ML20072H963
| ML20072H963 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/16/1982 |
| From: | Shovlin D GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-02, TASK-04, TASK-05, TASK-06, TASK-10, TASK-2, TASK-4, TASK-5, TASK-6, TASK-GB NUDOCS 8306290839 | |
| Download: ML20072H963 (204) | |
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK .
_ _ _ - _ _ _ __ _ _ _ _ _ - - - - -x dot GENERAL PUBLIC UTILITIES CORPORATION, a
- JERSEY CENTRAL POWER & LIGHT COMPANY, (t METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683
- (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J. RAY McDERMOTT & CO., INC., :
Defendants. t :
- - - - - - - - - - -- - - - - - - - - -x C')
(_/
Deposition of DANIEL SHOVLIN, taken by defendants pursuant to agreement, at the offices of Davis Polk & Wardwell, Esgs.,
One Chase Manhattan Plaza, New York, New York, on Friday, July 16, 1982, at 9:55 o' clock in the forenoon, before Nancy A.
Rudolph, a Notary Public within and for the State of New York
- i. i k
0306290839 820423 PDR ADDCK 05000 .
T DOYLE REPORTING, INC.
CERTIFIED STENOTYPE REPORTERS 369 LEXINGTON AVENUE WALTER SH APIRO, C.L.R.
NEw YomK. N.Y. 10017 CHARLES SHAPIRO. C.S.R.
TEl.E P H O N E 212 - 867 8220
1 2
2 A p p e a r a n c e.s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4 425 Park Avenue New York, New York
( 5 By: STEVEN J.
GLASSMAN, ESQ.,
6 of Counsel
~
n >
DAVIS POLK & WARDWELL, ESQS.
8 Attorneys for Defendants One Chase Manhattan Plaza 9 New York,.New York 10 By: ROBERT F. WISE, ESQ., ',
of Counsel 11 12 '
Also Present:
C\
-' I3 NINA RUFFINI 14 15 IG IT IS HEREBY STIPULATED AND AGREED by and 17 between the' attorneys for the respe ctive parties 18 hereto that the sealing, filing and certification 19 of the within deposition be, and the same hereby 20 are, waived; that the transcript may be signed 21 before any-Notary Public with the same force and k !
22 effect as if signed-before the Court.
l 23 '
IT IS FURTHER STIPULATED AND AGREED that all (g) 24 i
objections, except as to the form of the question, x_ .z -
25 are reserved to the. time of trial.
. - + , r .%- ,
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1 3
. n.
U 2 DA NIE L S HOVL I N, having been first 4
3 duly sworn by the Notary Public, was examined 4 and testified as follows:
( 5 EXAMINATION BY MR. WISE:
6 Q Mr. Shovlin, would you state your full name l 4
7 for the record, please?
8 A Daniel Shovlin.
i 9 Q Where are you currently employed?
10 A GPU Nuclear, Three Mile Islh.nd.
11 Q What is your present business address?
12 A Three Mile Island Nuclear Station, O
13 Middletown, Pennsylvania.
14 Q What is your current residence address?
15 A 445 West Caracas Avenue, Hershey, a
16 Pennsylvania.
17 Q Your counsel has produced to us this morning 18 a short resume which I would like to have marked as 19 B&W 897.
20 (Resume of Daniel M. Shovlin was marked 21 B&W Exhibit 897 for identification, as of.this 22 date.) !
i 23 Q Did you participate in'the preparation of !
D 24 B&W 8977
- 25 A I had input to that. That was part of a L
I 1
1 Shovlin 4 I /]
Gr .
2 resume of mine that was in the FSAR and other hearings.
3 Q Is it an accurate summary of your educational 4 background and_ work experience?
( 5 A Yes, it is. >
6 Q Briefly, X understand you were in the Navy 7 from 1946 to 1973, as shown on the resume.
] 8 A That is correct.
, l
, i 9 Q- During that time you had experience with 10 some of the nuclear ships that are in the Navy?
11 i A No, no nuclear experience prior to coming i 12 to Metropolitan Edison in 1973.
l i
-) 13
'I Q You joined Metropolitan Edison in July 1973, i- '
14 I believe?
15 h That is correct.
16 Q And your position at that time was supervisor '
17 of maintenance? -
18 A Supervisor of maintenance on Unit 1, yes, 19 sir.
4 20 Q~ And you remained in that position through 21 January of 19777 22 A That is correct,
[ f 23 l
l Q In January of 1977 you became supervisor
,' :(yw--,)
24 of maintenance for Unit 27
-25 A That is correct.
l r
I ns ,- 4 -*v w --, .--e-.-- , ,o w y
1 Shovlin 5 2 Q Who succeeded you as supervisor of .
3 maintenance for Unit 1?
4 A Bill Sawyer.
( 5 Q Your resume indicates that at the end of 6 1977 you became superintendant of maintenance for the 7 Three Mile Isla'nd Station. Am I correct that that would 8 include both units?
9 A That is correct.
10 Did Mr. Sawyer leave?
Q .
11 i A Mr. Sawyer left and I went to Unit 1 and 12 wore two hats for a period of time.
.O 13
.Q You were both Unit 3 supervisor of 14 maintenance and superintendent for the entire Island?
15 A yes, 16 ,Q Was there also at that time a supervisor 17 '
of maintenance for Unit 27 -
18 A Yes.
19 Q Who was that? I 20 A' Dick Sieglitz. l
. 21 Q He reported to you?
-( j 22 A Yes.
23 How long did that situation continue?.
Q
-(,
O). 24 A' Almost to the time of the accident. There 25 was a period of time where there was a gentleman who
i i Shovlin 6 tO
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2 was going to relieve me and he never officially took 3 over the title but I was there to tucor him and work 4 with him for a while, and his n'ame was Tom Hawkins.
( 5 Q Hawkins was going to,take over as Unit 1 6 supervisor?
7 A Yes.
8 Q And he would report to you as superintendant 9 for the entire station?
10 - A That's correct. -
Il Q But as -c f the time of the accident in 12 March 1979, is it correct that the structure was still '
13 you as superintendent for the station with Mr. Sieglitz i
14 l as supervisor for Unit 2 and the position for supervisor 15 for Unit 1 left blank with your temporarily filling 16 that?
17 A That is correct. .
18 Q Am I correct then that the position of 19 . supervisor of maintenance for Unit 1 was left unfilled 20 from December of 1977 until the time.of the accident?
21 MR. GLASSMAN: Are you-talking now about the 22 position or the function?
i 23 ; MR. WISE: I am talking about the position
- O)
- t. 24 as opposed to the fact that you may have fulfilled 25 those responsibilities.
1 shovlin 7 (7 sI u_J 2 A Yes, the time frame that Tom Hawkins was 3 brought in to take over that position but was not 4 officially instated, it was near the end of the year --
(~ 5 it is --
it was sometime near the end of the year, 6 I believe, in 1978.
7 Q That he was hired?
8 A No, no, he was part of GPU startup. He 9 was in the organization and they moved him in to take 10 over that position. 6 11 Q When was that done?
9 12 A I am not sure of the dates. I believe it was at the latter part of 1978.
13 14 Q And he was still training for that position 15 as of the time that the accident occurred?
16 A That is correct.
17 Q Why was the position of supervisor of 18 maintenance for Unit 1 left unfilled between December 19 1977 and the time that Mr. Hawkins was ask d to begin 20 training to fill that post?
. 21 A Well, I was a supervisor of maintenance *
'k-22 on Unit No. 1 for many years and I was very knowledgeable
'M of Unit 1 and I was the likely person to fill that
/ '\
( j 24 position until someone who met all the criteria, all l 25 the. qualifications.for the position, and it just so
1 Shovlin 8 2 happened that I filled that void for that period of 3 time.
4 Q The plan as of the end of 1977 was to have
( 5 a superintendent of maintenance who would oversee two 6 supervisors of maintenance, one each for the two units; 7 is that right?
8 A That is correct.
9 Q Was Metropolitan Edison having difficulty
~
10 hiring someone to fill the position of supervisor of
.11 maintenance for Unit 17 12 A I don't really know that they had problems O 13 or not.
- 14 Q As of December 1977 you were supposed to 15 move up to the position of superintendent of maintenance 16 for the entire station?
17 A And I was that. .
18 Q And you did have someone toacbas 19 supervisor of maintenance for Unit 27 20 A Someone filled the position, that's correct.
.. 21 Q Mr. Sieglitz?
L ,
22 A That's correct. i 23 I Q- And we have established that no one in i,/^N ;- 24 December'1977 immediately took over the position of
.v
, '25- supervisor for Unit 1.
y .- - - - -- --*-t. . --9 < y w. =r ,y--- ,-w---e y v 7e- ----_.e +
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1 Shovlin 9 2 MR. GLASSMAN: That is not what we 3 established. We established this a couple of 4 times already, that Mr. Shovlin filled that
( 5 position but they were looking for someone else 6 to assume that title and that position.
7 Q The plan originally, Mr. Shovlin, was that 8 you were supposed to have one person as supervisor 9 of maintendnce on Unit 1 and someone else who would 10 be supervisor of maintenance for Unit 2h 11 A That was the scheme.
12 Now, in that sense of the position not Q
O 13 being filled by someone who was different.from the person 14 who was filling the position.of superintendent of 15 maintenance,.you agree with me that the position went 16 . unfilled for over a year at Unit 17 17- A Yes. -
18 Q And my question now is, can you explain 19 for us the. reason why that was? l l
20 MR. GLASSMAN: I think that has been asked
- 21 and answered. He can try again.
k.
22 A Till they met someone to meet the f
l 23 : -qualifications-to fill'that position, and apparently g ,/ 24 ;there was a period of time that they did not'have an ;
25 applicant or a person in-house that they could put in 1
1 Shovlin 10
' ~
2 the position, and eventually Mr. Hawkins, who I believe 3 was in the startup program, was a candidate.
4 Q You referred in your answer to "they."
I~
( 5 Who are_you talking about?
_, g A I was the superintendent. I have a station 7 manager I reported to, and he reported to a vice i
8 president, and so I am not -- I was not out recruiting g supervisors of maintenance for Three Mile Island.
10 Q Whose responsibility was it ,to do that?
i il A Well, the personnel department.
12 Q Did you have anything to do with the 0'1
\'
selection of a supervisor of maintenance for Unit 17 13 14 A Oh, yes.
15 Q Can you describe what your responsibilities 16 were for filling that post?
17 A With regards to my interview with the 18 individual and looking at his background?
19 Q Whatever it was. '
-20 A I was very familiar with Mr. Hawkins. I 31 ; worked with Mr. Hawkins in the startup and test' program, I k,w so I_ knew of his background and I knew of his experience. . '
22 {
23 I
Q .I am afraid I haven't made my question clear.
f~(N) 24 There was a post at Unit 1 called supervisor of 25 maintenance who was-supposed to report to your right?
l
l l' Shovlin 11 D
2 A That's correct.
3 Q Could you describe for the record what your 4 involvement was in the recruitment and hiring of someone l
( 5 to fill that position?
l 6 A I did not have no personal involv,ement of 7 naming Mr. Hawkins to fill the position. That was 8 someone else. I just so happened to know Mr. Hawkins 9 and worked with Mr. Hawkins so I felt he was a very 10 good candidate.
11 Q Let's put Mr. Hawkins aside. I am not 12 speaking specifically of him. What I am trying to get
\_-
13 at, Mr. Shovlin, is what your responsibilities were 14 for seeing to it that that post.was filled in a timely 15 manner by someone who was qualified to occupy it. Did 16 you have any responsibility at all to do that?
17 A First of all, I was very comfdrtable in what 18 I was doing, filling both jobs. I had the position 19 for many years. I was in the startup of hheunit so 20 it was not an overburden or a problem for me; o.k. -As 21 long as I had a gentleman on Unit 2 who.was technically 22 qualified to fill that position on Unit 2, I felt very i I
23 comfortable in being able to han'dle the supervisor of O
(_g 24 maintenance on Unit-1 and also being responsible for
.25 both units.
f-f I
1 Shovlin J2 h(_/
2 ,Q I guess that doesn't answer my question.
3 What was your personal involvement or responsibility 4 in recruiting and hiring an individual in a timely
( 5 manner who would be qualified to hold the position of 6 supervisor of maintenance for Unit 17 7 A I have no responcibility whatsoever of 8 going out and procuring an individual to fill any 9 position at Three Mile Island.
10 Q Are you saying you had no responsibility 11 in getting that post filled?
g 12 A Except for me to go to my seniors and tell e
\~
13 them, when are we going to fill the positionsand are 14 there any candidates, and eventually yes, there was a 15 candidate that came up and it happened to be Mr. Rawkins 16 and he was with the company and was on the' Island.
17 Q Did you from time to time, between the period 18 December 1977 and late 1978 when Mr. Hawkins was 19 identified as a candidate, go to your supe $1 ors and 20 request that the-position be filled?
21 A I don't remember.
22 Q Do you know whether there was any active- I M_ l ' search that was taking place between December 1977
(~)
1( / '24 } and the time that Mr. Hawkins was identified as a 25 candidate in late 1978 to find an individual to fill
1 Shovlin 43 2 that position?
3 A I don't recall.
4 Q' You don't remember anybody reporting to you
( 5 one way or the other.what was taking place?
6 A No.
7 Q Did you interview any applicants for the 8' post of supervisor.of maintenance at Unit J between 9 December 1977 and the time that Mr. Hawkins wa's 10 identified in late '787 11 MR. GLASSMAN: I think the witness already 12 testified he had no role in that.
f' d,s) ,
A 13 I don'.t believe I had, no. I did not.
14 Q Is it true, then, that to the best of your 15 knowledge, there was nothing that was being done to fill 16 that post between December 1977 and the time that Mr.
l'T Hawkins was identified in 19787 '
18 A To my knowledge? Yes, to my knowledge, 19 there could have been -- personnel could have been 20 pursuing it or some other activity but --
21 Q But you had no knowledge one way or the 22 i' other as to anything that was being done?
i M A No. I
{}
(_,( 24 ' Q Did it ever come to your attention that 125 there were budgetary restraints with respect to the t
, e m, ,- - - - - - , - - , - - --; - ~ v w
- 1 Shovlin J4
(~
u) 2 maintenance department at TMI?
3 A With regards to what?
4 Q Well, there was a budget for maintenance
(.. 5 at TMI, was there not?
6 A Yes. .
7 Q And there was a budget in 1977 and 1978?
8 A There was a budget ever since the day I 9 was there.
10 Q Did it come to your attention in late '77 l
11 or during early '78 that Met Ed management was seeking 12 budgetary reductions across the board, including 13 maintenance, at TMI?
14 A Yes, there was, yes.
15 Q Isn't it true that part of the reason that 16 the post of supervisor of maintenance'for Unit 3 was 17 not filled was that there was a desire to. keep down 18 total personnel costs at the Island?
19 A I have no knowledge of that.
20 Q Let me turn back to when you first cime 21 with the company and were assigned at Unit 3. Do k '
g.
22 you' recall whether there was ever an incident at Unit 4
' 23 involving the rupture of the pressure dice on the
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-i'-) 24 reactor coolant drain tank?
25 A I remember a_ rupture disc. What time frame
-w - c.-- y- -.w- r vv += +- *v --E-h1 e-< -*-
- n - - - - --N -
1 Shovlin 15
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2 or how it happened or the circumstances of how it 3 happened, I don't know, out I know that a rupture disc 4 did rupture on the reactor coolant drain tank, that is
( 5 correct.
6 Q Yes.
7 A Yes.
8 Q What is your best recollection of the event?
l 9 A I am not --
this is not a certainty. I am 10 not sure. The relief valves had to lifh, I would 11 assume, and discharging into the reactor coolant drain g 12 tank, an'd my responsibility was to go in and replace 13 the rupture disc after that.
14 Q Were you present during the event?
15 A No. Actually in the reactor building when 16 it happened?
17 Q No, at the Island and present'in the control 18 room or the auxiliary building and aware of the event 19 when it was taking place.
20 A If it happened during the period of July 21 1973 on,.yes, I was there at Unit 1.
22 Q our records indicate that there was an I .
23 l event that occurred,-I believe, in December of 1973 in
('\- !
- (._) 24 which the rupture disc was blown on the reactor coolant 25 drain tank. Let me show you what we will have marked e- s- -- - +w- t- ,, e. , -r--, w e- -tv --
w
, .. . ._ . . .= -.
l l
1 Shovlin 16
- p).
2 as B&W Exhibit 898, which is a collection of excerpts !
3 from the TMI-1 logs for a period ~ including sometime 4 in December 1973 through, I believe, sometime in June
( 5 1974. There are actually two separate incidents 6 that are included within this one exhibit. The top 7- part of the exhibit relates to the later event in the 8 spring or early summer of '74, and at the back of the 9 -exhibit are the excerpts that relate to the event that t
10 j hurther discussion occurred in late '73 and there is some 11 of them in early '74.
1
- ' 12 A Is this the startup_ log?
V 13 , Q I don't know.
114 (Document consisting of excerpts'from 15 TMI-1 log was marked B&W Exhibit 898 for
+
i
.16 identification, as of this date.)
17 Q Let me-ask you first if you recognize 18 Exhibit 858.
19 A No. It appears to be a startuh log, and 20- I have never from 1973 to the present ever looked at 21 any of their startup logs.
L 22 Q There are entries in here signed by-Mr. ,
23 i Porter and Mr. Hawkins. . Did you know-those gentlemen '
9 _.
\j- 24 ~ back in.1973'and 19747 25' -A .Yes, they were in the startup program.
,, Q. ,You say the startup program.. Do you mean
1 Shovlin 17
/% ,
2 they were employed by GPU Service Corporation?
3 A Yes.
4 Q They did not report to you?
( 5 A They did.not report to me.
6 Q You were in Met Ed's employ at the time?
7 A Yes.
8 Q They kept their own logs? .
9 A That is correct.
10 Q They kept those logs and did not show them 11 to the Met Ed people?
f3 12 A I have no idea.
l 13 Q You never saw them?
l 14 A Yes.
15 Q And you were supervisor of maintenance at 16 Unit 2 and you never saw any of the maintenance logs?
17 A That is correct. -
18 Q And you were superintendent of maintenance 19- for the entire Island, employed by Met Ed t the time?
I 20 A That is correct.
I 21 Q Given that you have not seen this document, 22 I just want to refer you to some of its entries and 23 fsee whether the description of the events there helps n .
() 24 jog your memory at all as to something that you may 25 independently remember , given that you haven't seen e
l 1
Shovlin 18
(~)
U .
. 2 these particular papers before. If you turn first to 3 what I believe is the earlier event, you will need to 4 go back to the fourth page from the back of the 5 exhibit. It is marked in the upper left-hand corner 6 178. Do you see that? ~
7 A Yes.
8 Q You will note that the bottom of that page 9 on 178, about the fourth line up from the bottom, e
10 the date 12/23/73 appears.
11 A yes, 12 Maybe it is 12/13.
Q I can't read it very 13 well, 14 A 12/13.
15 MR. GLASSMAN: You can't tell, Mine looks
' 16 like it is 12/19, but whatever it is, i
17 Q Now, the entry on that page reads, 18
" Relieved I'. Porter. Conducted type C briefing to run 3
19 diesel generator startup test. Completed all test 20 requirements but.the ventilation" --
and it is hard to 21 read what it says there. Something " ventilation." ,
22 There-is a word that is illegible -- "in service j t
23 building machine shop." I am carrying over-onto page 4 -p
\- 24- 179 of the log now. It continues, "Placed 'B' powder 4
25 vessel-in 'out of' service' condition. Inspected RC i
e 1 -T* y g- , 9 me-e7-- e--y- t'-'z-'- --tFf '"'i Nw 7 -"Wf-*-k-'- T-T
1 I
1 Shovlin 19
\/ )
2 drain tank . rupture disc after RC system blow-down when 3 ESAS testing opened electromagnetic relief. No visible 4 damage to rupture disc." The entry continues with C. 5 some other matters that aren't relevant.
6 Do you recall in December of 1973 at Unit 1 4
7 the PORV opening during emergency safeguards systems 8 testing?
9 MR. GLASSMAN: I object. -Are you asking 10 whether this witness was there anb saw something 11 of this sort, or whether he heard about something 12 like this afterwards, or what?
13 MR. WISE: Either heard about it or saw it.
14 I am not limiting my question to whether he was 15 actually there. ,.
16 A No.
17 Now, if you continue on to thd'next page Q --
18 and we have skipped a few pages in the log -- you come 19 to the page that was marked 186 in the log. It is 20 several days later. And if you would go down to the ~ --
21 just under the middle of the page, you will note an 22 entry right after a Mr. Porter's signature. It indicates 23 the date of these entries is December ~21, 1973. Do I Oj
(_/ 24 you see that, about halfway down on the page?
25 A Yes.
,. - ,_ .,,--+__r- . , . . , - - - . - - .--.-,# 4 m- r, . . _ ,
I shovlin 20
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LJ l 2 Q Now, skipping down about four or five lines 3 underneath the date, you will see a line that begins 4 " lost IA" or " lost 1A inverter power" --
5 A Yes.
6 Q --
"and all NNI's. The electromagnetic 7 relief lifted and blow down to RC drain tank. The 8 electromagnetic relief valve blew rupture disc on" --
l' 9 and it is hard to read the next word, it is almost t &
10 illegible. And the final word in the sentence is " shift.
11 Repairs are under way."
gs 12 Do you remember an incident occurring in P )
L/
13 December of '73 which required repair to the reactor 14 coolant drain tank rupture disc following a lift of 15 the pilot operated relief valve? ,
16 MR. GLASSMAN: Is the question whether the i
17 witness recalls a repair specifically due to a 18 rupture of the electromagnetic relief valve, or 19 is the question just whether the witness recalls l
20 some repair to the rupture disc, because you had
- 21. j a couple of things in your question? I am not i f
22 sure what you are asking the witness.
23 l MR. WISE: Let me make it'perhaps simpler.
A
'( / )
24 Q You see here that an event is described, 25 Mr. Shovlin? ! !
_ , _ . - . . , . . - . _. - - . - _ ._ . _ . _ __ .~ . _ _ .
+
1 Shovlin 24 -
O. 2 Let me just ask it this way. After seeing 3 this report of the event, do you have any recollection 4 of this spccific happening?
( 5 A No. ,
6- Q Just to close out the record on this 7- December 1973 event, tLa last page of the ex hibit ,
. 8 which again skips several pages in the log, appears to 9 he for February 7, 1974. It appears at page 236 of
- i 10 the log. And you will note that the top entry there, ,
. I, 11 the fourth line down, it says, " Rupture disc reinstalled i 12 in reactor coolant drain-tank."
l 13 Again, does that help refresh your -
14 . recollection at all as to what happened there?
15 A No.
- IG Q Now, if you would go to the first part of 1
17 the exhibit, these are pages taken from the log for a 18 later period of time. I believe this is in June 4974.
19 Let me begin by asking you to take a look A't the entry I 20 for Friday, June 21, 1974, which appears on the second 21 page. Do you see that?
ki 22 A Yes. ,
I 23 ; Q Just immediately above that entry there is
-() 24 an entry by Mr. 'Gatto . Do you see.that?
i 125 A Y e, s .
,v,- . . , . , , , . . _ , - , , ., .-_..e , , . . -y.,-- ,,~y..,_,,...,,...,,-,_...,,.=,_...,e-m__.,,..e,, y -_,..,,,y_,w.....,,4-- . . . . . . - -
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1- Shovlin 22
. ,,3 4 )
'u d 2 Q Do you know who Mr. Gatto was?
3 A He was a startup engineer.
4 Q And he notes that "there is still steam
( 5 coming from the R.C.D.T.," and then if you go to the 6 entry immediately beneath it for Friday, June 21, 1974, 7 you will note that Mr. Hawkins, or rather, I believe it 8 is Porter, says that he started working on the items 9 required for startup, that he was relieved by Mr. Hawkins 10 and that Met Ed Company working RC-V-1 .and RC drain 11 tank rupture disc. Now, MEC would refer to Met Ed, 12 is that correct?
)
t
(_/
\_
13 .
i A Yes.
1 14 RC-V-1 would be one of the code safeties Q
- 15 at the top of the pressurizer?
i 16 MR. GLASSMAN: Are you asking whether the I.d witness knows something about this particular 18 document or whether he has some general 19 understanding of what that means? He already 20 said he doesn't remember this document.
, 21 Q I am just asking whether in fact at Unit 1
( f 22 the designation RC-V-1, what that valve refers to.
23 Let's just ask it that way. You don't remember?
~s s_) 24 A Right offhand I don't, no.
25 g- Do you recall in or about June of 1374
1 Shovlin 23 h -
2 working on the rupture disc for the reactor coolant l
l 3 drain tank? I don't mean you personally went down 4 there with a wrench and screw driver, but that your
( 5 maintenance dep ar tment was called on to do that.
6 A No.
7 Q You don't recall one way or the other 8 whether you were doing that work?
9 THE WITNESS: Can I amplify that --
10 MR. GLASSMAN: Just answer the question, 11 if you know one way or the other.
12 A The symptoms are not turned over to me.
O 13 There is a lot of maintenance going on that I don't l
14 l support. The construction could have replaced that.
15 MR. GLASSMAN: You should just answer the J
16 question. If you don't know the answer, you 17 should simply say that. -
18 Q Do you recall whether during 1974 there 19 was any consideration given to changing the design or 20 the procedures relating to the reactor coolant drain 21 tank in order to make changes to the rupture dise L
22 less frequent?
23 A No.
(G,) 24 Q' Do you recall whether anything was done to 25 the reactor coolant drain tank in 1974 to increase its
i 1
Shovlin 24 sm 2 capacity to accept heat flow?
3 A There was initiated to change the cooling 4 system te a larger capacity, but that never did
.( 5 materialize.
6 Q What happened to that?
1 7 A It was never required.
8 Q When you say it was initiated, who initiated 9 that request?
10 A I am not sure. It was an e'ngineering -- I
[ 11 am not sure, but I know it was discussed at that time, 12 of increasing the cooler, the reactor. coolant drain '
O 13 tank cooler..
14 Q Ilow did that come to your attention?
15 A I don't know. I have no idea.
16 Q Do you know when that came to your
. 17 attention? -
18 A No, I have no idea.
But I remember the i
I 19 incident.
20 Q When you say " incident," you are talking
. 21 about the fact that this was brought up?
l 22 A I am not sure whether there was a change i 23- modification initiated to install a large c
size
. (~T
{ (_,) 24 capacity drain core or not, but I know that was discussed l
25 and the period of time, I have no recollection.
[ .
i I
--_-_.__._m__m__m.-_..__m -
1 Shovlin 25 v.
2 Q Who was involved in the discussions?
3 A I have no idea.
4 Q Was Mr. Kunder involved in those
( 5 discussions?
6 MR. GLASSMAN: You don't want the witness 7 to guess?
8 MR. WISE: No, I don't want him to guess.
I 9 I am trying to get his knowledge and information.
9
] 10 A I have no ' idea. ',
11 Q You know who Mr. Kunder is, do you not?
12 A Yes.
O 13
- Q He was at Unit 1 in 19737 14 A Yes.
s 15 Q And he was there in 19747 16 A Yes, sir.
i 17 Q What position did he hold then, as you 18 recall it?
19 A He was in operations..
20 Q Do you remember what happened to the 21 request?
I 22 A offhand no, I don't. !
23 , Q You don't know whether it was approved or 1
24 disapproved?
25 A I know it was never installed. That would
1 Shovlin 26 m
2 be my end of it.
3 Q And you don't have any idea-today why it 4 , was not installed?
t e
( 5 A Apparently the need'-- no, I have no idea .
6 Q Do you know whether any changes to 7 procedures were instituted?
4 i 8 A No, I don't.
9 MR. GLASSMAN: Off the record for a moment. I 10 (Discussion off the record.) ,
i 11 (Witness confers with counsel.)
12 Q When did Unit 1 become commercial?
13 A I believe September of 1974.
4 1
14 Q After that time, is it true that any 15 design changes would require your approval?
16 A ,
No.
t 17 Was there a procedure at Unit.1 for Q '
18 instituting requests for design changes?
e4 19 A Yes, there was.
20 Q Could you describe that procedure as you 21 understood it?
(- l t
22 A It was a procedure that anyone could initiate i
23 ; a change modification.
24 Q What would happen to-it?
25 A The maintenance department was the central e
1 l
1 S hovlin 27 2 filing and controlled the document. It would go to l 3 engineering for their review. It is really an 4 engineering document.
( 5 Q As I understand it, if someone wanted to 6 institute an equipment change, they would fill out a
- 7 form called a change modification request form; is that 8 right?
5 9 A That's correct.
10
- Q That form would be forwarded,to your 11 department? '
12 A That's correct.
O 13 Q Would you see each of those forms or did 14 you have somebody else look at them?
15 A I could have seen some and it could have 16 been other supervisors saw them.
17 Q After you or one of the people who worked' 18 for you looked at it, the request would be forwarded 19 to the engineering department?
< 20 A The clerk would then log the request, 21 the document, where it was going, it was going over to I l
! 22 engineering for their review and approval.
23 Q Would,you have anything to say about who I
(~h 24
(,) ,
in engineering reviewed the particular request?
25' A If it was a mechanical, you would indicate
1 Shovlin 28 O) b 2 'a mechanical form; if it was electrical, you would 3 indicate electrical; if it was instrument, you would 4 indicate, so you knew where it went. We had the control
( 5 of the document. We.kn~ew what engineer had it. When 6 anyone would ask a question as to where its whereabouts, 7 the maintenance department was the f'ocal point for that.
8 Q So the decision of where in the engineering 9 department, where that particular requ'est was referred, '
10 belonged to your department? t 11 A To a clerk in my department.
12 .
_ Q Once the engineer completed the form, I
(
13 take it he returned it to the clerk?
14 A It came through the clerk; that's correct.
15 Q What did the clerk.do with it at that point?
16 A It all depends on what the disposition.
17 If the disposition of it had to be'sent -- if it was a 18 major change and it had to be sent to Reading, she 19 would take a cover transmittal sheet and send it to
- 20. Reading with my signature on it.
. It is as simple as 21 that.
22 Q What if it involved a turndown of the i
23 ! request.
l
%j) l 24 A She would log it in as disapproved, and 25 if it had-all the required signatures,.that is the end
I shovlin 29 {
O
'( J.
- 2. of it.
3 Q Did you personally become involved in the 4 review of change requests when they came back from the
( 5 engineers?
t 6 A Not a's a standing rule, no.
7 Q Is it true that you had no input into the 8
decision as to whether the particular change request 9 would be approved or disapproved?
t 10 A only on those that I would initiate, 11 personally initiate, that I felt were --
12 Q Otherwise you were simply a rubber stamp 13 for the engineering department?
- i 14 A I was simply a central file, a controlling 15 file. I had no authority to approve or disapprove a .
16 change modification.
17 Q Did that same procedure carry over when 18 Unit 2 was put into service?
19 A Yes.
20 Q Upon coming to Met Ed in July of 1973, 21 how did you become familiar with the design of the TMI-1 l km.
22 reactor? !
i 23 MR. GLASSMAN: Objection, no foundation 24 that the witness did or did not become familiar 25 with it. I am not sure of the scope of what you l
1 I
1 Shovlin 30 v-2 mean by design of the reactor.
. 3 g Mr. Shovlin, prior to coming to Met Ed, 4 you had never seen a nuclear power station?
( 5 A That's correct.
6 Q And you had never worked for a commercial 7 utility?
'8 A That's correct.
9 Q And in July 1973 you found yourself as a 10 supervisor of maintenance for a nuclear', power station.
11 Did you do anything to familiarize yourself with how that 12 station was constructed or designed, or how it worked?
[
k 13
, A Yes.
14 Q What did you do?
15 A I helped --
first of all, it is no different 16 than a fossil plant except that you have a nuclear as 17 the fuel. You know, steam -- the making of steam and 18 the running of the pumps and the heat exchanges, they 19 are all the same, whether it is fossil or a nuclear 20 system, so there is really no big major differIr.ce 21 except the radiological hazards. '
(- g l 22 Q So you are saying that essentially there !
23 was nothing in particular that you needed to do'in
~/~N
() 24 l order to get familiariced with the nuclear station?
l 25 A Basically that, yes, '
1 Shovlin 31 I
C
~
2 Q During the time.that you were supervisor
=
b i'
3 of maintenance for Unit 1 and then later superintendent 4 for the station but filling the role of supervisor
( 5 for Unit 1, up to the time of the accident in March 6 1979 was it the practice to keep you advised of reactor 7 trips at Unit 17 8 A Yes.
9 Q You would hear about each one when it 10 occurred? '
11 A If I was in the vicinity, yes.
', 12 Q And that would be from 1973 through March 13 19797 14 A Yes.
15 Q Would you normally learn of what events had 8
16 caused the reactor trip?
17 MR. GLASSMAN: Objection. Are you asking 18 whether the witness would obtain all technical 19 details of what had led up to this, or are you 20 asking whether he would receive some reports,
, 21 or what? I mean we are talking about a maintenance k.
22 i supervisor here, so I am not sure where your i 1
23 , question is going or how it is intended. -
(,- ) 24' I MR. WISE: Well, I deeply regret that you 25 are-not sure where my question is going. -I will 1
2, . . . - . _ . . . _ . _ . . __ , , _ . - - ~ . . ~ . , _ .. . . _ _ _ . _ _ . _ _ _ _ -.-- __
m 1
Shovlin. 32 f-t s._
2 stand on it.
3 Q Can you answer the question?
4 THE WITNESS:
3 Would you repeat the question,
( 5 please?
6' (Question read.)
7 A By the initial phone call?
8 Q No, after you learned that there was a 9 trip, would you learn anything more about the trip 10 than just that? !
11 A The purpose of the phone call to me is, 12 number one, there was a problem. I am the maintenance O 13 supervisor, I got to correct it. Also I am concerned 14 about the length of time we are' going to be down.
15 There are other things that I could schedule that we j 16 have identified to do during the period that we are II down. That would be my major concern, the manpower 18 that I would need to support whatever -- correct the l 19 maintenance that had to be performed during that time 20 we were down. I would notify other foremen and 21 . supervisors within the department.
To that extent, yes. l
. km I ;
22 Q Did you consider yourself part of the J
23 management group at the Three Mile Island Nuclear i
.(m 24 Station?
l 25 I A Yes.
9
_[ ._, r ,.yg, ..w,, v -w' r-e w--*w--" - - * ^ * - + 7*-~ ' ' ' - ~ ~ ~ ~ ' ' ~ ~ ' - " ' ' * * " ' ' '~ ' '
t I
1 Shovlin 33 O h LJ 2 Q And did the management group from time to I
3 time meet among themselves to discuss what was going 4 on at the plant?
( 5 A Oh, yes..
6 Q Were there regular meetings?
7 A There were plan-of-the-day meetings 8 Mondays, Wednesdays and Fridays.
j 9- Q Who would attend those?
10 A The station superintendent,',the supervisor i 11 of maintenance, the supervisor of operations, 12 engineering representatives, QA, quality assurance n
\- 13 representatives, health physics supervisors.
14 Q During those meeting which took place 15 three times a week, was there ever discussion of 16 operating events that had occurred at the plant?
17 A They discussed problems, identified problems 18 that had to be, corrected, and my part would require:
19 do we have the parts, do we have approved procedures 20 to do the job.
21 Q That wasn't really my question. I am sure j
(- ,
22 you may have discussed problems. The question'was, 23 ldidyoudiscussoperatingeventsthat had occurred i
l) 24 at the plant during that week?
25 A Not as a normal -- that wasn't really the
1 l
I 1
Shovlin ,34 b
U.
2 purpose of the meetings.
3 Q How did you keep yourself apprised of what 4
4 was going on at the plant?
5 '
A From the plan of the day, told you --
6 identified the plant operation, what power level you are I at, what decay heat loop you are on, the surveillances 9
that were coming up, the survellances that were due.
9 And you as supervisor of maintenance were Q
4 10 not'kept advised of the details of operating events 11 as they occurred at the plant?
12 A No.
13
, Q Do you know what a pilot operated relief 14 valve is?
15 A Yes, I do.
16 Q That is one of the relief valves at the 17 top of the pressurzer? -
18 A That's correct.
19 Q Its purpose is to relieve high pressure?
i 20 MR. GLASSMAN: Are you asking'for the 21 witness's understanding today or.are you asking L
22 l- what understanding he had sometime before the 23 accident?
, - b(_/ - 9
- 4 MR. WISE: It makes no difference. I just 25- i want to establish that's what we are talking j i
1 Shovlin 35
.2 about.
3 Q You knew that its purpose was to relieve
}
4 pressure, you knew.that before the accident?
( 5 A I knew that, yes.
6 Q And you were aware that TMI-1 had a 7 pilot operated relief valve installed on it?
8 A Yes.
i 9 Q If a piece of hardware on the reactor 10 system needed repair or maintenance aftbr the unit 11 went commercial, would that normally come to your 12 attention?
13 A Yes, it would.
! 14 Q Do you recall that in September 1974 the 15 pilot operated relief valve on Unit 1 was to be 16 removed and replaced with a pilot operated relief 17 valve from Unit 27 -
, 18 A I remember -- I don't remember the time 19 frame, but I do remember that it occurred, yes.
20 Q What was the reason for that?
21 A I am not --
I am just taking a guess. '
l 22 MR. GLASSMANs
, We don't want a guess, Mr. .
i 23 Shovlin.
l im I,
) 24 A At this point I don't know the main reason.
25 But I know that happened.
1 Shovlin 36
{v 2 MR. GLASSMAN: Just so the record is 3 clear, obviously the witness, as evident from the 4 beginning of the testimony, is somewhat confused
( 5 about whether he should be answering from his 6 knowledge or recollection or whether he should 7 be offering a guess if he doesn't have personal 8 knowledge, and I think it should be clear that 9 we are not looking for guesses, Mr. Shovlin, l 10 we are just looking for your knowledge or 11 recollection, whatever that may be.
12 Q What'do you recall about the removal of the D
O 13 pilot operated relief valve from Unit 1 and its 14 replacement with the valve from Unit 2?
15 A what I do remember, there were dimensional 16 flange differences in the flange dimension that required
^
17 a spacer, and that is about all I do remember en that.
18 Q I don't understand at all what you just i
19 described, so we will have to go into it in a little 20 bit more detail so I can get an idea of what you are 21 talking about. Are you describing.something about the L
22 Unit 1 valve or about the Unit 2 valve?
23 A I mentioned that at one period of time that
(~ . . . . 24 wa replaced the Unit 1 electromagnetic relief valve 25 with-a valve from Unit 2.
g-
,t- e- .- . -- . ,, .-rw -.w
-.%v v, . , , - c -e. y ee, ,ey- - - ,
d 1 Shovlin 37 2 Q Correct.
3 A And I said I do recall--I don't recall the 4 time. And what I do remember was that there was a
( 5 dimensional flange-to-flange difference.
6 Q What are you talking about now?
7 A Distance.
- 8 Q On what valve?
9 A on the Unit 2 valve. So you are taking 10 off one pressuriser and putting on another, but the 11 P i ping configuration was a little bit different, 12 and.I. don't know whether it was 3/4 of an inch or 3/8 k/ 13 of an inch, so that was the only difference. There was i
14 no problem. It was engineered and looked at.
15 Q Who performed that work?
16 A I am not sure, i s 17 - Q Was it done by somebody from Met Ed?
18 A We had a maintenance contractor on site 19 from 1973 to this day who supported maintenance 20 work activities, and in many instances they were given 21 a lot of the work.
22 Q Who was that contractor?
23 - A In what time frame?
A
(,,) 24 Q 1973 to 1974, 1975.
i 25 A That was Crouse.
, _ . __~. . _ . . . . _ . . . ~ , . . - _ . . , ~ . . , _ , , _ . . . _ , . . _ _ . _ _ , . _ _ . - .
1 Shovlin 38 P)
R-2 Q C-r-o-u-s-e?
! 3 A Right.
4 Q They were the maintenance contractor at
( 5 TMI-17
- 6 A TMI-1 at that particular time, yes.
7 Q How long did they continue as the 8 maintenance contractor? Just give me the best that you 9 can now recall.
10 A '76, '77. .
~
11 Were they replaced by someone at that time?
Q 12 A Catalytic.
13 Did Catalytic continue to be the maintenance Q
14 contractor through the time of the TMI-2 accident?
15- A Yes.
16 Was there a maintenance contractor for Q
17 TMI-27 '
4 18 A one and the same, yes.
- 19 So that Catalytic was the main enance Q
20 contractor for TMI-2 up to the time of the accident?
21 A Yes..
<. I 22 Q Going back to the switch of valves, do you 23 remember whether1there was any differance between the
-Q
(_ j 24- . voltage for the solenoid on Unit 2 as opposed to the 25 voltage for the solenoid on Unit 17
1 Shovlin 39
%/ -
2 A No. -
3 Q Do you have any recollection of any changes that were made in order to equalize the voltage?
~
4
/ .
(. .
5 !A No.
6 ,
g' Do you recall what, if any,. work was done h 7 on the Unit 1 PORV after it was removed?
8 , t 'A Ho.
_. 9 Q Do you have any recollection as to how ys 10 long the Unit 1 PORV remained off that' unit before v- 11 it replaced the Unit 2 PORV?
._.N
~
, 12 A No.
- . 13 Q You do not recall whether there were plans 1'
14 to decontamina:e the Unit 1 PORV and. send it back to 15 the manufacturer for refurbishing?
16 A In that particular time frame, I.know 17 we have done that. We havb sent the code safeties and 18 the PORV to Dresser for repairs.
19 Q Let me just state for you that we have some 20 records that' indicate that the TMI-2 PORV was removed 21 and replaced with a TMI-1 PORV in late September or 1
( ' {
22 early October 1974, and that the TMI-2 PORV was in fact 23 on the Unit 1 pressurizer by October.24th, if not i
/3
- () 24 earlier, of 1974. We also have some records that indi- )
25 cate that the Unit 2 PORV was still on~the Unit 1 r
e i
1 1
1 Shovlin 40 Iv )
2 pressurizer as late as October of 1975., which indicates l 3 that it was there at least a year and perhaps longer.
4 Now, there are'also some records indicating that
( 5 during that time the. valve was never sent back to 6 Dresser.
7 My question is, assuming the facts that 8 I have related to you about the timing are right and 9 can be supported by the various records and-documents 10 that have been produced in this litigatlon, do you 4
'll have any recollection of why the Unit 1 PORV was left 12 sitting in a warehouse for over a year and not sent 13 back to the manufacturer?
14 A No, unless it was a spare.
15 Q My understanding is that there were only 16 two PORV's ever bought for the Three Mile Island 17 Station, the one that came originally with Unit 1 and 18 the one that came originally with Unit 2. Do you have 19 a recollection that at some time a third PORV was 20 purchased?
21 A During the time frame, that particular 22 time frame? !
23 g At any time up until the accident in 24 March 1979, do you remember whether they ever went out 25 and bought another PORV7 y ny
l 1
Shovlin 41 2 A There was some time, if I remember correctly, 3 they did go out and purchase a spara, one spare valve.
4 Q You don't remember when?
( 5 A No.
6 Q Who would have approved that purchase?
7 What was the system for approving a purchase like that 8 within Met Ed?
1' l i,
s 9 A I could have approved it. It could have been l 10 Jack Herbein who approved it. It could' have been the 11 J
station manager or superintendent who approved it.
12 Q I guess what I am asking, Mr. Shovlin, is 13 whose job was it within the organization of Three Mile 14 Island to take care of ordering and warehousing or 15 stocking a spare part such as an extra PORV.
16 A That is my responsibility.
17 Q And you today cannet recall from y'our 18 recollection.when the purchase of an extra valve took 19 place?
20 A 4
I cannot conceive that we used the Unit 2 21 valve and it stopped there. So I apparently took some l
22 type of action to replace that valve, .so whether there l 23 was long lead times on safety valves .
so I am sure I
/~
(N) 24 must have taken some action during some period of time,
- 25 and I signed a purchase ~ requisition for a valve, either
1 Shovlin 42 AJ 2 to get one repaired or -- the time frame I can't re ca ll '.
3 Q Do you remenber that-there did come a time l
4 when the Unit 2 valve was removed from the Unit 1 )
-( 5 pressurizer and returned to Dresser for refurbishing?
6 A The Unit 2 pilot -- yes, I knew'it was 7 removed, but the time frame I don't recall.
8 Q We have records from Dresser Industries 9 indicating that Met Ed removed the Unit 2 valve from
- 10. the Unit 1 pressurizer and returned it'to Dresser to 9
11 be refurbished and returned in a "like new condition" 12 in late December 1975.
l~)
(_/ ,
e 13 1 Who within the organization at Three Mile 3 14 ' Island would have been responsible for arranging to 15 send a piece of equipment for refurbishing or 16 remanufacture?
17 A And this was at Unit 2 before -they went 18 commercial?
19 1
Q This would have occurred in late December 20 1975.
21 A That would have been the construction part
.(
22 of GPU; I would think Sandy Levin or Bill Gunn 's ;
23 responsibility. :
l lf 24 'Q. So once.the PORV was removed from' Unit 1, 25 - it became the responsibility of the service corporation
- ~ . - ..
I shovlin 43
,m-N_ - .
.2 which was handling the startup of Unit 27 3 A Yes.
4 Q Do you know anything about what was done
( 5 to the Unit 2 PORV after it was returned to Dresser?
6 A No.
7 Q Just to-make sure I understand, you today 8 cannot recall why it was the Unit 1 PORV was caken off
- 9 Unit 1 in the first place?
10 A No.
11 Q And you don't know whether any repairs were 12 made to that valve or not befere it was reinstalled c~)
13 on Unit 1 in late '75 or early '767 14 A No.
15 Q Did you normally receive copies of field 16 change requests at Unit.2 during startup?
17 A We received file ccpies of changes made, 18 yes. Maybe not in all instances, but we did have a 19 file.
-20 Q Do you recall whether in early 1977 pursuant 21 to field change request.188 modifications were made to thej 22 Unit 2 PORV?
23 A No, I don't recall that.
i
~ ("'N -
() 24 Q Do you recall that during that time frame 25 there was consideration.of possible corrosion problems
1 shovlin 44
/~}
4 k_/
2 with the valve?
3 A No.
4 Q Do you remember whether there was
( 5 consideration of a need for a new bushing type in order 6 to improve the freedom of motion in~the lever pin in 7 the valve?
4 8 A What was the time frame in that?
9 Q This would be early 1977.
19 A No, but I heard that after hhe accident.
11 There was a modification recommended"of spares that 12 were going down and that was on the arm, the bushing
\" 13 arm, I think was to increase the size-of the bushing.
14 Q You say after the accident you learned 15 there was a modification?
16 A I heard of that particular modification 17 that you just mentioned sometime after the accident.
I 18 Q When you say you heard of it after the 19 accident, what I am trying to ascertain is what you 20 heard was that-it had been a modification that had been 21 requested before the accident, or are you talking about.
22 a-requested change after the accident?
23 - A I heard about the change to the PORV after
) 24 the-accident, that particular change on the arm.
25 -Q_ All I am trying.to establish is that that d
- U - -
d ,
9-1 Shovlin 45 O
V 2 change that you are talking about was something that 3 was done before the accident, or is it something that 4 was done after?
( 5 A I am not.sure. There are changes that are 6 in effect right now that you just identified, and whether 7 it was done to one of the P'ORV's prior to the accident O
or done to the PORV's after the accident, I am not sure.
9 Q So you are not saying that after the accident 10 you became aware of field change reques't 188 which was 11 signed on January 19, 1977 and the modification that 12
, was requested there, which I have just described,'you 13 did not become aware of that specific request that had I4 been made on January 19, 1977?
15 A I don't recall that.
t 16 Q Do you have any knowledge as to whether 17 Met Ed ever completed that field change request?
18 MR. GLASSKAN: Are you talking about a 19 particular request of that date?
20 Q Whether Met Ed ever made modifications of
- 21 the type that I just described.
- k.
22 A l I believe.not for all of them. I am not i 23 sure. I believe that the change has been at least.
~
. () 24 made on one. l
[ 25 Q' You mean since the' accident?
p ae y, . . - - , ---m,, - 4 .-,e, , , . --p =-
l l
l l
1 Shovlin 46
, ~S f +
v.
. 2 A Since the accident. I don't have any 3 knowledge before. I don't recall.
4 Q You don't recall whether the field change
( 5 request that was put.in before the accident was ever 6 acted upon or not?
7 A I am not sure of that.
8 Q Would you normally receive copies of GPU 9 startup problem reports for Unit 27 10 A on occasion, yes. If you came and asked 11 me, did I have GPU number such-and-such, I couldn't ,
-s. 12 guarantee you that, but we did get information copies.
%/
13 Q Was it your praStice to review those?
14 A on occasion either I or a designated i
15 supervisor or lead foreman.
16 Q What was the purpose for reviewing them?
17 A To -- many times there were action items 18 1 that would be identified for maintenance to correct, i' 19 We would be the action party; that would be the only
~
20 purpose.
21 Q Do you know a Mr. Robert Saint Pierre?-
1 22 A Yes. ;
23 Q Who is he?
q
, ) 24 A He was in the Q -- quality assurance 25 organization. ^
-4 bem, s T,',-
g'% s% p *t
, _ _ _ . , , , , ,, ,n . .- -- et n -~ \ - ~ - A'
i f
s 1 Shovlin 47 p
J 2 Q Of Met Ed or GPU Service?
1 3
A I am not sure.
t
, Y;
4 Q How about Mr. W. W. Cotter?
1 (;,s .., 5 A Yes, I knew him. He was also QC, quality 6 control.
. s r
'7 Q Who did he work for in 1978, late '777 L
A
, ,N, g' A Who did he report to?
4 1
V '
Q No, was he working for Met Ed or was he 9
10 working for GPU Service Corporation?
- 11 A I am not sure.
, 12 Q Let me show you what was previously marked
(
~
13 as B&W Exhibit 656. It is a copy of a letter dated .
14 July 30, 1975, from Mr. Rogers of B&W, addressed to 1
15 Mr. Herbein of Metropolitan Edison Company, and it has 16 some handwritten notes at the top of the page that 17 appear to have been written by Mr. Herbein. I believe 18 he or someone has identified that as his handwriting.
), 19 You will note that the handwritten memo at the top 4
20 indicates it is from JGE, which are Mr'. Herbein's l
og initials, to W. W. Cotter. It'is rather hard to read, C
22 but-I think you can make it out, and the subject.is the !-
I 23 ;
RC-V2 valve lever preventive maintenance procedures. The
)
v- 24 RC-V2 would refer to the PORV, as you understood it, 25 . would it not?
.3,
, _ - . =_2 .
___--_-1-__-_
1 Shovlin 48
,) .
l
./ -
2 A I believe that is the --
3 Q Designation for the pilot operated relief 4 valve?
( 5 A Yes.
6 . Q What Mr. Herbein's note says is: "1. See 7 that procedure is prepared; 2. Get with DMS and JRF, 8 decide who should do procedure and what frequency or 9 occasion 3. Decide how operators or maintenance will 10 know to run preventive maintenance proc'edure when it 11 is due or occasion arises; and 4. Determine how we 12 will know it was done and whether the check was CE) 13 satisfactory or unsatisfactory and what comments were."
14 That is the end of his note. -
15 Your initials are DMS?
16 A Yes.
17 Q JRF would be Mr. Finfrock? -
18 A No, that was my counterpart, Jim Floyd.
10 Q You say he was your counterpart?
20 A well, he was supervisor of operations.
21 ! Q For which unit?
i
(_ !!
,t 22 A Unit 1.
l
~
23 Q Now, did you ever see a copy of Exhibit 656, l -
,--),
( .
24 Mr. Rogers' letter to Mr. Herbein?
25 A I can't be certain. ;
1 Shovlin 49 fs 2 Q Mr. Cotter I believe you identified as 3 somebody in the quality assurance?
4 A Yes.
( 5 Q And he worked for Met Ed, didnt he?
6 A I believe so.
7 Q Did you ever have a discussion with Mr.
8 Cotter concerning the subject of this letter?
9 A I don't recall.
10 Q. The subject of this letter krom Mr. Rogers 11 to Mr. Herbein is " Preventive Maintenance Suggestions 12 for the RC-RV2 Pressurizer Electromatic-Relief Valve."
O 13 You don't remember whether you ever discussed that with 14 Mr. Cotter?
15 A I have no recollection of that.
16 Q Do you recall discussing it with Mr. Floyd?
17 A No. -
18 Q Do you recall setting up a procedure to do 19 preventive maintenance on this valve?
20 A No.
1 21 Q Did you ever become aware of the events '
22 that Mr. Rogers described for Mr. Herbein in which 23 ; corrosion products caused the pilot operated relief s
k_)- 24 valve operator lever arm to remain in the open position 25 after actuation? i
,. . _ . _ , , , ,,_--w,. . m. ,.y - -
,. -r,, , , , , , - - . .
1 Shovlin 50
^
(~)N
~-
2 A No. -
3 Q Suggestions made by Mr. Rogers in his 4 letter to Mr. Herbein are as follows: "B&W therefore
( 5 suggests that RC-RV2- (pressurizer electromatic relief 6 '
valve) be inspected periodically for corrosion products 7 and for freedom of movement with respect to the 8 lever pin and lever hinge noting clearances with the 9 solenoid bracket."
10 Did anybody ever advise you of that 11 recommendation by B&W7
- 12 A g-'S I am not sure.
U 13 Q You have no recollection of it?
I4 A I don't recall that. It could even be 15 in the procedures. It could have been a procedure 16 change, but I don't recall.
17 Q The letter concludes as f ollow's : "B&W 18 also quggests that the preventive maintenance program 19 on this valve include the above provision with periodic 20 cleanup as necessary."
f l
21 Did anybody ever advise you that B&W had on i made that recommendation?
23 ' I A They could have, but I don't recall that. '
~m o
i
)
'N_/ 24
-Q Do.you remember anybody making a 25 recommendation to you-to that effect?
L_
1 Shovlin 51 2
A I don't recall that.
3 Q Were you ever advised that during a 4
startup test on Unit 2 in August 1977 the pilot
( 5 operated relief valve failed in the open position?
O A No.
7 Q You do not recall seeing a copy of GPU startup problem report 5073 for Unit 2 which was 9
written on August 28, 1977 concerning the testing of 10 that valve?
11 A No.
1 Q Did you ever see a startup problem report 13 '
, that was written on October 5, 1977,,I believe it was 14 GPU startup problem report 5417 for Unit 2, concerning 15 {
leakage past the pilot operated relief valve? l 16 A No.
17 Q Do you recall that following t' hat test a 18 work request was initiated to disassemble, inspect and ..
test the valve?
20 g yo, l
21 Q Do you know a Mr. Carter of Dresser Industries? !
. A No. 4 C
'd 24 i
Q Did you ever become aware that in October 95
~
1977.Mr. Carter of Dresser Industries came to TMI-2 4 - .. ..i . . . . . . . . . . . - .
1 Shovlin 52
~
/% .
(_. .
. 2 and performed a test of the Unit 2 valve, disassembled 3 it and inspected it?
4 A He could have. Dresser have done tests
( 5 on valves periodically. Their representatives were 6 there on Unit 1 and 2. .
7 Q When a representative of Dresser came to the 8 Island to work on one of the valves, would someone 9 from the ma'intenance department normally accompany him?
10 A We would initiate the reque'st and in many 11 instances the construction maintenance support would be 12 given that job.
O 13 Q And you don't have any personal recollection 14 today of the events that I have described in the fall 15 of 19777 16 A As far as valves leaking or when they 17 leaked or problems, no, but I do know that we have had 18 Dresser representatives, whether.it was Mr. Carter or 19 whoever. At any time we tested a valve or opened up 20 a valve, we had them on site.
21 Q But it did not come to your attention in 22 ,
the fall.of 1977 that there was any particular problem h
23 l; with respect to the pilot operated relief valve? I
(,)
,, 24 A I don't recall that.
25 Q Are you familiar with administrative
i l
1 Shovlin 53
/N _
I 2
procedure 1021 that was in existence at Three Mile 3 Island?
4 A Yes.
( 5 I Q What did-that procedure concern?
6 A Change modifications.
4 7
Q' Was it a requirement that when a change O
modification was made, that it be done in accordance i 9
with administrative procedure 10217 10 A 1021 identified the flow and approval 11 processes. It did not go into details on how to do --
12 yS effect the repair functions cn changes being made.
U
- 13 Q I guess what I mean is that'if someone 14 was going to make a change or modification, was it your 15 understanding that in getting that change.or modification 10 approved, they were to follow the processes set out in
. 17 ^
administrative procedure 10217 18 A Yes, sir.
I Q Was that true from the time that Met Ed 20 had or gained a license to operate Unit 27 l 21 A Repeat that again.
9o
~~ !
Q Let me go back. Unit 2 I believe got its 93
- operating license sometime in February 1978; is that 1
.(~N-C 24 right?
05 A I am not sure. '
f
d 1~
m Shovlin 54
\_ -
2 Q You don't know when they got a license?
3 A It was in the fall or around --
4 Do you know that Unit 2 had a license Q
5 before they loaded fuel?
6 A Yes.
7 And you know that the unit first went Q
8 critical at the end of March 1978?
9 A Yes.
i a
10 Q And you know that they had an operating 11 license by that time too?
12 s A Yes.
-w 13 Q Once Met Ed had an operating licen'se for 14 the unit and the unit went critical, that procedure 15 1021 was in effect and applicable?
16 A I am not sure whether it was commercial 17 date or it's when they got their final license to go 18 to power escalation.
19 Q ,You don't know when that procedure went 20 into effect?
21 A I am not sure whether it was at commercial ',
22 on Unit 2 when it was required-to be in effect or when ,
i 23 '
they got their license to go up to the power escalation.
[D s_/' 24 j Q You don't know whether administrative
<~
25 procedure 1021 was in effect as of March '78 or not?
1 Shovlin
^
55
, 2 A On Unit 27 3 Q Yes.
4' A No.
~
5 Q Are you aware that an event occurred on 6 March 29, 1978 at Unit 2 in which the pilot operated 7 relief valve remained open for a period of some four 8 minutes as a consequence of an electrical failure that 9 had occurred in the plant?
t 10 MR. GLASSMAN: Are you asking the witness 11 bether he is aware of that now or whether he 12 was aware of it at some prior time?
13 Q I: am asking if you are aware of it now.
14 A Repeat the cuestion.
i 15 Q Are you today aware that an event took 16 place on March 29, 1978 at Unit 2 in which the pilot 17 operated relief valve remained open for a p~eriod of 18 some four minutes following an electrical allure?-
19 A' Then, I don't recall, but I have discussed 20 it --
21 MR. GLASSMAN: I am assuming you are 22 excluding possible discussions with counsel.
23 'Q- Do you know anything about that event other. i
.(ew ) f s/.
24 than what any of your lawyers have told you?
I 25 A No.
l' Shovlin 56 rs 2 Q You don't recall whether you were made 3 aware at the time that there had been a reactor trip 4 in connection with that event?
( 5 A No. I could have been advised of the 6 reactor trip and for what re,asons, but I don't recall 7 that particular instance.
8 Q Do you know whether any change modifications 9 were instituted as a result of the incident?
10 A No, I have no recollection of that.
11 Q Did you become aware at any time in late
. 12 March or early April of 1978 that an indicator light O. 13 was to be installed in the Unit 2 control room to show 14 demand indication to the pilot operated relief valve 15 solenoid?
16 A No.
17 Q Did you become aware that that had been i
18 done at any time up to the March 1979 incident?
19 A No.
20 Q You became aware, did you not, of an event
/ 21 that occurred at Unit 2 on April 23, 1978 involving
(.
i l 22 an overcooling transient? ;
23 MR. GLASSMAN: Are you asking whether the
/~
l' k_)T 24' witness was aware.of that before the accident?
25 MR. WISE: No, whether he ever became. aware 8 v- wg. y , e. + .._m, _ . - - 9 y e -.w- .p y. % p 4 -v.p ,,,.i.-- -,-q
e 1
Shovlin 57
. 2 that that event took place.
3 A No.
4 Q You don't know about that?
( 5 A Unless you give me some more information 6 about it.
7 Q Why don't we show you the Met Ed report.
8 It is a B&W exhibit. ,
9 (Recess taken.)
10 Q Let me show you what has prkviously b'een 11 marked as B&W Exhibit 79. You will see that B&W Exhibit 12
-s 79 is a report prepared by Met Ed on a reactor trip in 13 an emergency safeguards incident that occurred on 14 April 23, 1978. There is a description of event t.
15 sequence of events analysis. There is plenty of 16 information about it there.
17 Does seeing that exhibit help' refresh your 4
18 recollection as to whether in April of 1978 you became 19 aware of the event-that is described in the report?
~
20 A No.
21 Q And you don't remember doing anything in 22 connection with that event?
g l
23 A No. .
24 Q Do you remember the main steam relief 25 valves being stuck open in that event?
l .-
i
)
i Shovlin 58
\_ .
2 A In Unit 27 '
3 Q Yes.
4 A I remember a main steam relief valve problem.
( 5 I don't know whether.at that particular time there was 6 an expansion joint ruptured because of a valve that 7 stayed open, I believe, and I don't know if you are 8 talking about one and the same instance.
I 9 Q Well, we have had a fair amount of 10 testimony about this April 23, 1978 inckdent. Just 11 to describe it for you, as I understand it there was a g- 12 problem on the secondary side.
, At some point during V
13 the event the main steam relief valves stuck in the 14 open position, caused an overcooling of the primary 15 system, a loss of reactor coolant system pressure to the 16 emergency safeguards actuation point and the reactor 17 tripped. Now, given that description, do'you remember 18 any of that?
19 A No, I don't recall that particular situation 20 that caused the relief valves to lift,'but I do 21 remember very vividly the main steam relief valves.
l 22 Now you are talking about --
3 t
23 Q Yes. '
.f~
'(s 24. A -- lifting and blew the cowling from over 25 the discharge piping, causing the cowling to fall --
l
./ -- .. - _ - , _- _
~ .
4
\
l 1
Shovlin 59
. p .
- M '
2 several pieces of cowling to fall close to the 3 maintenance complex, so I remember that. But I don't 4 .know what -- this is an operational report which I would
^
5 get for information only if I -- or if there was an i 4
'6 action item accompanied as a result of this report, 1
7 they would write up a job ticket for me to take 8
corrective action if it was after the commercial 9 operation. Before that they operated on very different 7-
~
10 procedures. They operated on the startup and test 11 ~ procedures. They had their own type of request and 12 they could have had a problem identified and the 13 problem corrected without me even being part of it.
I 14 Q Do~you remember being part of any of the 15 discussions concerning this April'1978 event?
16 A No.
17 Q Do you recall whether you were ever given I8 specific assignments to do in connection with the 19 investigation of the event?
20- A No.
j 21 Q Do you recall'there b'eing any problems that j 22 were identified to you as a result of the event that 23 tyou were supposed to work.on and get resolve,d?
-Y '
24 A No. ,
25 . g- - Do you remember hearing anything about how
['
.j l
l 1
l 1 Shovlin 60 r~n 2 the operators had responded during the event?
3 A No.
4 Q Do you remember hearing anything about any
( 5 problems that the control room operators had with the 6 alarm systems during.the event?
7 A No.
8 Q Were you asked to escalate any of the 9 programs that you had ongoing in maintenance as a result 10 of the event?
11 A I don't recall.
12 Do you recall something called the alarm g Q f
-C /
~
13 window correction program?
! 14 A No.
15 Q Do you know what that is or was?
16 MR. GLASSMAN: Do you want to know what the 17 alarm window is or the correction program?
18 A No.
19 Q You never heard of that? ,
20 A I know where the alarms over the console 21 are. I understand alarms.
(. 1 I 22 Q But you weren't aware of any specific 3 f
- 23 program that was in progress in April of 1978 called O
k._) . 24 the alarm window correction program?
25- A No.
, l
, ,,.-r.
1 Shovlin 61
-g 2 Q You never heard of that?
3 A No.
4 Q It would come as a su rprise to you if that
( 5 was occurring?
6 A Right now, engineering probably would have 7 been apprised of that problem or taken corrective 8 action and maybe the supervisor of maintenance on Unit 2 9 had some knowledge of it. I personally have never 10 heard of that before. .
11 Q Did you ever hear that during the April 12 1978 event the operators were disturbed or were confused O 13 by the number of alarms that they received?
14 A Not at that time. I heard that after the 15 accident.
16 Q After the March 1979 accident? l 17 A Right. -
18 Q would you take a look at page 17 of Exhibit 19 79, which is the Met Ed report on the April 23, 1978 20 transient. That occurs in a section on recommendations 21 and action items.- If you would look.under the section 22 that is headed "Other" you will see three items. The f 23 second item reads as follows: " Escalate the alarm (3
l
,/ 24 window-correction program in priority. This will 25 eliminate an excessive number of lighted panel alarms
1 Shovlin 62
- 0; .
! 2 at the baseline condition and give the operator 3 a better chance to focus on what to respond to."
l 4 The person who is assigned that responsibility is 5 listed as "Shovlin . ongoing."
6 Do you recall being given a copy of this 7 report and being shown this specific recommendation J-8 that you were to carry out?
, 9 A No.
- 10 Q Do you recall that somebody told you to l
j 11 1 carry out this recommendation?
g-- 12 A I am sure that I was given an action item V
13 under my name, Shovlin, and I am sure that it was sent 4
t 14 down to Unit 2 to Sieglitz to take corrective ac tion.
15 I don't recall this today, whether it was ever completed 16 or done.
! 17 Q And you don't know what happened to it at 18 all?
19 A No.
' 20 Q Do you have any knowledge as'to what kinds
'{
21 of changes or modifications were made in order to give j
[ 22 the operators better indication of the position of .
23 l the main steam relief valves following the April 1978 Ip j ,
' ( ,/ -24 event?
i
. 25 A No.
M -T8- y ---E- M *w ~ -- - y- y 4 v -M mW e- *y,-t m-9 ev y * ~
l 1 shovlin 63
) -
- 2 Q Did you ever learn that an audible alarm
} 3 was installed for those main steam relief valves as 4 a result of the incident?
5 A No.
6 Q You don't know that even -as of today?
7 A As of right now, I don't.
8 Q Do you remember whether there was in fact 9 I any problem' brought to your attention during early 1978 10 concerning the number of alarm windows bhat were 11 constantly in alert?
,- 12 A No.
13 Q You don't remember one way or the other?
14 A On Unit 27 15 Q On Unit 2.
1 16 A No.
17 Q Did it ever come to your attention during 18 the fall of 1978 that the pilot operated relief valve 19 was tested and remained shut at a time that the 20 indicator light in the control room showed that it was 21 open?
l 22 A No.
I ii ~
23 l Q Let me show you what has previously been '
1 i
p)-
(_ 24 marked as B&W. Exhibit 767. This exhibit has been 1
25 previously identified and I believe we had some .
l
l l
l l
1 Shovlin 64 r~%
q) 2 testimony this week from Mr. Noll of the Met Ed j 3 generation engineering department staff about it. I 4 believe that the task assignment form, which is the
( 5 first substantive page in the exhibit, would be something 1 6 that you would not have seen; is that right?
7- A That is true.
8 But following that there is a cover Q
J 9 memorandum dated January 30, 1979, addressed to Messrs.
j 10 KlingamanandTrofferconcerningchange) modification i
11 No. 2-0298. The cover memorandum is signed by you;
~%,
12 is that right? -
(d 13 MR. GLASSMAN: Are you asking whether that 14 is his signature or whether he recalls signing it?
15- MR. WISE: What possible difference would 16 that make? Why make an objection for that?
17 MR. GLASSMAN:
~
There may be a reason for 18 that.
19 Is that signed by you?
Q 20 A First of all, this is a Xerox signature. -
1 21 The original was-Xeroxed-in a thousand of these forms.
4 22 I never see hardly any of these ever. They came from our :
i 23 plant-staff. If you look at the evaluation, the 3 {
'p
! k/ 24 process that it goes through, and it was deemed that it 25 had to go to Reading, so it comes through to our clerk a ,, --
r -- . - ,
1 Shovlin 65
/m -
2 who puts this cover sheet on it, puts a control in .
3 the log sheet that it went to Reading, put that number 4 in the change mod; that is basically what it is for.
5 So there is no review process for me or no approvals.
6 I have no --
7 Q So what you are saying is that basically 8 there is a distinct possibility that you never even 9 saw these document's?
10 A Oh, yes, definitely. ',
11 Q And the function of having it go through l
_ 12 your office was solely as a file --
(-) 13 A Control mechanism.
14 Q Now, would you take a look at the form that 15 is attached to that, the major / minor change / modification 16 request form. Are you familiar with that form?
17 A Yes. -
i i 18 Q Who designed it?
i *
~
19 MR. GLASSMAN: Who designed the form?
20 MR. WISE: Yes.
21 Q Do you know where it came from?
r
~ 22 MR. GLASSMAN: Are you talking about a_
l f
23 i particular form as filled out or the format? !
, gg !
l
- (_) 24 MR. WISE
- The format.
- 25 Q There is a form here with spaces and it is L.
I-.
u .. . _ _ - _ --------------- - - - - - - - _ -
1 Shovlin 66 V.
2 all printed up and so on. Who put this together?
3 A I w uld think engineering had a big input 4 into the form. It is part of our -- and it became 5 part of our maintenance procedure AP 1021, 6 Q But your recollection is, even though the 7 maintenance department was responsible for controlling 8 the paper work on this, that this form was probably '
9 designed by the engineering department?
10 ,
A Yes, definitely. It is an engineering form.
I i
11 Q Who is responsible for filling out this form? i 12 A If you eee the top part of it there, it 13 was a change that was initiated by the supervisor of 14 maintenance.
15 Q That is Mr. Sieglitz's signature?
16 A That's correct. Now, that could have been 17 anybody's in the plant. It could have been an operator 18 or operations or other engineers could have submitted 19 a similar form for a similar problem. This particular 20 one the supervisor of maintenance initiated.
21 Q If you take a look at the printed form, it
{
22 has various blanks and spaces; most of those are !
23 numbered. At the. top there is a place to fill in the '
/7 - !
-(j 24 unit number and then there are various spaces over at 25 the right-hand side of the top block, which we will come L _ .
1 Shovlin 67
. (~\,
%)
2 back to in a minute, and beneath that there is a 3 question number 1 which says the system; question 4 number 2 identities the components; question number 3
( 5 is to describe the request; question number 4 is the 6 reason for the request; question number 5 is a blank 7 and it says " supervisor of maintenance" and thera is 8
a blank there and then a date.
9 A Right.
10 Q And then there is a solid line drawn across 11 beneath that and underneath that information it says 12
" cognizant engineer assigned."
a 13 Now, my question really is,-why was there 14 a blank specifically printed in on this form foe 15 supervisor of maintenance if these forms could be 16 originated by anyone?
17 A Well,'I am not sure -- yes, Di'ck Sieglitz 18 did sign thic as the supervis'or of maintenance, which 19
'he rightly saw. Ho is the one who indicated whether 20 going to mechanical or engineering, electrical
.21 engineering; he makes that decision.
22 Q That - is not the question I am asking. I ;
i 23 understood you earlier to say that these forms could be d 24 filled out and written by anybody.
25 A That's correct, and I am not sure whether
. . - , - , - - - . , _ _ . . . ~ , . - - . - . ._ _ . - _ _
m
)
l l
(Y \
!. i 1 Shovlin 68 2 Sieglitz could have originated this particular document. l 3 That is exact 1'y what I am telling you. I am not sure i 4 who originated this particular document. It doesn't
( '5 ' have a name to it, assigned to it, but Sieglitz' 6~ as the supervisor of maintenance has acknowledged the 7 problem, whoever submitted it, and I am not sure whether 8 Sieglitz submitted it or not and has indicated that it 9 is going to go to the next section, cognizant engineur,
} 10 and that is the end of his commitment. (
11 Q Do I understand you to be saying that the 12 form could be filled out through question ~4 by anybody?
! 13 A Right, by anyone, that's correct.
- 14 Q And then the procedure was that after they 13 had completed down to question 4, it had to be submitted I- l
[ 16 to Mr. Sieglitz as supervisor of maintenance for his i 17 signature? -
l 18 A Yes, to see if this was really valid. We i
19 get changes that are submitted that there.Are no changes.
.20 It is not even required to'have this form. It is a ,
1
~
21 replacement in kind, it is'a repair in kind. I L (_
oo Q But'with respect to this particular repair
-f l~ ' o3 - .or replacement or modification, or whatever'you want l-
- 3 p).-
- 24 to call it,.apparently the form was required to be j' 25 filled out? l
-,.r - _ _ , - - . - - . . . - , . . . -y.-, , , . , , - - , .
l 1
Shovlin 69 h
[d
~
\
2 A Someone filled out the form, yes.
3 Q Someone filled it out and we don't know who?
l 4 A It could have been an engineer. I am looking 5 at the -- the description is printed and it doesn't 6
. look like Sieglitz's printing. I am looking at h'i s I signature.
8 Q Well, we are not handwriting experts, but 9 in any event, what you are saying is that the normal 10 practice at TMI-2 was somebodycouldfiblout one of i
11 '
these forms down through question 47
'"g I2 A Correct.
13 Q And then th3 practice would-be that it 14 would be submitted to Mr. Sieglit for his revi3w?
15 A That's correct.
16 Q And we do see Mr. Sieglitz's signature on 17 this particular form?
18 A Correct.
19 Q And you recognize his handwriting?
20 A correct.
21 Q And he has dated that December 23, 19787 22 A Correct.
23 Q Immediately beneath that question 6, it (a
d.
24 t
says " cognizant engineer assigned," and somebody has i 25 written'in the name E. R. Krealling. I can't read that.
l l
- 1. shovlin 70 U(~\
2 Do you know who that is?
3 A Yes, he is an electrical engineer.
4 Q How is that spelled? '
( 5 A Krealling.
6 Q K-r-e-a-l-1-i-n-g?
7 A That is what it looks like.
8 Q He is an engineer who worked at TMI7 9 A TMI Unit 2 at that particular time. ,
10 Q Is it your understanding of.the practice 11 that once the form was submitted to Mr. Sieglitz, f_ 12 it would be he who would decide who the cognizant V)o
(
13 engineer would be?
14 A It would be the discipline. It would go 15 to Mr. Bensel, who in this particular case was the 16 lead electrical engineer, and he assigned a junior 17 engineer who -- apparently Ed R. Krealling was given 18 the assignment.
19 Q But that would be something that would be 20 left for the engineering department to decide upon?
21 A That would be their responsibility, that's 22 correct.
i 23 Q So Mr. Sieglitz's participation in this
- q ,e 24 form would be simply to receive it from whoever filled 25 .it out to item 4, sign it, and send it to Mr. Bensel
- .-.---,..-,e -
1 1
Shovlin 71 O
V 2
or whoever in engineering he thought was the appropriate
- 3 person?
4 A That's correct.
5 g would Mr. Sieglitz keep you advised of 6
change modifi. cation requests that came through?
7 A No.
8 Q Would you ever see them?
9 A No, there could be hundreds -- unless there 10 was one I initiated or was really of a ignature that --
11 yes, I would be apprised of that, but there is hundreds 12 of these that go through and I am not sure if you.would b(T 13 see Mr. Sieglith's signature there every time. It 14 could be the supervisor of mechanical or electrical 15 or their authorized signature authority. .
.16 Q Do you know what purpose was served by 17 i having the engineers go through the maintenance 18 department in order to have these things signed?
19 A Simply we are the controlling function, the 20 controll of all the documents.
21
- Q ':i But you are saying it is only a filing 22 function?
23 A That is basically -- and also what it does O
V 24 j
is after this goes through, it might prompt as an 25 approved procedure or modification and we are asked
1 Shovlin 72 m
2 to make the change. Then that is when we come into 3 play. It could leave here, the plant engineers could 4
forward it on to Reading, as this one apparently was, 5 and it came back to us with a disapproval, We didn't 6 do anything. File it away. I don't have any action 7 item.
8 Q So you don't become at all involved in 9 whether or not the particular request is a good idea 10 or bad idea?
11 A only when I initiate it aad I push the fg- 12 change.
13 Q In looking at this particular change 14 modification request, do you have any recollection of 15 being aware of this one at or about the time it was 16 submitted?
17 A No.
18 Q Before it was shown to you by counsel 19 in preparation for this deposition, had you seen this 20 particular form before that, that you can recall?
21 A Form?
22 Q I mean this form change modification request.
23 A No.
'(m., _) . 24-
,~ lQ Your understanding of the practice was that 25 after something like this got assigned to or sent to
1 Shovlin 73 O 2 Mr. Bensel and he assigned an engineer, that it would 3 be reviewed, and then I gather eventually it would 4
4 reach the unit superintendent's level. Do you see
(
l 5 where Mr. Logan has signed down on item 107
- 6 A well, he signed in conc'.trrence with the 7 safety evaluation,'it appears.
8 g well, let me see if I understand the 9 practice. Mr. Sieglitz got the form, logged it in 10 and sent it out to Mr. Bensel or whoeveh the lead 11 engineer was who was involved for the discipline involved; 12 right?
O 13 A Yes.
r' i
14 Q And the engineering department would do 15 whatever they do regarding the merits of the change 16 request?
).
17 A That'sexactly'rihht. ,
18 Q when they got all through with that is
(
19 it correct that the practice was that they were to .
20 submit the form back to your departm int?
'/,
7 e 21
.I i~
A
( First of'all, it sont chrough the station I
}
22 unit superintendent, because he had to review their 123 safety evaluation. '
' 24 -. Q In other words, it went from the engineering 25 ~ (.
- department to the unit superintendent next?
w 4 M.
e '
. . ~ .
f 1 Shovlin ,-- 74
. o r3
( '
-%J- -
2 A Right.
3 Q And he could either approve it or disapprove 4 it, I take it? !
n
( 5 A On here,.no --
what he did, he reviewed 6 -t he safety evaluation and he had two options.
7 Option A --
he reviewed the change modification and it 8 does not constitute a system or component as described 9 in the FSAR. He is there concurring with the engineer's 10 evaluation up in item No. 7. He also signed it and 11 forwarded it on to manager generation of engineering and
.gss 12 manager of QA for approval. 'A t that time --
13 Q I guess I am now totally confused. Let's F
14 back up.
15 Somebody out there in the plant -- we don't 16 know who -- thought this particular change,mo,dification 17 was a good idea; right?
^
,4 18 MR. GLASSMAN: Well, are you asking'this 19 witness to speculate about someohe else he doesn't 20 know about?
(L' 21 MR. WISE: Somebody thought it was worthwhile, l
22 to' write this up. tie don't need to speculate 23 about that. Somebody did it.
1 f~)%.
(. 24 Q Now, at'some point the request is sent to 25 Mr. Sieglitz, he signs it but doesn't review-the merits I
i
l
. v t
1 shovlin ?5 2 of the request. We have established that; is that 3 correct?
4 A He establishes whether it is a change or
. (~ 5 it is not a change.
6 Q He established -- apparently from this
! 7 report he established it was a change, he sent it on i' 8 to the engineering department.
9{ A That's correct.
10 Q A cognizant engineer was assigned, he 11 did whatever review he did. Was it your understanding 12 that the cognizant engineer would review the merits O; 13 of.the proposal? -
14 A Yes.
15 Q And he decided whether it was,a good idea 16 or bad idea?
17 A Yes.
18- Q Where on this form would it indicate his 19 .particular action on the request?-
20 A Do you see the signature of the evaluation 21 prepared on the next page?
r 22- Q Yes, right. 4 23 A The lead engineer was R.'W. Bensel, so by i s j y) 24 virtue of his signature,'he concurred with=the contents l 25 'of the request, the1 nature of this request, and he
1 Shov11n 76 f"~)s 2 concurred that it did not constitute a change to a 3 system or component as described in the FSAR.
4 Q I guess we are kind of talking about two 5 things here. One thing is a set of questions that
. 6 appear on the first page of the form, particularly 7 numbers 7 through 10 on the form, that appear to ask 8 certain specific questions about whether there are 9 unreviewec safety questions or changes to the.FSAR and 10 so on that may be posed as a result of the change 11 modification. I am really talking about a second 12 thing, and that is, putting aside whether various 13 reviews for safety questions and FSAR had been performed, 14 what evaluation is being done to decide whether or 15 not this is a good idea or not, put aside whether it 16 is going to affect the FSAR.
17 MR. GLASSMAN: Are you asking this witness 18 whether he knows who did that?
19 MR. WISE: Yes. This witness is in charge 20 of the paper work flow on this particular thing 21 and knows the procedure.
(.
1 i l 1
22 Q What was the procedure here? I 23 .
A It was submitted, it was a major change, and
(~)
!, ,/ 24 it was submitted to Reading engineering to make that
- 25 change, whether it was a good idea or not, to make the
. _ . . ,_ _ - .~
1 Shovlin 77 4
2 change.
3 g Suppose this change request was put in 4 by an operator and he says you ought to do a major 5 job. Are you telling me at - no time until it gets 6 t,o Reading, at TMI there is no judgment made as to 7 whether or not this guy's idea is a good idea or a bad' 8 idea?
9 MR. GLASSMAN: Are you asking him whether he 10 knows that? .
11 MR. WISE: Yes.
12 MR., GLASSMAN: Are you asking him how G
N_'I 13 this procedure works? This witness can't know 14 what everybody might know or think about a 15 particular' item.
I 16 A Procedurally it tells whether it was a 17 major or minor change. If it was a minor change, they 18 would make the decision on site. If it is a major
'19 change, the approval of that change must go to Reading.
20 Q Final approval, but what I am saying is, 21 is there a point in the process at TMI before it goes 22 tc Reading where someone at TMI decides whether or not l
I 23 ,
this should be sent to Reading at all? !
/~% j
. (, ) 24 Let me withdraw that.
25 Isn't it true, Mr. Shovlin, that the
1 Shovlin 78 2 engineering department at the site would review a 3 request such as this to determine whether they thought it 4 was a good idea or bad idea?
5 MR. GLASSMAN: You are asking whether this 6 witness knows what the enginee' ring department at 7 the site does?
O MR. WISE: Yes.
9 Q Isn't it true that that is the way the 10 procedure worked?
11 A If the change was a minor change, the 12 engineers on site would go ahead and approve it or 13 disapprove it.
- If it was a major change, they would 14 certainly be communicating their concerns with the 15 engineering department in Reading. There,is no lost 16 communication if it is a good -- if it is a good 17 proposal. If that is what you really want'. They just 18 don't say: here is an operator that submits a change:
19 what does he know about it? O.K., they don't take 20 that approach, because a lot of the operators do put 21 in significant good operating changes to make --
to 22 improve plant reliability.
23 g Let me see if I can get past this. There A
f t
'u/ 24 was-a-procedure set up at Met Ed, as we have discussed,
- i 25 i AP 1021, that governed the way change modifications '
,, r w--- ,, , ,,--e- ._ _. -, , - - - -
1 Shovlin 79
{~)T y
2 were to be handled. Your department was primarily l 3 responsible for overseeing the carrying out of that 4 procedure; is that right?
( 5 A The flow of the procedure.
6 Q So my questions are directed at the normal 7 flow of the procedure and who was supposed to do what 8 in carrying'out AP 1021 which was generally under your 9 jurisdiction to oversee. -
10 Now, we have established that somebody starts 11 a request. We have established that maintenance 12 simply looks at the request and sends it on to the
/
V 13 appropriate discipline at the Island, in the engineering 14 department, for review.
15 What I am trying to establish now-is that 16 the engineering department at the Island reviews the 17 request with an idea, with a view toward determining 18 whether the proposal is a good one or a bad one; 19 isn't that right?
20 MR. GLASSMAN: I think the witness just 21 told you what it was that people at the Island 22 did. He specifically described what was done, 23 and in fact in quite some detail described what i I' #
(_j 24 happened with regard to items 7 through 10 on this j l
i 25 form. I don't know if you are asking for l l I
1 Shovlin 80
(~% -
V -
2 something other than that.
3 MR. WISE: I am asking something other than 4l that, and I am having a great deal of difficulty
( 5 getting the one piece of information that I am 6 looking for, and I am not asking the same 7 question repetitively, and these continuing 8 objections and obstructions are making me wonder 9 why I am having such trouble getting a simple 10 answer to the question: whether knybody at TMI, 11 and under your understanding of the procedure, rN 12 did anybody at TMI review a request before it U 13' went to Reading to see whether it-was a good 14 idea or not, did anybody review the request to 15 see whether it was a good idea or not.
16 MR. GLASSMAN: Mr. Wise, I am not obstructing' 17 anything, and I object to your raisi'ng your 18 voice with this witness. The problem I have with 19 your questions is you'have been going over the 20 same form, the same material. You have got a 21 person here involved in the maintenance department
{
'l f 22 f and you are asking him questions about what I!
23 ', happened in the engineering department. I think
(" !
kTl 24 he told you what he understands is done. I ,
25 don't know what more he can give you.
1 ,
Shovlin 81 l
2 MR. WISE: I want an answer to the question
-3 that I have not been able to get an answer to 4 , for the last five minutes.
5 MR. GLASSMAN: What is that question again?
6 Q Under the prior AP 1021, as you understood 7 it, was the engineering-department to perform a review 8 on the merits of a proposed changeoor modification 9- before it was sent on to Reading for their review?
10 A Yes.. \
11 Q And it is true that that evaluation was 12 witnessed by the signatures at'the.very end of the-13 form on the second page; is that right?.
14 MR. GLASSMAN: Wait a second. I don't know 15 what you mean by something being witnessed, Mr.
16 Wise. This witness does not know what'went'on 17 in Mr. Logan's mind, the unit superi'ntendent's 18 mind. You are trying to get at~something that 19 is absolutely inappropriate here. This witness had 20 a particular role, his department had a particular
~
- ' 21 - -role in the. form, and you are tryinglto establish 22 'through.him, in the back door, what might have ~ -
i 23 - 'been in the minds of another department to which
- usb -24 it was sent:afterwards.. That is-absolutely i
25 ' inappropriate and you are trying to harp on this-s- .
[
1 Shovlin 82
.rh
- v) 1 2 witness for that purpose, and that line of -
3 questioning is really inappropriate. If you want 4 to find out whether he knows what the particular
( 5 engineers at Met Ed did as opposed to those at 6 ,
Reading -- I mean he's already told you what 7 his understanding is and I don't see how you can 8 go further than that.
9 MR. WISE: I think I am entitled to find 10 ' out what the meaning of the signabures on the 11 second page of this form is. This is the man
-(x
(
12 who was charged with responsibilities for carrying 13 out administrative procedure 1021, i 14 MR. GLASSMAN: That is not what he testified 15 to. He said he was responsible for particular 16 aspects of that procedure. You are. distorting 17 the testimony. He specifically said'that he 18 was responsible for document control. He has not 19 said that he was responsible for what happened 20 in the engineering department. You are trying 21 to distort the record by injecting a maintenance
{
22 man into the engineering department. i 23 MR. WISE: I think you are trying to narrow
,(- i l t
\_/ 24 this witness's ability to answer questions in 25 a way that is totally unwarranted, given the
1 Shovlin 83
(~h l L) 9
~
testimony he has given about what~the role of the 3
maintenance department was in monitoring the 4
- paper flow and carrying out the administrative 5 "
, procedure.
MR. GLASSMAN: I am frankly getting very
- I upset with you because you not only are trying to 8
distort the record, but then you are trying to 9
carry on colloquy to get us more upset. The i
witness not only answered your questions, but in 11 fact went into detail about his understanding I 12
/~} of this particular section of the form and who
\_/ j 13 filled, it cut and what the different items in I4
] this portion of the form meant, as far as he 15 understood. I don't know what else you could 16 get from this witness.
I MR. WISE: Let's see what we can get.
18 Q Would you look at the second page of the 19 form, Mr. Shovlin. You will see down at the bottom 90 there is a box. It says " evaluation prepared by,"
21 underneath that " reviewed by," and then there is another signature line for " concurred by," and finally i 3
a signature line for " approved by," and all of those r\ t t
\ /-- 94
~
signature, lines have dates to the right of them. Do 25 you see that part of the form?
1 Shovlin 84 b) v.
- 2 A Yes.
3 MR. GLASSMAN: I would like to take a short 1
4 recess.
5 MR. WISE: No, I object to that. I don't t
4 6 want you going out and having a discussion with 7 the witness to prepare him with the answers on i
8 this particular thing. This has gone on to i
9
~
- a ridiculous degree in previous' examinations.
4 t-10 2
I would like it noted on the record that
{, .
the witness and his counsel are leaving the room 11 l 12 to discuss this particular line.of questioning.
i ~
4-13 I ~ think it is outrageous.
14 MR. GLASSMAN:
I am frankly upset with your 15
{ repeated attempts to harp on the wi,tness in an 16' area that is not his, and I would like to be able 1
I-17 to discuss with the witness certain' matters.
I 18
- would like to'be sure the examination proceeds 19 properly and we don't get out of line here.
20 MR. WISE: I'think it is totally improper
, t 1 21. .and.I want it noted on the record. ,
22 ' (Witness and counsel confer outside the- ,
2-- .
23 : examination room.)
e 124 MR.. WISE: For what it is worth, I am going 1
25 to continue with the examination,,but I think thati L:
1 Shovlin 85 QJ 2 the testimony.which we get on this particular 3 line of questions is obviously going to be colored 4 by the fact that the witness's counsel has had l 5 an. opportunity at his request to coach the witness 6 with respect to this particular line of 7 questioning.
8 MR. GLASSMAN: I object to the implications 9 on the record. Mr. Wise, I have already noted 10 my objections to the nature of the questioning i
11 that you have carried on here and your attempt gN I2 - to hadger the witness in an. area that may not be l
, (J 13 i
in his area of understanding, and any other 14 implications are completely unfounded.
15 You may proceed with appropri, ate questioning.
16 BY MR. WISE:
17 g Before the interruption of the questioning 18 I had pointed you to the box at the bottom of the 19 second page of the form where there appears a series 20 of signature lines. Do you see that? I 1
- 21 A Yes.
22 Q What was your understanding as to what
-23 the signature lines there meant?
0)
\_j 24 A I previously testified several times, sir, l
25-that'the signatures starting on the first page, w ,, , ., ,e, , . , , , . r- , , - y a , '- -- ,e-, , e-a p-- .
1
- n Shovlin ,
86 b -
2 page 3 --
the engineering had a particular function 3- to perform, o.K., and they did. There were specific 4 questions that they were asked, and they answered them.
5 The unit superintendent had a specific question asked, 6 and he answered it.
7 Page 2, if you see item No. 5-A on the 8 top of the page, " nuclear safety evaluation," there 9 was no need -- these questions are asked. The change 10' -
must receive NRC approval. They are neither answered 11 yes or no. And the next block, reasons for answering y- 12 question 9.1, no. So apparently all the questions
\_)
13 on item No. 5 on paga 2 are answered "no." The change 14
{l to the lighting circuit of the RCRV2 will in no way 15 cause a release to the environment. I 16 The valuation was prepared by Mr. Krealling.
l l 17 l It was reviewed and this whole evaluation, which ;
18 included page 1 and 2, was reviewed by R. W. Bensel and 19 it-was approved by the unit superintendent -- it looks 20 like Mr. Logan. It was then changed -- it was then 21 relayed to Reading engineering for their review of the
( ;
i
'22 change and approval.. That is basically it.
23 And that is all you know about the Q
("N, i
'24 ' procedure?
25 A-
.That is all I know about the procedure.
^
I l
/
a l'
Shovlin 87 2 Q And you as supervisor of maintenance had
,, 3 no idea as to whether or not Mr. Krealling ever i
j 4 . performed any review of the merits, other than the 5- specific questions that are in this form? '
6 A I have no idea.
7- Q And you' don't know, as part of the normal 8
l way.that the administrative procedure 1021 works, 9 whether anybody in engineering was ever supposed to I
- ID do that, other than the questions that are specifically
. -11 on this form? ;
12 A only if it was a minor: change, and then
) - I3 they;had the approval authority to make that change. !
l-
- 14 Q 'But if it was a-major change, you don't ;
I
- 15 know as to whether anybody at.TMI in the. engineering l- 16 group made any evaluation other than to answer the l~
~
17
. specific questions that are on pages 1 and 2 of this l
- 18 . form? '
- i. ..
j 19 A 4
I have no idea whether they did or not.
- j. 20 Q Do you know whether when one of.these 4 '
r
{ 21 forms was filled out any record was made of who' filled
- 22 out the form originally? I am speaking about.the 4
l 23.
l1 initiation of the form, not the subsequent reviews
.. , l 24 and approvals that are indicated on it.
25 'A- I am not sure what the log indicates.
1 L- _ . , _ .m _ . _ _ . . - - . - . - - . --_ a- a - . - - a- - -- U
1 Shovlin .
.f"h' L) 2 Q Are you-aware of any record-keeping system 3
at all at TMI-2 that would enable us to determine who 4
initiated this particular change / modification request 5 form?
6 A Not unless it was indicated in the log 7 that they kept.
8 Q Where is that log maintained?
9 - A In the Unit 2 maintenance department.
4 s !
10 '
Q Do you know whether that has been searched I
11 in connection with this litigation?
g 12 A I have no idea.
\Y 13
.Q Is it still the r e? ,
1 !
14 A I have no idea, if it was lost in the 15 accident or whatever, but I have no idea.
16
.Q Did you ever see that log?
17 '
A Yes.
18 Q What does it show?
19 A It identifies the change, the discipline, 20 the engineer who is to review it, whether it is QC 21
( or non-QC. I believe it has whether it was a major ;
22 or minor change, and where it is at, and the date
.23 that it was sent.
1
'\_/ 24 Q Was it a handwritten document?
25 A It is a' handwritten logbook.
1
1 Shovlin 89 0 2 Q Who has it under his control?
3 A The supervisor of maintenanc'e on Unit 2.
4 Q Was it ever the case in your experience
( 5 that an individual at the Island would submit a change 6 or modification request on something other than the 7 form?
8 A By memorandum.
9 Q' By memorandum, a letter or a note?
10 j l A lt coula have happened that way. i l
l l 11 : Q When that occurred, what was the practice ;
I 12 for putting that into the proper format under the O 13 ,
procedure?
l 14 .l A Either the clerical individual would 15 initiate one of these forms and write down a 16 description as best --
that she could take from 17 the memorandum, yes. -
)
18 Q What would be done with t'he memorandum i ~
19 or note? Was there any procedure to save it?
20- A It went through the same review process 21 as any -- oh, as far as the memorandum --
22 Q Yes, what would~be done with the original '
' 'l
( 23 ,
note or memorandum? .
l
( 24 A It all depends on how it came in. If it '
25 came in as a formal letter, I am sure it would be on
1 Shovlin 90
(
Ms
'2 file.
3 Q But you don't know of any regular practice 4 that was maintained?
( 5 A No, because many of the times the 6 initiator would fill out -- we would give the engineer 7 a change' mod -- they had their own blank forms that 8 they could fill out themselves.
9 I Q But it did happen from time to time that !
I i l' i '
i' '
10 people would submit things by way of a'. note or 11 memorandum?
- 12 A It in possible -- yes, it is possible that
\ /
13 l a memorandum could have laitiated i t and as a renult, l 4
. 14 the change mod docunent filled out.
15 Q If you look at this particular one, you 16 will note in the upper right-hand corner of the first 17 page someone has assigned a change modification 18 number. Do you see that?
10 A Yes.
20 Q That would be done by the clerk?
21 A That would be indicated by -- it could i
22 have been by the clerk. ,
l I l 23 l -Q who else would have --
(')
(_- 24 A or it could have been by the initiator l
25 who initiated the form, an engineer.
-g y .- u -
e..--a .m-e,=. _ mwe-g. - , - ,,We
4 1 Shovlin 9J b).
u_
2 Q Well, for instance, there is a specific 3 number here, 2/0298.
4 A That is a change mod number that the clerk 5 would put on.there.
6 Q In other words, the number would be 7 assigned by the clerk?
4 8 A The change modification number, that's 3 correct.
, i 10 Q That would be dore after the form was ,
I.
11 submitted, I take lu?
12 A Yes, that's correct.
i l
13
- Q Or if the clerk was working off of somt ;
I l
14 other note or memorandum, it would be done at the 15 same time?
16 A Yes, that's correct.
17 Q Now, you note that'right under the line 18 there are three subsequent lines: the first one is 19 for priority, the second is for operator training, 20 and the third is for QC. Under your understanding of J
~
21 the procedure, who normally filled out those lines?
22 A It could have been an engineer assigned to-23 ' it or it could have been a supervisor of maintenance 24 setting the' priority.
4 25 Q That would not be a function for the clerk?
-w--. ,-- .-+r p- % ,- e,,, -=*%- y .-. = - - -
1 Shovlin 92 rN f\s) .
2 A Well, if it was in the memorandum, if they 3 considered it a high priority or priority 1 -- as I 4 testified previously, priority 1 is taken out of
( 5 context. Some people believe that a leaking fawcett 6 is a priority 1, and rightly so, and some people think 7 that a priority 1 is a leaking PORV.
8 Q What are you saying? I don't understand I
9j you. I
- , i 10 i A What I am saying is what you feel is a Il i
11 ' priority 1 might be a priority 3 to me. That is what '
4 l
- 12 I am trying to say.
(
13 g well, my question now is only really who 14 it was in the system that had the responsibility for 15 assigning a priority.
16 A The supervisor of maintenance.'s signature 17 there, he concurred by his signature down by line 5 18 that everything above that was --
19 Q He was in agreement?
j 20 A He was in agreement with, yes.
.21
[ Q So we don't know who filled in the 22 priority 1 here. It might have been the person who 23 : submitted the request, it might have been Mr. Sieglit=,
I
. f m,; .
(._,/ 24 it might have been Mr. Sieglitz knew as of the time he i 25 signed this he agreed with whoever put that in there. '
=
1 Shovlin 93 2 A That is correct.
3 Q- Is the same true for the boxes marked 4 quality training and operator training, both of which 5 have been marked "yes"?
. 6 A Yes.
7 Q Again we don't know whether the initiator 8 checked those boxes or Mr. Sieglitr?
9 A Whether the intiator made the recommendation,,
10 i whether it should be a priority 1 or 2 or 3.
11 MR. GLASSMAN: We are talking here about -
12 the general way this form is set up. Obviously O\ l 13 tha witnese has testified he did not know about l 14 the particular document in- front of him.
{
15 MR. WISE: I am simply asking him, based 16 upon his practice and his understanding of the 17 procedere within his department, what the meanings 18 of these various signature lines were and boxes 19 to be filled in.
20 Q Did you have any understanding as to what 21 guidance Mr. Sieglitz had concerning whether a
{
22 particular change modification should be put into the 23 operator training program or not?
s -
i u 24 A Well, _ he would make a recommendation, O.K.,
25 but this also went over to the training, a copy of
.1 shovlin 94 3
(O 2 this went to the training department, and they could 3 concur or not, whether it should be incorporated.
4 Regardless whether we said yas or no, the training
( 5 department reviewed,the change to see whether it was 6 worthy of being incorporated into some part of the 7 training. '
8 Q So, in other words, the mere generation 9 of this form would result in the training department i 10 being nctified of it?
11 A Oh, yes. They would see this change.
12 .Q And that made no difference whether or not O 13 Ruacing aventually approved or disapproved? 5
{
~ ,
it A only cfter final approval. Only after 15 final approval, because what the reason for --
the 16 reason for training to be involved is: yes, there is 17 a change for a system and we must change.the 18 curriculum that we are now teaching and everyone must 19 be aware of this change.
20 .Q Now I understand what you are saying is 21 they would not get a copy of this until after it was
(-
22 decided that the change modification was going to go l 23 i forward.
I
[)
- v. 24 A I am pretty sure they would not see this l.
25 until the final approval.
1 shovlin 95
-Q (}!.
2 .Q Now'I want to go back to the question that j 3 I was trying to get an answer to earlier.
4{ Someone filled out these boxes up here
( 5 for operator training and quality control, obviously 6 before they knew whether or not this was going to be 7 approved. Is that right? Is that your understanding 8 of the way the procedure worked?
9 A Yes.
l s
10 l Q And Mr. sleglitz agreed ar\ concurred 11 with the way that this form was filled out?
4 12 A Yes.
s
\_/ l-12 O TI.at is what his signature.down there 14 means.
15 A That'a correct.
16 Q How the question I am asking is, what l
17 guidance did Mr. Sieglitz have as to whether or not 18 any particular change modification request form 19 required operator training and therefore the box should 20- be checked "yes," or did not, and therefore~the 21 box should be checked "no"?
22 MR. GLASSMAN: Are you asking for a ,
23 general practice?
You are not asking particularly lf 3(,) 24 for wha t Mr. Sieglitz might or might not have 1
25 used or seen? l-
+ , - - , . . . , , ,,,.-. .-m u -
y e- , ~ , - - -+. - - - , . - - - , . , - , , - - - , , ,-
1 Shovlin 96
(
V 2 THE WITNESS: -I can answer that.
3 MR. WISE: All right, the witness is
(
4 ready to answer.
l 5 A Mr. Sieglitz, he knows that it is a change 6 to a system described _in the FSAR, it is a QA system.
7 Automatically that triggers him to indicate yes. It 8 is'a change that someone should be aware of.
- 9 Q So it was your understanding that the 10 j procedures required automatically that',the training !
11 department -- that the changs bo included in operator 12 training if it was a change to any system specified i
13 l In the FSAR7 14 A If that is what we fcit, either I, if I -
15 was concurring with this, but that doesn',t mean to 16 say that the training department would totally concur 17 with that. The trigger is that they at least get a 18 chance to see the change to make that decision, rather 4
19 than have a change made and they have no knowledge of 20 it.
1 21 Q Well, now I am confused again. I thought !
- k. I 22 you told me earlier that if the change got made, they !
+i' 23 got a copy regardless.
(~N - t
., (a) 24 A That's true. '
25 Q Well, what was the function of this box
.- _ - , .-. .., ~ - .
1 shovlin 97 2 up here with a "yes" and a "no" next to " operator 3 training"?
4 A We are telling them what we feel, O.K.
( 5 Q So you are recommending to the training 6 department that they include this change, or if this l l
7 change is approved, you are recommending that the l
8 training department include it in their program?
I 9 A Yes, and the clerk will make a copy of it 10 i to insure that there is a "yes" there, and I have to 11 send a copy of this here change over to the training 12 1 'd epar tmen t , yes.
la. l i
Q But whether that was checked "yes" or l
14 "no," they were going to send a copy to the training 15 department regardless?
16 A I am not sure of that.
17 Q Then you are saying there may-have been 18 changes that were approved and installed in the plant 19 that did not go to the training department?
20 A That is possible --
I --
21 Q You don't know?
22 A I don't know. That's possible.
I can't '
23
) say that every change that was made, that the training O
(,/ 24 department received a copy of the change modification.
25 g You today are not able to recall with i
-1 Shovlin 98
(")
l
. v.
2 clarify, I take it, the criteria to be used by Mr.
3 Sieglitz in deciding whether or not the operator 4 training box should be checked "yes" or "no"?
( 5 MR. GLASSMAN: I thought the witness just 6 gave you his testimony on that.
7 A I said yes, he would utilize the quality 8
assurance listing of nuclear safety related systems, 9 and use that as a criterion to establish whether it 10 is a significant change that should be reviewed and L
11 looked at by the training department, t
12 Q What quality assurance listing are you ,
() lo,, l talking about?
14 A I am not sure of the -- it was GPU 1008 15 and there has been a change because of our --
a change 16 in our organization structure and we now work under 17 a document ESO 11, but I am not totally s'ure if 18 Unit 2 completely comes under that curtain of the 19 ESO 11 chan'ges.
20 Are you saying that ,there was some kind of Q
21 a list of components?
22 A Yes, components that our quality assurance l 23 lists, that's right.
(3 '
1
(_ ) 24 Q And there are listed there the various 25 items?
J
1 Shovlin 99 (m -
)
2 A Yes.
3 Q And your understanding was that if somebody 4 put in a change modification that affected one of the
-( 5 components that affected that list, that it was 6 automatically something that should go into operator
, 7 training?
8 A Yes, at least reviewed and looked at.
9 Q Was it common when the form came back from l
L the engineering department that there 4,ould be 10 'l - some 11 kind of written evaluation that accompanied the form? l 12 1
' ~ A Yes. t
~
l 13 Q What kind of an evaluation normally would 14 accompany the form?
15 A A form similar to this.
l 16 MR. WISE: The witness is indicating the 17 page at the back of the exhibit, dated September 18 4, 1979, that bears the document production 19 number W 38019 in the bottom right-hand corner. I 4
20 Q That particular page, we had testimony
- 21 I !
the other day, Mr. Shovlin, was prepared by the l
22 engineering department in Reading. I am now directing 23 my question to the evaluation performed by the h
j ) 24 engineering department at TMI on site. After this was
{' !
25 referred to them, they sent it back to you before it
=- _
1 Shovlin 100
/~T I k ,]-
2 was sent on to Reading, as I understand the procedure.
- 3 Right?
4 MR. GLASSMAN: I may be a bit confused as
( 5 to which engineering department now.
6 MR. WISE: I think we established earlier 7 that this form was initiated by someone, went 8 to Mr. Sieglitz.
Mr. Sieglit: sent it on to ll .
9 il Mr. Bensel or whoever the lead engineer was for 0
10 ll the appropriate discipline. ,
I 11 l MR. GLASSMAN: We are now back to the l'
I2 form on pages W 38008 and *09? '
IU '
, l M2. WISS: Pight. -
14 Q The form was sent to the lead engineer 15 for whatever the appropriate discipline was, they 16 performed an evaluation. Eventually the signatures' 17 a
got onto the page, as indicated at the bottom of page 18 2 of the form, and then before the form was sent on 19 to Reading for their review, it came back to your 20 office and your secretary or somebody took the cover 21 l sheet with your Xeroxed signature on it, put the date
- I 22 January 30, 1979 on it, and sent it on to Reading; 23 correct?
r~N l
(/)
24 A Yes.
25 MR. GLASSMAu: Then you are talking about
'ry) 4 1 shov1'in 101 m ,
' (v l-2 the general practice. The witness did not 3 recall the particular --
4 MR." WISE: Right, that is the general
( 5 practi,ce, that is the way tha thing.would normally'
. 6 work. ,
{
7 A Yes. -
8- Q And in fact we can infer from this 9 particular' document, assuming that these signatures.. i l
10 ' are genuine and that the dates on them bre not i
11 forgeries, that Mr. Krealling signed it on December j 12 20, Mr. Bensel
'{
O- l signed on December 20, they 'se'r t it J
?
13 on to Mr. Logan who indicater that he signed it on
{
it i \\
14 January 29th of the following year, and'the cover l/ f 15 memo under your Zeroxed signature went to Reading $n 4
16 January 30, 1979, so unicss somebody has been forging ,
17 'the dates and the/ signatures here, we can assume that 18 was the normal procedure that was followed with this I
19- particular change' request; is that fair?
20 A '{
That's correct. - ,.
21 a Q Now my question is, when the modification
{ tl t
11
- d request form.came back fron Mes rs. Krealling, Bensel 23 !
and Logan, whoever had it last, to your secretary -
's jx
( 24 or whoever it was'that had the' assignment to attach ' I j N.- , ,
L 25 'the January-30 cover memo to the documents and send :j
- -- = w'
}
x 1
Shovlin 102 p
2 them on to Reading for their review, would there ,
3 normally be attached to it some sort of report or 4 evaluation by Messrs. Krealling, Bensel or Logan,
( 5 or one or more of them or all of them?
6 A The whole form goes to Reading, the whole 7 change modification form.
8 That is page 1 and page 27 Q -
9 A Right.
10 '
Q Now, is there anything else_that normally, 11 when your secretary got the change modification 12 request form back after Krealling, Bensel and Logan 1[]) 13 had it, that would come with it besides these two 14 l pages?
15 A There is a possibility, if they want 16 to give Reading engineering some of the leg work that 17 they have already done on looking at the change --
18 what the change involved, that is a possibili*y, that 19 they would attach that to the change.
20 Q Was it ever your experience that after 21 this two-page form was sent off to the engineering 22 group at TMI and before it came back to your secretary ;
23 .to be forwarded on to Reading, that some sort of l
(
's j
)- 24 written report or evaluation got attached to the two-25 page form? '
I shovlin 103
/~T U 2 A That is always a possibility, but I 3 can't right offhand --
4 Q I mean was it usually the case?
( 5 A No.
6 Q Usually the two-page form would come back 7 with these signatures on it and nothing attached?
8 A There was a form, a minor or major 9 change, I believe, that would be attached to that, 10 indicating what it was, and I believe t,here was a 11 checkoff list indicating certain questions on why 12 it is a minor or why it is a major.
O 13 Q But, for instance, in terms of somebody
- 14 writing up some kind of a written report saying that 15 here is what the change modification is, here is why 16 we think it is a good idea, here is why we think it 17 is a bad idea, here is our evaluation of.what would 18 be involved, it was your understanding that normally 19 under the practice that prevailed at TMI before the 20 accident, no one would prepare such a report before the 21 request was sent off to Reading?
22 A Not to my knowledge. ,
i 23 '
g was there any' procedure that you knew of
('N I t y. 24 for informing the individual who had requested the l
25 change what happened to it?
1 Shovlin 104 2 A They got a copy of the response on 3 whether it was approved or disapproved from Reading.
4 Q Well, for instance, how, from these forms,
( 5 can you tell whether the individual who initiated 6 this request ever found out what happened to it?
7 A Well, if you look at the response to the 8 change mod request, it is copied to Lawyer; Miller, 9 the station manager Logan, who was in the approval-10 circuit; Kunder; Bensel; Krealling, who, performed the 11 evaluation; and McGarrywho.was a lead engineer.
12 Q What was his discipline?
'13 A Mechanical.
14 Q Well, which one of those individuals 15 had iniaited this request?
l 16- A I have no idea.
17 Q Is it your understanding that-it-was one 18 of those people listed there?
19 A I have no idea.
20 MR. GLASSMAN: Are you asking him to take 21 e. guess?
22 MR. WISE No.
23 A '
I have no idea. It could have been any 24 one of them that initiated the --
25 -Q 'I may not be. making myself clear, Mr.
a 1- Shovlin 105 2 Shovlin. We earlier attempted to find out, if we 3 could, who wrote out this particular request that we 4 have before us.
( 5 A And I have no idea who initiated it.
6 Q My question now.is, if you don't have any 7 way of telling from the form who initiated it, how 8 can you get back to that person and tell him or her 9 or'whoever it was what happened to the request? l 10 A Because I believe -- I thin,k that most 11 changes that are originated in the plant are those 12 changes that are initiated by the engineering e -
13 ' department and --
14 Q But this might have been an operator, 15 might it not?
16 A But that is an exception. I told you I 17 don't recall.in the last nine years of having an 18 operator submit. He had the ability to do that, O.K.
19 He has -- there is no obstruction saying that an 20 operator could not submit a proposal to make a change.
21 To my~ knowledge, I don't'know if that has ever
. . i
- 22 l happened. Most changes are made through engineering. l 23 I That is what the form is for. It is an engineering O
- g. 24 design form.-
25' g .What. system did you have to make sure
. i
1 Shovlin 106
.p
(_) 2 that whoever the engineer was that initiated this 3 request, he got back a response?
) 4 A Only whether it was mechanical -- it had
( 5 to be-submitted by either electrical, mechanical, 6 or I&C, and the lead foreman in that group would be i 7 responsible to coordinate and insure whoever within 8 their cognizance is made aware of the status of the I
9 request.
10 Was there any formal procedure that you Q
11 are aware of, before the accident in late March 1979, 12 for insuring that individuals who initiated a chan'ge i 13 modification request were kept advised of the 14 disposition of that request?
15 A I am not sure of that, no.
16 In fact there was none, was there?
Q 17 MR. GLASSMAN: Wait a second.- The 18 witness is --
19 MR. WISE: He said he is not sure. I 20 am entitled to ask a follow-up ques. tion.
4 21 A There could have been. I am not aware
(~
22 of it.
i 23 You are not aware of that procedure?
Q .
./' l l
( j)/ 24 A I am not aware of that.
25 MR. WISE: Why don't we take a lunch break
, n , - c --y, ~ r-,w ,,-r - - ---r -- . - n-
1 Shovlin 106-A O 2 at this point. -
3 (Whereupon, at 22:45 p.m. a lunch recess 4 was taken.)
( 5 6
7 * *
- 8 9
10 11 12 13 14 15 16 17 18 e
19 20 91 22 i
23 24 25
i 3
1 107 me -
2 AFTERNOON SESSION 3 2:25 p.m.
4 DANI E L SHOVL I N, resumed.
( 5 EXAMINATION (continued) 6 BY MR. WISE:
7 Q Let's see if we can wrap up the questioning 8 on B&W 767. If you take a look at the second page of 9
, the change. modification request form up at the top 10 in the upper right-hand corner, you wiil see that the 11 change modification number is repeated, 2-0298.
12 A Right.
O I
13 Q Immediately beneath that there is an 14 indication for a work request number.
i It has been 15 assigned as number 0343. Do you see that?
16 A Right.
17 Q What is a work request number?
18 A' A work request is -- anyone can submit a 19 work request. For example,.I think I gave you a 20 leaking water fawcett analogy, or this particular 21 problem. Someone identifies it in a plant, it could 22 be the auxiliary operator out making his rounds, 23 so anyone could submit a work request to identify a
-q' "
(v/ 24 problem.
25 Q What would that have to do with the change e.
1 Shovlin 308 p
\
2 modification. form? What relationship is there i
3 between a work request and a form such as this?
4 A Well, say that was approved, this document 1
( 5 was approved --
6 Q Excuse me. Say what was approved?
7 A The change mod. In order for us to do 8 the work, we would have to do it with that work request 9 with the procedure and all the accompanying documents 10 that engineering would come up with for us to do that, 11 to perform the work function, so you would be doing it 12 with that work request or job ticket.
13 Q Was a work request filled out after a-14 change modification was approved?
15 A No. That is possible, but the policy --
l 16 Q Just describe the usual practice and 17 Procedure' as you understood it at TMI-2. .
18 A You make up-a work request first.
19 Q Before you make up the change modification 20 form?
21 A Let me go through, then you could --
i i
22 Q O.K.
23 A Say, somebody in the plant identifies a i
()
-xJ 24 Problem and it was a -- he does it on a work request, 25 and Mr. Sieglitz would get the work request and review
~*,. . , - - . -
- - , - - . .- .- - C --
l 1 Shovlin 109 j'%
(-) 2 it. And there were questions on there similar to what 3 is on a QC, and does it have an effect on the
'4 environment, and he is answering all of those questions,
( 5 is a change modification required, o . K'. --
6 Q Excuse me. You say that is a question 7 on the form?
8 A On the form, on that work request. And 9 Mr. Sieglitz would look at it and it says "yes" or 10 "no," so if it was "no," it would continue on as --
11 identified as a work item, and we have thousands and 12 thousands of work items. But say in the process of 7,
N* .) 13 that work request, there was a change identified, he 14 would then initiate, Mr. Sieglitz or a clerk or whoever 15 in the maintenance -- would fill out this document 16 because it is, they feel, a change. Sometimes they 17 make, Mr. Sieglitz, and sometimes even I have made a 18 wrong judgment of whether it was a change or not, 19 and someone said no, it was not a change, but they 20 would -- he would fill out this document and then --
21 Q Excuse me. Go ahead.
22 A And then it would go through the same ,
i 23 flow path as originally described. ;
.( ) 24 Q Let me ask the question this way. Given 25 ~ your background and knowledge of the procedures and ;
1 Shovlin 110
(_)
2 paper work associated with change modification 3 request forms, what is your understanding of the 4 significance of the work request number indicated on
( 5 page 2 of this particular form?
6 A The only significance it would have to me, 7 if I want to go back and see, did we perform the work, 8 did we do the change, if the change mod was completed, 9 what document was used in order to complete the work.
10 Q You are aware that this particular change
- 11 modification was disapproved by Reading?
12 A And then there wouldn't be any work 13 accomplished and that job ticket would just be signed 14 off as not being accomplished.
15 Q Are the work requests kept or maintained 16 in any fashion?
17 A Oh, yes.
18 Q So that it would be possible to find 19 work request 0343 today, as you understand the way 20 the files are kept?
21 A Yes, it should be.
22 i Q Do you know whether when a change s
23 modification form was filled out, such as is part of
- s I
( l 24 B&W 767, the work request that was associated with l
25 it would be attached to it?
~
l l
1 Shovlin 113 i
(m%)'
2 A It should be. I would have to --
I am l
3 not quite certain, but you still would be able to 4 come up with the two documents in one file or another
( 5 because the work request is also logged in. It's in >
6 a log.
f 7 Q Would the work request, as you understand 8 the procedure, be something initiated by the 9 maintenance department or is that something initiated 10' by someone who was proposing the idea?'
11 A A work request --
I said 90 percent of 12 our work requests are initiated by the operations O 13 department, people that are out in the, plant.
14 MR. WISE: Obviously we are going to call 15 for the production of this particular work 16 request. I don't know why it hasn't been 17 produced before now. -
18 Q Now, the other day we had some testimony 19 from Mr. Noll, who was the Reading engine r who worked 20 'on this particular request, and he testified that this
,- 21 change request form came to him with the drawings '
(s !
22 attached. You will note that there are several pages 23 of drawings attached to the form as part'of this .
24 . exhi bi t , excluding.the material' at the back, the 25 written textual material. I believe it is the last-
I i
l 1
Shovlin 132 n
2 four pages of the axhibit which we have had testimony e
3 on from Mr. Noll and which I believe are all documents 4 prepared in Reading, but the drawings were apparently
( 5 attached to this when it came to Mr. Noll.
6 Now, my question is, in your understanding 7 of the procedure, whose responsibility was it at the 8 Island to get at the drawings and indicate the 9 specific areas on the drawings to be changed? I 10 A Engineering.
11 Q So that would be something done by the 12 cognizant engineer or Mr. Bensel?
gg b 13 A That's correct.
14 Was it the practice, as you understood the Q
15 paper flow procedure, for the drawings to come back 16 simply.with handwritten notations such as the circles i
17 and penciled-in markings that appear on these drawings 18 but without any textual explanation as to what those 19 are?
20 A That could happen, yes.
21 Q That,is the way it normally worked? ;
22 A In all instances I don't'know, but I am 23 saying this is not the final product. ' When the change I
. (,)
f~) . 24 is made, the drawings are updated in a formal fashion 25 so that is --
_ _ -- - . ,_. ? . -
1 Shovlin 333
.ie. p) -
2 Q But insofar as you knew, before the form 3 was sent on to Reading there was nothing more given 4 to Reading about what these drawings meant or what it
( 5 was whoever attached them to this, form meant to show 6 by these drawings, and simply the drawings themselves 7 and whatever markings are on them?
8 A Yes, and I have no idea what -- >
l 9' Q You couldn't interpret yourself, looking 10 at these drawings, what it was they were intended 11 to signify?
12 A No.
O. 13 Q And just looking at them, you wouldn't 14 have any way of knowing why these particular drawings 15 as opposed to others had been selected?
16 A No.
17 Q And to your knowledge, there was no 18 requirement as part of the procedure, paper flow
~~
19 procedure, that somebody attach a written explanation 20 of what the drawings were and what it was the preparer 21 of these drawings or the person who collected them 22 and attached them to the form meant to show by them? l
.23 A Not to my knowledge.
3 [%. -
- 24 Q one more question on B&W-Exhibit 767.
25 I take it that you have no recollection of the L
.-, .,J..,,,., ,,--..--..,-~~,.L, , . . - - - > - - . - - . , , , .
1 Shovlin 114 2 resolution of this particular request?
3 A No.
4 Q It never came to your attention as to
( 5 whether it was approved or disapproved or what?
6 A No.
7 MR. GLASSMAN: It never came to his 8 attention --
9 Q Never came to your attention before the 10 preparation for this examination? (
11 A No.
12 Q You don't remember anybody telling you 13 about this particular item?
14 A No.
15 MR. WISE: I would like to have marked 16 as B&W Exhibit 899 a form that was previously 17 marked, I believe, during the plaintiffs' 18 commission testimony that you gavehollowingthe 19 accident. It is an undated form. The subject 20 is " Change Modification." There is a typed 21 signature of your name with a written signature 22 and it may well be a Xeroxed or a stamped j 23 l
- signature above the typed version of your name, j 4
I
'(,,) 24 (One-page document on letterhead of I 25
~
Metropolitan Edison Company, subject: Change
l 1
Shovlin 115 A
.U 2 Modification, undated, was marked B&W Exhibit 3 899 for identification, as of this date.)
4 Q The subject of the memorandum is change
( 5 modification. Do you recognize this form?
6 A Yes.
7 What was it used for?
Q 8 A This was made up by a clerk person to 9- guide the lead engineers in preparing the change l 10 modification document to do their evaluation.
11 This particular form --
Q 12 A Giving the flow process of where it goes.
. ('5 O 13 g
- This particular form happens to be for 14 Unit 1; is that right?
15 A That's correct.
16 Q Because Mr. Seelinger's name is on it 17 as Unit 1 superintendent? .
18 A That's correct.
19 Q Was there a similar form used for Unit 27 20 A I am not sure of that.
21 Q When was this form in use? Before the
!( .. I 22 accident? I' 23 : A Oh, yes. In Unit 1? ,
24 .Yes.
v o 25 .A Yes.
1 Shovlin 116 2 Q But you don't remember whether there was 3 a similar form for Unit 2 before the accident?
4 A For Unit 2, no.
( 5 Q Was the. procedure nonetheless the same 6 for Unit 2 as it was for Unit 17 7 MR. GLASSMAN: Which procedure?
8 MR. WISE: The procedure that is outlined 9 in he're, a transmittal to one of the lead 10 engineers for mechanical, electrical or I&C, 11 or to the unit superintendent, with the following 12 instructions, namely, that they should complete t
13 lines 6 through 9, prepare a safety. evaluation, 14 forward it to the unit superintendent, and then 15 return the forms to the maintenance office for J
16 further action.
17 A If it was after commercial operation, 18 there were common procedures for both units, and I --
19 Q Does this generally reflect t$e procedure 20 that was in.use in Unit 27 21 A Yes, it does.
s 22 MR. WISE: I would like to have marked as 1
23- I B&W-Exhibit 900 a form which is titled " Minor
(} 24 QC Change Modification Approval Form."
25 (on e-p age document entitled " Minor QC I -
, , . - .- - - - , . . , - . . . _. . . , . . - - _ _ - - . _ . - - _ . . _ . . ~ . - , . _ , , _ - _ _
e I i
1 Shovlin 117
'U 2 Modification Approval Form" was marked B&W 3 Exhibit 900 for identification, as of this date.)
4 Q Are you familiar with the form such as
( 5 B&W 900?
. 6 A That is the one that I identified in my 7 previous testimony.
8 When would this be used?
Q 9 A It would be used --
and I am not certain 10 when this was initiated, but it would be used at any 11 time you submitted a change modification. This would' 12 be part of our plant engineering to determine whether O
13 it was a minor change.
14 Q You will note in the upper right-hand 15 corner there is indication that this particular form 16 is revision 1 and it is dated January 17, 1978.
17 Was it the practice to date revisions of 18 the form as they occurred?
19 Yes.
,A 20 Q So this would indicate to you that this 21 i particular version of the form was in use after January k_ '
22 '
17, 19787 l l
23 , MR. GLASSMAN: ,Are you talking about any 1
i .g (~~j 24 time past that or at or about that time?
25 MR. WISE: Beginning with that time and e
, w -
rw- ,. ,.w- ,, , w -, c- -y. --
%-- c-----
1 Shovlin J18 s
<-)
2 carrying forward to whenever it was revised, J
3 if it ever was.
4 Q Is that what this would indicate to you?
( 5 MR. GLASSMAN: Are you asking the witness 6 to guess or are you asking him to give you a 7 general understanding of what such an indication 8 means?
9 MR. WISE: The latter. He was in charge 1
10 of the area that supervised thesd. forms.
11 A I was in charge of the area that controlled 12 these forms.
p.,
13 Q All right, I will accept that.
14 A This is an engineering document and 15 there have been several changes made to the procedures 16 and revisions, and I am not certain whether this in
- 17 fact is being used today. -
18 Putting aside whether it is being used Q
19 today, the fact that this particular form bears the 20 date in the upper right-hand corner January 17, 1978 21 underneath the notation " Revision 1," would that 22 indicate to you, based upon your knowledge'of the i
23 system that this was a form that was one in use in '
i
(/~w) 24- January 19787 25 A on Unit 1.
1 Shovlin 119 O
(J-2 .Q Was there a similar form in use at Unit 27
- 3 A I am not sure at that time.
4 Q Why do you believe this was for Unit 17
( 5 A Because I don't know of any at that 6 particular time that would'be initiated for Unit 2.
7 I am sure this is Unit 1.
8 Because in January 1978 Unit 2 was still Q
9 under the control of GPU Service Corp.?
j 10 A That, and the time frame in this revision, 11 1/17/78.
12 Q What is it about January '78 that makes i 13 you think that, other than the fact that Unit *2 was 14 still under the control of the Service Corporation?
15 A Until they went -- procedurally changes 16 in -- and I am pretty sure of this -- didn't change 17 until Unit 2 went commercial. -
18
, Q That was in December of 19787 19 A And they were-still going under the 20 l startup and test procedures.
]
21 .Q So based on that, you believed --
-22 A I would assume this is a Unit 1 form. .
23 Q And you don't know whether a similar form-24 got. adopted for Unit 2 or not?
l 25 A No. I
.-. . . - - ,~ .
1 Shovlin 120
( \
V 2 Q However, it was your understanding that 3 this form would be used in the event that the change 4 was determined to be a minor changes is that right?
( 5 MR. GLASSMAN: At Unit 1 you are talking 6 about?
7 MR. WISE: Yes.
8 A Yes.
9' Q And it is your understanding th'at at Unit 10 2 and once it went commercial and you t'ook over 11 responsibility for controlling the paper flow, that 12 minor changes at Unit 2 were also supposed to have some O 13 form filled out; is that right?
14 A Yes.
15 MR. WISE: Lastly, I would like to have 16 - marked as B&W 901 a form headed Change 17 Modification Design Checklist. It is a seven-18 page form.
19 (Seven-page form headed "C/M Design 20 Checklist" was marked B&W Exhibit 901 for 21 identification, as of this date.)
22 Q Are you familiar with this form? 4 23 A This is also an engineering evaluation type
~h #
I(s_) 24 form. I addressed this previously in previous 25 testimony.
I shovlin 121
( .
2 Q You are familiar with it then?
3 A Somewhat, yes.
4 Q Who filled out this sort of form?
( 5 A Whoever.the lead engineer would assign, 6 I would think. .
7 Q Was it filled out in connection with a 8 change modification request form?
9 A Yes.
10 Q This would be filled out by,the engineering 11 department at TMI?
s 12 A It could be. But in any event, this was 13 a document that was filled out by Reading engineering.
14 - Q And was it your understanding that this 15 form would be filled out either by somebody at TMI 16 or by someone at Reading with respect to each change 17 request? -
18 A originally Reading engineering had sole 19 responsibility for filling out these documents. When 20 plant engineering evaluated that it was a minor change, 21 they would -- they were given the authority to fill ~ i 22 p out this evaluation form. '
23 Q For minor changes?
I*
{(_); 24 A For minor changes.
.25 Q But' major changes, it remained the case
1 i Shovlin 422 o
, k.
2 that Reading would continue to fill out the form?
3 A I can't answer that because the 4 responsibility passed back and forth and procedurally
'( 5 changes have been made within the last few years, 6 so I cannot say for a fact when it all transpired 7 or when the document -- originally this document 8 was a' Reading engineering document.
9 Q At the top of the first page of the axhibit 10 there is reference to something called ' ANSI 45.2,J1 -
11 1974. Are you familiar with what that refers to?
~
12 A No.
T'T V 13 Q Did you ever see any of these forms after 14 they had been filled out?
15 A I don't recall reviewing them, no.
16 Q After Reading engineering had completed 17 its review of a change modification submi.tted through
. 18 your office, what, if anything, did your bffice have 19 to do further with the processing of that particular 20 change modification form?
21 MR. GLASSMAN: I think that's been testified 22 to just before lunch, as to how that whole i 23 ! procedure worked. i O
()
24 A With regard to Klingaman. sending me a 25 memorandum and listing whether they approved .or a--w .----ee - - - --we +- -w--- ----y- -
1 Shovlin 323 d
2 disapproved it? -
3 Q Right.
4 A That would be --
( 5 Q That would come back to your office?
6' A That would be the legal document coming 7 back to me, yes.
8 Now, when that came back to you from Mr.
Q 9 Klingaman and his staff, would they normally attach 10 a copy of this particular form in a fiiled-out version?
11 A I am not sure of that.
.12 You don't remember one way or the other?
Q 13 A No, I am not sure of that.,
14 When you received back the material from Q
15 Reading with whatever memorandas or reports were 16 attached to it, what physically would happen to the 17 change modification form? Was it kept in'a file with 18 all these related documents?
19 A First of all, it would be logged back in 20 and whether it was approved. The next thing would be 21 whether the significance of the jobewas immediate action 22 required, and then you would get it onto a schedule.
23 And you would have to have parts, procurement of
-r S i
(_) 24 parts to do it; you would have~ to develop procedures 25 to do it. So it could either go for months -- even
1 Shovlin 124
/3 2 though the procedure has been approved, you can go 3 for months or even longer than that before actually 4 performing the change modification.
( 5 Q Now, I guess you know though, I am just 6 curious about the custody of the files.
7 A The maintenance department kept the
, 8 original change mod and work request.
9 Q So whatever it was that came back from 10 Reading, it would be put in a file somewhere in the 11 maintenance department and maintained there?
12 A Until at a period of time it was then O 13 transferred to document control.
They would put it 14 on microfilm.
15 Q How long after the material was received 2
16 back from Reading would that happen?
17 A It would never get on the microfilm until 18 the job was completed.
'~
19 Q Suppose a change request went up to Reading, 20 they disapproved it and sent the paper work back to
. 21 .your office, I take it you would put it in a file and 22 ,
it would sit there for some period of time?
23 A And the administrator would determine how --
1 -
-f 24 the 16ngth of time u$en she would want to send down a 1
I 25 number of completed or cancelled change mods or work '
I l
1 1 Shovlin 125 A '
k)m 2 requ.ests.
3 Q At some point she would take on the 1
4 responsibility to decide --
( 5 A For file space.
6 Q She would take on the responsibility to -
7 decide to have that on microfilm?
8 A Yes.
9 Q Do you have any i' dea as to what her 10 criterion was for how long documents wo,uld be kept 11 in hard copy form before they were sent out for 12 microfilming?
U 13 A It could be six months to a year.
14 Q Before the accident at Three Mile Island 15 Unit 2 at the end of March 1979, did you become aware 16 that there was leakage past the re' lief valves at the 17 hop of the pressurizer? .
18 A Unit 27 19 Q Yes.
20 A No.
, 21 Q It did not come to your attention?
22 A I don't recall.
23 Q Before'rhe accident at Three Mile Island
'-(O) 24 _ Unit 2 in late March 1979, did you become aware that 25 there was leakage occurring past the Unit 1 relief
1 Shovlin 326 2 valves at the top of the pressurizer?
3 A I knew there was --
what time frame?
4 Q At any time before March 1979.
( 5 A In Unit.1, yes.
6 Q When did you become aware of that?
7 A I don' t know ' the particular time frame.
8 I know -- I know that I was apprised of that.
9 MR. WISE: Let me have marked as B&W 10 Exhibit 902 a copy of a memcrandum dated March 11 12, 1976, submitted by three people, including 12 Mr. Klingaman of generation engineerin'g to you,
\- 13 Mr. Shovlin.
14 (Copy of two-page memorandum dated Itarch 15 12, 1976 was marked B&W Exhibit 902 for 16 identification, as of this date.)
17 Q Mr. Shovlin, do you remember seeing B&W 18 902 at or about the time it was written?
19 A Yes, 20 Q The subject of the memorandum is " Task 21 No. 2279 Leaking Pressurizer Safety Valves." What 22 was the occasion for your receipt of this memo?. ;
23 : A I don't recall that.
(d7 24 Q Do you recall that the pressurizer safety 25 valves had been discovered to be leaking at Unit 1 l 8
1 Shovlin 127 p
O 2 at or around the time this memo was written to you?
3 A As far as the time frame, I was aware of 4 leakage and I was aware of the discharge piping l
( 5 question as far as the cold springing of it.
6 Q What was the question regarding the 7 discharge piping?
l 8 A Whether there were stresses being imposed 9 on a discharge piping as it was flanged up to the valve, 10 causing some distortion that could caus.e the leakage.
11 Q How had that question come to your 12 attention? How did you learn of that?
13 A Well, I was involved with the design 14 engineers who came in to make some piping --
relieve 15 some of the stresses that were imposed on discharge 16 piping, took some deflection readings, and I believe 17 installed some instrumentation to stress gauges to 18 determine during hot conditions just what -- just I
~
19 what happened to the piping during hot conditions.
20 Q Did you have any knowledge as to why this 21 investigation was initiated?
(' i 22 A Because we thought that was possibly the 23 cause of the leakage, and I don't know whether it was
(~3 q) 24 the one valve, one of the discharge pipes or two, but 25 I know they thought this was a possibility of why the
q.
/,
_ l
\
< , d 1 Shovlin 126
.s 2 valve was. leaking.
3 Q How had it been discovared that the valve 4 was leaking, as best you now recall it? ,
( 5 A I would. assume --
I am not going to say I 6 assume. I am not'sure. I am not totally sure.
7 Q Do you recall whether the discharge piping 8 thermocoupias were reading high at or about that time?
9 A I am not sure of that.
10 Q Did you have any discussions with anyone 11 concerning what should be done about the discharge 12 piping in connection with this memo?
O 13 A I talked to the Gilbert engir.eers wit'h
~
14 regards to what they were going to do, what they 4 15 proposed to do, but they were still working with our.
s
,/
16 engineering, plant engineering people.
17 Q What was your role in this entire ~ l'ss,ue?
18 A Giving them support, cre.f tsme n , in order '
- 19. to loosen up the: restraints, the piping restr'ints, a -
20 break flanges -- maintenance functions.
21 Q You ,were to provide the men to do the work?
22 A I was t'o prcvido . t he m,e,n t 6' - d o the work,
'23 . whether it be contractor' people to support them or
,f g I
, e -
() 24 Mot Ed craftsmen. , ,,
25 : Q. Wede you in any way" involved in the .
3 t v~ rr + r - - - - -m +vb < ,--+m v w,---s w - r~~ ,v ~'- ~ +e--,s
4 1 Shovlin ,129 i 2 analysis? .
3 A No.
4 Q You will note that in their memorandum
( 5 back to you which we have marked as B&W 902, the 6 submitters, if I can call them that, suggested that 7 the RC-RV-2 should be rebuilt as planned and tested 8 and set to the procedure we are currently using, a
9 SP No. 1303-11.2. That appears in item c under 10 paragraph 2 on the first page of the memorandum.
11 Do you see that? 's-t 12 A Yes.
('" 13 . Q As we have identified befo e the RC-RV-2 is 14 the same thing as the pilot operated relief valve?
15 MR. GLASSMAN: You are asking whether this 16 witness knows that?
17 MR. WISE: Yes. .
18 Q You know that?
- 19 A Yes.
20 Q Do you recall the recommendation from 21 Messrs. Klingaman, et al., that the pilot operated 22' relief valve for Unit 1 should be rebuilt?
23 A I can't recall, you know, what the A'
.ts ,) 24 recommendation was as far as repair, only that the 25 procedure for testing-I was familiar with, and
-- ,, - y - , , , - , e -- -,e,g,-~-s --- - -
l 1 shovlin 130 !
t V
2 apparently in the past we cold tested the valves and 3 we found better setpoint results by hot testing, 4 and I believe that is the change there or that is the
([ 5 procedure 1303-11.2, but what repairs were recommended 6 I don't recall.
7 Q And you don't recall, given your earlier 8 testimony, whether the valve that was on Unit 1 as 9 of March 1976 was the original Unit 1 valve or the Unit 10 2 valve which had been installed at Un i.t 1 when the 11 original Unit 1 valve was removed 7
~
,_ 12 A Say that question again.
I i
\
13 Q We established earlier today, I believe, 14 that there was a time when the original Unit 1 PORV 15 was removed from that unit and replaced with the PORV 16 that had been supplied to Unit 2.
17 A That's correct. .
18 Q And I think we established that that was 19 done in late 1974, according to the records that had 20 been provided to us.
21 A Yes, I wasn't sure of that time frame.
(' 22 i Q And the records that we have indicate that 4 23 the Unit 2 valve was removed from Unit 1 sometime in
.r Y j, j 24 late '75 or early '76, but you don't have any personal 25 recollection of that.
1 Shovlin 131
(~h V
2 A No.
3 Q so you are not able to testify today 4 whether the valve that this memorandum talks about,
( 5 and it was written in March 1976, is the valve that 6 was originally supplied for Unit 1 or the valve that 7 was originally supplied for Unit 27 8 A No, I can't answer that.
9 .Q You don't know which valve Mr. Klingaman 10 is talking about in this memorandum? ',
11 A No.
12 And you today don't have any recollection Q
13 as to what you did in response of this memorandum I
14 concerning the rebuilding of whatever valve it is that j
15 Mr. Klingaman is talking about? 3 16 A No.
17 Q There are some handwritten' notes on the 18 margin of this particular document. Would you look 19 at that briefly and see whether any,of those appear
~
20 to be in your handwriting?
21 A No.
22 Q None of those are yours? i 23 l A No.
( 24 Q Do you know what, if anything, you did 25 with this memorandum after you received it?
- . . . ,. -_- , -- , ,. - - . . .. .- - - . ~ -. .
I i
1 Shovlin 332 I O
O 4
2 A I am sure it ended up --
I am sure there 3 was action taken and I can't recall what particular 4 action except, as I mentioned in the previous testimony,
( 5 of knowing of the change of the valve and knowing there 6 was a dimensional problem.
7 Q Do you know whether whatever --
8 A This could have been -- I am sure there 9 was action taken and this is in the file right now, 10 on file. '
11 Q Do you know whether after receipt of this 12 memorandum and the performance of whatever actions O
. 13 were taken, the problem concerning pressurizer valve 14 leaking at Unit I was corrected?
15 MR. GLASSMAN: Which problem are you talking 16 about, the one that he was aware of or --
17 MR. WISE: Yes, the problem that prompted 18 the exchange of memos and the wo'rk that he has 19 described.
20 Q As a result of that work, did you come to 21 a point where the problem was corrected?
22 A Yes. i 23 , Q And leakage past the pressurizer relief (N
a
) 24 l
valves stopped at Unit 17 25 A As far^as my knowledge, yes.
- l, -
~ , . . - .. . . - - . .
1 Shovlin 133 O
-Q.
2 Do you recall whether that.was accomplished Q
3 shortly after this memorandum was received by you?
4 A. When they performed the maintenance, and
( 5 the time. frame I don't know, and they tested the valves 6 in the hot setting, the problem went away.
'7 Q Now let's switch to Unit 2. Do you know
' 8 whether the same hot testing procedure that was used l '9 for testing the valve on Unit 1 after Mr. Klingaman's 10 memo to you in March 1976, was used fob testing the
! 11 TMI-2 PORV7 12 A I can't attest to that, but I can only say --
\-)
13 Q You don't know?
14 A No, I don't know.
15 Q I believe you said earlier you are not 16 aware of the fact of whether or not there was leakage i
17 past the pressurizer valves at Unit 2. ~
18 A That's correct.
19 Q I would like next to show you what has 20 previously been marked as B&W Exhibit 456.
, It is a 21 copy of TDR'No. 160, prepared by GPU Service Corporation
'22 after the accident. The title is "PORV Investigation." ;
23 We have had testimony from another witness about the l
(~h
(_/ 24 preparation of the report and'I don't mean to question 25 you about the specific conclusions that he reached. '
- 2. . ., _ _ . - _ _ - . , _ . _ _ - _ . _ . , . . _ , _ . , . _ , - . . . - - - - . - _ . . -
1 Shovlin
, 134 2 During his work, however, he collected some materials
- 3. concerning the history of the pilot operated relief 4 valve and particularly that one that was supplied for
( 5 Unit 2 and was installed at Unit 2 at the time of the 6 accident.
+
7 Now, if you turn to page 3346 as marked 8 in the lower right-hand corner for the purposes of i
9 litigation, you will find a form called a material 10 transfer request, dated September 26, '1974. Do you 11 see that?
12 A Yes.
O 13 Q Are you familiar with this kind of form?
14 A Not totally. I know this form exists for 15 transferring materials from one unit to another, but 16 as far as knowing the details of it, you know, the 17 description, what is outlined on this form, no. But 18 I knew the form exists for transfer of materials 19 between units. And it was a control type document.
20 Q You were not required to be involved in 21 the. approval of that?
- 22 A In some instances, yes. !
23 Q And in some instances no?
(~h .
(_) '24 A And in some instances, a much higher 25 authority.
, - - - ,e- m -. -,,m-. .- r. . - , , u ,-.-r - , ~ ~ ,,n-- -- y p-e,. -v9 s - <-ap,,y -,,,~---e , -g-
1 Shovlin 135
[b V
2 Q Would you normally receive a copy of the 3 transfer request if material is being shifted from 4 one unit to the other?
( 5 A' I don't. recall. I don't recall having 6 this type --
this transfer request form as part of 7 our filing system.
8 Q Do you know Mr. S. Levin?
9 A Sandy Levin, yes.
10 Q Who was he?- ',
11 A He was a GPU -- he was at that time a GPU l
12 engineer on a construction arm.
O) t
- 13 Q Would you look at the next attachment 14 which begins at page 1348 as marked for. purposes of 15 this litigation. You will find a file memo there from 16 Mr. Levin to file, dated October 10, 1975. The subject 17 is a record of a telephone conversation concerning the 18 RC-RV-2 or pilot operated relief valve. Would you 19 read through that briefly.
20 Did you ever see a copy of this memorandum?
21 A I can't recall, but I know there was a lot I
(( I 22 of correspondence and conversation on where are the 23 valves. There was so much talk and changing that
(~x
( ,) 24 at one point I wasn't sure whether the valves, Unit 2 25- valves, were all in Unit 1 or all the Unit 1 valves
i i
Shovlin 136 2 . were on Unit 2.
3 Q Did you ever have a conversation with 4 Mr. Herbein about'the need to expedite the.
( 5 decontamination of the Unit 2 valve and its return 6 to Unit 2 from Unit 17
- 7. A I could have.
8 You don't remember one way or the other?
Q 9 A No, I don't.
10 Q Now, if you would go to page 1375. On 11 that page there is a two-page form entitled " Work 12 Request Approval TMI Nuclear Station." It is for. Unit O 13 2 and this particular one is work request No. 1467.
14 Are you familiar with this work request form?'
15 MR. GLASSMAN: The particular one or the 16 form itself?
17 MR. WISE: The format. l 18 A The format, yes.
19 Q Was this a Met Ed format or GPU Service 20 format?
21 A This was Metropolitan Edison.
(. 22 I
Q So this was something filled out and :
23 submitted.to the maintenance department, or would it Q 24 be filled out by the maintenance department?
25 A No, anyone could fill out this work reque'st.
~ _, ., _ _ -. .._,_ . . _ . . _ . ~ . - - - . . , . .- -- - . , . , _ _.___ .._ .-
l 1 Shovlin 137
\-)
2 Q And eventually it would come to the 3 maintenance department for processing?
4 A Exactly, yes.
( 5 Q Now, would you look at the second page.of 6 the form. At the very bottom of the page, item 23, 7 which is the last item on the page, says: Supervisor 8 of maintenance work request and procedure are complete 9 and signed off as required. Change / modification form 10 has been signed off as required. Mach'inery history
- 11 entry has been made, if required." And there is a 12 signature beneath that which is extremely hard to read.
! \-
13 Are you able to make out whose signature that is?
14 A Yes, J
15 Q Who is that?
4 16 A Bill Metsger.
17 Q Who is Mr. Metsger? -
! 18 A He was a supervisor on Unit 2 maintenance.
19 Q~ He worked for you?
20 A He worked for Sieglitz.
21 Q Who worked for you?
22 A Who worked for me.
23 Q And that appears to you to be his signature?
i ) ,
24 A Yes.
25 Q The next exhibit begins at page 1378.
1 Shovlin 138 b)
V j 2
Unfortunately, on the Zeroxing of this particular '
3 exhibit, or maybe the microfilming, the page is cut 4
in half so you will have to look at page 1379 and go C. 5 one page forward to that, but you will see there is a 6
copy of another work request. procedure -- not another; 7
there is a copy of a form called work request procedure.
O Do you see the part that I am talking about?
9 A Yes.
Q Was that a form that was i use at TMI?
11 A This was not this was a procedure that
. 12 was developed apparently with the help of the vendor.
t/ 13 Normally a procedure.is formalized and typed with a 14 cover sheet with the approval authorities, quality 15 control and the unit superintendent's signature 16 would be on it. Although this did go through the 17 normal approval channels, but this proced'ure was 18 developed apparently while the vendor was here.
19 Q As I say, it is unfortunate that during the 20 microfilming or the copying, the right-hand side of the 21 page was apparently cut off, but from what we have of the top cover sheet, it appears that this is a procedure 4 which was titled " Repair and Test of RC" --
then the
(
O) 24-rest of it is cut off, but I think from the attached 25 papers, handwritten notes, you will note that the
1 Shovlin 139 n.
V
. 2 procedure is titled " Repair of RC-RV-2," and the cover 3 form has a space at the bottom for recommendation of 4 approval by the supervisor of maintenance and a
( 5 signature line. Is.that your signature?
6 A Yes.
7 Q Do you recall reviewing this particular 8 procedure and approving it?
- 9 A Not this very moment, but after looking 10 the procedure over, I do recall it.
11 Now, this is for Unit 2, is it not?
Q 12 A- I understand, yes.
' O 13 Q And do you recall what prompted the 14 preparation of this procedure?
15 A No.
16 Q There is an indication that this was
, 17 approved in October 1977. As a matter of' fact, you 18 will note that Mr. Sieglitz, the maintenance supervisor, 19 signed the procedure on October 25, 1977, and that the j 20 quality control supervisor, Mr. Daniels, signed it 21 on October 26, 1977.
j 22 A But in the maintenance.the signature ;
23 authority -- we don't hold up the job because Sieglitz, 24 supervisor of maintenance Unit 2, is not on site.
(f .
25 other individuals have approval authority.
l
.._._._.-1 . _ , _ _ . . . . _ , . _ _. .. , .- . - . . . , _ _ _ _ , - ,
1 Shovlin 140
(%- j\
2 Q But all I want to know is whether you 3 recall that at or about October 25 or 26, 1977 there 4 was a request for approval of this particular procedure.
4E 5 A aieht now it rines a de11 to me that there
, 6 was a vendor on site and we used a vendor-supplied 7 procedure.
8 Q Now, do you recall what it was that prompted 9 the necessity for the prep. ara
- tion of this procedure?
^
10 A No. ,
11 Q You don't recall what problem had occurred 12' that caused this to be initiated?
O 13 A no.
14 Q At page 1382 there is a handwritten data 15 sheet which appears to be part of your work request 16 1467 with certain tests listed. Do you know anything 17 about the performance of these tests as indicated on 18 this data sheet?
19 A No, but this is a standard -- the normal 20 generic procedure would have the same information with 21 blanks which would be filled in at the time you are 22 performing the test.
i -
I 23 ;
Q Did you ever get a report on what the tests '
I
' A.
(,) 24 showed when the valve was tested?
I 25 A I have --
1 Shovlin 141 C ~
2 MR. GLASSMAN: Are you talking about a 3 particular test?
4 MR. WISE: Yes.
( 5 Q Did you.ever get a report back on this 6 March 1979 test?
7 A I don't know.
- 8 g Did you ever get a report back on this 4
9 October 1977 procedure change and what happened after 10 the procedure was applied in the test bf the PORV7 11 A No, I don't remember.
12 g would you look at the next page, 3383.
O V 13 This is a typed form. The department is listed as i
14 mechanical maintenance. The unit is listed as No. 2.
15 The system 1s reactor coolant, and the evaluation i
16 surveilled is listed as RC-RV-2, inspection, repair 17 and testing. The date of surveillance is October 26,
'18 1977, and work request 1467 is referenced.
19 Do you know whether you ever eceived 20 a copy of this form?
- 21. 1, A I could have. I don't recall.
- k. N 22 Q Do you see Mr. Cotter's signature on this f )
23 ,
form?
(~j3 24- A Yes.
25 Q. Do you recognize that as his signature?
1 shovlin 742 2 A Yes.
3 Q I just noticed that if you would turn to 4 page 1385, I believe there is another copy of the work I 5 request procedure form, and on this one we have got 6 the full page as opposed to the half page that we 7 were stuck with earlier. There does appear to be a 8 difference in that the earlier one showed a signature 9 by.Mr. Daniels, whereas the one on page 1385, which 10 otherwise appears to be identical, doeb not have Mr.
11 Daniel's signature on it. Is it true that these were 12 made up in multiple forms?
O 13 A No. I mean I have no idea.how that 14 transpired. If someone was making copies of the 15 procedure for the department or the vendor or whoever.,
16 I don't know.
17 Q Now would you turn to page 1392. There 18 is a form that appears there which lists the system 19 and the unit, and then has a section for problem-
, 20 description and a section for the proposed resolution 21 and a section for action. Are you familiar with this 22 kind of form? 1 23 A Yes.
l r' i k.)% 24 Q This is a problem report?
25 A GPU. problem report.
+ - - - - - , -,- -
we
1 Shovlin 143 m
2 Q It is very hard to read the handwriting on 3 the form. Some of it appears actually to be cut off l 4 on the microfilming, particularly at the left-hand i
( 5 margin, but as best.I can make out, this is a problem 6 report relating to Unit 2, the system listed'is the 7 reactor coolant system, and the problem description 8 is as follows: -During the running of this test 9 the temperature upstream -- downstream of RC-R2 10 . j was put on the trend recorder. When RC-V2 was --
11 and then the next word has been cut off the page --
12 the temperature was 165 degrees Fahrenheit. As soon 13 as pressure started to increase to 2255 the temperature 14 downstream of RC-R2 increased to -- and I can't read i
15 the temperature. It is some number of degrees ,
16 Fahrenheit. When RC-R2 opened temperature increased 17 to 250 degrees Fahrenheit, and when RC-R2 reseated 18 temperature gradually decreased to 195 degrees 19 Fahrenheit. When RC-V2 was closed - RC-R2 downstream 20 again returned to -- and you can't read the temperature 21 but it is some amount of degrees Fahrenheit. This 22 indicates that RC-R2 is leaking and needs to be l 23 you can't read the word, it may be " replaced" -- <
f~h) g 24 A v Resolved.
25 Q Please resolve.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ .J
4 2
1 Shovlin 144 2 MR. GLASSMAN: I am just going to say, 3 Mr. Wise, you seem to be an expert in attempting 4 to read handwriting. I commend you on your
(_ 5 effort, though I must say that some of the words 6 which you mentioned are - particularly I think 7 you put in the word " downstream." You put in the 4
8 word "i nc r e a s e ,'" even just the word " resolve" 9 now may be mighty attempts, but I don't think i
10 anyone who is reading it could find those words.
11 There are letters which may be portions of 12 such a word, but it is cut off and is just pure I '
! .13 surmise. I would suggest at this point --
14 MR. WISE: I think it is better than pure
, 15 surmise. We have been dealing with this case 16 for over two years-and I think,we have enough 17 knowledge at this point of what the PORV is and 18 what effects on the system parameters its 3,
t 19 opening and closing has to do better than make 20 a pure guess or surmise what is there. -I will
, 21 agree with you that because of poor copying, 22 parts of the words are obscured or left off,
+
~ 23 but I think that in general I have tried to do .
4 .
r l 24 a. fair reading, and.certainly the witness'can l
{
25 disagree'with me if he thinks my reading of it. .
l
l 1
Shovlin ,
145 9
is out of context or an improper characterization 3 in any event.
4 MR. GLASSMAN: I would like to note I
( 5 am not trying to commend you or reprimand you.
O All I am saying is that you are'not particularly 7
qualified to testify in this matter and the 8
witness is not a handwriting expert either. If 9
you have a question as to his knowledge,.please 10 do so and ask him. -
11 Q After the description of the problem, there
/" is a section in the form that says "For resolution by,"
(_ 13 1
and someone has written " Met Ed -
Shovlin." The date 14 of this problem description is October 5, 1977, and 5
the date sent to you for resolution is indicated as 16 being October 5, 1977.
17 My question is: do you remember receiving 18 this and the particular problem that is described 19 I here? l 1
00 A No.
9
~1
( Q You don't have any recollection of this no
~~
I particular problem description? :
23 i A No. !
/~N ,
~
Q And obviously you don't have any idea 9
~5 what, if anything, you did as a result of receiving
.. - . . L-...-- . -. . . . - . - - . , . . _ _ _ . . . . , - - , - .- - ,
1 Shovlin 146 i
2 this?
4 3 A What I did -- Met Ed, Shovlin --
I 4 passed it on to mechanical maintenance supervisor
( 5 John McGarry. It got onto an action item. This system 6 did not belong to me at the time. I was doing a work
, 7 function for GPU startup and so apparently --
8 MR. GLASSMAN: I just want to make clear
. 9 you say "apparently," Mr. Shovlin. You should 10 he testifying as to knowledge, i. don't know if 11 you are speculating or you are saying what 12 might have happened.'
~~j '
13 A Looking at this document, the valve was
- 14 tested and reinstalled in a timely fashion, so-15 apparently -- well, not apparently, but the problem 16 was corrected.
17 g In the caption labeled " Proposed Resolution" 18 someone has written in a number of initials with 19 signature blanks after each set of initials. There 20 'i s a set of initials DMS and someone has signed next 21 to that. Did you initial that?
22 A That's my initials, yes. .
. 23 ; Q what proposed resolution were.you approving O
(f 24 there?
25 A Apparently the valve was leaking through 1
l Shovlin 147 O
V 2 and the valve was required to be overhauled, tested, 3 and reinstalled, as was done.
4 g Do you know whether this work corrected
( 5 the increased temperatures in the discharge piping?
6 A N6.
7 Q Do you have any recollection as to whether
. 8 the problem continued?
9 A No.
10 Q You don't know what happen $d?
11 A No.
12 Q Now let me ask you to turn back to page 13 1361 of this Exhibit 456. On page 1361 you will find 14 a letter dated January 25, 1979, from a Mr, --
I 15 believe it is Frost. It is very hard to, read -- of 16 Dresser Industries, addressed to Mr. Lance of 17 Metropolitan Edison in Reading. The subfect is a 18 purchase order by Metropolitan Edison for,a replacement 19 valve, and I believe the designation is that of a i
20 pilot operated relief valve. The letter concerns a 21 purchase order submitted _by Metropolitan Edison for 22 a replacement valve. I 23 ; Earlier I asked you whether a spare.had l O
() 24 ever been ordered or purchased for the pilot operated 25 relief valve aside from the original valves that were L
1 Shovlin 148 O
2 supplied for Unit 1 and Unit 2. Does this letter, 3 which specifically references the fact that a purchase 4 order was put in, help in any way to refresh your
( 5 recollection as to when the order was placed?
6 A No.
7 Q Did it ever come to your attention that
'8 in response to the purchase order Dresser forwarded 9 to Metropolitan Edison a recommendation for several 10 design improvements?
11 A No, 12 Q Would you look at the next page in the f
\_
1:L exhibit. It is page 1362. It is a copy of the 14 attachment that is referenced in Dresser's January 25, 15 1979 letter to Met Ed, and there is a description ,
16 there of certain design improvements and changes 17 that Dresser was calling to the attention of Met Ed.
18 Did you ever see a copy of the attachment 19 to the Dresser letter?
20 A I don't recall.
21 .Q Do you remember ever having it called to 22- your attention that in January 1979 or early February 23 , Dresser was recommending changes or. improvements in ,
r' - .
t
. k,_,,s) 24 I
the PORV7 f 25 A In January '797 l '
s - - __ -_- ,. , , . , _ .. . . . . , . , . - -
1 Shovlin 149
( .
y/
2 Q Yes, that is when these documents are dated.
3 A No.
4 Q Did your maintenance department have any
( 5 responsibility for identification of leakage from the 6 reactor coolant system during power operation?
, 7 A No.
8 Was it ever brought to your attention Q
4 9 before the accident at the end of March 1979 that there 5
10 had been an increase in the unidentified leakage at 11 TMI-27 12 A No.
N_)
- 13
- Q Was that ever discussed at one of the 14 three weekly meetings that were held between you and 15 Mr. Miller and the other --
16 A It could have been.
17 You just don't' recall?
Q 18
~
A I don't recall that.
19 You don't recall ever being asked to do Q
~
20 anything in order to help resolve the increase in 21 unidentified leakage?
{ l 22 A The only thing I was asked to do was to ,
23 look at a change in the reactor coolant drain tank ,
n i I
, \m./ 24 cooler capacity. ,
25 Q When were you asked to do that?
L 1 shovlin 150 2 A I can't recall.
3 Q was it sometime shortly before the 4
4 accident?
5 A No, it was sometime earlier than that.
6 Q How much? Years,, months?
7 A Several years.
8 Q I am speaking about events that occurred 9 in January 1979 through the end of March 1979. You 10 don't recall anything during that time. frame?
11 A No.
12 Q You don't recall being made aware at that 13 time that there were elevated temperatures in the 14 discharge piping?
15 A No.
16 Q Leading away from the top of the 17 pressurizer? -
18 -A No.
19 Q Do you-recall being advised that the
~
- 20. temperature and pressure in the reactor coolant drain 4
21 tank was increased over normal levels during the 22 January to March 1979 time frame?
l 23 l A No. No. !
k]
s._f 24 Q And you don't recall being asked to do
. 25 anything with respect to that condition, if it existed?
i t
- l. ..
. . - - _ . _ - . - -- - _ ._ . , _ _ a- _ _
1 Shovlin 151 i /~N 2 A If it was that time frame I am not'sure.
3 only the reactor. coolant drain tank cooling capacity.
4 Do you recall any work request being Q
( 5 submitted with respect to repair of the relief valves 6 at the top of the pressurizer during the January to 7 March 1979 period?
8 A No.
9 Q Do you recall any attempt to determine 10 which, if any, of the relief valves at the top of the 11 pressurizer was leaking during the January to March 12 1979 period?
k) 13 A No.
14 Q You don't recall assigning anybody to 15 that task? .
16- A No.
17 .And you know nothing'about th'at?
Q
^
18 A I d,on't recall anything about that.
19 Q You were;at the Island between January and i
20 March 19797 21 A Yes.
I 22- And you were attending the meetings that Q
23 were being held on a regular basis by Mr. Miller with
/~N 24 km) his staff?
'25 A Most of them, yes.
., , . , . , , .- -- . .- . .--.. - - . - - . - - - . , - - . . . - . , - . ~ . - . - . - - .
l 1
1 1 Shovlin 152 0 2 Q And that was approximately three times a 3 week, I believe you said. Plan-of-the-day meetings.
4 A The plan-of-the-day was not necessarily C 5 attended by Mr. Miller at all times, nor was the 6 plan-of-the-day attended by myself. There were 7 representatives that would be sent in the absence of 8 Mr. Miller or the operations supervisor or the 9 maintenance superviscr, so I did not attend every t
10 meeting.
11 Q When you did not attend the plan-of-the-12 day meeting, did you send someone in your stead?
V 13 A The supervisor.
14 Q Was it the practice for him to report 15 back to you on significant items that occurred at the 16 plan-of-the-day?
17 A It was documented. ~
18 So you got a written report from him?
Q 19 A I got a written report every day.
20 Q Aside from the plan-of-the-day meetings 21 that were held on some regular basis among the i
22 management group at the plant, that is, Mr. Miller and 23 you and the supervisor of operations and the
\ l s.../ 24 I superintendents of the two units?
25 A only to do with personnel and budgetary
F 9
, 1 Shovlin 153 C) -
2 matters.
3 Q You earlier in.your testimony described i
4 ' something that occurred, I believe, three times a 5 week. I think you said Mondays, Wednesdays and 6 Fridays. Is that something different than plan-of-1 7 the-day or is that the same-thing?
8 A No, that is the same thing.
J 9 Q Well, during the January through March 4
'10 1979 time period, did you have anyreghlarperiodic 11 meetings with Mr. Miller, Mr. Miller and the other 12 members of the management staff, concerning the f
O 13 operation of the TMI units?
14 A No.
i 15 Q Do you ever recall any discussion before 16 -the March 1979 accident at TMI-2 about the-necessity 4.
i 17 to continue operation despite leakage past the 18 pre'ssurizer relief valves because no replacement or 4 19 spare valve was available in the event that inspection 20 ~showed the valve had to be replaced?
- 21 A No. ,
22 Q And you today.have no recollection at all l-4 j
23 l as to when.or why a spare replacement valve was ordered r: A ~Y
- () 24 from Dresser in 1978? l 25 -A Time frame it was ordered? ,
l
, ,,.-. _ . . . _ . _ , . _ . ~ . , _ . . _ . . . . . . . - . - _ -..-
1 shovlin 154 2 Q Yes.
3 A No.
4 Q And you have no recollection as to why
( 5 that was done?
6 MR. GLASSMAN: You don't want the witness 7' to guess?
8 MR. WISE: No, I don't want him to guess.
e 9 A I previously testified that we only had 10 two and certainly it would be prudent to have a I
11 spare, and I am sure that I signed a requisition to 12 purchase a spare, or if not me, the'next level of O 13 management.
14 Q You wanted to have a spare. I guess I 15 am now asking it in a little bit more detailed way, 16 as to whether you remember specifically what U occasioned the concern for obtaining the-spare.
18 A No.
19 Q And it does not refresh your recollection
~
20 if I suggest that there was leakage past the relief 21 valves.and TMI management, including you and Mr.
22 Miller and others, wanted to obtain a spare so that :
23 when the plant was next shut down, the valve could be l
i 24 replaced?'
j 25 A That is a possibility, but I don't recall 3
1 shovlin 155 J
k 2 that.
3 Q You don't recall that?
4 A No.
5 Q one more thing about the pilot operated 6 relief valve at TMI-2. That valve, as I understand 7 it, is located at the top of the pressurizer. Is 8 that your understanding?
l 9 A Yes.
- 10 Q And I have seen some drawidgs that 11 indicate that there is some kind of a ceiling, in a 12 layman's term, over the top of the pressurizer and r
(_ ~.
13 between it and the discharge piping that leads away 14 from the pressurizer. Do you know whether that is true?
15 A No, I don't know what you are, referring to.
16 Q The pressurizer is a large metal vessel; 17 is that right? -
18 A Yes.
19 Q And it is cylindrical?
20 A Yes.
]
)
21 Q And it is made out of metal?
22 A Yes. i 23 Q At the very top of it, there are, as I ,
l i
(~)%
s_ 24 understand it, three pipes leading out of the top.
25 Two of those pipes go to the code safety valves and
1 Shovlin 156 v
2 one of those pipes leads to'the pilot operated 3 relief valve; is that right?.~, ,
4 A- That's correct. -
5 Q And between the pilo t, operat' d relief 6 i valve and the top of thepressurizar, there is a ' ~
7 block valve; is that correct? ,
8 A That's correct. '
g 9 Leading away from tho_ valves, the code Q
10 safeties and the pilot operated relief valve, there is 11 some piping which I believe we have been discussing, q 12 ~
sometimes called the discharge pipi~ng,-rand that
.)
13 eventually connects up and runs en down t.9 the 14 reacto_r coolani. drain tank; is that right?
15 A Tha 's correct. ,
16 Q Now,'the thermocouples that are attached 17 to the discharge piping are attached,as'they say, 18 I guess, downstream of the valves; is that right?
19 L
~ A That's correct.
20
[ Q And there ismone attached downstream from 4
21 the pilot operated rell'ef valve and one attached t downstream from each of the two code sai.e tie s ; is that 23 right? <
l
' \.
C)h 24 yes.
' s x - A' x l l -
25 And tihose Q -
are strapped'right,onto the - -
.~
'. y
- c g
, -Q . L , . _ , , .a rl ~ . - , . . H: +-~ r ~ ~ ' - - - " ' ~~"
1 Shovlin 257 p
2 discharge piping itself; is that right?
3 A When you use the word " strapped," they~
4 were secured. I don' t know if they were strapped'or --
5 Q Bolted or whatever, but in some way they 6 are attached to the piping itself on the outside of 7 the pipes they are not inside the pipe.
8 A Right, they are outside the pipe.
9 Q Now, the valves themselves are located 10 directly above the top of the pressuri$er; is that 11 right?
12 A That's correct.
. 13 Q And then after the valves,.the piping 14 takes a 90-degree turn and leads away and off toward 15 the piping that leads on down to the reactor coolant 16 drain tank; correct?
i 17 A That's correct.
18 Q Do you know whether there was any insulation 19 between the metal at the top of the press rizer and 20 the. location of the thermocouples that were attached 21 to the discharge piping immediately downstream from s
22 the three relief valves? 1 23 A I have no idea. Normally the whole thing. -
- n i J.
\m /- 24 is mirror insulation.
25 Q Would you describe what you mean by u_
- _ _ . -. .= - - - -
1 Shov11n 158
(- -
-(/
2 mirror insulation?
3 A If you have a piece of pipe out here and 4 you have asbestos around it, well, this is a mirror
( 5 reflective type, insulation that is around your 6 reactor cooling system piping and pressurizer.
7 Q Do you know whether there was supposed 8 to be insulation around the discharge piping?
i 9 MR. GLASSMAN: What do you mean by 10 " supposed to be"?
11 l MR. WISE: Was it supposed to be there.
12 MR. GLASSMAN: Do you mean whether there O 13 was some original design intent?
14 MR. WISE: Yes.
15 Q In other words, is that the way it was
.16 supposed to be?
17 A Normal design, yes.
18 Q Do you know whether that insulation had 19 been removed at any time prior to the accident in 20 March 19797 21 A I have no idea.
22 Q Do you know whether there was any kind of 23 barrier interposed between the top of the pressurizer, ,
d) 24 the' top of the actual metal cylinder, and the portion 25 of the piping where the thermocouples were located?
1 Shovlin 159 r~N. -
2 A I have no idea.
3 Q I have seen some drawings that at least 4 indicated to me that there was at least some kind of --
( 5 and I will.use a layman's term -- ceiling, but it may 6 be a different term in the engineer's parlance --
"7 A I have no idea what you are talking about.
- 8. Q Insofar as you know, the thermocouples 9 were exposed at the top of the pressurizer itself?
10 When I say exposed, there was no barribr between the 11 top of the pressurizer and the thermocouples.
12 A I think you mentioned, and I agreed, 13 the thermocouples were on a discharge piping leading 14 down upstream from the valves and th'at is not on the 15 top of the pressurizer. ,
16 Q The pictures I have seen indicate that the 17 thermocouples are located at a point where they are 18 still directly over the pressurizer itself. You 19 don't know one way or the other?
20 A I have no idea ~.
21 Q You don't remember seeing that yourself?
i i
22 A No.
{
23 Q And you.are not familiar with those
("N . !
Ts/ 24 thermocouples enough'to be able to tell us whether 25 they were over the pressurizer or whether they were
l l
l l
1 shovlin 46a i
2 somewhere over to the side?
3 A That's correct.
4 Q And you are not able to tell us the 5 condition of the insulation on the day of the accident?
6 A That's correct.
7 Q And you don't know what the condition of 8 it was before the day of the accident?
9 A That's correct.
10 Q Let's talk about something'else for a 11 moment. I would like to discuss with you the 12 condensate polisher system at TMI-2. You are familiar a 13 with that system?
14 A To some degree, yes,
~
15 Q It is a system on th.e secondary side of the 16 plant, as I understand it.
17 A Yes. -
18 Q It has something to do with demineralizing 19 the water that is used in the secondary system, 20 A That's' correct.
t 21 Q As I understand it, the condensate
( l i
22 1 polishers are located upstream of the main auxiliary --
23 I of the main feedwater pumps in the system.
1
[% t
(_)- 24 l A- .That's correct, l
25 Q So that water that is going to be inserted l l
i l
1 Shov11n 161 2 in the steam generator by the main feedwater pumps must 3 first pass through the condensate polishers during the-4 normal operation of the system.
5 A That is. correct.
6 Q Now, prior to the accident at TMI-2 in 7 March 1979, there had been several problems experienced 8 with the condensate polishing system, had there not?
'9 A I have no knowledge of that.
10 Q Was it ever brought to you$. attention that 11 the condensate polishing system was malfunctioning 12 from time to time before the accident?
I O 13 A No. -
14 Q Were you kept cdvised on a regular basis 15- of maintenance problems as they occurred at TMI-27 16 A Not -- when -- you are talking about in 17 a startup mode, and no, I would not be. -
18 Q Well, when you took over the responsibility 19 for maintenance of TMI-2 at the time it went commercial 20 in the end of December 1978, did you personally or e 21 did you have someone on your staff who was assigned-to 22 make a review of the maintenance issues such as they 23 were at TMI-2 to familiarize-yourself with what had ,
f~' f
_ (, 24 been going on?
]
25 A .Mr. Sieglitz, the supervisor.of maintenance
1 Shovlin 262 m
2 at Unit 2, ran the maintenance activities at Unit 2, 3 and unless there was some really significant problem, 4 he didn't have enough people to support his operation,
( 5 that type of -- or an alarming problem, but we were.
6 still going through startup.
7 Q Were you ever advised of an incident that 8 occurred in the fall of 1977 which involved a buildup 9 of resin in the condensate polishers, followed by t
10 a trip of the main feedwater pumps? ,
11 A I didn't remember that inci-dent at that time.
12 Q You had been advised of it in preparation 13 for this?
14 A Yes 15 Q And has your recollection in any way been 16 refreshed concerning that incident?
17 A If there was any support at that time, it 18 would have been utility type labor force to go and help 19 clean up the resin, but I don't recall the incident 20 or why it happened or how it happened.
21 Q Do you recall another incident involving 22 the condensate polisher system that occurred in, ;
23 I believe, May of 1978 which resulted in a loss of 1 .fM l . C) - 24 main feedwater?
25 .g go,
,+ w -w -w< w
,e - - - , +, w y,,n - .-
1 Shovlin 163
[\
O 2 Q Do you recall any consideration being 3 given to whether an automatic bypass should be 4 installed at TMI-2 for the condensate polishers?
( 5 A I was in on a discussion on that particular 6 problem.
7 Q What do you reca'11 brought that to your 8 attention?
9 A The concerns of one of my supervisors --
10 not a concern, but he thought it would'be an appropriate 11 change.
gg 12 Q Who was the supervisor?
(_)
13 A weaver, Doug Weaver.
14 Q What was his position?
15 A He was lead foreman in the I&C, 16 instrument and control area.
17 Q He worked for Mr. Sieglitz in- Unit 27 18 A Yes.
19 Q What did Mr. Weaver report to you?
20 -A Not report --
he didn't make a report to l l
21 me.
22 Q What did he tell you?
23 -A He thought it would have been a good idea rr k-) 24 to install the bypass, and I asked what was -- you 25 know, looking at Unit l's configuration, so when I 1
l I
1 shovlin 164 e~
k_)g
, 2 did pursue it, I pursued it with Mr. Toole, and, you 3 know, he felt that a bypass was not necessary and 4 the plant would -- under design operating conditions 5 could handle any loss of feedwater or -- in the normal 6 fashion without any problems and that wasn't really.
7 a significant problem.
8 Q Do you remember whether there were any 9 writings prepared that reflected these discussions that 10 you had with Mr. Weaver and then later with Mr. Toole?
11 A No.
l l 12 Q It was all oral, as best you can recall?
13 A To the best I cah recall, Mr. Weaver's l
l 14 conversations with ne were oral.
15 Q Was your conversation with Mr. Toole oral?
16 A Yes.
17 Q And you never put anything into writing 18 about this?
19 A No.
~
20 Q Do you remember about when this occurred?
21 A During startup. l (L
22 Q You don't know whether that was in '77 23 ; or '78?
[)
\_/ 24 A No. Well -- no, I have no idea.
25 Q Were you aware at the time of the March
1 Shov11n 165 2 1979 accident at TMI-2 that there were 13 outstanding 2 work requests with respect to the condensate polishing 4 system?
( 5 A No.
6 Q Did that come to your attention after the 7 accident?
8 A No.
9 Q My telling you tha't today is the first you 10 heard of it? -
( 11 A The first that I can recall hearing of it, 12 that's correct.
13 Q Were you aware that during.the three 14 months prior to the March 28, 1979 accident at TMI-2, 15 13 other work requests had been carried out on the 16- condensate polishing system?
17 A No. '
18 This is the first you heard of that?
Q 19 A I can't tell you_how many outstanding job 20 tickets they had on Unit 2 at that particular time.
21 Q Was it ever brought to your attention that 22 there was a problem with water getting into the ,
i 23 instrument air lines on the condensate polishing system?
O
-( / 24 A I knew that was -- the time frame I knew 25-' it was after the accident.
1 Shovlin 166 b)
V 2 Q That was not brought to your attention 3 before the accident?
4 A No, it was after the accident.
( 5 Q So before the accident, you were unaware 6 thAt that was a problem at TMI-27 7 A With --
8 Q That is, water getting into the instrument 9 air lines for the condensate polishing system at any 10 ' time before the accident on Unit 2. ',
11 A No.
g 12 Q Am I correct that before the accident at b 13 TMI-2 on March 28, 1979, your maintenance department 14 consisted of approximately 135 people?
15 A Supporting two units? l 16 'Q Yes.
17 A That is roughly around the number.
18 Q Am I correct that before Unit 2 was turned 19 over to Met Ed for commercial operation, your 20 maintenance department was approximately the same size?
21 A There could have been some increase in k "
22 numoers, a few. ,
23 Q Could you give me roughly the number of
/'N b'
(.,) 24 people that you added at the time you took on 25 responsibility for maintenance of Unit 27
1 Shovlin 167 O
~
2 A It probably increased about 10, 15 people.
3 Q So you went from a staff of, say, 120 4 or 125 people that had been covering Unit 1 to a 5 staff of 135 people,to cover both units?
6 A No, it was more like in the neighborhood 7 of 155, 160 people, supporting both units.
8 Q As of what time?
9 A When we went to commercial operation on 10 Unit 2. .
11 Q I guess my question --
12 A There was an. increase in the numbers, and 13 you are asking me how many. I could tell you what I 14 have today just ~for one unit, but I don't ~ know at that 15 time. I know there was an increase in numbers because 16 I requested it.
17 Q I guess I am trying to get the magnitude of 18 that increase.
19 A I just gave it to you. It appeared to be 20 -15, 20 people.
21- Q First it was 10 to 15, now it's 15 to 20.
22- Between 10 and 20 people?
)
23 l
A There was a. total of 80 per unit. I What I.am trying-to get at, Mr..Shovlin, 24 Q 25 'is.this. ~When you arrived in 1973 and became supervisor
- u. _ __ _
1 Shovlin 168 2 of maintenance for Unit 1, you had a department under 3 you. Approximately how many people did you have in the 4 department? j
( 5 A 68.
6 Q That staff grew over the years, did it not?
7 A Yes.
8 By 1977 approximately how many people Q
t 9 did you have?
10 MR. GLASSMAN: Do you want a guess?
11 MR. WISE: I want a range.
12 ! A I don't know. 140.
O 13 Q Give or take a few, you had approximately 14 140 people?
15 A Yes.
t i
16 Q And at that time you had responsibility 17 for maintenance of Unit 1; is that correct?
18 A Yes.
I 19 Q And you did not have responsibility for 20 maintenance of Unit 2 at that time?
21 A Only to support some of the startup 22 functions.
23 Q =But basically that was a responsibility (j) 6 24 of GPU Service Corporation at the time?
25- A Right.
_ - _ - _ = _ _ _ _ _ _ _ -
1 Shovlin 469 O 2 Q Now, at some point your maintenance 3 department took on responsibility for covering Unit 4 2 as well as Unit J; is that correct?
k 5. A That's correct.
6 Q And that was at the time the unit went 7 commercial in late 19787 8 A That's correct.
9 Q And at that time you took on some additional 10 people; is that right?
11 A That's correct.
12 Q And your best recollection today is that
, \
13 that was about J 0 or 20 people?
14 A That's correct.
15 Q I believe you described earlier that Met 16 Ed was using an outside contractor to assist it in 17 performing maintenance work; is that correct?
18 A That is correct.
19 Q And you, I believe, named Catalytic as 20 the supplier of those outside maintenance services l
21 from 1977 on?
L 22 A That's correct.
23 Q It is correct,: isn't it, that during 4978,
,r a
(_s)\ 24 as a result of budgetary. restrictions, the amount of 25 outside contracting for maintenance work was cut back
1 Shovlin 170
(~h
(_f -
. 2 significantly, is it not?
3 MR. GLASSMAN: What do you mean by 4 significantly?
( 5 MR. WISE: It was cut back almost to nothing.
6 A No, that is not true. We.still had 7 contractor support during that time.
8 Q Was there a cutback in the amount of 9 support?
10 A There could have been a dedrease in numbers, 11 but there was -- we still had available those
- 12. contractors' support.
b(~g 13 Q Let me read you something that Gary 14 Miller stated after the accident, and this was during 15 his conversations with members of the task force ,
16 headed by Mr. Keaton of GPU Service. I am reading from 17 page 12 of the transcript that was prepared within 18 GPU Service of the conversation he had.
19 MR. GLASSMAN: Do you have a particular 20 date or document number on that?
-f 21 6 MR. WISE: Yes. This was marked as B&W
( l I
22 . '
Exhibit 360..
!i I' i
- 23 , Q Mr. Miller, at the bottom of page 12, i
(~)N
(_ 24 is esked the question -- actually at the middle of 25 the page, Mr. Williams asks him: "Take an item like
1 Shovlin J71 2 maintenance, did you take any time or did you have any 3 time left over to ever audit an area like that. At 4 least superficially to know whether maintenance was
[ 5 being done well or poorly or did you just not even 6; think of things like that?
7 " Miller: Well, one hard thought is that if 8 you look at January 1979 we had again for the second 9 year in a row, two new superintendents with us. We 10 had Seelinger coming to Unit 1 and Logan had just 11 started Unit 2. So I was involved in a lot of the
, 12 reviews where ve decided wh'at to cut out and from that O aspect I had a detailed review to make.
13 In the area 14 that I hadn't been able to get into was we had 1,000 15 to 800 open maintenance items work requests. I didn't 16 get into reviewing the priority of those."
17 Let me stop right there for a-second.
, 18 Were you aware in January of 1978 there 19 were between 800 and a thousand open maintenance 20 items at Three Mile Island Nuclear Stations?
1 21 A And wa have that today. That is the normal 22 thing. ; )
23 ,
Q It is normal to have about a thousand (D. ?
..(,) , 24 I Spen maintenance items?
25 A 800 to a thousand. You have a goal to
" e -> +y e e# .y -
2 m - -
y - , - -
1 shovlin 172 i
2 reduce-it but that's --
3 Q Mr. Williams continues with another 4 question. He said: "Did you ever think of why you 5 had 800 open maintenance items?"
6 Mr. Miller responded: " Yeah, I thought 7 of it. I didn't know how to proceed on it because the 8 answer kept coming up we need manpower. If you really 9 think about it we had shift maintenance but we only 10 really had -- we had two units worth a million dollars 11 and we had the ability to do one or two jobs on the 12 back shift."
(v~h 13 Continuing onto page 13, Mr. Miller 14 continued: "We just can't do it with the size of this 15 plant. You are just kidding yourself. You are going 16 to develop more work requests than you are going to 17 do, and at the same time we were cutting the contractor 18 out and we were going to try to. cut some of the budget 19 down."
20 Do you have any recollection of an attempt 21 being made in late 1978 or early 1979 to cut the budget 22 down and cut the contractor out? !
t i
23 ' 6 A There was a reduction in contractor work f)i
(. 24 force. I think the-inference presented that completely 25 there was no contractor work force on site, that was
1 Shovlin 173 c.
2 never true. Catalytic was still there, but I believe 3 their numbers were decreased and I don't know offhand 4 what their staffing was at that time.
( 5 Q Would you take a look at page 22 of the 6 transcript. Mr. Keaten at the middle of that page 7 asked a question to Mr. Miller. He said: "What was 8 the situation with respect to things like maintenance 9 budgets for the plant when it was in commercial 10 operation. Not when it was still under.GPU. Your 11 maintenance budget, of course, had big items in it gg 12 and those got reviewed by a lot of people including
()
13 me as a matter of fact but was there a.certain amount 14 of money that was set aside that was just for~ routine 4
15 non-defined maintenance?
16 " Miller: If you look at the routine way 17 we do business I don't believe we had the manpower to 18 do more than the priority ones. Don't ev n need to 19 talk about money. The only way you had of doing other 20 than priority one jobs was to contract and we were 21 beginning to limit that to zero. That was in fact 22 the way we were going. We had cut that back !
23 continuously."
h
(~/
\_ 24 Do you recall Mr. Miller's description of '
25 what was taking place in early 1979 as accurate?
i 1 Shovlin J74 o
2 A Yes, I think the thrust of what he has to 3 say is right, although 1 just can't recall the 4 contractor for us was completely down to zero. I 5 believe there was always a skeleton work force from 6 Catalytic on site.
7 Q Do you recall receiving instructions from 8
Mr. Miller or others to cut back on the amount that 9 you were using of contract maintenance?
10 A Yes. That has always been requested, to 11 do as much work in-house and to cut down on outside 12 contractors.
13 Q Mr. Miller continues on that page: "So I 14 don't, if you look at our manning itself you've got 15 30 instrument guys and you got two units. That's 15 16 guys a unit. If you take surveillance and we weren't 17 doing preventive ma'intenances when Unit 2'came along 18 we went from the 50 or 60 pere'ent preventive maintenance 19 performance in Unit 1 to almost zero. We did do tech.
20 specs surveillance. You threw that in there and you l l
21 can say there's 15 or 12 instrument techs and if you 22 put vacation and sick leave in you're going to find, ;
23 I;l I think, that you have maybe two or three people or l
(~'h ' '
km 24 four available to.do maintenance in the instrument 25 area. Okay. Therefore, you just think about the
I 1 Shovlin 175 m
2 fact that we had 1200 instruments or whatever the !
l 3 routine priority 1 maintenance you would have never 4 done that even."
( 5 Carrying over to page 23: "You had no 6 option. Your real challenge was to get priority 1 7 maintenance done."
8 I would like you to skip down on the 9 page. Mr. Wallace asked about the levels of manning 10 on Unit 1 in 1974, and Mr. Miller made the comment 11 at the bottom of the page as follows: "It had
- 12 increased but nowhere near -- I'd have to go back to 4
(%)%
13 the numbers but operations was staffed.I think 14 adequately at least as far as I could tell.
15 Maintenance was where the staffing problems were, and 16 we hadn't really increased our staffing in maintenance 17 very much beyond Unit 1's levels of maintenance. You 18 are talking a maintenance staff of roughly 40 19 mechanical people, probably 35 mechanics and 35 20 instruments, 24 electrical, serving two units and I 21 just couldn't believe you could serve two units with
{
22 that number of people and work and do a reasonable l 1
23 job without a contractor."
i
(~S s-) 24 Continuing over onto page 24: "The thing 25 .was really squeezing us before the accident, was L:
a 1 Shovlin 176 O 2 squeezing me, is the elimination of contractors.
3 We never did a major job in Met Ed. That's a fact.
4 Went out, the contractor did that job. We didn't
( 5 staff to do that kind of job."
6 Does my reading of this testimony help' 7 to refresh your recollection as to whether in early 8 1979 the maintenance department was not adequately 9l staffed to perform all of the maintenance tasks that 10 needed to be completed? '.
11 MR. GLASSMAN: Let me just scate that i
12 we ought to read in the rest of the transcript.
13 The portion which you read, Mr. Wise --
14 MR. WISE: You can read anything else you 15 want to. As a matter of fact, when this is over 16 you will get a chancs to ask him whatever 17 questions you want to. -
18 MR. GLASSMAN: I understand that, but 19 just in this particular area.
20 Can we hear theLlast word that he left 21 off on?
22 (Record read.)
23 MR. GLASSMAN: Immediately after that ,
,D
(_) 24 portion that Mr. Wise read there is an additional 25 amount of about ~ 14 or 15 lines within the same
~l l
l 1 Shovlin 177
(' '
2 quotation attributed to Mr. Miller in this 3 particular document, B&W 360.
4 MR. WISE: Do you want to read it all or l
( 5 should he answer the question?
6 MR. GLASSMAN: You don't'have to interrupt 7 me, Mr. Wise. I would just like to point out 8 that there is a discussion of various other D items relating to maintenance, and in particular 1
10 note that that particular paragraph that Mr.
L 11 Miller continues with the statement: "We s 12 didn't" --
e 13 MR. WISE: Now, wait a minute, Mr. Glassman, 14 j you are attempting to cut out. If you want to 15 complete the record, why don't you complete the 16 record, but let's not just pick one sentence 17 out and put that sentence in. -
18 MR. GLASSMAN: I am pointing out that you 19 read a particular portion of it and I am entitled 20 to note that it continues, in particular on 21 page 24 -- '
22 MR. WISE: I don't think it does continue l 23 ,
that way. -If you are going to continue with it,
/~T.
(_) 24 put it all in. If you want-to talk about some 25 other portion of this, you will have an
I Shovlin 178 1
2 opportunity to do that during the cross-
- 3 examination. If you want to fill out what I 4 read, I am perfectly happy to have you do that,
( 5 but I am not going to have you pick out some 6 other excerpt and put that in at this point. ,
7 If you want to read the whole thing, I am 8
perfectly happy to put the whrle thing in. l 9 MR. GLASSMAN: If you would like to read the 10 whole - p ortion o f- it , you may.
11 MR. WISE: I didn't want to do that.
12 MR. GLASSMAN: That is my problem. I O' 13 think if you are entitled to read part of it, 14 I can read the part that I think is relevant, 15 and in particular that Mr. Miller says here "we 16 didn't cut.any safety-related work out."
i 17 MR. WISE: Now I am going to read the 18 rest of it, if you insist upon it. I think it is 19 silly and it is something we'have not done with
~
20 the examinations you have taken of our witnesses.
, 21 At the end of the quotation that I' read, 22 Mr. Miller continues. He said, " Decay heat .!
1 23- :
, pump, we did that with the contractor and with !
t i
94
-the elimina tion of the . contractor from L the 25 budget your ability to do non-routine maintenance
, ,_,_... . . _ . . . . , . _ . -- . . _ . _ , , , _ . _ , _ . . _ _ . - . . . _ . - . _ _ . . -,_..m. _
1 Shovlin 179 O
~
2 was taken away."
3 Do you see that?
4 Then he makes the statement, "I am sure
( 5 that was felt below me."
6 Do you see that? We cut it and then there 7
is a blank. We arbitrarily say: Hey, we are 8
going to cut the blank down to this amount.
9 Do you see that?
10 MR. GLASSMAN: We see ever thing.
11 MR. WISE: Mr. Glissman didn't read those 12 comments.
13 '
MR. GLASSMAN: I don't see what significance 14 they have, Mr. Wise. I 15 MR. WISE: I think the signif,1cance is 16 that I don't mind your making objections and 17 making comments on the record where' you have 18 an opportunity to fill something out, but to
-19 present argument during the middle of my 1
20 examination I think is uncalled for. If you want 21 to read and fill out a particular statement in
(
22 the record, I have no objection to that. '
But 23 the proper way-to do that is to wait until it~
24 is your.. turn to examine. But I do object to
- 25 your obstructions and interrupting my examination i,
s .e.,, .,.,a. .
1 Shovlin 180
/m. ~
s, 2
by attempting to present what is obviously an 3 argument as to what you feel are other parts 4
of this particular statement by Mr. Miller.
( 5 You will have an opportunity to ask what questions 6 you want, but I think it is an abuse of the 7 rules to demand to put in a statement and then 8
pick out something arbitrarily from the middle 9
of the statement and not read the whole thing.
10 MR. GLASSMAN: I was responding to your 11 own conduct, Mr. Wise, g- IE MR. WISE: I read it from the beginning
%))
13 to the end of a portion in the statement 14 by Mr. Miller. It is a long statement and I 15 did .not intend to read it from beginning to end.
16 Certainly during the examination of B&W witnesses 17 your attorneys have felt free to que'stion our 18 people about statements in documents without 19 reading the document from the beginning to the 20 last word.
21 MR. GLASSMAN:
i You have done the same. ;
22 -BY MR. WISE: !
i 23 : g Well, in any event, let's go back-to the .
I
('T I
-(,) - .24 original question, Mr. Shovlin.
25 Does this help to refresh your recollection p .- . c. y.r._ ., _ , ,_g . _ ,
1 Shovlin 181 rv
- (]
2 that in early 1979 the maintenance staff at Met Ed 3 was not large enough to complete all of the maintenance 4 work requests that were being put in other than the
( 5 so-called priority 1 requests that Mr. Miller mentions?
6 A Mr. Wise, I was the main thrust behind 7 increase in personnel and the numbers that were 8 required in order to support a backlog of work.
9 Q By that you mean that more staffing was 10 needed to support the work?
11 MR. GLASSMAN: Will you let him finish J.h 12 the snswer.
- k 13 A Mr. Miller and I have discussed how would 14 he the best way to satisfy ourselves in reducing the 15 backlog so we went ahead and purified, looked, were 16 they real, were the thousand job tickets submitted, 17 were they all cut and dry or were there significant 18 problem areas that we should be looking i to, and we 19 did look and purify the job tickets or work requests.
20 So then we looked at -- it appeared that we were never 21 getting down below the 800 to a thousand, because 22 the input on a daily basis was the number that you -
j l 1 23 would correct on a daily basis, so if you had 50 coming .
r' I
/si (j I 24 in in a day and you were completing 50, of cour.,e you 25 had a negative gain.
1 Shovlin 182 r
i
(/ 2 Mr. Miller's --
I think, I am not sure, 3
the total numbers that he mentioned in hero are 4 totally correct, but they are close. And we have
( 5 increased, constantly increased, the numbers of people 6 on our staffing for both units.
7 Q But it is correct that as of early 1979 8 you believed additional staffing was necessary in 9 order to clean up.this backlog of maintenance work 10 ! requests?
gi A If we were going to reduce the numbers of g
12 our backlog, we would need additional people, but 13 we were still able to do the tech specs surveillance,s.
g4 I question Mr. Miller's =ero preventive maintenance, 15 I don't think it was that drastic, but there was a 16 reduction in preventive maintenance that we could 17 perform. .
18 Q Do you know whether any preventive 19 maintenance was being performed on the condensate 20 p lisher system before the acci' dent?
og A I have no idea.
22 Q Do y u know whether any preventive l
23 g !
maintenance was being performed'on the pilot operated l 24 l relief valve installed at TMI-2 before the accident?
25 A I have ne idea.
- . . - ~ .- - . ~ . - .-.. . - . .. - - - - . .
1 Shovlin 183
', 2 Q Do you know whether there was a preventive 4
3 maintenance procedure for the pilot operated relief 4 valve at TMI-2?
( 5 A I can't.tell you that.
. 6 Q Do you know whether there was any i 7 procedure for a regular inspection of that valve on 8 a periodic basis?
A' 9 I am not sure.
- 10 Q And you don't know whether any was actually 11 performed?
12 A No.
O,
- 13 Q Were thero records that were supposed to 14 be kept showing when preventive maintenance was 15 performed?
, 16 A I am not certain whether there was any 1
[ 17 preventive maintenance required at all fo'r a safety 18 valve other than required by tech specs that every 19 refueling you have to test 50 percent of your code
- 20 valves, and that was a requirement that we did, we i
f 21 e performed.
- -( !!
22 Q I think we established earlier that you 23 .never got Mr. Rogers' of B&W recommendation that-a '
! h)-
.1 N- -
24 preventive maintenance program be established for the I
25 valves.
. . _ . . _ . . _ _ _ . _ . . _ . - . . ~ . - . _ . . _ . . _ ._ _ _ . . - _. _. _ _.-, ._. ~ .
s
' . ,/
P#
g .
1 Shovlin . 184 2 A I said I was not certain about that.
-3 Q Did-it ever.come to your attention that
- 4 there was a problon regarding the amount of paper -
(
5 work that your maintenance foremen had to contend i
- 6 with during the performance of their jobs? ,
'~ '
7 A Yeis .
You learned ofIthatfhcfore the~ accident?
~
8 Q i
~
9 A Yes.
F % '
j 10 Q What was your understanding of-the-
/ .
j 11 situation? -
- t t
- j 12 A I increased oul. cl,erical staff.
I _
j 13. Q what was your understanding of the 4
3 14 problem ~with respect to the maintenance foremen? \
i l 15 A It reduced their amount of time that they 1 '.
q x .
j 16' could be'o'ut spending on t'ne? job rather than in the
=
- 17 . preparation for the job. -
- i. 18 Q Is it true that at..some.; point you did i
j- .. .
-19 a survey to deter,mine'how much of a maintenance r
20 foreman's time was spent on paper work? '
. ' ~
(V 21 'A We did a '#ork samplia study, yes.
22 Q When was that performed? ,
- i. ..
23 'i Sometime before-the accident. , J !
.n-
! -- 24
'Q; , --How long before the accident?- "
j 25 A' I can't say. A couple - of-ya.ars before f % >
,s.
.s u , ,=
' ~
[ ,
' , _ m(.,.1.. ' M._ _.
1 Shovlin 185 O
2 maybe. .
3 Q As a result of that, you found that the 4 maintenance foremen were spending over 80 percent of 5 their time on paper work, did you not?
6 A I don't know if those figures -- but it I was high.
8 Q Let me ask you to refer back to the 9 transcript of Mr. Miller's conversation with the 10 Keaten task force and look at page 13, reading from 11 his comment which begins at the top of the page and 12 going down to the fifth line from the bottom or the end 13
- of that comment. He says: "We did one simple survey 14 of a maintenance foreman and it told us that the guy 1
15 only spent 19 percent of his time supervising his 16 people. The other 70 or 80 percent was spent with 17 paper work. 20 percent of that was job r' elated, 60 18 perce% ci hi s work wasn ' t even related to the fact 19 - tht. ) as . .; , an I&P foreman."
-20 First of all, I&P would probably be 21 instrument and control. It is probably a typo.
22 A Typo.
23 MR. GLASSMAN: Are you asking'this witness !
'bi M 24 to testify whether that is a typo?
25 MR. WISE: I am asking him to testify if
_ ~ . _ _ _. _. , . - - , _ _,
l 1 Shovlin 186 l v
2 he had any section in the maintenance department 3 called I&P, and in fact if he did have a section 4 called I&C which in fact sounds very similar.
5 Q And it was an I&C foreman whose time was 6 evaluated in this survey?
7 A No, all classifications.
8 Q A11 foremen?
9 A Yes.
10 Q Do these figures correspond with your 11 recollection of the results of the survey?
_ 12 A I knew they were high but I don't
'd 13 know -- it looks g'o~od to me.
14 Q Are you familiar with a procedure or 15 the procedure generally for tagging instruments 16 in the control room at TMI-27 17 A I am familiar with a procedur~e for tagging, 18 not specifically for instruments in the control room.
19 Q My understanding is that the term " tagging" 20 refers to the situation where an operator will fill 21 out a tag of some sort and physically attach it to 22 an instrument or components to indicate that it is (
23 out of operation or malfunctioning in some way; is that .
24 correct?
25 A Yes, sir.
1 Shovlin 187 2 Q After an instrument was tagged by an 3 operator, what was your understanding as to what was 4 to be done in order to get the maintenance department C 5 aware of the situation and have corrective action taken?
6 A The first order of business would be, the 7 maintenance man would verify his tags.
8 Q What do you mean by that? I don't 9 unddrstand that.
10 A well, the operator went out.and tagged 11 certain valves closed so he could perform a maintenance r
12 function.
%)
13 Q So the operator could perform the 14 maintenance function?
15 A -So the maintenance man could perform the 16 maintenance function. So what he did was verify that 17 the tags.were put out --
to protect him in the 18 performance of his work,where actually the right 19 valves.were closed or open, whatever the case may be.
20 Q Let's take the control room, for instance, 21 the instruments in the control room. If an operator l~
22 j noticed that a particular instrument or control was
. L, u .
i
- 23 .not functioning properly or needed work, my understanding!
! \/ 24 is1he would fill out a tag and tag that switch or ,
25 . control..
I
i 1 Shovlin 188 G
2 A No. He would have to initiate a work 3 request.
4 Q Well, let me try to get at it this way.
C 5 I have read in the various reports following the 6 accident at Three Mile Island that a number of the 7 controls in the control room at Unit 2 on the day of 8 the accident had tags on them. I have heard that.
9 Are you aware that that was the case?
10 A After the accident I was aware of it.
- 11 Q Were you aware before the accident that s 12 it was a practice 5cr someone to put tags on various-N 13 instruments and controls in the control room at-Unit 2?
14 A Only if --
you know, if there was going to 15 be a maintenance function parformed in accordance with 16 a switching and tagging procedure. That is a normal 17 function. It is a requirement.
18 Q What would occasion the tagging of'an 19 instrument in the control room at Unit 2, as you 20 understood at, before the accident?
21 A They would want to calibrate it.
22 _Q Who would want to do that? Is that ,
23 ; something the operator would be requesting? ,
[h I 1
' '%) 24 A Anyone. It could be a foreman or it could 25 be the instrument man himself, or it could be a s , , ,- e-,e - -p 4 - v-n ,m ,q, ~-e e-- a-
1 Shovlin 189 2 surveillance _that we were conducting, a required .
3 surveillance.
4 Q And a tag would indicate what to someone
( 5 who saw it in the control room?
6 *A It would indicate the position of the 7 valve or whatever the isolation might be.
8 Q How long was the tag to remain on the 9 instrument or control?
10 A It all would depend on whai the problem 11 was.
3 12 Q We are not speaking about any particular 13 instrument or any particular control or any particular 14 procedure, but in general was the tag supposed to ho 15 removed at some point?
16 A When the action has been completed and
'17 the test satisfactorily tested, that the component 18 was satisfactorily tested. ,
19 Q Did it ever come to your attention before 20 the accident at TMI-2 in March 1979 that the operators
(%. 21 were having difficulty seeing all of the instruments 22 and indications in the control room because there i 23 were so many tags on the. control pancis that some of -I
\_/ 24 the instruments and dials and meters and whatnot were 25 obstructed by the tags? Did that ever come to your
1 Shovlin -190 l
\ /
2 attention before the accident?
k 3 A No.
4 Q Was that ever a concern that was raised
-( 5 before the accident?
- 6 A To me, no.
7 Q That there were too many tags in the O
control room?
9 A No.
10 Q Did you have any system fo keeping track 11 of how many instruments or controls were tagged in p- 12 the Unit 2 control room?
N/ 13 A ,There is a tagging out --
tagging and 14 switching log that operations maintains.
15 Q I guess what I-am driving at.is that 16 obviously you could have a situation where there are 17 no' tags in the control room at all becaus'e all the 18 instruments are fine and/or the instruments were 19 tagged or switched out. You could also have, I i 20 suppose, a situation in.which all the instruments 21 l were tagged so that nothing was operating. Now, I j 22 j understand that neither of those conditions prevailed 23 at TMI-2 in the control room. All.I am simply trying ks' - 24 to determine'is whether the. maintenance' department
=25 tried-to keep some handle on the number of instruments
1 Shovlin 191
\.s' .
2 or controls that had tags in the control room and 3 tried to keep it below some set number.
4 A No, that wouldn't be a concern of the
( 5 maintenance department.
, 6 Q That would not be a concern of the 7 maintenance department?
8 A No, that was a normal work function, to 9 go and tag out a particular piece of equipment, for 10 whatever reason it may be, and there w$s no piece 11 of equipment that was not tagged out that brought 12 about a condition that violated.a tech spec.
(
13 Q But I mean, was there*some limit on the 14 number of instruments or controls that could be tagged 15 out at any one time in the control room?
16 A There could be a tech spec requirement 17 saying: here is the instrument that must-be in service 18 during a certain operating mode, and othe than that, 19 no.
20 (Recess taken.) i I
I l
21 BY MR. WISE: ,
22 Q A little bit earlier this afternoon, Mr. ,
23 Shovlin, I asked you about your awareness of an event l
(~/N
(, 24 in 1977 during the fall at Unit 2 when there was a 25 problem with the condensate polishing system. I
l 1 Shovlin 192 '
2 believe you did not recall that event.
3 I would like to show you B&W Exhibit 165, 4 which is a copy of a GPU startup problem report that
( 5 has been filled out.in hand, or by hand. It bears 6 dates signed at different times between November 3rd
] 7 and November 17, 1977.
8 Do you recall seeing this problem report?
9 A No.
10 Q Attached to it is a copy ob a typed 11 three-page memorandum dated November 14, 1977, from 12 Messrs. Brummer and Ross, addressed to Mr. Miller and 13 Mr. Seelinger, concerning the problems.in the 14 condensate polishing system identified as a result of 15 an event on October 19, 1977.
16 Do you remember seeing a copy of the 17 typed memorandum? ~
18 A No.
19 Q You will note that you are listed as one
.20 of the recipients of a carbon copy.
21 A Yes.
22 Q Mr. Brummer worked for you?
23 , A No.
n/
-(- .24' Q Did the. instrument and control section work 25 for you?
e =-w < w - n mr n y-- r , -
v - n-- - - - -
g
1 Shovlin 193
(~
%d i 2 A Yes.
3 Q Was Mr. Brummer a control and instrument 4 engineer?
( 5 A Yes.
6 Q Could you explain why it was he did not 7 work for you?
8 A Mr. Brummer worked for plant engineering.
9 Q They had their own instrument and control I
10 section?
11 A That's correct.
~
12 Q And that was separate and distinct from the d
13 instrument and control section that was under you?
14 A That's correct.
15 Q Did the maintenance department at Three 16 Mile Island have any responsibility with respect to 17 radiation monitoring, that is, the radiation monitors?
18 A Yes.
19 Q And was it the responsibility of the 20 maintenance department to calibrate those monitors?
21 A Yes, to --
yes, surveillance.
22 Q And to conduct surveillance?
I 23 A Yes.
/~~
m 24 Q To make sure they were in operating 25 condition?
j ^.3 1 Shovlin 194
/ '
t C'
2 A That was part of it, yes.
3 Q Was it part of the maintenance department's 4 responsibility to perform any maintenance that was
( 5 required with respect to those monitors? >
t 6 A If it was identified, yes.
7 Q Was there any periodic surveillance done 8 on the radiation monitors by the maintenance department, 9 to your knowledge?
10 A Yes.
11'- Q Did it ever come to your attention that 12 there was a radiation monitor in the containment x) 13 building located near the letdown system, letdown 14 piping?
~
15 A I don't know what you're --
IG Q Have you ever heard of the so-called 17 1029 monitor? -
18 A No.
19 Q Did it ever come to your attention before th'e. accident that the radiation monitor which was 20
- 21. located ~in-the area of the letdown piping was 22 constantly in alert? l 23 A No.
(~S'
_ (_)- 24 Q Did you ever see a work request that had 25 been submitted before the accident to have-the letdown e
--e-- -
33 % - .yyy-* g -yw w .p3*- .g ,-.g. y y .9 m,f-m ==mr vr m ry,q--g p T7v.
1 Shovlin 195 2 system radiation monitor moved? -
3 A No.
4 Q Did you know before the accident that
( 5 there was a radiation monitor for, I believe, Iodine 6 gas in :.he containment building?
i d A Yes.
l 8 Q Are you familiar with the so-called 227 9 monitor?
10 A No. '.
11 Q You are not familiar with any of the l
(~ 12 particular monitors, I take it?
13 A. Not by the numbers that you are coming 14 out with.
15 Q Did it ever come to your attention before 16 the accident that there was a problem with water {
17 collecting in the radiation monitors inside the 18 containment building?
19 A No.
20 Q You never heard of that condition existing?
21 A No. !
l (c :
22 Q No one breaght that to your attention?
23 A I don't recall.
(
'- 24
\'
Q Now, Mr. Shovlin, I don't mean this to be 25 a facetious question, I am just trying to understand
1 Shovlin 196 h
.w' 2 what your position was within the organization and 3 what your responsibilities were. Did anybody bring 4 any problems, maintenance problems, to your attention 5 before the accident.at TMI-2 in March 1979 on Unit 2?
6 MR. GLASSMAN: In what time frame?
7 Q At any time frame before March 1979.
8 A The significant items were handled by the 9 supervisor of' maintenance on the unit.
10 Q I have asked you about the condensate 11 polishing system malfunctioning, and you said you gg
> 4 12 didn't remember that. I have asked you about the GI 13 radiation monitoring systems, and I have asked you 14 about the leakage past the pressuri=er relief valves 15 and the discharge from them, and you don't remember anythins 16 about that coming to your attention. I might say that 17 after the accident there has been quite a good deal 18 of investigation about various things and those three 19 problems have all been identified as things which 20 occurred before the accident and which were ongoing 21 problems. ':e n e of those things came to your attention 22 I before the accident. ;
23 MR. GLASSMAN: I object to that. The .
h
(~/
(_ 24 witness has given testimony as to where some 25 aspects of these items may have come to his
~. . _ _ _ - . _ _.- _
l l
4 1 Shovlin 197
.b 2 attention. The implication here is that 3 some weren't.
4 Q The question is: is it true that none of
( 5 the specific items that I just mentioned came to your 6 attention before the accident?
7 A 'On the time frames that you are asking me
.8 to recall, no. They could have --
I could have been 9 involved in several of the problems, but I don't recall 10 or remember specifics about them. Yes[.we had 11 leakage of the pressurizer valves. When, in the time gs 12 frames and the particular and specific problem, five, t I
%)
13 six, seven years ago, no, I don't remember it.
14 Q I don't mean to limit my questions to just i
15 some specific date during 1979, but I think that my ,
4 16 questions throughout the day have generally related 17 to your awareness of a problem with this system or that 18 before the accident.
19 MR. GLASSMAN: That was precisely the 20 nautre of my objection before, Mr. Wise, because 21' you seem to be generalizing in your statements 22 and we have spent all day going over various !
23 problems and at various points in time and at
. %.fD/ 24 various units, and the witness has given you 25 testimony with regard to some time frames, and
1 Shovlin 198
('N v i i
2 others he didn't have a recollection.
3 MR. WISE: Well, I thought I asked a 4 rather broad question, but in case it wasn't
'( 5 as broad as I thought it was or in case you 6 seem to think, as you apparently do, that my 7 question was more narrow, let's just make sure.
8 Q Are you able to recall today at any time ,
9 before March 28, 1979 being aware of leakage past the 10 pressurizer. relief valves at TMI-27 -
11 A No.
12 Q -And that is without. regard to any specific 13
. time period or anything else?
14 A No. Right.
15 Q That just never came to your, attention?
16 A I am telling you right now, no.
17 Q Now, I asked you before about'an incident 18 at TMI-2 in which the condensate polisher system' 19 malfunctioned, one of them.I believe occurred in the 20 fall of 1977, in fact on October 19, 1977, and 21 another one in May 1977. Now, putting aside that-you
'22 may not remember --
23 MR. GLASSMAN: 19787
.- hV 24 MR. WISE: 1978. May 1978 is the incident 25 y am referring to.
1 l
1 Shovlin 199
~
V(~%
2 MR. GLASSMAN: The witness said he didn't 4
3 recall that particular incident.
4 MR. WISE: That is the one Mr.Zewe 5 wrote in his now famous memo concerning a 6 serious problem.
7 MR. GLASSMAN: I would take issue with 8 what counsel is saying. I don't know what you 9 are referring to now, and it is nice to have you 10 attempt to testify, Mr. Wise, bubwe are here to 11 get testimony.
N 12 MR. WISE: Mr. Seltzer has repeatedly J
13 referred to Mr. Dunn's famous memorandum. I 14 suppose I am learning some bad habits.
15 MR. GLASSMAN: I think the reason you have 16 a smile on your face is that you are well aware 17 there is a particular significance to the Dunn 18 memorandum.
, 19 MR. WISE: I understand that plaintiffs 20 feel that way. Before this case is over, the 21 Zewe memorandum may attain the same
{
- 22 notoriety that until now it has not gotten i I
23 because plaintiffs have done an extremely good '
O.-
k 24 job of hiding the ball'with respect to those 25 pieces of paper.
1 Shovlin 200 I
v '
2 MR. GLASSMAN: I notice you still do have 3 a smirk on your face, and I do feel that is 4 totally inappropriate.
( 5 MR. WISE: Let's continue with the 6 questioning.
7 BY'MR. WISE:
8 Q I just want to make sure that you have not 9 misinterpreted my earlier questions.
10 It is true, isn't it, that'.you did not 11 become aware of the events that I have mentioned, the
- g. 12 fall 1977 and spring 1978 problems with the condensate
(,) ~
13 polisher system?
14 A The problems that you identified were i
15 problems that were a part of the startup of the unit, ,
, 16 and I noted you took excerpts from the startup log 17 sheet which I've never seen. Those probl' ems could 18 have been handled and therefore -- over a year,. year 19 and a half, I would have no knowledge of them. They 20 would be handled by the construction arm of'-- so yes, 21 there cre many things that happened that I wasn't 22 aware of because I had no need to be aware of them. ;
23 Q And just so that we are sure on this,
()
(_/ 24 with respect to radiation monitoring systems at TMI-2
- 25. before the accident, you cannot today recall'any
. , , , + - , - - , y - w _ .m, -
1 Shovlin 201 t"
- O) 2 instance where someone came to you and told you 3 before the March 1979 accident that there was a 4 problem with the radiation monitoring systems at
(
t 5 TMI-27 4
6 A That's correct.
7 MR. WISE: That is all I have.
8 EXAMINATION BY MR. GLASSMAN:
9 Q Mr. Shovlin, do you recall that earlier 10 today Mr. Wise asked you with respect do an April 23, 11 1978 incident, whether you had heard that operators 12 had been confused by the number of alarms and that 71-
\,
13 yea answered to the effect that you did not recall d
14 that about an April 1978 incident but that you had 15 heard operators were confused by the number of alarms 16 after the March 1979 accident? Do you recall that 17 question and that answer? -
. 18 A Yes.
19 From what source had'you hear Q that 20 operators were confused by the number of alarms 21 after the March 1979 accident?
22 A News releases, various news releases. ;
23 Q .Did you ever discuss that matter with any l
f~T s) 24 members of the operating staff?
i 25 A No.
.. . . - . , - _ . . . . , - - - - . - . . , _ . - . . . _ - . _ - . . . . . . - ~ - - .
1 Shovlin 202 2 -Q Did you ever discuss'that with anybody 3 alse?
4 'A No.
5 MR. GLASSMAN: I have no further questions.
6 MR. WISE: Thank you very much for coming i
l 7- in. '
i 8 (Time noted: 5:00 p.m.)
l 9 -
j l
10 '
11 -
l Daniel Shovlin i
12 13 Subscribed and sworn to before .
14 me this day of 1982.
15 16 17 -
18 19 20 91
~
22 i 23 0~ 24 25 i,.. . ..
1 2O g g 3 I I F,_ I E A._ E g 3 STATE '0F NEW YORK )
- ss.:
4 COUNTY OF NEW YORK')
0 6 NANCY A. RE M I, ,a I
Notary Public within and for'the State.of New York, 8
do -hereby certify that the foregoing deposition 9 of DANIEL SHOVLIN was taken before 10 me on July J 6, J 982 ;
. 11 That the said witness was duly sworn 12 before the co:::mencement 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 1G 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 day of vN / 9<Pd g
/-
22
. i
~
23 t
Q
%) . 24 7%~ ()< /S M f/ .J d
Nancy / A. Rudolph 25 l
,- , ,. - , - . -. , . . =, . , . . - . -. . .-. ....--- _
204
.O I N DEX WITNESS PAGE
- Daniel Shovlin 3 o
l E XHI BI TS B&W FOR -
IDENTIFICATION U
897 Resume of Daniel M. Shovlin 3 898 Document consisting of excerpts
]) from TMI-1 log e- 16 899 One-page document on letterhead of Metropolitan Edison Company, subject: Change Modification,
- . undated 114 900 One-page document entitled
" Minor QC Modification Approval
, Form" .. 117 e
901 Seven-page form headed "
C/M Design Checklist" .. 120 902 Copy of two-page memorandum dated March 12, 1976 126 4
L I
~
l l
a *
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