Appendix K to 50.467
'_j 25 MR. GLASSMAN:
Objection insofar as you r.
1 LenaEG 110
(')
2 are asking for an interpretation of a regulation V
3 which we can all read and apply ourselves, if 4
we wish.
5 If the question is directed to whether 6
you have corre ctly stated Mr. Lanese's 7
un de rst anding of that, then I will accept the 8
question.
9 MR. BENEDICT:
I am asking what his 10 unders canding is.
11 A
My answer is "No."
12 Q
Prior to the Three Mile Island accident, ew.
13 what was your unde rstanding of the utilization of U,
14 50.46 for purposes of licensing?
15 A
That in conjunction with applicable general 16 design criteria and other sections of Part 50, 17 app rop ri at e e q uipme nt availability would be defined, 18 the event had been defined, and equipment 19 availability would be an aly z e d, and the acceptance 20 criteria for fuel o xi da tio n, peak clad tempe rature,
21 et ce te ra, as we mentioned be fore, would be de fin e d h
22 in 50.46 and Appendix K.
23 Q
You mentioned that an analysis would be 24 done.
Isn't it true that that analysis would be done p
\\ _,/
25 pursuant to the assumptions set fo rth in Appendix K to
Lenace III 1
f)
2 Part 507 8J 3
MR. GLASSMAN:
You want the witness's 4
un de rs t anding?
5 MR. BENEDICT:
Prior to the Three Mile 6
Island accident.
You want the witness's 8
unde rstanding now o f wh at the regulations were 9
then?
10 MR. R EZI E D I C T :
What his unde rs tanding was 11 prior to Three Mile Is lan d.
12 A
No.
rS 13 Q
That it is not your understanding that U
14 Appendix K p rovide d the as s ump tions unde r which 15 analyses to assure compliance with 50.46 were done?
16 A
My answer to that question is yes.
17 MR. BENEDICT:
Let's hear the question 18 back.
19 (Re co rd re ad. )
20 Q
You are saying it is not your unde rs tanding?
21 A
My understanding is that Appendix K 22 supplies the criterion with respect to fuel pe rformance 23 under which you do the fuel analysis in order to 24 demonstrate compliance with 10-CFR 50.46.
I
)
s' 25 Q
When you say fuel analysis, do you mean
1 Lansso 112
[-)
2' core cooling analysis?
t 3
A core cooling, blow down as s umptions,
4 acceptable correlations to be used in the core cooling 5
analysis, yes. 5 0.4G and Appendix K are not the only 6
governing regulations.
7 Q
By that you mean there are other general 8
acceptance crite ria' othe r than 5 0.46 and Appendix K?
9 A
There are o the r regulations and gene ral 10 design crite ria waich de fine the analysis that has to 11 be performed.
12 Q
Those are in addition to, rather than in
(i 13 lie u of, an aly s es purs uan t to 50.46 and Appendix K?
\\ /
14 A
Yes.
15 Q
Prior to the Three Mile Island accident, 16 what was your understanding of the meaning of the 17 exp re s s io n, single-failure crite rion?
18 A
By " single-failure cri te rio n, " I assume 19 the postulation of a worst case active or passive 20 failure of electrical equipment or wo rs t case active 21 f ailu re of me chanical equipment to define the 22 eq uipment pe rfo rmance during various design basis l
23 events.
Single-failure did not include consequential 24 f ailures o f the event did not and does not include
. /s t
I 25 co nsequenti al failures and did not and does not include
1 Lcnoco 113 Ij 2
nondetectable failures.
\\_/
3 Q
What is a consequential failure?
4 A
Consequential failure wo'ulb be an equipment 5
failure or accident cons eque n ce that f$11ows from the
\\
6 event that is being postulated.
7 Cof f-the-re cord discussion ensued between 1
8 the witness and his counsel.)
9 Q
Was it your unde rstandinej phior to the[
s 10 Three Mile Island accident that the NRC did not require 11 that the design of a nucle ar plant comply dith the'
>,t 12 requirements of 50.46 in the event of a multiple x
r-~N 13 f ailu re situation?
N.
14 Let's hold back that question.
I will
\\
15 withdraw that question for the time being.
16 Could you explain to me what a multiple 17 failure situation is?
You use it in Line 9 o'f your 18 testimony at Page 5699.
That is where I got it.
19 A
Multiple failures would be independent s
20 failures of s afety-related equipment.
21 Q
Is a common mode failure a type'of h
22 multiple failure, as you unde rstood it, p rio r t o the 23 Three Mile Island accide nt?
24 A
It is a separate categorization of failure.
t
)
K' 25 Q
Are all common mode failures contained as eu -
~
1 Lcncos 114
(,,)
2 a s ub s e t within the gene ral set of multiple failures 3
as you un'derstood it prior to the accident?
4 A
No.
5 Q
In what respect, as you understood it prior 6
to the Three Mile Island accident is a common mode 7
failure di f fe re n t from a multiple failure?
8 A
A common mode f ailure is di f fe rent from a 9
multiple failure in that it is included in th e design 10 basis of the power plant.
11 Q
Is a common mo de failure o f high-press ure 12 inje ction included within the design basis of Three f^}
13 Mile Island Unit 2 or was it prior to the ac ci de nt ?
%j 14 A
Let me explain my answer again.
If a 15 common mode failure is detected or is postulated to 16 cause failure of all high pressure injection, then, a
X 17 yes, it is within the design basis o f the plant.
3 18 -
Q Is a common mode' failure a failure of a 19 single component which has th e e f fe ct of eliminating
~
20 othe rwise re dundant components, all redundant 21 components?
f 22 A
If you mean a single component that is 3.
23 duplicated in more than one train, and I should say 1
24 redundant train, then the answer would be yes.
It is
?
)
"I 25 not a single component that affects multiple trains.
\\
\\-
.s
1 LEnone J35
(
)
2 Q
It rather is a component, one of which is a
3 contained in each train, which is s ub j e ct to 4
simultaneous failure with its fellows?
5 A
To a common cause of failure, yes; fo r 6
example, a design deficiency, which could cause multiple 7
components to fail at the same time.
8 Q
Is it -- was it prior to the Three Mile g
Island a'ccidentsin the s afe ty analyses done,e ve r ass ume d 10 for purposes of analysis that a small break loss of 11 coolant accident could occur at Unit 2 when there would 12 be no high-pressure injection available?
/~h 13 MR. GLASSMAN:
Objection.
You used in U
i 14 your question a statement of any safety analysis 15 done.
16 MR. BENEDICT:
I will restate the question.
17 Q
Earlier in your testimony you used the 18 e xp re s s io n, FSAR transients and accidents.
Did any of 19 the FSAR transients or. accidents included in the Three 20 Mile Island Unit 2 FSAR which relate d to small break 21 LOCA's conside r the scenario of no available k
22 high-pressure injection?
23 A
Yes.
24 Q
What transient or transients were those?
,/ \\
25 A
There was a question relating to the
1 Lanaga 116
[~)
2 failure o f a high-pressure inje ction line associated
'V 3
with the single active failure that could result in 1
4 no high-pressure inj ection and which is a small bre ak 5
loss-of-coolant accident.
6 Q
Was there a procedural change made to 7
eliminate the possibility that no high-pressure 8
injection would be available prior to the Three Mile 9
Island accident?
10 A
I believe so.
11 Q
Was that the cross-connect of the HPI pumps ?
12 A
Manual cross connect?
13 Q
Yes.
(n) 14 A
By operator action, yes.
15 Q
Other than that event, was there any 16 postulated FSAR transient or accident relating to 17 small-break LOCA's which assumed the total absence of 18 high-pressure injection?
19 MR. GLASSMAN:
You are looking for Mr.
20 Lanese's reellection?
21 MR. BENEDICT:
Yes, prior to the Th ree 22 Mile Island accident.
l l
23 MR. GLASSMAN:
Obviously we can read the 24 FSAR and try to as ce rt ain that.
l
,A.
( )
25 A
Implicit in any accident in which HPI
1 Lan900 117 l')
2 was assumed was the conclusion that the re were no V
3 common mode failures or consequential failures of 4
that event which could result in failure of 5
high-p re s s ure injection.
6 Q
Was the j us ti fi catio n fo r that implicit 7
assumption the single-failure crite rio n ?
8 A
It was a numbe r o f things, including the 9
single-failure criterion.
10 Q
What else j ustified that implicit 11 ass umptio n?
12 A
Explicit investigation of the ef fects
("]
13 of high-energy line break, the pipe whip and jet
\\J 14 impingement resulting from the line break, common mode 15 failure considerations, and the e f fe ct of a natural 16 phenomenon.
17 Q
Such as earthquakes?
18 A
Yes, or floods or fi re s.
19 Q
Prior to the Th ree Mile 'sland accident, 20 what did you understand to be the source o f th e 21 single failure crite rio n?
22 A
With respect to LOCA analysis, it was 23 embodie d in general design criteria 35, and a footnote 24 to the preamble of Appendix A.
5 4
25 Q
Appendix A?
i 1
Lrnsco 118
(~h
( )
2 A
Appendix A of 10-CFR 50, and as re fe ren ce d 3
4 Q
Would it be corre ct for me to say that 5
single-failure criterion and design basis are terms 9
6 of art in your job?
7 A
' Single-failure crite rion is well de fine d,
8 and certain areas are subj ect to interpretation as is 9
any regulation, but no, I wouldn't consider it art.
10 Be fo re the accident, there weze f airly well-de fined 11 criteria upon which to perform single-failure analysis.
12 Q
I guess I may have assumed that that
[- )
13 expression common to lawyers was common to enginee rs.
LJ 14 By " term of art," I mean a term that has a regularly 15 accepte d de finition in your business ; a generally 16 accepte d definition would be a better expression.
17 Are the exp res sions,
18
" design basis " and " single-failure cri te rio n, "
19 expressions with a gene rally accepted de finition 20 within Mr. Lanes e ' s field?
21 MR. GLASSMAN:
I don' t know what you me an 22 by Mr. Lanese's field.
23 MR. BENEDICT:
Nuclear engineering and f-24 licensing.
!\\ _./
25 MR. GLASSMAN:
You are talking about now
1 Lanage 119 en
(
)
2 or then?
v MR. BENEDICT:
His entire ca re e r.
3 4
MR. GLASSMAN:
You are looking for his 5
judgment on this, I assume?
6 MR. BENEDICT:
Absolutely.
If he is 7
uncomfortable with saying it, he can just s ay h e 8
doesn't know.
9 A
There is no one de finition of the 10 single-f ailure c ri te rion, but I believe the de finition 11 that I previously gave is accepted within the industry.
12 Q
Is that true as well with the expression,
~h 13
" design basis"?
(d 14 A
With respect to licensing the plant, 15 design-basis e ve nts are defined.
16 Q
I beg your pardon?
17 A
Design-basis e ve nts are defined with 18 respect to lice nsing power plants, and there is some 19 interpretation associated with that from docket to 20 docket.
21 Q
Can you provide me with a general definition 22 o f design-basis e vent, as opposed to a de finition by 23 example, a general understanding, as you unde rstand it 24 in licensing, your expertise?
i
[~'N
\\
25 MR. GLASSMAN:
Haven' t we done this b efore?
1 LcnacG 120 l',
_f l
2 MR. BENEDICT:
This is the question you 3
said I was entitled to ask a few more questions 4
on.
5 MR. GLASSMAN:
I understnad.
But it seems 9
6 like you are asking the same question.
7 MR. BENEDICT:
I put on the record that I 8
moved to strike the answer as non re spo ns ive.
9 I would like to try to get an answer that is 10 responsive.
11 MR. GLASSMAN:
I should note that the 12 answer which you purportedly moved to strike was
(~'i 13 not to the question which you have just phrased.
V 14 The question you just phrased was asked a good 15 de al earlie r in the day, and there was an 16 answer, and there was no motion or no comment.
17 Eve rything was fine. I will let you have the 18 witness answer this to speed things along.
19 MR. BENEDICT:
I agree I did cover part of 20 this subject earlier.
I stoppe d be cause I was 21 going to go off to another one, because I O
22 realized I was going to have to work from i
23 example, be ca us e I wasn't ge tting answers that 24 I could deal with, and I thought if I presented 25 him some testimony where he used the expression,
1 LEnase 121 73 i
j 2
I might get something out of him.
That happened 3
later in the deposition.
I don't think I am 4
abusing the deponent or the practice of taking 5-depositions.
gg 6
MR. GLASSMAN:
In the interest of getting 7
on with it, he can answer once again.
8 BY MR. BENEDICT:
9 Q
Could you give me a general de finition of 10 the expression which you used, " design basis event,"
11 as opposed to a definition which relies solely on 12 example?
[~ }
13 A
A design basis event is a postulated
%/
14 accident or transient which is a basis for the 15 licensing of 'the powe r plant in which acceptance 16 crite ria are specified.
17 Q
Are design basis events negotiated with 18 the NRC for a particular plant?
19 A
I wouldn' t use the word " negotiated,"
20 but on various dockets, ce rtain events are imposed 21 that may not be imposed as design basis events on other 22 dockets.
23 Q
For example, some dockets might impose a 24 more strict requirement with respect to seismic i
25 activity.
Is that an e x amp l e o f wha t y ou me an, o r
1 Lonsso 122
(,)
2 aircraf t impact?
I 3
A Aircraft impact is an example o f an event 4
that may not be imposed on every plant.
5 g
Is the re a list o f th e design-basis events gg 6
for Three Mile Island Unit 27 7
A Not in that form, no.
8 Q
What form -- how are the design-basis 9
events fo r Unit 2 inco rporated into the FS AR?
10 A
They appear in the Accident Analysis 11 Section, in Chapter 2 on natural events.
I believe 12 also it would appear in some cases as license conditions.
rx j
13 Q
Would that mean that they were not included
\\v/
14 in the FSAR or they were?
15 A
That the event might have been discussed 16 in the FSAR, but not having been incorporated into the 17 body of Chapter 15, it would not ne cess arily be come a 18 design-basis event.
Merely answering your ques tion,
19 on the consequences of an event in the FSAR or on the 20 docket does not make it a design-basis event.
21 Q
Are you aware of any design-basis event O
22 include d within the docket or applicable to Three Mile 23 Island Unit 2 which relates to a small-break LOCA and 24 as s ume s the total abs en ce o f high-pressure injection?
,3
\\
)
25 A
I have to f all back on my previous answer.
1 Lanaco 123 f~n
()
2 Explicitly, the HPI line b reak and implicitly eve ry 3
other small break assumes that HPI is available be cause 4
there is no common mode failure, consequential failure 5
or single failure that makes HPI totally unavailable.
gg 6
Q Prior to Three Mile Island, did you 7
understand that the requirements of 10 CFR Part 21 as 8
they applied to you required that you report 9
hypothetical or potential events beyond the design 10 basis of the plant?
11 MR. GLASSMAN:
Objection.
Compound 12 question.
I) 13 MR. BENEDICT:
Let me hear the question.
'v/
14 (Re cord read. )
15 MR. BENEDICT:
You just have a quarrel with 16 the hypothetical or potential?
17 MR. GLASSMAN:
I don' t know if there is 18 any dif fe rence.
19 MR. BENEDICT:
I will stand on the 20 question because I can't think o f any reasonable 21 way to rephrase i.t.
O 22 A
Yes.
23 Q
Did you at any time prior to Three Mile 24 Island make any reports p urs uant to 10 CFR Part 217
(
I 25 A
I don't recall.
1 Lan20e 124 ck_'
2 Q
Have you made any reports pursuant to the 3
p roce dure s in place at GPU prior to Three Mile Island, 4
procedures in place at GPU with respect to compliance lll 5
with Part 217 6
A Who do you mean by "you"?
7 Q
I will rephrase the question.
My earlier 8
question was, did you make any reports purs uant to 9
Part 217 I want to make sure we unde rs tand e ach othe r.
10 I mean to include reports pursuant to the procedure at 11 GPU with re sp e ct to compliance with Part 21.
12 MR. GLASSMAN:
Reports by Mr. Lanese?
13
( J-
-13 MR. BENEDICT:
Yes.
14 A
No, I neve r did.
15 Q
Have you made any pursuant to that procedure 16 since the Three Mile Island accident?
17 A
No.
18 Q
Did you make any reports with respect 19 to the Three Mile Island accident unde r the procedures 20 at GPU for 10 CFR Part 21?
21 A
No.
O 22 Q
Did you understand prior to Three Mile 23 Island that pursuant to Part 21 you were oblige d to r^N 24 report hypothesize d multiple-f ailure situations in j
]
25 which general acceptance crite ria would be e xce e de d?
l i
1 Lensas 125
,. m
(%,)
2 A
It hinges on the me aning of " multiple 3
f ailure s. "
4 Q
I understood you to mean by " multiple 5
failures," failures beyond those hypothesized by the ggg 6
single-f ailure crite rion.
7 A
If there were hypothesized multiple 8
failures of safety grade equipment not caused by 9
common mode failure, you would not be required to 10 report by Part 21.
I should add, not as a result 11 o f common mode failure or consequential failure, pipe 12 whip or j et impingement, then you would not be require d
/']
13 to report.
(J 14 Q
Has your unde rs tanding o f the de finition 15 of single failure crite rion changed since the time of 16 the accide nt at Three Mile Island?
17 A
No.
18 Q
Has your unde rs tanding o f the de finition 19 of design-basis event changed since the accident at 20 Three Mile Island?
l 21 A
No.
1 22 Q
H as your understanding of the meaning of 23 the expression, " common mode failure," changed since 24 the accident at Three Mile Island?
l
~-
(
)
~
25 A
No.
1 Lanasa 126
,s
(
)
Q Do you unde rstand the requirements of
_j 2
Part 21 to have changed since the accident at Th re e 3
Mile Island?
4 "Y
" " *d9**
ggg 5
6 Q
Are y u aware f any proposed changes to the requirements of Part 21 by the NRC since the 7
8 accident at Three Mile Island?
A No, I am not.
g 10 MR. BENEDICT:
That is all, it (Time noted:
5:00 o ' clo ck p. m. )
12
[)
13 N_/
Louis C.
Lanese 14 15 Subscribed and sworn to be fore me 16 this day o f 1982.
17 18 Notary P ublic 19 20 21 0
22 23 24 cx 25 E
I 127
(^')
2
_C _E _R _T _I _F _I _C _A _T _E g
3 STATE OF NEW YORK
)
- ss.:
4 COUNTY OF NEW YORK )
5
'g 6
I, JOSEPH R.
DANYo a
7 Notary Public within and for the State of New York, 8
do hereby certify that the foregoing deposition 9
of LOUIS C.
LANESE Was taken before 10 Wednesday, March 24, 1982 me on 11 That the said witness was duly sworn 12 before the commencement of his testimony and 13
[
)
that the within transcript is a true record of said 14 testimony; 15 That I am not connected by blood or 16 marriage with any of the parties herein nor 17 interested directly or indirectly in the matter in 18 controversy, nor am I in the employ of.any of the 19 counsel.
20 IN WITNESS WHEREOF, I have hereunto set 21 my hand this 7
day of
/4 ((
1982.
,O e
22 YW Daho oseph R.
}
25
128 IN DE X WITNESS PAGE LOUIS C.
LANESE 3
O EXEIB I TS j
B&W FOR IDENTITICATION 603 Re sume of Louis C.
Lanese 4
604 Memorandum dated Novembe r 19 on letterhead of GP Se rvice Corpo ration, subj e ct :
Major outstanding TMI-2 NRC Licensing g
Issues 59 4
oOo O
~
4
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